RESPONSE TO OWENTS
ENVIRONMENTAL If PACT STATEMENT
PROPOSED ISSUANCE OF
PERMITS TO
THE PITTSTON COMPANY OF NEW YORK
FOR THE CONSTRUCTION OF A
250., 000 BARRElVDAY OlL REFINERY
AND MARINE TERMINAL— EASTPORT, MAINE
BYS
REGION I/ BOSTON, MA 02203
-------
INTRODUCT ION
Volume IV contains responses to comments on the DEIS received from
Federal, State and local agencies and from the public sector. Due to
the large number of comments, this volume has been divided Into two parts.
Part A contains those comments from Federal, State, and local agencies
as well as comments from the public sector that require specific responses.
All comments are answered either in a block on the appropriate letter or
on separate pages immediately following the letter. In addition, text
changes have also been made in Vo lume II of the FEIS, particularly in the
areas of soclo—economics, air resources, and marine biology/oil spills.
Also, Volume II contains a new Chapter X which includes responses to the
most characteristic coimnents that were received. Consequently, the first
part of this volume includes a response index which assigns a comment!
response number as well as indicates where in Volume II information can be
found with respect to a given agency’s or individual’s comments. All pages
in this volume are numbered in a format which indicates the comment!
response number. For example, p. 5—11 would be the eleventh page under
comment/response 5.
The index also includes a key to the type of comments received, as
follows:
SE — Socio—Economic
ME - Marine Ecology
FR — Fisheries Resources
HN - Hydrography and Navigation
AR — Air Resources
A - Alternatives
0 - Other
Part B contains comments received from the public sector that tend to
express general opinions on the project and therefore require no specific
response. The first section of Part B includes an index of comments with
numbers designed in a similar fashion as in Part A.
1
-------
Index of Responses
2.
VI—28ff,
3. W.G. Gordon 1 U.S. Nat.
Marine Fisheries Serv .
ME: Comment noted.
4, F.S.M. Hodsoll , U.S. Dept.
of Commerce
0: Comment noted
5. G. Liii , Nati. Ocean Survey
HN: X—31
6. R.E. ?hilpott, U.S. FEA
0: Comment noted
7. J.L. Reed, U.S. FEA
0: Comment noted
8. R.W. Mitchell, U.S. FEA
0: IV—1f
15. DR. King , U.S. Dept.
of State
0: Comment noted
16, K, .lonietz, U.S. Dept.
of State
0: Comment noted
17. S. Je11inek Council on
Envli’onmenfal Quail ty
X— 1 42ff
HN: VI—36, X—26ff
ME:. IV—38ff, X—5ff,
SE: VI—lf’f, X—3
o : 1—3
1. R.F. Elden. U.S. Coast
Guard
A: X_L2
HN: VI—36, X—26ff, 11—5,
IV—38
SE: VI— 1 ff, X—l3ff
0: 111—50, 111—52, IV—53,
VI —29
ME: IV- . 1 43, VI—38, VI—59,
X— 21
AR: VI —73
10. A.W. DiSilvestre, U.S.
Sec. of the Treasury
0: Conunent noted
11. R.I. Chals, U.S. ICC
SE: X—14
12. C.S. Buchanon, U.S. HUD,
Region I
SE: VI—l 1 lff, X—6ff
13. H.D. Woon, U .S. Fish &
‘ Wildlife Service
ME: Comment noted
1 $. S.S. Doremus, U.S. Dept.
of Interior
HN: X—26ff
ME: VI—38ff,
VI—59ff
0: X—35, X— 1 l1, X— 35
S.R. Ga1ier U.S. Dept.
of Commerce
ME: 111—70, IX—38, XI—38,
X—5, VI—59, VI—38fT
0:
X— 1 49, 111—166
SE:
VI— 2 4ff
FR:
111—87, VI—28ff
RN:
X—26ff.
A:
X— 42ff
VI—38ff
9. H.W. Stevens,, Roose-
velt Campobello IPC
ME: IV—38
HN: VI.-36
AR: VI—91, VI—78, VI—63,
vI 6 4, X—37
18..R. Garver, J. Chandler
Corps of EñTginéer s
ME: VI—38ff, IV—38ff, VI—59ff,
X-5ff
HN: VI—36, X—26ff
SE: X—14, VI—iff
o : X-. 41, III—159ff
19. J.D. McDermott, Advisory
Council on Historic Preservatioh
0: X- 1 41
ii
-------
20. Passaznaguoddy Tribe,
Perry, NE
SE: VI—iff, IV—lff,
III —159
21. M.F. Marsh, Maine Dept.
of Inland Fisheries &
Wildlife
ME: Comment noted
22. Maine Land & Water
Resources Council
o : X— 1 47
SE:
VI—lO, X—2ff, VI—l 1 Iff,
X—7f’f, vI—l8ff, VI—2 1 4ff,
X—13, VI—liff
0 : 111—159, X—l0, VI—20, X—10
HN: X—26ff
A : X— 1 42ff
23. R.A. Giffen, Maine State
Planning Office
O : 111—166
214. M. Barnes, Eastport
City Council
SE: Comment noted
25. E. Baxter, Eastport
Planning Board
SE: Comment noted
26. B. Blanch, Eastport
Planning Board
SE: Comment noted
27. W. Harding, Eastport
Police Dept .
SE: Comment noted
28. R. Flagg, Eastport
Fire Dept .
SE: Comment noted
29. M. Conti, Eastport
Fire Dept.
SE: Comment noted
30. R. Maholland, Eastport
Law Enforcement
SE: Comment noted
31. E.J. Barnes, Office
of’ Town Mgr., Lubec
SE: Comment noted
32. E.J. Boone, Town of
St. Andrews, N.B .
SE: Cbmment noted
33. R.J. Ryan, Calais Econ.
Development Board
SE: Comment nôbed
311. A. Bates, Calais Eco
Development Board
SE: Comment noted
35. E.G. McKeon Bangor
Dept. of Development
SE: Comment noted
R.G.
Wolfe, Terre Haut
e,
IN
ME:
VI—28f1’
0:
111—159, x—49
AR:
VI—62ff
P.S.
Mathews, Aliston,
MA
0:
IV—2
SE:
VI—2f ’f, X—2ff
36. F.H. Morell, S .Portland ,
ME
SE: X—2, VI—2
ME: VI —28ff, IV—38ff
37. A.J. West, Cobscook Bay
Laboratory, Boston
ME: VI—28ff, VI—59ff
38. K. Good, Dennysvllle, ME
AR: VI—78f1
ME: IV—38ff
39. J.E. Chappell, North-
eastern Univ., Boston
0: 111—159
HN: X—26ff
ME: IV—38ff, VI—25
SE: VI—iff, X—2ff
40.
141.
iii
-------
0: See comments by
M. McGleannon in
Vol. IV
RN:
0:
SE:
oceanographer
FR: III—öl
MN: X—26ff
AR: VI—9lff,
0: IV—52
ME: IV—38ff,
A: X— 1 42ff
X- 9
AR: VI—62ff
0: III—159ff
56. S.K. Katona, College
of the Atlantic, ME
57. H. Stence, Lubec, ME
AR: VI—78ff
0: X—149
SE: VI—iff, VI—liff
ME: VI-28ff
VI—28ff
51. J. Dorchester, Lubec, ME
0: Comment noted
52. C.A. Lewis, For the
Love of Eastport
ME: IV—3BfT, III—]O7ff
0: 111—69, IV—531f
MN: X—26ff
SE: V—i, VI—liff, X-9
AR: VI-22ff
53. P. Glasser Univ. of Maine
142. A&E. Webb, Winterport , ME
SE: IV —53ff, X—9
AR: VI—78ff
413. D. Walker, Sunbury Shores
Arts & Nature Center
ME: IV—38ff
AR: vI—78ff
1414. M. Hodgins, Trescott, ME
AR: VI—78ff
MN: IV—23ff, X—26ff
145. C. Sunde Trescott, ME
AR: VI—7 ff, IV-.6Off ,
X.37
146. S . Lehigh L Colby College,
Waterville
SE: X—ll, Vi—20
ME’ IV—38
147 D. Hodgins, Eastport, ME
AR: VI—78ff, VI—62ff
48. D. Dowley, Quoddy Bay
Fish CoOp 1 Eastport
Iv—6ofr, X—37
VI—28ff
514. R. Jones, Eastport, ME
SE: VI—20, X—].O, I11 53,
55. J. St.rogen, Lubec, ME
AR: VI—78ff
FR: III—t 7
0: 111—159
ME: VI—28ff, VI —56ff,
III—l o9ff
‘49. C. Herter, Council of
Maine
A: X—142ff
ME: IV—3 ff, VI—38ff,
VI—28ff
X—26ff
111—159, 111—166
VI—iff, X—3, VI—18f1,
VI—l 4 iff, VI—22
50. A MacKay, Rep. Bay of
Fundy Weir Fisherman’s
Association
ME: VI—28ff, X—l5ff,
X-23ff, see response
by Dr. Edward Gel—
fillan, consulting
58. E.&R. Coakley , W. Fern—
broke, ME
ME: V1—38ff,
SE: VI—lff
HN: IV—23ff, X—26ff
0: 111—159
lv
-------
59. J.E. Sullivan 1 Kearney ,
68. A. Ruffman, Halifax 1
NJ
AR: VI—78
60. G. Fatula, Cherry Lane
Farm, ME
SE: Comments noted
61. R.L. Dow, Augusta, ME
ME: VI—2Bff, IV—381f,
VI—38ff, VI-.53ff
AR: X—37ff
FR: X 2Z4ff
0: III—159ff
RN: X—26ff
SE: VI—9
62. R.T. Stagg, Setauket ,
NY
0: 159ff
63. J.A. Donaghy, Lubec ,ME
ME: VI—29ff
0: III—159ff, X— 47
FR: X—24
SE: VI_Z4ff
614. G.B. Carter, Calais ,
IV—lff, III—159ff,
VI—27ff
VI—2ff, VI—].ff, VI—9
VI—59ff, VI—29f I
VI—36
65. L. Elerin, Eastport ,
ME
0: III—159ff
ME: IV—38ff
6 . J. Rier, Lubec, ME
SE; VI_llff, VI—29ff
67. J. Sassarnan, Sanford ,
ME
0:
X— 1 49, X— 47, III—159ff,
‘v—i c r
RN: VI—36, X—26ff
SE: VI—20, X—ll
N.S .
HN: X—26f1
ME: VI—281f
69. M.H. Boyer , Boston ,
MA
f : VI—28ff, IV.-38ff
0: V—llff
70. Stagg, Port Jefferson,
New York
SE: IV—145, VI—19, X—9
0: Vol. III, A—5lff
ME: VI-28.ff
71. J.H. Hutchison,
Eastport, ME
SE: IV— 1 43ff, X—g
HN: VI—36, X—26ff
AR: vI—i8ff
72. B. Cecirr , Eastport ,
ME
HN: X—26ff
73. N. OtisL Perry, ME
SE: VI—20, X—1l
74. J.H. Buehner, Lubec 1
ME
ME: VI—28ft, IX—38ff
SE: X-5
75. J.P. Grady, Eastport ,
ME
RN: IX—23ff, X—2611
ME: VI—59ff
76. R.J. Smith Camden ,
ME
0: 111—15911
0:
SE
ME:
HN:
V
-------
77. FA. Eustis II, Sec.
Plan. Bd., Isle au
Haut, ME
ME: VI—28ff, IV—38ff
A: X— 1 42ff
0: IV—lff
78. G. Lehigh, Eastport ,
ME
SE: VI—22, VI—1 1 ff
79. M.J. Cohen, Lubec, ME
ME: VI—28ff
0: X- 1 fl.
80. K.A. Lewis, Eastport ,
ME
SE: VI—l
81. R. Klyver, Eastport ,
ME
HN: X—26ff, VI—36
82. R. Molyneaux, Nati.
Parks & Conservation
Association
0: X- 47
A: V—l2ff
AR: VI—62ff
ME: VI—59ff
HN: X—26ff
83. K. Larson, E. Machias ,
ME
ME: VI—28ff
8 . B. Cunningham, Lincoln ,
MA
ME: IV—38ff
SE: X—5
85. S. Bahrt, Pembroke ,
ME
SE: IV—53fr, X—9
86. S. Riggs, Robinson ,
87. S. Lambert, Deer Island,
N.B., Canada
HN: VI—36, X—26ff
ME: VI—28ff
88. M.B. Myers, Eastport ,
ME
0: III—159ff
SE: IV—53ff, X—9
89. W.H. Drury, Bar Harbor ,
ME
ME: VI—28ff, IX—38ff
SE: VI— 1 4, VI—5
90. D. Pike Lubec, ME
AR: VI— 2ff
91. Transport Canada,
Canada
ME: VI—38ff, III—3lff,
Ill—loft, IV—38ff,
Iv—28, ITI—28
AR: VI—62, III—12 1 ff
HN: IX-.23ff
SE: VI—iff
A: X— 1 42ff
92. L. Dale Barteau, Deer
Island, N.B., Canada
HN: IV—23ff, X—26ff
93. E.H. Latham, Ellsworth ,
ME
: IV—27ff, IV—38ff
914. S. McDu o1d, Eastport, NE
HN: X-26ff
ME: VI- .28ff
f4 E
SE: X —5
vi
-------
Ite ml Source
No. Name or Affiliation
Issues Raised
SE IME FR [ }I+N tAR A_ O
The response to all the following was “Comment noted.”
— — — — —
95 B. Barnes, Eastport, fE X
96 P.P. Thornton, Neil, Inc. Scarborough, ME
97 IR.W. & M.E. Clement, Eastport, ME
98 !J.G. Haynes, soc. Gen. Contractors, Augusta, M X
99 W.L. Wilson, Calais, ME
100 JW.R. Flagg, Furniture, Eastport,ME X
101 G. Jackson, bangor, ME
102 ‘L.V. Smith, Jonesport, ME X
103 S.C . Shaw, Williston, VT
104 1 J. McGrath, & L. Levesque, Statler Tissue,
Augusta, ME
105 T.M. Armstrong, Biddeford, ME X X
106 E.W. Thurlow, Cent. Me. Power Co., Augusta, ME
107 H.C. Brill, Lincolnville Telephone Co., ME X
108 V.iB. Rupert, Blue Hill, ME
109 H.L. Vose, Eastport, ME X
110 M.L.& C.M. Small, Eastport, ME x
111 K. Cline, Eastport, ME X
112 J.F. Jaffray, Jr. Pittsfield, 1 E X
113 J.K. Keefe, Econ. Res. Assoc., Waterville, NE X
114 J.P. Kelley, Jr., Rotary Club, Calais, ME X
115 A.L. Moore, Waterville Savings Bank, Me X
116 E.M. Holmes, Winterport, ME
117 JM.P. Foley, Eastport, NE X
118 G. Peters, Jr., Eastport Water Co., ME X
119 IM.F. Norton, Yarmouth, ME X
120 M. Davis, Fredericton, N.B. X X
121 IM.C. Wells, Jr.., Assoc. Industries of Maine, X
Augusta, ME
l22 !L.B. Hoxie, Eastport, ME
123 R.S. Jones, Eastport, ME
124 R.M. Stolkner, Insurance Rep., Bangor, ME X
125 L.M. Thrnckniorton, Cutler, ME X
126 IJ.G. Dudle, Alexander, ME
12 C. Weeks, Eliot, ME
12 h 1 • Stence, Lubec, ME
129 Mr. & Mrs. A. Townsend, Sr , Eastport, ME X
j130 M. Taylor, Eastport, ME
131 G. Ganong, Pembroke, ME X
,132 G.L. Cole, Cole Express, Bangor, ME X
1133 R.W. Lyon, Eastport, 1E
134 L.W. Guetersloh, Pine Plaines, New York
t135 J. Collins, Eastport, ME
vii
-------
- -
Item
No.
I
[
Source
Name or Affiliation
Issues Raised
H+N i
r
.
136 A.M. Roth, University of New Brunswick, Freder— X X X
icton, N.E.
137 IC. Bevers, Trescott, Maine x x
138 F.F. Jones, Lubec, ME x x x x
139 C. Goddard, Eastport, ME x x x
140 Mr. Donaghy, Lubec, NE X X X X
141 R. Ross, Superintendnet of Schools, Easport, NE X
142 J. Dorchester, Crows Neck, ME x x X X x
143 E.P. Kroonenberger, Brookline, MA x
144 A.J. Raug, Eastport, ME x
145 N. Sunde, Lubec, ME x x
146 A. Harris, Candidate for Council, Eastport,ME X
147 Dr. H. Eda, Stevens Inst. of Tech., Hoboken, N.J X X
148 D.P. Hoult, M.I.T., Cambridge, MA X
149 E. Gilfillan, Bidgelow Laboratory for Ocean x x
Sciences, West Boothbay, ME a
150 A.H. Fenlason, Rep.Dist. 10, Maine St. Leg. X
151 J.C.Bates, Physician, Eastport, ME X
152 H. Richardson, Eastport Mem. Hosp., Eastport, ME X
153 ‘G. Marshall, Maine Maritime Academy, Castine, ME X
154 W.C.Bullock, Jr., Merril Trust Co., Bangor, ME X
155 W. Thomas, Canal National Bank, Sauth Freeport,MJ X
156 iN. Cohen., Coy. Ezec. Council, Eastport, ME X
157 ‘Capt. D. Kennedy, VLCC Pilot, Belfast, ME
158 P. Merril, Nerril Transport Co., Portland, ME X
159 C.M. Neily, Economic Resources Council of Maine X
160 H. Loring, Construction & Bldg. Trades Council X
161 RH.Reny/P.C. Emerson, Maine State Chamber of X
Commerce, Portland, ME
162 1 B. Cram, Natioanl Executive Reserve, Bangor, ME X
163 1 N. Davis, J Lachiasport, ME X
164 IDr. J. Co-nmjto, U. of Maine, Hachias, ME X X X
165 tJ. Yerxa, Sam Ely Comm. Services, Inc., South X X X
Princeton, ME
166 CC. Arsenault, Eastport Main. Hosp., Eastport, NE X
167 M.C. Ie1ies, Jr. Assoc. md. of lIE, Eastport, NE X
168 R.N. Haskell, Bangor Hydro—Elec. Co., Bangor, NE X
169 A.M. Johnson, The Action Committee of 50, Bangor X
170 W.N. Haselton, Depositors Trust Co., Augusta, ME X
171 M. Hodgins, Lubec, ME X X X
172 R.M. Smith, Bath Iron WoPks Corp., Bath, ME X
173 IJicConchie, Owls head, NE X X
174 B.L. Peters, Maine Central HR Co., Portland, NE
175 L.V. Smith, Pres Wash. Co. Chamber of Commerce, X
Jonesport, 1E
viii
-------
Source _______ Issues Raised
Name or Affiliation SEjME FR H+N
176 D. Bradshaw, .Dennsyville, ME X X
177 B.J. Smith, Camden, NE x x
178 H.R. Keezer, Eastport, ME
179 L. Conti, & Co—signers, Eastport, ME
180 H.S. Stanton, Guilford Industries, Eastport, ME X
181 D.F. Turner, Mean Corp., Eastport, ME
182 A.P. May, Pembroke, ME X X X
183 H. Conti, Eastport, NE
184 P. Leighton, Eastport, ME
185 C.M. Small, Eastport, ME X
186 R. Emery, Eastport, NE X
187 D.L. Brooks, Friends of Intelligent Land Use,
Kennebunkport, ME
188 D. Cohen, Lubec, ME X X
189 E. Blackinore, Pres. Maine Lobsterman’s Assoc.,
Stonlngton, lIE X X
190 F. Trocco, Lubec, ME X X X X
191 K.J. Leighton, Eastport, ME
192 3. Lehigh, Eastport, ME
193 B. Nagusky—Trocco, Lubec, ME X X
194 R.J. Shinners, Great Northern Paper, Millinocket X
195 J.E. Chappel, Northeastern Univ., Boston, ME
196 Coimnent No. 265
197 Doc and II. Hodgins, Trescott, X X
198 R.& D.Csenge, Perry, ME X X
199 M.M. Kearney, New Sharon, bIE
200 Con inent No. 270
201 (N. Standen, Eastport, ME X X
202 1 B. Esler, Foxcraft, ME
203 P. Robinson, Brooksville, NE
204 P. & N. Birdsall, Blue Hill, HE X X
205 R.S. Jones, Eastport, ME X
206 R.L. Grindal, Bangor, ME
207 C.W. Brown, Nonson, lIE
208 I.J. Donaghy, Lubec, ME X X
209 E.E. Brown, Monson, lIE
210 J.E. Chappell, Jr. Northeastern Univ., Boston,MA
211 L..L. Holmes, Machias, HE X
1 •1. Holmes, Eastport, ME
213 E A. Hofferman, Eastport, NE
214 d.N. Hefferman, Eastport, ME
215 h Kent, Co—signers, Monmouth, ME X X X
216 l.A. Donaghy, Lubec, ME
1217 {.G. Lehigh, Eastport, NE
218 I.H. Smith, Pembroke, HE X
‘219 .B. Norton, Harbormaster, Jonesport, NE X X
1220 .E. Nerrill, Merrill Transport Co., Portland,Iffi
ix
-------
Ite m
No.
Source
Nam. or Affiliation
Issues_Raised —
AR
A 0
221 K. Ruff, Pres., Washington Co. Chamber of Corn., X
Calias, NE
222 A. Bell, Township of Edmond—Wash. Co., lIE X X X
223 R. Merrill, Lubec, HE X X X
224 R.J. Peacock, Sun Oil, Lubec, NE
225 R.S. Peacock, Pres. R.J. Peacock Canning, Lubec X
226 M. Otis, Perry, ME X X
227 . Good, W.C.C. Manufacturer, Dennsyville, ME X X X
228 IN.B. Pike, Homes Packing Co., Eastport, ME X X X
229 Hr. LLvard, Lincoln, NE X X
230 1 c. Cronin, Bus. Rep. Local #4 - O.E., ME X
231 IR. Conti, Eastport, NE x
232 M.C. Morrison, Perry, ME X X X
233 . Davis, Easport, lIE X X
234 Ir. Cooke, Eastport, lIE X
235 Ir. Eramian X X X
236 R.C. Naban, Calais Chamber of Coimnerce, Ca1ais,}fl X
237 1. Leigh, Eastport, HE
238 Ir. Reavey, Passamaquoddy Tidal Power Advocates X
239 fIr. Guay, Eastport, HE X
240 JJ. Klyver, Eastport, ME
241 K. Callahan, Eastport, NE X
242 Current , Shead Men.H.S., ME(Poll)
243 Nr. & Mrs. R. Jatnieson,(Gaeta, Italy) Eastport,NF
244 fl’. Kinney, Eastport, ME X X X
245 E.}1. Blanch, Sentinel Insurance Agency, Eastport X
246 . Cohen, Member, Coy. Exec. Council, Eastport X
24? . Mills, Representative, Eastport,
248 . Najke, N.B., Canada X X
249 ‘etition X
250 .J. Cook, Washington County, ME
251 r. Unobskey, Unobskey’s Fashion Center, Calais,NE X
252 alais Lions Club, Calais, ME X
253 i. Keezer, Federson Agency, Inc., Eastport, ME X
254 . Mitchell, Eastport Little League, Easport, NE
255 II.M. Hansconi, Action Agency, Realtors, Machias,ME X
256 E.J. King, The New England Council, Boston, MA X
257 1.L. Armstrong, Merrill Trust Co.,Llncoln, ME X
258 . Stagg, Port Jefferson, N.Y.
259 . Sitason, Eastport, NE
260 .B. Jackson, Monmouth, ME X X X
261 .J. Boone, St. Andrews, N.E., Canada X X
262 . Snyder, Whiting, ME X X
263 1.W. Brydon, Calais, ME X
264 L Grandmaison, Local Unic’n No. 545—SIWA, Lewisto X
265 Sunde, Trescott, NE X
x
-------
Item
No.
Source
Name or Affiliation
-
Issues Raised
—
SE ‘ME
FR
N+N
AR
A
0
— — —
—
x
X
x
x
266
267
268
269
270
271
272
273
274
275
276
277
278
279
280
281
282
283
284
285
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
101
1302
1303
J304
J305
3 06
307
308
b 09
T.McDugald, Eastport, ME
P. Segien, Eastport, ME
W.C. Nickerson, Service Master of Maine, Inc.
Portland, HE
A. Harris, Peregrine Assoc., Eastport, ME
F.A. Brown, Brown & Tibbetts, Calais, ME
T.C. Naughton, New York, N.Y.
N. Spencer, East Rockaway, N.Y.
E.Fishbein, Eastport, ME
F. Trocco, Eastport, ME
N.J. Bradshaw, Dennsyville, ME
L. Szatkowski, Robbinston, ME
B.M. Shotwell, Kennebunkport, NE
S.B. Miller, Kennebunkport, ME
M. Speer, New York, N.Y.
M. Mullis, Cooper, ME
W. McGarvey, Moose Island, ME
N. Cohen, Trescott, ME
S.C. Levin, The Counseling Center, Bangor, ME
D. Cohen, Kilhington, VT
M.J. Cohen, Lubec, ME
B. &. M. Mickewieg, Wilmington, MA
C. Aylward, Lincoln, ME
L.M. Healy, New York, N.Y.
M.D. Latharn, Ellsworth, ME
Mrs. P. Clukey, Vexted, ME
H.M. Merrill, Jr., Quoddy Bay Co—op, Inc. Lubec
C.S. Morrison, Perry, ME
E.B. Ebershaw, Hanover, N.H.
L.W. Guetersloh, Pine Plains, N.Y.
W.J. Armstrong, Warwick, R.I.
Passarnquoddy Tibe, Perry ME
D. Dowley, Quoddy Bay Fish Corp.ME
Mr. & Mrs. H. Dudley, Eastport
J.W. Anderson, ilarine Nannal Corn., Wash., D.C.
G.N. Ewing, Canadian Hydrographic Ser., Ottawa
Canada
R. Richardson, Deer Island, ME
H. Majke, The N.B. Fed. of Naturalists, Canada
G.W. Barnes, Engineers, Topsharn, ME
N.C. Casey, Bernardini Co., Calais, ME
J. Lowe, Eastport, NE
E.K. Warinell, Woodland, lIE
J. Follis, Eastport, NE
Mr. & Mrs. H. Dudley, Eastport, ME
R.L. Violette, Hascall & Hall, Inc., Portland,ME
S. Camick, Eastport, NE
x
X
x
x
X
X
X
x
X
X
X
X
x
x
x
X
x
x
x
X
x
x
LX
X
ix
LX
x
x
X
x
X
x
x
x
x
x
X
x
X
x
x
x
x
xi
-------
Item
No.
Source
Name. or Affiliation
SE ME PR H+N AR A 0:
311 W.G. Preston,Kennebunk, x
312 R.A. Dyer, III, Portland, ME
313 w.j, Weck, Cainbro Corp., Pittsfield, ME X
14 F.W. Frost, Calais Federal Savings, ME
315 j. Wilson, Jr., Marietta Cement, S. Portland,NE X
316 c.v. Starbird, Starbird Lumber, Strong, ME X
317 J.A. Saunders, Saunders Mfg. Co., W1nthrop,ME X
318 S.C. Noyes, S.C. Noyes Co., Rangeley, NE
319 II. Loachita & E. Lemhoefer, Robinston, ME X
320 A. l4agee, St. Andrews Civil TruEt, NB,, Canada
321 L Conti, Eastport, ME
xl i
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COMMENTS SUBMITTED BY
FEDERAL AGENCIES
-------
DEPARTMENT OF TRANSPORTATION
MAILING ADDRESS:
UNITED STATES COAST GUARD U.S. COAST GUARD (G-wEP-7/73)
WASHINGTON. D.C. 20590
PHONE: 202—426—3300
[ . JAN REED •].6476/7.b 222
30 cmc
Mr. Walter Stickney
U. S. Environmental Protection Agency
Region I, Enforcement Division,
Permits Branch
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. Stickney:
The concerned staff elements of U. S. Coast Guard Headquarters have
reviewed the draft environmental impact statement on the proposed
Pittston Oil Refinery at Eastport, Maine.
The following general comments are submitted:
1. The preparation of a separate executive summary is to be
commended. Due to the size of the EISsuch a document Is invaluable
as many reviewers do not have the time to review the complete document.
2. The chapter format is inconsistent with Council on Environmental
Quality Guidelines (40 CFR 1500). This inconsistency in and of itself
is not critical; however, most reviewers are accustomed to and expect
an environmental impact statement to follow the CEQ Guidelines Format.
3. The chapter on alternatives could be expanded to give greater
treatment to other items such as the Gibbs refinery proposal for Portland/
Sanford, vessel sizes and mix (tankers vs. barges), and components such
as hoses vs. loading arms on the piers, storage tank types, and operations
procedures.
4. The DEIS as written is a qualitative discussion of many of the
impacts of the proposed project. In order to assess the validity of this
qualitative discussion a great deal more qualitative data is required.
Lacking this data, a rational assessment of the environmental impacts of
the proposal cannot be made.
The following specific conunents are submitted:
1. Volume I, page 14: The conclusion that the channel approaches
to Eastport are excellent is subject to some debate. Although the channel
is deep enough to accomodate VLCCs without dredging, rock outcroppings and
high currents pose dangers to transiting vessels which make it less than
ideal, although not necessarily inadequate.
1—1
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SIJBJ; Comments on the draft Environmental Impact Statement
2. Volume I, page 18: The conclusion that there would be less
spinoff in jobs created in Portland than in Eastport is highly question-
able. The lack of an established infrastructure in Eastport and the
small size of the direct employment in the refinery means that resi-
dents will still have to travel to Bangor for many services. In the
case of Portland, these services would more likely be furnished by
expansion of the existing infrastructure (e. g., shopping centers,
restaurants, wholesale distributors, etc.).
3. Volume I, pages 25 — 26: For the reasons discussed above, it is
not likely that a high proportion of the payroll will be spent in the
local area once basic items such as housing are accounted for.
4. Volume I, page 27: 011 containment booms are not generally very
effective In areas with currents as high as those expected at Eastport,
up to 4 knots In some places. Through deployment at an angle to the
current, their effectiveness can be Improved, but in many cases booms can
be expected to be of little value in containing oil spills associated with
this proposal.
5. Volume I, page 37: The last sentence should be completed by
referring the reader to Chapter seven.
6. Volume II, page 9: The term “navigational aids” should be “aids
to navigation,” as applied to Coast Guard responsibilities. The term
“navigational aids” applies to devices placed and utilized on board
vessels, while “aids to navigation” are externally situated.
7. Volume II, page 9: It should not be implied that Pittston’s
navigational aids require a Coast Guard permit, since the electronic and
electro—acoustic approach and docking aids do not fall under the defini-
tion of aids to navigation. These devices do require FCC licensing
which is coordinated by the FCC with the Coast Guard.
8. Volume II, page 9: The Coast Guard regulations (33 CFR 154.300)
do not require a “Spill Prevention Control and Countermeasure Plan” but
rather an “Operations Manual”. The correct terminology should be used
In the EIS.
9. Volume II, page 9: As now used by the Coast Guard, the term
“deepwater port” refers to a facility licensed under the Deepwater Port
Act of 1974. None of the proposed facilities at the Pittston Refinery
are outside United States territorial waters or subject to this Act, and
therefore “marine terminal” would be a more appropriate term to use in
the EIS.
10. Volume II, pages 75 — 76: The data presented in Tables III — 13,
and III — 14 are ambiguous. At what depths were the water samples taken?
Where were the sample locations? At what point In the tidal cycle were
the samples taken?
1—2
-------
SUBJ: Comments on the draft Environmental Impact Statement
11. Volume II, pages 75 — 83: A comparison of the values obtained
from the water analyses should be made with expected natural estaurine
values obtained from other investigations.
12. Volume II, page 222: Our experience with deepwater ports indi-
cates that a private UHF, as opposed to citizens band, radio system is
more appropriate for the intended uses. Any decision on the type of
radio system to be licensed is up to the FCC.
13. Volume II, page 225: Although the channel dimensions appear
adequate for a VLCC under normal operating conditions, an analysis
of the effects of casualties (e. g., loss of steering, loss of propulsion)
and currents should be conducted. Several computer simulators have been
developed which could be used for this type of analysis.
14. Volume II, page 238: It is mentioned that the oil recovered in
the cleanup of a spill will be processed by the refinery; however, no
discussion is made of the disposal of the solid waste collected. In
the past, disposal of oil spill debris (oil coated rocks, seaweed,
absorbants, etc.) has been a major problem.
15. Volume II, page 238: The Coast Guard regulations (33 CFR 156.150)
require a checkout procedure aboard the vessel as well as the shore faci—
lity before oil transfer operations can be conducted.
16. Volume II, page 248: Some modification in the types of tankage
for various types of petroleum liquids shown in table IV — 11 may be
appropriate. Floating roof tanks significantly reduce hydrocarbon losses
and therefore have environmental as well as potential economic advantages.
in addition, it may be disirable, from an environmental standpoint, to
equip cone roof tanks with some kind of vapor recovery system.
17. Volume II, page 255: Fresh water will likely be used in the
refinery as process water (cooling) and in the fire water system in
addition to the uses listed.
18. Volume II, page 258: Most tankers are not equipped to discharge
their sanitary wastes through a shore tie to the facility’s treatment
system, but rather discharge it directly into the sea. Some progress is
being made in vessel treatment systems, but untreated discharges are likely
for the immediate future.
19. Volume II, pages 280 — 1: It is not necessarily correct to assume
that spinoff jobs In Portland would be less than those in Eastport (see
comments (b) above).
2O. Volume II, page 291: It is stated that there are no plans to
transport refined products by land while on page 249 it is stated that
five to ten tank trucks and one or two rail cars a day of products are
expected to be shipped to inland Maine markets. It is reasonable to
expect some overland shipments of products and the text on page 291 should
be changed to reflect this situation.
1—3
-------
SUBJ: Comments on the draft Environmental Impact Statement
21. Volume II, page 296: Although the existing highways may be
adequate for the present traffic density, anyone who has driven on
Routes 1 or 9 to Bangor would be hard pressed to consider them adequate
by present interstate standards for sizeable deliveries of supplies
by truck.
22. Volume II, page 298 — 9: The discussion of the impacts of
routine refinery discharges fails to treat effects in a meaningful
manner. Although their concentration may be small compared to oil and
grease, heavy metals may be included in the discharge in quantities
having potential for significant environmental damage. Their levels
and threshold levels of area biota to toxic effects of all expected
constituents of the discharge should be given so that a meaningful
conclusion can be reached.
23. Volume II, page 299: By neglecting the rare but major oil
spill the analysis is incomplete. In many cases it is this very type
of spill which has the greatest impacts on the environment. Some form
of risk profile which accounts for this type of spill is necessary to
make this section meaningful. The simple average number of barrels of
oil spilled per year Is meaningless.
24. Volume II,, page 299: Portland is not the largest oil port
on the East Coast. Historically New York has been approximately four
times as large and Philadelphia slightly larger in terms of tonnage
handled. With the completion of the Trans—Provincial pipeline to
Montreal, it is possible that In the future Boston will also be a
larger oil port than Portland.
25. Volume El, page 314: The effects of blasting (noise, vibra-
tion, fish kills, etc) associated with the proposed dredging should
be discussed.
26. Volume II, page 314: A more detailed discussion of the utili-
zation of the dredged material should presented.
27. Volume II, page 314: The possibility of a requirement for
maintenance dredging should be discussed.
28. Volume II, page 314: A more detailed discussion of the dis-
persion of fine sediment resulting from the dredging should be presented.
29. Volume II, pages 315 — 332: No analysis of the effects of
the projected hydrocarbon emissions on the ozone level is conducted.
In many areas, a linear rollback model is used for analyzing this
impact. In addition, if it is true that Portland is responsible for
ozone problem, then it must follow that Eastport would have
significant impacts on St. John’s air quality. Although St. John is
in Canada, if the proposed refinery would impact its air quality, such
Impacts should be discussed in the EIS.
1—4
-------
SUBJ: Comments on the draft Environmental Impact Statement
30. Volume II, page 354: The statement that dredging will not
be done to the extent possible during the prime spawning periods of
marine species can hardly be construed as a mitigating measure. What
is the probability dredging will or will not be accomplished during
there critical periods?
31. Volume II, page 354: A discussion of the uses to which the
dredged material will be utilized should be presented as well as
mitigating measures to be initiated to prevent the return of fine
sediments to the marine environment, (See comment (26) above).
Sincerely,
I . i. rTT !
c i ’nta1
1—5
-------
Responses to U.S. Coast Guard Conments
Si. The preparation of a separate executive summary is to be commended. Due
to the size of the EIS such a document is invaluable as many reviewers
do not have the time to review the complete document.
Ri. Comment noted.
S2. The chapter format is inconsistent with Council on Environmental
Quality Guidelines (40 CFR 1500). This inconsistency in and of itself
is not critical; however, most reviewers are accustomed to an expect
an environmental impact statement to follow the CEQ Guidelines Format.
R2. The format of the FEIS will be in compliance with CEQ Guidelines.
S3. The chapter on alternatives could be expanded to give greater treat-
ment to other items such as th Gibbs refinery proposal for Portland!
Sanford, vessel sizes and mix (tankers vs. barges), and components
such as hoses vs. loading arms on the piers, storage tank types and
operations procedures.
R3. See FEIS, Vol. II, p. X—42ff.
S4. The DEIS as written is a qualitative discussion of many of the im-
pacts of the proposed project. In order to assess the validity of
this qualitative discussion a great deal more qualitative data is
required. Lacking this data, a rational assessment of the environ-
mental impacts of the proposal cannot be made.
R4. Comment noted.
S5. Volume I, p. 14: The conclusion that the channel approaches to
Eastport are excellent is subject to some debate. Although the
channel is deep enough to accomodate VLCCs without dredging, rock
outcroppings and high currents pose dangers to transiting vessels
which make it less than ideal, although not necessarily inadequate.
R.5. See FEIS, Vol. II, p. IV—23, Marine Transport System.
S6. Volume I, p. 18: The conclusion that there would be less spinoff
in jobs created in Portland than in Eastport is highly questionable.
The lack of an established infrastructure in Eastport and the small
size of the direct employment in the refinery means that residents
will still have to travel to Bangor for many services. In the case
of Portland, these services would more likely be furnished by ex-
pansion of the existing infrastructure (e.g., shopping centers,
restaurants, wholesale distributors, etc.)
R6. Comment noted. See FEIS, Vol. II, p. VI—4 through VI—il, Socio—
Economic Impact.
1—6
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S7. Volume I, pp. 25—26: For the reasons discussed above, it is not likely
that a high proportion of the payroll will be spent in the local area
once basic items such as housing are accounted for.
R7. See FEES, Vol. II, p. VI—4 through VI—il, Socio Economic Impact.
S8. Volume I, p. 27: Oil containment booms are not generally very effective
in areas with currents as high as those expected at Eastport up to
4 knots in some places. Through deployment at an angle to the current,
their effectiveness can be improved, but in many cases booms can be
expected to be of little value in containing oil spills associated
with this proposal.
RB. Comment noted. See FEIS, Vol. II, p. IV—38ff, Oil Spill Containment
and Recovery. The technology and techniques involving the use of
oil booms and associated skimmers is continually being improved.
For example studies performed by B.A. Folson and C. Johnson of
Ultrasystems, Inc., and presented at the March 1977 Oil Spill Con-
ference sponsored by the EPA, USCG, and API den nstrated that a
specific streamlined oil boom is capable of retaining and recovering
oil spills in currents up to 6 knots. However, this system performs
best in wave conditions under one foot. Also this oil boom is a
research prototype and is not yet available commercially.
S9. Volume I, p. 37: The last sentence should be completed by referring
the reader to Chapt. seven.
R9. The above—mentioned change has been noted and corrected. Vol. 1 has
been corrected.
SlO. Volume II, p. 9: The term “navigational aids” should be “aids to
navigation,” as applied to Coast Guard responsibilities. The term
“navigational aids” applies to devices placed and utilized on board
vessels, while “aids to navigation” are externally situated.
RlO. Comment noted. Change noted and made.
Sll. Volume II, p. 9: It should not be implied that Pittston’s navigational
aids require a Coast Guard permit, since the electronic and electro—
acoustic approach and docking aids do not fall under the definition
of aids to navigation. These devices do require FCC licensing which
is coordinated by the FCC with the Coast Guard. See FEIS, Vol. II,
p. 11—5.
Ril. Comment noted. Appropriate statement was changed to reflect these
views.
S12. Volume II, p. 9: The Coast Guard regulations (33CFR 154.300) do not
require a “Spill Prevention Control and Countermeasure Plan” but
rather an “Operations Manual.” The correct terminology should be
used in the EIS.
Rl2. Comment noted. Correct terminology is used in the FEIS.
1—7
-------
S13. Volume II, p. 9: As now used by the Coast Guard, the term “deep—
water port” refers to a facility licensed under the Deepwater
Port Act of 1974. None of the proposed facilities at the Pittston
Refinery are outside United States territorial waters or subject
to this Act, and therefore “marine terminal” would be a more ap-
propriate term to use in the EIS.
R13. Comment noted. Appropriate terminology is used in the FEIS.
S14. Volume II, p. 75—76: The data presented in Tables 111—13, and
111—14 are ambiguous. At what depths were the water samples
taken? Where were the sample locations? At what point in the
tidal cycle were the samples taken?
R14. See revised Tables 111—13 and 111—14 in Vol. II, FEIS.
Sl5. Volume II, p. 75—83: A comparison of the values obtained from the
water analyses should be made with expected natural estaurine
values obtained from other investigations.
Rl5. Comment noted. See FEIS, Vol. II, Tables 111—13 and 111—14.
Respective tables contain current and historical data.
S16. Volume II, p. 222: Our experience with deepwater ports indicates
that a private UHF, as opposed to citizens band, radio system is
more appropriate for the intended uses. Any decision on the type
of radio system to be licensed is up to the FCC.
R16. Comment noted.
Sl7. Volume II, p. 225: Although the channel dimensions appear adequate
for a VLCC under normal operating conditions, an analysis of the
effects of casualties (e.g., loss of steering, loss of propulsion)
and currents should be conducted. Several computer simulators have
been developed which could be used for this type of analysis.
R17. The Pittston Co. has contracted with the Nationai. -Maritime Research
Center (Kings Point, N. i.) to perform real time simulation studies
of tanker passage through Head Harbor Passage waters in cooperation
with the State of Maine and the U.S. Coast Guard.
Sl8. Volume II, p. 238: It is mentioned that the oil recovered in the
cleanup of a spill will be processed by the refinery; however, no
discussion is made of the disposal of the solid waste collected.
In the past, disposal of oil spill debris (oil coated rocks, sea-
weed, absorbents, etc.) has been a major problem.
R18. The methods for disposal of oil coated debris will be developed
at a later date and will be part of the Pittston Co.’s oil
spill contingency plan.
1—8
-------
S19. Volume II, p. 238: The CoaHt Guard regulations (33CFR 156.150)
require a checkout procedure aboard the vesBel as well as the
Hhore facility before oil transfer operatiOfl8 can be conducted.
R19. Comment noted. The text will read as such.
S20. Volume II, p. 248: Some modification in the types of tankage
for various types of petroleum liquids shown in Table IV—ll
may be appropriate. Floating roof tanks significantly reduce
hydrocarbon losses and therefore, have environmental as well
as potential economic advantages. In addition, it may be desir-
able, from an environmental standpoint, to equip cone roof tanks
with some kind of vapor recovery system.
R20. The emissions from the cone roof tanks are so low that an ex-
penditure for such equipment as floating roof tanks or vapor
recovery systems would not be economically or environmentally
justified.
S2l. Volume II, p. 255: Fresh water will likely be used in the refinery
as process water (cooling) and in the fire water system in addition
to the uses listed.
R2l. Comment noted. The text will be changed in the FEIS to reflect
this statement.
S22. Volume II, p. 258: Most tankers are not equipped to discharge
their sanitary wastes through a shore tie to the facility’s
treatment system, but rather discharge it directly into the sea.
Some progress is being made in vessel treatment systems, but un-
treated discharges are likely for the immediate future.
R22. Comment noted. While holding tanks per se are not required, they
may be needed on some vessels in order to satisfy EPA regulations
on the content of the effluent (e.g., <1,000 parts total coliforrn
/100 ml water;no visible floating solids). Furthermore, holding
tanks cannot be pumped out within the 3—mile limit.
S23. Volume II, p. 291: It is stated that there are no plans to trans-
port refined products by land while on p. 249 it is stated that
five to ten tank trucks and one or two rail cars a day of products
are expected to be shipped to inland Maine markets. It is reason-
able to expect some overland shipments of products and the text
on p. 291 should be changed to reflect this situation.
R23. Comment noted. See FEIS, Vol. II, p. VI—27 and p. x—13.
1—9
-------
S24. Volume II, p. 296: Although the existing highways may be adequate
for the present traffic density, anyone who has driven on Routes
1 or 9 to Bangor would be hard pressed to consider them adequate
by present Interstate standards for sizeable deliveries of supplies
by truck.
R24. Comment noted. See FEIS, Vol. II, p. VI—25ff and X—l3.
S25. Volume II, p. 298—9: The discussion of the impacts of routine
refinery discharges fails to treat effects in a meaningful manner.
Although their concentration may be small compared to oil and
grease, heavy metals may be included in the discharge in quart—
tities having potential for significant environmental damage.
Their levels and threshold levels of area biota to toxic effects
of all expected constituents of the discharge should be given
so that a meaningful conclusion can be reached.
R25. Comment noted.
S26. Volume II, p. 299: By neglecting the rare but major oil spill
the analysis is incomplete. In many cases it is this very type of
pill which has the greatest impacts on the environment. Some form
of risk profile which accounts for this type of spill is necessary
to make this section meaningful. The simple average number of
barrels of oil spilled per year is meaningless.
R2f . A hypothetical oil spill analysis has been performed and is presented
in the FEIS, Vol. II, p. VI—38ff.
S27. Volume II, p. 299: Portland is not the largest oil port on the
East Coast. Historically New York has been approximately four
times ES large and Philadelphia slightly larger in terms of ton-
nage handled. With the completion of the Trans—Provincial pipeline
to Montreal, it is possible that in the future Boston will also be
a larger oil port than Portland.
R27. Comment noted. Portland is the largest oil port in the State of
Maine and also in New England. The balance of the comment will be
incorporated into the FEIS and the error removed.
S28b Volume II, p. 314: The eftects of blasting (noise, vibration,
fish kills, etc.) associated with the proposed dredging should be
discussed.
P28. Blasting during the dredging operation will kill fish and bottom
organisms in the area of the explosion. The lethal range of the
blast is not expected to exceed two hundred yards, unless unusual-
ly large amounts of explosives are used. Areas that are not alter-
ed but experience benthic mortality will be repopulated quickly. No
significant affect to any commercial fishery is anticipated and no
populations of fish are expected to be significantly reduced. ‘The
impacts associated with dredging and blasting are considered to be
temporary and short—lived in nature. The survival of aquatic resources
and the ecological integrity of the area will not be threatened.
To ensure the protection of significant migrations of fish transit-
ing through the area the Pittston Company will be regulated under
1—10
-------
permit from the Corps of Engineers to cease blasting operations
during migrations. The company has expressed their willingness to
work wtth hto og1sts and local fishermen to determine the presence
of such fish.
The Pittston Company will be required to retain a seismologist to
record the vibrations from blasting at different inland locations.
This will help to ensure that no inland damage will be caused.
Though the noise of blasting will be heard inland, it should not, how-
ever, create any disturbance or disruption sufficient to cause con-
cern or alarm.
S29. Volume II, p. 314: A more detailed discussion of the utilization
of the dredged material should be presented.
R29. All spoil material will be utilized in the construction of the
refinery. Appropriate information including chemical analysis
would be obtained during the subsurface exploration and testing
pro gr am.
S30. Volume II, p. 314: The possibility of a requirement for maintenance
dredging should be discussed.
R30. Maintenance dredging is not anticipated to be required because of
the scouring and flushing action of the tides and currents.
S31. Volume II, p. 314: A more detailed discussion of the dispersion
of fine sediment resulting from the dredging should be presented.
R31. Comment noted. See FEIS, Vol. 11, p. Vl—64, Dredging.
The dredging and blasting associated with the construction of piles
and piers will caase the resuspension of fine grain sediment in
the Shackford Head/Deep Cove area.
The flora and fauna of the Shackford Head/Deep Cove area are al-
ready exposed to sediment movement. They consist of species which
are well adapted to cope with local siltation resulting from dredging.
Tidal activity can be expected to rapidly disperse fine grain sedi-
ment resuspended during dredging operations. Utilizing information
obtained during surface sediment sampling as a basis, there appears
to be little fine grain sediment in the area to be dredged.
S32. Volume II, p. 315—332: No analysis of the effects of the projected
hydrocarbon emissions on the ozone level is conducted. In many
areas, a linear rollback model is used for analyzing this impact.
In addition, if it is true that Portland is responsible for East—
port’s ozone problem, then it must follow that Eastport would
have significant impacts on St. John’s air quality. Although St.
John is in Canada, if the proposed refinery would impact its air
quality, such impacts should be discussed in the EIS.
1—11
-------
The proposed refinery will not emit 8ignificant precursors of
ozone into the air, and therefore, ozone formation is anticipated
to be insignificant. Ozone from the Portland area is due to a
combination of HC from the port facilities and NO from automo-
bile exhaust. Automobile exhaust is insignlficant’ t in the Eastport
area and ozone levels experienced are due to transport from in-
dustrialized areas.
R32. See FEIS, Vol. II, p. VI—81.
S33. Volume II, p. 354: The statement that dredging will not be done
to the extent possible during the prime spawning periods of marine
species can hardly be construed as a mitigating measure. What is
the probability of dredging being accomplished during these
critical periods?
R33. The prime spawning periods of marine species occur from late
spring to mid summer. Because the anticipated time period re-
quired for dredging is approxImately 3—4 months, the dredging
and blasting activities can be scheduled around these periods.
These activities will be regulated under permit from the Corps
of Engineers.
S34. Volume II, p. 354: A discussion of the uses to which the dredged
material will be put should be presented as well as mitigating
measures to be initiated to prevent the return of fine sediments
to the marine environment.
R34. The dredged material, comprised mostly of rock, will be placed
in barges, taken to shore, and moved by truck to specified land
sites which have previously been diked to control runoff. Be-
cause two—thirds of the spoils will be rock, drainage should
take place before reaching shore. Limited amounts of runoff
are therefore expected. The outflow from this diked material
will be returned to the waters surrounding E stport through a
constructed channel controlled by a series of weirs, so that
contamination of any sort will not be returned to the bay. The
dredged material will be utilized at the construction site.
1—12
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UNITED STATES DEPARTMENT OF COMMERCE
D C ‘ u The Assistant Secretary for Science and TechnoIo y
Washington. 0 C. 20230
December 13, 1976
Mr. John A. S. McGlennon
Regional Administrator
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
The draft environmental impact statement for “Proposed Issuance
of Federal Permits to the Pittston Company of New York for
Construction of a 250,000 Barrel Per Day Oil Refinery and
Marine Terminal - Eastport, Maine” dated October 13, 1976,
has been received by the Department of Commerce for review
and comment. The statement has been reviewed and the
following comments are offered for your consideration.
General Comments
The draft environmental impact statement (DEIS) lacks
sufficient information to accurately evaluate probable
impacts of the proposed action on living marine resources
and on the public which derives its livelihood from those
resources. It has frequently been concluded by investigators
that despite the application of all feasible precautions,
oil spills will occur . 1 2 , 3 , 4 Even so, the DEIS does not
identify areas and marine resources that may be impacted by
spills, nor is there a discussion of contingency plans for
containment, clean-up, and disposal of spilled oil. The
probable effect of spills on fishing gear assemblages and
ancillary equipment likewise is not addressed. Other
environmental aspects that should have received attention
include the differing impact potential of various crude
and refined petroleum products and their rate of deterioration
or persistence under given weather conditions. Also, it could
have been noted that tidal and current characteristics of
Passamaquoddy Bay would ensure that any spills of oil would
be widespread and dispersed throughout the water column.
2—1
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-2-
It is our understanding that the State of Maine permits for
this project have been conditioned to the effect that the
applicant must secure transit rights through Canadian
waters. This, to our knowledge, has not been accomplished.
Also, the proposed refinery site Is located near Canadian
territory. Considering these two factors, a discussion of
the affected and potentially affected Canadian environment
should be included in the impact statement, unless precluded
for other or overriding reasons.
We believe that the DEIS could more adequately discuss
several significant environmental issues outlined in our
specific comments which follow.
Specific Comments
Chapter 1 - Introduction
Page 1, para. 5 : The significance of “conditioned approval,”
especially if it applies to passage through Canadian waters,
should be discussed in more detail.
Chapter 3 - Description of Existing Environment
Socio-Economjc Characteristics
Economy
Page 35, paras. 1 and 2 : Using the figures presented in these
paragraphs, it appears that about 36 percent of the work force
in Charlotte County, New Brunswick is engaged in the fishing
industry. The fact that over one-third of the work force is
directly dependent upon marine resources is significant and
should be stressed.
Page 35, para. 4 : It should be noted that there is an intertidal
fishery for periwinkle in the bay area, and that an extensive
fishery for herring (over 300 wiers) is concentrated in the
vicinity of Eastport, Maine.
Aquatic Resources
Marine Hydrology
Page 66, para. 2 : The State of Maine permit requires that the
applicant’s piers (and the associated oil containment facilities)
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-3-
be in areas where currents do not exceed 1.0 knots. Work done
by Miller, Lindemuth and Altmann for the U.S. Department of
Transportation, and by McCracken for the U.S. Environmental
Protection Agency (in press), indicate that waves 0.3 to 0.6
meters high having a length of 2.7 to 9.1 meters and a period
of 1.5 to 3.0 seconds can cause inshore boom ystems to fail
at current velocities of less than 1.0 knots. In the case of
offshore booms, calm water trials revealed that a current
velocity of 1.0 knots was the failure point, while rough
water failures occurred at approximately 0.7 knots.°
In view of the preceding, it would appear desirable to include
a more detailed map of current velocity profiles and a more
thorough description of the piers that have been designed to
comply with the state’s requirements.
Page 75 para. 2 : In view of the important inshore and intertidal
fisheries (described on pages 105-116) it would be helpful if
major components of the referenced drift were identified.
Aquatic Ecology
Page 105. para. 4 : Using only the economic value of clams to
determine their “worth” is misleading since their value as a
source of food for other marine fauna or, in other words, their
role in the marine food web is not taken into account.
Other Federal Projects in the Area
The Maine Coastal Zone Management Program
Page 194 : Although the State’s lead Coastal Zone Management
office has been contacted for comments, the CZM goals and
policies are not discussed in the DEIS.
Air Resources
Climatology
Pages 134-144 : It wo 1d be worthwhile to present a comparison
of the rate at which weather deteriorates, and deteriorated
weather persistence, with transit times of VLCCs through the
Head Harbor Passage. Also, an attempt to analyze the
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-4-
relationship between fog frequency, tidal cycles, and the
applicant’s assertion that there will be no tanker traffic
when visibility is less than one mile would be informative.
Chapter 4 - Description of the Project
Economic Rationale
Page 209 : It is noted in Table IV-5 that the level of refinery
investment is the same for both Eastport and the Middle Atlantic
States. In comparison with Mid-Atlantic States the remoteness
of Eastport would require a longer distance transport of men,
materials, and support facilities. Accordingly, it appears
the refinery investment at Eastport would be higher. This
should be expanded to provide for a more complete understanding
of the costs.
Description of Plan
Marine Transport System
Page 214, para. 2 : Canadian Government opposition to tanker
transit through Canadian waters is noted on page 3 of the
Executive SllmRry but is omitted from the description of the
Marine Transport System. Insofar as the Transport System
involves navigation aids, electronic surveill nce/guidance/
coninunication facilities, channel characteristics and operating
features, transit and berthing procedures, etc., in Canadian
waters, it appears the draft should be expanded to discuss
Canadian opposition.
Page 238, para. 1 : From the figures presented in this section,
it appears that any accident with the crude oil unloading/loading
lines would result in a minimum spillage of approximately 8,300
gallons. It would be helpful to have such a spill put in the
context of the expected capacity of the boomed area and clean-up
capabilities.
Oil Spill Containment and Recovery
Page 247. para. 1 : It is noted that Department of Transportation,
U. S. Coast Guard Pollution Prevention Regulations must be
complied with. A further explanation or at least an appendix
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—5—
should be devoted to Part 154, Large Oil Transfer Facilities
and Part 156, oil Transfer Operations, the applicable U.S.
Coast Guard regulations.
Chapter 5 - Project Alternatives
Alternative Sites
Page 275 : The table in Figure V-I provides a comparison of the
alternative refinery sites that were investigated by Pittston.
Eastport was rated first followed by Hancock Point and Harbor
Side. The remaining eleven sites were rated considerably less
desirable. The capacity of the proposed Eastport refinery is
planned for 250,000 BPD. In view of an estimaged 1.5 million
BPD increase in New England’s requirement by 1985, there is a
need for an additional five such refineries to satisfy the
demand. With the small number of prime site locations available
in relation to refinery requirements, the impact statement should
address the feasibility of future expansion of the proposed
Eastport refinery to some capacity much greater than 250,000
BPD. It is noted the Marine Transport System as planned could
be expanded without any channel overloading.
From Figure V-i it appears that one - or possibly two - alternative
sites were nearly as desirable as Eastport, differing only
slightly in each factor considered except the availability of
rail service. Because of the closeness suggested by the table,
a more complete discussion of the advantages offered by the
Eastport site over other acceptable locations should be
included.
Chapter 6 - Environmental Impacts of the Proposed Project
Aquatic Resources
Impact of Routine Refinery Discharges on Marine Water Quality
Page 298, para. 4 : A more thorough compilation and analysis
of when maximum discharge levels of 3.5 mgd from the facility
would occur would be useful. For example, can a reasonable
estimate be made of how much oil will be discharged into area
waters on a weekly and yearly basis, taking into account annual
precipitation patterns, frequency and amount of ballast water
to be handled, on-site generated discharges, etc.?
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Page 298, para. 5 : If hydrocarbon levels in Deep Cove can
be elevated as the result of a discharge from a single vessel
(page 87, para. 3), then the discharge of up to 60 gpd would
seem to have a potential for adversely affecting living marine
resources in the area. It is likely that the intertidal zone
would be more severely impacted by the processed water discharge
than would the subtidal substrate.
Oil Spills Due to Tanker Accidents
Potential Effects of a Spill
Page 3O9 para. 1 : Arrangements, if any, being considered
for the cleaning, repair, and replacement of fishing gear
damaged as a result of a spill should be discussed.
Page 309 para. 4 : In view of the work of Dow, Hurst, Barry
and Yevich, it should be stated that soft shell clams will be
significgn ly affected by any oil spills that reach their
areas. 7 ’
Investigations performed by Canadian researchers have found oil-
induced lobster mortalities in pounds where oil coating did not
occur. -° Additionally, it has been shown that certain hydrocarbon
fractions interfere with olfactory functions in lobsters and may
impair mating and feeding activities) 1 -
Ecology
Page 313. para. 5 : Forrester reported that oil, lost as a result
of the “Arrow” spill in Chedabucto Bay, was collected at depths
of up to 80 meters.’ 2 Were this depth range superimposed on
Passamaquoddy Bay it would include most of the subtidal bay
bottom; thus, few areas would escape the adverse impacts induced
by a spill.
Page 314, para. 5 : Additional information relative to the proposed
blasting during construction of berthing facilities should be
provided.
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—7—
Chapter 8 - Relationship Between Local Short-Term Uses of the
Environment and Maintenance and Engineering of
Long-Term Beneficial Uses
Page 357 : If a major oil spill were to occur in Passamaquoddy
Bay, especially during the spring to fall period, the entire
socio-economic structure of Washington County, Maine, and to a
larger extent Charlotte County, New Brunswick, would be altered
to some unknown degree. Fisheries and the recreation/tourism
industries would most likely not be profitable or in some cases
even possible for some undefinable period. Losses during this
period would, in some instances, represent failure for the
entire year. If an oil spill could not be dealt with promptly
and effectively because of boutidary and/or jurisdictional
problems, the adverse impact upon marine resources and associated
industries would be compounded. The boundary alignment and
the location of spill contingency units make such problems a
distinct possibility.
Thank you for giving us an opportunity to provide these comments,
which we hope will be of assistance to you. We would appreciate
receiving twelve (12) copies of the final statement.
Sincerely,
Sidney R. GAller U
Deputy Assistant Secretary
for Environmental Affairs
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Literature Cited
1. U. S. Department of the Interior, Office of Economic
Analysis. 1973. Draft Environmental Impact Statement:
Deep-Water Ports.
2. U. S. Army Corps of Engineers, Norfolk, Virginia 23510.
1976. Proposed Final Environmental Impact Statement:
Hampton Roads Energy Company’s Portsmouth Refinery
and Terminal, Portsmouth, Virginia.
3. Porricelli, J.D., V.F. Keith, and R.S. Storch. 1971.
Tankers and Ecology. Transactions: The Society of
Naval Architects and Marine Engineers. Vol. 79, pp. 169-2.21.
4. _________. 1974. Suiw ary of Physical, Biological, Socio-
Economic and other factors Relevant to Potential Oil Spills
in the Passamequoddy Region of the Bay of Fundy. Fisheries
Research Board of Canada, Technical Report No. 428, pp. 229.
5. McCracken, W.E. 1976. Performance Testing of Selected
Inland Oil Spill Control Equipment. In Press. Office of
Research and Development, U. S. Environmental Protection
Agency, Cincinnati, Ohio 45268. pp. 112.
6. Miller, E., W. Lindenmuth, and R. Altmann. 1973. Analysis
of Lightweight Oil Containment System Sea Trials.
7. Dow, R.L. 1975. Reduced Growth and Survival of Clams
Transplanted to an Oil Spill Site. Marine Pollution Bulletin.
: 8: 124-125.
8. Dow. R.L., and J.W. Hurst, Jr. 1975. The Ecological,
Chemical and Histopathological Evaluation of an Oil Spill:
Part 1. Ecological Studies. Marine Pollution Bulletin. 6:
11: 164-166
9. Barry, M., and PP. Yevich. 1975. The Ecological, Chemical
and Histopathological Evaluation of an Oil Spill: Part 3.
Histopathological Studies. Marine Pollution Bulletin.
: 11: 171—173.
10. Scarratt, D.J. 1976. Personal Comunication. Fisheries
Research Board of Canada, Biological Station, St. Andrews,
New Brunswick, Canada.
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11. Todd, JH., D. Engstrom, S. Jacobson, and W.O. McLarney.
1972. Introduction to Environmental Ethology; Preliminary
Comparison of Sublethal Thermal and Oil Stresses on the
Social Behavior of Lobsters and Fishes from a Fresh-water
and Marine Ecosystem. (unpublished manuscript,) Woods
Hole Oceanographic Institution, Report No. 72-42, 104 pp.
12. Forrester, W.D. 1971. Distribution of Suspended Oil
Particles Following the Grounding of the Tanker Arrow,
Journal of Marine Research. Yale University. 29: 2: 151-170.
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Response8 to U.S. Department of Commerce Conmients
Si. The DEIS lacks sufficient information to accurately evaluate probable
impacts of the porposed action on living marine resources and on the
public which derives its livelihood from those resources.
The DEIS does not identify areas and marine resources that may be
impacted by spills, nor is there a discussion of contingency plans
for containment, clean—up, and disposal of spilled oil. The probable
effect of spills on fishing gear assemblages and ancillary equipment
likewise is not addressed.
Ri. See FEIS: Vol. II, p. IV—38ff, Oil Spill Containment and Recovery;
Vol. II, p. VI—28ff, Oil Spills.
S2. The State of Maine Permits are conditional so that Pittston must
obtain transit rights through Canadian waters.
Page 1, para. 5 : The insignificance of “conditioned approval,”
especially if it applies to passage through Canadian waters, should
be discussed In more detail.
R2. Mr. Richard Vine, Assistant Secretary of State for Canadian Affairs,
in a letter to Mr. John McGlennon of EPA, stated that the Canadian
issue was not an appropriate topic of discussion for the EIS.
S3. Page 35, paras. 1 and 2: Using the figures presented In these para-
graphs, it appears that about 36% of the workforce in Charlotte
County, New Brunswick, is engaged in the fishing industry. The
fact that over one—third of the workforce is directly dependent
upon marine resources is significant and should be stressed.
R3. Comment noted. See FEIS, Vol. II, p. vI—5Off.
S4. Page 35, para. 4: It should be noted that there is an intertidal
fishery for periwinkle in the bay area, and that an extensive
fishery for herring (over 300 weirs) is concentrated In the vicinity
of Eastport, Maine.
R4. See FEIS, Vol. II, p. 111—87, Commercial Invertebrates. The Atlantic
herring ( Clupea harengus ) has been the single most important fishery
in the region. Weirs are the principle gear used in the Eastport area
to catch herring. From 1948 to 1958, there were about 22 weirs in the
Passamaquoddy and Cobscook Bay areas of Washington County. Today,
weirs are operating mostly along the coast of Perry in Passamaquoddy
Bay.——from p. 121, DEIS.
S5. The State of Maine requires that the piers be In areas where currents
do not exceed 1.0 knots. Work done by Miller, Lindemuth, and Altman
for the U.S. Department of Transportation, and by McCracken for the
U.S. Environmental Protection Agency (in press), indicate that waves
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0.3 to 0.6 meters high having a length of 2.7 to 9.1 meters and a
period of 1.5 to 3.0 seconds can cause inshore boom systems to fail
at current velocities of less than 1.0 knots. In the case of off—
shore booms, calm water trials revealed that a current velocity
of 1.0 knots was the failure point, while rough water failures
occurred at approximately 0.7 knots.
In view of the preceding, it would appear desirable to include a
more detailed map of current velocity profiles and a more thorough
description of the piers that have been designed to comply with
the state’s requirements.
ES. Final pier locations will comply with Maine BEP stipulations.
Comment noted. See FEIS, Vol. II, p. IV—38ff,0il Spill Containment
and Recovery. The technology and techniques involving the use of
oil booms and associated skimmers Is continually being improved.
For example, studies performed by B.A. Folsom and C. Johnson of
Ultrasystems, Inc., and presented at the March 1977 oil Spill Con—
ference sponsored by EPA, USCG, and API, demonstrated that a
specific streamlined oil boom is capable of retaining and recover-
ing oil spills in currents up to 6 knots. However, this system
performs best in wave conditions under one foot. Also this oil
boom is a research prototype and is not yet available commercially.
S6. Page 75, para. 2: In view of the important Inshore and intertidal
fisheries (described on pages 105—116) it would be helpful if major
components of the referenced drift were identified.
R6. The most recent investigation of coastal currents that applies to
the Maine Coast, Gulf of Maine, and Is applicable to the area, is
work done by Graham (1970) in connection with herring studies.
He reviews the previous work concerning the Gulf of Maine and
summarizea the atlas prepared by Bumpus and Louzler (1965). The
following from Graham portrays the Gulf circulation: “The surface
circulation of the Gulf includes seasonal changes; in autumn, a
counterclockwise eddy in the northeastern part of the Gulf retreats
northward to an area between Cape Sable, Nova Scotia, and the coast.
This area has several smaller irregular eddies in winter. A souther-
ly flow develops along the western side of the Gulf. The spring dis-
charge from rivers strongly activates the Gulf eddy and this large
cyclonic gyre occupies all of the Gulf during May. Water moves Into
the gyre from the Scotian Shelf and then north into the Bay of Fundy
or west to the coast of Maine. Less saline water from the Bay of
Fundy moves down the eastern side of the bay and joins the west-
ward moving gyre. At times water moves down the western side of the
bay through Grand Manan Channel directly to the coast of Maine. The
flow continues down the coast past Cape Ann and into Cape Cod Bay
(42 degrees 00’N, 70 degrees 30’W) or eastward and then north of
Georges Bank. The eddy slows down in June and by autumn the southern
side diverts into a drift across Georges Bank.”
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Graham’s research showed that the routes of travel of coastal
waters suggested that surface water generally moves along the
coast and bottom water moves shoreward. These shoreward movements
are significant in the transport of herring to inshore waters
and into estuaries and bays such as those in the Quoddy Region.
This type of compensatory movement inshore has been measured in
various Maine river mouths as the Sheepscot and Kennebec (Graham,
personal communication). Reference: Literature Review of the Maine
Environmental Data for Eastport, Maine. TRIGOM, 1973.
S7. Page 105, para. 4: Using only the economic value of clams to de-
termine their “worth” is misleading since their value as a source
of food for other marine fauna, or in other words, their role in
the marine food web is not taken into account.
Ri. comment noted. In addition to their economic importance, the
soft—shelled clam arenaria ) occupies an intermediary trophic
level in the aquatic food web. As a suspension feeder, obtains
nourishment by filtering sea water of phytoplankton, detritus, and
bacteria. In turn, it may provide food for other aquatic life such
as invertebrate predators (e.g., polychaetes, crabs) and fish
(e.g., winter flounder, striped bass). Shorebirds also feed upon
soft—shelled clams.
S8. Page 194: Although the State’s lead Coastal Zone Management office
has been contacted for conunents, the CZM goals and policies are
not discussed In the DEIS
R8. Comment noted. Goals and policies have not been finalized,
S9. Pages 134—144: It would be worthwhile to present a comparison of
the rate at which weather deteriorates, and deteriorated weather
persistence, with transit times of VLCCs through the Head Harbor
Passage. Also, an attempt to analyze the relationship between fog
frequency, tidal cycles, and the applicant’s assertion that there
will be no tanker traffic when visibility is less than one mile
would be informative.
19. See FEIS, Vol. II, p. X—26ff.
SlO. Page 209: It is noted in Table IV—5 that the level of refinery
investment is the same for both Eastport and the Middle Atlantic
States. In comparison with Mid—Atlantic States the remoteness of
Eastport would require a longer distance transport of workers,
materials, and support facilities. Accordingly, it appears that
the refinery investment at Eastport would be higher. This should
be expanded to provide for a more complete understanding of the
costs.
RIO. The cost difference of constructing a refinery in Eastport vs.
the Mid—Atlantic States is approximately 1OZ. This increase
translates to an increase of 5 /Bbl. handled at the refinery.
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However, this is more than offset by the 40C/Bbl. transportation
cost savings realized by the Eastport location. Furthermore,
there are additional cost advantages with the Eastport location
with respect to products.
Sil. Page 214, para. 2: Canadian Government opposition to tanker
transit through Canadian waters is noted on p. 3 of the Executive
Summary but Is omitted from the description of the Marine Trans—
port System. Insofar as the Transport System involves navigation
aids, electronic surveillance/guidance/communication facilities,
channel characteristics and operating features, transit and
berthing procedures, etc., in Canadian waters, it appears the
draft should be expanded to discuss Canadian opposition.
RU. Mr. Richard Vine, Assistant Secretary of State for Canadian Affairs,
in a letter to Mr. John McGlennon of EPA, stated that the Canadian
issue was not an appropriate topic of discussion for the EIS.
Sl2. Page 238, para. 1: From the figures presented in this section, it
appears that any accident with the crude oil unloading/loading
lines would result in a minimum spillage of approximately 8,300
gallons. It would be helpful to have such a spill put in the con-
text of the expected capacity of the boomed area and clean—up capa-
bilities.
Rl2. If an unloading/loading line were to part, oil would spill until
the onboard tanker pumps are turned off and the motor operated
valve on the tanker deck is shut off. Land—based operational per-
sonnel at the pier together with the tanker based personnel
supervise the offloading of oil. The greatest quantity of oil
would be lost when the offloading is at maximum capacity——lines
under full pressure and pumps operating. When offloading crude
oil, four 16—Inch loading units are in operation. The crude is
pumped from these lines into two 36—inch lines which connect to
the refinery tank farm. In the event of a break In a 16—Inch
line, the onboard tanker pumps would be immediately turned off
by supervisory tanker personnel. At the same time, the motor
operated valve on the tanker deck would be shut off. The land—
based operational personnel would also proceed to close the
motor operated gate valve on shore. Because of the immediate
drop in the offloading line, pressure due to the pump shutdown
and the closing of the two motor operated valves, the spill
emanating from a complete break would be considerably less than
the 200 barrels.
The tanker oil connection trough together with the deck of the
tanker will serve to contain most spills of this nature. Before
unloading operations begin, the tanker is surrounded by contain-
ment booms as a precaution in the event that the tanker deck and
tanker collection trough are not adequate for the containment of
oil.
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In the event of a 36—Inch line break, the procedures that would
be taken to rectify the problem are Identical to those outlined
for a 16—inch line. The catastrophic spillage would amount to
400 barrels——but again this figure would be considerably reduced
because of line pressure loss from pump shutdown and the effect
of closing the two motor operated valves.
Experience has shown, that by far the majority of “breaks’ t in the
offloading units are not breaks per se, but rather leaks, splits
in piping, etc. Rarely does an offloading unit part completely
resulting in crude losses outlined above.
The boomed area around the VLCC has the capacity to contain spill
and oil quantities of this nature.
Sl3. Page 247, para. 1: It is noted that Department of Transportation,
U.S. Coast Guard Pollution Prevention Regulations must be com-
plied with. A further explanation or at least an appendix should
be devoted to Part 154, Large Oil Transfer Facilities and Part
156, Oil Transfer Operations, the applicable U.S. Coast Guard-
regulations.
RJ3. Coent noted.
S14. Page 275: The table in Figure V—l provides a comparison of the
alternative refinery sites that were investigated by Pittston.
Eastport was rated first followed by Hancock Point and Harbor
Side. The remaining eleven sites were rated considerably less
desirable. The capacity of the proposed Eastport refinery is
planned for 250,000 BPD. In view of an estimated 1.5 million
BPD increase in New England’s requirement by 1985, there is a
need for an additional five such refineries to satisfy the
demand. With the small number of prime site locations available
in relation to refinery requirements, the impact statement should
address the feasibility of future expansion of the proposed
Eastport refinery to some capacity much greater than 250,000
BPD. It is noted that the Marine Transport System as planned
could be expanded without any channel overloading.
R14. The site at present has the capacity for expansion to at least
50,000 BPD. In the event that the company decided to expand, they
would be subject to a permit modification review by EPA.
S15. From Figure V—i it appears that one or possibly two alternative
sites were nearly as desirable as Eastport, differing only
slightly in each factor considered except the availability
of rail service. Because of the closeness suggested by the table,
a more complete discussion of the advantages offered by the
Eastport site over other acceptable locations should be included.
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R15. See discussion on alternatives in the FEIS, Vol. II, p. X—42.
S16. Page 298, para. 4: A more thorough compilation and analysis of
when maximum discharge levels of 3.5 mgd from the facility would
occur would be useful. For example, can a reasonable estimate be
made of how much oil will be discharged into area waters on a
weekly and yearly basis, taking into account annual precipitation
patterns, frequency and amount of ballast water to be handled, on—
site generated discharges, etc.?
R16. Maximum discharge will occur when ballast water, storm water
runoff, and process wastewater are all being discharged at the
same time. These combined discharges will produce a flow of ap-
proximately 4.4 mgd. At the permitted maximum concentration of
15 mgfL, this would be 550 pounds of oil per day or 92 gpd,
644 gallons/week and approximately 33,488 gallons or 797 barrels
per year. However, dispersion through the diffuser outfall should
minimize the visual impact of this amount of oil and grease, al-
though it will then be present in the ecosystem. The concentra-
tions in the vicinity of the diffuser should be near or below
the threshold at which animals and plants may be affected. It
is expected that the further dilution of the oily discharge by
the receiving water, as well as the fact that most animals and
plants would be exposed to the low oil levels for short durations,
should result in minimal effects on the surrounding area’s marine
biota.
The above—mentioned figures are the permitted maximum concentra-
tion of oil and grease. However, Pittston anticipated the concentra-
tion of oil and grease to be 3.7 mg/i. This is the oil and grease
concentration that will occur after treatment in the refinery
waste treatment system. Utilizing this concentration (3.7 mg/i),
the above—mentioned figures would be reduced by 75%.
S17. Page 298, para. 5: If hydrocarbon levels in Deep Cove can be
elevated as the result of a discharge from a single vessel (p. 87,
para. 3), then the discharge of up to 60 gpd would seem to have a
potential for adversely affecting living marine resources in the
area. It is likely that the intertidal zone would be more severely
impacted by the processed water discharge than would the subtidal
substrate.
JUl. See FEIS, Vol. II, p. VI—28ff.
S18. Page 309, para. 1: Arrangements, if any, being considered for the
cleaning, repair, and replacement of fishing gear damaged as a re-
suit of a spill should be discussed.
R18. See FEIS, Vol. II, p. X—Sff.
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S19. Page 309, para. 4: In view of the work of Dow, Hurst, Barry and
Yevich, it should be stated that soft shell clams will be signifi-
cantly affected by any oil spills that reach their areas. 7, 8, 9.
Rl9. See FEIS, Vol. II, Table IV—15, the stunmary of toxicity data.
See also FEIS, Vol. II, p. VI—56ff on carcinogenicity.
The soft—shell clam and other benthic invertebrates of the
intertidal zone are very susceptible to spilled oils because
they are not mobile. Soft—shell clams, which are filter feeders,
can tolerate filtering small quantities of oil, however, large
quantities of oil in water or heavy coating by oil will suffocate
these organisms. A . stated in the FEIS, Vol. II, in the section
on carcinogenicity, research by Barry and Yevich has demonstrated
the presence of tumors in soft—shell clams at the site of a large
fuel oil spill. Hydrocarbon concentrations in t’e sediments at
this site immediately after the spill were found to be very close
to those listed as toxic to bivalves. Although the probability of
a spill resulting in these conditions is reported to be low, if
such a spill did occur it could result in the occurrence of tumors
in the soft—shell clam populations of the Eastport area.
S20. Investigations performed by Canadian researchers have found oil—
induced lobster mortalities [ n pounds where oil coating did not
occur. Additionally, it has been shown that certain hydrocbrbon
fractions interfere with olfactory functions in lobsters and may
impair mating and feeding activities.
Page 313, para. 5: Forrester reported that oil, lost as a result
of the “Arrow” spill in Chedabucto Bay, was collected at depth
of up to 80 meters. Were this depth range superimposed on Passa—
maquoddy Bay it would include most of the subtidal bay bottom;
thus, few areas would escape the adverse impacts induced by a
spill.
R20. Comment noted.
S21. Page 314, para. 5: Additional information relative to the proposed
blasting during construction of berthing facilities should be pro-
vided.
R2l. The impacts of blasting during the dredging operation will be
limited to the organisms at the location of the actual blast site
and fish in the area. If the charges are properly placed (the
correct ratio of explosives to the rock being moved) fish would
not be killed further than 20 feet away.
If the person setting the charge used greater amounts of explo-
sives than what would be required, fish might be killed as far
away as 200 feet. Only limited blasting will be required and
the relatively small area of impact, coupled with the dredging
period (3—4 months) will not result in significant fish kills.
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Noise and vibration as a result of blasting is not anticipated
to be a significant problem. The depth of the water and remote-
ness of the area will further mitigate the associated impacts.
S22. Page 357: If a major oil spill were to occur in Passamaquoddy
Bay, especially during the spring to fall period, the entire socio-
economic structure of Washington County, Maine, and to a larger
extent Charlotte County, New Brunswick, would be altered to some
unknown degree. Fisheries and the recreation/tourism industries
would most likely not be profitable or in some cases even pos-
sible for some undefinable period. Losses during this period would,
in some instances, represent failure for the entire year. If an
oil spill could not be dealt with promptly and effectively because
of boundary and/or jurisdictional problems, the adverse impact
upon marine resources and associated industries would be compounded.
The boundary alignment and the location of spill contingency units
make such problems a distinct possibility.
R22. Comment noted. Procedures for oil spills involving the U.S. and
Canadian boundary are contained in: Joint Canada—U.S. Marine
Pollution Contingency Plan for Spills of Oil and other Noxious
Substances, 20 June 1974, Publ. #AD—732--895 Coast Guard, Wash.
D.C. and Annex Two Atlantic Coast short title Canuslant Contin-
gency Plan.
The operation of the refinery represents the commitment of the
community, region and State to accept the risk, however small,
that an accident could affect all or portions of the fisheries
in the area. Thus, the refinery may represent a commitment to
an industrial activity which could result in the suppression
or evel elimination of a renewable resource fishing. It is not
likely that the tourist industry in Charlotte and Washington
Counties will be significantly affected. In addition,
if the fishermen were to abandon their present lifestyle and
turn to the potentially more lucrative service industries
(which would be generated as a result of the construction of the
efinery) the fishing industry could also be eliminated.
2—17
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UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Federal Building, 14 Elm Street
Gloucester, Massachusetts 01930
February 24, 1977
Mr. John A. S. McGlennon
Regional Administrator
Environmental Protection Agency
JFK Federal Building
Boston, Massachusetts 02109
Dear Mr. McGlennon:
The National Marine Fisheries Service (NMFS) has reviewed Draft
National Pollutant Discharge Elimination System (NPDES) Permit
No. ME—Ol-77, which describes the application of the Pittston
Company for a ttNew Source” discharge for a proposed refinery at
Eastport, Washington County, Maine.
While we realize that the normal NPDES commenting period has
expired, we offer the following commentary and recommendation
for your possible use in development of the Final Environmental
Impact Statement.
Careful review of the Draft Environmental Impact Statement (copy
of previous NMFS comments attached for your information), dis-
cussions with consultants and conferences with Canadian and Maine
representatives lead us to conclude that implementation of the
proposal to construct a 250,000 barrel/day refinery at Eastport,
Maine, represents a threat to living marine and anadromous re-
sources of the area, and to that portion of the international
community which derives food and livelihood from those resources.
Limited capabilities for dealing with oil spills, the certainty
of spill occurrence, and the dubious need for additional re-
fining capacity in that area, compound NMFS concerns.
, efore ecjoxmnend against issuance of a discharge permit for
s t 1 t
Sincerely,
1i (7 ( ‘ü AL,
William G. Go don
Regional Director 2. 1977
Attachment
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U. 1. DEPARTMrI’VT C. .r COl MERC
PJatinnal Oceonic and tmosphcric drn nIstrati a
N(’ flL)NAL MARt1 I I *HIF
}:ederal Building, 14 Fin Street
G1ouc st or, Massachusetts 01930
DATE: November 29, 19Th
TO: EE - Director, Office of Ecology and Environmental Conservation
ThRU: FS - Acting Assistant Director for Scientific and Technical Services
FROM: FNE - William C. Gordon, Regional Directo ,. I.
SUBJECT: Comments on DEIS - Proposed Issuance of Federal Permits to the Pittston
Company of New York for Construction of a 250,000 Barrel/Day Oil Re-
finery and Marine Terminal - Eastport, Maine (EPA) - DF.IS #7611.03
The Draft Environmental Impact Statement, Proposed Issuance of Federal Permits to
the Pittston Company of New York for Construction of a 250,000 Barrel/Day Oil Re-
finery and Marine Terminal, Eastport, Maine, that accompanied your memorandum of
November 5, 1976, has been received by the National Marine Fisheries Service for
reviev and comment.
The st tcmeiit has been reviewed and the following com:nents .irc offered for your
consideration:
General Comments
In our opinion, the DEIS lacks sufficient information to accurately evaluate
probable impacts of the proposed action on living marine resources and on the
public which derives its livelihood from those resources. It has frequently been
concluded by investigators that despite the application of all feasible precautions,
oil spills will occur.’ 2 34 Even so, the DEIS does not identify areas and marine
resources that may be impacted by spills, nor is there a discussion of conti ’gency
plans for containment, clean-up, and disposal of spilled oil. The probable
effect of spills on fishing gear assembelages and ancillary equipment likewise
is not addressed. Other environmental aspects that should have received attention
include the differing impact potential of various crude and refined petroleum
pro iicts and their rate of deterioration or persistence under given weather
conditions. Also, it could have been noted that tidal and current characteristics
of La.samaquoddy Bay would ensure that any spills of oil would be widespread
and dispersed throughout the water column.
It is our understanding that State of Maine permits for this prolect have been
conditioned to the effect that the applicant must SCCUTC transit rights through
Canadian waters. This, to our knowledge, has not been acc iplished. Consequently,
the subject DEIS may be somewhat prenuture.
3—2
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2.
While we believe that the DEIS could more adequately discuss several significant
environmental issues, it is perhaps more important that we seriously question
whether an oil refinery can be made compatible with the environmental factualjtjes
of this particular area.
Specific Comments
INTRODUCTI ON
Page 1, para. 5 -- The significance of “conditioned approval”, especially if it
applies to passage through Canadian waters, should be discussed in more detail.
Also, we assume there is little likelihood that federal permits will be issued
unless the necessary state permits are first secured by the applicant.
DESCRIPTION OF EXISTING ENVIRONMENT
Socio-Economic Characteristics
Economy
Page 35, paras. 1 and 2 -- Using the figures presented in these paragraphs, it
appears that about 36 percent of the work force in Charlotte County, New Brunswick
is engaged in the fishing industry. The fact that over one-third of the work
force is directly dependent upon marine resources is significant and should be
stressed.
Page 35, para. 4 -- It should be noted that there is an intertidal fishery for
periwinkle in the bay area, and that an extensive fishery for herring (over 300
wiers) is concentrated in the vicinity of Eastport, Maine.
Aquatic Resources
Marine Hydrology
Page 66, para. 2 -- The State of Maine permit requires that the applicant’s piers
(and the associated oil containment facilities) be in areas where currents do not
exceed 1.0 knots. Work done by Miller, Lindeniuth and Altmann for the U.S. De-
partment of Transportation, and by McCracken for the U.S. Environmental Protection
Agency (in press), indicate that waves 0.3 to 0.6 meters high having a length
of 2.7 to 9.1 meters and a period of 1.5 to 3.0 seconds can cause inshore boom
systems to fail at current velocities of less than 1.0 knots. 5 In the case f
offshore booms, calm water trials revealed that a current velocity of 1.0 knots
was the failure point, while rough water failures occurred at approximately 0.7
knots. 6
In view of the preceeding, it would appear desirable to include a more detailed
map of current velocity profiles and a more thorough description of the piers
that have been designed to comply with the state’s requirements.
Page 75, para. 2 -- In view of the important inshore and intertidal fisheries
(described on pages 105-116) it would be helpful if major components of the
referenced drift were identified.
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ECOLOGY
Aquatic Ecology
Page l05 ra.4 -- Using only the economic value of clams to determine their
“worth” is misleading since their value as a source of food for other marine
fauna or, in other words, their role in the marine food web, is not taken into
account.
AIR RESOURCES
Climatology
Pages 134-144 -- It would be worthwhile to present a comparison of the rate at
which weather deteriorates, and deteriorated weather persistence, with transit
times of VLCCS through the Head Uarbor Passage. Also, an attempt to analyze the
relationship between fog frequency, tidal cycles, and the applicant’s assertion
that there will be no tanker traffic when visibility is less than one nile wou]d
be informative.
DESCRIPTION OF THE PROJECT
Description of Plan
Marine Transport System
Page 238, para. 1 - - From the figures presented in this section, it appears that
any accident with the crude oil unloading/loading lines would result in a minimum
spillage of approximately 8,300 gallons. It would be helpful to have such a
spill put in the context of the expected capacity of the boomed area and clean-up
capabilities.
ENVIRc 4MENTAL IMPACTS OF ThE PROPOSED PROJECT
Aquatic Resources
Impact of Routine Refinery flischarges on Marine Water Quality
P-ige 298, para. 4 - - A more thorough compilation and analysis of when maximum dis-
charge levels of 3.5 mgi from the facility would occur would be useful: For
exampic, can a reasonable estimate be made of how much oil will be discharged into
area waters on a weekly and yearly basis; taking into account annual participation
patterns, frequency an w4lount of ballast water to be handled, on-site generated
discharges, etc.?
Page 298, para. S -- If hydrocarbon levels in Deep Cove can be elevated as the re-
sult of a discharge from a .;ingle vessel (page 87, para. 3) , then the discharge
of up to 60 gpd would seem to have a potential for adversely affecting living marine
resources in the area. It is likely that the intertidal zone would he more
severely imp icted by the processed water discharge then would the subtidal substrate.
3—4
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Oil Spills Due to Tanker Accidents
Potential Effects of a Spill
Page 309, para. I -- Arrangements, if any, being considered for the cleaning, re-
pair, and replacement of fishing gear damaged as a result of a spill should be
discussed.
309, para. 4 -- In view of the work of Dow, Hurst, E arry and Yevich, it should
be stated that soft shell clams will be significantly affected by any oil spills
that reach their areas. 7 ’ 8 ’ 9
Investigations performed by Canadian researchers have found oil-induced lobster
mortalities in pounds where oil coating did not occur. ’° Additionally, it has
been shown that certain hydrocarbon fractions interfere with olfactory functions
in lobsters and may impair mating and feeding activities.”
Ecology
Page 313, para. 5 -- Forrester reported that oil, lost as a result of the “Arrrw”
spill in Chedabucto Bay, was collected at depths of up to 80 meters. 12 Were
this depth range superimposed on Passamaquoddy Bay it would include most of the
subtidal bay bottom; thus, few areas would escape the adverse impacts induced by
a spill.
Page 314, para. S - - Additional information relative to the proposed blasting
during construction of berthing facilities should be provided.
RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF THE ENVIRONMENT AND MAINTENANCE
AND ENHANCEMENT OF LONG-TERM BENEFICIAL USES
Page 357 -- If a major oil spill were to occur in Passamaquoddy Bay, especially
during the spring to fall period, the entire socio-economic structure of
Washington County, Maine, and to a larger extent Charlotte County, New Brunswick,
would be altered to some unknown degree. Fisheries and the recreation/tourism
industries would most likely not be profitable or in some cases even possible for
some undefinable period. Losses during this period would, in some instances,
represent failure for the entire year. If an oil spill could not be dealt with
promptly and effectively because of boundary and/or jurisdictional problems, the
adverse impact upon marine resources and associated industries would be compounded.
The boundary alignment and the location of spill contingency units make such
problems a distinct possibility. In our opinion, the proposed action carries an
inordinate threat to marine resources of the area, and to long-established
Canadian and United States industries that are dependent upon those resources.
FMLudwig/MFBoussu cc: F53(3). FNE, Milford EAB
3—5
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Literature Cited
1. U.S. Department of the Interior, Office of Economic Analysis.
1973. Draft Environmental Impact Statement: Deep-Water
Ports.
2. U.S. Army Corps of Engineers, Norfolk, Virginia 23 1O. 1976.
Proposed Final Environmental Impact Statement: Hampton Roads
Energy Company’s Portsmouth Refinery and Terminai, Portsmouth,
Virginia.
3. Porricelli, J.D., V.F. Keith, and R.L. Starch. 1971. Tankers
and Ecology. Transictions: The Society of Naval Architects
and Marine En i eers. Vol. 79, pp. 169—221.
4. ______ . 1974. Summary of Physical, Biological, Socio-
Economic and other factors Relevant to Potential Oil Spills
in the Passamaquoddy Region of the Bay of Fundy. Fisheries
Research Board of Canada, Technical Report No. 428, pp. 229.
S. McCracken, W.E. 1976. Performance Testing of Selected
Inland Oil Spill Control Equipment. In Press. Office of
Research and Development, U.S. Environmental Protection
Agency, Cincinnati, Ohio 45268. pp. 112.
6. Miller, E., W. Lindenmuth, and R. Alrmann. 1973. Analysis
of Lightweight Oil Containment System Sea Trials.
7. Dew, R.L. 1975. Reduced Growth and Survival of Clams Trans-
planted to an Oil Spill SiLt . Marine Pollution Bui.ietin.
6: 8: 124—125.
8. Dot’, R.L., and J.W. flurst, Jr. 1975. The Ecological, Chemi-
cal and Histopathological Evaluation of an Oil Spill: Part 1.
Ecological Studies. Marine Pollution Bulletin. 6: 11: 164—
166.
9. Barry, M., and P.P. Yevich. 1975. The Ecological, Chemical
and Histopatholog [ .:al Eva]uation of an Oil Spill: Part 3.
Histopat1iolo tcal Studies. Marine Pollution Bulletin.
6; 11: 171—173.
10. t1rr tt, i).J. 3976. Personal Communication. Fisheries
Research Board of Canada, Biological Station, St. Andrews,
New 1 runswick, Canada
11. Todd, 3.H., 1). Engstrom, S. .1a obson, and W.O. McLarney.
1972. IntroductIon to Environmental Ethology; Preliminary
Comparison of Sublethal ‘fheriaal and Oil Stresses on the
Social liehavior of Lobsters and Fishes from a Fresh—water
and Marine Ecosystem. (unpublished manuscript.) Woods
Hole Oceanographic Institution, Report No. 72—42, 104 pp.
3—6
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12. Forrestor, W.D. 1971. Distribution of Suspended Oil Particles
Following the Grounding of the Tanker Arrow. Journal of
Marine Research. Yale University. 29: 2: 151—170.
3—7
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Response to Comments by W. Gordon,
U.S. National Marine Fisheries Service
See following letter from the Corps of Engineers requesting
clarification on the Marine Fisheries Service recommendation
against issuing the NPDES permit and the Marine Fisheries
Service response to that letter.
Also see responses to questions by S. Galler, U.S. bepartment
of Commerce.
3—8
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DEPARTMENT OF THE ARMY
NEW ENGLAND DIVISION. CORPS OF ENGINEERS
424 TRAPELO ROAD
WALTHAM, MASSACHUSETTS 02154
REPLY TO
ATTENTION OF
NEDOD—R—20 27 September 1977
Regional Director
National Marine Fisheries Service
Federal Building, 14 Elm Street
Gloucester, Massachusetts 01930
Gentlemen:
This letter is in reference to the Pittston Company’s application for
a proposed oil refinery project at Eastport, Maine.
On 22 February 1977 we received your recommendation to deny that
application. We are inclosing Volumes I, II, III, IV of a 6 and 12
September 1977 draft of the Environmental Protection Agency’s proposed
final Environmental Impact Statement. Considerable new information
baa been included both in the main text and in sections on comments
and responses. In order to properly evaluate your recommendation, we
ask that you review this new material and provide us with your comments
on the project in as much detail as possible.
The Corps’ decision on this most controversial project will be made
at the Washington level by the Chief of Engineers or higher. We will
make our recommendations on permit action to the Chief’s office at the
end of the 30 day public response period following publication of the
final EIS.
Va sure you realize the difficult weighing and balancing process that
faces us in arriving at our recommendation. As such, we need as much
detail as you can give us to properly reflect the views of your
service. We would appreciate receiving your comments within two
weeks as EPA would like to include them in the final EIS.
If I can be of any further assistance, please contact me at your
convenience.
Sincerely yours,
JOHN P. CHANDLER
Colonel, Corps of Engineers
Division Engineer
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0•
UNITED STATES DEPARTMENT OF COMME e!
I J J National Oceanic and Atmospheric Administration
NATIONAL MAHINE FISHERIES SERVICE
Federal Building, 14 Elm Street
Gloucester, Massachusetts 01930
October 21, 1977
Col. John P. Chandler
Division Engineer
Department of the Army
Corps of Engineers
424 Trapelo Road
Waltham, Massachusetts 02154
Dear Coloi.el Chandler:
The National Marine Fisheries Service has reviewed the documents that
accompanied your letter of September 27, 1977, regarding the application
by Pittston Company for an oil refinery at Eastport, Maine.
Comments regarding Public Notice No. NEDOD-R-25-76-367 were provided your
office in letters dated November 5, 1976, and February 22, 1977. Perusal
of the draft FEIS of September 1977, for the proposed refinery has not
given us cause to change our basic position relative to this project:
Namely, that we are opposed to permit issuance.
Our opposition is grounded in concern for the biological resources of the
area, their supportive environments, and those industries, particularly
fishing and tourism, that depend on the maintenance of healthy environments
and resources. We appreciate the difficult decision-making process that
you are faced with, and concur with your elevation of the final decision
to higher authority. From the standpoint of concern for marine resources,
however, we are compelled to maintain our negative stance for the following
reasons:
1. The FEIS, in several instances, references the somewhat unique aspects of
Cobscook and Passamaquoddy Bays, of Head Harbor Passage, and their
associated resources. Frequently, the document identifies the area as
being productive, pristine, and diverse or unique in marine flora and
fauna. We agree.
2. At present, there is no significant vessel traffic or any movement of
products that pose a major threat of environmental degradation to this
“somewhat pristine” area.
a. NOV .‘i
3—10 ( i
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2.
3. We believe it is generally agreed that oil spills will result, and that
these spills will have an adverse impact on biological resources. Only
questions of frequency, magnitude, duration, and severity are indeterminate.
In this vein, we note the U.S. Army Corps of Engineers interim report,
“Atlantic Coast Deep Water Facilities Study”. This report states that:
“A natural access channel, with a depth averaging over 120 feet, is pro-
vided by Head Harbor Passage and Friar Roads. However, its approaches
are winding: its currents extremely difficult to judge and the area has
the highest number of fog days along the coast.” Our concern over the
frequency and severity of adverse impacts to biological resources is
heightened by the presence of these natural forces and their potential
for contributing to spills.
4. Regardless of the delivery system used, the facility will be allowed to
discharge petroleum fractions into an area that does not now receive such
contaminants with consistency or in quantity.
The NPDES permit for the subject facility allows the discharge of 15 mg/l
of oil or, theoretically, up to about 26,600 gallons per year.
5. The people of both Charlotte and Washington Counties rely heavily on the
industries of fishing and tourism. A refinery operation would seem to be
largely incompatible with these industries, especially if a major spill
occurred, but possibly as a result of chronic pollution as well.
In view of the above, and as a result of our unresolved concerns regarding
potential adverse impacts upon living marine resources and their environments,
we continue to recommend that a permit for the proposed action be denied.
We appreciate the opportunity to again comment on this matter. If you wish
us to expand further on any of our points, or to discuss the issue, please
c n act my office or the Environmental Assessment Branch.
Sincerely,
William G.
Regional Di
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/ , UNITED STATES DEPARTMENT OF COMMERCE
The Assistant Secretary for Policy
. Washington, D.C. 20230
‘ ‘U Q
7 D C 1976
December 3, 1976
Mr. John A.S. McGlennon
Regional Administrator
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
I make reference to the draft environmental impact statement
prepared by your agency in connection with the issuance of
Federal permits for the construction of an oil refinery and
marine terminal at Eastport, Maine. I note that the Federal
Energy Administration prepared that part of the draft EIS
pertaining to the need for additional domestic U.S. refinery
capacity.
My purpose here is to join with the FEA in expressing the
need for additional oil refining capacity on U.S. soil,
particularly along our East Coast which now relies so
heavily upon foreign product imports for its oil needs.
This particular refinery would be “fuels oriented”; that
is, designed to maximize production of distillate and
residual fuel oil, the two products most critical to the
area’s needs.
Even though a refinery such as this would operate on foreign
crude oil, its advantages as compared to product imports
(both from an economic and security viewpoint) are quite
apparent. There is also a possibility that substantial
amounts of domestic crude oil might eventually be produced
in the area and be available for refining. This would depend
upon the degree of success obtained in the development of oil
and gas deposits off the Atlantic Coast.
4—i
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—2—
Of course, our support for the actual siting of any
particular energy producing facility would be based on
the assumption that all relevant environmental consid-
erations would be taken into account, both from the
point of view of problems associated with a particular
site and from the point of view of the availability of
alternate sites.
Sincerely,
F.S.M. Hodsoll
Deputy Assistant Secretary for
nergy & Strategic Resource Policy
Response:
Comments noted.
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UNITED STATES DEPARTMENT OF COMMERCE
The Assistant Scr.t.ry for Science and T.chnolog
W.sh nQton. D.C. 20230
January 14, 1977
Mr. John A. S. McGlennon
Regional Administrator
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
This is in reference to your draft environmental impact statement
entitled, “Proposed Issuance of Federal Permits to the Pittston
Company of New York for Construction of a 250,000 Barrel Per
Day Oil Refinery and Marine Terminal - Eastport, Maine.” The
enclosed comments from the National Oceanic and Atmospheric
Administration, National Ocean Survey, were received subsequent
to our letter transmitting Departmental comments dated December
13, 1976.
Thank you for giving us an opportunity to forward these additional
comments for your consideration, We hope they will be of assis-
tance to you.
Sincerely,
ji
Deputy A istant Secretary
for Environmental Affairs
Enclosure - Memo from National Ocean Survey, January 4, 1977
(Response: Comments noted & text
changes made. A sonar survey of
the proposed channel route to
prove it to a depth of 75 ft MLW
will be done prior to passage of
L _tankers.
5—i
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1’_\ U.S. DEPARTMENT OF COMMERCE
National Oc.anic and Atmospheric Administration
NATiONAL OCEAN SURVEY
Rockvilla, Md. 20852
C52/CWC
JAN 4 1971 5 7
TO: William Aron
Director
OPfice of Ecology and Environmental Conservation
FROM: Go’s-don L i i i
Deputy Director
National Ocean Survey
SUBJECT: DEIS #7611.03 - Pittston Company Refinery, Eastport, Maine
The subject statement has been reviewed within the areas of NOS respon-
sibility and expertise, and in terms of the impact of the proposed action
on NOS activities and projects.
The following coninents are offered for your consideration.
Under “Marine Hydrology (page 51), reference is made to NOS chart
No. 13328 and the “75 foot plus” deep natural channel. While NOS surveys
of this area are quite old, they do not prove a 75 foot plus channel.
The most recent NOS surveys were by wire-drag methods in 1918 and by hand-
lead line in 1861. The 1918 survey proves the charted deepwater passage
from East Quoddy Head to Shackford Head to be at a depth of 44 feet. NOS
recoim ends a new wire-drag survey before 150,000 DWT vessels are permitted
to enter this channel. The Canadian Hydrographic Service (CHS) surveyed
this area in 1948. Since most of this area is Canadian and their surveys
are more recent, CHS coninents should indicate the adequacy of existing
surveys.
Under “Current and Tidal Patterns in Area” (page 59), the statement regarding
an annual increase of 0.01 feet in tidal range at Eastport is not correct
without qualification. NOS records show that the annual mean tidal range
has varied from a low of 17.52 feet to a high of 18.58 feet over the 20-year
period, 1930 through 1949. The record does not show an annual increase
of 0.01 feet each year over the 20-year period. The accepted mean tidal
ranqe value at Eastport for the period 1941 through 1961 is 18.2 feet.
NOS reconnends a chart or graphic display to depict the maximum and minimum
ranges and percentage of ranges above and below specific values.
5—2
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FEDERAL ENERGY ADMINISTRATION
REGION I
ISO CAUSEWAY STREET
BOSTON, MASSACH(JSErTS 02114
November 5, 1976
Morgan R. Rees, Chief
Regulatory Branch
Corps of Engineers
424 Trapelo Road
Waltham, MA 02154
Dear Mr. Rees:
We have reviewed your public Notice NEDOD—R-25-
76-367 requested by the Pittston Company to con-
struct and maintain marii e petroleum handling
facilities for a 250,000 barrel per day oil
refinery.
Due to New England’s dependency on foreign fuels,
anything that can reduce this situation must be
utilized. Therefore we are in support of this
project.
Thank you for the opportunity to comment.
Sincerely,
Robert E. Philpott, Director
Energy Conservation, Environment
& Resource Development
Response:
Conunents noted.
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FEDERAL ENERGY ADMINIs1’R 1 vr I ON
WASIHN(;TON, D.C. 20 161
December 1, 1976
OiF!Cj OF Tfl ,;lIN;sr r
Mr. John A. S. McGlennon
Region I Administrator
Environmental Protection Agency
JFK Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
It has been the policy of the Federal Government, through
several administrations, to encourage the construction
of refining capacity to meet domestic needs within our
own borders as a matter of national security. Until
1960, U.s. refining capacity was adequate to meet
domestic demand. However, after 1960, the growth in
refining capacity slowed and lagged behind demand. By
the year 1973, our product imports totaled 3 million
barrels per day, or 17 percent of total requirements.
Changes in Federal policies in 1973 caused a numLer of
refinery expansions to go forward, and in 1976 alone,
about 900,000 barrels per day of new capacity will go
on stream. Imported refined products have dropped from
the 1973 peak to slightly less than 2 million barrels per
day this year. Although this is encouraging, still more
capacity will be needed to back out imported products,
which are still quite high, and to take care of future
demand growth.
‘1e are all now familiar with the serious problems created
by our dependence on foreign produced crude oil and the
monumental task the nation must now undertake to correct
this condition. To become overly dependent on foreign
refineries could be equally as dangerous.
The region with the most severe deficit of refining
capacity is the cast coan , hcre refining capacit y in
1975 rcpre cntcd only about 30 pcrcciiL of requi.rcuicnLs.
This situation is even more pronounced for the New England
States, with virtually no regional refining capacity.
7—].
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2
My sta [ f has prcparcd a nc eds analysis which discusscs
these points in rnorc dctail for inclusion in the Environ—
mental Impact Statement for the Pittston Company’s
refinery project. It seems clear to us that increased
refinery capacity on the east coast, and particularly
in the New England area, is in the national energy interest.
Sincerely,
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Testimon yCivefl by Mr. J.L. Reed, USFEA, at the
D ’ c. 3, 1976, Public Hearin
MR. REED: Thank yc’u very much, Mr. Chairman. It
was approximately two years ago thiz date that you
appeared in Washington in front of a hearing that I was
chairing. The subject of the hearing was the problems
confronting people trying to construct refinery capacity
in this nation today. At that time you talked about
a committee that had been formed in this region of the
country, composed of members from the various federal
agencies that had an interest in refinery location or
would at least be acting on a permit. I think it was
that task force in fact that pretty much did the work
on he environinental impact statement that has been
released in draft form. I would want to just take this
minute to commend your efforts. I think that the task
force was constructive, I think it was fair and open.
and that the work was done in a timely manner, and I
think that the task force members hou1d he ccmplimented
4_•_. .._ .; 4-
My main task today is to transmit to you a letter
from Frank Zarb, the Administrator of the Federal Energy
\dministration. I would like to read it into the record
nd then I would like to summarize just a few points.
Th l t r is a little over a page. It ±s a ressed
t O you, • r. Cha rman.
It. ‘ s eer the policy of the federal government
-------
38.
through several administrations to encourage the
construction of refining capacity to meet domestic
needs within our own b3rders as a matter of national
security Until 1960, U.S. refining capacity was
adequate to meet domestic demand, however, after 1960
the growth in refining capacity slowed and lagged
behind demand. By the year 1973, our product imports
totaled 3 million barrels per day, or 17% of total
requirements.
“Changes in federal policies in 1973 caused a number
of refinery expansions to go forward, and in 1976 alone
about 900,000 barrels per day of new capacity will go
on stream. Imported refined products have dropped from
the 1973 peak to slightly less than 2 million barrels
per day this year. Although this is encouraging, still
mare capacity will be needed to back out imported
products, which are still quite high, and to take care
of future demand growth.
‘We are all now familiar with the serious problems
created by our dependence on foreign produced crude oil
and the monumental task the nation must now undertake
to correct this condition. To become overly dependent
7—4
-------
39.
on foreign refineries could be equally as dangerous.
“The region with the most severe deficit of refining
capacity is the east coast, where refining capacity in
1975 represented only 30% of requirements. This
situation is even more pronounced for the New England
States 1 with virtually no regional refining capacity.
“My staff has prepared a needs analysis which
discusses these points.in more detail for inclusion
in the environmental impact statement for the Pittston
Company’s refinery project. It seems clear to us that
increased refinery capacity on the east coast, and
particularly in the New England area, is in the national
energy interest.”
That is signed by Frank Zarb.
I wc’- 1d like to take just a few more minutes to cover
a few points pertaining to the refinery in this region.
I will be brief because I can see already that many of
the points I am going to make have been made and will
be rnade over and over again today.
There are several things that a person that has
experience in the oil industry or with the oil business
looks for today in the design and construction of a new
7—5
-------
40.
refinery. Some of the things that stand out are
things such as he would wish it to be a large efficient
plant taking advantage of the economy of scale. He
would like for it to have access to deep water so that
the VLCCs can be used and transportation costs would
be a minimum. He would like to see the refinery have
the ability to make low sulfur fuels that are needed
for the environmental standards that are predominant
throughout the country today. He would like to see
an orientation away from the high gasoline yield so
traditional in U.S. refineries more towards the fuel
oil yield. He would like to see the utilization of
modern techniques to mitigate against environmental
impacts. And the industry term for this a clea i
refinery. All of thczc char cteri tLc a a part c
the proposed Pittston project.
There are some other important factors th t should
be considered, aside from the particular esign or
construction or characteristic of the ref in y. th
are m ore or less inherent tecause of this egion. :
n3ted in Mr. Zarb’s letter. Ne Er : .d i - 5enti .U’f
‘oid - f refiner’ pacity The cc .. ct
-7. ..
-------
41.
refinery means security. When a refinery is built,
there is crude oil inventory in the form of tankage
that goes with it. There is also product tankage
inventory. There is also a number of tankers on the
open seas carrying crude oil on the way to the refinery.
Adding all this oil together gives about 60 or maybe
even 70 days supply of oil, which at time of an embargo
or some other critical international situation would
be very valuable.
Secondly, the construction and operation of a refinery
means jobs. It is an economic stimulus. For the initial
construction years you are talking about 2,000 to 3,000
jobs. That is direct jobs. After the refinery is con-
structed and operating: in other words, permanent, long—
term, you are talking about a fe hur 1 d ed jobs directly
with the refinery, and practically a thousand jobs
indirectly. That provides economic stimulus, very
significant to the area, significant within the region,
and..it represents a plus for the United States as a whole..
One other point that I feel obligated to make: we
are encouraged that the applicant in this particular
situation is an independent oil company. The entry of
1—7
-------
42.
a new person or an independent into the refining
business is a real plus for the consumer, it enhances
competition in the industry, it makes for a healthier
industry, and it is just a little bit better for all
of us.
The points that I have made here, and several others,
are explained in more detail in various parts of the
draft EIS for the Pittston project, particularly in
the need for the project section. The FEA has forwarded
some additional comments and edits for the need section
by way of a letter to Mr. Wallace Stickney, dated
November 26. 1976. We believe the material transmitted
clearly establishes the substantial benefits accruing
from a refinery ccnstruction in this area, and we
commend it to your attention.
That will conclude my statements, and I will leave
Mr. Zarb’s letter with you, Mr. Chairman.
Response:
Comments noted.
7—8
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JAN 131977
FEDERAL ENERGY ADMINISTRATION
REGION I
ISO CAUSEWAY STREET
BOSTON, MASSACHUSETTS 02114
MEMORANDUM FOR KEN WOODCOCK, DIRECTOR
ENERGY POLICY OFFICE
FROM: ROBERT W. MITCHELL
REGIONAL ADMINISTRATOR, REGION I
SUBJECT: DRAFT ENVIRONMENTAL IMt ACT STATEMENT
PITTSTON COMPANY OIL REFINERY, EASTPORT,
MAINE
We have reviewed the above mentioned Impact Statement. The
only comments we have pertain only to those sections which
FEA authored. These comments are a consensus of both the
National and Regional Offices who developed the material.
The changes were informally sent to Wallace E. Stickney (EPA)
by John K. Freeman (PEA) November 26, 1976. Therefore, we
would like to have these changes formally sent to EPA via
the Environmental Impact evaluation procedure.
1. The PEA was one of many agencies that assisted EPA in
the writing of this document. PEA had the responsibility
for providing the economic needs evaluation for the pro—
ject. Attachment I Balance of Payment Impact and Con-
sumer Price Impact should be inserted in both VoluxneII
page 202 and Volume III page J—4 preceding the section
Current Situation .
2. Page 12, Volume I — last line of first paragraph — add
the words “increase in” after 1985.
3. Page 202, Volume II — first complete paragraph, the ninth
line — delete the complete sentence starting with the
word “Crude oil”.
4. Page 202, Volume II — delete the entire third complete
paragraph and add the newly submitted material.
5. Page 203, Volume II — second paragraph from the bottom of
the page. The last sentence should be rewritten to read
“Meanwhile, residual fuel oil was priced to compete with
coal but had a decided advantage over coal in that it
could be more easily transported and stored. It also had
marked air quality advantages over coal.”
I
8—1
-------
2.
6. Page 204, Volume II second paragraph fourth line — change
the word “commitments” to read “firm plans”.
7. a. Page 205, third line the words “and unleaded gasoline”
should be deleted.
b. 4th paragraph Table IV—2 — Change to Table IV-3.
8. Pages 206 and 3-9 - change Table IV—2 to IV-3 and Table
P1-3 to IV-4
9. Pages 207 and J-9 - change the two references to Table IV—4
to IV-5
10. Page 208, last paragraph — change reference to Table IV—5
to P1-6
11. Page 209 — change Table P1—S to P1—6
12. Page 210
a. change Table P1-5 to P1-6
b. Third paragraph — change reference to Table IV—6 to
P 1— i
c. Fourth paragraph - change reference to Table P1-7 to
IV—8.
13. Page 211 — change Table IV—6 to IV—7
14. Page 212 — change Table IV—7 to IV—8
15. Page 212 — There is no indication of where the end of the
presentation occurs. It is suggested that the sentence
“The complete FEA Report with technical sections is
printed in Volume III Appendix J”, be added after the last
paragraph at the bottom of the page.
16. Volume III, page 3—4
a. top of the page - delete the entire sentence which be-
gins with “Crude oil...
h. second paragraph — delete the entire paragraph and add
the newly submitted material.
17. Page 3—5, second paragraph from the bottom — the last sen-
tence should be rewritten to read “Meanwhile, residual fuel
oil was priced to compete with coal but had a decided ad-
vantage over the coal in that it could be more easily trans-
ported and stored. It also had marked air quality advan-
tages over coal.”
&- 2
-------
3.
18. Page 3-6, third paragraph last sentence — delete the
words “and unleaded gasoline”.
19. Page 3-8 - change the references from Table IV-2 to IV—3
20. Page J—12
a. first paragraph under “For 1985” — delete “see attached
description”
b. second paragraph — delete “see attached description”.
cc: J. Adger, FEA Washington
Response: Coniments noted.
Entire needs section has been
redrafted.
8—3
-------
TEST i r•;or iv
bY
flObERT U, ItITCrIELL
r
t EGIOi AL ILM IfIISTRATOR
FEDERAL EI;ERGY ADU ISTRAT1ON
ON
IJRAFT LIS
DECE1 . ER .,, E 75
: r j ;;T rr TT tiEJD ‘ r”’ r
t hi . .., i ,J, ur r 1i I I ri I r ..,L. I iUd
i L Y 1,1 IE ,i E.3J 1 t). ThIS E iOi hILL EEi,EFI1 OT O LY
- .. çr • = ‘ .——- ( -IIr)r , r’ — I ‘‘ r •
,.j i :h. .. .LCUr IT’ U L L ...U rL\ bi.i h . . . . . )O Fi OiI 1h JbS Jzi- iE1i
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,11r, JUT. CiF iiT ATI.j 1 .AL POLICY TO CVIiJE LÜ ESTIC REFI 1 :ERY
Ci PACiI SbFFICIEi i TJ 1 EET IJCR ASE U. S E; iA s FO PETROLEU 1
3bLuTS,
—. r r . , • fl — .-.— r- ‘tj y - . r • , nii ’ r’T T r’ ‘ 1. “r r J —-, ‘
- —I Ii r :u L I 1i. Li -I i J H: ..IIiL rIS.tJILLI iu hbc hLJ, In_.
,½ k.PUFI ti; ThE h tt)ii,iL Ei.LR i\ SI iUi i lUil WITrI
i c.Sr .i TO PLI OLELSI S1.t L’i A i iiE, 1 , AiUJ T E i;EEiJ FO A
- • r s r.-i r . “‘jT r’ .- vc’ T Tt:
r Lr I i. \ I I I. i Lt4 Li eLhs.i .’ . It i hLs J I 1.) 1 , iLUIt1 Lhlt I Li) iii t
L’r’. ’s JR; Fi L 1 4V u; ;LI41 L h-. ACT ST 1E -;E 1 ;T U A FRQ :OS [
r . ¶ - — .-r • . .- . . • . y
‘L1 f LELti.i .r I Li. \ I L/\ TP’JR I , I 1 t
8—4
-------
2
i I )E WUF TO TEAT [ EP3 T hAS DEEIJ SUIflTTEU TO THE EPA.
I. . . - r - p ‘- r- ‘ ‘ —
(,. i I SW I1 Ii TUuA; FO 1 Tr, . I tU\VL COPIES AVAILA LL
hJr , ThL F’t LL t 1t) UTriLi li TL :SiLt) PERSOnS ) THE ADDEUDU 1J
LAL 1LQF P ,L, Lj:;? Ci A 1 L PR ‘ FIPACL SHOULD
ç J L. -,.z - :4J7
L I SE TEij Ii
‘-.• j 1 C T1]I” jI.. _____ 7 t’- - r Y
1- Lt 1-E - 3L 14 U
r Li y +TtJi . 1HIS Auij: JUii SHOULD BE EVALUATED S PART
Or 1HL LUr PLL1E iiOLU Eil.
8-5
-------
FEDERA I EN rfGv t I) { I ‘ )STP.ATION
REGION I
ISO CAIfSEWAY SIRtET
BOSTON. MASSACII%.’SETiS 02114
The following four pages have been submitted by
FEA as an addendum to the naterial which they
provided for the Draft Environi ental Impact SLttE-
ment. These sections ( 2 iance f ?ay ent I .; ct
and Cons er Price Imp t ) should be inserted in
both Volume 11 page 202 preceding the sectici
Current ituatio and Volunc 11 page J—4 pic-
ceding the secti Current Si io . Thi! ad :-
d sh i be eva!uatec a ar ef the cc p :E
document.
8—6
-------
_____ c ‘ct
Ir& g2ncra.i, t ’ir net say . ‘jz 3n ..O1 lar OU iC. .. 1 . pLuxi atcs
the va . uc t cc.i to crucc o l -e inc in forei locations
plus t:;e cost of ;hi p nc prc ducz.s over cru to
porLs in this r.itcd Stctt s . For N : rnzj! nd this savings is
cauiv .a ez:t to the difference bctwe n th delivered cost
of crudc oil at Eastp rt, thc and th delivered cost of
the equivalent a ount of products a: East Coast .crts such
as Bcston.
Th factors and a5su ption ;: deU to calculate a
net flow cf f ds it; ct as a rcs t of itic r. sz
Coast rcfini c 1 pacity arc reason ibly similar to thcrc’
found in t c !‘ace Study . Usinc infor :ation fror that Stuc ,
thc rcd c:rt of c: de ci to rEt :ort : :.i.c
with the c licr :d cost cf prc zts frem thc ha s,
arid Rottcr n: ;, . Sec Tibic 2. These thrce
foreign rcfi i cer.tcrs are rc rcsentative of prcha ie
Jppliors Cf !nct Co t rkets if suff.icier.r c ’stic
rce!inin- c. r.3c±t.- is l c :ina. n ord’ r to sirtt)lifv ca1 —
eu) tie ;, it wj j thrt• .’ r’t ::i::. c: t r
would r are the tart co i:;t in, o I : irket equally.
‘i’ht ‘.I:i. C” ‘ .i iv • UI;.! r: i :; . i c n “f !‘•: j P 4(i •. t -n •
I:.: , ‘. .; , . • r t 1 , p . 3.
8—i
-------
T \JLC 2
cc :r;::: ; or p; • ?CT c ’: :s
Totc l relivered
Prc Juct Cost
R har as $17.7S
Rotterdaa 18.58
Curacao 17.82
Average 18.06
De1iv Cru e Cost 16.02
(Ea rr, . ic)
Difference 2.04/bbl.
1980 !c 1rs
1. :r :t rr’ :rc ry ..z
9 c:c r c -” cvc r
outpt is a c :i!:.:. : .y 250,000 >: .9 = 22 ,O00 F. , or
82 million arre1 cr year. If this cuar tity ‘ rc bc’ ; t
!rc- t t cc for. i rt firi cc crs intc . i r’f
rcfir d csti tl-’, the dif rcr.c-c in th’ otfi of
would 5c c’:s >. o: 1G ii:c
S1: t iri1ar r f cric - wc, ]d rrc Jucc a nc s vingr i:
doihir o t fi r f x 6 or v;ro:.:ii; t-c1y 1 bill io
annually.
8—8
-------
—3—
CO S U i’ . PR1C 1ir
A si nific,i: t. rc 1uc’ ion in t!it’ price of oil products
in New i:ncjla: is unli ;e1y to result from the construction
of a single rcfi: ery in the area. It is prob blc that, with
one refinery, prc uct :ice will c .her be unaffected
or will decline by less than O. per gallon on the aver ige.
The O.5 per gallon figure represents the differencebetween
the cost to a iddle Atlantic rcfir.cr and a Gulf Coast
refiner arke:ing in ew tngland. (This is discussed ore
fully in the eccnc ic 3CC:ion. 1
Factors that wou1 tend to reduce product prices are
related to the supply £itu tion and r.tarkct co: pctition.
I . rcfincry, y inc:c the cupply cf jrcductz
to New L lan& içh cause scmc of the i e:- pricc
t:cc t c 5;pThcc . c cr, the c b1c ::c.
rcdicton p c•b: y .‘ no c•c fcr t a: t :c tnc:’c:—
tation cost s •inqs betwcc: cw n:;13 i a: the cio cr
market area. hat is, cutnut from the refinery could al ;o
bc sole in thc :i ! n- t ic reqio:., so ref i ery ce ;‘ .
pricc to ew not. afl Lc : p.i1i c—
duct prices in thc .1 nt ic : ;in tnrc o:
Costs.
) fl jr.: uC c nt to a n w r fincry to c] I oil prctn
for lens than th prev4i Ii n r..a t :et pV 1C( in i:r j i d
8—9
-------
a
— ‘I—
would b the otc: tial to cam a larcjcr share of the
market. The price sha :incj coiid 1e either ter pcrary or
perrna c t dcpc; ing upon the rcact on of co pctitors.
Althoe h s :e factors courage price cutt : cj,
others would 1i it or offset i z likelihood. A mentioned
prcvio ly, the Middle Atlar.tic and indeed the entire
East Coast arc alternative arkcts for a cw England.
refinery. In addition, the refinery need only sell its
output for s i :t y lens than thc r r :ct -içc c c i: entry.
Finally, thc refinery :ill scc;i ç 1cn -tcr. Za1C
contracts and will. therefore be unlikely to price its
du t ny : .• r than r c css ry.
j the first rcf ncr r y fostcr adiitiona]
rc !inc: i t r c : : . The :iti 3 cf r : -c
: rt r: :: t :C
subnt y. f co-p:ti rio :c i;zcric ; ari t. ,
and the co thineJ output of rc al refineries n orc nearly
ntO t r.. rk• •t- : r c r I i he tore ! iI;ely t c! I ect
the full ccs: r vi::;s c thcir : cttion.
8-10
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ROOSEVELT CAMPOBELLD INTERNATIONAL PARK COMMISSION
CAMPCI C L IBLANO Ntw BRUNBWICK. CANADA
February 22, 1977
Mr. John A. S. MoGlennon
Region Z 4dministrator
Environrn ntal Protection Agency
John P. Kennedy Federal Building
Bo8ton, Macaachueetts 02203
Dear Mr. MeG lennon:
At the request of the Roosevelt Campobello Internation: :
Park Commisat.on, I am transmitting to you the comments of t’
‘ommte cn regarding the environmental Impact of the ropos .i
&il refinery at Eaetport, Maine.
‘Is you know., the Commission stated its concern previcusiy
during flearings held by the State of Maine. Issues raised
the draft Environmental Impact Statement require further
. omment. Thoec comments are contained in the attached state-
ment.
The Commission requests that ycu give careful con3ider
ation to these questions.
Sincerely
Henry St :Vene
Acting Executive Sec: e. ary
Superintendent
1 ’ncios :ro
9—1
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ROOSEVELT CAMPO8ELLD $NTERNATIDNAL PARK COMMISSION
CANPOe(LLO ISLAND Ncw BRUNSWICK. CANADA
STATEMENT OF THE ROOSEVELT CAMPOBELLO INTERNATIONAL PARK
COMMISSION ON THE PROPOSAL FOR A PITTSTON COMPANY REFINERY
AT EASTPORT, MAINE
The Roosevelt Campobello International Park Commission
would like to take this opportunity to raise some questions
regarding the draft Environmental Impact Statement for the
proposed issuance of a permit to the Pitt ton Company of
New York for the construction of a refinery at Eaatport, Maine.
The Cor mis&ion is deeply concerned about the environmental
impact of the proposed refinery.
Water Pollution Problems
The Commission has gone on record at the hearing held by
th r State of Maine. The grave concerns expressed at that time
remain. The difficulty of transporting oil to the refinery
creates a strong possibility of substantial damaging oil spills
as well as the certainty that some oil will be discharged into
the water during normal proceduraB of loading and unloading.
The navigation hazards have always been a large question.
Further discussion of the difficult currents, the steps taken
to protect against navigation errors (including human errors)
and the protective measures of control spills during normal
operations is needed. The fi8h, wildlife, plants, recreation
c ppcrtunities and entire ealogy of the area are unique and
“‘ust be protected.
Air Poiuticn ProHems
(1) The Clean Air Act Amendments of 1976 had broad
ngressional support and may well be enacted sometime during
the ?5t Conqress. The 2976 Amendments would have de8ignated
. c aevclt Campobeilo Park as a Class I area. Projections of
S4.f r ox de levels over the Park as a result of the refinery
aot vity shov a 24-hour reading of 6? micrograms per cubic
meter ao’ rdin ; to page -2 of the Appendix. Under the 1976
A’ Jmen , th 24- ho:4r mjxjmuri for a Class I area would have
mfor’:r s rer cubic meter. The 1976 Amendments would
have alZo cd an appeal to be made for approval of the facility
even though these numerical limitations might be exceeded. It
‘oud he usefu., therefore, to have a full analysis of the
relationship between the projected emissions for the refinery
and the requirements of the 1976 Amendments, and of require-
ents for Class I areas under present EPA regulations.
9—2
-------
Statement of R.C.I.P.C.
Pittston Company Refinery
1 a8tpOrt, Maine — 2 -
(2) The draft statement discussed the potential of a high
rate of formation of acid mist and other sulfates due to the
fact that emissions will impact high levels of fog. The
statement gave no indication of what levels of concentrations
likely to occur or the nature of sulfate particulates that
might form under such conditions. Further study seems necessary
here. The effect of these sulfate particulates on visibility
should also be clarified.
(3) On page 323 of the statement, table VI-6 indicates
that the highest 24-hour concentration would be 19.7
micrograms per cubic meter. ret the appendix on page G-2
indicates that the 24-hour maximum for SO 2 would be 67 micro-
grams per cubic meter. The discrepancy here should be resolved.
(4) It is presumed that the greatest quantities of any
pollutant permitted would be hydrocarbons, yet the statement
contains no figure regarding the emission rate of hydrocarbons.
The statement does say (in a comparison with the Portland area
and Cumberland County) that the emissions from Cumberland
County would be 10 times the amount of hydrocarbons that the
refinery is projected to emit. More information regarding the
emissions of hydrocarbons should be present.
(5) A definite commitment of the company to the use of the
very best available control technology and processes must be
stated with greater clarity. The definition of such technology
should not rest with the company. In addition, plans regarding
stack heights should be made extremely clear.
We hope these comments have been useful to you. We transmit
these comment8 to you as a continued expression of the grave
concern held by the Commission regarding the impact of the
proposed refinery.
9—3
-------
Response to Comments by
Roosevelt Campobello International Park Commission
Si. Navigation
Ri. In a memo dated Aug. 23, 1973, the U.S. Coast Guard assessed the
adequacy of the channel through Read Harbour Passage as follows:
It is the opinion of the Coast Guard that the
channel is adequate for safe navigation of
250,000 JT tankers; however, final determi—
nations would have to be based on the vessel
dimensions, maneuverability, speed, etc.
EPA requested that the Coast Guard perform a more detailed review of the
naviagational aspects of the channel. ta a letter dated August 8, 1977
the Coast Guard feels It can be premised that tank vessels can safely navi-
gate the channel approaches to Eastport under certain conditions,
(see FEIS, Vol. P VI—36).
Furthermore, the U.S. Coast Guard will regulate the port
and control the passage of tankers.
Also see FEIS, Vol. II, p. IV—38ff, Oil Spill Containment and
Recovery; p. X—26ff Navigation.
S2. Air Pollution
R2. See Vol. II, p. VI—62.
S3. Acid Mist
R3. See Vol. II, p. VI—78, expanded section on acid rainfall.
S4. so 2 Concentrations
R4. The dispersion calculation results have been adjusted to reflect
the emission rate changes due to the employment of tail-gas clean-
up and of on—site power generators.
$5. Hydrocarbons
R5. Emissions of non—methane hydrocarbons are presented in Tables VI—16
and VI-17, in the columns headed NWC. Methane is not included
because it is a natural atu spheric constituent, not a pollutant,
and has no odor nor does it cause any adverse effects.
S6. Control Technology
9—4
-------
R6. The EPA has declared that BACT will be employed, including tail—
gas clean—up of SO 2 . Process stack heights are stated to be 300
feet.
BACT is required under EPA’s new source review and is also
specified in the Maine Air Emission License.
S7. Uniqueness of the Area
R7. Comments noted. The diversity of species and abundance of different
habitats have been addressed in revised sections of the FEIS. See
FEIS, Vol. II, p. III—7Off, X-l5ff, X—23ff.
9—5
-------
Gentlemen:
OFFICE OF THE SECRETARY OF THE TREASURY
WASHINGTON. D.C. 20220
DE 2
This is in response to your request for comments on the draft
environmental impact statement for the proposed Pittston Oil
Refinery, Eastport, Maine. This Department has no comment.
Thank you for the opportunity to review the Statement.
Environmental Protection Agency
Region I
Enforcement Division, Permits Branch
John F. Kennedy Federal Building
Boston, Massachusetts 02203
trative Progrems
)
Response:
Comments received.
10—1
-------
6 EC i 76
nter tate Commerce Cosrnut ion
Ia%Jiin ton, C. 20423
E OF PROCEEDINGS
December 1, 1976
Mr. John S. McGlennon
Regional Administrator, Region I
U.S. Environmental Protection
Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Re: Draft EIS disc .issed in public notice
ME-O1-77
Dear Mr. McGlennon:
The Section of Energy and Environment has reviewed the
Draft Environmental Impact Statement on the proposed construction
of a 250,000 barrel/day oil refinery and marine terminal at
Eastport Maine, and offers the following comments.
The statement contains a detailed and comprehensive dis-
cussion of the impacts associated with the proposed project and
alternatives to the refinery. However, it appears that the only
mode of transportation given serious consideration for the move-
ment of refinery products to distant New England markets was
water carrier. We feel that the statement should discuss other
methods of bulk shipment for tarL or all of the refinery products.
Specifically, consideratior should be given to the use of the
existing rail service which is currently provided by Maine Central
Railroad at Eastport for this freight movement.
New teclmiques in bulb. h nJLing by r i1 maIze :his mode a
reasonable alternative warranting consideration. The unit train
concept, which involves the use 25 to 110 car trains shipped
from one ori in to one desrina c , has been extensively used
for bulk freight shipment in recent years. For ir.stance, a
western railroad has stateo ir t-’- iotiora1 re1ea es that it pro-
vide& crude rj 1 to a California refine by w :v o 70 car
(3Sf OO 1 arre’ c ; ity) UfliL rr s. I lOU -i train would have
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the capacity of 50,000 barrels, or 1/5 the proposed refinery’s
daily capacity. On the surface, a rail alternative presents a
number of advantages over water carrier such as; an ability to
ship in poor weather, flexibility to ship to alternative desti-
nations, and the avoidance of potential accidents in the marine
environment. These advantages should be given consideration in
a ccznparison with advantages presented by water carrier.
A second area of concern to the Comission is the effect
the proposed refinery would have as a catalysis for new industrial
develo ent (such as petro-chemicals) in the Eastport area.
While secondary socio-econxaic and enviroim ental impacts of the
refinery and its work force has been examined in the DEIS, the
possibility of secondary industrial development has not. We
feel that the Final EIS should address this possibility, including
the potential demand for transportation services that may result.
It would be useful to note land use and zoning plans for the
surrounding area as they relate to potential industrial develop-
men t.
As was noted in the Draft EIS, the Maine Central Railroad
has applied to the Cauvnission for authority to abandon its East-
port branch line. However, the Interstate C imerce Act requires
that such authority be granted only if public convenience and
necessity require abandonment. Before deciding the abandonment
question, the Conmiission must examine the potential for substantial
increases in demand for rail service.
If I can be of any assistance in the development of a rail
alternative, or in any other matters within our area of juris-
diction or expertise, please do not hesitate to contact us.
Cc*xiuunications on this matter should be directed to Assistant
to the Section Chief, John W. Giorgio, at FTS 275-7167.
Sincerely,
I ) 1. e
Richard I. Chais
Chief, Section of Energy
and Environment
11—2
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Response to Comments by Interstate Commerce Commission
Si. Use of Rail Service
Rl. A cost comparison of shipping the refinery’s products by rail
as opposed to water shows that rail is not cost competitive. For
example, using standard Conrail shipping rates, it would cost
$4.20 a barrel, plus car rental, to transport oil from Eastport
to Boston. To ship the oil by water using a 5,000 ton tanker,
the costs would be approximately $0.49 a barrel. Although it
could be expected that the use of unit trains would reduce the
rail costs by approximately 10 to 25 , the cost differential
is still too large to make rail cost effective.
S2. New Industrial Development
R2. The Eastport project will not be a catalyst for new industrial
development such as petro—chemicals. Industries of this nature
require feeds tocks that will not be readily produced at the
refinery. In addition, due to the remoteness of Eastport from
population markets, together with the lack of supporting facili-
ties, make the probability of future petro—chemical development
unlikely.
S3. Use of the Eastport Branch Line
R3. The Maine Central Railroad has Indicated that its Eastport
branch is in poor condition and would need substantial upgrading
to bring its current carrying capacity of 100,000 pounds up to
the 263,000 pounds needed. The cost for this upgrading would run
into the millions of dollars.
11—3
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
AREA OFFICE
NORRIS COTTON FEDERAL BUILDING
275 CHESTNUT STREET
REGION I MANCHESTER. NEW HAMPSHIRE 03103
Room 800
John F. Kennedy Federal Building J u 21 1977
Boeton MsNachuutts 02203 an 8 1 N REPLY REFER TO:
1.333
NPDkS # M OO22420
CORPS # 25—76-367
United States Environmental Protection Agency
Region I
Enforcement Division, Permits Branch
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Gentlemen:
This office baa reviewed the draft environmental statement
related to the application by Pittston Company for permits
necessary to construct and operate an oil refinery in East-
port, Maine.
The principal areas Of HUD concern in this development
proposal are housing and land use, and impacts on HUD
assisted facilities at the Passamaquoddy Indian Reservation
at Perry.
As a general comment, we do not feel that the draft adequately
addresses the impact of the proposal on the housing resources
of the area. Discussion of the entire area of housing is
scant at best, and does not serve to present the issues and
impacts which will arise should the proposal go forward.
The basic assumption of the draft statement is ‘that the hous-
ing supply in Washington County is plentiful, and that most
units are in good condition, including those which are vacant.
Our own opinion is that the basic occupied housing atock is
only in fair to moderately good condition, with rental units
currently being extramely scarce. In addition, based on
diaci. asion with local officials, standard vacant units are
virt D. i non—existent, and in fact, existing vacancies are
either universally deteriorating or dilapidat
The housi.ng element oi the draft EIS is also :xtremely super
fic .al 4 The infusion of 2,275 temporary- construction work-rc
intt Eastport’s ecc no’ y could have a very disruptive community
impact ir the present as well as in the future, if not properly
pla’; d. The report 8t tes that tc iporary housing will be
provided (p. 291) and reference is made to housing people in
12—1
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2.
“The Village Area” (p. 296). There is no mention of the amount,
type, and size of housing to be made available. In order to
reduce or ‘ ninin ize negative housing impacts such as overcrowd-
ing, excessive rents and inferior qm lity, a well—thought—out
temporary housing plan should be provided, If not, undesirable
1 ii’vi use patterns could develop and as the history of temporary
housing has generally shown, the unite often become permanent
and are highly susceptible to rapid deterioration. The corn-
munity then inherits a slum and must expend funds to alleviate
or eli.inate the problem.
The draft states that construction workforce will be housed by
Pittston. Again it is difficult to believe that a significant
number of these workers will nót choose to find their own
accomeodatione • For example, what was the experience during
the cited Faa samaquoddy study? What has been the experience
in other more recent projects with similar locational charac-
teristics? To the extent that workers will prefer to live off
site, there should be some enalyeis of what would appear to be
a serious potential impact on the availability of existing
housing, since it is stated that there is little rental housing
in the County (85% is owner occupied).
The eocio-ecomomic ramifications of this sort of short—run
disruption, I it with a long-term impact, are significant.
What effect will higher housing prices have on existing reaidenta?
Will out migration of such residents result as they are priced
out of the market? Will the supply of houaing increase in
response to short—term demand pressures and. what problems does
that pose? If expansion of the supply occurs, what form will
it take (i.e., mobile homes) and what will, be the effect on
l*M use patterns in the area?
It should also be noted that the njiiyeie contained in the
draft attempts to spread the impact over a two—county area.
Washington County alone is 85 miles North to South and 55 miles
aat to West. Clearly most of the impact will occur within
a 40—mile radius of £astport, which, if assumed, would certainly
magnify any beneficial or adverse impacts on the area housing
supply.
Lastly, in terms of HUD sponsored unite, location of a refinery
at £aatport. would have no adverse effect on public housing in
the area, due to the liRited number of units available and
their tenant statue,
12—2
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3.
Another area of MUD concern covers recently completed as well
as on-going contracts at the Passa naquoddy Indian Reservation
at Perry. Our Department has constructed new housing on both
sides of Route 190, with additional units programmed for the
future. HIJD has also provided grants to the Reservation for
the construction of a neighborhood facility and swimming
pool which is located on that portion of the Reservation
south of Route 190. This activity haa resulted in a great
deal of increased foot traffic across Route 190, especially
by children.
The Draft EIS addresses the issue of noise from increased
traffic, especially truck traffic by stating that moat traffic
for the proposed refinery would be restricted to daytime. This
daytime use will exacerbate the existing safety problem at the
Reservation.
It would be our recommendation that consideration be given to
the construction of at least one footbridge across Route 190
at the Reservation, as the only effective way to alleviate
this traffic hazard. A traffic light at this site is
an alternate, but much less effective method of dealing with
the traffic hazard because the traffic light may often be
ignored by children and because traffic tends to proceed
through this area at fairly high speeds.
There are other areas of the draft statement which we could
comment on, however these are not within the guidelines of
CEQ as areas of HUD jurisdiction or expertise. We would hope
that other agencies might comment on such subjects as water
supply, general highway safety, coordination with local and
state government, impacts on other community facilities such
as schools, land title questions, and structural unemployment.
We hope that our comments will be of use to your agency and we
look forward to their conaideration in subsequent issuancea.
If you have any questions or require any further information,
please call Mr. Sieminaki, my staff Environmental Officer,
at 834—7788.
Sincerely,
• 1
/ CreeleyA. Buch n n
Area Djt’ector
12—3
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Response to Comments by
Department of Housing and Urban Devel3pment
The soclo—econotnic sections of the Draft EIS have beea rewritten
extensively. In particular, see Vol. II, PP. VI—14 througti VI-17
and X-7 and X—6.
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• I,
DEPARTMENT OF THE
1-ISH AND WILDLIFE SERVICE
.11 I
NIW ()N (0FINI.i1, MASSACHUSEtTb 0215d
430-844
M1 P ‘ 1977
Division k ngineer
Ne w England Division
Corps of Engineers
424 Trapelo Road
Waltham, MA 02154
Dear Sir:
The U.S. Fish 6 Wildlife Service has reviewed Public Notice #25—76—367,
dated October 12, 1976. The Applicant, Pittston Oil Company, has re-
quested a permit to construct a marine terminal at Eastport, Maine, in
connection with a 250,000 BPD Oil Refinery.
Review of the Draft Environmental Impact Statement on this project,
consultation with knowledgeable authorities, and literature reviews,
make it abundantly clear that this type of industry is not environ-
mentally suited to this location.
There is a very real and inevitable threat of an oil api11, which in
turn could devastate the living marine and anadromoua resources in
the area for many years to come. This probability looms even larger
in light of recent sinkings, groundings, and explosions of oil tankers
around the United States.
In view of findings from our investigation, the U.S. Fish and Wildlife
Service recommends denial of subject permit.
Please advise this office of any action taken on this application.
Sincerely yours,
— 4::’ . U4. 1
Regional Director
13—i
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Response to Comments by H. Woon,
U.S. Fish and Wildlife Service
See following letter from the Corps of Engineers requesting
clarification on the U.S. Fish and Wildlife Service re-
commendation against issuing the NPDES permit and the Marine
Fisheries Service response to that letter.
13—2
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SEP 29 1977
DEPARTMENT OF THE ARMY
NEW ENGLAND DIVISION. CORPS OF ENGINEERS
424 TRAPELO ROAD
WALTHAM, MASSACHLJ5E’fls 02154
IPLY TO
, 1TENTIOfd Of
NEDOD—R—20 27 September 1977
Regional Director
U.S. Fish and Wildlife Service
OlTe Gateway Center, Suite 700
Newton Corner, Massachusetts 02158
Gt•ntlemen:
T1is letter is in reference to the Pittston Company’s application for
-a proposed oil refinery project at Eastport, Maine.
Oi- 8 March 1977 we received your recommendation to deny that
ajplication. We are inclosing Volumes I, II, III, IV of a 6 and 12
September 1977 draft of the Environmental Protection Agency’s proposed
final Environmental Impact Statement. Considerable new information
has been included both In the main text and In sections on Comments
and responses. In order to properly evaluate your recommendation, we
abk that you review this new material and provide us with your comments
on the project in as much detail as possible.
The Corps’ decision on this most controversial project will be made
at the Washington level by the Chief of Engineers or higher. We will
make our recommendations on permit action to the Chief’s office at the
end of the 30 day public response period following publication of the
final EIS.
I’m sure you realize the difficult weighing and balancing process that
faces us in arriving at our recommendation. As such, we need as much
detail as you can give us to properly reflect the views of your
service. We would appreciate receiving your comments within two
weeks as EPA would like to Include them In the final EIS.
If I can be of any further assistance, please contact me at your
convenience.
Sincerely yours,
JOHN P. CHANDLER
Colonel, Corps of Engineers
Division Engineer
U
1 3 - 3
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UNITED STATES
DEPARTMENT OF THE INTERIOR
FISH AND WILDLIFE SERVICE
Ecological Services
P. 0. Box 1518
Concord, New Kfilnpshire 03301
November 3, 1977
Co].. John ChRndler
Division ngjneer
New L g ] Division, Corp. of Engineer.
421 Trapelo Road
b 1them, Massachusetts 0215k
Dear Col. Chandler:
Your letter of September 27, 1977, requested our review of the draft
Ytnel Enviroiaeutal Ispact Statement for the proposed refinery at
stport, Maine, by the Pittston Coapeny. As you are aware, we viii
be reviewing this doct snt after publication of the Fine]. Euviro ntai
I psct Statement, and feel it iz*ppropriate to do so at this time.
You vii]. be receiving a copy of our c nt. upon conpietion of our
review.
Sincer,ly yours,
Tang 7
Acting Supervisor
13—4
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‘• “ ZU 7977
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
ER 76/1OLI 7
JAN 1 7 1977
Dear Mr. McGlennon:
Thank you for your letter which we received on November 2,
1976, transmitting copies of the Environmental Protection
Agency’s draft environmental impact statement for 250,000-BPD
Pittston refinery and deepwater marine terminal, Washington
County, Eastport, Maine.
Our comments are presented according to the format of the
statement or by subject.
General
Generally, the draft statement adequately treats most aspects
of the environmental impacts of the proposed facility.
1-lowever, we believe there are two major areas which need
further attention in the final statement. The first is the
discussion on Nilford Haven, which is emphasized as a “clean”
port, based solely on the amount of oil spilled per annum.
A major point emphasized in the draft statement is that oil
and the marine environment are compatible. We believe that
further discussion in the final statement should be given to
biological considerations within Milford Haven, including a
discussion of the marine biota prior to and after project
operation.
Secondly, we do not believe the draft statement emphasizes
areas of responsibility especially in the areas of safe
navigation and oil spills. The final statement should specify
who has responsibility for inspecting, at regular intervals,
the navigational aid systems to make sure they are in proper
working order, who is responsible to see that these aids
are used, and describe the assurances that no ship moveTnent
will occur during unfavorable climatic conditions as specified.
The final statement should also indicate who has the respon-
sibility for oil clean-up away from the piers, yet under the
influence of coastal currents, both for crude tankers and
product transport. We believe all of these points must be
Save Energy and You Serve A merica!
14—1
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2
addressed in detail within the final statement. Finally, we
do not find that the draft statement adequately emphasizes
the critical importance of just one major oil spill in this
area, which could destroy countless marine organisms and render
the marine environment almost totally unproductive.
The maps in the draft statement are generally of poor quality
and the drawings of the facility layout are practically illegi-
ble. It is also difficult to reference the exact location
of the proposed site where it is not designated on the maps
of the environmental characteristics of the region, and
where no map scale is provided. We recommend that care should
be taken in preparing the final statement to assure that the
graphics are clear and that the proposed site is located on
all the appropriate maps.
Geology
Volume II of the draft statement under “Geology” provides a
thorough description of the bedrock geology and notes on page
12 the existence of veins of quartz and iron sulfides. Other
than this brief mention, there is rio discussion of these
occurrences in terms of a potential for minable deposits.
Interestingly, along Denbow Neck, 11 miles southwest of the
project site, ores of lead, zinc, and silver are known to occur.
Although the rocks of Denbow Neck differ from those of East-
port, the close proximity of known high—grade occurrences and
the occurrence of iron sulfides on the project site should be
discussed in the final statement. The possibility that the
project site may contain economic concentrations of these
minerals should also be assessed in the final statement.
Hydrology
Although page l of the draft statement indicates that flooding
is of minimal concern in the basin, we believe that the effects
on the project of tidal flooding from a combination of unusually
high lunar tides and storm—generated waves should be addressed
in the final statement.
14—2
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3
Parks
We take special note in the omission of Roosevelt Campobello
International Park from the Historic Sites Section on page 8
of Volume I, the Executive Summary, and brief mention of the
park on page 38 of the draft statement. This International
Park, though owned and operated by Canada, is of national
significance to the United States. This park is of closer
proximity to the proposed project than other sites considered
and is a site jointly administered with the National Park
Service.
We believe the final statement should discuss the probable
impacts on this International Park in greater detail and we
encourage a consultation with the Park’s Executive Secretary
at Welshpool, Campobello, N.B. Canada or P.O. Box 97, Lubec,
Maine, USA 04652. The Executive Secretary’s commentary should
be displayed in the final statement.
pact on Recreation
On pages 37—38, the draft statement identifies the park
facilities and recreational resources in the area of the proposed
project, including Quoddy Head State Park, Cobscook State Park,
Gleason Point, Perry, Reversing Falls Park, and St. Croix
National Park. But, the draft statement does not provide an
adequate assessment of the impact of the construction and
operation of the proposed facilities upon parks and recreation.
We recommend that the final statement supply a complete evalua-
tion of the primary and secondary environmental impacts of
the proposal upon parks and recreation activities. These
considerations should include air emissions, waste effluents,
potential oil spills, dredging, influx of construction workers,
secondary development, tanker traffic and the like.
In addition, in light of the September 24, 1976, memorandum
from the Council on Environmental Quality concerning the
application of the environmental impact statement requirement
to environmental impacts abroad, we believe that the probable
impacts upon Canada’s Roosevelt Memorial Park on Campobello
Island from the project should be enumerated and fully assessed
in the final statement.
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4
Cultural Resources
We find consideration given to the proposed upland area of
the refinery proposal adequately covered. The negative state-
ments on the presence of archeological values on pages 193 and
297 of the draft statement are supported by Dr. Bonnichesen’s
report as displayed in Volume III, Appendix I. While this
treatment is adequate for upland effects to be caused by
the project, it does not cover the potential for offshore/under-
water archeological values which may be affected by the proposed
offshore project facilities described on page 213 and else-
where in the draft statement. We believe that prior to the
final design and construction of offshore facilities, that a
determination be made by a qualified archeologist as to the
probability of adverse effects by the project on such resource
values. This determination should be revealed and any sub-
sequent mitigation efforts should be discussed in the final
statement.
Due consideration seems to have been given to the National
Register of Historic Places and proper contact made with the
State Historic Preservation Officer. A favorable commentary
from the State Historic Preservation Officer, as well as a
qualified archeologist regarding offshore values should be
displayed in the final statement.
Impact on Passamaguoddy Tribal Territory
There is a serious question with regard to possible Indian
title to the sites designated for the location of the Pittston
re.finery and deepwater marine terminal. This area is part of
aboriginal Passamaquoddy tribal territory, and a persuasive
argument can be made that the Indian title was never validly
extinguished in accordance with the Indian Nonintercourse
Act of 1790 (25 U.S.C. §177.) A federal appeals court has
ruled that the Interior Department has a trust responsibility
to take appropriate action on behalf of the Tribe to secure
its Nonintercourse Act claims. The Justice Department has
been ordered to notify the federal court in Maine by January 15,
1977, whether it intends to pursue the Tribe’s claims in
litigation entitled United States v. Maine .
14—4
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5
In the event that the Passamaquoddy Tribe’s claims are denied
arid the proposed installation is constructed, then it is our
opinion that operation of the facility, in accordance with
existing rules and regulations, will not create any adverse
environmental effect on the Passamoquoddy Point Pleasant
Reservation that is located about three (3) miles to the north
of the site.
If the court deems the claims to be valid, either a change in
land status or a claim settlement could occur. A claim
settlement might not necessarily affect the proposed project.
However, in the case of a change in land status, any construc-
tion and operation of the proposed project would be subject to
negotiation with Passaniaquoddy Tribal authorities and the
Department of the Interior as trust officers.
Impact of Routine Refinery Discharges on Maine Water Quality
This section of the draft statement does not provide an
adequate assessment of the impact of the maximum concentration
of the combined discharges of oil upon marine biota. The
anticipated concentration of oil in the discharge plume and in
the vicinity of the diffuser should be given in the final state-
ment, together with the thresi-ihold levels for the area’s marine
biota. The final statement should provide descriptions more
specific than “minimal effects” for the impact of the exposure
to low levels of oil upon the area’s marine biota. Specific
details on hydrocarbon levels, plume dispersal, and cumula-
tive effects on marine organisms should be included in the
final statement to discuss the impacts after instituting
mitigation measures.
The portion of this section of the draft statement that concerns
the mitigation of adverse impacts should be moved to the section
on mitigation measures in the final statement.
Groundwater Monitoring
The draft statement does not make clear whether any monitoring
of groundwater is planned to assure that measures taken to
avoid infiltration of polluted storm water are functioning
efficiently. We note on page 351 of the draft statement that
there are plans to monitor groundwater in the vicinity of
14—5
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6
th nsite landfill against the infiltration of leachate.
But, there is no indication of monitoring groundwater else-
where against the infiltration of pollutants from refinery
operations. The final statement should specifically indicate
whether or not any groundwater monitoring is planned to
detect infiltration of polluted stormwater and other pollutants
from refinery operations.
Dred g .i g
We do not find an adequate assessment of the possible effects
of any leaching and siltation from drainage of the dredge
spoils to be used onsite. If no mitigating measures are to
be instituted to control any leaching and siltation that might
occur, the final statement should give specific reasons as
to why mitigation would not be needed. In addition, the final
statement should provide a more specific description of the
“minimal’ t water drainage expected from these areas, as men-
tioned on page 314 of the draft statement.
We believe that the dredging operation will release fine
sediment; the ultimate location of these dispersed sediments
is the key to the consideration of environmental impacts.
If the dredging operation is done on an incoming tide, the
potential of sediments being carried into coves and bays is
much greater, and could have a tremendous adverse impact on
overall biological productivity in these areas, especially
if dredging was done during spawning periods.
Details on the ambient sediment movement should be presented
in the final statement to substantiate the statement on page
314 of the draft statement on sediment movement in the Shackford
area.
The final statement should also provide a discussion of any
required maintenance dredging, associated environmental impacts
of that dredging operation and maintenance dredge spoil disposal.
14—6
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7
Wildlife
The draft statement does not provide realistic consideration
of the impact of habitat loss on wildlife populations local
to the refinery site. Individuals of certain species will
be expected to leave the area, and there may not be habitat
available in the adjacent areas. Also, the mechanisms of
territoriality and competition will not necessarily permit
the absorption of wildlife populations from the site into
adjacent habitat.
The draft statement also does not include any consideration
of the impact of air emissionson local wildlife and nearby
wildlife refuges. The final statement should address these
issues.
Marine Transportation System
The section in the draft statement concerning marine transport
of imported oil to the refinery does not include an adequate
analysis of tanker traffic under normal weather conditions.
The final statement should include a realistic scenario of
the tanker traffic expected to be able to navigate through
Head Harbour Passage to Eastport under the normal weather
conditions of the area for each season. The analysis in the
final statement should be able. to demonstrate that this
frequency of tanker arrivals will assure adequate quantities
of oil to fulfill the anticipated refinery production rate.
Based on the realistic estimate of tanker traffic through
Head Harbour Passage, an approximate probability of a tanker
collision or other accident should be discussed in the final
statement.
The plans discussed in the draft statement indicate a marine
navigation system will be installed to include a sophisticated
control guidance and communication system. Under the plans,
certain operating limitations will be used to ensure safe
passage in the Eastport waters; for example, no movement of
any tankers when visibility is less than a mile. We are
concerned about the public safety of a situation where numbers
of approaching tankers would have to hold in the open sea
14—7
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8
until “visibility exceeds limitations.” The final statement
should provide a realistic scenario of tanker traffic holding
in the open sea under these adverse operating conditions. The
scenario should include the tanker traffic and approximate
range of holding time along with the duration and frequency
of adverse weather conditions based on historical weather
records by season. The probability and size of a tanker acci-
dent(s) under such conditions and associated clean-up operations
should be fully evaluated in the final statement.
Potential Environmental Effects of an Oil Spill
We find that the draft statement provides only a very general
assessment of the ecological consequences on local flora and
fauna of an oil spill from the operation of the proposed
facility. This section in the draft statement makes broad
assumptions and conclusions without providing adequate support-
ing data. For example, on page 309 of the draft statement, the
discussion of the impact of the Arrow Spill in Chedabucto Bay
indicates that “overall, however, the fishery was not signi-
ficantly affected.” This is a general assumption that was not
substantiated in the text. The final statement should provide
an adequately supported analysis of the ecological consequences
of a potential oil spill on the local marine biota.
This section in the final statement should also contain
reference to the Arrow Spill, in relation to soft-shell clams,
as to the lingering toxic effects of oil that has been trapped
in the sediments. We believe that petroleum leachates are
still persistent in sediments subjected to exposure during this
spill, and continue to be death traps for spat and young clams
which are carried onto these areas.
On page 309 in the draft statement, this discussion implies
that all fractions of petroleum products from the refinery
process can be considered as “heavy fuels.” However, petroleum
fractions vary considerably in solubilities. This sentence
in the final statement should reflect this fact and indicate
that some petroleum products may be extremely toxic to lobster,
especially larval forms.
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9
Mitigation Measures
Throughout the draft statement, the proposed mitigating
measures are scattered within the discussion of impacts.
A separate section on mitigation measures should be prepared
for the final statement including a discussion of measures
which must or which are proposed to mitigate environmental
impacts. This section should provide details of legal limits
of all emissions and effluents, and the resulting levels of
pollutants emitted after instituting mitigation measures.
A listing of those mitigation measures imposed by Federal,
state and local regulations and of those initiated in excess
of legal requirements should also be supplied in the final
statement.
In addition, we find that the description of mitigation
measures lack specificity such that neither the effectiveness
of the measure, nor its impact can be established. It is
difficult to determine the true meaning of such terms found
in the draft statement as “maximum attention to the operation
and maintenance” (p. 299).
Alternatives: Offshore Oil
The draft statement mentions that only imported high sulfur
oil is projected for use in the refinery. We believe that
the final statement should consider the alternative of using
offshore oil from probable Atlantic Outer Continental Shelf
(OCS) production. Further, the consideration of OCS oil should
include transportation of the oil to the refinery.
Specific Comment
Page 310, last sentence. This sentence has nothing to do
with effects from oil spills, the subject of this section
of the draft statement.
We hope that these comments will be useful to you.
Sinc ely yours,
SPUty Secretary of the Interior
Mr. John McGlennon
Regional Administrator
U.S. Environmental Protection Agency
Region, I, JFK Federal Building
Boston, Massachusetts 02203
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Response to Comments by the U.S. Department of the Interior
Si A major point emphasized in the draft statement is that oil and marine
environment are compatible. We believe that further discussion in the
final statement should be given to biological considerations within
Milford Haven, Including a discussion of the marine biota prior to and
after project operation.
R i. A study made by Dr. Jenifer M. Baker (which can be found in Marine
Ecology and Pollution Proceedings, of spring meeting of Institutes of
Petroleum, April 1975. John Wiley and Sons, New York) indicates that
there has been no overall ecologicai. damage In Milford Haven which can
be attributed to the oil industry. However there persists a varying
pattern of short term localized effects, attributable to oil, which are
described in the paper. Among these are population fluctuations of liin—
pete and gastropod molluscs after a spill of 2000—3000 tons of oil. Al-
so a patch of Spartina grass has disappeared, possibly as a result of
exposure to chronic refining effluents.
S2 The draft statement does not emphasize areas of responsibility especial—
ly in the areas of safe navigation and oil spills. The final statement
should specify who has responsibility for inspecting, at regular inter-
vals, the navigational aid systems to make sure they are in proper working
order, who is responsible to see that these aids are used, and describe
the assurances that no ship movement will occur during unfavorable climatic
conditions as specified.
R2 The U. S. Coast Guard will be regulating the port and approving the
operational plan. The navigational system will be maintained by the
appropriate government agencies and where applicable, by the Pittston
Company.
S3 The final statement should also Indicate who has the responsibility for
oil clean—up away from the piers, yet under the influence of coastal
currents, both for crude tankers and product transport.
R3 See FEIS, Vol II p X—5.
S4 The draft statement does not adequately emphasize the critical import-
ance of just one major oil spill in this area, which could destroy count-
less marine organisms and render the marine environment almost totally
unproductive.
R4 See FEIS, Vol II, p ‘11—38 ff.
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S5 The maps in the draft statement are generally of poor quality and the
drawings of the facility layout are practically illegible. It is also
difficult to reference the exact location of the proposed site where it
is not designated on the maps of the environmental characteristics of the
region, and where no map scale is provided. We recommend that care should
be taken in preparing the final statement to assure that the graphics are
clear and that the proposed site is located on all the appropriate maps.
R5 Comment noted.
S6 Volume II of the draft statement under “Geology” provides a thorough
description of the bedrock geology and notes on page 12 the existence of
veins of quartz and iron suif ides. Other than this brief mention, there
is no discussion of these occurrences in terms of a potential for minable
deposits. Interestingly, along Denbow Neck, 4 miles southuest of the
project site, ores of lead, zinc, and silver are known to ocour. Al—
through the rocks of Denbow Neck differ from those of Eastport, the
close proximity of known high—grade occurrences and the occurrence of iron
sulfides on the project site should be discussed in the final statement.
The possibility that the project site may contain economic concentrations
of these minerals should also be assessed in the final statement.
R6 No geological surveys have been conducted that would indicate whether
significant deposits of lead, ainc and silver exist on the site. There is
no reason to perform such a survey since the likelihood of such deposits
being present in the minable quantities is remote at best.
S7 Although page 41 of the draft statement indicates that flooding is of min-
imal concern in the basin, we believe that the effects on the project of
tidal flooding from a combination of unusually high lunar tides and storm—
generated waves should be addressed in the final statement.
R7 Comment noted.
S8 The final statement should discuss the probable impacts on this International
Park in greatest detail and we encourage a consultation with the Park’s
Executive Secretary at Welshpool, Campobello, NB. Canada or P.O. Box 97,
Lubec, Maine, USA 04652. The Executive Secretary’s commentary should be
displayed in the final statement.
R8 Comments from the Roosevelt Campobello International Park
Commission have been addressed (see p 9—1 ff).
14:11
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S9 On pages 37—38, the draft statement identifies the park facilities and
recreational resources in the area of the proposed project, including
Quoddy Head State Park, Cobscook State Park, Gleason Point, Perry,
Reversing Falls Park, and St. Croix National Park. But, the draft
statement does not provide an adequate assessment of the impact of the
construction and operation of the proposed facilities upon parks and
recreation. We recommend that the final statement supply a complete
evaluation of the primary and secondary environmental impacts of the
proposal upon parks and recreation activities. These considerations
should include air emissions, waste effluents, potential oil spills,
dredging, influx of construction workers, secondary development, tanker
traffic and the like.
R9 As discussed in Vol. II, thapter 6 of the FEIS, it is anticipated that
the refinery will have little impacts upon Eastport’s recreational
facilities. With regard to the park and recreational facilities sur-
rounding Moose Island, it is expected that the main impact will be
associated with a major oil spill. The effects of such a spill are
described in the FEIS, Vol. II, p. 38 ff.
Air quality impacts at the recreational facilities should be minimal
since the plant will have to satisfy stringent PSD Class I increments
with respect to Campobello International Park. PSD refers to the
Prevention of Significant Deterioration regulations which will be im—
plemented by EPA through a permit process. (See FEIS Vol. II, p. VI-
62 ff.)
Sb The draft FIS does not cover the potential for offshore—underwater
archeological values which may be affected by the proposed offshore
project facilities described on page 213 and elsewhere in the draft
statement. We believe that prior to the final design and construction
of offshore facilities, that a determination be made by a qualified
archeologist as to the probability of adverse effects by the project
on such resource values. This determination should be revealed and
any subsequent mitigation efforts should be discussed in the final
statement.
RiO Divers working in the area that will be disturbed have not encountered
any archaeological artifacts. However, an underwater archaeological
survey will be completed prior to construction and will be a condition
of EPA ’s permit.
Sil Due consideration seems to have been given to the National Register of
Historic Places and proper contact made with the State Historic Preserva-
tion Officer. A favorable cou entary from the State Historic Preserva-
don Officer, as well as a qualified archaeologist regarding offshore
values should be displayed in the final statement.
R.ll See letter from the State Historic Preservation Officer.
14—12
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S12 There 18 a serious question with regard to possible Indian title to the
sites designated for the location of the Pittston refinery and deepvater
marine terminal. This area is part of aboriginal Passainaquoddy tribal
territory, and a persuasive argument can be made that the Indian title
was never validly extinguished in accordance with the Indian Noninter—
course Act of 1790 (25 Usc 177.) A federal appeals court has ruled
that the Interior Department has a trust responsibility to take appro-
priate action on behalf of the Tribe to secure Its Nonintercourse Act
claims. The Justice Department has been ordered to notify the federal
court in Maine by January 15, 1977, whether it intends to pursue the
Tribe’s claims in litigation entitled United States v. Maine.
In the event that the Passamaquoddy Tribe’s claims are denied and the
proposed Installation is constructed, then it is our opinion that opera-
tion of the facility, in accordance with existing rules and regulations,
will not create any adverse environmental effect on the Passamaquoddy
Point Pleasant Reservation that is located about three (3) miles to the
north of the site.
if the court deems the claims to be valid, either a change in land
status or a claim settlement could occur. A claim settlement might not
necessarily affect the proposed project. However, in the case of a
change in land status, any construction and operation of the proposed
project would be subject to negotiation with Passamaquoddy Tribal
authorities and the Department of the Interior as trust officers.
R12 Comment noted.
Sl3 This section of the draft statement does not provide an adequate assess-
ment of the impact of the maximum concentration of the combined dis-
charges of oil upon marine biota. The anticipated concentration of oil
in the discharge plume and in the vicinity of the diffuser should be
given in the final statement, together with the threshold levels for
the area’s marine biota. The final statement should provide descrip-
tions more specific than “minimal effects” for the impact of the exposure
to low levels of oil upon the area’s marine biota. Specific details on
hydrocarbon levels, plume dispersal, and cumulative effects on marine
organisms should be included in the final statement to discuss the im-
pacts after instituting mitigation measures.
R13 See FEIS, Vol. II, p. VI—28 ff.
S14 The portion of refinery discharges section of the draft statement that
concerns the mitigation of adverse impacts should be moved to the section
on mitigation measures in the final statement.
R14 Comment noted.
S15 The draft statement does not make clear whether any monitoring of ground-
water is planned to assure that measures taken to avoid infiltration of
polluted storm water are functioning efficiently. We note on page 351
14—13
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of the draft statement that there are plans to monitor groundwater in the
vicinity of the onsite landfill against the infiltration of pollutants
from refinery operations. The final statement should specifically indicate
whether or not any groundwater monitoring is planned to detect infiltration
of polluted stormwater and other pollutants from refinery operations.
R15 As a part of normal operating procedures, groundwater samples will be drawn
to determine Mhether the pollution control techniques are producing the
desired results. This will be a condition of EPA ’s NPDES permit and is
required under the new Maine Solid Waste Regulatory Code.
S16 We do not find an adequate assessment of the possible effects of any leach-
ing and siltation from drainage of the dredge spoils to be used onsite.
If no mitigating measures are to be instituted to control any leaching
and siltation that might occur, the final statement should give specific
reasons as to why mitigation would not be needed. In addition, the final
statement should provide a more specific description of the “minimal”
water drainage expected from these areas, as mentioned on page 314 of
the draft statement.
We believe that the dredging operation will release fine sediment; the
ultimate location of these dispersed sediments is the key to the considera-
tion of environmental impacts. If the dredging operation is done on an
incoming tide, the potential of sediments being carried into coves and
bays is much greater, and could have a tremendous adverse impact on over-
all biological productivity in these areas, especially if dredging was
done during spawning periods.
R16 See FEIS, Vol. II, p. VI—59 ff.
S17 The dredging and blasting associated with the construction of piles and
piers will cause the resuspension of fine grain sediment in the Shackford
Head/Deep Cove area.
A17 See FEIS, Vol. II, p. VI—59 ff.
S18 Details on the ambient sediment movement should be presented in the final
statement to substantiate the statement on page 314 of the draft state-
ment on sediment movement in the Shackford area.
A18 Sec FEIS, Vol. II, p. VI—59 ff.
S19 The final statement should also provide a discussion of any required
maintenance dredging, associated environmental impacts of that dredging
operation and maintenance dredge spoil disposal.
R19 Dee to scouring and flushing activities of the tides and currents, it is
anticipated that maintenance dredging will not be required.
14—14
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S20 The draft statement does not provide realistic consideration of the
impact of habitat loss on wildlife populations local to the refinery
site. Individuals of certain species will be expected to leave the
area, and there may not be habitat available in the adjacent areas.
Also, the mechanisms of territoriality and competition will not neces-
sarily permit the absorption of wildlife populations from the site into
adjacent habitat.
The draft statement also does not include any consideration of the im-
pact of air emissions on local wildlife and nearby wildlife refuges.
The final statement should address these air issues.
R20 Due to refinery construction, birds and animals will be forced to migrate
to adjacent land areas of similar character, which are plentiful in the
area. This increase in population density could result in competition
for food and habitat. No serious disruption is expected because of this.
The impact from air emissions on local wildlife refuges should be negli-
gible. All air emissions from the refinery will comply with State and
Federal regulations designed to protect health and welfare.
S21 The section in the draft statement concerning marine transport of imported
oil to the refinery does not include an adequate analysis of tanker traf-
fic under normal weather conditions. The final statement should include
a realistic scenario of the tanker traffic expected to be able to navigate
through Head Harbor Passage to Eastport under the normal weather condi-
tions of the area for each season. The analysis in the final statement
should be able to demonstrate that this frequency of tanker arrivals will
assure adequate quantities of oil to fulfill the anticipated refinery pro-
duction rate. Based on the realistic estimate of tanker traffic through
Head Harbor Passage, an approximate probability of a tanker collision or
other accident should be discussed In the final statement.
R21 Pittston estimates that approximately 468 tankers will enter Eastport
annually to service the refinery. Approximately 50 of these will be
VLCCs, arriving once every 7 to 10 days. These will proceed directly
from sea to berth on one ebb tide, and berth at slackwater. The product
tankers, however, can enter from sea and anchor at Friar Roads before
proceeding to birth at slack, on the same tide. On this basis, using
a carefully planned schedule, two or three product tankers can enter and
and berth on one tide while meeting conditions as presently stipulated
by BEP orders. With only one ebb tide utilized per day, 50 VLCCs and
630 to 945 product tanker entrances could be made a year. Furthermore,
it should be noted that the U.S. Coast Guard will regulate the port and
control the passage of tankers.
Also see FEIS, Vol. II, p. X—26 ff.
S22 The plans discussed in the draft statement Indicate a marine navigation
system will be installed to include a sophisticated control guidance
and communication system. Under the plans, certain operating limitations
will be used to ensure safe passage in the Eastport waters; for example,
14—15
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no movement of any tankers when visibility is less than a mile. We are
concerned about the public safety of a situation where numbers of approach-
ing tankers would have to hold in the open sea until “visibility exceeds
limitations”. The final statement should provide a realistic scenario
of tanker traffic holding in the open sea under these adverse operating
conditions. The scenario should include the tanker traffic and approxi-
mate range of holding time along with the duration and frequency of
adverse weather conditions based on historical weather records by season.
The probability and size of a tanker accident(s) under such conditions
and associated clean—up operations should be fully evaluated in the final
statement.
R22 According to the U.S. Coast Guard letter of March 25, 1977 to Mr. Wally
Stickney of USEPA: “However, in being at sea or putting to sea in
extremely inclement weather, the handling of the ships should not pre-
sent any greater hazard than encountered presently at sea under similar
conditions throughout the world.”
Also see FEIS Vol. II, p. X—26 ff, p. VI—36.
S23 We find that the draft statement provides only a very general assessment
of the ecological consequences on local flora and fauna of an oil spill
from the operation of the proposed facility. This section in the draft
statement makes broad assumptions and conclusions without provide ade-
quate supporting data. For example, on page 309 of the draft statement,
the discussion of the impact of the Arrow Spill in Chedabucto Bay
indicates that “overall, however, the fishery was not significantly
affected.” This is a general assumption that was not substantiated in
the text. The final statement should provide an adequately supported
analysis of the ecological consequences of a potential oil spill on the
local marine biota.
R23 See FEIS, Vol. II, p. VI—29 ff for revised material on oil spills.
S24 This section in the final statement should also contain reference to
the Arrow Spill, in relation to soft—shell clams, as to the lingering
toxic effects of oil that has been trapped in the sediments. We believe
that petroleum leachates are still persistent in sediments subjected to
exposure during this spill, and continue to be death traps for spat and
young clams which are carried onto these areas.
R24 A study performed by .1. H. Vandermenlen and P. D. Keizer of the Beckford
Institute of Oceanography, Dartmouth, Nova Scotia, titled, “Persistence
of Non—Alkane components of Bunker C oil in Beach Sediments of Chedabucto
Bay, and Lack of their Metabolism by Mollusks” appeared in the March 1977
Oil Spill Conference Proceeding sponsored by EPA, USCC and API. Certain
fractions of the oil from the Arrow spill are highly resistant to degrada-
tion and remain for potential re—entry into beach infauna and into the
water column or for continued residence within the sediments. The effects
of oil on clams and other organisms is covered in the FEIS on pages
IV—28 ff, Oil Spill Effects. The effect of oil on spat and young clams
is more significant than the effect on mature clams.
14—16
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S25 On page 309 in the draft statement, this discussion implies that all frac-
tions of petroleum products from the refinery process can be considered
as “heavy fuels”. However, petroleum fractions vary considerably in
solubilities. This sentence in the final statement should reflect this
fact and indicate that some petroleum products may be extremely toxic to
lobster, especially larval forms.
25 Comment noted. The FEIS notes that various petroleum fractions are lethal
to larval forms, especially lobster. See FEIS, Vol. II, p. VI—56 ff,
Toxicity, p. VI—28 ff, Oil Spill Effects.
S26 Throughout the draft statement, the proposed mitigating measures are
scattered within the discussion of impacts. A separate section on miti-
gation measures should be prepared for the final statement including a
discussion of measures which must or which are proposed to mitigate en-
vironmental impacts. This section should provide details of legal limits
of all emissions and effluents, and the resulting levels of pollutants
emitted after instituting mitigation measures. A listing of those miti-
gation measures imposed by Federal, state and local regulations and of
those initiated in excess of legal requirements should also be supplied
in the final statement.
In addition, we find that the description of mitigation measures lack
specificity such that neither the effectiveness of the measure, nor its
impact can be established. It is difficult to determine the true meaning
of such terms found in the draft statement as “maximum attention to the
operation and maintenance”. (p. 299)
R26 Comment noted. There is a section in the FEIS on mitigating measures
and a section which outlines EPA’s permit conditions.
S27 The draft statement mentions that only imported high sulfur oil is pro-
jected for use in the refinery. We believe that the final statement
should consider the alternative of using offshore oil from probable
Atlantic Outer Continental Shelf (OCS) production. Further, the con-
sideration of OCS oil should include transportation of the oil to the
refinery.
R27 The refinery is capable of using any feedstock economically and opera-
tionally feasible, including OCS oil. If available,OCS oil would be
expected to bring about a transportation savings. Specific plans will
await its availability.
S28 Page 310, last sentence. This sentence has nothing to do with effects
from oil spills, the subject of this section of the draft statement.
R28 Comment noted.
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2 DEC 1 76
DEPARTMENT OF STATE
Washington, D C. 20520
BUREAU OF OCEANS AND INTERNATIONAL
ENVIRONMENTAL AND SCIENTIFIC AFFAIRS
December 22, 1976
Mr. John A. S. McGlennon
Regional Adinini strator
Environmental Protection Agency
Room 2203
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
The Department of State appreciates the opportunity
to comment on the draft EIS covering the proposed Pittston
marine terminal and oil refinery at Eastport, Maine. As
you are aware, Karl K. Jonietz of the Department’s Office
of Canadian Affairs made a statement at the public hearing
and entered into the record a letter to Pittston from the
Canadian Department of External Affairs. In addition, we
have already forwarded to your office several studies pre—
pared by the Government of Canada which bear on the poten-
tial impacts on Canada of the proposed project.
The Department of State has no further comment on
the draft EIS but stands ready to assist you and your
staff with regard to interpretation of applicable interna-
tional law and the potential impacts of the project on
Canada.
Sincerely yours,
Donald R. King
Director
Office of Environmental Affairs
CC: Council on Environmental
Quality (5)
Response:
Comments noted.
15—1
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Testimony Given by K. Jonietz,
U.S. Department of State, at the Dec. 3, 1976
Public Hearing
MR. JONIETZ: My name is Karl Jonietz. I am from
the Office of Canadian Affairs of the U. S. State
Department. The Department of State has been given by
the Canadian Embassy in Washington a copy of a letter
from the Department of External Affairs in Canada to
the Pittston Company regarding the proposed refinery
at Eastport. The Canadian Government has asked that
the Department have this letter included in the record
of these proceedings. Accordingly, I would like to
insert a copy of the letter into the record, and I will
read it to you now.
The letter is to Mr. Kaulakis, Vice President for
Energy Development of the Pittston Company. It is
dated December 1st, from Ottawa.
“Dear Mr. Kaulakis:
The Canadian Government has for some years observed
with concern your company’s plans to use Head Harbor
Passage as a means of access for large tankers to a
proposed oil refinery in EastpOrt, Maine. As you are
aware, Canadian officials have met with officers of
your company on a number of occasions and reviewed
the proposal.
16—1
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You will recall being informed by letter of March
30. 1973 from the Department of Transport that the
physical site at Eastport would not, if in Canada,
meet the standards used to evaluate the safety of pro—
psed Canadian oil terminals and their approaches.
It has also long been clear that any significant oil
spill or leakage in the passage or in the harbor at
Eastp rt would severely affect valuable Canadian
resources, including fisheries and fish storage facilities
not only in the immediate area but in the Bay of Fundy
as a whole.
“The Canadian Government accordingly made clear to
U.S. authorities and the public as early as June 7, 1973
that the risks inherent in the transport o a large
volume of pollutants through Read Harbor Passage would
be unacceptable. and that the Government was therefore
opposed to such transport in these difficult waters.
This position has been reiterated on a number of
occasions in public statements and communications
with US. authorities and has the full support of the
Government of New Brunswick.
“Your company has apparently chosen, however, to
proceed with preparations for the project. and we
understand that the U.S. Environmental Protection
16—2
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Agency will shortly be conducting hearings on a draft
environmental impact statement on the Eastport proposal.
In light of these developments and the direct infor-
mation provided by you to Department of Transport
officials, we have conducted a thorough and careful
review of the documentation on the Eastport proposal,
including the environmental report prep3red by your
company.
“After consultation on this matter, however, with
the Departments of Transport and of Fisheries and the
Environment 1 I must tell you that we see no new evidence
which would lead us to revise our longstanding posi€ion.
“In June 1975, we noted with int.erest the decision
of the Maine Board of Environmental Protection to approve
the construction and operation of the refinery and
associated transport facilities subject, inter alia,
to the restriction that ‘Pittston shall execute
appropriate agreements or otherwise secure approval
or permits from appropriate Canadian authorities
regarding transit through and pilotage in Canadian
waters’. In view of the well established Canadian
position, it will not be possible for the Canadian
Government to enter into such agreements, extend
such approval, or grant such permits. Regulations
to give effect to our position will be issued, should
16- 3
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this prove necessary.
“This being said, I would like to make it clear
that we are sympathetic to the energy supply problems
of the New England area and are in regular contact
with United States Government officials on matters of
mutual concern in the energy field. Our opposition
is only to certain aspects of your project as currently
envisaged and relates primarily to the proposed trans -
port of large volumes ot pollutants through Head Harbor
Passage.
“The text of this letter is being sent to the
Department of State and will be made public shortly.”
The letter is signed by H. B. Robinson, Under
Secretary of State for External Affairs. That con-
cludes the Canadian letter. (Applause)
The Canadian position communicated to the Pittston
Company is that the transport of large volumes, large
quantities of pollutants through Head Harbor Passage
is environmentally unacceptable and, therefore, the
Government of Canada cannot approve transit of hydro—
carbons through the affected Canadian waters as
envisaged in the refinery proposal.
The letter indicates that the Government of Canada
has reconfirined its position following thorough review
of documentation on the Eastport proposal. The Depart-
16—4
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ment of State has been informed by the Government of
Canada that this conclusion is based on detailed
navigational and environmental studies. We understand
these studies are to be made public in the immediate
future.
As the Department has previously stated, the United
States Government considers that vessels proceeding.to
or departing from United States ports through the waters
of Head Harbor Passage enjoy the right of innocent
passage under international law. This right is not
subject to unreasonable or arbitrary interference or
suspension.
Before reaching a position on the Canadian action,
the D partment of State will wish to review the
Canadian studies carefully. Mr. Chairman, that
ccxicludes n ’ statanent.
Response:
Comments noted.
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EXECUTIVE OFFICE OF THE PRESIDENT 27 UL. 1916
COUNCIL ON ENVIRONMENTAL QUALITY
722 JACKSON PLACE. N. W.
WASHINGTON. 0. C. 20006
Peceinber 23, 1976
Dear Mr. McGlennon:
The Council on Environmental Quality has reviewed
the draft environmental impact statement (EIS) on
the “Proposed Pittston Oil Refinery and Marine
Terminal, Eastport, Maine,” prepared by Region I
of the Environmental Protection Agency, and offers
the following comments.
In many respects this EIS is a commendable effort;
its clarity and readability are particularly
welcome. The proposal and the federal actions
that pertain to it are lucidly presented. In some
important respects, however, we find the analysis
in the document incomplete.
1. The discussion of alternative sites appears to
us inadequate. NEPA requires that agencies analyze
all reasonable alternatives in their EIS process.
In this EIS, EPA has an obligation as a lead agency
to consider such alternatives, not only to its own
proposed permit decision but also to other relevant
federal decisions. Analysis of reasonable alternatives
to the Eastport site is therefore essential.
The Council recognizes that there are practical limits
to the consideration of siting alternatives, and that
it would have been easier for EPA to identify them had
the State of Maine completed its coastal zone manage-
ment plan. Nevertheless, certain alternative refinery
sites have been widely discussed and analyzed over the
past decade, and these clearly deserve special attention
in this EIS. The Council’s letter to the Administrator
of FAA on September 20, 1974, specifically mentioned two
such alternative sites —- Machias (near Eastport and also
in Washington County) and Portland (now used as an oil
terminal). These were the only two locations recommended
for refineries by the Governor of Maine’s task force
in 1972.
17—1
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—2—
The Federal Energy Administration analysis of costs
and other economic factors, included in the EIS, compares
the Eastport refinery location with two entirely
different regions, the Gulf Coast and the Middle
Atlantic; it includes no environmental analysis. EPA’S
analysis of the Portland and Machias alternatives includes
no cost analysis, and its environmental analysis is
very brief. This spotty discussion does not provide
an adequate basis for comparing alternative sites.
The draft EIS rejects both Portland and Machias on
“socio—economic grounds,” because in industrial Portland
suitable land for a refinery site was “not available,”
and the “only suitable land” in Machias was owned by
oil interests other than the applicant, the Pittston
Company. NEPA requires that agencies analyze the environ-
mental impacts of reasonable alternatives that may be
outside the individual applicant’s land ownership and
economic interests. To confine the alternatives too
narrowly to those available to the applicant --
especially here, where the interests and values repre-
sented by six federal agencies are at issue -- is to
neglect the full potential of the EIS process for informed
decisionmaking.
2. The EIS should also consider, as an alternative to
the Pittston proposal, the set of conditions to the
refinery permit as ordered by the Maine Board of
Environmental Protection. While some elements of the
Board’s Order receive passing mention in the draft EIS,
there is no systematic consideration of the Order as a
whole. The Board represents the environmental interests
of the citizens of Maine, and the conditions set forth
in its Order -— including requirements as to size of
tankers, double bottoms, tanker movements in fog and
tidal currents -— constitute a reasonable alternative to
the applicant s proposal that merits careful examination.
3. A crucial element in the Eastport refinery siting
decision is whether the tanker passage is acceptably
safe. The information and analysis the EIS provides
on this point is in our view insufficient. An analysis
by the Coast Guard of the hazards and conditions at
Eastport at least as detailed as the cost analysis
provided by FEA, including a comparison with other
locations such as Machias and Portland, would be
highly desirable. A thorough exploration of possi-
bilities for offshore monobuoy ports at each location
should form a part of the analysis.
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—3—
The draft EIS gives considerable space to the applicant’s
comparison of channel characteristics at Eastport and
at Britain’s Milford Haven, to Eastport’s advantage.
But the comparison omits fog, which is present one-third
of the time in the summer months at Eastport and some-
times forms so rapidly that visibility is obscured in
minutes; winds, for which records are incomplete, but
which reach gale force not infrequently in winter; and
frigid weather. It is conceded that tidal currents
in the 7- and 8-mile passage to the VLCC and product
tanker docks are high at times (up to 4 and 5 knots,
reflecting the great tidal reach of the Bay of Fundy); but
assurance is given that VLCC’s will undertake the passage
only when the current is slow, and that they will berth
at slacktide. However, a comparison of planned VLCC
passages, as submitted by Pittston (Table IV-9, page 233),
with information on slacktimes (p. 66) reveals apparent
inconsistencies; it appears that a part of the passage
to the VLCC dock at Broad Cove will take place at slack,
leaving not enough slacktime to complete berthing.
We believe that there is a clear need for independent
analysis of the proposed passage, in relation to all
the unusual features of tide and climate at Eastport.
A Coast Guard memorandum quoted on p. 307, of the EIS
states: “It is the opinion of the Coast Guard that the
channel is adequate for safe navigation of 250,000
DWT tankers; however, final determinations would have
to be based on the vessel dimensions, maneuverability,
speed, etc.” The EIS, however, should provide con-
siderably more supporting information and analysis
from the Coast Guard to address this issue adequately.
We recommend also that EPA complete its analysis of
real time tanker simulation studies, and the twelve
trial tanker voyages through Head Harbor passage
(required by Maine’s Board of Environmental Protection as
one of the conditions for granting a refinery permit)
before making its permit decision. EPA’s explanation
and analysis of these tests should be made available to
the public, perhaps as a part of the final EIS or in the
form of brief supplements published prior to a permit
decision.
4. A fuller, more realistic discussion of oil spill
clean-up capability is needed. It is important to note,
as the draft EIS does, what clean-up equipment will
be available. It is also important to explain what the
limits are to clean—up capability, in terms of currents,
winds, waves, and temperatures, and to relate the dis-
cussion to local conditions. No information on wave
heights in the Eastport area is presented in this EIS.
17—3
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—4—
The EIS ought also to discuss specific clean-up
responsibiliities in both U.S. and Canadian waters.
5. The EIS provides general information on effects
that may occur in and around Eastport waters if an
oil spill occurs. An effort to describe a hypothetical
oil spill in terms more specific to the site would
be helpful. The Council recognizes that the variables--
size of a possible spill, location, wind, temperature,
tidal currents, and so on —— are countless; but there
is an important value in choosing a plausible set of
circumstances and describing specific probable effects,
including the trajectory of the spill, the areas of
shore and bottom likely to be affected, and impacts on
biotic communities. Such a study was made for Machias
Bay (Massachusetts Institute of Technology, “A
Preliminary Assessment of the Vulnerability of Machias
Bay, Maine, to Oil Supertankers,” 1973), and was
useful in demonstrating possible local effects of an
oil spill in understandable terms.
5. Information presented on the “boom—and—bust”
effect of refinery construction, which will occupy
some 2,275 workers for two years, is sketchy. No
estimate is given for maximum population increase during
the construction boom. Passing reference is made to
Pittston’s intentions to construct a temporary labor
camp; but the draft EIS does not address problems of
constructing or dismantling the camp in an acceptable
manner. Mitigation of boom—and—bust effects is not
discussed, but is summarily referred to local authorities.
The Council suggests that in revising and improving
this draft EIS, EPA discuss the possibility of
mitigating possible adverse impacts by adding specific
conditions to EPA’s own new source permit. For example,
in consultation with the Coast Guard, EPA might require
the passage of VLCC’s and product tankers under
prescribed tidal, wind, and fog conditions. Likewise,
all the aids to navigation proposed by Pittston in its
application might be formally included as conditions
to the permit.
If you have any questions concerning our comments, please
feel free to call on us.
Staff Directbr
Mr. John A.S. McGlennon
Administrator - Region I
Environmental Protection Agency
Boston, Massachusetts 02203 cc: Rebecca Hanmer
17—4
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Respçrnse to Comments by the Council on Environmental Quality
Si Alternatives
Ri The discussion on alternatives has been expanded in the FEIS. See Vol. II,
p. X—42 ff.
S2 Navigation
R.2 EPA requested that the Coast Guard perform a more detailed review of the
navigational aspects of the channel. In a letter dated August 8, 1977 the
Coast Guard feels it can be premised that tdnk vessels can safely navigate
the channel approaches to Eastport under Ltain conditions, (see FEIS, Vol.
p VI—36).
Furthermore, the Pittston Co. has contracted with the National Maritime
Research Center, (Kings Point, N.Y.)to perform real time simulation studies
of tanker passage through Head Harbor Passage waters in cooperation with the
Coast Guard and the State of Maine.
Also, see FEIS Vol. II, p. X—26 ff.
S3 Oil Spill Cleanup
R3 See FEIS Vol. II, p. IV—38 ff, Oil Spill Containment and Recovery.
Also see FEIS Vol. II, p. X—5 ff.
S4 Hypothetical Oil Spill
R4 See FEIS Vol.11, p. VI—38 ff (new revised section).
S5 “ Boom—Bust” Effects
RS See revised socio—economic impact section, FEIS Vol. II, p. VI—l ff.
Also see FEIS Vol. II, p. X—3.
S6 Mitigating Imyacts
R6 See FEIS Vol. II, p. 1—3, EPA’s Decision on the NPDES Permit.
17—5
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DEPARTMENT OF THE ARMY
NEW ENGLAND DIVISION. CORPS OF ENGINEERS 2
424 TRAPELO ROAD
WALTHAM, MASSACHUSETTS 02154
REPLY TO
ATIENTION OF:
NEDOD—R—1 27 December 1976
Mr. John McGlennon
Regional Administrator
Ti. S. Environmental Protection Agency
Region I, JFK Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
The Corps of Engineers has reviewed the Draft Environmental Impact
Statement for the Proposed Issuance of Federal Permits to the
Pittston Company of New York, for the construction of a 250,000
barrel/day Oil Refinery and Marine Terminal, Eastport, Maine,
13 October 1976.
The Final Environmental Impact Statement will be the chief document
used by the Corps of Engineers for the public interest review of the
permit applications submitted by the Pittston Company. To coordinate
the development of an Environmental Impact Statement adequate f or this
review, we are submitting our comments below.
Information disclosed to date is not adequate to show reasonable naviga-
tion safety. More specific information must be provided with respect
to controlling depths in the approach channel; a broad range of para-
meters affecting vessel control (wind, wave, tide and current conditions)
must be investigated; and operation, maintenance, and responsibility for
navigational aids must be specified.
The effects from a major spill of oil, ballast or other refinery pro-
duct must be addressed. Modeling for the worst case conditions and the
evaluation of their potential impacts are necessary to properly assess
the effects of the project. Potential impacts to both the U. S. and
Canadian fisheries and fish processing industries should be included.
The primary and secondary socio—economic effects should be explored in
the Environmental Impact Statement. This should include degree of
dependence of the local economy on the fishing industry, how a refinery
operation or oil spill might affect that industry, and whether an oil—
based industrial economy might offset losses, if any, to the fishing
industry.
0 jJTIo 4
Q ,
176191€
18—1
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NEDOD—R—l 27 December 1976
Mr. John McGlennon
A complete discussion of an oil spill contingency plan is needed.
The operational plan, the necessary equipment and its availability,
and the manpower needed for performance should be presented. A
“state of the art” discussion of oil spill cleanup is essential
information. This should be compared with the realistic capabilities
of the Pittston Company.
To date, we have not received copies of the Canadian studies on
navigation and the environmental. effects of a spill on Canadian
resources. E m inat1on of this information is necessary and further
cousnenta after its review will be forthcoming.
The final statement must also include a discussion of the navigable
safety and spill potential of s a11er tankers. The sophisticated
navigational instrumentation has been outlined for the VLCC’s in
the draft statement. The navigability of partially ballasted and
fully loaded smaller vessels should be reviewed under their instrument
capabilities.
During the public hearing, the regional railroad expressed their
comaitaent to abandon the Eastport line. The need for a railroad
should be discussed to clearly inform the ICC of its need.
The construction methods to be used for dredging and pier construction
should be described in the Enviroiaantal Impact Statement. The need
for temporary structures, fills or d(kin.g must be presented. More
detail on the disposal of the dredged terial is needed, including
whether it will be used on site and whether the atoàkpile and disposal
areas will be diked.
The draft impact statement mentioned the avalinbility of four tug boats
for tanker berthing and fire fighting assistance. The impact statement
should also address tug related facilities. Docking and fueling
facilities for the tugs must be presented. If additional marine
structures or dredging will be necessary, then it must be detailed and
reviewed in the Enviroiaental Impact Statement prior to any Corps action.
The Pittston Company will be eubmitting a permit application to the Corps
for this work.
Safety of berthing maneuvers must be presented to indicate the tug and
tanker capabilities in close quarters. Adverse weather conditions in
the pier area should be considered.
2
18-2
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NEDOD—R--l 27 December 1976
Mr. John McClennon
Oil contamination of local waters would severely affect their use as
a marine resource. A discussion of economic responsibility and
liability for losses of marine resources resulting from tanker
spills or refinery wastes should be addressed.
An archaeological survey was conducted of the Pittston project
area. Upland and inter—tidal areas were investigated without
any significant findings. But, the sub—tidal area where dredging
has been proposed has not been surveyed.
The final statement should address possible impacts and coordination
with the Passamaquoddy Tribe of the Pleasant Point Reservation. The
Tribe has proposed to build the Half Moon Cove Tidal Power Project and
an aquaculture project in Cobscook Bay. The tidal power project of
the Tribe has been coordinated with the Corps and is compatible with
the Federal Passamaquoddy Tidal Project. The potential impact of
the refinery on their proposed aquaculture project should be investi-
gated.
Impacts to the reservation from the refinery construction must be
reviewed since all traffic will have to pass through the reservation.
With respect to the relationship and impacts of the proposed oil
refinery and marine terminal to the Passamaquoddy Tidal Power Project,
it is necessary to defer full comment until approximately April 1977.
At that time the economic feasibility studies on the tidal power pro-
ject will be completed by the Corps of Engineers, New England Division.
It is essential that the above information be included in the Environ-
mental Impact Statement. We feel the additional information is re-
quired and should be provided as a supplement to the Draft Environmental
Impact Statement. The supplement would include the following:
1. Navigation, navigational aids, docking, and berth facilities;
2. The environmental assessment of the effects of tanker spills
and excessive discharges;
3. Socio—econoflhiC impacts and other issues described above.
3
18—3
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NEDOD—R- .].
fr. John McGlennon
27 December 1976
The significant material being added would necessitate additional
public review and hearings on those specific areas of consideration.
Public con nt need not be opened on the entire project. Following
this process the Final Environmental Impact Statement would be pre-
pared.
The details of this additional material and the assignment of
responsibility for its preparation, can be determined in coordina-
tion meetings of the involved Federal agencies early in January 1977.
The development of an adequate Environmental Impact Statement to address
the full spectrum of public interest is essential to the Corps permit
process • We are looking forward to a continuing coordinated effort.
4
Sincerely yours,
Aci
Engineers
Engineer
18—4
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C T1,
NL’; :NC :J r r
V.:_T -A’ , ..‘ 02 54
T1 TI O
NEDOD—R—25—76—3G7 8 March 1977
}ir. John A. S. NcGlennon, Regior aL Administrator
Region I, Environznental Pro tectioa Agency
JFK Federal Building
Boston, Massachusetts 02203
Dear Nr. McClennon:
This is in reference to your letter of 15 February 1977 concerning
the development of the final EIS for the Pittston Company t s proposed
oil refinery and marine terminal at Eastport, } aine.
It appears that the proposed methodology for developing the final EIS
viii aidress all of the r jor issues that have been raised.
Your intent to delay publishing the final EIS until the Corps has
cd _ cc1 siQ s._rotCor5 stcntt ithregu1at1onsrequtring
1 ublicationof the final EIS prior to a final decisI n on iii* permit.
Also, because of the highly controversIal nátureof thePi €cn
application, I will be forwardIng the case, with my recommendations,
to the Chief of Engineers for the final decision on the application.
I will forward my recommendations to the Chief of Engineers along
with the final EIS. The final decision will be made shortly after
the waiting period that must follow the filing of the final EIS with
the Council on Environt cntal Quality.
The final EIS should present all of the impacts associated with the
proposed refinery and v arine terminal. The EIS process should identify
all environt ental impacts so that these impacts can be given full
consideration in the d2cision making proccs es regarding all of the
various Federal permits and approvals that are required. I plan to
use the final EIS as the principal back—up ocu ent for my recorinendations
to the Chief of Engineers and I anticipate that he will use the EIS
when evaluating my recommendations and making his final decision.
f
18—5
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NEDOD—R—25—76—367 8 March 1977
Mr. John A. S. }cClennon, Regional Administrator
I would lIke to have cne itc added to the questions that you
si It d to th Coast Guard in Mr. Stickney’s letter. of .2S. 3anuary
1977 The “General Issue” question concerning the navigability of
VCCC’s on a regular basis should actually question the safe
navigability of the passage ccnsidering the cox ibIned traffic of VLCC’s,
a variety of product tankers and barges, and the various tugs, service
boats, and fishing boats that c rn be expected to use the waterway. I
feel that all of the traffic in the waterway should be considered when
evaluating potential navigation problems.
Woul i please let me know your schedule for your “oil spill hazard”
i l jsissoon as itis av ,ilabl . 1 want to be sure that my staff
will be able to schedule adequate tine to review the “scenarios” that
will be considered. The most significant factor that can affect the
adequacy and usefulness of the analysis is the decision on which
“scenarios” to analyze.
I agree that the EIS process and permit decisions must be made in a
timely nner; however, we must also be extremely careful that, in
our efforts to act quickly, we do not do an inadequate job of serving
the public. If there is anything that we can do to help complete the
EIS process with a minimum amount of “red tape”, please do not
hesitate to cail me.
Sincerely yours,
o M’ c f St a —
( Colonel, Corps of Engineers
% D . ision Engineer
18—6
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!EPARTMENT OF THE ARMY
NEW ENGLAND D I VISION. CO PS OF ENG1N
J1I 424 TRAPELO ROAD
REPLY TO WALTHAM, MASSACHUStTTS O. l54
ATTENTION OF:
NEDODR—25—76367 19 April 1977
Hr. John A.S. NcGlennon
Regional Adtiinis trator
Region I, Environment&l Protection Agency
JT ’R. Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
The purpose of this letter is to confirm the Corps positIon concerning
the need for an oil spill hazard study for the EIS on the proposed
Pittston Oil Refinery at tastport, Maine.
Based on the discussions with your staff since the submission of our
eoents in December, ‘e do not feel that a special oil spill hazard
study is necessary. However, EPA ’s conclusion . that a major spill can
be expected and that the spill can be expected to adversely affect
the fishery must be clearly stated in the final EIS.
Our initial recotendation for a special study was based on our revIew
of the data presented In the draft EIS. Since that ti a, your staff
has clarified the data in the draft EIS and s1 oun that studies done
for other areas can be corsidered adequate for making reasonable
conclusions concerning Eastport. We have also reviewed the IIT study
done for Nachias to determine if a study of this tThe should be dcne
for Eastport.
Additional studies of spill probaiiility nd analysis may provide some
additional information, but we don’t feel that any informati3n of
great enough significance to affect the decision ma1 ing process will
be generated. Therefore, in the intcresc of expediting the Federal
decision makIng prccess, we reco=end that the above conclusions
concerning the probability and cff cts of spills be clearly stated
in final EIS and that r o additional studies be done.
_ 4 1 s
IJf 7
18—7
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NEDOD—R—25—76—367 19 April 1977
Mr. John A.S. McClennon
We will be providing input to the final EIS regarding effects of
dredging and blasting, and the Passamaquoddy project.
Picase contact me or any one of my staff if you feel that the Corps
can be of any additional assistance preparing the final EIS.
Sincerely yours,
RALHT.G R
Colonel, Corps f Engineers
Acting Division Engineer
18—8
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Response to Comments by the Corps of Engineers
Si Effect of a Major Spill
RI See FEIS Vol.11, p. VI—38 ff.
52 Oil Spill Contingency Plan
R2 See FEIS Vol.11, p. IV—38 ff, Oil Spill Containment and Recovery.
S3 Navigation
R3 EPA requested that the Coast Guard perform a more detailed review of the
navigational aspects of the channel. In a letter dated August 8, 1977 the
Coast Guard feels it can be premised that tank vessels can safely navigate
the channel approaches to Eastport under certain conditions, (see FEIS, Vol.
p VI—36).
Furthermore, the Pittston Co. has contracted with the National Maritime
Research Center, (Kings Point, N.Y.) to perform real time simulation studies
of tanker passage through Head Harbor Passage waters in cooperation with the
Coast Guard and the State of Maine.
Also see FEIS Vol. II, p. X—26 ff.
S4 Eastport Railroad Line
R4 See FEIS Vol. II, p. X—14.
S5 Dredging
R5 See FEIS Vol. II, p. VI—59 ff, revised section on dredging,
S6 Oil Spill Cleanup Costs
R6 See FEIS Vol. II p. X—5 ff.
Si Archaeology
Ri See FEIS Vol.11, p. X—41.
S8 Passamaguoddy Tidal Power Project
R8 See FEIS Vol.11, p. 111—159 ff.
S9 Soclo—Economic Impact
R9 See FEIS Vol. II, p. VI—1 ff. The section on socio—economic impacts has
— been rewritten extensively.
18—9
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Advisory Council on
Historic Preservation
1522 K Street N.W.
Washington, D.C. 20005 January 13, 1976
Mr. John McGlennon
Region I, Administrator
U.S. Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. MeGlennon:
Thank you for your request of November 20, 1976, for comments on the
environmental statement for the proposed issuance of a permit to the
Pittston Company for the construction of an oil refinery and marine
terminal at Eastport, Maine.
Pursuant to our responsibilities under Section 102(2)(C) of the National
Environmental Policy Act of 1969 and the Council’s “Procedures for the
Protection of Historic and Cultural Properties” (36 C.F.R., Part 800),
we have determined that your draft environmental statement appears
procedurally adequate; however, we have the following substantive
conments to make:
1. As the technical appendix was not furnished to the Advisory
Council for review, we are unable to comment with respect to the
methodology used in conducting the archeological survey.
2. To ensure a comprehensive review of cultural and historical
resources, the Advisory Council recommends that the final environmental
statement contain evidence of contact with the Maine Historic
Preservation Officer. A copy of his comments concerning the effects
of the undertaking upon these resources should be included in the
environmental statement. The Historic Preservation Officer for
Maine is Earle C. Shettleworth, Jr., 31 Western Avenue, Augusta,
Maine 04330.
Should you have any questions on these comments or require any additional
assistance, please contact Jordan E. Tannenbaum of the Advisory Council
staff (202—254—3380).
______________________________ Sincerely yours,
Response:
: letter.
John D. McDermot V
__________________________________ Director, Office/of Review
and Compliance
19—1
The Couscil is an independent unit of the Executive Branch of the Federal Government charged by the Act of
October 1 , 1966 to advise the President and Congress in the field of Historic Preservation.
-------
tp 2 91977
MAINE HISTORIC PRESERVATION COMMISSION
242 State Street
Augusta, Maine 04333
Earle C. Shettleworth, Jr. Teiep1io
Director 2O7-289-2
September 26, 1977
Mr. Wallace Stickney, Director
Environmental Impact Office
Environnvrntal Protection Agency
2203 JFK Federal Building
Boston, Massachusetts 02203
Dear Mr. Stickney:
In response to your request, I have reviewed the Pittston
Company’s proposal for the construction of an Oil Refinery and
Marine Terminal at Eastport, Maine. I find that this proposal
will have no effect upon any structure or site of historic, arch-
itectural, or archeological significance as defined by the Nat-
ional Historic Preservation Act of 1966.
If 1 can be of further assistance concerning this matter,
please do not hesitate to let me know.
Sincerely,
Earle th, Jr.
State Historic Preservation Of
-------
COMMENTS SUBMITTED BY
STATE AGENCIES
-------
GOVERNOR AND COUNCIL
* P€edd4e P e
PERRY, MAINE 04667
December 3, 1976 1:00 P.M.
Shead Memorial High School
Eastport, Maine
U. S. Environmental Protection Agency Department of the Army
Region I New England Division, Corps of
Enforcement Division, Permits Branch Engineers
John F. Kennedy Federal Building 424 Trapelo Road
Boston, MA 02203 Waltham, MA 02154
RE: NPDES ME0022420
CORPS 25-76-367
Pittston Company
Gentlemen, Members of the U.S. Environmental Protection Agency, the Department
of the Army, CORPS of Engineers, and members of other Federal Agency and State
Agency representatives; My name is Raymond Moore, Lt. Governor of the
Passamaquoddy Nation.
I have been appointed by Governor Nicholas to represent the Passamaquoddy
Tribal Council in stating our position on your Issuing permits to
the Pittston Company.
Until November 22, 1976, upon receiving a copy of the Draft Environmental
I nact Statement, We have never be roached by the people responsible for
th report and the oil refinery. The Tribe has been totally ignored in a
decision that will affect every individual Passamaquoddy m ber.
During the last ten days the Tribe has not had enough time to analyze the
three volumes of the Environmental Iriinact Statement adequately. For the pur-
poses o this hearing, we thdrefore, oppose Lhe oil refin ry and your issuinq
p2rH ts to the Pittston Company.
do not have the resource ; or sta If as this big corporati on, although at
tnis t . . ar b1 e to proii de comn ents on the foil o i rig ar2as
20-1
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The Pleasant Point Passamaquoddy Tribal Council has long been interested in
tidal power as a valuable energy source. The most immediate concern is how
the tribe 1 s own proposed tidal project at Half-Moon Cove would be affected
by the oil refinery. Our tidal project planned for Half-Moon Cove would
have a definite impact on the present population’s economic status, supply
a renewable energy source for the reservation and surrounding area, and pro-
vide tidal technology its opportunity for development for future tidal pro-
jects. Because of this linkage with future tidal project’s it is important
that the viability of the Half—Moon Cove tidal project is not damaged by the
oil refinery’s construction and operation. We must request that a compre-
hensive study on the interrelationship between any proposed tidal schemes
(i.e., Corp of Engineers, LJ.C., Stone & Webster) and the operation of an
oil refinery must be conducted and reviewed before any further steps are
taken in the planning of the oil refinery.
The Pleasant Point Tribal Council has supported the tidal project from
the beginning. It recognizes that tidal power is a clean and renewable energy
resource as opposed to oil which is nonrenewable and environmentally dangerous.
Quoting directly from Vol. I, pg. 40 of the Draft Environmental Impact State-
ment “...., the refinery may represent a commitment to an industrial activity
which could result in the suppression or even elimination of a renewable re-
source - fishing.” Five years ago the Pleasant Point Reservation held a
referendum vote on the desirability of an oil refinery. By an overwhelming
majority the refinery was rejected.
20-2
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- - ---‘
4 Do You Pre erQuQddyorpjttstQfl? -
• Ouøddy
IF
17
I El
—
The Bangor Daily News in : p i1 1974 conducted a poii of
Eastport and other towns nearby on the issue of an oil re-
finery. One of the questions was whether respondents vouId
prefer the Passaniaquodcty Thial Power Project or an oil re-
finery. The results for Eastport are shown above. Lu’oec,
• Machias and Pembroke also preferred the Quoddy project by
, 6 , an 3 percent, respectively.
The Diagram shown above is a poll conducted in 1974 by the Bangor Daily
flews which shows the Quoddy Project being favored by a nine to two ratio.
We feel that a similar type of behavior exists today.
We have stated several strong points that have to be clarified. Consider-
ation has to include thesocio-eCOflOmiCaSPeCtS the area’s energy demand; the
protection of the environment; institutional restrictions and the investigation
of alternate projects which might be incompatible with the irreversible conse-
quences of the construction and operation of an oil refinery.
In consideration to all concerned, we intend to develop a more precise state-
ment based on refining our own analysis of the Environmental Impact Statement.
Prior to the deadline of December 13th, the U.S. Environr ental Protection Agency
and Departrnent of the ft rn y will receive in writing,statements concerning our land
and the Environment a 1 a ffectL ro pse Pitts ton Jij n rY .
Thank you.
(1) f\ttch. 20—3
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Attachment: December 3, 1976
Coninents - Draft
Environmental Impact Statement
The Pittston Company
In Volume 11 pg. 9 U.S. Coast Guard, Department of Transportation In
addition, Pittston must file a “Spjll Prevention Control and Countermeasure
Plan” with the Coast Guard within six months of the start of operation.
BEFORE or AFTER a debatable point.
In Volume I pg. 17 Terrestrial and Aquatic Flora and Fauna However, it
should be noted that the Penobscot/Blue Hill Bay area is the center of Maine’s
lobster, clam and fishing industry.
Another debatable issue.
In Volume I pg. 17 Oil Spills Entire paragraph eludes to costs of oil spills.
Oil Spills are equally damaging, wherever: The economics involved are equal
as well.
In Volume I pg. 40 Marine Resources .,The fishing industry could also be
eliminated. A $500,000,000 oil refinery with a future of transporting in a
natural resource, is a minimal amount to pay when a potential exists that could
emit ten-fold in utilization of the present environmental resource of this area,
Mariculture and Tidal.
Passamaquoddy Tribe
Governor’s Office
20—4
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Testimony Given by Mr. Chandler at
Dec. 3, 1976, Public Hearing
MI(. C l (I N1LL1 I ‘ u l’l I •
rather than a questi n, on Lieutenant Govotitor Moore’s
comments. I agree that. tue Half—Moon Tidal Project
should be included in the Environmental Impact Statement
and the impact identified. In fact, this hearing is
really serving its purpose then to have learned of
your concern on behalf of the Passarnaquoddy Nation.
As an aside, be assured that my staff has advisec me
earlier this week that your proposed project is
compatible with the larger Passamaquoddy Tidal Project.
And as I said here earlier today in my opening remarks,
the larger project is thought to be compatible with
the Pittston proposal. Nevertheless, in order to
assure ourselves that these relations continue to be
examined as both tidal projects are further defined
and the filing of the final impact statement approaches.
we should incorporate your project into the Environ-
mental Impact Statement.
Let me further assure you that the Corps of Engineers
will continue to work closely with the Passarnaquoddy
Nation in this matter.
20—5
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OFFICE OF THE GOVERNOR
* Péeada4ee O e e4ewae o c
PERRY, MAINE 04667
TO: Mr. John A.S. McGlennon
Regional Director
U.S. Environmental Protection Agency
Regional I
John F. Kennedy Federal Building
Boston, Massachusetts 02203
RE: NPDES ME0022420
FROM: Francis J. Nicholas /
Governor
DATE: December 10, 1976
I have enclosed (2) copies of our statement relating to the evaluation,
and assessment of the Draft Environmental Statement concerning the Pittston
Company of New York and their proposed Oil Refinery. The Passamaquoddy
Tribe requests your agency to reject this permit or permits requested by
this company and any other company or corporation, proposing an oil refinery
in the Passamaquoddy or Cobscook Bay area.
We have, also, forwarded a similar request to the U.S. CORPS of Engineers,
Departhient of the Army.
cw
S
20—6
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GOVERNOR AND COUNCIL
*
TO: Mr. John A.S, McGlennon
Regional Director
U.S. Environmental Protection Agency
Regional I
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Enforcement Division, Permits Branch
EPA: NPDES ME0022420
€4d4 t P.e e e4e tiô.c
PERRY, MAINE 04667
December 10, 1976
Col. John P. Chandler
Division Engineer
Department of the Army
New England Division,
Corps. of Engineers
424 Trapelo Road
Waltham, Massachusetts 02154
CORPS. 25-76-367
RE: Permit issuance
Applicant; The Pittston Company
of New York
On December 3, 1976 at the Hearings held at Eastport, Maine, Lt.
Governor Raymond J. Moore presented a preliminary statement on behalf of
the Governor and Council of the Passamaquoddy Tribe. Lt. Governor Moore’s
statement emphasized the following:
a) The Tribe was completely ignored by the Federal Agencies,
and State Agencies involved,
b) The Tribe was completely ignored by the Pittston Company
and their advocates,
c) Until receipt of the EIS Volumes I, II, and III on November
22, 1976, specific information had not been available,
d) December 3 Hearin is were held too soon for adequate review
by Tribal StafF,
e) Future Tidal Projects will be placed in complete jeopardy,
f) No consideration taken on the Tribal referendum concerning
Occidental Oil , five years ago, by either Pittston or the
Federal or State Agencies involvad,
g) And, no con idoraticn to th Tribe of it’s ri jhts of pur rg
without restrictions tha development o natural reSourCes on
Tribal 1 ar.ds nd waters,
GW’
S
20-7
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We have reviewed the Environmental Impact Statement and have found,
the SL temant lo be inadequate and not complete in the Biology arid Socio-
economic area, and environmentally dangerous
The Passamaguoddy tlation throu i its Tribal government requests the U S.
Environmental Protection Agency to fulfill it’s purpose and mission for
which this Department was created and,reject any permit orpermjts
reauested by this company (Pittston) or any other company or corporation;
and. req uest the U.S. Department of Army, CORPS of Engineers to reject
the request for permit for construction ofan Oil refinery .
The Pleasant Point Passamaquoddy Tribal Council in this written testi-
mony will state its position on the issuance of permits concerning the
Pittston oil refinery. The Three Volumes of the Draft Environmental State-
ment have been reviewed and evaluated in regards to the oil refinery’s
potential impact on the Pleasant Point Reservation and the environment,
The Tribe has depended on the natural resources inherently abundant
in the region for its existence. The qualIty of land, water, and air are
now being threatened by the Pittston project. The industrial complex
planned by Pittston has not been responsive nor considerate of the basic
needs of the people living in the affected area. The promise of economic
rejuvenation is supposedly the major arguing point for the oil refinery’s
acceptance by the people of the region. We believe that the Tribe can be
more selective on matters affecting its future. We believe that there is
nouqh initiative from the native population to d ’tej mine its economic
dectiny. For example. tho Iribe has developed and proposed orojects in
c1r’ -’ S of aqriacul tur and Tidal Powet’ durini L}i nas t year which would
have a det I : 1 tp ip. on the region i thout rul i n out or ci mu nati miq
20—8 2oflO
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other options for deye1oç nent We further believe that projects, similar
to Tribal proposals, would be severely hindered by the Pittston refinery,
Pittston would receive the financial benefits while not risking the loss
of its land and environment,
Our position on factors related to the Pittston refinery will be ex-
pressed in the following pages. The topic which concerns the tribe the
most is how the environment will be utilized and protected for present
and future generations: The technical questions concerning federal en-
vironmental guidelines and refinery operations have not been addressed
in our report. We do not have the staff nor the time to analyze these
matters. It will be assumed that the federal regulatory agencies (i ,e ,,
Environmental Protection Agency, Corps of Engineers) will be responsible
for th.e enforcement of environmental guidelines Our only comment on this
matter is directed to the problem of 1ong- term effects of continuous
discharges of pollutant contamination of Cobscook Bay as a function of
time. Studies of existing and comparably—sized reFineries should contain
the type of information needed to assess long—term environmental effects,
The topics which will be commented upon will include: a uacu1ture;
soc o -political impacts; tidal power; environment; and economic, concerns,
I, ENVIRONMENT
Comments are related to the three phases of ir plernentation.
A, Planning & Design;
- Community needs have not been given any consideration , The
Tribe has been totally ignored in a decision that will affect
every individual Pas naquoddy men ber. Th2 ction of Pittston
has been progran;med for acceptance frd1 select, influential
groups not totally repr entative of the
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Provisions for advance planning to avoid a “boom-bust”
situation (Vol. 2-pg. 356) are not adequate. We do not feel
Eastport has the practical experience nor the staff necessary
to deal with the problems within such a short period of time.
Housing for the construction crew will be a major problem (RE:
Vol 2—pg. 295). There are many old houses presently unoccupied
in Eastport and a great deal of repair is needed. Since 92.4%
of the houses have been constructed before 1940, the condition
of these homes are of questionable value.
B. Construction -
The traffic (motor and rail) entering and leaving Eastport will
be passing through the reservation along US. Route 190, there-
by, creating a safety problem to pedestrians and traffic. In-
creased noise levels will be a related problem. We were not
aware of any safetyprecautlons outlined in the EISrelated to
this problem which is of vital importance to the reservation.
This question is related to a basic premise of our comments:
“If Pittston’s project is such an environmental risk and since
it demands a decision on exchanging a renewable resource for
a non-renewable resource; then, why hasn t the reservation
been involved in the decision—making process?” We understand
that this is our opportunity to have an input into the choice
of an economic structure for the surrounding region, and, we
hope that our concerns will be clarified before any decision
is made that affects our Community.
C. Operation
The possibility of a major or minor oil spill is an ev’ nt which
would have a catastrophic effect on any plarire i acmiaculture
project in ( ohscook 1 ay. This topic will ht covered in detail
20—10 4 oF 10
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in the section on aquaculture; however, for now we would
like to request an estimate on the worth and assessment of
existing and proposed aquaculture projects in case of damage
from spillage and how the parties responsible for damage
would be held liable, We realize that there must be some
sort of legal precedence for refinery—related accidents, but
our i ediate concern is focused on equitable payment and ad-
justI ents for losses of marine resources.
The discharge of solid and liquid wastes into Cobscook Bay is
a problem analogous to a dirty bath tub. As the oil is dis-
charged into the bay it is circulated along the tidal basin’s
surface and perimeter until it is either flushed or deposited
on shore with the ebb and flow of the tides. This residue will
accumulate on the tidal flats and in the water columns; there-
by, causing potentiai damage to the marine life and shell fish.
We feel that the EIS did not deal with this long-term cumulative
effect as a major environmental problem.
II. Aquaculture
The following comments are related to the specific aquaculture program
at the Pleasant Point Reservatton. During this past year an aquaculture pro-
ject was initiated which investigated various types of shellfish (i.e., oysters
mussels, clams, etc....) for their potential in a cold-water environment.
Two additional projects hove been proposed for next year w iich includes an
ext nsive aquacuiture study and the construction of a rish-processirig plant.
- The draft US report did not contain any specific mention of
potential aquaculture projects in Cobscook arid Pass aquoddy Ray.
We have concluded frc i ojr studies that aquacultur Y;ill h9
an int ra1 el nent oF fu Lure nir inc epnent rojec t on
the r ’servati fl rifld tppl icThle L:: . i e
S cf 10
20—li
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The importance of the food chain link which is dependent on
a delicate balance between micro-organisms, plankton life,
tiny marine species (i.e., prawns - a red shrimp), and the
large marine species has not been described in the draft EIS
report. The connection between oil spills, waste discharge,
and contamination effects is one specific area where the
draft EIS report is lacking.
III. Socio—Political Impacts
The construction of a major industrial project in Eastport will change
the rural characteristic of the area and endanger the present lifestyle of
the reservation’s population. We realize that there will be economic bene-
fits from employment and business stimulation. The tribe is reluctant to
support a “boom-bust” economy which might result from the Pittston refinery.
It is also concerned with the types of social ailments symptomatic of in-
dustries based on a non-renewable resource and a non-indigenous construction
work- force.
IV. Economic
According to figures from the Federal Energy Administration (FEA) the
refinery might result in a decrease of S.OO5/gal in oil prices. New England’s
“Need for the project” is defined by FEA in terms of:
— U.S. demand for petroleum products
- Developing U.S. refineries
-- National policy
-- Security of supply
-— Economic benefits (i.e., balance of payments, capital
investment)
-- Siting in N w England
Pittston’s motive is based on an economical rationale. e iindc rstand th
different needs, but we are confronted wi Lb the proble; o sacri icinçi o’ir
20—12 6 of 10
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environment for the construction of an oil refinery with a limited life-
time (as determined by the availability of an adequate oil supply).
Pittston has traditionally purchased its oil from both domestic and foreign
sources. This raises the question of a dependable oil source for Pittston’s
continuance — future supply and demand.
There is no doubt Eastern Washington County could use the $400-600
million, that this project would bring in, nor any doubts for increasing
employment in this area by the 200 full time job opportunities. The total
300 employees full time, yielding an annual payroll of $3 million would
certainly be an asset to any community. There would be an economic gain.
With art economic gain, we see a tax base increase arising out of a
dollar base increase per capita; demands on housing, utilities, public
services, and, the up-grading of each, warrants considerable attention
across the entire scope of that cciirnunity’s responsibilities to jt’s re3ider,ts.
This would also be an asset to the Community or if not evaluated adequately
a disasterous “boom-bust.’
Now as in past years employment opportunities in l Iashington County for
Indians was and is non—existant. We have stood in line, and waited for job
applications to be responded to, and have never realized these opportunities.
The only job’s available have been those developed here on-reservation over
the past 3-4 years. Yes, there is discrimination by local towns and local
companies and unions. W anticipate that this attitude would not change,
and, in total area econcmics; The PasSama9 dd jrihe_would suffer_the nost.
There would be higher costs for basic neccessities. Food which is presently
ahurd nt and threatened — i.e., clars, oysters, lohst r, periwinkles. pollock,
haddock, etc. , and, the potential of these increasiuq ;‘e econciiic ractors
not taken into considerat ion by Pittston (Two months ago. record caLch s
were recorded on fish and squid, when foreign fishing il ets imved out of
the m’eI beyon i th 200 ii le limit).
20—13 7 of 10
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V. Tidal
The Pleasant Point Passamaquoddy Tribal Council has long been interested
in tidal power as a valuable energy source. The most immediate-concern is
how the tribe’s own proposed tidal project at Half-Moon Cove would be affected
by the oil refinery. Our tidal project planned for Half-Moon Cove would have
a definite ic pact on the present population’s economic status; supply a re-
newable energy source for the reservation and surrounding area; and, provide
tidal technology its opportunity for development for future tidal projects.
Because of this linkage with future tidal projects it is important that the
viability of the Half-Moon Cove tidal project is not damaged by the oil re-
finery’s construction. We demand that a comprehensive study on the interre—
lationship between any proposed tidal schemes (i.e., Corp of Engineers, I.J.C.,
Stone & Webster) and the operation of an oil refinery must be conducted and
reviewed before any further steps are taken in the planning of the oil
refinery.
A brief description of our Half—Moon Cove Project is appropriate at this
time to show the importance of this project to future tidal investigations
and the economic livelihood of the surrounding area. The development of
tidal power into a useable and economical form of energy is the primary ob-.
jective behind the planning for the construction of the Half-Moon Cove Tidal
Power Plant. From its inception the project has been considered as a demon-
stration plant for the purpose of developing tidal technology into an area
ofapplied technology. In addition to the production of an appreciable amount
of energy th3re would be mmy positive side benefits connected to the tidal
plant’s construction. They would include: the development of a sound economic
base for the surrounding area; the enhancement of recreational industries
and tourism; the investigation of research and deve1op;i ent topics; and, the
direct irnp1en ntation of a previously unused n itura1 resourcc for energy pro-
duction. The economic development is associated with the proposed aquaculture
20—14 8 of 10
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industry utilizing the closed and controlled bay, and, the introduction
of allied industries (i e , gas production, desalinization, cryogenics)
which would Lu iLtracted through the availability of tidal generated
e ectricity.
Tha ap raisa1 report prepared by Dr, Normand Laberge is a sumji ary of
the work which has been accomplished during the past year on the tidal
project ar.d is available on request, Because of the power plant s size
the immediate ber eFits will he focused on the surrounding area and a
regional power network.
The Cobscook Bay area has many sites available for the application of
the technology that would be researched and developed at the Half—Moon
Cove Tidal Projects The possibility’ of linking these small basins into
an integrated power network i’s a realistic objective for future tidal develop-
ments, The system of basins could produce a continuous energy supply and
also serve as a site for aquaculture projects, However, before these pro-
jects can be termed cost- effect1ve a research and development program must
be instituted at a site appropriate for demonstration purposes (i e.,, Half-
tioon Cove),
Further, tidal development will also be aimed for national and global
implementation of tidal technology as a viable source of energy production -
a natural resource for this area.
The Pleasant Point Tribal Council has supported the tidal project f oni
the beginning. It recognizes that tidal power is a clean and renewable
energy resource dS opposed to oil which is nonrenewable and environmentally
dangerous. Quoting directly from Vol. 1, pg. 40 of th DraFt_Environm ’nt i
Impact Staten’ent “. , the refinery may represent a co nitment to an in-
dustrial activity which could result in the suppression or even elit ination
of a rnewable rc so Jrce - fishny. Five y: ars ago the Ple. s nt Point
P.. rvatio h ld d reF:reeiduii vot on the d si rahil ity of un oil reuin ry.
20—15 9 0t 10
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By an overwhelming majority the refinery was rejected. The regulatory
agencies should not be the only party contacted.
As an addendum to this document we have added It. Governor Moore’s
presentation with the attachment concerning four relating comments. In
this document, we have not been able to address all the facts that we
draw our conclusions on. The severe climatic conditions in temperature
changes, fog, sr.cw, rain coupled with high winds, and strong tides and
currents are significant enough to warrant these permits to be rejected.
The Passarnaquoddy Tribe in this document has presented its major areas
of concern regarding the Pittston oil refinery; After these facts have
been carefully reviewed, we have reached the opinion that the Tribe can
not support the refinery’s construction until serious differences (as ex-
pressed in this document) have been resolved by Pittston and the Federal
agencies. However, we are of the opinion that our concerns with aquaculture
and tidal power are incompatible with the Pittston project until proof is
presented to the contrary. We wish to have the opportunity to make final
judgement and assessment of any new information pertinent to our project.
We are not opposed to economic development in Washington County on a unilateral
basis, but we have voiced our opposition to the oil refinery because of
the potential dangers to our environment and because of possible detrimental
side effects which would affect the future utilization of the natural
resources of Cobscook Bay and adjoining waters.
Governor and Council
December 10, 1976
20—16
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Responses to Comments by Passatnaguoddy Tribe
Si. The Passamaquoddy Tribe has never been approached by the people
responsible for the oil refinery.
Ri. On February 17, 1976, at a meeting in Boston of the FRC Energy
Resources Development Task Force, eight representatives of the
Passatnaquoddy Tribe headed by Governor Francis J. Nicholas heard
a Pittston presentation on the project. On July 21, 1976, a copy
of the Environmental Assessment Report was hand delivered to
Governor Nicholas by Pittston’s Eastport representative, together
with a letter of transmittal from Pittston’s Vice President. In
October and November 1976, after issuance of the DEIS, Pittston’s
Eastport representative asked for opportunities to discuss with
tribal representatives their views on the project.
S2. The tribe has not had adequate time to review the DEIS and opposes
the issuing of permits to Pittston.
R2. Comment period was extended.
S3. The viability of Half Moon Cove tidal project is important to
remain preserved.
R3. See FEIS, Vol. II, p. III—159ff.
S4. The Pleasant Point Tribal Council has supported the tidal power
projects from the beginning and recognizes that tidal power is
a clean, renewable energy source.
R4. Comment noted.
S5. Five years ago the Pleasant Point Reservation held a referendum
on the refinery and it was rejected by an overwhelming majority.
R5. Comment noted.
S6. Consideration has to include the socio—economic aspects: the
area’s energy demand, the protection of the environment, institu-
tional restrictions and the investigation of alternative projects
which might be incompatible with the oil refinery.
R6. See FEIS, Vol. II, p. VI—lff, p. IV—lff, and p. III—l59ff.
S7. When must Pittston file a “Spill Prevention Control and Counter-
measure plan”——six months before or after operation of the
refinery begins?
R7. Six months before the start of refinery operation.
S8. In Volume I, p. 17, Terrestrial and Aquatic Flora and Fauna,...
However it should be noted that the Penobscot/Blue Hill Bay area
is the center of Maine’s lobster, clam, and fishing industry.
Another debatable issue.
20—17
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R8. Comment noted.
S9. In Volume I, p. 17, oil Spills, entire paragraph eludes to
costs of oil spills. 011 spills are equally damaging, where-
ver: The economics involved are equal as well.
R9. Text has been modified.
S10. A $500,000,000 oil refinery is a small price to pay when the
potential for tidal power and aquaculture exist.
RIO. See FEIS, Vol. II, p. III—159ff.
The refinery construction or operation should not have any adverse
impacts upon aquaculture projects.
20—18
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DEPARTMENT OF
INLAND FISHERIES AND WILDLIFI
284 STATE STREET
AUGUSTA, MAINE 04333
A’fl4AROc MARS$
WtLS4MPEPPARO
flCoNVPdSiOnIf 4 0j -
October 22, 1976
Mr. Morgan Rees
Chief, Regulatory Branch
Operations Division
New England Division, Corps of Engineers
424 Trapelo Road
Waltham, Massachusetts 02154
Re: NEDOD—R—25—76—376
(Maine DEP Wetlands #03—14 —2921O)
Dear Mr. Rees:
The environmental responsibility of this Department as concerns this
application by the Pittston Company centers around the potential
harm to waterfowl and other aquatic birds. While we do not object
specifically to the construction proposed, the facility will carry
with it the ever—present threat of a major oil spii 1 . This would
be devestating to wildlife in the area.
Enclosed is our cot nt to the Maine Department of Environmental
Protection concerning this project.
Sincerely,
Maynard F. Marsh
Cotmnissioner
MFN/CFR: cs
Enclosure: Environmental Protection Recommendation
cc: Machias Headquarters
Francis E. Reynolds, District Warden
John Bader, Environmental Protection
2 ’- ,.
21—i
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. II JLU4 ,I. IJ. & .U ’. LLiL’JI
r L Lh.L .LLLLa”u t .LsuerleS flCI L. . I1!3
rc sed Proj.’ct pj rDo ng Facilities — Eastport —Wash: Co. (The Pittston Co.)
DEP Project 1 •:er
#03—1466—29210 Due Date: 8/25/76
After t1ic r u l rv c- ’ of the above na icd project, as presented to us by the applicaii
or his .gc: t, r d coI1 ide1-3tLr fl of tha project’s cf ects on the environr nt and cur
progra:.s an i responsibilities, the following cor izent s are subnitted to the D partr nt
b Enviro .-i :r.antal Protection.
1. Aspects of the pro esed proJect fal] within the jurisdiction and/or interests of
this agency. ChECK C X L: YES X NO ________
2. The r.ropo ed project is in accord with our progran s and responsibilities.
CHECK ONE: YES ____ NO ____. If NO, please st*bnit details, on a separate shc -t.
. it I c our o inion that th proposed project doos warrant a public hearing.
CHECK ONE: YES NO
Fisheries Considerations — Carson — Anderson — Wildlife Considerations
“We would like to point out that, in our opinion, an oil spill could
have a rerious impact on waterfowl and other aquatic birds”.
Response:
Comments
noted.
—J
September 8, 1976
21—2
1sf (;7 2 /2 7 —
I)a t e
,..,,. ., .. / /
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NTAT MAINE
OV THE GOVIIPr40fl
AI 0UNTA, MAINE
04080
November 24, 1976
JAMES B. LONG LEV
ObV PNO
John McGlennon
Regional. Administrator
United States Environmental Protection Agency
Region I
John F. Kennedy Building
Boston, Massachusetts 02203
Dear John:
In late September I requested the Chairman of the Land
and Water Resources Council to coordinate a multi-agency
review of the Pittston/Eastport oil refinery Draft Environ-
mental Impact Statement.
In that request I made it clear that the Board of
Environmental Protection’s decision on the Pittston
proposal should represent the State’s position on the
environmental aspects of the proposal. However, since the
scope of this Environmental Impact Statement as mandated
by the National Environmental Policy Act exceeds that of
Maine’s Site Location Law, I asked the Council. to evaluate
the Draft Environmental Impact Statement and con nent on
the following aspects of the proposals
(1) Social and economic impacts of the development.
(2) Effects on the State’s energy supply and price.
(3) Cumulative impacts (i.e. additional development
that might be stinnilated by the presence of a
refinery);
(4) Any acceptable alternatives to the whole proposal
(or part of it).
The Maine Land and Water Resources Council is composed
of the following:
One member each of the State Senate and House of
Representatives
The Director of the State Planning Office
The Commissioner of the Department of Environmental
Protection
(Over)
22—1
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John McClennon -2- November 24, 1976
Regional Administrator
U. S. Environmental Protection Agency
The Director of the State Development Office
The Commissioner of the Department of Conservation
A representative of the Directors of the Regional
and County Planning Commissioners and the Council of
Governments
The Vice President of Research of the University of
Maine at Orono
The Commissioner of the Department of Marine Resources
The Commissioner of the Department of Inland Fisheries
and Wildlife
The Commissioner of the Department of Agriculture, and
The Commissioner of the Department of Transportation.
The Council has completed its review as requested
and submitted its report to me. In line with my normal
policy, I am forwarding this report to you for inclusion
in the official record of your public hearing on December 3.
I would also appreciate it if you would publicly read
this letter at that hearing and make the attached copies
of the Council’s report available to interested members
of the public and media.
Sincerely,
JAMES B.
Governor
JBL/gwd
22—2
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November19, 1976
PITTSTON/EASTPORT REFINERY
POSITION PAPER OF THE MAINE LAND AND WATER RESOURCES
COUNCIL ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
Background
In the Spring of 1973, the Pittston Company filed an application with the
Board of Environmental Protection, under conditions of the Site Location Law, for
permission to construct a 250,000 barrel per day oil refinery and two marine terminals
in Eastport, Maine. One marine terminal, located at Shackford Head, would be
for the receipt of crude oil. The other terminal, located at Deep Cove, would be for
the transshipment of refined product. The total cost of construction was approximately
$500 million. It was originally proposed that the crude oil would arrive in
250,000 DWT shps and that the refined product would depart in 70,000
DWT ships. The route of travel to and from the terminals would be thr3ugh Head
Harbour Passage, Friar Roads and Cobscook Bay.
From the summer of 1973 until January of 1975, the Board held hearings on
the proposal. The hearings were s pended and resumed several times. Such Issues
arose as Opposition from the Canadians to the ise of their territorial waters, substantial
‘ 1 fltle, right and interest” to the land on which the refinery would be located, and
proper control of airport property.
In March of 1975, the Board of Environmental Protection issued a conditional
permit to the Pittston Company to construct the refinery. Two major concl&ons were
drawn. First, the crude oil transport system failed to meet the requirements of the
Site Location Law. It failed to make adequate provision for the movement of the crude
carriers to and from the refinery site, it did not meet the water pollution control
22—3
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standards, and it would have an adverse effect upon the natural environment. Second,
the refinery and the oil storage facility and product transport system did satisfy the
requirements of the Site Location Law, sthject to certain conditions.
Sixty-three conditions were amended to the Board order. There were General,
Pre—Operaflonal, Navigation and Vessel Design, and Continuing conditions. Major
among the condhions were, one, the resfriction to only one product pier and, two,
the prohibition of vessels of greater than 70,000 DWT from carrying crude oil or refined
product to or from the marine terminal.
In June of 1975, the Board issued another order allowing the Construction of
the second crude oil unloading pier at Shackford Head provided that it was located in an
area where currents were one knot or less. This change was based upon better under-
standing of existing oil spill containment technology and upon a more precise location
of the one knot line in the Shackford Head area. After reviewing the record ‘he
Board also concluded that ships up to 150,000 DWT could be safely navigated in the
channel waters. Therefore, the two loading piers and the increased tonnage carriers
for both crude oil and refined product transport were permitted, with conditions, in
the sthsequent order.
As a result of the two BEP orders, a lawsuit was filed against the
Board. The Office of Energy Resources sued becaLse the permitting of the oil refinery
would possibly preclude the building of the ftissamaquoddy Tidal Power Project. The
Department of Marine Resources sued becai.ze, given the possibility of a major oil
spill in the area, short and long term irreversible harm would occur to the marine life
of the local area and to the Gulf of Maine generally. The Department of Inland
Fisheries and Wildlife sued because, given the possibility of a major oil spill in the
22—4
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area, short and long term irreversible harm would occur to anadromoi. and cotadromoie
species of fish and to the thousands of marine and other birds wing the area including
eagles, osprey, waterfowl, shore birds, wading birds and sea birds. The Office of the
Attorney General is representing the three aforementioned state deparirients, or plaintiffs,
in the suit against the Board of Envkonmental Protection. A fourth plaintiff in the law-
suit is the Coastal Resources Action Committee.
Council Involvement
In September of 1976, Governor James B. Long ley, In a memo to William R.
Adams, Chairman, requested the Land and Water Resources Council to coordinate a
multi-agency review of the PlttstorVEastport refinery DEIS and report on its recommendations
for an appropriate state response. Stating that the BEP orders should represent the
state’s position on environmental aspects, the Governor asked that the Council limit
its report to the Following five areas:
• relating the Rndhigs and decisions of the BEP orders to the findings
and conclusions of the DEIS, and commenting on the
• social and economic impacts of the development;
• effects on the state’s energy supply and price;
• c miulative impacts (I.e., additional development that might be stimulated
by the presence of a refinery); and
• any acceptable alternatives to the whole proposal (or part of it).
The Council, at its regular meeting of October 19, 1976, acted on the request
of the Governor. The CouncIl assigned a subcommittee composed of the State Planning
Office, Chairing, the State Development Office, the Department of Conservation, the
Senate member and the House member to formulate the comments In the five sublect
areas. The Deportment of Marine Resources, the Department of Environmental Protection,
22—5
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the Office of Energy Resources, the Department of Inland Fisheries and Wildlife and
the Office of the Attorney General were asked to provide input to this process, as
requested by the Governor in his memo. All other members of the Council were also
asked for comment.
Comments of the Council on the Pittston DEIS
It should be clearly noted that the Council has been asked, In the Governor’s
memo, to comment on the adequacy of the DEIS, not on the relative desirability of the
Pittston proposal directly. In this regard, the Council notes the statement in that memo
that the BEP Order “should represent the State’s position on the environmental aspects
of the proposal.” The Council has chosen not to raise any additional environm,ntal
questions in this position poper while also recognizing that h.’o of its membe’ , the
Departments of Marine Resources arid Inland Fisheries and WildUfe, are currently in
lifigatien with the Board over environmental matters. Therefore, U must be recognized
that thk position paper does not purport to fully represent all of the concerns raked by
its members relative to the entire PDtston proposal. This cannot be accomplished fully
until all decisions have been rendered relating to the lawsuit.
It is the conclusion of the Council, however, that the DEIS is deficient in
several areas. These are summarized here and expanded upon in sections A through E
following.
. None of the conditions appended to the BEP decision have been addressed.
Although the legal requirements of the DEIS may not call for the inclusion of, or even
reference to, the Order and Us specific conditions, it is the position of the Council
that the SEP Order stipulates many environmental feelings strongly held by Maine people,
and that at least the major conditions of the Order should have been referenced in the
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DEIS. Because they were not, some motor conclusions appear to be based upon uncertain
data. These include data relating to currents, Fog, and oil spills.
• Some social and economic impacts have been inadequately addressed.
• Certain effects on the State’s energy supply and price are unclear.
• Alternathes to the entire proposal or to certain parts of it have not been fully
explored.
The following represents the findings of the Council relative to the proposal
of the Pittston Company. It is organized in answer to the five areas of concern raised
In the 6 overnor’s memo requesting Council action.
A. Relation of Findings and Decisions of the Board of Environmental Protection (REP)
to the Findings arid Conclusions of the DEES
None of the condifions of the BEP Order have yet been addressed by the
Pittston Company. The DEIS does not address them; therefore, there is uncertainty
on the port of the Council about much of the data contained in the DEIS. Major
instances of insufficiency of data occur in the sections relating to sea currents, fog
conditions, and the control of channel spilled oil.
Regarding the specific conditions contained within the BEP Order, the
following is noted: vessel design has not yet been addressed by the Pittston Company;
the heat discharge system is only implicitly mentioned in the DEIS; the navigational
aids system is inadequately presented, and no mention is made that a complete system
depends upon Canadian agreement; there is no reflection of the BEP decision to require
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a Harbor Control Officer; no mention Fs mode of the BEP concern with the absence of
trained and experienced pilots and/or crew to operate the VLCCs; the oil spill
conta1m ant and cleanup system outside the berthing area Is not foctied on; the
subject of liquid sulphur control Is inadequately addressed; there is disagreement
concerning the wind direcflons; and there are some internal contradictions Concerning
ar pollutant levels.
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B. Social and Economic Impacts of the Development
1. Subjects Needing Clarification in the DEIS
a. The Definition of the Region of Impact
The definition of the area over which impacts resulting from an action are
spread is a crucial question in any environmental impact statement, but
only a limited effort at such a definition k made in the DEIS. Reference
is made at several points to the “local area,” but nowhere is any more
explicit description given. Maine has experienced somewhat similar
construction and operation impacts at such other sites as the Wiscasset
nuclear power generating plant and a new paper. company plant in Fairfield.
It is recommended that the FEIS relate its impact analysis to these recent
Maine experiences.
b. &nployment timates
The DEIS contains an estimate of 1200 indirect and induced jobs to be
created by the refinery. It uses a multiplier estimate of 4.0. Other studies
of a 250,000 b/d refinery use lower multiplier estimates. The A. D. Little
study of refinery development in New England uses a multiplier estimate of
3.6 while the NERBC—RALI study uses a multiplier estimate of 2.0. These
would yield estimates of 600 to 1080 jobs to be created by the refinery. A
multiplier of 4.0 may be justified in this case, but a rationale will need
to be presented f the figure is to be accepted. A more complete description
of where jobs may be created should be included in the FEIS.
c. Effects on the Unemployment Rate
It k not clear in the DEIS what impacts the construction of an oil refinery
may have on the unemployment rate in Washington County. A more definitive
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staten ent is needed on the possibility of hiring Canadian labor. Also the
promise of job may lure skilled and unskilled workers from other counties
of the state.
d. I-lousing
The DEIS speaks of an abundance of avaflable housing; however, such an
abundance is subject to several measurements. It should be noted that
much of the housing supply is not currently for sale; also much of it is
currently substandard. The Pittston Company has recognized this and
offered to build housing for construction workers, but the DEIS contains no
estimate of either the number of workers who will need housng, the type
of housing to be provided, or the location of that housing. In two previous
environmental assessments of the project, there are varying estimates nf
the nijnbers of workers who will need housing. Foster and Wheeier
esflmates that 1500 workers of the 2000 man construction workiorce will
come from outside the area, and that 900 of these will be expected to
live within two hours of the construction site. There is clearly not enough
housing, based on for sale rates, within a fifty-mile radius of Ec*stport to
house this many workers. Even though that region is based on an approximate
one—hour drive, there is still no significantly greater housing availability
within a two-hour radius (approximately as far as Ellsworth). In the
environmental assessment prepared by Enviro- Sciences, this lack of ova flable
housing is recognized, and this report anticipates only 200 single workers
can find housing in the area, and that housing will have to be provded
for 1165 workers.
The Pittston Company will hove to pmvde bousing for the majOrity
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of those cor truction workers who will caine from outside Washington
County. The FEIS should provide as detailed a description of such housing
as possible, including the envronmenthl impact of this housing.
e. Governmental Services
In addition to the sublect areas mentioned below, the discussion of the
effects on governmental services lacks specific cost estimates for the
increased demands for services which will occur in both the cor truction
and operation phases. Such cost estimates are essential if governments are
to properly anticipate the financial impacts of such proposals.
Schools : The HUD estimates of Increased population would yield a
much higher school population than the 225 students estmated in the DEIS.
The increase in the school population will obviously depend on the estimates
of families coming, but it has already been suggested that this ! ure may
be fairly high. If the figure of 225 students Is to be accepted, a rationale for
it must be presented.
Medical Services : The DEIS comment lacks cost estimates of additional
personnel and facilities, and states only that the costs will be borne either
by Pittston or Eastport. A more definitive statement on who will bear these
costs should be made, or at least a statement of conditions surrounding such
a decision.
Police : Accurate cost estimates will be needed for the police deportment
increases that the DEIS mentions.
Fire : The additional fire equipment and personnel needed to cover the
construction workers’ housing is not menfloned. A large development of the
type that would seem to be necessary may require Substantial ciddUlons to the
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fire department. Again, accurate cost estimates will be needed for the
fire department increases that the DEIS mentions.
The refinery will also have its own fire—fighting equipment and
personnel when construction is completed. There is no disc sion, however,
of what kinds of fires such a force would be capable of handling, and
whether such a force would be sufficient to handle a major fire resulting
from on explosion in either the transport, storage, or refining syst ns,
Unless the refinery firefighting force is able to handle the “worst case”
type of fire, the local firefighters in the surrounding region may be called
on to assist. This could have three potential dangers: one, several com-
munities may be left unprotected while their normal fire protection equipment
is engaged at the refinery; second, the possibility of the fire spreading
to homes and other structures in the area; and third, the e of local
firefighters who may not be properly trained in the strategy and tactics
of fighting refinery fires. All of these considerations should be given
fuller treatment in the FEIS.
Trunsportatkn : Future rood improvements may be necessary along Route 190 and at
the intersection of State Aid 2 and Route 190 according to an analysis made by the
Maine Department of Transportation. State Aid 2 will be used as one of the access
points to the refinery and increasing traffic at this locaflon will place a hgher priority
on improvements to this intersection. The FEIS should note these impacts.
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F. The Potential Impacts of Governmental Overhead Costs and Revenues
Since the DEIS has not addressed the conditions of the BEP Order, then
it is difficult to assess their impacts on the proposal. However, if the
conditions are met, definite costs will accrue to the government. These
will become consumer costs, being borne by the taxpayers. They wii 1 result
from such needs as the Harbor Master, the tests of pilots and crew, general
accountability to the pubflc for refinery and transport system safety, and
maintenance of leases.
Conversely, the applicant will be a taxpayer and a leasee of public
lands. Revenue from the lease of submerged lands is likely to be substantial
in relation to other public lands revenue. __
The relative costs and benefits to the government have not be ,ti dis-
cissed in any detail in the DEIS; it is recommended that reliable estimates be
made in the FEIS.
g. Taxes
The DEIS lacks accurate estimates of the property faxes to be paid to
Easfport, as well as estimates of income and other taxes to be paid. Such
estimates are necessary For the same reason that accurate estimates of
governmental services are necessary — appropriate advance planning s
impossible without them.
The problem of the lag in time between the construction impacts and
the ability of the refinery to pay full taxes to the local community is also
omitted from the DEIS, and yet this constitutes one of the greatest diffi-
culties faced by the communities. The question of pro-rated tax payments
should be carefully addressed in the FEIS.
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2. Additional Actions the Applicant Could Take to Alleviate Negative Impacts .
Steps that could be taken by the applicant in dealing with some of the
problems that have been outlined here, and that the DEIS does not mention,
include:
a. A stated policy of Maine-first hiring for both construction and operation
phases, including specifically hiring from Washington County.
b. A system of centralized hiring for construction workers, so that those
seeking employment building the refinery would not have to go to Eastport
to get a job.
c. A program to train workers who participated in the building of the
refinery.
d. Avoidance of the creation of temporary housing which would add no
significant long—term benefit to the region. The applicant rc .J, r
cooperation with local, state, and regional housing authorities, arrange
to build permanent housing, usable by the refinery construction force,
and then available for sole to the local population after the construction
phase. This could add a permanent improvement to the housing stock
of the region, which would be available, for example, as low income
housing, housing for the elderly, as a conference center, or as housing
for the permanent workforce and those who may come to the region to
seek employment as a result of the mpmvement in the economy in the
region engendered by the refinery. Such housing need not be built
in one location, as the temporary housng envkioned in the Enviro-
Sciences envirorinental assessment report is, but could be spread
throughout the region to spread the benefits.
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e. An attempt to make arrangements with Eastport (and other Communities)
to aid in paying for services demanded during the construction phase. Such
assistance could take the form of a pro-rated paying of future taxes, as a
loan, or as guarantee of municipal bonds.
3. Impacts on Aquaculture Potential
Some areas in and around the Cobscook Bay area may be suitable for
aquaculture; some efforts to this end ore being investigated currently; soft
shell clam, oyster, and trout production methods are established, compatible
with the area, -and the products are marketable. The Brood Cove area alone
may yield up to $3.9 million annually. The DEIS did not adequately
assess the value of irreversible impacts such as aquacultural losses in and
around Brood Cove.
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C. Effects on the State’s Energy Supply and Price
1. ProvisIon of Petroleum Product to Maine
It is the opinion of the Council that it is not currently possible to estimate,
from the level of data available, whether the construction of the Pittston refinery would
constitute a benefit to Maine’s energy supply or whether it would not, It is assumed
that there is some possibility, within the context of several Varying crDeiia, that
gasoline and fuel may be available to Maine markets, however, no price benefit is
currently seen. Therefore, the question of the refinery’s effect on the energy picture
in Maine should be addressed more explicitly in the FEIS; projections of product price
and availability should be stated if at all possible.
2. The Supply of Electricity for the Refinery
a. The DEIS does not adequately address the question of electrical transmission
network rebuilding or the cost of such rebuilding. The network frc - i Jonesooro
to Eastport will have to be overlaid with added capacity. The network from
Bongor may have to be overlaid. The FE 1S should address this question,
particularly of who will pay for the rebuilding.
b. The effect of adding 60 MWe to system peak will hasten the time when
capacity additions must be made. It is questionable whether these additions
would do anything to enhance system load Factors.
The Council would like the FEIS to examine the alternative of On—site
generation of electricity utilizing a combined cycle approach to maximize
use of energy by utilizing the waste gas to produce process steam of the needed
temperature and pressure. Alternatively, f on—site generation is ruled out, the
question of who pays for the transmission system should be considered.
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3. The relationship between the Pittston Refinery and the Passamaquoddy
Tidal Power Project .
Evidence would indicate that with certain changes in the refinery proposal,
the two projects could be compatible. Evidence also indicates that not
enough is known about either project to make a clear judgment as to
compatibility. The lack of a firm commitment in the DEIS as to the
compatibility of the tidal power project with the refinery proposal precludes
a definitive judgment on this important aspect of the proposal. Because of
this omission, the State requests the opportunity to comment later as more
information becomes available.
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D. C snulotIve Impacts, or Additional Development That Might be Stimulated by the
Presence of a Refinery
1. Cinwlotve Economic Impacts
Both the refinery complex and the accompanying workforce ore expected
to increase the level of economic development in Eastport and on area
(which must be defined) around it. The DEIS recognizes that the refinery
will change the economic base of the region from a renewable r i nriri-
renewable resource but has not yet detailed the long-
term changes in the economy. It has already been suggested (in section B-i-b)
that there will possibly be fewer jobs created by the refinery than the DEIS
projects, and that this impact will be spread out in a wide area, and that a
better description of both jobs and impact area will be made. From an
improved description should come a discussion of the long term 3c r.omy in
the area, and in particular a discussion of the long term economy of a one
conipcny town. Maine provides several examples of this kind of economy,
and serious attention should be given là the impliàations of being a one
company, one industry economy.
In order to make the more accurate estimates of employment that are
called for in Section B-i -b, it may be necessary to estimate the kinds of,
goods and services that the refinery and its workforce will demand in
sufficient quantities to justify either the expansion of local businesses or the
location of new businesses in the region to meet those demands. Such estimates
will also be an integral port of the description of the long term changes in
the economy of the region. These questions should be addressed in the FEIS.
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2. Water Supply and Related Matters
The fresh water cons iption of 2 mIllion gallons per day (mgd) for
refinery operation would require a four-fold expansion in capacity for the
Eistport Water Company, which now zes 600,000 gallons per day. An
engineering report as part of the Pittston proposal stated that the seven—
mile 8” and 10” main now carrying water From the Little River in Perry
would have to be replaced by a 16” pipe at a cost of one million dollars.
An additional informal assessment has revealed that a 24” maIn would be
a more suitable size to carry 3 mgd with only an 8—pound line loss In
pressure over seven miles. Replacement of the main was not mentioned In
the DEIS and should be in the FEIS.
The DEIS mentioned that the safe yield of Boyden Lake — LIttle Rver
watershed was 12 mgd. This s correct, providing that Boyden Lake is
uflflzed as a reservoir and all its stored water is released during low—flow
stxnmer and winter periods. The lake may be drawn down six feet to release
approximately 10,000 acre feet or three trflflon gallons. This reservoir is
large enough to store all the spring runoff In the watershed under average
conditions of precipitation. If the lake were kept at full pooi, the water-
shed would have a safe yield oF 4 mgd under conditions of average precipitation.
This is adequate to cover the expanded supplies required by Pittston. During
years of below average precipitation, it is likely that release of stored water
From Boyden Lake would be required.
Substantial diowdown of Boyden Lake could catse drawdown of adjacent
Pennamoquan Lake beca e of flow through a connecting thoroughfare.
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A drawdown of Pennainoquan Lake would threaten the quality of a wildflfe
management area maintained by the Department of Inland Fkherles and
Wildlife. However, thk thoroughfare does not experience unimpeded
flow since it is traversed by two roads underlain by culverts. An attempt
was mode to install these culverts high enough to prevent cross-flow from
Pennainoquon Lake should Boyden Lake be drawn down substantially.
In view of the prospects of regular, substantial drawdown of Boyden Lake,
should the Pittston refinery be constructed, in contrast with the casual
drowdown that now occurs, it is recommended that the area be surveyed to
deteimine fully the cross-flow relatiornhip6 between the lakes and whether
or not on mproved dike arrangement should be constructed to prevent
undue drawdown of Pennamoquan Lake with accompanying decrease the
quality of this wildlife management area.
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E. Any Acceptable Alternatives to the Whole Proposal or to Any Part of It
a. The use of a single-point mooring system located off Lubec in the Grand Manon
Channel may be considered as a possible alternative to fankering down Head Harbour
Passage to Shockford Hood. The DEIS has not, in the Council’s opinion, offered
convincing reasons to dismiss the single—point mooring system. In view of the
concerns over the question of compatibility between the refinery proposal and the
tidal power project, the use of the SPM system should be investigated more, thorough I>.
b. There are sevemi alternatives to the entire proposal. There is the alternative
of no refinery. There are alternative sites. There are alternative methods of
siting. Presently, the State considers oil refineries and other sUing proposals
on a case—by—case basis under appropriate State laws. There Is currently no State
policy which anticipates proposals to site oil refineries. The initiative fur
proposals rests with the developer. Becoioe of the lack of a State policy context,
it would be inappropriate at this time for the Council to suggest alternatives to
the current proposal.
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Response to Comments By ?4 jne
Land & Water Resources Council
General
By letter dated March 2, 1977, EPA responded, in part, to the comments
of Land and Water Resources Council, coordinator of the multi—agency
review task force created by Governor James V. Longley. That letter
noted several questions raised by the Council which were uniquely
within the knowledge of state officials in Maine. Issues addressed
included tax revenue, employment, transportation, other government
expenditures and submerged land revenue.
Si. None of the conditions appended to the BEP decision have been
addressed. Although the legal requirements of the DEIS may not call
for the inclusion of, or even reference to, the Order and its speci-
fic conditions, it is the position of the Council that the BEP
Order stipulates many environmental feelings strongly held by
Maine people, and that at least the major conditions of the Order
should have been referenced in the DEIS. Because they were not,
some major conclusions appear to be based upon uncertain data.
These include data relating to currents, fog, and oil spills.
Some social and economic impacts have been inadequately addressed.
Certain effects on the State’s energy supply and price are unclear.
Alternatives to the entire proposal or to certain parts of it have
not been fully explored.
Ri. EPA will adopt the conditions of the REP order, where appropriate, in
their permit.
S2. The subject of liquid sulfur control is inadequately addressed.
R2. Elemental molten sulfur will be produced at the rate of 465 metric
tons per day. It will be shipped to market in small tankers of the
10,000—15,000 DWT class. Therefore, approximately one sulfur carrying
tanker will transit Head Harbor Passage every 21 days. In the event
that molten sulfur would enter the water, it would solidify into
chunks and sink. There would be no detrimental effects to the marine
ecology since elemental sulfur is insoluble and unreactive in water.
The spilled, solidified sulfur would be dredged by conventional
means as soon as possible after the spill.
Si The definition of the area over which impacts resulting from an
action are spread is a crucial question in any environmental impact
statement, but only a limited effort at such a definition is made
in the DEIS. Reference is made at several points to the “local
area,” but nowhere is any more explicit description given. Maine
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has experienced somewhat similar construction and operation impacts
at such other sites as the Wiscassat nuclear power generating plant
and a new paper company plant in Fairfield. It is reconinended that
the FEIS relate its impact analysis to these recent Maine experiences.
R3. See FEIS, Vol. II, p. VI—15.
S4. The DEIS contains an estimate of 1,200 indirect and induced jobs
to be created by the refinery. It uses a multiplier estimate of
4.0. Other studies of a 250,000 bId refinery use lower multiplier
estimates. The A.D. Little study of refinery development in New
England uses a multiplier estimate of 3.6 while the NERBC—RALI
study uses a multiplier estimate of 2.0. These would yield estimates
of 600 to 1,080 jobs to be created by the refinery. A multiplier
of 4.0 may be justified in this case, but a rationale will need
to be presented if the figure is to be accepted. A more complete
description of where jobs may be created should be included in the
FEIS.
R4. See FEIS, Vol. II, p. VI—lO.
S5. It is not clear in the DEIS what impacts the construction of an
oil refinery may have on the unemployment rate in Washington County.
A more definitive statement is needed on the possibility of hiring
Canadian labor. Also the promise of jobs may lure skilled and un-
skilled workers from other counties of the state.
R5. See FEIS, Vol. II, p. VI—lO.
S6. The housing of the construction workforce is not adequately addressed.
R6. See FEIS, Vol. II, pp. VI—l4 through VI—16 and pp. X—7 through X—8.
Si. The DEIS does not adequately discuss the strain on governmental ser-
vices that will arise during construction and operation. Specifically,
they indicate that cost estimates are not provided.
R7. See FEIS, Vol. II, p. VI—l8ff.
S8. Future road improvements may be necessary along Route 190 and at
the intersection of State Aid #2 and Route 190 according to an
analysis made by the Maine Department of Transportation. State
Aid #2 will be used as one of the access points to the refinery
and increasing traffic at this location will place a higher priority
on improvements to this intersection. The FEIS should note these
impacts.
R8. See FEIS, Vol. II, p. VI—24ff and p. X—l3ff.
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S9. The DEIS does not provide cost estimates that will accrue to the
State of Maine as a result of the operation of this facility.
Specific reference Is made to the costs associated with the
Harbor Master, the “tests of pilots and crew,” “general accounta-
bility to the public for refinery and transport system safety,”
and maintenance of leases.
R9. See revised soclo—economic impact section, p. VI—iff. Further
refinements with respect to cost estimates will have to be made
at a later date once navigational plans have been finalized.
SlO. The DEIS lacks accurate estimates of the property taxes to be paid
to Eastport, as well as estimates of income and other taxes to be
paid. Such estimates are necessary for the same reason that accurate
estimates of governmental services are necessary——appropriate ad-
vance planning is impossible without them.
The problem of the lag in time between the construction impacts
and the ability of the refinery to pay full taxes to the local
community is also omitted from the DEIS, and yet this constitutes
one of the greatest difficulties faced by the communities. The
question of pro—rated tax payments should be carefully addressed
in the FEIS.
RiO. See FEIS, Vol. II, pp. VI—il through VI—13.
Sli. The Council lists a variety of “additional actions the applicant
could take to alleviate negative impacts .“
Ril. See FEIS, Vol. II, p. VIl—iff.
S12. Some areas in and around the Cobscook Bay area may be suitable for
aquaculture; some efforts to this end are being investigated c&ir—
rently; soft shell clam, oyster, and trout production methods are
established, compatible with the area, and the products are market—
able. The Broad Cove area alone may yield up to $3.9 million
annually. The DEIS did not adequately assess the value of irrever-
sible impacts such as aquacultural losses In and around Broad Cove.
R12. See FEIS, Vol. II, p. IIl—l59ff.
S13. It is the opinion of the Council that it is not currently possible
to estimate, from the level of data available, whether the con-
struction of the Pittston refinery would constitute a benefit to
Maine’s energy supply or whether it would not. It is assumed that
there is some possibility, within the context of several varying
criteria, that gasoline and 1/2 fuel may be available to Maine
markets, however, no price benefit is currently seen. Therefore,
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the question of the refinery’s effect on the energy picture in
Maine should be addressed more explicitly in the FEIS; projections
of product price and availability should be stated if at all possible.
R13. The addition of 250,000 barrels a day of refined product in
northern New England should alleviate the supply problem to some
degree within the State of Maine, although no price benefit will
be given to the State of Maine as the result of locating the re-
finery in Eastport.
S14. The DEIS does not adequately address the question of electrical
transmission network rebuilding or the cost of such rebuilding.
The network from Jonesboro to Eastport will have to be overlaid
with added capacity. The network from Bangor may have to be over-
laid. The FEIS should address this question, particularly of who
will pay for the rebuilding.
The effect of adding 60 KW to system peak will hasten the time
when capacity additions must be made. It is questionable whether
these additions would do anything to enhance system load factors.
The Council would like the FEIS to examine the alternative of on—
site generation of electricity utilizing a combined cycle approach
to maximize use of energy by utilizing the waste gas to produce
process steam of the needed temperature and pressure. Alterna-
tively, if on—site generation is ruled out, the question of who
pays for the transmission system should be considered.
R14. See FEIS, Vol. II, p. X—lO.
S15. Evidence would indicate that with certain changes in the refinery
proposal, the two projects could be compatible. Evidence also in-
dicates that not enough is known about either project to make a -
clear judgement as to compatibility. The lack of a firm commitment
in the DEIS as to the compatibility of the tidal power project
with the refinery proposal precludes a definitive judgement on
this important aspect of the proposal. Because of this ommission,
the State requests the opportunity to comment later as more in-
formation becomes available.
Rl5. Comment noted. See expanded FEIS section on the compatibility of
the refinery and the Passamaquoddy Tidal Power Project. (FEIS,
Vol. II, p. IIl—159ff.)
S16. The FEIS should address the long term changes in the local economy
that would be caused by the refinery. Attention should be paid
to Eastport becoming dependent upon one company and one industry.
R16. Volume II, Chapter VI discusses the anticipated economic and land use
impacts associated with the refinery’s operation. Also see Volume
II, page X—3 S3.
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ENVUR MENTA’.. PROTECTION AGE V
arch 2, 1977
Mr. William Aaams, Chairman
Land and Water Resources Council
state of Maine
Augusta, ME 04330
Dear Mr. )¼dams;
i s you know, we are in the process of reviewing comments on
the Draft nvironrienta1 Innact tat lent (EIS) on the rittston
ComTany’s proposed oil refinery and marine terminal.
Your letter of Nove. ther 24, 1976 commented on many aspects of
the Draft impact statement. We will limit the discussion in
this letter to those areas where we had specific questions
with regard to state policies and procedures. These include
tax revenues, emplovthent, transportation and other government
expenditures. ‘7e would like to request your assistance in
these areas in order to prepare the Final EIS. Our specific
concerns (questions) are outlined below.
Tax !(evenues
How would the construction and operation of the proposed
facilit” effect the local, count” and state tax base?
In the Draft EIS we used the tax estimates provided by
the Pittston Company (DrI , page 295). They estimated the
pronertv tax base would increase fron about $12 million in
1975 to possibly 300 - $400 million after construction of the
proposed facility. The total state and local tax revenues
ou1d he increased to approximately $7 million/year generated
from oneration of the refinery and the payroll of the employees.
Of this, the contribution to the local property tax would be
aF’out $4 nillion/year.
Based on our consultation with professional assessors
and officials fror the City of Eastport, the estimates in
the Draft FIS for the propert” tax base appear to be the best
estimates available at the present time. If you can provide
dc1itiona1 inforiiation or suggestions as to the accuracy of
these estimates, we would apv reciate it.
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ENVI 4MENTAL PROTECTION AG
—2—
Emplovrient
What would be the effect of increased revenues and employ-
ment on the local and county wide economy?
Extensive testimory on the socio—economic impact to East-
port was received at the Public Hearing, December 3, 1976, from
Arthur Johnson, an economic historian. Attached is the report he
submitted to us.
We would like your evaluation of this report with specific
reference to the analysis of wage and salary impact (page 111-2),
the multiplier effects of the transfer of this money on the econ-
omv (page 111-5 and 111-10), and the resulting reduction of
unezn 1ovment in the Eastport and 7ashinqton County areas (page III
111—5)
Transportation
tThat probable highway improvements are expected within the
vicinity of Easttort? -
In the Council’s co’ ments to EPA (page 10) it was mentioned
that the Department of Transportation had studied State Aid 4 2
and Route 190. if improvements are projected, what is the exact
location of these improvements, how extensive are the improve-
ments, and when would construction begin?
Other (overnment Expenditures
If the ref inerv is located in Fastport, what are the
projected cost estimates for additional public services?
In the r)raft EIS (page 295-297) we described the type of
infrastructure improvement and expansion that we felt would occur
in rastport if the proposed facility were constructed. Since
that time, we have consulted with the Cit” officials to obtain
cost estimates for these improvements. City officials, however,
are not at a noint in their planning process where they have
developed cost figures for these facilities.
The construction impacts on municipal services at other
Maine sites may he imi1ar to the proposed project at Eastport.
“e are presontlv reviewing information on the Scott Paper Mill
at Winslow, Maine; Maine Yankee; and the vr an IV power plant.
If you feel any other Maine projects have aprlicable public
service needs and cost estimates, we would appreciate your con—
tacting us .
22—27
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ENVI] 9MENTAL PROTEcTION AGE
—3—
Does the State have any standard factors or rules of
thurth which it ap’,lies for its own planning purposes ihich
can be utilized for Fastport?
Suhi erg d Ladd Revenue
Revenue for leasing of public, “sub erqed” land was
mentioned as being a substantial contribution to the State
revenues in your colir%ents (pacTe 11). We presume this fee
will be set by the state so we will need your advice as to
how much it will be.
The other concerns of the Land and Tlater Resources Counci)
are being thoroughly reviewed by EPA, the Cores of Engineers,
and other federal agencies of the FRC Refineries Task Force
will be addressed in the Final ETS.
If you have any questions, please contact rte at your earliest
convenience.
Sincerely,
Wallace F.. Stickney, P.E.
V Environmental
Policy Coordination Office
enclosure
EiS MESWES:na:3/2/77
22—28
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STATE OF MAINE
Department of Environmental Protection
MAIN OPPICE: RAY BUILDING. HOSPITAL STREET. AUGUSTA
MAIL ADDRESS: STATE HOUSE. AUGUSTA 0*333
- , , ,,
April 8, 1977
STRATIVE SERVICES
Mr. Wallace E. Stickney, P.E., Director
Environmental Policy CoordInation Office
TYcONTROL U.S. Environmental Protection Agency, Region I
J. F. Kennedy Federal Building
Boston, Massachusetts 02203
OVALITY cONTROL
)RATORY SERVICES
* Dear Mr. Stickney:
OLLUTIOJI CONTROL
Thank you for your letter of March 2, 1977, regardIng the
4*LDIFI cII. Draft Environmental Impact Statement on the Pittston Company’s
rU REET proposed oil refinery and marine terminal. Our staff has reviewed
the specific functional areas about which you have inquired (tax
GR(SSSTRSET revenues, employment, transportation, and other government
expenditures), and hope the following will be of help to your
INSTREIT office.
JE LE 047 51
Tax Revenues
ANTICS CONTROL
E RCIAL STREET
At the present time we have no way of estimating tax revenues
UREPOATSONLY any more accurately than the Information you already possess.
REEI ISOO -4$Z-O171
Employment
4 ESVIRON*NTAL
*EE SERVICE
REUIIO ,Sfl SEZ Please see the enclosed evaluation prepared by the State
Planning Office of Arthur Johnson’s paper analyzing the estimated
socioeconomic impacts of the refinery on the Eastport area.
Transportation
No highway improvements have been formally projected. The
major concern of the Maine Department of Transportation is the
intersection of State Aid #2 and Route 190. No in—depth study has
been done yet; therefore, no one knows how extensive such improve-
ments may be, and, of course, no construction is planned, as yet..
Other Government Expenditures
The State is presently working on the establishment of a
mechanism for estimating projected costs for additional public
services in cases of pending commercial development. In lieu of
this mechanism, we are not able to yield any further information.
WILLIAM A. ADA*IC. JR.
COMMISSIONER
2 592*fl
22— 29
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With regard to the construction irr acts on municlpa
services at other Maine sites, we assume you are reviewing inform-
ation on the new Scott Paper Mill at Hlnckley . We are not
currently able to reconinend any other Maine projects which may
have applicable public service needs and potential costs. The
State does not have any standard factors or rules of thurth (a’though
some are in progress of development) which could be utilized for
planning for Eastport.
Submerged Land Revenue
At present, we have no idea h much the revenue from the
leasing of public submerged lands may be; no appraisals have been
made to date, therefore, no estimates can be given.
We are pleased that our concerns, as made kn in In our Land
and Water Resources Council paper, are being reviewed by EPA and
the Corps of Engineers; we hope this latest Information may be
helpful to you.
Sincerely,
• William R. Adams, Jr.
Coninissioner
wa. j
End.
22—30
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Evaluation of “REPORT ON THE SOCIO-ECONOMIC IMPACT OF THE
PROPOSED PITTSTON PROJECT AT EASTPORT, MAINE” - (Submitted
by the Action Committee of 50, Bangor, Dr. Arthur M. Johnson, et al.,
December 3, 1976).
This report is generally well documented and its conclusion that the
refinery would benefit the region economically is difficult to dispute. There
is, however, a major difficulty with the paper as presented, and a number of
minor aspects which require comment.
The greatest problem with the analysis is an inadequate consideration
of alternatives to the refinery. Thh is especially true with the potential fishery
development in the area. While the paper correctly points out that fishery de-
velopment is not as mmediate as the Pittston proposal, the prospects for future
development in this industry are not as remote as the analysis indicates. The
efforts in Eastport to rebuild a municipal pier, and the creation of a marine trades
school as a branch of Washington County Vocational Technical Institute are both
indications that alternative development s possible.
The paper points out that recent landed value of the shell fishery in
the area is greater than the annual Pittston payroll, but concludes that Pittston
is favored because of the multiplier. Since most of the value of the fish catch is
exported from the region, there is no multiplier similar to the Pittston payroll at
this time; but with a rise in fish catch, and with more intense processing of the
fish in Eastport, or eastern Washington County, more of the value would remain
in the region, creating a multiplier, and thus bringing the two closer.
Another alternative which the paper fails to consider is Tidal Power.
While not currently competitive with existing forms of energy generation, it is
expected to become so within ten years. While the Passamaquoddy Tidal Power
Prolect is still being studied, and is some years still in the future, a proposal has
been prepared for a small scale Tidal Power plant at Half Moon Cove. These would
not be incompatible with the proposed refinery, but they do indicate another alter-
native future for the area.
In short, the refinery cannot be considered the only hope for Eastport.
While alternatives are still in the future, and complete analysis of their character-
istics at this point is impossible, more attention should be paid them than this report
has.
Specific aspects of the paper which deserve attention:
The estimates of increased school population during the construction
phase do not appear based on any estimates of how many construction workers
will bring families with school age children. This is difficult to estimate in any
case, but it seems likely that additional school demands at all levels are possible.
2 2—31
-------
The reduction of unemployment in the region of 42% cited on page 35
is undocumented.
Training construction workers to build the refinery may not represent
any long term addiflon to the region. Construction of the refinery, and possibly
secondary installations and other development in the Eastport area will occur in
a relatively short period, and then will stabilize. While some newly tr]ined
workers may stay in the area, most wfll probably have to go elsewhere to practice
their new skills. This will unquesfionably be an addflion to the state and to
national skills, but not necessarily to Eastport or Washliigton County.
The estimate of 573 lobs generated by the refinery is very likely high.
It rests on the assumption that the jobs Will be at the current average wage for
Washington County. This assumption is not likely to hold, however. Since the
current population of the area could not fill on additional 573 jobs, others will have
to come from outside the region. But they would not be likely to move to Washington
County at prevailing wage rates, which are lower than elsewhere in the state. Some
rise in wage rates in these created jobs will be necessary to attract people, thus
implying that a smaller number of jobs may become available.
22—32
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tate of *Ihu
EXEruItur rpartn*nd
tatr 1airniug ®ftht
104 1at, trnt, AuguMa, 04333 ru.. (207) 28$.32S1
ALLEN G. PEASE
STATE PLANNING DIRECrOR
December 17, 1976
Memorandum
TO: Bart Hague, Chief of Planning, Federal Water Quality Administration,
240 Highland Avenue, Needham, MA. 02194
FROM: R. A ec Giffen, Supeiv r, Resource Planning Division
SUBJECT: Consistency of Pittston Proposal with CZM in Maine
As per our earlier conversation, attached are my thoughts on how the secflon
of the draft Environmental Impact Statement dealing with the relationship of the
Pittston proposal to the Coastal Zone Management program should be modifTed.
If you have any questions, feel free to contact me.
rag. j
End.
JAMES B. LONGLEY
GOVERNOR
23—1
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December 17, 1976
Consistency of Pittston Proposal with CZM in Maine
Maine is still in the process of program development in its Coastal Zone
Management program. Because it does not have an approved 306 program in place,
nor an application pending, it’s not possible to Formally judge the consistency of
the proposal for a refinery at Eastport with the Coastal Zone Management program.
However, the extensive informoflon which has been gathered as a part of
Maine’s coastal planning efforts has been reviewed for the Eastport area and
evaluated against the information contained In the draft Environmental Impact
Statement,O the basis of this analysh it does not appear that there are any con-
trodictions between the data contained in the draft Environmental Impact Statement
and that available as part of the Coastal Planning Program.
Further, wMle as stated earlier Maine does not have an approved 306 program,
the proposal for a refinery at Eastport has been processed under existing state programs
which control the location of such developments. These include primarily those
programs administered by the Department of Environmental Protection. It is expected
that these same programs will form an important part of the basis for a 306 application
when one is prepared.
Beyond this, the personnel of Maine’s Coastal Planning Program played an im-
portant role in preparing the comments on the draft Environmental Impact Statement
submitted by Governor Langley from the Land and Water Resources Council
Response:
Comments noted.
23—2
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COMMENTS SUBMITTED BY
LOCAL AGENCIES
-------
Testimony Given by M. Barnes,
Eastport City Council,
at the Dec. 3, 1976, Public Hearing
Mr. Chairman, members of the Committee, I am Maxwell Barnes,
President of the Eastport City Council and I represent the City Council,
I have been a resident of this area for more than 55 years.
During the mid 1930’s approximately 2500 persons were added to th
City’s population as part of the influx of persons associated with the
Quoddy Project. Things began to boom. At that time we had bowling
alleys, theatres, sports activities, thriving businesses,, everybody
who wanted a job had one and the area in general benefitted by the
payroll expenditures of the wor cien who temporarily resided here.
Al]. aspects of the economy improved and a prosperity existed which
was very welcome in counteracting the effects of the great depression.
Unfortunately our new found prosperity was short lived an the
bubble burst. The demise of the .uoddy project was followed by the
advent of the ulational Youth Ad iinistration contingent at Quoddy ‘ - L
participants in the program were tau ht v .rious and sundry trades.
There were approximately 1200 young poople enrolled in this ograrn.
Again the economic benefits from this influx of personnel were most
beneficial to the area.
In the early 1940’s a Naval Construction Battalion numbering
about 350 personnel was stationed at Quoddy Village. This ain
constituted a sizeable infuix of people, however, px oblem areas
were minimized due to prior planning procedures. A a result of
these periodic economic infusio ns the City of Eastport had its p riods
of ups and downs.
Since the early 1950’s there has been a steady decline in the
economic stability of the City, a steady out migration of young
people who had to leave in order to find employment necessary for
their survival, a continuous decre .se in the number of business
establishments and a decrease in recreation and amusement facilities
to a point where such is non—existent at the pres nt time.
I have seen prosperous times and I hqve lived through bad times,
including the present. I want to see the City of Eastport propper
24—1
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and I am convinced that with the advent of the Pittston Company we
shall see that prosperity. We shall be able to do t1 ings that have
needed doing for a long time but were prohibited because of lack of
funds. We shall see people employed who wish to be employed. 1 e
shall see full time employment not seasonal employment. Vie shall see
a rejuvenation of the business district beacause the patronage will
be there. We shall see recreational facilities where none presently
exist. We shall live instead of exist. We shall have the luxury
of retaining our . :outh since employment opportunities will be
available to them.
Whore once we could but dream of these things we are now in a
position where the reality is within easy reach.
L r. Chairman, . four—fifths the Eastport City Council
favors the building of an oil refinery complex in Bastport b the
Pittston Company.
Other key personnel of the City of Eastport will discuss
specific areas which I h ve not covered in detail or have not
included in m7 presentation.
Th nk you.
Response:
Co ents noted.
24—2
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Teatimony Given By E. Baxter,
City of Eastport, at the Dec. 3, 1976, Public Rear g
i ir. Ch.ir aari, I.:emb rs of the Co itiittee:
My n. me is Everett Baxter and I a u presently City LIana er
of the City of Eastport. I have been a resident of this City
for more than fifty years.
As a boy I remember Ea tport as a bustling Seaport
Coanunity. Since th t tiwe I h ve viatched a steady decline
in the population and economic situ tion. 7e are innocent
victi is of a eo raphical circumstance such as to prohibit
the loc. tion of most industries who ooa ete roductiv ly on
the o)en in_r et. Once in a reat vthile an industrial project
appears which is suited to our needs and eo raphical loc.tion.
I beli ve that he Pittston Qo pany is such an industry.
)‘hen I thin: of the economic import of such a project
I be;in to t .i:L: of v:h .t needs to be done and what can be
done with the tax income that would accrue.
1.
2.
Sew e tre t ient plant
Sep.aratin our sewer fron surface drain and modif ring
the whole syste:u
3. £rosion control project for the 7aterfront
4. A ne ’ High School
5. 1’ eighborhood par s
6. Off street p .r.in in business district
7. Rebuildin of approximate i.y three miles of roads in .i
sidewal s
8. Cocimunity Youth Center
9. Development of Recreation pro ra1n and associated
facilities
25—1
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10. Senior Citizens Center
11. iew City Gar •e and ?olice SLtion comolex
12. Low Cost Housin ; ?rojeet
13. I ’ew .nd aodern Hospital and ursin Home
14. ?encing in of the Cemeteries
15. Complete the revision of the ?ire larri System
16. Co:nmunications system for Pire Departhent and Hi hway
Department
17. Reolace f1oatin slip at unici)al Pier
18. Increased street lighting
19. Increase in friri e benefits for City znployees
These are some of the areas which need attention and money.
These we could very well realize with tax income which would
derive from Pittston Comp:i.ny and I have iientioned only a very
small part of the economic impact on the City of st ort.
Present ‘ ashington County Valuation $304,450,000.00
3 stim ted Valu tion after Pittston $725,000,000.00
% of County ‘tax now paid by Baileyville 22%
% of County tax now p:.tid by astport .047%
Assuming a bud;et of $400,000.00 and a new valuation
of $725,000,000.00 the mill r _te fur the County would be
.00055 as compared with .00154 mills 1975 or approxim-.itely
65; reduction.
After Pittston Baileyville tax $41,250.00 2o.3 )
After Pittston Eastport tax $231,000.00
Th re is no question in my mind but what the completion
25—2
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of the refinery project pro osa1 v ’ou1d h ve a positive eoono nio
jLpact on the City o C ist.ort, the County of uiashin ;tori .nd
the State of Laine.
Response:
Conunents noted.
25—3
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‘U.
MR. McGLE NON: Mr. Baxter 1 could you answer one
question for us?
MR. BAXTER: Yes, sir.
MR. STICKNEY: Mr. Baxter, one of the comments by
the state was that we did not in the EIS outline how
the capital expenditures required of the conrnunity
would phase in with the tax receipts that ou would
be getting from the refinery, which would of course
start from zero and go up to a maximum over a three—
year period. For us to do that, we are going to need
your help. and I wondered if you would be available
to cooperate with us in putting that information
together?
MR. BAXTER: Yes.
25—4
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112.
MR. STICKNEY: The second question is relative to
the zoning of the area and the zoning of the city in
general. As I understand it, the city does have a
zoning ordinance at the present time?
MR. BAXTER: Yes, it does.
MR. STICKNEY: flow are amendments or changes made
to the ordinance, sir?
MR. BAXTER: Just like any other ordinance that is
proposed, it is advertised for a two weeks period, a
public hearing is held, and then the city council votes
on it. The city council is the official governing body
of the city.
MR. STICKNEY: Is there a provision for a referendum
in the charter?
MR. BAXTER: There is in the new charter, which
becomes effective 1 January.
MR. STICKNEY: Thank you very much, sir.
MR. McGL ,ENNON: Could I ask just a couple of quick
questions. Has there ever been a referendum on the
question of a refinery here in Eastport?
MR. BAXTER: Not to my knowledge. There have been a
lot of surveys, but I don’t think a referendum - I know
25—5
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113.
a referendum has not been held, no.
MR. McGLENNON: Do you have any sewage treatment
system here now in the city?
MR. BAXTER: No, we do not. We have a variance to
allow us to run until we get money enough to build
the system. The federal funds aren’t available.
MR. McGLENNON: I see. Are you. on the priority
list somewhere for the State of Maine?
MR. BAXTER: Away down at the bottom.
MR. McGLENNON: Oh, heavens. Have you and the city
council discussed the social kinds of impacts that may
occur in Eastport if this refinery is placed here, the
quality of life kinds of changes that tend to occur
when a big industrial facility a city c f
this nature?
MR. BAXTER: Oh, yes. many times. And as Mr. Barnes
mentioned, we have had three examples of an influx of
people and so forth, and we have been through this
before.
MR. McGLENNO : Is there any way to interpret the
attitude of the people of the community in general
about this kind of an influx? Is this something that
25—6
-------
114.
you would interpret to be that generally the people
of the community would be in favor of?
MR. BAXTER: I don’t think I am in a position to
answer that yet. I think you would find a normal
dispersment. where some are opposed to it regardless,
a lot of people are in the middle, and some are in
favor of it regardless of what happens. I think you
have got a normal spread here just as you would have
anywhere else. But since no referendum has been
conducted, I don’t know of any--- there have been
telephone surveys which have indicated favorable
response to the proposal. There was one conducted
that asked the question of whether the Quoddy Project
was preferred. or would people want the Quoddy Project
or the oil refinery, and the preponderance were in
favor of the Quoddy Project; a loaded question. I
think.
25—7
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East )Oi’t
I’VIuIiiCipaI
P h 1 nnjn ,
B YOU 1 la n rO(1fl for Progress rornorrotu
oat (1 EASTPORT. MAiNE 04631
December 3, 1976
U. S. Enviromental Protection gency
Region 1
Boston, Mass.
Gentlemen:
The Eastport i-lanning Board consists of residents of Eastport
who have lived with the problems of the area, watched the ?ittston
iroject evolve and be subjected to a thorough enviromental study.
e realize that the influx of personnei for the refinery will create
problems end have been preparing for them. However, it will generate
the money needed to make many civic improvements, enable merchants to
expand their services, and provide a stable economy.
I ir. A. F. Kaulakis, Vice President of the Pittston Company, met
with the Planning Board on November 10, 1976, and stated that Pittston
desires en attractive cornmu ity, because a pleasant enviroment attracts
and holds quality personnel. He brought to us a wealth of information,
relative to community planning, and committed Pittston to help us at
such a time we feel the need of their resourses and expertise.
The Eastport Planning Board is currently reviewing the present
comprehensive plan and zoning ordinance, so it will work smoothly and
preserve our small town livestyle. We are interviewing various
community p1annin ; and. development consultants, who will be hired to
do the actual revision.
If this refinery is built, it will provide the motivation and
economic resourses to revitalize this old community at an opportune
time. There are many small lots of land clustered together with
numerous open areas, similar to the concept of an open space sub-
division. The residential area is a pleasant and enjoyable place to
live. Our shopping center could be condensed into a pleasant, compact
area with our schools and. churches within walking distance. A bus
route around the perimeter and through the shopping area, by the
schools and to the main gates of our industries could eliminate the
need for two and sometimes three autos in a family. Think of the
convenience for the elderly and the savings for a workin farnily. A
ferry could run from Lubec to Eastport, connecting with the local bu
and supplementing our work force, — a benefit for the whole county.
I8 tport, .iUaiuc L1• 1531
26—1
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(2)
U.S.Enviromental Protection Agency December 3, 1976
We believe there is an opportunity for the Pittston Company and
Eastport citizens to work together to create a model cormunity.
Yours very truly,
9(
Burton H. Blanch, Chairman
Eastport Planning Board
Response:
Comments noted.
26—2
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Testimony Submitted by W. Harding,
City of Eaatport, at the December 3, 1976, Public Hearing
Mr. Chairin n and members of the Committee, My name is William
Harding ard I am the Chief of Police for the City of Eastport.
I foresee no problem areas with the influx of personncl who
will be associated with the Pitt. ton project. Our planning
provides for an increase in the Police Force by selection
of trained personnel, for a force which is necessary in
number to take care of projected situations requiring police
actton, for traff ic control relating to increased number of
vehicies aid ir.creased usage of vehicles, ani for gereral
vigilance as a prever ive n aswe.
If a situation calls for it we do have available personnel
from both the Sheriff Departn’ent ani the State Police. I
an confident that we will be able t.a effectively ani efficiently
handle any of the situations with which the Eastport Police
Department may- be faced since our norma]. operation is usually
in dealing with unexpected circumstances.
Response:
Comments noted.
27—1
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Testimony Given by R. Flagg, City of Eastport,
at the December 3, 1976 Public Hearing
MR. FLAGG: Mr. Chairman and mertbers of the board,
ladies and gentlemen: My name is Richard Flagg, and I
am speaking in behalf of the Eastport Fire Department.
The Department is fully supporting the proposed develop-
ment by the Pittston Company. We feel that the Increase
In population will be no burden on the Department. The
Pittston Company has told the Chief of the Department
that it will train the Eastport members the same time It
Is training the personnel that are working at the site.
With the cooperation between the two departments, we will
be able to cope with any emergency that would arise.
Response:
Comments noted.
28—1
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I ietptirt, i iine 04(31
November 16, 1976
Mr. Wallace E. Stickney
F.nv1ror.n ent Protecticn Agency
aegion I
John F. Kennedy Bldg.
Boston, Mass. 02203
Dear Mr. Stickney:
I an p aking in behalf of the Eastport Fire Department.
The Department is fully supporting the proposed development by the
Pittston Company. We feel that the increase in population will
be no burden on the Department. The Pittston Company has told
the Chief of the epertai cnt that it will train the Eastport
members the same time it is training the personal that are working
at the site. With the cooperation between the two departments
we will be able to cope with any emergency that would arise.
Cordially yours,
Chief Merrill Conti
Response:
Comments noted.
29—1
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Testimony Given by R. Maholland, City of Eastport,
at the December 3, 1976 Public Hearing
MR. MAHOLLAND: Gehtlemen, my name is Sheriff Reid
Maholland, and I am speaking today to you in behalf of
law enforcement. I would like to speak in behalf of
law enforcement in the County of Washington and what
this refinery would do in regard to helping out law
enforcement.
I believe you people are aware that the statistics
prove that unemployment is at a very low ebb, and when
it is, the crime rate prevails. Washington County has
a very low ebb of unemployment and a very high rate of
crime - I would like to correct myself on that - it
has a high rate of unemployment in Washington County.
also that the crime rate is going up and up.
As far as I am concerned, I believe that the Pittston
Oil Company would benefit a great deal with a new modern
refinery, and It is my opinion that when people are
working they will not spend their hard—earned money n
a courtroom. At the present time the courts are filled,
and I believe that Washington County courtrooms are
perhaps filled as much as most of the courts in this
state. So it is my opinion and my hope that this
refinery will add a great deal to Washington County,
and particularly to the City of Eastport.
Also, I would like to add that it has been my
30-1
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observations in the past year, being Sheriff of
Washington County Jail, that a tremendous amount of
our young people are involved in crime, and I feel
that if these young people had an opportunity to
further their education or find a skill or a trade,
give them something to do, it would take them off
the street and we wouldn’t be involved in the problems
that are arising throughout the county. In the past
two weeks from Washington County Jail there has been
in excess of 15 young people that have been sent to
further institutions. This has been going on in the
past year - I can’t give you the exact statistics on
the young people that are involved, but I can assure
you of one thing, that we are finding young people
anywhere from 12 years old up to, generally speaking.
20 to 24 years old, and it is my belief sincerely that
when people are working they will not spend their money
in courtrooms.
Thank you very much.
Response.
Comments noted.
30—2
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OFFICE OF TOWN MANAGER
LU DEC. MAINE
12/3/76
Cha i rman
Environmental Protection Agency
Environmental Impact Hearing
Eastport, Me
The Lubec Board of Selectmen have directed me, as their Town
Manager, to express the concensus of the majority of the Board
concerning the construction of an oil refinery by the Pittiston
Company in Eastport.
Lub.ec has a population equal to that of Eastport. The two
con riunities are seperated by two miles of water and were in fact
until incorporation in 1820 one community. They share a conwnon
geographical location and its citizens face many of the same problems.
Presently, the economic base of Lubec is at a very minimum. The
central business district is struggling to servive. Many businessmen
have expressed an increasing inability to survive.
The young people leave town to earn an income. This outmigration will
continue if the job base is not expanded.
Many taxpayers are having a difficult time paying their property
taxes. The cost of del ivering the same level of municipal services has
increased more than the increase in wages, Wtthout a stable job
market it is possible the level of municipal services will drop x x
drastically. Without services the community will fall into-oblivion.
The Lubec Municipal Airport which is fully lighted, plowed and fully
maintained can serve the Cobscock Bay Area if this refinery is built.
A capital improvement priority of Lubec is a Commercial Dock. Such
a dock can facil itate a Ferry Service between the two towns. The
benefits will be many. The environmental impact will be stringently
regulated by state and federal agencies.
Therefore, it is the recommendation of the Lubec Board of Selectmen
that the construction of a refinery will generally benefit the
citizens of Lubec.
Respectfully yours,
MOST EASTERN TOWN IN THE UNITED STATES
Response:
Comments noted.
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Teatimony Given by E. J. Barnea, Lubec,
at the December 3, 1976 Public Hearing ,
MR. BARNES: Gentlemen, I come to you as the Town
Manager of Lubec, Maine, a community approximately
two miles across the water. I have been directed to
speak to you by a recent meeting of the Board of
Selectmen of Lubec. They unanimously support the
construction of the Pittston refinery and its general
intent.
Lubec has a population equ&l to that of Eastport.
The twD c i’ s a e sep r t by cnly two miles of
e n tact one CL ITL rtUn1ty until 1820. They
share a common geographical location, a common economy,
and its citizens face many of the same problems.
Presently the economic base of Lubec is at a very
minimum. The central business district is struggling
to survive. We have twelve stores, if you include the
Water and Power District. Many businessmen have expressed
a very negative feeling about staying in business very
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much longer.
The average age of the taxpayer in Lubec is between
45 and 50 years of age. The young people must leave
town either after graduation from college or high
school. The outmigration will continue if the job
base is not expanded in the very near future.
Many taxpayers are having a difficult time paying
their property taxes. For the services that we render.
I feel that in proportion to services the taxes are
quite reasonable. Yet the cost of delivering services
this year have increased more than wages by far. The
municipal price index is 2% more than the consumer price
index. Without a stable job market it is almost
impossible to continue this level of services. The
level of services now is minimal, it is functional,
but what we have is, I feel, very good. Without the
services a community will do one thing, it will decline,
and it will continue to decline.
The Lubec Municipal Airport is a fully lighted airport
and it is on the State Airport Plan. We are working
very hard to have this put on the Federal Airport Plan.
It is plowed in the wintertime and it is fully maintained
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by the municipality. Most certainly within this area
Lubec would be very willing to expand its airport.
A capital improvement priority of Lubec is a
commercial dock. Such a dock can facilitate a ferry
service to this community. Until 1948 there was a
ferry service which transported workers to the central
business district here in this town. We had social
interaction and also just general tourism.
The environmental impact will be stringently regulated
by state and federal agencies, according to the Environ-
mental Impact Statement, although I realize the Environ-
mental Impact Statement is not perfect, but no document
is.
Therefore, it is the recommendaticn of the Lubec
Board ‘ ‘ l’ ctrnen that the construction of a refinery
would generally - and I stress the word “generally” —
benef it the citizens of L,ubec in its economic, social,
and environmental planning.
Thank you.
Response:
Comments noted.
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— _ w i V
TOWN OF ST. ANDREWS Q
PROViNCE OF NEW BRUNSWICK
T. ANDREWS, N. B.
EOO
December 3, 1976
Mr. John McGlennon, Director
EPA Region 1
John F. Kennedy Building
Boston, Mass. 02203
Dear Mr. McGlennon:
I am writing to express the concern of the residents
of the Town of St. Andrews to the Pittston Company rroposal
to build an oil refinery and marine terminal at Eastport,
Maine. Like Eastport, St. Andrews has seen its fortunes
come and go with the Drosperity of the fisheries and
coastal trading, but we remain convinced that the future
prosperity of the region does not lie with industrialization
of the type the Pittston Company proposes. Furthermore, the
draft Environmental Impact Statement does nothing to re—assure
us that the company can operate such a comr>lex without
serious risk to the environment on which today’s
prosperity depends.
Our principal regional industries are Fisheries,
Forestry and Tourism which depend absolutely on clean air
and clean water, and a significant fraction of St. Andrews
economy is with the various biological research and teaching
institutions which are located here because of the unspoiled
and productive waters which surround us.
We are firmly convinced that when the likely impacts
of the proposal are properly evaluated, it will be seen that
the inevitable deteriorstion in air and water quality on
a regional scale and the economic conseauences cannot be
justified simply by the material benefits accruing to
1 astport and the Pittston Comiany. We would far rather see
a rational joint developTnent of our natural renewable
resources, so that all of our towns and communities can
mutually work for the betterment of the region as a whole.
You )s cerely,
‘. Jc n Boone
M A Y 0 R —
Copies to: Chamber of Commerce
Hon. omeo Lel3lanc Response:
Hon. Don Jamieson
Hon. Omer Le er 32-1 Comments noted.
Premier Richard B. Hatfield
-------
t)FC 1 1971
December 13, 1976
Calais, Maine
Economic Development Board
City Building
Calais, Maine 04619
Environmental Protection Agency
Region One
Boston, Massachusetts 02203
Dear sirs:
The Economic Development Board of Calais wishes to appear on the
official record in support of the proposed oil refinery to be built by
the Pittston Company of New York in Eastport. It is our belief that
such a facility would go far in helping to solve the need for permanent
jobs in Washington County. If the employment situation in this area
could be characterized, it would have to be said to be suffering from
underemployment or seasonality. The proposed facility would provide
300 jobs to this area and present a real option to our present needs
and to future generations.
The Pittston Company will •provide training so that 200 of the 300
jobs can be occupied by the local labor force, and this is a step
towards encouraging employment opportunities. ‘Spin—off’ jobs will
be encouraged, as is the case with any company of this magnitude moving
into any area.
There is little doubt in anyones mind that the proposed facility
poses a challenge to the residents of Washington County. We have been
courted before by proposed economic booms, and to date we have survived.
It is our belief that residents will handle the challenge of an oil
refinery in our midst effectively and with concern.
Therefore, the Economic Development Board supports the refinery
ro os 1. We believe that the resulting jr hs, the nature of the technologj,
the ‘spin-off’ opportunities to he generated, and the resulting tax
revenues can only move in the direction of helping to solve the areas
economic problems. There can be little doubt that such a facility would
serve the needs of the Washington County area and the nations energy
needs.
Respectful ly,
R.John Ryan,Jr.
Director
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U. S. Fnvironmental 1-rot.otion Agency:
I am Arlo Bats of Calsis, the Vics—Cliairxnaa of the
Economic Dsv.lopeient Board of Celais.
This is a board establiski.a by the Cal is City Council
to encourage and proLilot. the expansion and d.vslopm.nt
of existing industrial and commercial firma, and to
promote and encourag. the location of new industrial
and comm.rcial firma in th. city of Calais.
We support enthusiastically the Pittston project as
the employment opportunities generated during both
the construction ond operational phases of the
Pittston project will greatly b.nsf it all the citi-
zens of the Calr is area.
Cslala has th. largest retail shopping area ea8t of
El].sworth. We anticipate this service can be expaudcd
with the additional jobs gen.r t.d in Eastport.
A more detailed statement will be submitted, ror the
reoord, at a later date.
Response:
Comments noted.
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Bangor. Maine — New England &owlh Cenler
EDWARD G McKEON
(7j1) 947-0341
Qttt uf angnr, latnv
DEPARTMENT OF DEVELOPMENT. RESEARCH nd PLANNING
November 22, 1976
Permits Branch, Enforcement Division
Environmental Protection Agency
Kennedy Federal Building
Boston, Massachusetts 02203
Gentlemen:
The responsibilities of my department include providing
development services to a population of 35,000 within the
city. However, the impact of our programs in Bangor are
far more reaching than our own city limits. For example,
44 percent of the jobs created in Bangor are filled by
residents of communities up to 40 miles away.
The economic health of Bangor, therefore, is important to
a population base representing nearly 15 percent of the
state.
Conversely, the stability of our economy here in Bangor
and its ability to serve as a job center depends heavily
on the economic health of the entire Eastern and Central
Maine Area, a region that represents the primary and
secondary market for the goods and services generated
in Bangor.
More specifically, the economic welfare of the Bangor-
Brewer center which has proven able to produce an ad-
ditional 300 to 500 jobs annually, depends substantially
on activities elsewhere. The production, price and
transportation of agriculture products grown elsewhere
in Maine, the fish catch and level o± tourism along the
coast, the production of pulp, paper or other manufactured
goods in numerous small Maine communities within our market
areas, the level of unemployment in communities from Rock—
land to Eastport to Fort Kent to Greenville and Newport are
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Environmental Protection
Agency —2— November 22, 1976
all factors of the utmost importance to Bangor. . .because
they directly affect our commerce.
For this reason, and for many more specific reasons, the
development at Eastport proposed by the Pittston Company
represents a substantial contribution to us in this region,
in both short- and long-term benefits.
The important environmental questions have been resolved.
The project, therefore, deserves our support.
Sincerely,
‘
Edward 0. McKeon
EGM:k
Response:
Comments noted.
35—2
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COMMENTS SUBMITTED BY
THE PUBLIC SECTOR
-------
L C rgo
33 Clumons Street
South Portland,Nain. 014106
6 November 1976
The U.S. ivironmental Protection Agency Subject: The US ’A F S,
Region I; forcernents Division; Permits Branch 13 OCT ‘76. M I PETROL 1J) ..
The JJ. Kennedy Building, Boston, Na. 02203 0RI iTE2) COMMENT ON; B!
18 OCT 1976 INVITATION
Dear Sire:
Congratulations for quite a comprehensive l statement of Pittatonte p’c-
posed 250 N b/d l\iels Refinery. However, Pittston’s hypotheses, technical
and statistics]. inputs smack of typical hard sell N by existing major
refiners. In n r opinion , based upon years in the petroleum industry: The
Pitts*on Company of New York, although a fossil fuel producer, possesses no
substantial petroleum products manufacturing experience --- let alone off-
loading of nu.merous VLCC’S at the proposed N monomooring N
1. Page No. 238 Surface area, actual oil spill containment ( and prevention
proeedures, on standby ) are, xr y considered opinion, just so naich rhetoric.
Please refer to continuing VLCC oil spills --— few reported this side of the
Atlantic-— in seawaye west of Cape of Good Hope. No tortuous currents of
channels there. It is known that oil-spill frequencies, from tankers less than
200 14 barrels are greater; and, there is no rule to prevent shipside off.-
loading, from any and all vessels, at the monon oring ( and piers ) presenting
additional, special spill hazards. Again, I quote in part, from Page 238
N p . y oil COLLECTED by the recovery operation will be processed by the refineryN
How about the oil spills and slicks NOT COLLECTED ? Urgently suggest The U • S.
Coast Guard Squadron Commander, and The Corps of hgineera re-study that.
a.Page No. 25, Vol. I To N permanently employ 300 people full time The
Pittston Company obviously ignores the more economic , automated refinery op-
erations. You may find such automation should require only, some 21.6 men, for
each daily eight—hour shift. Further, by lack of interest by extant major re-
finers for the Northeast, I find Pittston’s estimate of 1,200 einployees,permanent,
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economically unsc ind now , and fubire, for Maine. Le a resident,I wish so too.
3.Such a high estimate seems to belies Pittation’s statement, in parts” air poll-
ution enisetona wcxa]4 be dec aaed by elimination of” (the) catcracker, viabreaker and
coking “(phases) Excuse me, sire, do you not name the !acilit : N An Air-Cooled
Topping Refinery ‘ ? &iggest you, at initial operational phase, restrict it only
to that. You, and all federal cognizant agencies, may use aforesaid as testimony
for the piblic heraings commencing 3 December W?6
Respectfully yours,
Frederick if. llorreil, retiree, from t & yeight years
management & operative experience
in the petrol im industry.
CC: The Hon. James B. Long1 ’, Governor The State of Maine, Augusta Main. 04.330
Response:
Conunents noted.
Also see FEIS Vol. II,
p. X—2 ff, p VI—28 ff,
p, IV—38 ff, p. VI—4 ff .
36—2
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Robert S. Friedman Cobscook Bay Laboratory
Suffolk University Beacon Hill
Boston, Mass. 02114
Dennysville ME 04628 (617) 723-4700
(207) 726-4749
November 10, 1976
U.S. Environmental Protection Agency
Region I, Enforcement Division, Permits Branch
John F. Xennedy Federal Building
Boston, Massachusetts 02203
Re: NPDES #ME0022420, CORPS #25—76—367
Gentlemen:
Responding to the invitation to coumsnt on the proposed construction of an oil
refinery by the Pittston Conçany in Eastport, Maine, I should like to request an
opportunity to have the following concerns addressed either in writing or at the
public hearing scheduled for December 3, 1976, in Eastport, Maine. I preface this
request with the recognition that Suffolk University has chosen not to take a posi-
tion on the question of locating an oil refinery that has been proposed within the
geographic proximity of its 1 bert S. Friednian Cobscook Bay Laboratory. The Univer-
sity recognizes that the economic advantage for the area is a matter that the citizenry
of the area must determine when all of the alternatives have been considered. It is
the relevant factors associated with these alternatives that Suffolk University
wishes to have established.
The waters of Cobscook and Whiting Bays, with all of their subdivisions and tribu-
taries, represent a relatively natural and stable condition for studying the myriad
fbrms of marine life which abound there. These waters are a virtual paradise for
the scientists studying marine coldwater life forms. The tidal fluctuation, which
is the greatest to be found anywhere within the continental United States, provides
the unique condition for observing marine organisms under intertidal and subtidal
conditions.
The questions that Suffolk University:poses are:
Will the proposed alteration of Deep Cove and Broad Cove, and the
subsequent release of soluble and particulate matter into the waters
of this complex, produce environmental changes which will alter the
marine ecosystems from those that have been established?
Will there be a tendency for discharged materials to be washed into
the inner bays rather than flushed out into the deeper waters, thus
posing the potential for a build-up of materials to polluting levels
at a location remote from the site of discharge?
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—2—
These questions are addressed to the g.n.ral qusation of whether this natural
condition will be sufficiently altered to render an unnatural environment to the
inner water of the Cobicook and Whiting Bays.
Since,1Y 0
Arthur J. t, 11, Ph.D
Director, Robert S. Friedman
Cbbs cook Bay Laboratory
cc: The Pittston Cou any
P.JW/skk
Response:
Comments noted.
Also see FEIS Vol. II,
p. VI—59 ff, p. VI—28 ff.
37—2
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Testimony G±v by A. West, R. S. iedTh n Cobsc ok B y _ Laborato ry,
at the December 3, 1976 Public Hearing
MR. WEST: Thank you. Mr. McGlennon and members of
the commission. We have a statement on file, dated
November 10, 1976. I would like to preface my remarks
by saying that I am Arthur West, the Director of the
Robert S. Friedman Cobscook Bay Laboratory of Suffolk
University, and a Professor of Zoology at Suffolk
University. I would also preface my remarks by indicating
that we have a co—joiner, which is New England College,
that is in possession of an island, known as Williams
Island, formerly known as Ha11o e11 Island, that adjoins
our property, some 108 acres, and both of our institutions
are concerned about the çuallty of th w ’ce . e have
no basis to question ‘h’ ’r.her or not t : tho
water will be altered. We do depend on the Environmental
Protection Agency to be concerned about this factor. But
we do know that the waters of Cobscook and Whiting Bay,
with all of their subdivisions and tributaries, represent
a relatively natural and stable condition for studying
myriad forms of marine life, and they abound there.
These waters are a virtual paradise for the scientists
37—3
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studying marine cold. water life forms, and the tidal
fluctuations, which happen to be the greatest to be
found anywhere within the continental United States,
provides these unique conditions, and provides the
conditions for observing intertidal and subtidal
organisms.
So the questions that we pose are simply will the
proposed alterations of Deep Cove and Broad Cove, and
then the subsequent release of soluble and particulate
matter into the waters of this complex produce environ-
mental changes which will alter the marine ecosystems
from those that have been established. Will there be
a tendency for the discharged materials to be washed
into the inner bays rather than flushed out into the
deeper caters, thus posing the potential for a build-up
of materials to polluting levels at a location that may
be remote from the site of discharge.
We draw to your attention that apparently there will
be a continual flow of material from the refinery into
the bay, and we suggest that this may pose a greater
problem to us than the potential threat of an oil s llage.
Because of that constant flow of effluent and Tnatetial
37—4
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into the waters, with the tides washing into this bay,
this confined bay, it may very well be that the cumulative
effect of this will have a greater devastation upon the
marine life around our own facility.
I would indicate again that the University is very
sensitive about this question because we are in many
respects visitors to the area. We use this as our
laboratory. Our principal place of location, of course,
is in Boston. So the official position of Suffolk
university is not to take a position on the question of
locating an oil refinery that has been proposed within
the geographic proximity of the Robert S. Friedman
Laboratory, but rather the University would like to
recognize that the economic advantages for the area is
a matter that the citizenry of the entire area should -
determine. And when all of these alternatives have been
considered, it is the relative factors associated with
the alternatives that Suffolk University wishes to
establish.
We are concerned that there is apparently no provision
for capturing the effluent, should the effluent prove to
be a detriment to the bay. We might suggest to the
37—5
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Environmental Protection Agency that they consider
maybe the construction of another holding tank should
any eventuality occur that would like to interrupt that
flow and stop that system.
Another possibility is that with this tide flowing
back and forth every six hours that twelve hours of the
day it will be flowing.into the bay, and some of this
matter may in fact settle out in the bay. These are
factors that we would like to raise for your consideration
for further review.
Thank you very much.
MR. McGLEi NON: Thank you. Dr. West.
37—
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November 6, 1976
To the itor Quoddy Tides
stport • ham.
Dear ) a. Trench;
I )a ow you receive hundreds of letters a year on the Refinery Issuo but I cannot
refrain from sending you one more. The DEP has sent out come of their findings on
permits requested by Pittston and for th. people who didn’t receive them or have not
read than I would like to make several points.
Th. refinery will be operating Vi hours a day at a noise level equal ti $m in ex-
cess of th. noise level of the building phase. They say 60 decibles at Rte 190, though
the Ssndford Refinery has levels of 60 deoibles at 2,300 feet, almost 1000 feet further
than the estimates for this ref thery.(60 dociblos is like listening to heavy traffic
from 300 feet they say. The D ’ says that at levels of 70 decibles there can be
bearing loss).
The projected number of spills a. year is 8—12, for a total of 14 —32 barrels but they
say the Welsh refinery- has 53 -9I spills a year for’ a total of 206 barrels a year during
1963 to 1971; and 9& a year in 19t 9 ,70, aM 71. They didn’t give any figures for iore
recent years. This spillage is in addition to the projected daily discharge of 60
gallons a day, every - day, or 21.900 a year.
They say that the refinery wifl not contaminate the shore • It is virtually impossible
to spill even a small amount of oil in Eastport and have it stay off th beach, Sev-
eral years ago there was a sciall spill in oneeof the factories in F.astport and the follow g
day there was oil on the beach as far as Bollier Cove in Fthirnnds.
Another problem that we will have to live with is the one of sulfuric acid i d.sts. They
say it is not a problem bocauso there are no federal standards for this eumission. That
means it is one of the things they do not count, but one need not be a ecienti t to knot;
that breathing culfsric acid cannot be good for you. The air ‘ulli also be contaminated —
by particles, within the D ’ strnd&rds, of course, thyy say.
The report is not a diseua$on of the refinery will harm the enviorni .’ont of the Bay,
but rathor a disonesion of acoeptable 3.nvols of berm. The deotsion will not be made by
fisherman and others who live hero, but by peep 1. who drink water that has been recycled
38—1
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2
thru tr *ta,ent pLants. who twin in pools that are bill chlorine and breathe sir sat—
orated with lead; and who watch the sewage they flu sh od in the toilet ocideg back on
than (like in Long Thia .w last manner). They think it. oil alrir,ht. k. should be the
ones saking the decision. ‘,ls should be the ones who decide that we do or don’t want this
blechina, bang, pounding • stinking ness in our door pads. Not soneone who livers in
the aiddie of Nov Tork City or .hington, D.C. Those people are used to ard don’t wind
living in t liution. that about you? bbat about th. rest of the residents of Fastorn
Iksbi.rgton County? kxl what are vs tt .thg in return for the sob, of cur health and peace?
No are getting OOO construction vork rs for two you. (for whoa the,. is adequate housing
says the report). blo are going to loan the littl, we have left of our fishing industry
and the possibilitics of inprovewent ‘ hru thing. like aquacultur.. g exchange for that
vs are told we can perform ‘cupportiv service’ work. I leate it to you to iit*gino tthat
those Job. 41l b . As for r# . I am gt a total loss to know wh*t sort of job I can do,
having no capitol to invest in a business that would ho vinbie said I am sure that the bait’
are not likely to lend neney to a business with a lifo bxpectancy of two years. The asin
strsot of Fastport will be a lot of bar., hooky tonks said asesage pelore.
Clearly we are gcirig to loss a way of life that is rare and precious. He ooaplain of
the lack of security and of the crime but we forget that in coeipsrison to moat plac’o in
this country we are rel*ttvley free of that kind of barrassewent. bk still have co inunitits
and relationships to each oth.w, though not ideal, which are a east izprovaient over what
nest people can expect. I runerther a relative of wine who has a r sfl baby and lives in
Now Irk City sa ’i.n% she realised what she was living with one day when she had to go out
to the sèore. te was feeling dissy •aid weak and suddenly she knew that if she were to
(a.int on the street, sh would vake to (laid her baby gone, her pocket book stolen sad God
Imows what else. i rogard1ess of hay bad we think Fastport is, we do know that its not
that bad.......ynt.
inoerely,
t iI JJ(7OO1
Response: —
Cousnents noted. )lip
Also see FEIS Vol. II,
p. IY—38, p.VI-78 ff.
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U 2 1976
NORTHEASTERN UNIVERSITY
BOSTON, MASSACHUSETTS 02115
AI11IVff OF EALTh ScIENCES 21 Nov. 1976
U.S. Environmental Protection Agency, Region I
Enforcement Division, Permits Branch
John F. Kennedy Federal Building
Boston, Mass. 02203
Dear Sirs:
In accord with your notice and invitation of public comments, I hereby submit my
views and analysis of the draft Environmental Impact Statement dated Oct. 13, 1976,
regarding issuance of proposed federal permits to the Pittston Company of New York,
for the construction of a 250,000 barrel! day oil refinery and marine terminal at
Eastport, Maine. These comments form the basis for remarks which, transportation
allowing, I hope to make at the public hearing over this matter at Eastport on Dec.
3, 1976. They supplement remarks made in letters to your office dated 30 Aug. and
14 Sept., the contents of which, I might note here, are not reflected in any way
in the draft environmental impact statement, although they were sent in response
to a public notice (11 May 1976) calling for input to the decision—making process
leading to the issuance of this statement, and In time to be considered.
My general opinion of this draft E.I.S. is that it does not even begin to meet the
standards set up by federal law which is in fact reproduced in the appendices (vol.
III) of the E.I.S. Although your public notice calling for these comments states
that Pittston is applying for a permit to discharge pollutauts, it is clear from
the nature of the E.I.S. that all aspects of the refinery operation are supposed
to be considered by the EPA, and that the EPA must consider in Its decision all
manner of impacts on the environment, and not just those immediately involved in
disch arging of pollutants. In the federal rules and regulations printed on page
A-78 of vol. III of the draft E.I.S., it is stated that “Agencies are required to
view their actions in a manner calculated to encourage productive and enjoyable
harmony between man and his environment, to promote efforts preventing or elimina-
ting damage to the environment and biosphere and stimulating the health and welfare
of man, and to enrich the understanding of the ecological systems and natural re-
sources important to the Nation.” I believe the E.P.A. has failed in carrying Out
this commission in the E.I.S. here under consideration, for the following reasons:
1) The most Important natural resource of the Eastport region, in my opinion, is the
tiiique tidal range——unique in the eastern United States in being over 18 feet on the
average, representing the best available tidal power resource in the U.S. outside
of Alaska. The tidal power generated by the proposed international project in these
waters would be about 1,000,000 kilowatts in capacity, or about the size of one large
thermal electric plant, either fossil—fuel or nuclear. It would have the advantage
aver these other types of plants in being completely non—polluting, in not requiring
fuel purchases, and in not being subject to exhaustion of fuel sources. Since recent
t ises in petroleum costs, tidal power has become more competitive economically, and
recent reviews of its benefit—cost ratio are now underway in both the U.S. and Canada.
It would seem highly unwise to jeopardize this unique resource at such a time; and
39—1
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2
yet that is, I firmly believe, what the Pittston refinery proposal would do. It is
also my firm opinion that the importance of the tidal power potential is grossly
underplayed in the draft E.I.S., and the possibility that tidal power development
is compatible with the refinery plan is very inadequately evaluated.
In vol. I of the E.I.S, no mention whatsoever is made of tidal power as a resource
to be conserved or as something - that which would be endangered by construction of the
oil refinery; tidal power is mentioned only in a peripheral fashion related to the
possible economic impact of construction of the tidal power plant (which, it is
said, would be similar to the impact of construction of the refinery), on p. 23.
Since many if not most of the public who receive copies of this report will draw
their primary impressions from the small and convenient summary in vol. I, this
complete omission of the tidal power problem from the summary renders the entire
report inadequate to inform the public of the main issues at hand.
Later, in vol. II of the E.I.S., there is a page devoted to tidal power, and a
map showing site adjustments allowing tidal power construction next to the refinery.
The text (p. 193—194) implies that the site adjustments constitute the main problem
involved, and says that they have been agreed to satisfactorily. Somehow, however,
the map (p. 195) which shows the site adjustments is different than the other maps
of the refinery site in the volume (p. 217, 321); this indicates at least that the
report is sloppily prepared, and perhaps also that the site adjustment was just an
afterthought that was not taken seriously. The map on p. 195 contains, as do many
maps throughout the volume, an inadequate legend,which leaves the reader guessing
just where the new site boundary between the two projects will run, but from my
conversations at the offices of the Corps of Army Engineers, I determined that it
would cut off about 10% of the old refinery site, none of it next to the critical
deep—water anchorages.
But it is my strong contention that site adjustment is by no means the most ser-
ious problem involved in compatibility of the two projects. Navigational problems
are much more serious. The E.I.S. says that Pittston has been advised of the need
for a lock if the two projects were to co—exist, and that “the size of the lock will
be subject to future considerations and negotiations if, and when, both projects
are built.” No hint whatsoever is made of the size of the required lock. Let me
make some suggestions. My research has revealed no larger locks in existence today
than those in the Panama Canal, which accommodate vessels 1000 feet long, 110 feet
wide, and drawing 40 feet of salt water. Yet the 250,000—ton very large crude car-
riers Pittston wants to use in Eastport would be, according to information published
in the E.I.S. (and similar to data found elsewhere)onp. 229, 1141 feet long, 170
feet wide, and would draw 65.4 feet of salt water. Thus the volume of the new lock
needed at Eastport would clearly be more than twice that of the largest existing
locks anywhere in the world. If Indeed there are slightly larger locks elsewhere
than at Panama, the argument remains strong that the lock needed is an exceedingly
large and expensive lock, in any case. It is clear that no lock has been built
yet anywhere in the world which will accommodate a super—tanker, i.e. a VLCC. To
write that the size of the lock will be subject to future considerations is to ob-
scure the issue very seriously. It is presently certain that such a lock will have
to be the largest lock, or very near to it, ever built, anywhere in the world. Not
a word is said in the E.I.S. about who will pay for that lock. Private information
from the Corps suggests that Pittston would have to pay for all or most of it, but
I find this arrangement highly informal, and very unsatisfactory. If tidal power
Is to be generated in the waters around Eastport, and a refinery is to be built in
the area first, then to protect the tidal power resource, the refinery owners ought
to be required to place in trust an amount of money equal to the estimated cost of
the lock some several years hence, and to be required by law to pay all the cost Of
that lock over and above the cost of smaller locks needed for other customers only.
That none of these matters are considered in the E.I.S. anywhere means that the
most serious objection to the com ?atibility of the two projects is simply ignored,
and that therefore the tidal power resource is not being adequately protected by
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3
the considerations contained in the report. As far as guarantees from Pittston
are concerned, I find it also rather strange that nothing is said in the report
about transfer of land indicated in the site adjustment map; is Pittston deeding
this land to the federal government, or not? If tidal power is to be generated,
such arrangements should be made forthwith.
Another defect of the discussion of tidal power in the E.11.S. is the inadequate
consideration of changes in water level due to the refinery and its docks being in
the low pool of the presently—considered tidal power project. This situation 1
mentioned on p. 194, vol. II, but it is not reflected in the various discussinns
of navigational problems throughout the rest of the report. This adds to the im—
pression that the tidal power question was merely an afterthought in the report,
and has not been integrated into it in any effective way.
To summarize my argument in this section, I believe that, primarily because of
the problems of conetructing adequate navigational channels through the tidal
power dam——i.e. the largest lock heretofore built anywhere in the world——the Pitts-
ton refinery would very largely discourage further work in developing the unique
and valuable tidal power resource of this area. Nothing would stop Pittston, ac-
cording to current arrangements, from applying pressure against building such a
lock once the refinery were in operation; it would, after all, have to pay for
all or most of it, and might prefer to avoid this expense. There are no guaran-
tees on record that Pittston would do any more than make perfunctory nods in the
direction of compatibility, and then be free to go ahead and block tidal power
development with all the resources at its disposal. In view of what is to be said
below about the character and background of the Pittston company, this is an in-
adequate situation indeed in terms of the tidal power resource and its ultimate use.
2) Apart from tidal power, I find the report highly biased in its discussion of the
navigational problems involved in directing VLCC’s into Eastport. On p. 14 of Vol.
I (the stm1m ry vO .ume) it states that Eastport is a superior site for a refinery
because of, among other things, “a very deep, natural sheltered harbor, with ex-
cellent channel approaches as regards its width, depth, straightness, and length.”
This analysis runs counter to much expert opinion. Among those who doubt its
veracity are obviously many officials in Canada, who have thus far denied permission
to navigate any super—tankers laden with oil through Head Harbour Passage, the main
approach to Eastport and the only one possible for the VLCC’s Pittston plans to use.
They have stated that the danger of oil spill is great in this passage. So, as a
matter of fact, does the statement issued on 12 March 1975 by the MaineDepartment
of Environmental Protection, in regard to the Eastport site itself: “Oil spills
at Shackford Head, due to the currents, cannot be controlled using presently avail-
able technology. The R cótd provides no evidence that significant breakthroughs
in such technology can be expected in the near future. The combination of currents,
tides, fog, extremes of weather and rocky shores make Eastport one of the more dif-
ficult ports in the world.” The report then goes on to discuss the various navi—
gational problems in detail. Among other things it points out that docking must
be done at slack water, and that slight delays in transiting Head Harbour Passage
might increase the dangers of docking. It is pointed out that Pittston might be
under such pressure to operate the refinery at full capacity that it would take
unacceptable risks in navigation in order to keep a supply of crude oil flowing
even in bad weather. Such possibilities are important to consider, again in con—
nection with the history of Pittston’s previous environmental precautions or lack
of them, discussed below.
Now, it is strange indeed that the draft E.I.S., in its summary and in its main
text (vols. I and II), reflect3 none of the skepticism shown in this Maine D.E.P.
report, for the report is reprinted in its entirety in vol. III, the appendices.
Is the reader actually expected to glean this information from the appendices him-
self and use it to modify the much different conclusions in the main text and the
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4
summary? Clearly no redsonable person would expect this. Therefore one must con-
clude that unfavorable opinions from Pittston’s point of view have been relegated
the the appendices either out of gross carelessness or out of a deliberate effort
to make the report more favorable to Pittston.
None of what I say here is invalidated by the fact that the Maine D.E.P. changec
its mind on the dangers of oil spills in its reversed decision dated June 4, 1975,
and also reprinted in the E.I.S. appendices, on p. A—51 and A—52 of vol. III. tn
this reversed decision, it is stated that oil spills in currents of up to 1 knot
can now be contained, and that Pittston has now provided alternative pier loca-
tions at Shackford Head in currents of less than 1 knot. This information hardly
invalidates the generally dangerous nature of the waters around Eastport; it only
provides the small details of why the D.E.P. changed its mind, and the change is
highly suspect indeed, inasmuch as the June 4 report goes on to say that Pittston
has failed as of yet to give the precise location of the 1—knot current velocity
line in the Shackford Head area. Furthermore, even the June 4 decision reveals
serious problems when compared to the rest of the draft E.I.S., since the maps of
current velocities (p. 61 and 63, vol. II) reveal many currents over 1 knot, and
some as high as 2.9 and 3.0 knots, in the approach to the proposed tanker berths
at Eastport; these velocities are, therefore, much in eess of those in which
spills can be handled safely, if we take the Maine D.E.P.’s figures as correct.
Spills might be less likely in the middle of the channel than when docking, but
certainly they must be regarded as possible.
The E.I.S., however, obscures all this. It obscures it primarily by listing
the objections in vol. III, which, according to employees of the E.P.A. itself
when I visited them recently, has not been mailed out to most of those who received
volsd.I and II. It further obscures objections when, on p. 288 of vol. II, it
says “opponents testified that such navigation is not safe”——referring to navi-
gation through Head Harbour Passage. Not a word is said to expand on this state-
ment; in other words, we are given none of the arguments of the opponents to the
Pittston navigation plan, only those of Pittston itself. Evidently Pittston
produced experts who testified the passage was safe, but we are not told of how
they countered the arguments of those who said it was not safe, any more than we
are told of those latter arguments themselves. (The same passage also obscures
the result of the hearings, which were decided in favor of Increasing the size of
tanker allowed to navigate the passage into Eastport, to 250,000 dwt.)
On p. 17 of vol I of the E.I.S., it is said that oil spill danger would be
greater at the rejected Machiasport refinery site, than at Eastport, because of
the Machias area being “more exposed to the wind and weather from the Bay of Fundy.
Elsewhere in the report (vol. I, p. 7; vol. II, p. 136, 143—144, 147, etc.) it is
made clear that Eastport is unusually susceptible to fogs. Elementary meteorology
is all that is needed to be aware that strong winds disperse fogs, and that being
exposed “to the wind and weather” might make a safer rather than a more dangerous
passage near Machias, than near Eastport. Unusually bad weather might endanger
ships at Machias more, but by definition almost, unusually bad weather does not
happen :ery much of the time. More serious problems than the weather offshore
at Machias would appear to be the swift currents, frequent fog, and narrow channel
in the Eastport area.
I might add that the maps in vol. II of the report are unusually careless in
illustrating the approach channel into Eastport. This is seen on pages 231 and
53.On p. 53, the channel Is shown to be about 3/8 of a mile wide at its narrowest,
near Casco Bay Id. of f the northwest coast of Campobello Island. But the larger—
scale map on p. 231, lacking a scale but nevertheless subinissible to measurement
in terms of the other map’s scale, shows the channel to be only about 1/5 of a
mile wide——nearly half as narrow. It also shows depths of 70 and 74 feet well
within the area of the so—called 75—foot + channel; and if one consider.,s that
39—4
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the depths of water on this chart are evidently in terms of mean sea level, whereas
the diagram of the channel is supposed to show a channel 75 feet deep at mean low
water, then since the tidal range around Eastport is about 20 feet, depths up to
84 feet should fall outside the 75—foot channel. There are at least 9 additional
depths shown on the map on p. 231 which fall between 75 and 84 feet; together they
vastly constrict the channel between Moose Island (Eastport) and Campobello Island.
In addition, all these waters would be shallower if they were in the low pool of
the tidal power project; this whole subject, as stated above, has been ignored in
the bulk of the E.I.S. Of course, channels can be dredged to greater depths, and
in some sections of the E.I.S., dredging is discussed. That does not change the
fact, however, that the 75—foot channel is called a “natural channel” (p. 51),
thus considerably misrepresenting, in conjunction with the maps shown, the true
situation as to channel depth and width.
Finally it should be noted, in regard to navigational hazards, that no oil spill—
simulation studies have been conducted by Pittston or others in this area. This c nn—
mission is even mentioned on p. 27 of vol.1, where it says Pittston “will perform
real time simulation studies and test voyages”, but adds that “the only conclusion
that can be drawn is that the regular passage of tankers to Eastport will directly
expose the area to a potential oil spill hazard.” Not only is there no guarantee
mentioned that Pittston will indeed perform such studies, but it is concluded in
advance that only a nondescript conclusion is possible, instead of one emphasizing
the possibility of extreme danger from spills. One gathers that the entire E.I.S.
is designed to ease Pittston’s path towards completion of Its goals, rather than
to entertain real objections to environmental impacts. The same bias is evident
in reporting the progress of Pittston’s case through the Maine D.E.P., on p. 3
of vol. I: after the first judgement was negative, hearings were “therefore”
reopened——as if it were routine for a defeated applicant to have another chance,
until somehow it made a better case.
3) I further object to the report because it promises 200 jobs for residents of
Washington County, without making any mention of firm guarantees by Pittston that
indeed such jobs would be provided (vol. I, p. 25). The word “guarantee” is used,
but no details are given as to the nature of the guarantee involved; one must
therefore judge, I prestmie, by the applicant’s character record, of which more is
said below. It is worth observing that public opinion is frequently swayed by
promises of jobs in such cases. And yet public opinion in Washington County is
often recorded as favoring tidal power, I have noted in the past. I submit that
if the truth about the incompatibility of the tidal power and refinery projects
were known, public opinion would vote against the refinery now; after all, the
real profits to be made from it are from land sales, and this involves only the
privileged few. The state of Maine stands to gain from taxes, and there is good
indication that Eastport would benefit from tax tevenues too; but this still does
not guarantee benefits to the average citizen of Eastport or Washington County.
4) The character of the Pittston Company is mentioned in the Maine D.E.P. state-
ment of March 12, 1975, reproduced on p. A—57 of Vol. III of the E.I.S. It is
said that the applicant’s record “in meeting environmental and safety standards”
is adequate. I beg to differ, and to point out that the Pittston Company was re-
sponsible for frequent violations of environmental and safety regulations in its
coal mine operations in West Virginia a few years ago; in one case it built an
unsafe dam which collapsed and resulted in the deaths of over 100 people (See p.3I ,
Peter Bradford, Fragile Structures , Harper’s, 1975). We are dealing here, there-
fore, with a firm that is much more suspect thanthe average energy firm.
The many other complaints about the report that could be made include the matter
of the disappearance of the Eastport Airport under the refinery buildings, which is
treated very casually; and numerous minor errors and Inconsistencies such as thos.e
involving water supply, channel width and depth, etc. It matters little that the
39—5
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6
draft E.I.S. makes careless statements like the one saying the water supply for
the city of Eastport is northeast of the city, when in fact it is northwest (at
Boyden Lake; see vol. II, p. 181); but it is important that this degree of care-
lessness is visible frequently throughout the report, and affects more important
matters such as tidal power and oil spill danger. One is left with the distinct
Impression that the earlier environmental Impact report prepared privately by
Pittston, and obviously used In preparing this report, has been too little modi-
fied and too little criticized in putting together t draft E.I.S.
In addition to the poor job by the EPA of showing concern for environmental values,
one must add that the U.S. Army Corps of Engineers has managed to do very little
if anything to protect its Interest, and the public’s interest, inthe tidal power
project. This seems upusual indeed, in view of the Corps’ frequent contributions
to past studies on the tidal power project (the “Passamaquoddy” international
tidal power project, in Its latest version). The Corps did contribute to the E.I.S.
One would not expect the EPA necessarily to discuss the differences between public
and private energy sources, but I must add my opinion to this comaentary that we
have In this E.I.S. a clear preference for private profits in the energy field,
as opposed to public interest. I believe that New Englanders would benefit from
much lower energy rates if they were allowed to purchase power from public power
entities instead of private ones (The rest of the U.S. bears out this contention
in Its electric rate structure). Tidal power would probably be federally financed
and would yield lower— ost electricity than most private installations in New
England. Pittston’s fuel oil, however, would be fed into the existing private—
power thermal plants and produce high—cost power, with profits to both Pittston
and the private—power firms and consequent higher cost to the public. In addition,
it Is more wasteful of raw materials to convert oil into electricity than to use
It for other purposes.
In general, this E.I.S. is totally ziimaginatIve in the matter of looking for new
answers to energy problems. Surely it is not beyond the general interest of the
public vis—a—vis the environment, to ask that energy sources which are no*-pollu—
ting and which are not ephemeral, as tidal power is not, be given some encourage-
ment and preference as against the older, more dangerous and scarce sourees of
power such as represented by oil refineries and oil—fired electric plant&. Yet
this E.I.S. leans the other way, and favors the older, less satisfactory solutions.
Finally I would like to say a few words about my own qualifications to write this
statement. I could mention that I have a Ph.D. in Geography (1968, Kansas), have
studied under some of the best water resources experts in that discipline, and
have published over 20 professional papers in geography journals (Although few
of them deal with water resources, I have made a special study of tidal power in
the last 2 years and delivered several papers to professional meetings on the
topic). But my prime qualification, I think, is that I am not motivated by a
financial interest, but rather by the search for truth and the public interest.
No funding whatsoever is supporting me in this work. I do it simply to gain a
measure of professional competence and hopefully some rventual recognition. It
is not even being supported by Northeastern University, whose letterhead I use
as a courtesy along with offices there, after temporary employment there last
year. Pittston, on the other hand, has millions at stake and millions to spend
in convincing others of Its case. I leave it to the reader to judge the likely
relative degrees of adherence to objective standards, in making one’s argument.
Yours sincereiy,9 ‘ ,‘ ( ( , (/ j
E. Chappell, Jr. cc: Several interested
- parties.
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Testimony Given byj. Chappell,
at the December 3, 1976 Public Hearing
MR. CH1 PPELL: My name is John Chappell , Jr. I
live in Boston and I have taught university level
geography courses 1 including water resources, in
both the U.S. and Canada for seven years, most recently
at Northeastern University. I have a six page statement
which I have submitted and I am going to try to summarize.
It seems to me the Environmental Impact Statement
that we are talking about, the draft statement, is so
full of incompleteness and inconsistency that it should
not be accepted as a fair representation of the environ-
mental risks involved. Incidentally, it even fooled
me: in my statement on page 4, I make the false assuznption
that 250,000 ton tankers have already been approved. It
seems to be assumed that they are approved throughout
the report, and yet we find out today that they are not.
It seems to me that not much has been said yet,
although Mr. Harris said something, about the character
of the Pittston Company. An awful lot has been written
in the past about the Buffalo Creek disaster, which was
presided over in 1972 by the Pittston Company. Not very
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much has been made of this, but we have to consider the
character of the company, based on its past record, as
to whether it is going to carry out its responsibilities
here in Eastport to avoid oil spills and other things
that would harm the €own. And I am rather disturbed
over the fact that the Maine Board of Environmental
Protection accepted the character of the company as
acceptable without a good deal of investigation into
its past record.
It seems to me that oil spills in general are vastly
underplayed in the Environmental Impact Statement.
Almost nothing is said about the oil spill danger in
Volumes I and II of the Environmental Impact Statement.
The only real objections y u can find aie in Volume 111,
which was not even mailed out to a great ta ny pecple
who received Volumes I and II. And it is contained in
quotations from the Maine BEP Report, which were not
invalidated by the later approval of the refinery. The
Maine BEP thinks that a 1-knot current is ‘fast enough
and over 1 knot you can’t control the oil spill. I
don’t know if that was invalidated by the testimony given
here today, but at. any rate, there is a lot of inconsistency
39—8
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on this issue and incompleteness in the report. It
simply does not treat the oil spill problem very well
at all. It does not mention the negative aspects of
this problem, the contradictions to the Pittston point
of view, at all, not adequately at all.
In fact, it even makes the statement that if you
had a complete study of the oil spill danger, which
Pittston has definitely not made, you couldn’t determine
anything more than that an oil spill danger would exist.
And that is all you could determine, so why bother making
much of a study. That is the implication from that
statement. It is a predetermined conclusion contained
in the EIS.
It seems to me that all the comments made here today
about the economic benefit of the refinery overlooks
something that one other person has pointed out here
today, and only one, that this is a short—term project.
It is only going to be good for a few more decades,
and then there isn’t going to be any more oil to bring
in. We may run out sooner if we have a national emergency.
People here today just don’t seem to realize that we
are in a new era. The oil is running out. We don’t
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need plans from the old era. We need clean eternal
energy sources such as the Tidal Power Plan, and I
want to speak mainly in terms of tidal power. (Applause)
It seems to me that the omission of tidal power
from the first volume of the EIS is a grave omission.
The main threat the refinery poses to the environment
is to the tidal power resource, which is the best in
the 48 conterminous United States. It is barely
mentioned in Volume II. We find out there that there
Is a compatibility, supposedly, between tidal power
and the oil refinery plan, but what is the problem of
establishing the compatibility? What does it consist
of? Apparently it consists only of making the .two sites
non-overlapping. But that is not the biggest problem.
The biggest problem is that if you have the refinery
and you have the supertankers coming in, you are going
to have to build - if you build the tidal power plant
too — a lock for the supertanker that is more than two
times as large as any other lock ever built in history.
Now, who is going to pay for this lock? Nothing is
said about it in the EIS. When Colonel Chandler talked
about it today, he said well, that will be negotiated
39—10
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later on. Well, why don’t we negotiate it now? Why
don’t we tell Pittston that in view of this unique
tidal power resource — you can build refineries in
lots of places, but this is a unique resource - anybody
building a refinery here should be required to place
in trust the amount of money required to build the
lock-- (Applause) --which is now estimated, I under— .
stand unofficially, by the Corps of Army Engineers at
85 million dollars, a very large fraction of the total
cost of the refinery. Now, what is to prevent Pittston
from lobbying and agitating against the building of
tidal power so it won’t have to pay that 85 million
dollars2 Nothing is said about these kinds of guarantees.
Nothing is said really to protect the tidal power project.
It seems to me that another issue that is ignored in
all the discussion of navigation in the EIS and else-
where is the problem of docking in the low pool of the
tidal power project. The tankers are going to have
even more trouble coming in if they are in the low pool
than they would have otherwise.
Furthermore, the discussions of the so—called 75 foot
natural channel and the maps of the same have a very
- 39—11
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grave error in the EIS. They are made on maps which
show the water depths at mean sea level, and yet they
say this is a 75 foot channel at mean low water. Well,
these is a 9-plus foot difference between mean sea
level and mean low water here because there is an 18
foot tidal range. This inconsistency is ignored in
drawing these maps of the so—called natural channel.
It is a very careless job; you wouldn’t get a C—minus
for it in a college course. (Applause)
It seems to me that the EIS simply doesn’t present
the real dangers either to the tidal power project or
to the potential victims of oil spill. A public reading
of this report simply does not inform the public of what
is at stake, n1 ss they examine it carefully for its
z i . z ai inconsistencies. The full facts of the case
would cast grave doubt on the wisdom of the refinery
plan.
Thank you. (Applause)
MR. McGLENNON: Mr. Chappell, we want three minutes
for rebuttal.
MR. CHAPPELL: Did I take more than three?
MR. CHANDLER: Mr. Chappell, I wàuld like to just
39—12
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follow up on one of your comments, but I think you in
fact answered it a great deal yourself. I, as the
Division Engineer in the New England Division, will
not determine the cost formula, cost—sharing formula,
for whatever might be the cost sharing for the lock,
if there is a Pittston refinery before a Passarnaquoddy
Tidal Project. However, both of those are still very
much in the “if” phase, and the purpose of course of
this particular public hearing is to talk to the Pittston
permit itself. But I give you my personal assurance
that I also accept that duty, which is totally apart
from that of reviewing the total impacts on the Section
10 permit, I accept that responsibility as also being
responsible to the Congress to properly analyze the
Passarnaquoddy Tidal Project. We certainly accept that
it is a unique resource of Eastport. and we will, as
the study progresses in the preparation of the report
that is now under way for the Congress, give it the
attention that is due. I just can’t tell you that we
know the answers now that could have been in the draft
Environmental Impact Statement perhaps in the detail
that you would want. But it will be there, and I accept
39—13
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these two responsibilities, but they are somewhat
separable, and yet they must be also brought to face
one another.
MR. CHAPPELL: Well, my main concern is that it
doesn’t seem that tidal power is viewed as a resource
in this report, and I think it is a resource. And it
seems to me that in the tradition of the Army Engineers,
the Army Engineers have usually defended their own
projects and tried to look out for the possibility
that they might not be able to be built ultimately, and
they have put a lot of money into this project already.
MR. CHANDLER: That was my point. We are talking
of the Pittston permit right now and the Environmental
Impact Statement with it.
MR. CHAPPELL: I know, but it seems to me that you
just aren’t taking into account the fact that if the
Pittston refinery is operating the way they want it to
operate, the Tidal Power Project is going to be much
less likely to ever be built. That is the point that
does not seem to be clear at all in the EIS, seems to
be clear to me.
MR. CHANDLER: O.K. You are not of course privileged
39—14
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yet to have seen even the first draft of comments.
As you probably know, we are of course making official
comments to the Environmental Protection Agency on the
EIS before the 10—day period expires, and considerably
more information will be included in that 1 and particu-
larly addressing this cost differential of the lock and
the problem of cost sharing.
MR. CHAPPELL: Yes, Mr. Leslie told me that, but I
don’t have it to see.
MR. STICKNEY: Mr. Chappell, just for the record,
the crude carrier dock as shown in the EIS and analyzed
in the EIS is within the 1—knot current regime as
required by the Maine DEP conditions.
Secondly, on the study of oil pi 11 s , in the prepa-
ration process we analyzec e\T r\ 5t 2 V zr at hed been
done so far, and we couldn’t find anything that was
statistically valid to extend to conclusions on the
potential for accidents in the channel out there. We
are here seeking information as well as giving it, and
if you or anybody else can show us that information, we
would be glad to use it.
MR. CHAPPELL: Well, all I can say is that in Volume
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11 Dec. 1976
Mr. John McGlennon
Regional Administrator, District I
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Mass.
Dear Mr. McGlennon:
No sooner had I sent off to you my letter of 10 Dec. with its enclosure,
a copy of the article by T. Bethell and D. McAteer from Washington Monthly,
May 1972, “The Pittston Mentality: Manslaughter on Buffalo Creek”, than I
ran across this second article, here enclosed. It is by Mary Walton, and
appears In Harper’s of March 1973. It is titled “After the Flood a contin—
SYS4 WHtr
uing lesson in corporate insensitivity. If anything, it -4urtneii’ 4 emphasizes
the lack of concern for human life and for environmental values in the cor-
porate structure of the Pittston Company. The people of Eastport have every
reason to be alarmed and angry over the possibility that this company would
be building any kind of business whatsoever on their island, especially one
that involves explosive substances such as petroleum. This is a company
without experience in refinery operation, but with plenty of experience in
jeopardizing human life. I further emphasize that the corporate record,
the character, in other words, of this applicant for a license is very
relevant indeed to your review. I urge you to consider both of these art-
icles and others on the same topic as an integral part of your review of
the application.
Yours incerely,
, John E. Chappell, Jr.
‘—‘ do Dept. of Earth Sciences
Northeastern Univ., Boston, Mass. 02115
39—16
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j4/74L
/Lla ,-ck
‘973
Mary Walton
A 1 [ L . t Dz E ©© )
A continuing lesson in corporate insensitivity
At 8:00 A.M., Febcua,y
26, 1972, a Sa col-
lapsed on the head-
waters of B4d. Creek
in Logan Cowuy, rest
Virginsa. It w mid-
afternoon be/,re the
news media in Charles.
ton, 100 miles .w,y,
learned of the flood and
two months before the
missüig were pressmed
dead, establishing the
fluial toil at 125. TM
was built on ea
pony property 0/ i ite
materials from cod
mines owned by the
Ba f/do Mining Cam.
pony, a subsUia y of
the Pittston Company
of New York City.
‘O 7 Wttho,,, /orfl?er!y
a reporter jot the
Chark q 0 Caz. -ite. s
flO maritjm, writer jar
the Philadelphia In.
qu, .
The rain faUs softly at fr* its soumi ampli.
fled by the trailers’ metal roofs. A child begins
to cry. A miner dressed for the second shift
steps Jrom the door and trtzd gas toward she creek
The rain continues through the night mid he
remains there, missing work for a compulsive
vigil at the creek bank Car after car filled with
Jamilies and, belongings rolls from the trailer
park in search of higher ground. Those who do
not Leave listen to the rain and remember. Their
tears are the sorrow of BuflaLo Creek
j’ SULLEI GRAY CELLINC pi es down across
k’ Buffalo Creek hollow, from hilltop to hilltop
and as far up and down the winding valley as
you can see, clamped on like a lid. Except for the
green grass and trees—these faintly singed with
early autumn—it is a black and white movie.
The sky, the houses, the people are all mono-
chrome: pale white children living in a shadowy
valley where they’ve never seen a horizon, ash
brown people whose great..graudfathers came to
lay the rails and stayed to mine coal beside whites
turned as black as they. There is a bnsk, cool
wind stirring, unusual here, cleansing but eerie.
More often the valley is still, clogged with dust
kicked up by cars and pickup trucks traveling
the crumbling road, and with black grit from
the tipples where coal is loaded into boxcars.
And, under skies such as these, a fine dulling
mist. At this particular hour in midafternooñ,
the long lines of C & -O cars are full but not
moving.
The upper end of the seventeen-mile-long
valley is a pretty place. Horses are tethered in
thick pastures on choice bottom land. The trees
are full, riffled by the wind, and the creek is clear.
But something is wrong. It is too quiet, curiously
empty, too clean. In the coal-mining hollows of
West Virginia. flatland hustles with small coal-
camp houses and carefully nurtured gardens,
company stores, trailers squeered onto tiny lots,
drive-in restaurant shacks, cars and more cars.
It is that cluttered leaving the town of Man,
at the mouth of the hollow, where the single
movie theater is for sale and you are “cordially
invited” to a revival. But at Kisder, three miles
up the valley, the homes seem oddly dilapidated
and the yards are muddy. Farther up you see
the high-water marks, the houses askewon foun-
dations. And then it is empty.
Where are they, the people? The people: the
old couples sitting on front porches, men tinker.
ing with gaping cars, children scattered among
the houses, the young girls walking in pairs, long
} air stringing down their backs and hips sway.
ing in tight jeans, the boys in worked-over
Chevys and Fords, honking as they roar by,
screeching to a stop toy l, “Where y’aIl goin’?”
The girls smile too sweetly. “We’re just tnkjn ’
a walk.”
A state road sign, green with white letters,
stands beside a large field. It says “Lorado Un-
incorporated.” Is could say “Lorado TJninhab-
ited.” There is nothing here. Lorado is one of
several communities that vanished February 26
when the dam collapsed.
5 AT... KATHLEEN. . . WAUCH is at home.
Rome now is a two-bedroom trailer, sleek.
ly paneled in plywood, with a new color TV, in
a place called Latrobe No. IV—here, Lay-trobe.
Odd, these Roman numerals, an outsider’s, a
planner’s touch.
She is a tall slender woman of forty-three, in
dark-blue flared slacks and a blue and white
patterned shirt. Heir hair is light brown, -very
short, soft and fluffy. Her voice, fragile and
quavering, carries the jarring West Virginia
twang; her laugh is nervous. She grasps her
hands when she isn’t drawing on a menthol cig-
arette, now three packs a day, she tells you. She
is a beautiful woman and tragic even before she
smiles. But the smile, with disconcerting gaps
between her teeth, is heartbreaking. It is there
and not there, more a wish than a smile.
“And what did . -. what was your husband’s
name?”
“Robie.”
“Robie?”
“Robie, yuh.”
“How do you spell that?”
“R.o-b-i-e.” She coughs. “I get nervous just
talking about that.” She coughs again, apolo-
getically. “I’ve SOrt of had a cold the last few
days too.”
7’
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Resyonses to Comments by J. E. Chappell
si The most important natural resource of the area is the unique tidal range and the Pittston
proposal will jeopardize this resource. There is no mention of tidal power as a resource
to be conserved. Not all of the maps are in agreement with the map on page 195 which
shows the compatibility of the refinery and Quoddy. Many of the maps contain inadequate
legends. Navigational iroblems are much more serious than the site adjustment problems.
if the tidal project comes to fruition, tanker transit to the refinery w uld require the
largest navigation lock in the world. There is no navigation lock that is presently in
operation that will accommodate VLCC’s. The cost of the lock and who will be required
to pay for it have not been determined. The refinery owners should be required to place
in trust an amount of money equal to the estimated cost of the lock and pay for all costs
above the cost of a smaller lock required for transit of other customers. The changes
in water level due to the refinery and its docks being located in the low pool of the proposed
tidal project have not been adequately considered.
Ri The map on page 195 of the DEIS delineates an alternative layout of the refinery in the
event the International Quoddy Tidal Project Is constructed. If and when Quoddy Tidal
Is built, this arrangement would be made available at that time. The various maps in
the report show the layout as presently planned and are not In conflict with the p. 195
layout. The Corps of Engineers Is also studying an All —American project as well.
See expanded text on p. 111—159 ff.
If and when the tidal project becomes feasible and authorized for construction,
navigation routes, locks and constraints will be considered. Pittston has been
informed of these constraints on their planned shipment of crude and finished
products.
S2 The report is very biased in its discussion of the navigational probelnis of directing
VLCC5 into Eastport. The analysis of the navigation goes contrary to much expert
opinion. Canada is the main opposition. The DEIS does not reflect the Maine DE P
skepticism shown in their order of 3/12/75 regarding oil spills, cleanup and containment.
The unfavorable opinions from Pittston’s point of view are relegated to the açpendices out
of carelessness or deliberate effort. The Maine DEP Board Order of 6/4/76 must be held
in suspect for reversing many of its stands. Even though Pittston has provided pier
locations in currents of less than 1 knot, approaches contain currents as high as 3.0
knots — currents In which oil spills cannot be safely handled. He disagrees with the state-
ment that the damages of oil spils would be greater at Machiasport than at Eastport
because the former is more exposed to the Bay of Fundy. The greater danger is fog
and in areas of greater wind, fog disperses. The maps illustrating the approaches to
Eastport are careless and are difficult to follow. Inside of this outliimd channel are
points less than 75 feet in depth. No oil spill simulation studies have been conducted
by Pittston or others in the area.
39—18
-------
R2 The Maine BEP actions (included in Appendix A of the FEIS, Vol. III)
must be complied with as well as any permit conditions of the EPA.
The technology for containment and recovery of spilled oil is continual—
ly being improved. For example, studies performed by B.A. Poison and
C. Johnson of Ultrasystems Inc. and presented at the March 1977 Oil
Spill Conference sponsored by the EPA, USCG and API demonstrated that
a specific streamlined oil boom is capable of retaining and recovering
oil spills in currents up to 6 knots. However this system performs
optimally in wave conditions under 1 foot. Also, this oil boom is a
research prototype and is not yet available commercially.
Vol. II of the PEIS, page III—3i, ff explains the channel that is pro-
posed for use by Pittston. A survey will be performed to verify
that the proposed channel is 75 feet deep throughout.
See FEIS, Vol. II, p. Vl—29ff, Oil Spill Effects.
S3 No details as to the nature of Pittston guarantee that 200 of the 300
jobs will come from the Washington County workforce. If the people
knew of the incompatibility of the refinery and tidal power, the refinery
would be voted down.
R3 It is to Pittston’s advantage to recruit heavily from Washington County
for their workforce because in doing so it will minimize the need to
bring new people and their families into the area. Pittston will -
provide job training. This will reduce the demands on housing, public
facilities, etc. It has been shown that if and when the Quoddy Tidal
Project is constructed, it will be compatible with the refinery. Also
see FEIS, Vol. II, p. X—2 and X—3.
S4 The character of the Pittston Company is not a subject of discussion ann
should be included. In many other places subjects are treated very
casually and numerous minor errors and Inconsistencies abound. EPA and
the COE have done a poor job of showing concern for envIronment ü values
The EIS makes a clear preference for private profits in the energy field
as opposed to public interest. In general, the EIS is totally unimaginative
in the manner of looking for new answers to energy problems.
R4 Comments noted.
39—19
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14.010 Hulman Street
Terre Haute, Indiana I ..7803
November 22, 1976
Mr. John 3. MeGlennon, Regional Administrator
Region 1, U.S. nvirorniiental Protection Agency
Boston, Massachusetts 02203
Dear I ir. NcGlennon:
I wish to express my aDpreciation for &A’s consideration in forwarding
to me the 1½—inches of documentation concerning Pittston’ Eastport
proposal. Since I an neither oceanographer nor engineer, it is
impossible for me to comment effectively on much of the content, but
I value the documents highly, and I should like to make a few remarks
about them.
They confirm my apprehensions about and onposition to Pittston’s
proposal. They make it clear that, no matter what efforts are made
to keep pollution to the minimum, it is going to occur regularly,
in the event of accident may do so on a disastrous scale (EIS, 308 ff.,
3S9 ff.), and will almost certainly destroy the fishing industry now
extant--this last at a time when the U.S. and others are finally
taking action to preserve the industry. A number of passages suggest
that EPA staff comprehend the extreme thange which the refinery wou]ñ
impose uron the area. Several references to the Passamaquoddy Tidal
Power project suggest that EPA is well aware of an alternate use for
the tides near Eastport which, now that world oil supplies are
dwindling, may be more productive for the long term.
When I wrote EPA early last June, one of the first issues I raised
was the negative position of the Canadian Government, through whose
waters carriers must pass to reach the proposed refinery site. I
raise the point again, although I realize EPA ’s peculiar position of
ignoring the issue is not of its own devising. I would point out,
however, that reference is made (EIS, 237) to possible use of
Canadian pilots and elsewhere to possible erection of navigational
aids on Canadian territory. The point retn&ns a critical one.
An issue new to me is that of continuing high noise-levels. When
the U.S. Navy constructed its short-wave p&dio—station at Cutler,
the noise was indeed overwhelming; after two years, however, the
noise ceased, and the tt almo st pristine” condition described for
Eastport (EIS, 2145) was restored. i PA holds out no such prospect
in connection with Pittston’s proposal, however: TtThus, while
construction noise will indeed be an impact on the community, it
will not be as severe as the noise impact resulting from the 214
hour per day operation of the completed refinery.” (ElS, 3L 0-3L ..l)
Similarly, one can hardly draw solace from the statement ( SS, 29)
that emission odors will hardly be noticed in comparison with that
put out by canneries in the area: no one has ever suggested that
toxicity might be involved with the latter, and there seems considerable
question about the safety of the refinery’s emissions, e.g. pOtential
40—1
-------
-2
production of acidic fogs (EIS ,29; E IS, 330—331). I find highly
disturbing statements that ‘more data is necessary and that
“the high incidence of fbg in the astport area Lone of the objective
statements whose accuracy I know from personal experionce/...indicate/ 3 /
a potential for the formation of acid mists and other sulfate compoun ,”
Environmental organizations have frequently voiced the view that in
too many instances the government has chosen to rely on the human
guinea pig for test purposes; I must conclude that this is another
such instance.
I read that required simulated trials by Pittston are to be concluded
by December, 1976, and have, of course, no way of knowing at this time
what the outcome of those trials may be/may have been nor of precisely
how they were conducted nor what non-Pittston observers may have been
present. I note that page 221 of the EIS describes the passage from
East Quoddy Light to berthing in Broad Cove as “straight,” in presumed
contrast to the course at Nilford Haven which involves a 60-degree
turn. While quite ready to grant that the turning-area in Great
Britain is more restricted, I fail to see how anyone could call passage
between Estes Head/Treat Island and continued passage between Shackford
Head/Seward Neck a “straight” course.
With regard to studies of alternate sites, I cannot accept the evalua-
tion of any wholly-owned subsidiary of Pittston (EIS, 273), and I
dispute an assessment ‘which describes the Eastport area as having an
induatpja1/com eroja1 orientation (thus implying an indifference to
environmental/natural resource concerns) and no tourist, recreational,
or summer residential development to endanger (ElS, 273). The economy
of the area has àurvived, marginally, through a mixture of small
agricultupe and lumbering on both large and small scales, fishing and
fish-processing, and tourism and summer-residOnce. Harvest and
preparation of commercial timber and pulp remain a major source of
income, and their value shows every sign of increasing. Harvesting
the coastal waters is still vital to the area and with proper attention
should become even more so; I assume i PA is aware of aquaculture projects
under way both at Sebayick (the nearby Indian reservation) and at the
institute maintained on Cobscook Bay bythe University of Maine and
Sussex University of Massachusetts). Cobscook is an ideal location
for such developments, and they can only be threatened by Pittston.
Ship-building is beginning to make a modest comeback. Tourism has
grown steadily throughout my lifetime; to say, as Pittston does and
EPA appears ready to believe, that there is no tourist traffic to
endanger is simply not true. The State of Maine has purchased and
plans to develop a 100-acre State park on Passamaquoddy at Gleason’s
Cove. There are many summer residents, most of whom have neither funds
nor desire to establish a presence such as one finds around Mount
Desert or Blue Hill; most of them would be delighted to see non-
polluting industry brought into a part of the country for which they
deeply care and whose values they, like most year-round residents,
wish to preserve.
Finally, I should like to point out that it has taken dogged, underpaid
effort from private enVironmental groups to achieve virtually all of
the controls now in existence . I do not think I exagc’erate, We would
not have such safeguards as we now possess without the lobbt? ’ing and
40-2
-------
—3
legal action of the 1 nviro ontal Defense Fund, the Natn j l Resources
Defense Council, Friends of the Earth, I ivironmental Action, the
Coalition of American Rivers, the Union of Concerned Scientists, etc.,
etc. I am deeply grateful for the support and action of legis1ato
and agency staff who have worked with these groups and attempted to
enforce regulations. Nevertholess, it remains true that (so far as I
know) it has been in every instance the efforts of a few organizat ens
and citizens which have first brought to rublic attention matters of
grave potential hazard--a brief list of such instances is attached.
What this all adds up to, in my view, is failure by the Federal
authorities to establish goals, safeguards, and guidelines for our
energy nroduction and conservation of resources. I realize that these
are problems exceeding the authority of Region I of A; but the
general delinquency justifies fundamental doubt as to the wisdom of
even temporary approval for Pitaton’s proposal. In this context, while
one may perhaps intuit an extianation of EPA’s admittance of a
proposal which violates its own recoinniendation for the siting of
oil-port facilities in New i igland (i JS, 28 ) and I lIT’s recommendation
for the use of inonobuoys (EIS, 286), it remains impossible to regard
this violation/exce”tion as legitimate.
Last of all, I must find unacceptable the perhaps well-intended but
thoroughly disingenuous statement that iPA will not attempt to judge
what is best for Eastrort and that the community itself must decide
(i Is, 3 9). The people in the area who have time and energy to try
to think about the matter have expressed themselves in a poll taken by
the local newspaper, The Quoddy Tides , and they voted, to the best of
my recollection, two to one against Pittston--I am writing to the
editor, Mrs. Winifred French, requesting her to send you the results
of that poll. Nobody has yet suggested that there should be a refer—
enduin, and most people in Washington County work too hard to spend
as much time as I have in ploughing through the IS. A great many of
them understand well the unique character of the resources in their
environment, but their government has significantly failed to educate
them about the whole environmental question; such information as they
have comes largel-” from the organizations mentioned and from special
Programs in the comr ercial news media.
At best, approval of Pittston’s proposal will mean a few years of
intensive, polluting activity in the Eastport area with considerable
short—term impact, both positive and negative. This : eriod will be
succeeded by a few years more of even more dangerous operation. The
refinery and its resultant pollution will remain in situ for decades
beyond the point where any economic benefit for Eastport or Washington
County can be expected.
I hope with all my heart that 1 FA will render a negative jud nent on
Pittston’s nrorosal. Thank you fbr sending th• documents and for
considering what I h ive written.
Yours sincerely,
Copies to: §enator Muskie - A
Senator Hathaway (. i ’ t ’i1It
Rep. Cohen / (Mrs. R.G. Wolfe)
Mrs. French
40-3
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-Li.
As examples of the correctness of vision applied by sundry envirornn nt
groups, one may cite the following:
1. Use of fluoro-carbons in aerosol-sprays, first questioned by siith
groups throe to four years ago and made a jest by the producing
industries; studied by AAAS with subsequent warning; now very
largely phased out, in part voluntarily by industry (a result, no
doubt, of railing sales--the American public is not nearly so
stupid as the bureaucra•y seems to think) and recently via FDA
rulings.
2. fforts put forth for years by these groups for adequate testing
and control of toxic substances. Following Kenone, Reserve Nin ng
Dicidriri, the PCB and PBB disasters, we have now made a start.
3. &‘forts on noise-abatement at airrort sites, very recently ruled
upon by the DOT.
of adequate controls
ti.. Dogged pursuit/for effluent emission into our rivers, e.g., the
Hudson where commercial fishing has now been banned.
. Perhaps the most glaring example of them all, the refusal of
industry and government to face up to the issue of radioactive
wastes produced by the commercial production of nuclear power,
a technology of the future which is already obsolete(to quote a
wise man).
6. Current attempts, so far unavailing, for adequate control/planning
in connection with strip-mining Western coal, liquefaction, and
gasification thereof. I would classify the treatment thus far
accorded Pittston’s proposal with that furnished proposals in this
area.
Does this list not suggest anything to the minds in charge of EPAt
40—4
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Responses to Conuuentsby R.G. Wolfe
_ i Chronic afl(I cv’ntual disaslerous oil discharges will ruin the fishing industry at a
time when efforts arc being made to preserve it.
Ri Sec FEIS Vol. 11 p. VI—28 ff.
32 EPA is aware of Quoddy and the long term potential vs. short term oil.
The refinery and any tidal project are compatible. See FEIS vol. II p tII.159.Other
Federal Actions In the Area.
S3 The Canadian issues remain critical.
! . Comment noted. See p. X—49.
S4 Noise levels will increase.
M Comment noted.
Air emissions are hazardous to human health. The emissions and fog will produce
acid fogs and mlst8.
R5- See FEIS Vo . II, p.-’VI’-18, expanded aection on acid rainfall.
s The passage between Estes Head/Treat island and continued passage between Shack—
ford head/Seward’s Neck Is not a straight course.
R6 The majority of the transit through Ilead Harbor Passage and Friar Roads is a straight
course, and at the part of the course mentioned, the tanker is beginning its berthing
procedures, assisted by tugs.
37 We cannot accept the evaluation of any wholly owned subsidiary of Pittston
regarding alternative sites, and the statement that Eastport has an industrial!
commercial orientation and no tourist or recreational development.
R7 Co ent noted.
40—5
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S8 Aquaculture projects of the Quoddy Indians may be threatened by Pittston.
RB See FEIS, Vol II, p. 111—159.
S9 The tourism, fishlng,lumberindustriesshow every Indication of increasing and the
State of Maine plans to develop a park at Gleason’s Cove.
Comment noted.
sio Environmental groups have achieved virtually all of the controls now in existence
through dogged efforts.
! 2. Comment noted.
Si]. Finds fault with EPA unwillingncss to judge what is best for Eastport.
pjj Comment noted.
512 Approval of the Pittston proposal will at best result in considerable short term Impact-
followed by more years of dangerous operation. It will all culminate in little or no
economic benefit for Eastpórt or Washington County.
Render a negative judgement on the Pittston proposal.
fl Comment noted.
40—6
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PHiLIP S. MAThW$
, ‘ ;,4
O&Jj V ) “ , JL Cw
h
4 U4± fl i
Oi c . pWy Wf *
athi 4\*he p z.
41—1
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The November 12 issue of the Quoddy Tides contained a statement
attributed to John A. S. McGlerman, an EPA administrator. The
statement was intended as a summary of the main points contained
in the draft EIS on the Pittston Oil Refinery. Mr. McGlennon
mentioned three “beneficial iinpacts” and five or so “adverse effects”
of the refinery. Two aspects of this breakdown should not go unchallenged.
The first of these is the third “beneficial impact” mentioned
in the article. It reads, “more assurance of a co itinued petr 1eum
supply, reducing the vulnerability of the nation to another embargo.”
A laudable objective and one with which it would be difficult to
take issue without being branded unpatriotic. However, this statement
appears at best exaggerated, at worst untruthful. A continued
supply of pebroleum does not depend on our capacity to refine
it depends on our abilit to find it • Likewise, we do not import
oil from the Arabs because we are unable to refine our own oil) but
because we don’t have a sufficient supply it.
A major justification for oil price increase 3 in this country was the
need of the major oil companies for capital to conduct the costly
search for more petroleum. Company profits have increased; and)
if the resu1t is the discovery of more oil than we have the capacity
to refine, refineries wifl be constructed to meet that need • Just
as the construction of a sardine factory in Eastport would not result
in more sardines, the construction of a -refinery will not result in ç
an increase in domestic oil supplies.
The second criticism involves an addition ’ad- rerse efrect” whidh has
received scant attention. Presently, Eastport’s shaky economy rests
on the fishing industry and a small to medium size tourist industry.
Despite ludicrous claims to the contrary, these pursuits are incompatible
with an oil refinery. Therefore, an oil refinery will result in a small
community dependent on a large corporation for its economic livliehood.
The boom and bust cycle occasioned by the growth of the sardine
industry earlier this century will occur again with possibly greater
consequences. These consequences are complex and varied. The
best available estimate of the known supplies of oil may make the refinery
an anachronism in a very few decades, perhaps only two or three.
The decline of oil as a prime ener r source wifl be accompanied by
the economic decline of Eastport; a decline which may not leave
-------
I’ Eastport with the character ai natural beauty it now has.
However one. feels about the refinery, everyone should desire to
embark on this venture with a realistic view of it’s positive arid
negative effects. I happen to fee], the economic justification for
the refinery is one of its major dangers. It seems that many
Eastportere, perhaps a majority, fee], the same way. The mislead
statements that appeared in the Quoddy Tides promote a false s se
of security and seem more geared to persuade the doubtful “
inform the concerned • I hope the EPA has n’t• become an u’ com cicns
partner in an attempt to weaken the rational voice of di sent, whether
on this side of the border or the other.
Philip S. Mathews
41-3
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Responses to Oonments by P. S. Mathews
Mr. McG1ennon’s statement, “more assurance of a continued petroleum supply,
reducing the vulnerability of the nation to another embargo,” is exaggerated
and untruthful.
See FEIS Vol. 11 p. IV—2. Security of Supply. . . product Inventories plus crude
stocks in storage and afloat mean that a typical East Coast refinery has 65—70 days of
assured supply.
S2 A major justification for oil price increase in this country was the need of the major
oil companies for capital to conduct the costly search for more petroleum. Company
profits have increased; and, if the result is the discovery of more oil than we have the
capacity to refine, refineries will be constructed to meet that need. Just as the con-
struction of a sardine factory In Eastport would not result in more sardines, the con-
struction of a refinery will not result in an increase in domestic oil su lies.
R2 The d m ind for petroleum products far exceeds the present domestic production.
Therefore, we mist rely on foreign sources for our supply of crude and products.
It is less expensive to import crude and refine it in the U.S. than to import
products.
S3 The fishing and tourist industry are incompatible with an oil refinery. The refinery will
result in a small community dependent upon a large corporation for its economic liveli-
hood. it will result in a boom-bust cycle. The supply of oil will decline in 2—3 decades
and leave a possible despoiled Eastport behind. The economic justification for the refinery
is one of its major dangers and I hope that EPA has not become an unconscious partner in
this attempt to weaken the rational voice of dissent.
Coninent noted. See FEIS, Vol. II, p. VI—4ff, Soclo—Economic Impact; Vol. II,
p. tV—if f, Need for the Project.
41—4
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DEC $7
Winterport, Maine
November 30, 1976
#Me. 0022420
US EPA
Region 1
Enforcement Division — Permits Branch
John F. Kennedy Federal Building
Boston, MASS 02203
Gentlemen:
We are writing you concerning the p’r*pped Pittston refinery
at Eastport, Maine, since it will be Impossible for us to appear
at the December 3 hearing at Eastport, Our opposition to this
project is total for all reasons propoun4ed in the past, i.e.
dangers to the eco—system from oil spills, air pollution, etc.
However, in this letter we wish to make a few other observations.
It was only a few years ago that vç bought a nice, old home on
Washington St. in Eastport a distan ce f about 3/4 mile from the
proposed refinery site. We have been restoring it and plan to
move there next June. I happened to be there when the first of
the hearings were being conducted . nd I recall hearing about a
wonderful refinery in Stanlow, Englaid, — how modern, clean and
exemplary it was.
Last April we had the opportunity to spend almost a fortnight in
Cheshire, England. (We are both teachers and were making a study
of certain phases of the English School system. Mrs. Webb
teaches elementary school and I teach physics and am currently
head of the Science Department at Bucksport High School), While
in England, we had an opportunity to go to Stanlow and see this
highly praised (by Pittston) refinery. We soon learned from
medical people that the incidence of Chronic Bronchitis in this
area is the highest in all England. We also learned that within
the past 10 years the “eternal flame” has gone out twice. When
this occurs, moat all personnel and the area residents within
two miles of the refinery are evacuated as a precaution against
violent explosions until the flame has been rekindled (by
helicopter).
42—1
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DMa. 0022420 / November 30
If this two mile radius is considered to be a safe precautionary
measure, where would the residents of Eastport go in an emergency?
Probably 90% of the population will be living within one mile of
the refinery and there is only one exit highway off the island
within a few yards of the refinery.
Eastport is now completing construction of a new Elementary School
on top of Battery Hill, the highest point in Eastport which is
about 1/2 mile from the proposed refinery site. The High School
is located across the Street from this new building. In the
event of an explosion what of the safety of all Eastport children?
Eastport is also noted for its fogs, sometimes we are completely
blanketed for 2 weeks at a tine. Now it is a well known fact
that SO 2 is a toxic emission from the best of refineries and
when combined with water vapor produces a suiphurous acid. The
people of Eastport will be forced to live under this toxic
umbrella. We consider this a most serious health hazard.
The people of Eastport have not really been made aware of the
hazards a refinery will create for their community and never have
they been given an opportunity to express themselves by ballot
It is past time for the people to decide the issues when in
full possession of all facts.
We appreciate this opportunity to express ourselves here and
can only pray that sanity will prevail in making this vital
decision for Eastport and its surrounding communities, industry,
and our Canadian neighbors.
Sincerely yours,
/
( ‘‘ ( - 1 . -
j cv
cc Mr. Webb
42—2
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Re onae to Cqi nents ? A. & LWebb
Opposes the refinery for the reasons of potential oil spills, air pollution, etc.
R i Comment noted.
52 They visited the highly praised refinery (by Pittston) In Stanlow. Conversations with
medical people revealed that chronic bronchitis In the area is the highest in England.
Also the flare has gone out twice requiring the evacuation of the population within a two
mile radius. In the event of a similar emergency at Eastport, where would the people
go? There is only one exit highway off the Island and It is within a few yards of the
refinery.
The Stanlow refinery was never made a part of any formal Pittston presentation with
respect to operational comparisons. Emissions from the refinery will comply with
Federal and State Air Quality standards designed to protect human health and welfare.
the refinery flare Is equipped with an automatic ignition system and In the event the
pilot light is extinguished, an alarm would sound and the pilot light would be automatically
reignited. Conditions that would result in the use of the flare are infrequent and of one
to ten minutes duration.
Eastport is completing a new school one half mile from the refinery on the highest point
— in Eastport. What of the safety of the children if an explosion occurs?
See FEIS, Vol. II, p. IV—53 ff, X—9.
54 Eastport is noted for its fogs. SO 2 and water vii ]. create suiphurous acid
and this is a health hazard.
R4 See FEIS, Vol II, p. VI—78 ff.
S5 The people of Eastport have not been made aware of the hazards of a refinery
and have never been given an opportunity to express themselves by ballot.
R5 The subject of a local referendum is an entirely local government
matter and must be conducted on that level.
42—3
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.
INBURY SHORES ARTS AND NATURE CENTRE INC.
PHONE 52933se / P.O. BOX 100 / ST. ANDREWS I NEW B$UNSW)CK I CANADA I EOG 2X0
1st Decether, 1976.
Mr. John McCIez ion, Regional Adviser,
Protection Agency, Region 1.,
Jgbn Fitzgerald Kennedy Building,
Boston, Mali.,
U.S.A.
Dear Mr. McGl muon:
Sunbury Shores Arts and Nature Centre was founded in 1964 by the 1 ate
Mr.. Dorothy Bidlita of New York City who formulated our aims clearly: “It
attaapta to fuse and harmonize the views of the artist ‘with those, of the
sCientist. Thus, there is a stress on the aesthetic appreciatiod’ .of nature
and on the necessity of its wise use.”
In the twelve years since its inception $ bury Shores at St. Andrewe,
New Brtiiawick has proved itself to be a growing,. thriving insti’bition, drawing
•thdenta and enpporters from the United States and Canada. The courses that
we offer are catholic in variety, ranging from painting to marine and shore
life, to the flora and fauna of the district, arid to handcrafts.
Pase quoddy Bay and its surr Mngw are anong the nest beautiful
envirci ents on the eastern coast of North America, ideally sit*ated for
the purposes we serve, the sea aboomding in life, the shore. washed by the
great tides of the Bay of Fundy.
It is not for us to discuss the navigational prob Lens ‘wt1ich an oil
refinery at Eastport would face and would cause. We confiüe ouirael.ves to
the two , .*4n d*nger. that would *ffect us here, both abufldantly anthanticated
by disinterested scientifió opin 4 jn. We state then simply and blun.tly:
1. oil o1Intion
In s, 1974 an oil spill of s 500 barreLs (about 20,000 gallons)
ocoarred at the Ca sport Ter’.4n&l, 60 ails, away. With4 48 hour. crude
oil had reached the L’Etite Passage and one day Later was coating the shores
of the Bay wed the St. Croix estuary. In Jun., 1976 a umch weaU..r spill.
of 40 barrel.. at Canaport reached Deer Island within 48 houxs. Unsuccessful
att ptS were made to con 4 d clean up both these spills.
Eastport i i 14 miles from St. Andrew. at the south end of the one of
the three main cb nnels through which the sea races, raising and lowextng
the level of Pa.e c uoddy Bay by a. much as 24 feet with each tide. These
43—1
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2.
are among the most turbulent waters on Earth., and even a small spill of oil.
in the channels could not be contained. It would despoil our doorstep at
the next flood tide. Such spills are inevitable in the longer term. They
have always occurred and always will. A major oil spill would destroy Paasamaqu
Bay as we knov it altogether. So much for the sea and the shore.
2. Atmospheric Pollution
Under certain climatic conditions (e.g. of temperature inversion) any
winds from south-by-west to west-by-south — that is 900, one quarter of
the compass — would rain sulphuroue fumes on the Canadian and American
coasts of Passamaquoddy Bay. Winds from other directions would drive into
Maine, Cenpobello Island and Grand M n*n . If there La no d ger of this,
why plan smoke stacks 300 feet in height?
We quoted at the beginning: “...a stress on the aesthetic appreciation of
nature and on the necessity of its wise use,” The operation of an oil refinery
at Eaatport would not be that It would be an ecological enormity.
Yours sincerely,
David Walker,
President.
DW/tfm
Response: Comnents noted.
See PEtS, Vol. II, p. VI—29ff,
p. vI—l8ff.
43—2
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December 1, 1976
U. S. Envirnnmental Protection Agency
Permits Branch, Enforcement Division
John P Kennedy Federal Building
Boston, Massachusetts, 02203
RE: 1{E0022420
Dear Sirs:
I am writing to oppose the proposed oil refinery in Eastport.
My opposition is based on the following facts:
1. The quality of the air will be harmful to all living things.
(ie the 2 tons of sulfur dioxide spewing from the chimneys
HOURLY.) I have a farm and would be unable to purchase the
amount of lime necessary to combat the acids which will fall
on my land.
2. There is no way a VLCO could manage the waters through Head
Harbor during inclement weather safely .
3. The fogs are dense and frequent around here, much worse than
around Portland where the weather statistics are different
and from which the information was used in the reports.
4. The way of life here would be abolished. It Is a place wh re
people are still self-sufficient, independent and happy. Do
not be mislead by reports that It Is a depressed area. That is
laughed at by the people around here.
5. The health of the trees are weakened by salt sprays in bad
weather anyway, and would surely be further weakened by the
chemical residues spewing from the Pittston chimneys.
6. The 60 gallons of oil put into the bay every day would b&
devastating to the clams, periwinkles and other shellfish which
play a major rolp in our lives and enable us to live without
factories, oil, or any other governing order.
7. The Pittston Company has one of, If not the , worst environme .ita1
records in this country. They are not responsible people
(remember Buffalo Creek) and would only further the destruction
of land, people and all living things. Everyone has had
enough of that.
8. We have not been allowed to vote on this issue.
Listen —— T could go on and on, but I have written countless
letters, talked for hours about it, worried, lost sleep, made the
decision to move away if they decide to build it, and It is like
all 0! it has just dropped into a bottomless pit. Does it matter
what I say or do or what anybody says or does? Is the deal all
sewed up? Is it responsible for ANYONE to build an oil refinery
ANYWHERE? What happened to power from rivers, wood heat, and
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the old values which taught us to conserve? Is the btwtnees world
o greedy now that values have no place in the .r decisions? We
are desperate, tired of the Pittston people and wish the whole eae
would just go away.
As responsible people it is tiuie to say STOP to all these hustlers.
Believe me, if I have to move, I won’t forget that it was because
those assholes down in New York need their electric hair fluffers
and plastic Christmas trees.
Respectfully subtnitted,
Marian L. Rodgina.
Crow Neck Rd.
Prescott, Maine
44—2
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Responses to Comments by M. Hodgins
Si. The quality of air will be harmful and I will not be able to
purchase the amount of lime necessary to combat the acids which
will fall on my land.
Ri. All air emissions will comply with federal and state primary
and secondary standards that are designed to protect human
health and welfare. Also see FEIS, Vol. II, p. VI—78 (revised)
S2. There is no way a VLCC could manage the waters through Head
Harbor during inclement weather safely.
R2. Comment noted. See FEIS, Vol. II, p. IV—l6ff, Tanker Operation
and Marine Transport System.
S3. The fogs are dense and frequent around here, much worse than
around Portland where the weather statistics are different and
from which the information was used in the reports.
R3. Comment noted. See FEIS, Vol. II, p. III—153ff. Fog data in the
EIS deals with fogs in the Eastport area——Portland was utilized
only for wind data.
S4. The way of life here would be abolished. It is a place where
people are still self—sufficient, independent and happy. Do not
be misled by reports that it is a depressed area. That is laughed
at by the people around here.
R4. Comment noted.
S5. The health of the trees are weakened by salt sprays in bad weather
anyway, and would surely be further weakened by the chemical resi-
dues spewing from the Pittston chimneys.
R5. See revised text on acid mists. All emissions will comply with
Federal and State regulations which are set to protect human health
and welfare.
S6. The 60 gallons of oil put into the bay every day would be devasta-
ting to the clams, periwinkles, and other shellfish which play a
major role in our lives and enable us to live without factories,
oil, or any other governing order.
R6. The oil that will be put into Deep Cove will be in compliance with
all water quality standards. The effect of this oil will be negligi-
ble. The bacterial decomposition of the oil, compounded with the
flushing of the tides, should minimize the impact.
S7. The Pittston Company has one of the worst environmental records.
Everyone has had enough of the destruction of life and land.
Ri. Comment noted.
44—3
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S8. We have not been allowed to vote on this issue.
R,8. Voting on the refinery issue is an entirely local concern and
must be dealt with on that level.
44—4
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Z.
U.8. ENviror mental Protectior Agency
Region #1 Enforcement Diiieion
Permits Division
J.F.K. Federal Building
ston, Ma58. 02203
To Whom it May Concern,
lam concerned about the proposed oil refinery at Eaetport— I
have many unan8wored que8tiofls which I understand you people are obligated
to answer:
1. What gage will be used to determine the amount of oil spillage
at the docking site?
2. The allowable spillage of 86 barrels per year..do.s that
apply to the whole refinery, tft$ or to just one docking sit.?
3.’ What type of occurence would happen for production to cease at
the refinery?
4 What is th. definition of a protected harbor? ( It wasn’t protected
during the ground hog day gale)
5. What is the definition of mild visibility? Who is going to make
the determination of visibility?
6. What are the amount of fines that E.P.A wi].l impose upon the
refinery company if they violate any of your regulations?
Please list the specific fines for the specific violations ?
7. What. is your research on sea breeze fumigation? Wh&t controls
will Pitteon Oil Company provide?
8. What research have you done on acid mist? What controls will
Pitt a Oil Company provide?
9. Will the refinery smoke stacks have scrubbing devices?
Thank you. Please answer my questions.
Sincerely
44J 1 U
Christian Sunde
Tr.ecott, Maine 04652
45—1
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Response. to Conuents by C. Sunds
Si. What gauge will be used to determine the amount of oil spillage
at the docking site?
Ri. Any spill at the docking site will probably be contained. In
addition, terminal operators are required to report spills and
are subject to fines if they do not.
S2. The allowable spillage of 85 barrels per year. . .does that apply
to the whole refinery, or just to one docking site?
R2. The statement refers to the information on p. 306 of the DEIS:
can be concluded that the chronic spillage at Eastport
will probably be between 20—86 barrels per year.” No spillage
is “allowable” but that is what is likely to occur.
S3. Whay type of occurrence would happen for production to cease
at the refinery?
R3. Events which would cause the production to cease at the refinery
would be: complete lack of crude supply, repair of essential
process facilities, etc.
S4. What is the definition of a protected harbor?
R4. A harbor is considered protected when it is almost entirely
surrounded by land and protected from the open sea.
S5. What is the definition of mild visibility? Who will make this
determination?
1(5. The port operating manual to be prepared will specifiy this.
S6. What are the amounts of fines that will be imposed if Pittston
violates any of your regulations?
R6. Fines are set by the Coast Guard with EPA recommendations and
will vary with the size of the spills and the conditions under
which they occurred. Also see FEIS, Vol. II, p., X—5ff.
Fines and punitive measures imposed for violation of conditions
and regulations are evaluated on a case by case basis that may
result in monetary fines or possible revocation of permits.
Si. What is your research on sea breeze fumigation?
R7. Air modeling for this project has included the effects of sea
breeze fumigation. See Appendix C.
45—2
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S8. What reaearch was dons on acid mists?
R8. See FEIS, Vol. II, p. VI—78.
S9. Will, the refinery smokestacks have scrubbing devices?
R9. See FEIS, Vol. II, p. IV—6Off, p. X—37.
45—3
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NOV 3f /C
I
.,..
,1
bt) ‘ Y’
October 26, 1976
Joth A. S. McGlerinon, Director
Environmental Protection Agency
J. F. K. Federal Building
Boston, I ass.
Dear Director McGlennon,
I would like to requst some information regarding the proposed Pittston
refinery at Eastport. I would like a copy of the Enviro-Scjenc Inc.
environmental impact study done on the proposed refinery area, as well
as any information available about the effects of the proposed refinery
on the water supply for the city of Eastport. I have heard reports that
once complete, the refinery would require water in sufficient quanities
to lower the level of the source, Bowdoin’s lake, by approxirnateJy
six feet. Is there any truth in this rumor? Also, what renovations
of the decripit water transportation system now utilized has the company
proposed? Any additional information you feel might be pertinent to
the situation would be appreciated.
In conclusion, I would like to register my disapproval of the project
in its entir i?ty. To me, an incident which happened last summer is one
of the prime reasons to oppose the project. After the spill from the
Canad ’ ri refinery at St. John, the clean-up crew, replete with the newest
and most sophisticated methods of oil removal was called into t-he Eastport
area, since oil had been spotted drifting on the tide in the direction
of Eastport. I happened to be on the breakwater talking to a senior
member of the crew during this period, since a four day stretch of
extremely heavy fog precluded any removal activity, and the eritirc crew
was just hanging around cursing the weather. He told me that the crews
did indeed have the methods to clean-up the spill, but the fog obviated
using them, and in the event of similar weather conditions at the time
of a heavy spill from the Pittston refinery, the oil would be hcpelessly
dispersed by the time the clean-up crews could get into action. And
Pittston has admitted that periodic spills would be “unavoidable”.
Thank you very much for your time and trouble. Please send the requested
inforrnati.on tos
Scot Lehigh
Roberts Union Center
Colby College
Waterville, Maine 011.901
Sincerely yours,.
46—1
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4 14 1917
Respox se:
Comnenta noted.
Also see FEIS Vol. II,
January 11, 1976 pgs. X—ll, VI-20, and IV?-38 Ef .
John A. S. McGlenrion
Region I Administrator
Environmental Protection Agency
Dear Mr. McGlennon,
I recently wrote to you requesting an environmental impact study of
the Pittston Company’s proposed refinery for Eastport, since I was
doing a study of the effect the refinery would have on the Eastport
water supply. After examining this report, as well as the Enviro-Science
study prepared. by Mr. Irv Cohen’s firm, I come away dissatisfied.
Althouh both studies conclude that the present water supply can easily
handle t e increased demands that a refinery and the accompanying
population would 4ncur, one couldn’t truthfully say that one report
corroborates the other, for upon inspection it becomes obvious that
in fact one study has simply copied the other. Indeed, the two
studies contain almost all the same charts and maps, and even much
of the text is identical.
As an example, both reports contain the benign assertion that,
‘TtJhe existing water supply source is reported to have sufficient capacity
to serve the (efinery’s needs and the increased population of the
community.” Obviously this lacks any sort of mathematical or scientific:
proof. As a geologist preparing a report, I need to have the facts
and figures from which I can derive my own conclusions, not the
premasticated material which both studies present. Therefore, I would
be indebted to y!ou if you could send me the actual facts and figures
from which the EPA’s conclusions were derived.
Also, did the study take into account the fact that although there
is an abundance of water available in the winter and spring, even
under present circumstances the lake often drops five to ten feet
in the hot summer months? Can the lake supply the refinery even at
this time?
I would appreciate it very much if you could make all possible haste
in getting me these figures, for at present my study is somewhat
stalemated since I have no figures other than my own on such things
as capacity of the lake, average summer drop, gpa (gallons per minute)
provided by the watershed in the summer as compared to the winter,
etc.
I do appreciate you s t response to my previous requests.
Sincerely yours, -
‘r .- 4./ -- 7’ t
Scot Lehigh 303 Averiu.. Robert s Union Colby College Wate- . O
46—2
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1Z D C I S i S
Dallas Hodgins
Crow Neck
Trescott, Ye..0 45 52
U.S. Environmental Protection agency
Region I; Boston, assachusetts, 02203
Cent lernen:
My name is Dallas . Hodgins. I own a mile of shore line on
Straight Bay -- a part of the Cobscook system. I also manage the
fields of two adjoining farms which provide hay for my cattle and
sheep. We are a small family farm that is now self—sustaining after
five years of intensive effort. I wish to comment on the Draft
Environmental Impact Statement (DEIS) re ME0022 4 20 (EPA) and
25—7 —3 7 (Army Corps of Engineers).
I think this proposal is insane. Were it not for the fact
Pittston has already demonstrated their environrnental irresponsibility
in the mines and at Buffalo Creek; and various governrient agencies
have brought us disasters on the order of the Teton Dam fiasco,
one would tend to dismiss a proposal for an oil refinery at Eastport
as frivolous. Unfortunately, the deadly results of unchecked greed
and beaurocratic empire building has led us to confront this
irrationality as a possible real event.
I am shocked at the substance and auality of the DEIS. Volume I
ver es on being a misleading, unethical summary of Volumes II and III.
“r )uuie II, which I suspect, is mostly Pittston’s effort, is so devoid
01 s ho1arshlp and orderly research that it reminds one of a term
pape - submitted to a professor who is known to weigh his students’
efforts. Volume III struck me as an honest effort on the part of the
EPA staff to deal with some of the critical issues involved. The
accoustic work is a classical example of orderly research and
presentation. One could collate text and tables easily and under-
standably. The outstanding weakness of the whole DEIS is the lack
of fundamental data germane to Eastport and the process of refining
47—1
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—2—
Pittston proposes. The work of Volume III almost negated by
the lack of initial condition data.
It is certainly beyond my ability and your patience for me to
attempt to evaluate, in its entirety, the DEIS. I wish to say,
however, before going on to two specific areas, that it seems a
very shabby effort was made when one considers the magnitude of the
pro3ect —— both in impact and dollars. It hardly approaches satis-
fying the law, as outlined in the appendices.
I should like now to enter that labyrinth in Vo1uu e III
dealing with the emissions analysis:
(1) Why did not Pittston supply meteorological aata for
Eaetport? They have been located there for ten years.
(2) Why is there not a clear definitive description of the
hydro—skimming process? One would like to see the
proposed chemical engineering inputs, yields, and losses.
(3) Why is there not a chemical analysis of the proposed crude
oil to be used? I want to know what is in a typical gallon
of this Persian Gulf high sulfur crude:
a) How much sulfur? -
b) How much lead, mercury, and beryllium?
c) How many carcinogens?
(4) What sulfates, sulfides and oxides are formed and what
is their fate? With scrubbers where do the oxides
collect and how are they disposed?
(5) I’d Like to see the Gaussian Steady State equation and
the coefficient values that were used to model the
stack emissions.
(6) I’d like to know why numerical analysts weren’t hired to
model the actual conditions at Eastport, using the wind,
47—2
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—3—
rain, rog, snow, temperature, and terrain data that
actually occurs there.
The discussion in Volume III pertaining to emissions is based
on an urban model modified to approximate Eastport terrain using
Portland meteorological data. The sulfur dioxide and nitrogen oxide
inputs are, as far as I can ascertain, mere guesses (and these
guesses vary from volume to volume.) Why? Why is the computer
program (model) so insensitive to wind shear variances? Aparameter
as critical as wind in a fog plagued area seems not to affect the
program. Why7 Is it reasonable to hypothesize a constant 5 MPH
wind at the base of those stacks, as was done? Why didn’t the
EPA demand Pittston give them solid data?
I append a statement from the Bangor Daily News which says in
essence that the EPA has failed to come to grips with ambient air
quality standards in the first place. If this is, in fact, true -—
how can rational men then conclude from the above maligned computer
model that Pittston will not worsen the air quality in Eastport and
environs? In fact, I suspect this summer is the first time aujone
really Dt*iiT with the current air quality in Eastport -- a
very good insight into the integrity of this applicant.
The major plant —toxic pollutants are sulfur dioxide (SO 2 ),
fluorine (F), ozone (03), and per oxyacetyal nitrate. Concentrations
of .25 parts per million (ppm) of SO 2 and .01 ppm of 03 over a
period of hours will injure plants. Sulfur dioxide is a relatively
short lived atmospheric pollutant because it is readily oxidized
to sulfur trioxide (SO 3 ) and finally to sulfuric acid mist and
sulfate particles. Ozone Is a photochemical oxidant. Photochemical
oxidants are the products of atmospheric reactions involving
hydrocarbons, oxides,of nitrogen, and sunlight.
47—3
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-4-
Now, for the month on July, 49 violations of the Federal
primary ozone standards were recorded (in Eastport), with a maximum
value recorded of .152 ppm, or almost twice the Federal Standard
(.08 ppm)” (Pg 158 Vol II).
EVERY HOUR Pittston plans to emit from their stacks 2 tons of
SO 2 and 4/5 of a ton of nitrogen oxides. (pg G—8, Vol. III).
“Despite the scarcity of reeearch findings, however, the
possibility of the interaction of SO 2 from the proposed Pittston
refinery with fog in the Sastport area and the possible resultant
formation of sulfuric acid mist and other sulfates is of concern
because of the possible human health effects related to sulfates.”
(pg 330 Vol. II).
“...the high incidence of fog in the Eastport area, as well as
the occurrences of 03 violations and signiftca it 302 emissions,
indicate a potential for the formation of acid mists and other
sulfate compounds.” (pg. 331, Vol II).
very ten days in June, July, and August the 2 tons of 302
and 4/5 tons of nitrogen oxides will go directly into a fog bank!
I would like to know why Pittston should be licensed to
expose us to this kind of a disaster. Are we do die for
capitalism as those in Thgland did in the sixties? Are so many of
us expendable, as sacrifices to corporate greed and irresponsibility?
The State of Maine ranks fourth in the United States in
incidents of lung diseases. The soil of Eaetport and the surrounding
area is now so acid from Northeast industrial air pollution it is
necessary to lime fields regularly and persistently to produce
minimum grass yields. I want to know If Pittston is going to be
liable for the medical problems of the people they will poison?
Will Pittston supply me and my colleagues lime for our fields?
47—4
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—5—
Does the government and Pittston have a plan to take care of the
acid baths we will inevitably suffer? I want to know before the fact
what the limits of my subsidy of this oil refinery are going to be.
Am I to offer my childrens’ lungs to this conglomerate to waste as
they did the people at Buffalo Creek?
Can the EPA, who knows better than any of us, that SO 2
concentrations in the air have n ot lessened appreciably over the
last six years, morally, ethically, and legally license a pollution
source of the magnitude of the Pittston high sulfur crude oil schenie
in an area already in violation of Federal Ozone levels? I can’t
believe this. I have this uneasy feeling that this insane plan
parallels the strategy used in the Vietnam War. Threaten X -- then
offer X. Everybody sighs with relief -- forgetting that any
part of X is immo* al, indecent, inhumane, and a damned sh k.
Having lapsed into the metaphysical —- I’d like to conclude this
cry in the wilderness with a few comments on the “receptivity of the
community.” I apologize to those of you that think, but in the end,
the political solutions usually are the ones that kill us.
The fact of the matter is that it is not known what the
ordinary people of Eaatport think about the refinery. A petition
to have a vote on the refinery with more signatures than the nurr er
of people that voted in the previous election was presented to the
Eastport city council... A Mr. Leighton who was president of the
Council and two of his colleagues took the position that as
elected representatives they would make the decisions. The vote
not to hold an advisory election was 3_2.1f. tAro councilmen for the
advisory vote had signed the petition. Subsequently, Leighton was
defeated for the Council ix an election that saw an anti-oil man
elected. Superficially, you might guess Eastport was against oil.
Leighton 1mmediately opened an office as Pittston agent and openly,
47—5
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—6—
for a ohange, conducted Pittston business.
The Governor of this State was elected on an anti-oil platform.
He subsequently changed positions; and, in the opinion of some,
seriously weakened the Maine Board of nvironmental Protection (BE?)
by his appointments.
Two state agencies -- the Department of Inland Game and.
Fisheries and one others filed suits via the State Attorney General
to set aside the Maine BEP conditional permits as unsound.
When you stir the muck, you find that the “people” have tried
to speak. We voted a bottle return bill in over the dire threats
of the business community. We’ll vote this oil refinery out if
given a chance. Why haven’t we had a vote? Why hasn’t Pittston
appealed to the people of Eastport to see if they (Pittston) are
welcome?
The business community is notoriously suspect when it comes
to leading us to Nirvana. Growth, expansion, and progress are
anachronisms. We must conserve, 4 We must protect high
protein yielding areas 4 4 We must have an energy policy. Hopefully,
Carter and his people will shut these oil people off. The
automobile, concrete, and oil people do not carry a sane vision
of the present or future.
Are we to rape the rest of our environment, and our children’s
future to power air conditioners to enable us to breath our own filth?
A
47—6
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Testimony Given by D. Hodgins at
Dec. 3, 1976, Public Hearing
MR. HODGINS: Thank you, that is Hodgins.
MR. McGLENNON: I am sorry.
MR. HODGINS: May I call you John?
MR. McGLENNQN; Of course.
MR: HODGINS? We are a]d so friendly, “Corky” and
“John”. (Laughter) I want to comment that as thi’s
hearing goes on, the advocates of this refinery, if
you could write down their ages and keep that in mind,
and then the people that are against the refinery.
Now, you will find the old people want the refinery
for their children, but you will find the children
don’t want the refinery. (Applause)
And I want to attack you a little bit in a friendly
way. I think this thing is insane. And the only
rational part of it is the fact that I know you people
brought us Buffalo Creek - not you, but Mr. Kaulakis
and his company. You people, the Army Corps of Engineers,
have brought us a drainage system in the Mississippi
that now threatens to erode the whole thing from
Minneapolis to. New Orleans. I am sorry if I seem
emotional, but we have been under this pressure for
almost ten years., six years steady, of whether we can
go on with our life in this county, and whether I can
47—7
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go on with my farm. I have a farm, we have devoted
ourselves to it, our resources, everything we have, and
there is no way to tell, whether I can farm it because
I don’t know if I can buy enough lime. If you are going
to clean the fishermen’s nets for them, I think that
Pittston should supply me with lime. I can’t grow grass
in a sulfur dioxide atmosphere or a nitrogen oxide
atmosphere.
Now, I don’t want to ramble on. but I have two points
to make. One, about the receptivity of this refinery
in this community. We would like to have a vote on
that. There was a man, a Pittston man. Leighton, in
this town, that was presented with a petition with
more people than had voted in the previous election.
This petition was for a referendum on oil, whether we
should have Pittston here or not. This was denied on
the basis that these were elected representatives and
they would make the decision. In the next election
this man was defeated. There is a message there.
Our Governor was elected in a race of three men on
the statement that he opposed oil. Shortly after that
time he changed his position. So what I am trying to
say is let the people in Eastport vote on this. The
Passamaquoddies have voted. They have been ignored,
but they voted against it. It would be very interesting
47—8
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to see what a vote would be in Eastport, and I think it
is well within the realm of reason.
The next thing I want to talk about - and I have to
throw in a joke - in the immortal words of Cokey”,
“Corky” Kaulakis - I don’t know if I should throw up
here or out in the hail-- (Laughter - applause) --
but I read your statements, I read Volume I, the
Executive Summary, which I couldn’t believe. I con-
sidered that a propaganda instrument. I read Volume
II, which got a little more involved. I got very
interested when I got to Volume II, and I waited with
baited breath for Volume III, at which time I got some
information, and I am aghast. I am aghast at the
difference between Volume II and Volume III, but I am
aghast at what is passing for research. I mean, if
you are going to take a $1.98 environmental report
from these companies - they are going to turn three or
four million dollars a day in this town, that is a
gross; a billion and a half a year, that is gross.
Now, specifically, I want to talk about the emissions
analysis, and the fact that there doesn’t seem to be
any data to support this program. Now, as I understand
it in the appendix, a model was-taken that was developed
by you people, an urban model for the stack emissions,
and it was modified to represent the terrain of Eastport.
And the data input, the meteorological data, was taken
47—9
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158.
from Portland, and little things like the sheer factor
or the wind factor in this 300-foot stack was taken
at a constant two and a half kilometers at the base
of the stack, which is five miles per hour. Well, I
couldn*t make heads or tails of that. I was hoping
the computer program was in there. And you know, I
know a little — it is terrible to appear here, you
know, I am not crazy or an egotist, but I know a little
bit about a Gaussian steady state equation and the co-
efficients that go into it, and I can’t really believe
that you can seriously propose to put in tons and
measure at 20 kilometers or 12 kilometers micrograms
or parts per million. Well, we will get into that
later, but the thing is that there is no data going
in there. That oil has certair Icfir ite chemical -
properties. I want to know where the mercury, where
the beryllium, and where the lead is going. Now, that
lead, mercury, and beryllium is there. Those sulfates,
sulfides, and nitric oxides are there. And t1 ere is
nowhere in there that they are coining out. Now, yøu
know the finished product and you know what is going
in: you must know where these things are.
47—10
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159.
To sum up this thing. I am sure you are interested
in finding that the oxidant level here, like in July,
it was exceeded 49 times. The federal standards for
oxidants in this area was exceeded 49 times in July
of this year. Now, do you really seriously propose
to put a nitrogen oxide source in this town under
those conditions? We are already suffering from the
whole east coast. How are we going to handle that?
What about our children? You know, it is beyond
comprehension. that this would be considered.
Well, I would like to just make a simple statement
and I will quit. But we have a way of life here, every-
body survives here, and people have for generations;
we fish, we log, and we work on farms. What all these
people are talking about is turning this into an
industrial area for progress and growth. Those are
anachronisms. We are hoping that Carter and the Carter
Administration is going to change that around, that you
will have an energy planning program, that we will go
to conservation, we don’t need increased capacity, that
we will protect these protein producing areas. For
instance, 20 percent of the Atlantic Salmon go up the
47 —11
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160.
Dennys River. 20 percent of the spawn go up the Derinys
River. You are going to wipe that out. If you wipe
out the clams and wipe this stuff out, what are you
going to eat? You can’t eat this oil. And it is going
to be gone in 20 years. Thank you. (Applause)
MR. STICKNEY: Mr. Hodgins, I would like to respond
in two ways, because I certainly can’t blame you for
being concerned, you have got a right to be concerned.
But the two things I would like to say is that, from
a practical matter, the areas around other rural
refineries — and all I am doing is reporting what I
have seen — are farmed, and as a matter of fact, in
some of the excess land on refinery grounds, they are
rented for farming activities. Now, all I am saying
is that goes on.
Secondly, you can’t imagine how hard our categorical
programs people worked, our air, noise, solid waste, to
prove that this thing would violate the standards. They
worked very hard to do that. They used very conservative
numbers all, the way through, and they did not accept
data on its face value, but checked every piece Qf data
back to its origin. And I believe that the conclusions
47—12
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161.
that are reached are supportable by the best technology
that is available right now. (Applause)
MR. HODGINS: I would like to read something. This
is from the Bangor Daily News, November 25, 1976. I
will skip the first part. “The 22 million dollars
spent on research was a very expensive learning process.
Subcommittee Chairman George E. Brown, Jr., Democrat of
California, told a news conference. It could have been
done more economically. We have to have better and
more accurate studies and know how to get them. Tech-
nical errors in measurement, unresolved problems in
statistical analysis, and inconsistency in data in the
1974 CHESS Monograph render it useless for determining
what preci’se levels of specific pollutants represent a
health hazard, the subcommittee reported.”
I mean, you are not infallible, you are human beings.
We are human beings. You are coming here and putting
something on people that they may not want. Just let
them vote on it, that’s all we ask, let us vote on it.
If we don’t want it, you know, if we don’t want Pittston,
sobeit. (Applause)
MR. McGLENNON: I think all the people of Eastport
47—13
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162.
know that there are three levels of approval that are
required before this refinery will be constructed, arid
one is the local one. And neither the state nor the
federal government are going to make that determination
for the local government, and the loéal government will
do it. in the mechanisms that are set up to make that
determination. And if this community under its normal
governmental processes approved the zoning and siting
of this facility, then it is up to the state and
federal government to carry out its legal responsi-
bilities.
47—14
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Responses to Comments by D. Hodgins
Si. Make a note of the ages of the people who are for and against
the refinery.
Ri. Comment noted.
S2. Pittston brought us Buffalo Creek and the OE have brought us the
Mississippi River system that threatens to erode from Minneapolis to
New Orleans. He has been under this pressure of not knowing if
he can continue to live in the county for the past six years. He
doesn’t know if he can continue to farm because he doesn’t know
if he can buy enough lime if the refinery is located. He can’t
grow grass in an SO 2 atmosphere. H 2 S04 mist may be formed from
the refinery emissions combining with fog.
R2. Comment noted.
Note: See FEIS, Vol. II, p. VF-78, Air Emissions.
S3. Let the people of Eastport vote on the refinery question.
R.3. Comment noted.
S4. The DEIS is a “dime store document” and isn ’t worth anything.
He wants to know where the mercury, lead, and beryllium are
going. Sulfates, sulfides and nitric oxides are there. The oxi-
dant standard was exceeded 49 times in July of 1976——how are
we going to handle that? Wb*t about our children?
R4. See FEIS, Vol. II, p. VI—62ff, Air Emissions. The air emissions
will be below standards set to protect human health and welfare.
55. Why was Portland wind data utilized instead of Eastport data?
R5. See FEIS, Vol. II, p. 111—113.
S6. Why is there not a clean, definitive description of the hydro—
skimming process?
R6. See FEIS, Vol. II, p. IV—48ff.
S7. Keep the area as it is, we don’t need an industrial way of life.
You are going to wipe out the dams and other resources——we can’t
eat oil and it will be gone in 20 years.
R7. Comment noted.
47—15
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Testimony Given by D. Dowley at
Dec. 3, 1976, Public Hearing
MR. DOWLEY: My name is David Dowley. I live in
Machiasport, and I am a member of the Quoddy B4y Fish
Co-op. and this summer I was a fish peddler. I have
a question for Mr. Kaulakis and I would like to address
this to Mr. Kaulakis.
I am deeply concerned about this project for one
basic reason, and that is that all responsible pre-
dictions about the future of oil as a major energy
resource for this planet earth would indicate that
by the year 2,000 oil would no longer be that major
source. Now. I am particularly concerned about this
because what we are asking in the Eastport and Wash—
ington County areas is that people that are now largely
self—reliant, self-sufficient, with a specific life-
style. are going to be asked to make a major change
and become members of an industrial society. What
has Pittston planned for the year 2,000 when oil will
no longer be available to be refined?
MR. McGLENNON: Mr. Dowley, since this hearing is
being conducted by the federal government, you can
address questions to us. or to Mr. Kaulakis through us,
48—1
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175.
and it is our responsibility as part of the Environ-
mental Impact Statement Process to satisfy ourselves,
if we think your question is a valid one, to the answers
to those questions as we write the final impact state-
ment. And that is the purpose of this hearing, to give
you an opportunity to raise questions that you don’t
think are adequately addressed in the draft impact
statement, and we will accept the questions. We don’t
necessari.ly have all the answers right here. But your
question is a legitimate one, and——
MR. DOWLEY: Let me just continue then without the
answer. But I think the impact would be more severe
in this particular part of the country than in another
area that is more industrialized because the people are
going to be asked to become dependent upon this highly
industrialized complex, make a radical change, and when
this oil is no longer available and Pittston walks away,
we are going to be left holding the bag. (Applause)
MR. DAVIS: Excuse me, sir, but you had called my
name before Mr. Dowley.
MR. McGLENNON: You are Mr. Davis?
MR. DAVIS: Right.
48—2
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176.
MR. McGLENNON: Can I just say one comment on Mr.
Dowley’s comment. One is that there are a variety of
projects for the extent to which oil is going to
continue to be available in large quantities for us
to use the way we use it. The oil companies contend
that we will continue to find and develop technology
to recover more quantities of oil than are now projected.
So it is hard to say whether by the year 2,000 there
will be any oil around for this refinery to refine.
Secondly, t e question of what happens to used oil
refineries, normally the cost of the metal and the
value of the material that goes into constructing a
refinery is recycleable. and to the extent that it can..
be recovered by the oil companies to be used elsewhere
or in other manufacturing processes, and it is economic
to do so, it tends to be used for that purpose.
48—3
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4g•• .4
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esti1nony given by Christian Rerter, Executive Director of the Natura]. Resources
council of Maine, at a joint hearing in Eastport,, Maine of the Environmental Pro-
tection Agency, Federal Aviation Agency, and the U. S. Army Corps of Engineers on
the proposed oil refinery and marine terminal of the Pittston Company — December 3,
1976.
My ma ine is Christian Herter. I am the Executive Director of the Natural Resources
C,uncil of Maine, whose purposes are to unite and coordinate efforts for the advancement
1
of natural resource conservation and to relate the economy of the State of Maine to its
natural resources by study, research and literary publication. The NRC has a current
membership of over 2500 individuals and over 125 affiliate organizations from around
the state.
As an organization extremely concerned with the wise use of natural resources and
with land use patterns along the coast of this state, we have reviewed the Draft
Environmental Impact Statement (DEIS) for the proposed issuance of Federal permits
to the Pittston Company for the construction of a 250,000 barrels per day oil
refinery and marine terminal. The NRC finds certain subj ct.. areas of the DEIS sufficient
in scope and discussion to adequately mn if from construction and maintenance
of such a facility, but is extremely disappointed that other such areas —. areas that
have been of continuing concern to the people of Maine — have been only partially
discussed, or simply not discussed at all, in this impact statement. We believe
that without detailed examination of these areas of concern, economic andenvironmental
data and their Implications, cannot be fully assessed in a decision—making process
that will determine the long range shape and life style of Washington County, its
Coastline and adj acent islands. Specific concerns include noncôm liance with the
National Environmental Policy Act (NEPA), crude oil and refined project transportation
Systems, and the lack. of data which would adequately predict the effects of oil
Spills on existing natural and other resources, and oil spill clean up continguency
Plans. I would like to discuss them individually.
49- 1
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First, Section 102(2)(D) of the National Environmental Policy Act states that Federal
Agencies shall “study, develop, and describe appropriate alternatives to recommended
courses of action in any proposal which involved unresolved conflicts concerning
alternative uses of available resources.” The Council on Environmental Quality (CEQ)
guidelines on the implementation of this section states consequently that “a rigorous
exploration of the enviromental impacts of all reasonable alternative actions, partjc
larly those that might enhance environmental quality or avoid some or all of the
adverse environmental effects is essential.”
The guidelines continue by saying that, “in each case, the analysis should be
sufficiently detailed to reveal the agency’s comparative evaluation of the environmental
benefits, costs and risks of the proposed action and each reasonable alternative.”
this light, the NRC believes that the DEIS does not address in any formal way the
components of the Board of Environi iental P tection’s Order regarding the refinery
which resulted from hearing’s on Pittston’s Site Locat.ion Application. This Order
reflects many environmental concerns of Maine people, and constitutes an alternative.
It, therefore, must be included under EPA in any discussion of the impacts of the
proposed project.
crude oil transport system described in the DEIS presupposes the use of 250,000
DWT tankers, when, in fact, the Board of Environmental Protection in its Order will
not allow ships greater than 150,000 DW to negotiate Head Harbor Passage, nor to
berth at the Shaékford Head Pier.
7
Assuming either classification, there is insufficient data on fog and sea curre s
- -s-
that directly pertain to Eastport as a site for an oil refinery and marine terminal
49—2
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for Very Large Crude Carriers (VLCC). Both fog and currents affect the navigability
of Head Harbor Passage, the docking abIlity of tankers, and the relibility of oil
spill clean up systems. The DEIS discusses the frequency of fog in the Eastport area,
but Joes not di rwrnsfrafe how it might affect the transport of crude or refined pro—
ducts, nor does it discuss the rapidity with which fog in the Eastport area can form .
A VLCC could be commited down Head Harbor Passage on its scheduled 132—minute trip
to the loading berth, while the fog could obscure visability within a matter of minutes
The Board of Environmental Protection In its Order has stated that at least on rrfle
of visibility must be maintained at all times, but this factor is not mentioned or
assessed in the DELa . Also, the DEIS does not mention any emergency navigation or
anchoring procedures in the appreciation of this possibility.
1so in the Board of Environmental Protection record during Site Location Hearings
Dr. Jerome Milgren, an Associate Professor of Ocean Engineering at the Massachusetts
II stitute of Technology, and one of the most qualified experts on oil spill control
hchnology in the country, has testified that oil spilled at the Shackford Head Berth
*rea cannot be contained by traditional booming methods in sea currents over 1 knot .
sea current data is especially important since the DEIS reports that the average
elocity at Shackford Head is 1.9 knots, with a maximum of 3 knots on an incoming
tide. Dr. Hf lgren, when asked to comment on the Pittston Company’s assertion that
— J--
booms would contain oil of currents of 1.75 knots, flatly disagreed . Nowhere in the
1 pact statement are oil spill containment plans more than lightly discussed, and
With no reflection of testimony before the Board of Environmental Protection regard—
Ing oil entrainment, nor the various current pressures on the tankers during the 24—
hour off loading period. As well, there is no mention in the draft statement of any
liquid sulfur containment plans, nor of what system will be available or able to
-.-
control debris in the oil spill clean up process.
49—3
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What, however, is most negligent is the failure of the DEIS to speak of anything but
the ost general terms of a major oil spills in Head Harbo Passage . It does not talk
of the fact that several major oil companies have in the past looked at Eastport as
a site for a refinery and yet all rejected it as being to dangerous. Nowhere does
the DEIS mention the testimony of Virgil Keith , a Naval Architect and Marine Engineering
expert who was brought before the Board of Environmental Protection in its Site
Location hearings as an impartial witness, who, when asked to evaluate the proposed
VLCC port at Shackford Head said that taking all factors into consideration, currents
being the most important, there was no more dangerous port in the world .
In light of this kind of testimony, the DEIS should certainly discuss the ultimate
navigability problems of both crude and refined product tankers, but there is simply
no discussion of this.
As to the major effects of a sizeabi.e oil spill, the DEIS notes that herring fishing,
ground fishing, and sheilfishing will suffer to varying degrees and that “birds in
the area could also be damaged by a major spill. ” How many must suffer irreplaceable
damage and be killed? What kinds of birds is the DEIS talking about and how many?
Specific information on marine avifauna should be presented including species
occurrence, and areas of significant use and specific numbers. These same factors
would apply to the effects on other marine organisms as well. For instance, what are
the differences of a major spill in Head Harbor Passage and its ultimate effect as
opposed to a major spill outside the channel.
The. description of the refining process is briefly discussed, but there is no dis-
cussion of the procedures or safety factors involved in loading refinery products
nf-n smaller vessels . How many refined product ships will negotiate the channel
- U
— I- —
49_4
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and what will they carry? How will this affect the traffic pattern of large crude
carriers? Will any need tug assistance or escort ? These questions seem acutely
germane, especially since the potential affects of a spill of refined products will
apparently be more harmful than the spill of crude, and must be answered if an
objective decision on the viability of this project is to be made.
In regard to the transport of crude or refined products in the channel or docking
areas, the draft statement also does not address vessel design and the safety
•factors of doubled—hulled tankers that have been stipulated by the Board of Environ-
mental Protection’s Order.
As to the discussion of alternatives of the proposed action, I have already mentioned
the need to treat the set of conditions placed on the Pittston Company by the Board
o Environmental Protection, and the implications, as one alternative. The NRC
believes that the monoinooring system has not h en given as much attention a _ it
deserves. The DEIS says that the utilization of a monomooring scheme would reduce
or eliminate dredging; eliminate vessel traffic close to shore, thus reduce the
potential of grounding; reduction of traffic density, thereby reducing collision
hazards; and by locating oil transfer stations further from shore areas, thus
reducing risks to sensative coastal ecology. However, if this system where used
there would be greater risk, according to the statement, of minor spills, more
frequent operation interruption, and more safety risks to personnel. There is,
though, no supporting data given in the DEIS for these disadvantages, and if this
alternative is to be ruled out, those assertions must be justifie4 As well, a
monomooring system would eliminate the physical incompatibility of the refinery project
with the potentional Passamaquoddy Tidal Power Project.
49—5
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The DEIS has called the Passamaquoddy Project one that is only “potential” rather
than “proposed.” However, by pursuing the construction of a refinery, the option
of power generation through an indigenous and renewable source has been eliminated.
Although the Passamaquoddy Project does have some seemingly major drawbacks, it is
impossible to weigh two projects of this significance without having a greater
understanding of Passamaquoddy as an alternative. Since Passamaquoddy would provide.
an apparent expansion of aquaculture opportunities for Washington County, this option
can certainly not be eliminated out of hand. Domestic energy projects whose operation
depends on an inexhaustible resource makes better sense than the need of this state or
country to develop additional capacity for the refinement of fossil fuel.
The Federal Energy Administration in the DEIS bases its “need for additional
refinery capacity” statement on three considerations. They cite the increased
demand despite conservation efforts, the economic benefits (primarily construction jobs
and proximity to markets), and national security. As a justification for this
proposal, they must be seriously questioned. First, demand will naturally increase
until the PEA forces us to exploit our own resources. To continue to rely on imported
crude is a step backwards. Second, a three—year injection of labor into Eastport
will almost certainly result in a boom—and—bust cycle, and surely an oil spill will
affect the Eastport fishery , and the jobs it supports, for many more than three boom
years. Also, Eastport couldn’t be further from the market place in terms of U. S.
based refineries. The major market on the East Coast is way south of Eastport.
Thirdly, the national security argument is ridiculous. No matter where a refinery is
in the United States, if it relies on imported oil and an embargo occurs, it will
have nothing but air to refine. Added to this, the Eastport location depends solely
4Q—’
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on the acceptance of Canada as to the allowable navigability of Canadian waters.
Canada, as yet, has done nothing but oppose this proposal, and if this opposition is
ever relinquished, is in a position at anytime to jeopardize transport of oil to the
refinery. It would seem that the Eastport location and the use of imported oil in—
creases risks, jeopardizes jobs and puts us at the mercy of forces we cannot control.
Another alternative to the proposed action would be the possible expansion of the
fishing industry and aquaculture practices within the area. The 200—mile limit
which will become effective in the Spring of 1977 will enhance the opportunities
of U. S. fishermen, especially off the New England coast. There is legislation, as
veil, that has been introduced before the U. S. Congress that would appropriate
monies to bolster Maine’s fishing fleet. The DEIS on the other hand states that
Eastport t Would not appear to be of value except as an oil port.” In light of
statements like this, Passainaquoddy Tidal Project and increased fishery potential
should certainly be discussed in greater detail.
I would like to direct my next remarks to information not sufficiently addressed
concerning the refinery site and its impact on the local communities. A total of
1.16 million cubic yards of material must be dredged from the tidal waters to provide
berthing facilities and that this material will be used in site. How will this be
used, and what affect will its placement have on erosion patterns?
Secondly, housing is said to be available in Eastport to accommodate those who
will gain permanent employment from the project. As well, Pittston plans to build
housing for workers during the construction phase of the project. Nowhere in the
impact statement is there an estimate of either the number of workers who will need
49—7
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housing, what kind of housing will be provided by Pittston. and wh r ’ that- h ng
will be located. Will housing be temporary for the construction work force and will
it be on site? What will the impact on the local solid waste disposal services,
and who will pay for the additional disposal? What is the gràwth life expectancy
, of the regional landfill at Edmund, especially in light of the hanging state regu1atjo
concerning solid waste disposal procedures?
As well, cost estimates of additional hospital personnel and facilities to Support a
large influx has not been made by the DEIS, nor are we sure who will pay for these.
Cost estimates on additional police are lacking; and the additional fire equipment
and personnel needed to cover the construction workers housing is not mentioned.
Certainly, an estimate of these costs on the local governments is essential, if they
are to fully evaluate the project.
The DEIS discusses a maximum of 225 high school students that may be brought to the
area during the construction phase of the project, but no supporting data was provided
for that number; nor was any approximation of new elementary school children given.
If Eastport and possibly Calais are to plan, more definite figures must be discussed.
The DEIS also does not discuss the additional costs to governments of sustafnfn ’ a
Harbor Master, and a pilot training program which will result from conditions in the
Board of Environmental Protection’s Order.
finally, the aesthetics of the proposed refinery have been only slightly mentioned,
and the aesthetic impact of this major construction in terms of other state and
regional planning programs has been avoided. Maine is currently in the process
49—8
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of developing a coastal plan under the Coastal Zone Management Act which may or may
not call for heavy industrialization such as this refinery in the Eastport area.
) ctThn 101(6) of the National Environmental Policy Act states that “it is...the
responsibility of the Federal Government to use all practicable means, consistent witl i
other essential considerations of national policy, to improve...Federal...prograins...
to the end that the Nation may...assure for all Americans...esthetically...pleasing
surroundings”; and to “preserve important...cultural and natural aspects of our
national heritage, and maintain, wherever possible, an environment which supports
diversity) and variety of individual choice.”
The Maine coast is, before all else, a place of incomparable beauty in the eyes of
the nation as a whole. That belief in the special blessing of Maine with natural
and man—made beauty is what brings people to it from all over the country, indeed
from all over the world. They will come more and more in the future, and not., only
as tourists, but for every kind of solid advantage of Maine’s life and economy. To
jeopardize this special heritage without fully discussing some of the vital points
that the NRC believes has been raised in these remarks, would be an unconscionable
act.
The NRC fully appreciates the opportunity to submit these comments.
49—9
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Responses to Comments by Council of Maine
Si. The DEIS violates the National Environmental Policy Act by
inadequately describing and evaluating alternative sites
and courses of action.
Ri. Comment noted. See FEIS, Vol. II, p. X—42ff.
S2. The NRC believe that the DEIS does not address in any formal
way the components of the Board of Environmental Protection’s
Order regarding the refinery which resulted from hearings on
Pittston’s Site Location Application. This Order reflects many
environmental concerns of Maine people, and constitutes an
alternative. It, therefore, must be included under NEPA in
any discussion of the impacts of the proposed project.
The crude oil transport system described in the DEIS pre-
supposes the use of 250,000 1 JT tankers, when, in fact, the
Board of Environmental Protection in its Order will not allow
ships greater than 150,000 IMT to negotiate Head Harbor Pasaage
nor to berth at the Shackford Head Pier.
R2. !ittston will comply with all decisions of the Maine BEP before
operatiOn of the refinery will begin.
S3. The DEIS does not provide sufficient information on the effects
of fog and currents on navigation, docking, reliability of oil
spill cleanup systems. Also left out were the rapidity of fog
formation in the Eastport area. The Board’s Order that at least
one mile of visibility must be maintained at all times, is not
mentioned.
R3. Pittston will comply with all decisions of the Maine BEP before
operation of the refinery will begin. It should be noted that
the U.S. Coast Guard will regulate the port and will control the
passage of tankers. Also see FEIS, Vol. II, p. X—26ff.
S4. Expert testimony has revealed that oil cannot be contained in
currents of 1.75 knots. The DEIS discussed only lightly oil spill
containment plans.
R4. Comment noted. See FEIS, Vol. II, p. IV—38 ff, Oil Spill Con—
tairunent and Recovery.
S5. There was no mention of liquid sulfur containment plans and its
effect in the event of a spill.
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R5. Elemental molten sulfur will be produced at the rate of 465
metric tons per day. It will be shipped to market in small
tankers of the 10,000—15,000 1 T class. Therefore, approxi-
mately one sulfur carrying tanker will transit Head Harbor
Passage every 21 days. In the event that molten sulfur would
enter the water, it would solidify into chunks and sink.
There would be no detrimental effects to the marine ecology
since elemental sulfur is insoluble and unreactive in water.
The spilled sulfur will be removed as soon as possible through
conventional dredging methods.
S6. What system will be available to control debris generated
from the oil spill cleanup process?
R6. Material and debris generated from the cleanup of an oil
spill will be disposed of in a State approved landfill.
S7. The DEIS speaks only in general terms of a major spill In
Head Harbor Passage.
R7. Comment noted. See FEIS, Vol. II, p. VI—38ff (revised).
S8. It does not talk of the fact that several major oil companies
have in the past looked at Eastport as a site for a refinery
and yet all rejected it as being too dangerous. Nowhere does
the DEIS mention the testimony of Virgil Keith, a Naval Archi-
tect and Marine Engineering expert who was brought before the
Board of Environmental Protection in its Site Location hearings
as an impartial witness, who, when asked to evaluate the pro-
posed VLCC port at Shackford Head said that taking all factors
into consideration, currents being the most important, there
was no more dangerous port in the world.
R8. The EPA is not concerned about past proposals but has evaluated
this project on its own merits.
S9. There is no discussion of navigability problem of crude and
refined product tankers.
R9. Comment noted. See FEIS, Vol. II, p. IV—l6ff, p. X—26ff.
SlO. As to the major effects of a sizable oil spiii, the DEIS notes
that herring fishing, ground fishing, and shellfishing will
suffer to varying degrees and that “birds in the area could
also be damaged by a major spill.” How many must suffer irre-
placeable damage and be killed? What kinds of birds is the
DEIS talking about and how many? Specific Information on
marine avifauna should be presented including species occur-
rence, and areas of significant use and specific numbers. These
49—li
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same factors would apply to the effects on other marine organ-
isms as veil. For instance, what are the differences of a ma-
jor spill in Head Harbor Passage and its ultimate effect, as
opposed to a major api11 outside the channel?
RiO. See FEIS, Vol. II, P. VI—29ff, Oil Spill Effects.
Sil. There is no discussion of the procedures or safety factors
involved in loading refinery products into smaller vessels.
How many refined product ships will negotiate the channel
and what will they carry?
RU. See FEIS, Vol. II, p. IV—35, Unloading/Loading Facilities;
p. Iv—46, Oil Storage and Movement System. An estimation of
the type of products to be shipped and the number of tankers
negotiating the channel per day is given in approximate terms
in the section of the FEIS mentioned above. Product type and
number-of shipments are dependent on a great number of influ-
encing factors. These include: Demand for particular products,
time of the year and availability of tanker size.
Sl2. The DEIS does not address vessel design and factors of
double—hulled tankers stipulated by Maine BE?.
R.12. Pittston must comply with decisions of the Maine BEP and
will do so before operation of the refinery is permitted.
S].3. The NRC does not believe that the monomooring system has
been given as much attention as it deserves. A monomooring
system would also eliminate: the physical incompatability
of the refinery project with the Passamaquoddy Tidal Power
Project. The project may also dninage aquaculture plans.
R]3. Comment noted. See FEIS, Vol. II, p. X—42, Alternatives;
p. 111—159, Other Federal Actions in the Area.
S14. The PEA justification of the refinery is based on increased
d wind in spite of conservation efforts, Increased jobs, and
national security. FEA is forcing us to exploit our resources
and oil will surely affect the Eastport fishing. Eastport
couldn’t be further from the marketplace of the East Coast.
These statements must be seriously questioned.
R14. Comment noted.
S15. The building of the refinery will create a boom—bust situation.
R15. Comment noted. See FEIS, Vol. II, p. VI—lff, Soda Economic
Impact.
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S16. No matter where a refinery is in the U.S., if it relies on
foreign oil and an embargo occurs, it will have nothing but
air to refine.
Rl6. Comment noted. It is a more desirable situation to refine
foreign oil than to purchase foreign products. With a refinery
on U.S. soil, product inventories plus crude stocks in storage
and afloat mean that a typical East Coast refinery has 65—70
days of assured supply——a supply that would not be available
for U.S. consumption if an embargo took place and the refinery
were located on foreign soil.
S17. The Eastport location depends solely on the acceptance of
Canada to permit VLCCs through Head Harbor Passage.
R17. Mr. Richard Vine, Assistant Secretary of State for Canadian
Affairs, in a letter to Mr. John McClennon of EPA, stated
that the Canadian issue of tanker passage was not an appropriate
topic of discussion for the EIS.
Sl8. Additional alternatives to the proposed project include aqua—
culture.
RiB. Aquaculture and the proposed refinery and marine terminal are
compatible and therefore, aquacuiture is not considered an al-
ternative to the action. See FEIS, Vol. II, p. 111—159.
S19. In light of the above statement, Passamaquoddy and increased
fishing potential should be discussed in greater detail.
R19. Comment noted.
S20. Nowhere in the DEIS does it state the estimate of the number
of workers who will need housing, what kind will be provided
by Pittston, and where it will be located. What will the impact
on local solid waste disposal services and who will pay for the
additional disposal? What is the growth life expectancy of the
regional landfill at Edmund in light of State regulations?
R20. See FEIS, Vol. II, p. VI—l4ff.
S21. Costs of the following are not evaluated: hospital personnel,
police and fire personnel and equipment, and estimates of the
costs to local governments.
R22. See FEIS, Vol. II, p. VI—l8ff.
S23. The DEIS discusses a maximum of 225 high school students that
may be brought to the area during the construction phase of
the project, but no supporting data was provided for that num-
ber; nor was any approximation of new elementary school children
given. If Eastport and possible Calais are to plan, more definite
figures must be discussed.
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R23. See PEtS, Vol. II, p. VI—22.
S24. The DEIS does not discuss the costs of sustaining a harbor—
master or the pilot training program and who will pay for it.
R24. Pittston has agreed to undertake the cost and responsibility
of the training program. The harbormaster will be paid through
taxes and under a U.S./Canadian authority or a State of Maine
authority. The exiéting harbor master is paid $300 per year from
city funds (Ev. Baxter).
S25. The aesthetics have only been given nominal treatment • Also
the aesthetic impact in terms t,f the CZM plan has not been
evaluated.
R25. From land, the visual impact will not be significant because
of the topography of Moose Island and the location of the
residential communities. The high ridge ground splits the
island basically into two parts, effeàtively isolating the
site on the westerly half from the Eastport community which
lies on the downward slope of the easterly half. Only the 300
foot stacks would be visible, and only from a few sections of
the town. The visual impact from the highway entering Moose
Island will be reduced by the 100 foot buffer zone of trees
between the refinery proper and the boundary fence line. Fur-
thermore, the principal structures will be 1,000 feet or more
away, and on a downward sightline. From most of Quoddy Village,
which lies on the far side of a 100 foot hill that faces the site,
the refinery will not be visible except for possibly the stacks.
The view from the Point Pleasant Indian Reservation in Perry
will be virtually obstructed by Quoddy Village.
From Campobello Island at the site of the Roosevelt Memorial,
the presence of the facility will not be very conspicuous,
partly because it is three miles away, and partly because
the terrain on Moose Island shuts out the view of many tanks -
and the lower half of the other structures. It will not be
visible from most of Campobello, and not at all from Deer
Island. From Lubec, more of the refinery will be visible, but
again across a substantial body of water nearly four miles across.
See FEIS, Vol. II, p. 111—166, Maine CZM Program.
S26. NEPA states that it is the responsibility of the Federal government
to support cultural aspects of our national heritage...and variety
of individual choice. The Maine coast is a place of Incomparable
beauty——many people come to enjoy these sites.
R26. Comment noted.
49—14
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Testimony Given by A. MacKay at
the Dec. 3, 1976, Public Rearing
MR. MacKAY: My name is Arthur MacKay. I am President
of Narine Research Associates, a consulting firm located
in Deer Island. I am representing 300 businessmen who
usually, when I see them, don’t look nearly as polished
as the businessmen from the State of Maine who have
been approaching the podium here. These are 300 fisher—
men who belong to the Bay of Fundy Weir Fishermen’s
Association.
The figure of 300 is an interesting one, if you will.
take note of the fact that I believe it is 300 jobs
that Pittston is talking about. We are talking here
about a direct numerical exchange, 300 jobs versus
300 jobs.
The report we have handed on to you we trust will
be tabled and written into the document that will come
from these proceedings. If so, we can proceed along
and avoid some of the information at the first.
Basically, the first page is a statement of the
Weir Fishermen’s Association’s stand on the Pittston
oil refinery. The Association opposes the refinery,
and the reasons for it are in brief stated on page
No. 1.
50—I
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Now, our understanding was that this was supposed
- searing to rr 1 &ke comments on the draft environ-
mental im act statc ont,. and so far I think that 99
percent of the time has been taken up with comments
on positions with regards to the Pittston oil refinery.
By the way, I am your first live, living Canadian,
which I think is important. We live just a few hundred
yards over that way--
MR. McGLENNON: We know that you are out there.
UNIDENTIFIED MAN: Mr. Chairman, I object.
MR. McGLENNON: Why?
UNIDENTIFIED MAN: As long as we are in the Canadian
issue——
MR. MacKAY: My understanding, Mr. Chairman, as I
read the information that came from your department,
it was that the boundary was not to be considered in
your deliberations.
MR. McGLENNON: That is correct. We are considering
the total environmental impact of this refinery, regard-
less of where it occurs.
MR. MacKAY: This gentleman s comment points out
something that I was afraid of, and that is that apparently
there is a tendency to be myopic in terms of developments
of this kind. Now, I can understand, I think the members
of the Bay of Fundy Weir Fishermen’s Association, whom
I represent, can understand the feelings of the business-
50—2
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men of this part of Maine. It certainly is understandable
that if the opportunity for economic development comes
along that indeed this is what should be done. However,
if you take a look at your nextdoor neighbors who live
a few hundred yards away, and indeed we do — you may
-eca11, if you know anything about history, that this
once was known as the Passarnaquoddy Bay Commuflity - one
of the great dangers that seems to be developing from
this Pittston proposal is that in fact there is going
to be a continuing development of international
antagonism on both sides of the border, a border which
once really didnet exist. There is no dotted lines.
out there. I have looked for them, and they just do&t
exist. So, Mr. Chairman, with your p rmission . I would
like to proceed and make comments on the draft Environ-
mental Impact Statement. So we have established that
we exist. I gather?
MR. McGLENNON: Yes.
MR. MacKAY: All right. The first thing that we must
- and this has come out in the draft Environmental
ir pact Statement — is that there is indeed a viable
fishery located within a few hundred yards of Eastport.
The statement has been made that there is a declinIng
fishery in Washington County. and the draft EIS quotes
figures for 1975 from Charlotte County alone, within
50—3
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the framework of the fin fishery, of $3,383,000— that
is Charlotte County alone - with an additional $1,905,000
in income coming largely from shellfish and groundfish,
things like clams, scallops, and so an. Now, this
represents to me, to my mind, a relatively viable
industry, a $5,00Ô,000 income that is going directly
to the fishermen. This does not include spinoff, it
has nothing to do with spinoff: it is $5,000,000 direct
that comes into Charlotte County. Those $5,000,000 are
being spent throughout Charlotte County, because there
are a large number, something over 2.000 fishermen
involved in the fishery located in a wide variety of
communities. There is a good spread in the spinoff
of this $5,000,000. And I will have some more comments
to make on this later.
Now, our contention is that because there is a well
developed fishery located within a few hundred yards -
of Eastport that this a:ca is i a highly pIucti’ ’
area within the framework of the Bay of Fundy. Now, I
have spent 14 years as a professional marine biologist
working out of Deer Island largely. I spent probably
an average of one dive a week subtidally, anywhere from
low water to 100 feet in depth, I have probably visited
several hundreds of subtidal sites over the last 14
years in this area, and untold shore sites. Now, throughout
50—4
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258.
this period of professional study within the framework
of the Head Harbor Passage area we have gathered a lot
of data. We have something like twelve massive ring-
binders filled with data that has been collected over
this 14—year period. Unfortunately, it is not all
available at this time. But what we have done within
the framework of this report is to try to summarize
some of this data that we have available to point out
to you that this is indeed a highly valuable and a
highly productive area which is highly fragile to
anything in the way of surface-borne oils.
One of the ways of measuring diversity is simply
by saying how many species are there within the frame-
work of the study area, and the reports that I have
seen, some of which were drawn largely from a rather
disasterous report put out by Envirosciences — in my
opinion a rather disasterous report - I was quite
happy to see in reviewing the Environmental Impact
Statement that you avoided printing some of the errors
that were in that particular report, and I thought that
the draft Environmental Impact Statement - I have read
a lot of them - I thought that the draft Environmental
50—5
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259.
Impact Statement was well documented, well written,
and well researched. However, it had that one major
drawback of stopping at the International Boundary;
it did not in fact take into account Canadian waters.
You had good documentation on physical oceanographic
parameters, you had good documentation on fish statis-
tics landings, however, you had nothing to say abo it
the productivity of the area. And that may be because
you couldn’t send your men over there to do the work,
I don’t know.
So what we would like to say is that this, we hope,
is the framework for a whole new section in the Environ-
mental Impact Statement which takes into account the
Canadian side of the border,
What you have done is looked largely at Moose Island,
which is effectively the same as looking at one tree
and making projections onto the forest. Moose Island
is in fact within the framework of the Passainaquoddy
Bay West—Isles area, a proverbial drop in the bucket;
it does not reflect the true character of the entire
area.
Now, the problem seems to be to take 14 years and
50—6
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260.
try to plug it into your heads in three minutes. Now,
one way of measuring diversities is in species nu.mber.
Your study indicated something like 200 families of
marine invertebrates occurring within the area. We
have compiled all the data from the Passamaquoddy Bay
area in terms of species number. These are located
on p ages 3, 4, 5, 6 and 7 for invertebrates; for
fishes, located on page 8 and 9; for marine mammals,
including baleen whales, toothed whales, seals, and
so on, on page 10; for marine algae, on page 1]. and
page 12.
Now, what is interesting here is that your records
show 200 families, of which 160-odd were identified
to specific level. If you will take a look at page
No. 12, you will see that in fact it has been documented
on the basis of the references that we have cited;
that there are 836 species of invertebrates occurring
within the Passamaquoddy Bay—West Isles area, 96 spe.cies
of fishes, 70 birds, 20 mammals, and 223 plants, for a
total species count of 1,245 different species. Now,
that is simply one indication, diversity is simply one
indication of the productivity of the area.
50—7
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261.
All right, what I am going to try to do in the next
minute is pack 14 years into your heads. Basically
what happens is that we have heard all about the
currents out here. That map over there I think shows
eight islands occurring between Deer Island and
Caxnpobello. There are in fact, if you will study a
chart, in excess of 40 islands in that particular
area. If you also look at the bathymetry of the area,
you will find that on the outside of Head Harbor
Passage the depths drop to over 300 feet on the
inside they go to well in excess of 200 feet. In
some cases the drop goes from several feet at low
water to depths of over 200 feet in a matter of a
few yards. Now, if you study the charts, you will
see that this is so. Indeed there is a wide and varied
topography vertically there.
The net effect of this is that the water coming
from the open bay passes through these channels, it
drops off, and you have a wide range of velocity of
currents. And then you have large areas where the
velocity drops of f very suddenly and drops down. What
this does, this creates a tremendous variety of niches,
50—8
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262.
ecological niches, places where different animals can
grow. And as a result, we find that we have within
this area something in the vicinity of 1,245 different
species because such a wide variety of habitats are
provided for these animals.
Now, that is one measure of it. It is simply one
measure of the productivity of the area. Now, it does
two things, because when this happens it means that
the nutrients coming from the open bay are mixed
throughout the total water column. All right, now,
if you have visited Head Harbor Passage, you are well
aware that there is a tremendous amount of turbulence,
upwellings, and so on. The net effect of this is that
it takes nutrients, which in the open bay are within
the light zone of the top of the water — the phyto-
plankton are produced there - it takes this material
and distributes it throughout the total water column,
that is, down to 300 feet.
Now, I have been to 100 feet out here, and believe
me, I have also been to 100 feet at Lorneville, and
there is a tremendous difference between the numbers
and diversity of animals that occur at these depths.
50—9
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263.
The reason is that the vertical mixing within these
waters insures that food gets to great depths and
allows for a greater production over a larger surface
area of plants and animals.
Now, the net result is that most of these things
are filter feeders which also produce plankton by
spewing larvae off into the water. As a result, we
have within this area one neat little pocket of very
high plankton production, and it accounts for all the
birds that you see, all the mammals that come in here,
and the fact that we have a large fishery. That is
basically the thing.
Now, if the rest of the Bay of Pundy had as many
species of animals, this would be of no consequence
whatsoever; the area would not be unique in terms of
productivity.
I have included two tables on page 13 which show
the occurrence of indicator species. Now, these are
species which occur at all of the sites that we visited
along the coast of New Brunswick, clear from St. John,
Grand Manan, Passarnaquoddy Bay, all through the Deer
Island area and indeed down through Cobscook Bay, and
50—10
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264.
it shows — what we have done here is chosen species
which could not be missed by a diver that means that
small species which you might miss would not be
included — only guaranteed animals that you would see
on a dive are included in here, and this is to eliminate
the bias from knowing one area better than another.
As you can see, Lorneville is very low, Grand Manan
is somewhat higher, and Deer Island comes out as being
the highest. That is in terms of subtidal benthic
organisms, invertebrates.
The second figure shows the difference between
Lorneville, the four bars on the left, and Clam Cove
on Deer Island and Bocabec Bay in Passainaquoddy Bay,
and I think you can see visually there is some con-
siderable difference. This, incidentally, is total
numbers of animals found within scientifically run
transects.
The other net effect of this peculiar hydrographic
situation is that we tend to protect endangered species,
but out here we have some very unique situations largely
where waters channel through shallow channels, the water
drops at high velocity - the water drops off to 200 and
50—11
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265.
some feet in a hurry, the velocity drops down like
that - as.a result, the planktonic organisms suspended
in the water drop down over the face of this ledge.
Now, in the Deer Island-Carnpobello archipelag ,
among the 40 islands there, there are some veritable
gardens of unique assemblages of marine invertebrates,
and these in themselves could be classified as an
endangered marine site. They are very small, they are
highly susceptible to pollution, and they have never
been identified. We have identified endangered species,
but we have never identified endangered ecological
assemblages.
O.K., I hope I have more or less got the idea across
that the area is highly productive, and the reason that
it is highly productive is because of the peculiar -
hydrographic circumstances that exist here, and I hope
that we have documented that it indeed is the case.
The main problem with regards to the Pittston refinery
is that it has the opportunity of fouling up what is
really a very delicate and very intricate food web
which exists out here, and this is illustrated in very
simplified form on page 16 and 17. Basically what
50—12
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266.
happens, of course, is that you have phytoplanktori,
the small plants that grow in the water, which are fed
upon by larger zooplankton, which are fed upon by the
herring, and so on and so on, up until man.
Now, the key to this whole thing and the problem
with oil is that we have one very unique biological
occurrence out here that is different from any of the
places these gentlemen have talked about. You can
talk about Mu-Haven and all the rest of them, but we
have one occurrence here - and this is exemplified in
a number of examples supplied by the Canadian Wildlife
Service and others — the fact that the fishery hinges
around one group of animals, the krille. Now, during
very good summer seasor s, if you happen to visit Head -
Harbor Passage, you can see this diagram on page 16
simply by stopping your boat. You will have no problem
finding birds. You look for a large ball of feeding
birds on the water, stop your boat in the middle of
that, you will then see a large red patch in the water which
is composed of Meganyctiphanes, Euphausid shrimp or
krille, and this is the foundation of the whole fishery
in this area. If you catch cod, they are stuffed with
50—13
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267.
Euphausid shrimp: if you catch herring, they are
stuffed with Euphausid shrimp: if you catch dogfish,
poflock, haddock, you name it. anything that comes
from this area when the fish are here is stuffed with
Euphausid shrimp. And this is during most years.
The problem is that this is one of the most unusual
areas on the east coast. In this particular area the
Euphausid surface swarm, and that is the key to the
whole thing. And we trust that you will take a close
look at this. I don’ t know whether you have ever seen
it or not: if you spend any time on the water, it is
second nature to you here. But those things are very
•delicate. You can lift them out of the water and they
are dead probably within a half a rriir.ute or a minute.
Other anirn 3s, ‘3U can pick them out - crabs will run
around on your floor for an hour and still not succumb,
but these things are extremely delicate animals and
I would ask you to inform yourself about their existence:
“The Fishes of the Gulf of Maine”, it is documented in
there and other places. That is the one key, that is
what will kill the fishery in the Bay of Fundy, along
with some other possibilities that we have documented.
50-14
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268.
Birds, for example, it has been estimated that there
has been at one time 500,000 Northern Phalaropes in
Head Harbor Passage at any one time. 500,000, that
is a half a million, which represents probably a large
percentage of the population. Now, these things are
feeding on these Euphausid shrimp and others.
The fact that these birds are present may seem like
nothing. You know, you kill a few birds, and believe
me, if there is an oil spill here in the summertime,
they are not——
MR. McGLENNON: Are you about ready to conclude, Mr.
MacKay?
MR. MacKAY: Pardon me?
MR. McGLENNON: Are you almost ready to conclude?
MR. MacKAY: I am right at the end.
MR. McGLENNON: We have about 70 more speakers.
(Applause)
MR. MacKAY: I would like to just make one last
point. There is a rating index which is normally used
in ecological studies where you take into account highly
valued factors in the environment around. There are
a series of maps there which I hope that you will study
50—15
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carefully. They indicate ratings on the basis of 14
years of data which has been collected, and I think
if you look at them carefully you will see that they
show that Head Harbor Passage is indeed the principal
area.
Thank you. (Applause)
MR. McGLENNON: Thank you, Mr. MacKay. I would
just say that this is a very scholarly and thorough
dissertation and it is precisely the kind of material
that we came here to roceivo, and I really appreciate
it.
50—16
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COMMENTS ON
EPA’S DRAFT ENVIRONMENTAL IMPACT STATEMENT
ON THE PROPOSED
PI1TSTON OIL REFINERY
AT EASTPORT, MAINE
U,
c
4
THE BAY OF FUNDY WEIR FISHERMEN’S ASSOCIATION IN(,
-------
COMMENTS ON
EPA’S DRAFT ENVIRONMENTAL IMPACT STATEMENT
ON THE PROPOSED
PITTSTON OIL REFINERY
AT EASTPORT, MAINE
PUek 1 .d at $ Pi Mc Hisring
U’
00 THE U.$. ENVIRONMENTAL PROTECTION AGENCY, REGION I
Mmarlsl Hi i Sthool
Ds smb.r 3, i ii
PREPARED BY: p,j’thur A. Mackay, Director
Marine R......_di Associates,
Lords Cove, Deer Island, NB.
FOR
THE BAY OF FUNDY WEIR FISHERMEN’S ASSOCIATION INC.
Ernest Wentworth, Pres. Hazen Mitth&I, Sec.-Trss.
. Andrew ,, N.B. Lord’s Cove, Deer island, Na.
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U i ThE BAY OF FUNDY WEIR FISHERMEN’S ASSOCIATION re.
presents approximately 300 fishermen operating Herring webs in the
Bay of Fundy. Members of the Association have viewed with alarm
and dlsus y the progression of events which seems, at least on the sur-
face, to be leading to the successful establishment of a Pittston oil re-
finery at Eastport, Maine. The objection of the Association was origin-
ally voiced at public hearings held at Eaatport In December, 1973. In a
twenty-page document, the Association detailed:
I. the economic importance of resource-based
Industries; particularly the fishery in the
Pasuamaquoddy Bay Area,
2. the importance of the fishery In terms of em-
ployment,
3. the current value of the fishery In terms of
capital Investment,
4. the harmful effects of an oil ,lll on the fish-
ery,
5. the delicate ecological nature of the marine
system in the Passamaquoddy Bay area and
the catastrophic collapse which, we believe,
will occur under the pressure of continued
or excessive pollution.
We believe that the establishment of an oil refinery, or for that mat-
ter any heavy Industry In the West Isles Area, Is counterproductive and
will result In:
I. a net loss In jobs throug i the elimination of
renewable resource-oriented industries Indud-
ing the fishery, tourism, education, and re-
search,
2. the elimination of an Important food producing
area.
3. the disruption of coastal residents with con-
sequent detrhnental.ocial and cultural dislo-
cation,
4. the reduction of air and water quality, and
5. the 1 ** of new types of fisheries which are
just now in the developmental stage.
In short, the refinery has the potential of exchanging several thousand
jobs for 300, a renewabk resource for a non-renewable resource, a clean
environment for a polluted environment, a pleasant rural way of life
for that of a quail-industrial center and last but most certainly not
least, a relatively co-operitive local international attitude for one of con-
tinuing conflict.
I
-------
The foregoing is a statement of bias. The Bay of Fundy Welt Fish-
ermen’s Association opposes the establishmern of a refinery at East.
port. The ii;embers of The Association do not wish to lose their live-
lihood or way of life because of this development and this is the basic
motivation for making this presentation. Nevertheless, this bias Is not
blind. Wc know also that principle food producing areas are vital to
the world as a whole and we also know that the Passamaquoddy Bay
Area is vital in this respect. If we failed in our first attempt to con-
vince you itiat this Is so, we will now make a second attempt Should
this fail, we will continue, in anyway possible, to work towards our
goal of protecting this area.
in reviewing the ‘draft Environmental impact Statement, we found
It to be well documented and well prepared. It suffers, however, from
one major short-coming.... it effectively stops at the international bound-
ary line, the dots of which can be seen on the water only a few hun-
dred yards offshore from Eastport; at Least when the weather is fine.
Uniortunately, there are no boundarle. In the ocean and a moving fish
can change nationality at will. Similarly, what we do to the water In
Canada will affect the citizens of coastal Maine. It has already happened.
In June, 1974, a spill at Saint John, NB. hit these shores as weLl as ours.
As Canadians we could hardly be proud of this event. As Americans,
we doubt that you would be proud of reciprocating. We are not neigh-
bours, we are members of the Passaniaquoddy Bay community. If we
sup, you feel It and vice verse and no one in New York or Toronto,
or Washington or Montreal, will care.
The fact that an extensive Canadian coastal area exists within one
mile of Easiport cannot be ignored. It Is like surveying a forest’ by ex-
amining one tree. In this case, detailed examinations of Moose Island
have been made and the adjacent Canadian marine areas have been giv-
en, in certain areas, only a cursory examination. In the hope that we
have convinced the board that adjacent Canadian waters must be con-
sidered, we are presenting here additional data, from the Canadian side,
which we feel should be Included In the final Environmental Impact
Statement and which, we feel, should mitigate against the construction
•of a refinery at Eastport.
I INDUSTRIAL DEVELOPMENT IN RELATION TO ThE PAS-
SAMAQIJODD V-WEST ISLES REGION. The present trend of Indust-
rial development has been correctly documented (Vol. Ii pp. 35). De-
velopments at Saint John-Lorneville and at Point Lepreau are as ill-
advised as the Easiport refinery devclopmenl and have resulted from
the absence of a coastal zone management program and lack of under-
standing, on the decision-making level, regarding the value and corn-
plexity of the marine system. While we object to these developments,
they differ considerably from the proposed Eastport refinery in that
the Eastport development Is located In the middle of one of two areas
of major productivity 1 on this coast, the West isles and Grand Manan
Because of their peculiar situations, these two areas have species diver-
sity and abundance of tremendous magnitude and, indeed, can be, to-
gether with the Suer island Area in Nova Scotia, viewed as the “nurseries”
of the Bay of Fundy. Should any one of these areas be seriously affect-
ed, the fishery in the Bay of Fundy as a whole will be seriously affected.
iould the Passamaquoddy Bay-West Isles area be subjected to daily
pollution and occasional large oil spilisthere is little doubt that a large
local fishery, centered around herring and herring weirs, will collapse
and fish will be forced to areas with sub-optimal feeding conditions with
a consequent reduction in stock size.
II ThE PASSAMAQUODDY BAY-WEST ISLES AREA - A UNIQUE
LOCALITY IN ThE BAY OF FUNDY. Biologists have correctly ident-
ified the Pammaquoddy Bay area as “the production ground for the
arld’s greatest population of Herring” (Russell, 1970). Indeed, as has
been pointed out In the EIS (Vol II pp. 123-124) this production re-
sults in a multi-million dollar fishery ($3,383,000.00 from Charlotte
County, N.B.) In addition, the area supports other fisheries including
mackerel, groundflsh, lobsters, soft-shelled darns, shrimp, scallops, pen.
winkles, squid and other species which added an additional income of
approximately $1,905,000 to the Charlotte County economy in 1975
(EIS, Vol. II pp. 115.122). ThIs large commercial production is not
an accident! It results from a unique set of ecological circumstances
which make this area one of the most productive on the Atlantic coast.
The productive ability of the Passamaquoddy Bay-West Isles area is only
hinted at by fisheries statistics; It becomes even more obvious when the
entire system is taken into account.
The area supports a tremendous diversity and abundance of marine
species which Is not accounted for In a study as restricted as Moose is-
land, the target site in the draft EIS. When considered as a total area
the picture becomes more impressive. Tables 2.1 to 2.5 lists most of the’
marine organisms which occur in this area (Data drawn from Linkletter
(1976), MacKay (1972, 1975), Caddy (1970), U. of Western Ontario
(1972), Tyler (1971), Webb (1973), Spencer (1973), Marine Research
Associates (unpublished records 1964-1976), Leim and Scott (1966),
Pettingill (1939), Squires (1952), Gaskin (per. conim, 1976), and Neish
(1973)). As can be seen, the total list of species is ii’npressive, with a
breakdown as follows:
.1
0
-------
rIUJWWA
Peridinium divergcns
Ceratium tripos
C. fuicus
C. furca
C,onyauiax tainarensis
Dinophyzis norvegica
Distephanus speculum
Tint1nnop s campanuta
1. ventricosa
Cyttarocyiis dent iculata
Stenosemella joergensen
PORIFERA
Leucosoknia botryoides
L. eancellata
Scyphaciliata
Isodictya palmata
I. deichmannae
Haliciona ocutata
H. canaliculata
Microciona prolifera
Mycakcarmia ovulum
Haiichondria panicea
• H. bowerbanki
Pdllina gitiens
Subelites ficus
PoIymastia robusta
Cliona celat i
C. vastifica
Plocamionila sp.
lophon plllcrsoni
Sphaerotyttis borealis
CNIDARIA
HYDROZOA
Corymorplia pendula
Euphysa alI ata
Tubularia I’.rynx
1. crocea
T. couthoiiyi
T. indivis a
T. spectabilis
T. tennella
Hybocodon prolifera
Acaulis primarius
Myriotheta phiygia
Sarsia tubulosa
Syncoryne mirabilis
Clava Leptostyla
C. squamata
Cordylophora lacustris
Rhizogeton fusiformis
Podocoryne borealis
P. carnea
Hydractinia echinata
Bougainvilhia carolinensis
B. supercitiaris
Dicoryne conferta
D. flexuosa
Rathkea octopunctata
Catabiema vesicarium
Leuckartiara octona
Eudendrium album
E. capillare
E. dispar
E. rameum
E. insigne
E. ramosum
E. tenue
B. cingulatum
Campanularia gelatinosa
C. flexuosa
C. amphora
C. gigantea
C. groenlandica
C. uitegra
C. neglecta
C. verticillata
C. volubilis
Gonothyraea gracilis
G. loveni
Obelia articulata
0. commissuralis
0. dichotoma
0. flabellata
0. longissima
0. geniculata
Clytia edwardsia
C. johnstoni
Phialidlum bicophorum
P. languidium
Calycella syringa
Opercularella lacerata
0.pu nhla
Tiaropsis multicirrata
Halopsis oceliata
Staurophora merteni
Ptychogena lactea
Meicertum octocostatum
Rhacostoma atlanticum
Aequorea albid.
Hebella pocilluin
Lafoea fruticosa
L. dumosa
Lafoea gracilhima
Gammaria abietina
G.gracilis
Filellum serpens
Halecium hakcium
H. labrosum
H. muricatum
H. articulosum
H. bean,
H. curvicaule
•H.giacile
H. tendllum
Sertularia pumila
I Abietina a fihicula
A. abietina
Hydrallmania falcata
Sertularehla polyzonias
S. tricuspidata
S. rugosa
Thuilaria lonchitis
1. plumulifera
1. similis
T. latiuscula
T. argentea
1. tenera
T. thuja
1. cupressina
1. immersa
Diphasia tamarisca
fl fallax
D röaacea
S ’hlzotricha gracillima
Antennularia antennina
A. americana
Aglantha digitale
Physalia physahia
Stephanomia cars
Stephanonna sp.
Lensia canoidea
Agalnia ekg*ns
SCYtH OZOA
Lucernana quadricornis
Haliclystus salpinx
H. auricula
Craterolophus concolvulus
nocymthus lagena
Jagica noctiluca
Cyanca capiilata
Phacdilophora camtschatica
Aurelia aurita
A. lln,hata
ANThOZOA
Alcyonium digitalum
C sem i arubiformls
1 I$ i muhtlflosa
Ed vardsla elegans
E. inpunculoides
Italcampa duodecimcirrata
Tealia felina
Bunodactia delia
Actinostola callosa
Stomphiua! coccinea
Metridium senile
Haliplanella liciae
Cerianthus borealis
Bolocera sp.
CTENOPHORA
Pleurobrachia pileus
Mertensia ovum
Bolinopsis infundibulum
Bolina alata
Beroe cucums
Plagiostomum album
Monoceis sp.
Procerodes littoralis
Foviella affinis
literiporus vulgaris
Discocelides ellipoides
Stylochus ellipticus
Notoplana stomata
Monoophorum triste
RHYNCHOCOELA
Lineus socialis
1. ruber
Micrura affinis
M. Ieidyi
M. dorsalis
• Cerebratulus lacteus
• Amphiporus frontalis
A. groenlandicus
A. lactifloreus
A. angulatus
A. puicher
A. bioculatus
A. caccus
A. ochraceus
Tetrastemma candidum
Oerstedia dorsalis
ASCHELMINThES
Synchaeta johanseni
Trichocerca stylata
1. curvata
Priapulus caudatus
Pontonema vacillatum
ENTOPROCTA
Pedicellina cernua
Sagitta sp.
S. elegans
S. maxima
PLATYHELMINThES
U’
t.J
3
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TABLE 2.1 (contInued)
1 s. aesratOdent h VJUl aflI IP. Turritellopsis acicula ‘Polycera dubta Arctica i landM3
I Eukrobnla hanusts Schlzomarrella auriculiti Tachyrhynchus cross Dendronotus frondosus Thyasira gouldii
Alcyonidium polyoum .Tegeua unscornis Epttonlum eenlandicuin D. robustus Cerastodern%a pinnulatum
FlustreUldra hispida Barcntsia dis reta E. multistratum Doto coronta Clinocardium ciliatum
BOWCtbInkII Trichotropls borealis Coryphella rufibranchialis Mercenaria mercenaili
Trktlcella pedicelista PHORONIDA . cOfl IC S C. peftucids Gemma gemma
Crisis cbuznea Crucibulum striatuns C. tmonacca Pitar morrhu.na
C. CIibnhla Phoronis ‘P. Crepldula fornicata Eubranchus cxlgua Spi ,ula solldissima
C. denticulata Aporrhals occidentale Cuthons Concinna Mesodesma arctatum
Idmonea atlantlca BRACHIOPODA Natics dausa Tergipes deapectus Macoma baithica
TubuUpora bliscea Lunstia Immaculata Acolidis papWosa En,is directus
OftCOLlaoecla dissatoporides Terebratulina septentrtonalis L. heros Turbonilla buahiana Mya arenaria
UChenOpOrI hlspida L. trisertlata f Trophon ‘P M. truncata
L.verrucaria MOLUJSCA L.pslllda
Histeila arctics
tAstes angulna L. groenlandica J SCAPHOPODA H. striata
Ioi ta APLACOPHORA Marcenmna glabra Dentalium entale H. dIicana
Membranipora ‘P. Crystallophrisson nitidulum Velutina u data . Cyrtodaria siligua
EICC5SI PUbis . V. laevigata PELECYPODA Zlrfaea crispata.
CaUopora oraticula I AMPHINEURA Thus laplilus Solemya borealis Teredo navalis
C. lineata IsChflOChlton slba T. lapillus var. imbricatus Nucula proxima Pandora gouldiana
Buguls simplea I. ruber Boreotrophon clathrstus N. tennis i Lyonsia hyalina
I B. lurrita Tonicelia marmorea Mitrefla lunata J N. delphinodonta L.
Dendrobeanla murrayana M. dissimills Nuculana tenuisulcata Periploina papyratium
TrsoeUarla gracilis GASTROPODA ‘ M. rosacea Pd. minuta P. leanum
T. peachil Puncturella noachina I fluccinum undatum Yoldia sapotilla P. fragihi
T. ternata Acmaes tcstudinalis B. totteni I Y. myaUs Thracia truncat.
aberea elijah Lepeta caeca ‘ Neptunea decemcostats V. thraciacrormis T. conradi
Crlbduina annulata Calliostomi occidentale Colus sttmpsoni I Y. limatula Cuspidaria glacialis
Hippothcs hyalina Solarlella obscura C. pygmaeus Mytilus edulis I
H. kippopus Marprfte ,o l lvace. Nausrius obioletus MuscuJus discors I CEPHALOPODA
Schizoporefla sp. U. hellctha N. trivittatus U. niger Illex illecebrosus
Microporella ciliata I U. costalis Admete couthouyi U. corruptus Loligo pealei
Turbiceliepora canaliculata I U. groenlandicus Ptycbatractus liptus Modiolus modiolus I Bathypolypus arcticus
Escharella Immersa Moellerla costulata Pleurotomella packardi U. demiasus
Parasmltt lnajeffreys l Lacuna pallidula neritoldea Lora pleurotomarla Crenena glandula ANNELIDA
Porelia smitU L. ylucta Oenopota turricula C. faba
P. COflciflfla I Littonna obtusata 0. elegans Chlamys Islandicus POLYCHAETA
Rhamphostomella costata J L. saxatlils Diaphana minuta Placopecten magellanicus Phyilodoce maculata
ft. SC Ibu I L. Littorea Cylichna sib. Anomla simplex P. groeniandica
PalmiceVarla dcenei I Hydrobta minuts I Philine Urns A. aculeata P. mucosa
Cryptosula pallaslana Alvania carinata Spirateils retroversa Astarte undata Paranaitis speciosa
Myriapora subgracila A. castanea Clione limacina A. subaequilatera Mystides borealis
Aeverrila WtICel* A. arenana Acanthodoris pilosa A. quadrons Eteone Iriineata
Diaporoecla harmeri A. areoLata Onchidorus fusca A. borealis U. heteropoda
Tegella arctlca Onoba (Cinguta) aculeus I 0. diademata A. castanea E.. tanga
Amphlblcstrum flemingli eneopsis planorbls 0. aspersa Venericardia. borealis B. tiara .-
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TABLE 2.1 (contInued)
Eumkla sanguinca
Eulalia viridis
E. bilineata
Tomopteris helgolandica
Aphrodila hastata
Laetmonice filicornis
Antinoelta sarsi
Lepidametria commensalis
Lepidonotus squamatus
Gattyana cirrosa
Hartmania moorei
Harmothoe imbricata
H. extenuata
H. oerstedi
H. nodosa
Pboloe minuta
Dysponetus pygmaeus
Glycera capitata
G. dibranchiata
G. robusta
Goniada maculata
Ophioglycera gigantea
Ephesièlla mmuta
Sphaerodorum gracilis
Nepthys bucera
N. mcisa
N. paradoxa
N. ciliata
N. discors
N. cacca
Aglaophamus circinata
Autolytus prolifer
A. cornutus
A. alexandri
A. prismaticus
A. fasciatus
Autolytus
Sphaerosyllis erinaceus
Parapinonosyllis longicirrata
Exogone hebes
L€. verugera
E. dispar
Amblyosyllis finmarchica
Streptosyllis vanans
Syllides longocirrata
Eusyllis blomstrandi
ynis cornuta
Gyptis vittata
Microphthalmus aberrans
Nereis virens
N. diversicolor
N. pelagica
Capitetla capitata
Notomastus latericeus
Arenicola manna
Scalibregma inflatum
Polyphysia crassa
Nicomache lumbricalis
Praxillelia praetermissa
P. gTaciliS
Rhodine loveni
Clymendlla torquata
C. zonalis
Ophelia glabra
Travisia carnea
Ammotrypane aulogaster
Sternaspis scutata
Spio filicornis
S. setosa
Scolecolepis viridis
Streblospio benedicti
Pygospio elegans
Prionospio steenstrupi
Potydora ligni
P. websteri
P. quadrilobata
P. ciliata
P. gracilis
P. concharum
Laonice cirrata
Aricidea quadriobata
A. suecica
Apistobranchus tullbergi
Onuphis conchylega
Eunice pennata
E. oerstedii
E. vivada
Lumbrinens latreiili
• 1. fragilis
L. tenuis
Ninoe nigripes
Arabella iricolor
DTtIonerets magna
Euphosine borealis
Spinther citrinus
Naineris quadricuspida
Scoloplos armiger
S. acutus
S. fragilis
S. robustus
‘Cirratulus cirratus
Chaetozone setosa
Tharyx acutus
1. similis
Ledon leidyi
Dodecarerla concharun
Cossura longocirratus
Owenia fusiformis
Myriochele heeri
Pectinaria granulata
P. gouldil
• P. hyperborea
Ampharete acutifrons
A. arctica
Samytha sexcirrata
Asabellides oculata
Melinna cnstata
Sabellides octocirrata
Amphitrite ornata
A. brunnea
• A. affinis
A. cirrata
A. johnstoni
Trichobranchus glacialis
T. roseus
Terebellides stroemi
Nicotea venustula
Pista maculata
Polycirrus eximius
P. phosphoreus
P. medusa
Artacama proboscidea
Thelepus cincinnatus
Flabeltigera grubei
F. affinis
Pherusa plumosa
P. affinis
P. aspera
Brada granosa
B. inhabilis
B. setosa
B. villosa
Diptocirrus hu sutus
Haptobranchus atlanticus
Fabricia sabeila
Euchone rubrocincta
Chone infundibutiformis
Sabefla crassicornis
S. pavonina
S. zonalis
Potamilla neglecta
P. reniformis
Myxicola infundibulum
Fiograna implexa
Spirorbia borealis
S. spiriilum
I S. granulatus
i Protula media
Microserpula sernula
Serputa vermicularis
OL IGOCHAETA
Peloscolex benedeni
Clitellio arenarius
Enchytraeus albidus
SIPUNCULA
I’hascolosoma gouldu
Phascolion strombi
ARThROPODA
PYCNOGON IDA
Nymphon stromi
Achelia spinosa
Tanystylum orbicutare
Phoxichilidium femoratum
Anoplodactylus lentus
Pycnogonum littorale
Pseudopallene circularis
CRUSTACEA
Podon leuckarti
P. polyphemoides
I P. intermedius
P. finmarchicus
Evadne nordmanni
E. spinifera
Calanus finmarchicus
C. hyperboreus
Rhincalanus nasutus
Nannocalanus minor
Microcalanus pusillus
Paracalanus parvus
Pseudocalanus minutus
Aetideus armatus
Gaidius tenuispinus
Euchirella rostrata
Euchaeta norvegica
Scolecithrix danae
Scotecithricetla minor
Centropages hamatus
C. typicus
Temora longicornis
T. stylifera
Eurytemora americana
p E. herdmani
E. hirundoides
Metridia longa
M. lucens
Pleuromamma robusta
Candacia armata
Anomalocera patersoni
Acartia bifiosa
A. clausi
A. longiremis
A. tonsa
Tortanus discaudatus
Ectinosoma neglectum
Microstella rosea
Harpacticus chelifer
H. gracilis
H. littoralis
H. uniremis
Zaus abbreviatus
Z. goodsiri
Z. spinatuz
U’
S
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TA8LE 2.1 (contInued)
Aitcutha obtonga
I Ttsbc furcata
Th Iestria gibba
‘T. longimana
ifalithalestris cioni
Dactylopusia tisboides
I D. vulgaris
Paratha)estrzs Jackson I
P. pygmaea
Dlouccus tenulcornis
Ameira parvula
A. curvlseta
Ctetodcs buchholtzi
Lelmia vip
Nannopus pa ustrls
Laophonte discophors
L... minuta
L. irilobata
Platychelipus littorilis
Tichidius littoralis
Oithona plumifera
0. similis
Oncaca conifera
I Sspphirina gemma
Monstrilha canadensis
M. dubia
M. belgolandica
Caligus rapax
L.epas fascicularis
L. anatifera
Balanus balanoides
•B.batanus
B. crenatus
• B. improvisus
Nebalia bipes
Leptocuma minor
Mancocuma
Eudorella truncatula
Campylaspis rubicunda
Lamprops quadriplicata
I Dlastylis quadnspinosa
D. scuipta
Leptostylls longimana
Oxyurosiylis smithi
Leptochclia filum
L.. zapax __________
L.sav lgnyi
Cnathia cenna
Cyathura polite
Ptilanthura tenuls
Calathura branchlata
Cirolana concharum
C. polite
Aega psOra
Umnorla lignorum
Chiridotea cocci
C. tuitsi
Idotea baithica
I phosphorea
I . metaflics
Edotea tirloba
E. montosa
hera marina
Janira alta
Munnoapsis
Munna fabricli
Pleurogonlum rubicundum
Eurycope mutica
Bopyroides hippolytes
Phronima sedentaria
Parathemisto pudichaudil
P. compressa
Hyperia galba
Acanthonotozoma aerraturn
Ampetisca macrocephala
A. abdita
Haploops tubicola
Ampithoe rubricata
Leptocheirus pinguls
Unciola urorata
U. inermia
Apherusa glacialis
Call iop luslaeviusculuu
‘Corophium volutator
C. crassicorne
C. bonnetit
C. insidiosum
Erichthonlus
Dexamine thea
Eusirus cuspidatus
Cammarus duebeni
C. tigrinis
U. oceanicus
C. lawrencianus
G. nucronatus
G. setosus
G. annulatus
Marinogammarus finmarchicus
M. obtusatus
Amphiporeia Iawrenciana
Pontoporcia femorata
Priscillma armata
Hyak plumulosa
lscbyroceros anguipes
Lafystlidac Latystlut sturtonhs
Anonyx debruyni
A. nugax
A. Wieborgi
A. sarsl
fllppomcdon serratus
Ordiomenella minute
Tmetonyz nobilis
Casco bigelowi
Micra danse
M. loveni
Melita dentate
Bathymedon obtusifrons
Monoculodes edwardal
M. intermedius
M. tesselatus
Wcatwoodilla coecula
Paramphithoe pulchella
P. hystrlx
Gammaropsts metanops
Photis macrocoxa
Podoceropsis nitida
Protonaedeia fasciata
Harpinia cienulata
H. propinqua
I Phoxocephalus holbolli
Stenoplcustcs gracilis
S. lnermis
Dulichia porrecta
Pontogenela inermis
Stegocephalus inftatus
Metopa groenlandica
M. alden
Orchestia r’atensis
• 0. pmmarella
0. griflus
Ityak nilsonni
Syrrhoe crenulata
I Tiron spin iferum
Aeginella spinosa
Aeginina longicornis
Caprelle linearis
C. unica
i C. septentrionalis
Mayerella limicola
Erythrops erythropthalma
Mysis gaipensis
M. stenolepla
,M.mixta
Neomysis americana
Praunus flexuosus
MePnyctiphanes norvegica
Thysannoessa inermis
Palacmoneies pugio
P. vulgaris
Eualus pusiolus
E. (abricli
Spü ontocaris spinus
S. phippsii
Lebbeus groenlandicus
L. polaris
L. zebra
Dichelopandalus leptocerus
Pandalus montagui
P. borealis
Sclerocrangon boreas
Crangon septemspinosa
Hornarus americanus
Pagurus acadianus
P. pubescens
P. longicarpus
P. ascuatus
Hyas arancus
H. coaretatus
Peia mutica
Ubinia dubia
L emarginata
Cancer irioratus
jC. borealis
r*r .;niic
EC!LLNODLRM AlA
IIOLOTI ILJROII)IA
Psolus fabrkii
P. phanlapus
Cucumur Ia frondosa
Steroderma uniscniila
Thyone sp.
Leptosynapta roseola
Chiridota luevis
Molpadia oolitica
Caudina arenata
ECIHNOIDEA
StrongylocentrotU s
drocbachicfl%iS
Echinaracbrtius patina
STELLEROIDEA
Ctcnodiscus crispatus
Hippasteria phrygiana
SOIaStCI endccs
. papposuS
Pteraster militaris
Henricia sanguinolenta
H. eschrichti
Asteruts forbesii
A. vulgaris
Urasterias lincki
Leptasterias 1ittorali
ft. tenera
Stephanasterias albub
Gorgonocephalus arcttiu
Ophiura sarsi
0. rubusta
Ophiacantha bidentata
Ophiophohis aculeata
‘Amphipholis squamata
£
-------
TABLE 2.1 (con(wueO)
HEMICHORDATA
ENTEROPNEUSTA
Saccaglossus kowalewsk yi
Stereobalanus canadensis
CHORDATA
rASCIDIACEA
Distaplia clavata
Amaroucium glabrum
A. stellatum
A. pallidum
A. spitzbergense
Didemnum albidum
D. candidum
Ciona mtestinalis
Chelyosoma macleayanum
Asck!e2 callosa
A. obliqua
Polycarpa fibrosa
Dendrodoa carnea
Stycla partita
Cnemidocarpa mollis
Botryllus schiosseri
Boltenia ovifera
B. echmata
flalocynthia pyriformis
Molgula citrina
M. retortiformis
M. griffithsii
M. arenata
M. manhattensis
M. provisionalis
M. complanata
M. siphonalis
I Bostrichobranchus pilularis
THALIACLA
Salpa fusiformis
lasis zonaria
LARVACEA
Fritillaria borealis
Oikopleura labradorienss
Aurelia aurita
‘ S. ,
L u
planula
wyphistoma
.ctrobila
eph via
strobila relcasing ephyra
7
-------
TABLE 2.2
FISHES RECORDED IN ThE STUDY AREA.
IMARSIPOBPJANCH II
Myirine ghztinosa (Hagfi )
Petronsyzon marinus (Lamprey)
SELACI III
Carcharias taurus (Sand Shark)
Alopais vulpu us (Thresher Shark)’
Carcharodon carcharias (White Shark)
Lamna nasus (Porbeagie)
Mustelus canla (Smooth Dogfish)’
Rhizoprionodon terraenovae (Atlantic Sharpnose
Shark)’
Somniosus mlcrocephalus (Greenland Shark)
Squahis acanthus (Spiny Dogfish)
Raja erinacea (Little Skate)
I R. laevis (Barndoor Skate)
R. ocdllata (Winter Skate)
R. radlata (Thorny Skate)
Torpedo nobillana ( Atlantic Torpedo )
PISCES
Acipenser oxyrhynchus (Atlantic Sturgeon)
Alosa pseudoharengus (Alewife)
A. sapidissima (American Shad)
Brevoortla tyrannus (Menhaden)’
Clupea harengus (Herring)
Etrumeus sadina (Round Herring)’
Coregonus clupeaformis (Lake Whitefish)’
Salmo Iar (Atlantic Salmon)
Salvelinus fontlnalis (Brook Trout)
Mallotus villosus (Capelln)’
Osmerus mordax (Smelt)
Mauroclicus muelleri (Muller’s Pearisides)’
Anguilla rostrata (American Eel)
Conger oceanicus (Conger Eel-larval)’
Scomberesox saurus (Atlantic Saury)’
Hyporhamphus sp. (Common Halibeak)’
Fundulus heteroclitus (Mummithog)
Syngnathus fuscus (Northern Pipeilsh)
Apeltes quadracus (Fourspine Stickleback)
Gastero4teus aculeatus (Threespine Stickleback)
G. wheatlandi (Blackspotted Stickleback)
Pungitius pungitius (Ninespine Sticklcback)
Brosme brosme (Cusk)
Enchelyopus cbnbrius (Fourbeard rockling)
Gadus morhua (Atlantic Cod)
• Melanogammus aeglefinus (Haddock)
• Merluccius bilinearis (Silver Hake)
Microgaddus tomcod (Atlantic Tomcod)
i Pollachius virens (Pollock)
tirophycls chuss (Squfrrel Hake)
Nezumia bairdi (Marlin Spike)’
Zenopsls oceilata (American John Dory)’
Roccus americanus (White Perth)
R. saxatilis (Striped Bass)
Stenotomus chrysops (Scup)’
Tautog onitis (Tautog)’
Tautogolabrus adspersus (Cunner)
Ammodytes americanus (American Sand Lance)
Sarda sarda (Atlantic Bonito)’
Scomber collas (Chub Mackerel)
S. scombrus (Atlantic Mackerel)
Thunnus thynnus (Bluefin Tuna)
Anarhichas lupus (Atlantic Woiffish)
A. minor (Spotted WolfflsIi) ’
Pholls gunnellus (Rock Gunnell)
Cryptacanthodes maculatus (Wrymouth)
Lumpenus lumpretaeformls (Snake Blennv’
IJivarla subblfuccata (Radiated Shanny)
Lycenchelys verrilli (Wolf Ealpout)’
Macrozoarces amerlcanus (Ocean pout)
Poronotus triacanthus (Butterfith)
Menidia menidia (Atlantic Silverslde)
Sebastes marinus (RedfWs)
Prionotus carolinus (Northern Searobin)
P. evolans (Striped Searobin)’
Artediellus uncinatus (Arctic Hookear Sculpin)’
Gymnocanthus tricuapis (Arctic Staghom Sculpin)’
Hemitripterus americanus (Atlantic Sea Raven)
Myoxocephalus octodecemspinosus (Longhorn
Sculpin)
M. scorplus (Shorthorn Sculpin)
Triglops murrayi (Mailed Sculpin)’
Aspidophoroides monopterygius (Alligatorfish)’
Cyclopterus lumpus (Lumpfish)
Eumicrotremus spinosus (Atlantic Spiny Lumpfish)’
Liparis atlanticus (Atlantic Seasnail)
L. liparis (Striped Seasnail)
Paralichthys dentatus (Summer Flounder)’
P. oblongus (Fourspot Flounder)’
Scophihalmus aquosus (Windowpane)
Glyptocephalus cynoglossus (Witch Flounder)
Hippoglossoides platessoides (American Plaice)
H. hippoglossus (Atlantic Halibut)
Liopsetta putnami (Smooth Flounder)
Pseudopleuronectes americanus (Wi. tt Flounder)
Monacanthus hispidus Nanehew 1 le . sh) ’
Mola mola (Ocean Sunfish)’
Lophius americanus (Monkfish)
* RARE OR OCCASIONAL OCCURRENCE.
U’
1’.)
0%
S
-------
TABLE 2.3
MARINE BIRDS OCCURRING IN ThE STUDY AREA.
Gavia immer immer (Common Loon)
Gavia stellata (Red-throated Loon)
Colymbus grisegena holboelli (Holboell’s Grebe)
Colymbus auritus (Horned Grebe)
Podilymbus podiceps podiceps (Pied-billed Grebe)
Thalassogeron chiororhy nchos (Yellow-nosed Albatross)
Puffinus griseus (Sotty Shearwater)
Puffinus gravis (Greater Shearwater)
Fulmarus glacialis (Atlantic Fulmar)
Oceanodroma leucorhoa (Leach’s Petrel)
Oceanites oceanicus (Wilson’ Petrel)
Moris bassana (Gannet)
Phalacrocorax carbo carbo (European Cormorant)
Phalacrocorax auritus auritus (Double-crested Cormorant)
Ardea herodias herodias (Great Blue Heron)
Butorides virescens virescens (Eastern Green Heron)
Nycticorax nycticorax hoactli (Black-crowned Night Heron)
Botaurus lentiginosus (American Bittern)
Ixobrychus exilis (Least Bittern)
Branta canadensis canadensis (Common Canada Goose)
Branta bernicla hrota (American Brant)
Anas platyrhynchos (Mallard)
Anas rubripes (Black Duck)
Dafila acuta tzitzihoa (American Pintail)
Nettion carolinense (Green-winged Teal)
Querquedula discors (Blue-winged Teal)
Nyroca manIa (Greater Scaup Duck)
Glaucionetta clangula americana (American Golden-eye)
Charitonetta albeola (Buffle-head)
Clangula hyemalis (Old-squaw)
Somatenia mollissima dresseni (American Eider)
Melanitta deglandi (White-winged Scoter)
Melanitta perspicillata (Surf Scoter)
Oidemia americana (American Scoter)
Mergus serrator (Red-breasted Merganser)
Porzana carolina (Sora)
Charadrius melodus (Piping Plover)
Charadrius semipalmatus (Semipalmated Plover)
Oxyechus vociferus vociferus (Killdeer)
Pluvialis dominica dominica (American Golden Plover)
Squatarola squalarola (Black-bellied Plover)
Arenaria interpres morinella (Ruddy Turnstone)
Actitis (Spotted Sandpiper)
Totanus melanoleucus (Greater Yellow-legs)
Totanus flavipes (Lesser Yellow-legs)
Arquatella manitima (Purple Sandpiper)
Pisobia melanotos (Pectoral Sandpiper)
Pisobia fuscicollis (White-rumped Sandpiper)
Pisobia minutilla (Least Sandpiper)
Pelidna alpina sakhalina (Red-backed Sandpiper)
Limnodromus griseus (Dowitcher)
Ereunetes pusillus (Semipalmated Sandpiper)
Crocethia alba (Sanderling)
Phalaropus fulicarirus (Red Phalarope)
Lobipes lobatus (Northern Phalarope)
Stercorarius parasiticus (Parasitic Jaegar)
Larus hyperboreus (Glaucous Gull)
Larus leucopterus (Iceland Gull)
Larus marinus (Great Black-backed Gull)
Larus argentatus smithsonianus (Herring Gull)
Larus philadelphia (Bonaparte’s Gull)
Rissa tnidactyla tridactyla (Atlantic Kittiwake)
Sterna hirundo hirundo (Common Tern)
Sterna paradisaea (Arctic Tern)
Alca torda (Razor-billed Auk)
Uria aalge aalge (Atlantic Murre)
Uria lomvia lomvia (Brunnich’s Murre)
Alle alle (Dovekie)
Cepphus grylle grylle (Black Guillemot)
Fratercula arctica arctica (Atlantic Puffin)
9
-------
TABLE 2.4 MARINE MAMMALS RECORDED IN ThE STUDY AREA
A. BALEEN WHALES
Eubalaena glaclalis
Megaptera novaean.gllae
Dalaenopt era phyxab s
Balaenoptera borealis
Balaenopz era acutoro strata
Baleenoptera muscuh,s
B. TOOTHED WHALES
Phocoena phocoena
Lagenorhynchus acutus
Lagenorhynchus albia-ostris
Globicephala melaena
Delphi napterus leucas
ifyperoodon planifrons
Mesopiodon bidens
Zlphius cavfrostrls
Kogfa brevlceps
Tursiops truncatus
Delphi nus delphls
Orcinus orca
C. PHOCID SEALS
Halichoerux g ypus
Phoca vitulina
right whale
humpback whale
finback whale
sel whale
minke whale
blue whale
harbour porpoise
white-sided dolphin
white-beaked dolphin
pothead whale
white whale
bottlenose whale
bidens beaked whale
Cuvier’s beaked whale
Pigmy sperm whale
Bottlenosed dolphin
Common dolphin
Killer whale
Grey seal
Harbour seal
Sporadic visitor. Endangered species.
Regular visitor to Brier Island. Endangered species.
Regular visitor to both subregions.
Regular visitor to southern part of Brier Island.
Regular visitor to both subregions.
Reported sporadically but not in last iS years. Endangered
species.
Regular resident for up to 12 months of year, but most of the
population migrates offshore in faU.
Sporadic visitor.
Regular visitor; may be residential In outer region.
Sporadic visitor, but forms large schools.
Occasional strays from Gulf of St. Lawrence (one in 1976).
Known from a stranded specimen.
Known from a stranded specimen.
Probably sporadic visitor.
Probable sporadic visitor.
Possible rare visitor.
Possible rare visitor.
Sporadic visitor.
Local resident -Grand Manan only.
Previously common, much reduced by bounty hunting, now
recovering.
-------
TABLE 2.5 ALGAE RECORDED IN ThE STUDY AREA
CYANOPI IYTA
flerinocarpa prasina
PIeurocap a fuliginosa
Ilydila caespitosa
Lyngbya aestuarli
Oscillatoria Iaetevirens
0. nigroviridis
Spirulina subsalsa
Anabaena variabilis
Nodularia harveyana
Calothrix confervicola
Rivularia atra
RHODOPI IYTA
Petrocelis cruenta
Cytoelonium purpureurn
RhodophYillS veprecula
R. veprecula
Ahnfeltia plicata
Chondrus crispus
Gigartina mommilosa
G. stellata
Hhldenbrandia rosea
H. prototypus
Corallina officinalis
Lithothamnion polymorphum
L. fasciculatum
Melobesia lejolisil
Dumontia incrassata
Polyides rotundus
Euthora cristata
Choreocolax potysiphoniac
Rhodymenia palmata
Halosaccion rurnentaceus
H. ramentaceUs
Callithamnion pylasaei
C. rothii
Ceramium rubrum
Plumaria elegans
Ptilota elegans
P. sarrata
Delesseria SiflUosa
Phycodrys rubens
Polysiptionia lanosa
P. urceolata
P. fastigiata
Rhodomela confervoides
Bangia fuscopurpurea
Porphyra umbilicalis
P. miniata
P. laciniata
XANTHOPHYTA
Voucheria thuretll
PIIAEOPHYTA
Ectocarpus confervoides
E. littoralis
Pilayefla littoralis
Ralfsia verrucosa
R. deusta
Elachista fucicola
Leathesia difformis
Chordaria flageLliformis
Dictyosiphon hippuroides
D. foeniculaceus
Scytosiphon lomentaria
Petalonia fascia
Desmarestia viridis
D. aculeata
Chorda tomentosa
C. filum
Laminaria longicrurus
L. saccharina
L. digitata
Saccorhiza dermatodea
Agarum cribrosum
Alaria esculenta
A. esculenta
Ascophyllum nodosum
Fucus vesiculo sus
F. epiralis
F. edentatus
F.
F. furcatus
CH LOROPHYTA
Gomontia polyrhiza
Prasiola stipitata
Ulothrix ulacca
U. implexa
U. collabens
Monostroma blytii
M. fuscum blytil
M. greviflel
Enteromorpha prolifera
E. linza
E. intestinalis
E. ,nicrococca
E. percursa
E. crinita
E. compressa
!E minima
Ulva rigida
U. lactuca
Entocladia viridis
Spongomorpha arcta
S. spinescens
Chaetomorpha melagonium
C. melagoniurn rupincola
Cacrea linum
Cladophora sericea
C. arcta
C. letevirens
C. rupestris
C. gracilis
C. flavescens
RhizoclofliUm tortuosum
R. riparium polyrhizum
BACILLARIOPHYCAEAE
Melosira nummuloides
M. marina
M. sulcata
M. moniliformis
M. hyperborea
M. crenulata
M. subflexilis
M. juerghensii
Coscinodiscus radiatus
C. eccentricus
C. concinnus
C. centralis
C. fasciculatus
Thalassiosira decipiens
1. nordenskioldä
Skeletonema costatum
Stephanopyxis appendiculata
Actinoptyichus senarius
Paralia sulcata
Bidduiphia puichella
B. mobiliensis
B. regia
B. aurita
B. alternans
Chactoceros danicum
C. convolutum
C. corn pressUm
C. concavicorne
C. contnctUflt
C. laciniosum
C. diaderna
C. willei
C. socialis
C. teres
C. simplex
C. debilis
C. decipiens
Ditylum brightwdllui
Cerataulina pelagica
Leptocylindris mmimus
Guinardia flaccida
Bacteriosira fragilis
Rhizosolenia styliformis
R. gracillima
R. obtusa
R. alata
R. shrubsolei
R. setigera
R. hebetata
R. faeroensis
Fragilaria capucina
Rhaphoneis amphiceros
Asterionella japonica
ALGAE
01
0
D. alata
11
-------
TABLE 2.5 (continued)
Striatella unipunctata
Synedra pulchella
S. utni
S. g*llIonIi
S. hmarie
S. radians
S. salina
S. undulata
S. affinla
Thalsssiothrlx longissima
• Thalassionema nitsachioldes
GrammatophOra marina
CL serpentina
Rhabdonema arcuatum
Achnanthes subsessilis
A. longipes
• Cocconeis scutclum
Navlcu)a smithil
N. vitidis
N. peregrina
N. elliptica
Dlplon•eis didyma
Stauroneis obtiqus
Pinnularia distans
P. viridli
Pleurosigma fasciola
P. acuminatum
P. strlgilhs
I P. aestuaril
(P. balticum
P. formosism
P. decorum
P. angUlatum
P. ailenuatum
P. strlgosum
P. elongatum
P. obscurum
Gomphonema
6. crucigerum
Rhopalodia muscuIu
IL. gibba
IL. turgida
I K. zebra
Nitzsch ia bilobata
N. sigma
APPROXIMATE TOTAL SPECIES 1245
Among these species are many which have potential and current
economic value as well as a number of rare and endangered specks.
Many are extremely abundant. The point Is, however, that DiVERSITY
AND ABUNDANCE POINTS TO A HIGHLY PRODUCTIVE AREA.
This would not be unique if the rest of the Bay of Fundy had equally
diverse populations of marine animals. This Is not, however, the case.
In 14 years of field study,at hundreds of Intertidal and subtidal sttes
along the New Brunswick coasts, Marine Research Associates of Deer
Island. has compiled data which shows that the highest diveratty occurs
in the West Isles Area with a marked decrease on the mainland coast,
as shown In Figures 2.6 and 2.7.
The tremendous diversity of marine organinns in the Passamaquoddy
Bay-West Isles area Is the result of a unique set of bathymetric and
oceanographic conditions. The Archipelago is composed of over 40 is-
lands and numerous ledges packed into a relatively small area. In addition,
the bottom varies widely and abruptly from several feet in depth to over
300 feet in depth; in some areas such changes in bottom profile occur
within a few dozen yards. The extremely lngh tides of the area force,
twice daily, an enormous volume of water among these islands result-
ing In currents reaching S knots in some areas. In addition, the extreme
ly varied bottom topography results In efficient vertical mixing through
the entire column of water. This phenomenon is indicated by the up-
wetlings and rips which can be observed throughout the area. Such
mixing has two Important consequences: I) It distributes nutuents to
all levels and makes them available to greater numbers of animals,at all
depths,than would normally be possible and 2) it brings “feed”
organisms to the surface where they are more readily available to fishes
birth, and mammals.
The net result of this mixing phenomenon is that food, in the form
of plankton, reaches most of the bottom surface and, consequently,
that bottom supports a greater abundance of life, particularly filter
feeders (which are abundant In this area). Since most organisms re-
lease gametes or larvae directly into the sea, this abundance of bottomS
dwelling invertebrates results in a localized increase in plankton whid ,
of course, is the basis of the high productivity of the area; particularly
Head harbour Passage and vIcinity. In addition,phytuplanktOfl. proS
N. closterium
(N. scalaris
N. punctata
N. thermalis
N. granulata
N. paradoxa
N. sertata
Scollopleura tumida
Brebhssonla boeckil
Epithesnia muscutus
Surirdila ovalis
S. gemma
S. pulchella
S. moleriana
INVERTEBRATES
FISHES
BIRDS
MAMMALS
PLANTS
g36 EC IllS
96 SPECIES
70 SPECIES
20 SPECIES
223 SPECIES
1
-------
20
C’)
U I
“I C.)
0
05
I- ’
UI
z
LORNEVILL.E GRAND M ’ CAN DEER ISlAnD
FIGURE 2.6 OCCURRENCE OF ‘ 1N’)ICATOR SPECIES
AT LORNEVILLE, GRAND MANAN, AND DEER ISLAND,
NB.
‘U
>
o
8
o
LORNEVILLE HARBOUR
FIGURE 2.7 COMPARISON OF TOTAL NUMBERS OF
MUD-DWELLING ANIMALS AT LORNEVILLE, CLAM
COVE IN DEER ISLAND AND BOCABEC BAY IN PASS-
AMAQUODDY BAY.
U,
U i
C-,
‘U
0.
U,
U-
0
0
2
10
13
-------
S fl• S t I
duced in the surface waters of the Bay of Fundy are sucked into the
area and distributed throughout the water column through this violent
mixing, thus making this vital food available to deep-dwelling animals.
Without this mixing this surface borne food would not normally reach
great depths in concentrations.
The peculiar current patterns of the area also produce unique “poc-
kets” where diversity and abundance of marine organisms is extremely
great; veritable underwater “garden?’. This appears to occur when large
volumes of water pass through shallow channels which drop to great
depths at the mouth. In these cases, plankton Is compressed Into a small
volume of water travelling at great speed. When this water reaches the
mouth of the channel 1 velocity decreases sharply as the drop-off is
reached and plankton, In large quintitles,settle down over the face of the
drop-off. In such cases, plankton-dependent organisms occur In large
numbers along with the scavengers and predators which feed on them.
Such areas, contribute significantly to the plankton base and are, In
terms of this exercise, “ENDANGERED MARINE SITES” since they
are unique, small in extent, and subject to pollutants such as oil (which,
incidently, will,ln this area of violent currente,be distributed through
the whole water column). Within the vicinity of Head Harbour Passage,
we can Identify such sites at:
SPRUCE ISLAND
SANDY ISLAND
BEAN’S ISLAND LEDGES
HADDOCK LEDGE
VICINITY PARKER ISLAND
ThE “NUB::, SIMPSON’S ISLAND
I II ThE FOOD WEB. To anyone who works daily in this area (as 1
have for the past 16 years) the productivity of the area Is obvious. You
then see the tens of thousand: of seablrds In Head Harbour Passage;
plankton blooms; the enormous school* of feed fish, herring, and ground
fish; the great whales; the Impressive surface swarms of krilie, and the
fishermen whose livelihood has depended on these creatures for cent-
uries before Champlain sailed up the St. Croix River. But how do you
explain this to businessmen or politicians whose experience does not
Include first-hand knowledge of such things; whose priorities are on
another level? I would like to impress on the board, that the food web
is the vital link in this controversy and that it is vital that It be under-
stood.
In any marine system, the “food web” is the coiimpkx intcr.tction
tween all the plants and animals in that sysmcm.The existence of e cl
species, Is either directly or indirectly dependent on the existence of
other species. The balance can be so delicate that the removal, thruutth
over fishing or pollution, of small, apparently insignificant species, can
result In the virtual collapse of the system as a whole.
Head Harbour Passage appears to be one of the centers of product-
ivity in the Bay of Fundy. Almost all of the species in the bay, from
the tiniest planktonlc form to whales, can be found in this area during
the highly productive months of July, August, and September. Huge
surface swarms of Eupliausld shrimp appear during this period I L is
this animal.which Is the basic food for larger specie: and which is direct-
ly responsible for the valuable herring and ground fishery of the area. An
extremely delicate animal, the Euphausid shrimp would be greatly affect-
ed by increased pollution in the bay. As It goes, so will the fishery.
Figure 31 illustrates the basic food chain at Head Harbour Passage. The
solid lines show the direction in which the energy (low s. The sun (I),
particularly during the summer months, provides the energy for the
blooming of small microscopic plants called phytoplankton. These
plants are food for larger planklonic animals called Zoopiankton (2),
and together they are food for numerous species of Intertidal and sub-
tidal animals (3 and 4), krille such as Euphausid and Mysid Shrimp (5).
smaller flab (6), and birds. Together with medium sized fIsh (7) which
feed on them, the Euphausid and Mysid shrimp and smaller fishes are
food for the larger species such as tuna and sharks (8), whales, por-
poise, and seals (9), and man (10).
But the story does not end there. The corpses of the larger species
are returned rapidly into the system by scavenging starfish, urchins, sea
fleas, and other creatures. Even during life, all of the animals are return-
ing vital materials to the sea. The nutrients(12)tn the unknown tons
of droppings which all marine animals release daily, are vital along with
the energy of the sun, to the growth of the phytoplankton, the basic
food-stuff of the sea.
In other words, “the food web” is a fragile chain and the loss of val-
uable fishery may not result from direct effects on the species which
are being harvested. In the 1-lead Harbour Passage area, collapse could
result from:
I. LARGE SEABIRD KILLS. The droppings from
seablrds are significant since they contribute a
major source of nutrients to the water. Their re-
moval wçuld reduce the productivity of the area
UI
I
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14
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resulting in lower plankton levels and, consequent-
ly, the food available to commercial fish and in-
vertebrate species.
2. INTERRUPTION OF WE FOOD WEB..The food
web at Head Harbour Passage, during the peak sum-
mer and fall fishing period, hinges around a prolific
bloom of planktonic creatures of which Euphausid
shrimp (krllle) is the principal species. Unfortunate-
ly, Head Harbour Passage is one of the few areas
where this species surface swarms In large numbers.
Being a delicate animal, significant numbers of
these animals would be killed by an oil spill which
occurs during the swarming period. The result
would be a reduction in “feed” for commercial
fish species, birds, and marine mammals.
3. PENETRATION OF OILS INTO WE FOOD WEB.
Population reductions and tainting of fish meat may
result from penetration of sublethal and continuous
doses of oils, or other pollutants from the refinery.
Into the local food web. Little research has been
done in this field, but, deleterious effects may re-
sult from interference with reproductive functions,
genetic changes, or reduction of physical resistance
todve.
N VALUE INDEXING. A common method of evaluating the
worth of any site Is a “value index map”. Essentially, maps are pre-
pared for each characteristic of the study area which has economic,
cultural, social, or environmental value. When combined into one map.
areas which are locally vital become clearly defined and developmeMs
which would adversely affect these areas are 01-advised. To our know-
Iedgesuchanapproachhasnot been used many of thczeportssub-
mitted for the Pittston proposalS Marine Research Associates is pre-
sently preparing such an evaluation for other work for a department
of the Government of Canada. Summary maps are presented here in
the hope that the high value of the Head Harbour Passage area will be
recognized.
The parameters which were used and the rationale for choice of rat-
ing values is given. Figure numbers refer to graphic evaluation present-
ations for each major grouping.
I. PHYSICAL RESOURCES (Figure 4.1)
a) Scenic areas - areas which are visually pleasing and consider-
ed an economic asset In terms of tourism (Rating value 1).
b) Outstanding topographic features - areas with unusual feat-
ures which are an attraction to tourists. Eg. geological
features, coves, cliffs, etc. (Rating value = 1).
c) Oceanographic - areas with tides, currents, whirlpools, rips,
etc. which are an attraction to tourists (Rating value = 1 plus
1 in all areas for tidal rise = 2).
d) Water Quality - areas with water quality suitable for
recreational activities such as swimming, diving, boating, fishing,
etc. (Rating value = 1).
2. BIOLOGICAL RESOURCES. (Figures 4.2 to 4.15)
a) Distribution of subtidal sponges (Rating value : occurs = 1,
unusual abundance = 2).
b) Distribution of subtidal Cnidaria (Jellyfish, Anemones, etc.
(Rating value: occurs = I, unusual abundance = 2).
c) Distribution of subtidal worms (Rating value: occurs I,
unusual abundance = 2).
d).Distrlbution of subtidal Molluscs and Brachlopodt (Rating
value: occurs = 1, unusual abundance = 2).
e) Distribution of subtidal Arthropods (Rating value: occurs
= 1, unusual abundance = 2).
f) Distribution of subtidal Echinoderms (Rating value: occurs
= I, unusual abundance = 2).
g) Distribution of subtidal Protochordates (Rating value: occurs
I, unusual abundance 2).
h) Significant areas for marine birds. Significant areas ident-
ified by Canadian Wildlife Service (Rating value: local sig-
nificance 1, Regional significance 2, National significance
= 3).
I) Areas of occurrence of whales including Finback, Minke,
and Right Whales (Rating value: each species 1).
U’
15
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ZOOPLAN KTON
11. SEABIRDS , GULLS
TERNS , ETC.
-
U i
0
10. M P
16
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j) Feeding areas for Whales (Finback and Minke) (Rating value:
each species 1).
k) Feeding areas for Porpoise (Rating value I).
I) Distribution of Harbour Seals (Rating value: = 1).
m) Location of surface swarming Euphausids (Rating value - 1).
n)Locationofprlncipalalgae(Ratingvalue: eachspecles- 1).
3. FISHERY RESOURCES (Figures 4.16 to 4.18).
a) iut .off areas - areas where herring are commonly captured
by “thut-off” (Rating value = 1).
b) Location of Lobster pounds and tank houses (Rating value
= 1).
c) Location of ground fishing (Rating value: ground fish taken =
1, major sites = 2).
d) Location of Dulie beds (Rating value = 1).
e) Location of Clam beds (Rating value = 1).
1) LocatIon of Periwinkle beds (Rating value = 1).
g) Location of Lobster fishing activity (Rating value: Lobster
taken = I, major sltes 2).
h) Location of major scallop beds (Rating value = 1).
i) Location of weir fishing (Rating value = 1).
j) Areas where scientific specimens are collected commercially
(Rating value = 1).
4. RESEARCH RESOURCES (Figure 4.26).
a) Areas of principal value for research and teaching (Rating
value w 1).
FIGURE 3.1 ThE FOOD WEB AT HEAD HARBOUR PASSAGE BETWEEN CAMPOBELLO
AND DEER ISLANDS, NB.
S
9
8. WHAL
I
• PORPOISE
I
, SEAU
A I
I
I
I
I
“1w
I
I
I
I
/
/
f 1
8. LARGE FISH-TUNA
SHARKS. ETC.
17
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4.1 THE STUDY AREA RATED IN TERMS OF
PHYSICAL RESOURCES
RATED VALUE
II 02
___ 5
-------
DEER ISLAND
4.2 RATED DISTRIBUTION AND ABUNDANCE OF
SPONGES (3 .ciss )
HATED VALUE
[ ]
__ 2
4
6
imile _ j
ScsI.
19
%
PASSAMAQUODDY BAY
Ui
-4
DEER ISLAND
4..
C
Eadport, Me.
I
/
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DEER ISLAND
4.3 RATED DISTRIBUTION AND ABUNDANCE OF
CNIDARIA (10 species)
I mile
RATED VALUE
02
2-4
5-6
7 .8
9-10
-------
DEER ISLAND
4.4 RATED DISTRIBUTION AND ABUNDANCE OF
ANNELIDS (2 ipecies)
RATED VALUE
0.1
2-3
4 -6
6-7
link 21
is...
I
BAY
U i
LI
DEER iSLAND
Eadpod , M c.
-------
DEER ISLAND
4.5 RATED DISTRIBUTION AND ABUNDANCE OF
MOLLUSCS AND BRACHIOPODS (10 species)
RATED VALUE
LI
4-8
9
10
11
12
TOP RATING -12
GRAND MANAN-8
I Imile
I .
-------
DEER ISLAND
4.6 RATED DISTRIBUTION AND ABUNDANCE OF
ARTHROPODS (4 scsss)
11
imile
Sc .1.
RATED VALUE
0-3
4
5
B
BAY
U i
DEER tSLAND
Eastport, Me.
23
-------
DEER ISLAND
.4.7 RATED DISTRIBUTION AND ABUNDANCE OF
ECHINODERMS (10 species)
LI
RATED VALUE
0.7
8
9
10
11
13
L-
t Jr
1• P.;. ?. Eastport, Me.
I 1 rniIc 1
I
I s .s.
-------
DEER ISLAND
4.8 RATED DISTRIBUTION AND ABUNDANCE OF
PROTOCHORDATES (2 species)
RATED VALUE
0
1
2
3
4
AQUODDY BAY
U’
C
t J
El
1.
DEER ISLAND
Eastport, Me.
I- Imile
Ic.I.
L
25
-------
4.9 SIGNIFICANT AREAS FOR MARINE BIRDS
(Data from MRA and Airphoto Analysis, 1976).
0
LOCAL SIGNIFICANCE
REGIONAL SIGNIFICANCE
NATIONAL SIGNIFICANCE
-------
F
/
F
“I
1
I
1
/
I
PASSAM/QIJ000Y BAY
/
I
DEER ISLAND
U’
0
I
I
ID
3 ’
‘¼
Eadport,Me.
.
DEER ISLAND
4.10 RECORDS OF BALEEN WHALES 1971.1976
(Gadcii and MRA records combined).
• FINBACK WHALE Ion, or more)
o MINKE WHALE Ions or more)
• RIGHT WHALE Ions or more)
£ HUMPBACK WHALE (on. or more)
‘ ‘ APPROXIMATE BOUNDARY OF OCCURRENCE OF
FINBACKS AND RIGHTS
‘..“ APPROXIMATE BOUNDARY OF OCCURRENCE OF
MINKES
27
I mile
$c.Is
‘I
‘
3’
3’
3’
I’
‘4
a
a
.
.
.
.
a
•
.
•
I
/
It f.
-------
DEER ISLAND
4.11 FEEDING AREAS OF FINBACK AND MINKE
WHALES. (Gaskin and MRA records combined).
MINKE WHALE
imile
t,mI.
FINBACK WHALE
t
!A WAQUODDY BAY
U I
9,
a’
1’
•1
I
:
I
I
.1
1’
DEER
ISLAND.
• ‘(I ’
.\ .i
7.
-------
PASSAMAQUODDY BAY
DEER ISLAND
Eastport, Me.
DEER ISLAND
4.12 FEEDING AREAS OF HARBOUR PORPOISE.
LITUIC
St.’.
UI
.4
/
I
I
29
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PASSAMAQ(JODDY BAY
DEER ISLAND
•.f.
:
) . t
‘.4 .... .
•11 5 ‘.
S
‘ ‘t i .
: ‘ •
S
.
.
• ::
S
•.
I • ,
F imi!e
Sc.I.
81 -
DEER ISLAND
4.13 RECOR SOF HARBOUR SEALS. 1970-1976.
(qaskin and MRA records combined).
• SIGHTING OF ONE OR MORE
* KNOWN HAULOUT. (Numbers indicate number
of Seals commonly seen).
\0
I •/
Il
. ‘l•
. (
/
Eastport,Me.
/
I
A
-------
6
DEER ISLAND
4.14 SURFACE SWARMING EUPHAUSID SHRIMP
Lo t*,n of swarms observed from 1970-1976
(Gaskin and MRA records combi ed).
PASSAIIAQU000Y BAY
‘Eadpoft,Me.
/
/
‘•i
j
::
U’
0
I
1mB.
31
-------
DEER ISLAND
4.15 RATED DISTRIBUTION AND ABUNDANCE OF
MARINE ALGAE (6 species) Data from Neish (1973)
and MRA records.
RATED VALUE
1
2
3
4
5
6
1mi!e
$c.I.
-------
DEER ISLAND
4.16 RATED DISTRIBUTION OF FINFISHING ACTIVITY
INCLUDING WEIR FISHING, LONGLINING. HAND-
LINING, SHUTOFFS AND BOTIOM DRAGGING.
I I
I Im5e
I
I__ _
RATED VALUE
1
2
3
PASSAMAQUODDY BAY
-------
DEER ISLAND
4.17 RATED DISTRIBUTION OF FISH JNG FOR CHELL-
FISH AND PLANTS INCLUDING LOBSTER. CLAMS
PERIWINKLES, SCALLOPS AND DULSE
‘ 7 ,2
RATED VALUE
0
1
2
3
imile
-------
DEER ISLAND
4.18 AREAS CURRENTLY VITAL TO THE cOL-
LECTION OF RESEARCH SPECIMENS, ON-
GOING RESEARCH PROGRAMS AND FIELD
TEACHING.
imile
Sc.’.
G
DEER ISLAND
Eastport, Me.
0
I
I
35
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A cursory examination of the foregoing figures will show that, for
the parameters considered here, the area in the vicinity of Head liar.
bour is highly rated. This becomes even more clear when all of the par.
ameters are combined In a single map. We trust that this will demon-
strate to the board that the area Is so highly rated that entertaining
the establishment of a refinery at Eastport borders on the ridiculous.
V ThE WEIR FISHERY. As has been demonstrated In the fore.
going discussions the Passemaquoddy Bay-West Isles ares Is a highly
productive, highly valued area which is unique in the Bay of Fundy. It
Is this productivity w ilcih brings the fish to our shores and supplies the
wehmen with their Income and a highly valued life style. The annual
Income may not reach Pittston’s operational figures, but with proper
fisheries management and protection from poliution, the income wifi
continue for our ions, grandsons, great grandsons, and great-great
grandsons, whether or not there Is an oil embargo or, for that matter,
if there Is no oil at all.
The value of the weir fishery has been documented In the draft BIS.
Yet the report speaks of the area as If there Is In fact a seriously de-
clining fishery which Is not worthy of protection. This may appear to be
so from Washington County statistics, However, it Is not so when the
entire Passamaquoddy Bay area Is considered In the light of reality.
Firstly, the apparent decline in Washington County landings has re.
suited from shifts In business activities over the last 30 years. Previous-
ly, Canadian fish were commonly landed In Eistport. In recent years,
increased and refined business pressure has resulted In the flow of fish
away from Eastport factories to Canadian Plants. This was accelerated
by closure of plants at Eastport which, we believe, resulted from ex-
cessive competition between the numerous plants located there. Second.
ly, fisheries statistics do not truly reflect fish populations or economic
potential. During 1975 and 1976 heavy runs of herring resulted in a
“glut’ of the market. Most welrs were filled with fish and many were forced
to hold fish for weeks before they were sold. I-lad these weirs been able
to sell their catch and reopen their welts, fish catches would have been
very high during these years. However, with a market which cannot
process very large volumes of fish, catch statistics are biased to low fig-
ures.
This brief represents the opposition of about 300 welt fishermen.
Ttiis is an interesting figure, since Pittston projects a work force of 300.
This will not mean that there will be 600 Jobs between the two groups.
We firmly believe that an Industrial development of thiS nature
will eliminate our source of livelihood. Where is the value In a direct
“trade-off” of employment; not to mention the several thousand oth.
er fishermen, fish processers, and helpers in Wathington and Charlotte
County.
We trust, gentlemen, that you will review this material, realize the
delicate nature of the area and its current and potential value and refuse
Pittslon’sapplication for construction of a refinery at Eastport.
We vigorously support the Canadian Government’s stand on rights
of passage through Head Harbour Passage and will continue to work
for the exclusion of the Pittston refinery and any other polluting in-
dustry from the Passamaquoddy-West Isles area.
“The human population of the coast forms part of the
biological chain which originates In the adjoining sea and
Which extends from the microscopic vegetable and animal
life to the higher mammals, among which we count Man.
These bloma are proper to each region...and It Is, there-
fore, a p rime duty of every coastal state to Insure that
they are not destroyed in the only way possible, which
Is by the depradation of man ’
TRUMAN PROCLAMA TION ON FISHERY C ’ONSER VA TION (from
Marx. 1967).
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VI ADDENDA
As we have already stated we feel that the draft EIS was well re-
searched and prepared. We trust that the information presented here
will contribute significantly to your understanding of important con-
side rations on the Canadian side of the dotted line. In addition, we
wish to make the following corrections to data presented in the
draft EIS.
1. WEIR CONSTRUCTION VALUES. Inflation trends have
affected the weir industry and material costs now place weir con-
struction in the range of $10,000 to $30,000 with an average cost of a-
bout $15,000.
2. CAPITAL INVESThIENT IN WEIRS. Our previous es-
timate of $1,792,000 in total investment on the New Brunswick coast
and $1,016,000 in the Passamaquoddy Bay-West Isles area must be re-
vised upwards to the following values.
ESTIMATE CAPITAL
INVESTMENT
NEW BRUNSWICK SHORE $3,360,000.00
PASSAMAQUODDY-WEST ISLES $1,905,000.00
3. ENDANGERED, UN1QUE , OR RARE SPECIES. Our
understanding is that developments which threaten rare or endangered
species may be blocked on this basis. This is an unfortunate criterion since
it does not recognize unique ecological assemblages of organisms. Never-
theless, we can identify several endangered species as being resident in the
Passamaquoddy Bay area and another species Which occurs in such large
numbers in Head Harbour Passage that it may be threatened by a massive
spill-
I. ThE BALD EAGLE. While the draft EIS notes that the bald
eag$e occurs occasionally In the Moose Island area, It does not
Identiry the species as a resident. However, the bald eagle is a
common winter and summer resident In the Passamaquoddy
Bay area. Adults are common at Deer Island, Bocabec and
Waweig during the summer. The author has observed young
at Deer Island and as many as 6 individuals wintering in the
St. Croix River Estuary.
2. ThE NORThERN PHALAROPE. Dr. R.I.G. Morrison, Re-
search Scientist with the Canadian Wildlife Service, Ottawa
(per. comm.) has Informed us that Head Harbour Pasge Is
the most important site for northern Phalaropes on the
east coast and that as many as 500,000 individual phalaropes
have been estimated to be in the Passage at one time. Should
a spill occur when the major portion of the population is pre-
sent in the Passage, this species may be a candidate for the
endangered specks list.
In addition, the restricted occurrence of large numbers of
Terns, Bonaparte’s Gulls, and Kittiwakes indicates that the
area is unique since it fuilfills the sped fic food requirements
of these species.
3. WHALES. Both the Finback Whale and Northern Right Whale
can be considered as endangered species. Both of these Whales
are common summer residents. Finbacks commonly penetrate
into Head Harbour Passage and along the Deer Island shore to
Indian Island. Right Whales are less common in this area but
are frequently seen at Grand Manan. Gaskin (per. comm.) has
stated the surface borne oils effect the respiratory system of
whales by producing symptoms similar to pneumonia.
4. HARBOUR PORPOISE. This is the most abundant marine
mammal in the Passamaquoddy Bay area where herds approach-
ing 100 anImals have been observed. It Is a year around resident.
However, a large migration into the area occurs in July or Aug-
ust. In a worldwide study of Harbour Porpoise Gaskin (per.
comm.) has shown that other populations are on the verge of
collapse. He believes that the population on Canada’s east
coast may be the last healthy Atlantic group. Since the Fundy
herd has a seasonal center in the Passamaquoddy Bay area, he
believes that an oil spill, at the right time of year, could serious-
ly deplete this population or force these animals to areas with
ub-optlmal feeding conditions and a consequent reduction in
population size -
U i
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37
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Re por ses tb Commenrs by A. MacKay
Representing the Bay of Fundy Weir Fisherman’s Association
Comments noted.
A number of sections in the FEIS have been rewritten extensively.
In particular, see FEIS, Vol. II, p. III—7Off, VI—28ff, X—l5ff,
X—23ff, X—26ff,and Appendix F.
50—56
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Testimony Given by J. Dorchester at
Dec. 3, 1976, Public }learing
My name is James Dorchester. I live in Lubec, and I
like to breathe.
I think it is quite interesting to listen to all the
bankers make their statements, and other people say how
pbverty is the main problem we have around here; I think
that is probably due to the fact that we are smart enough
not to report it to the federal government.
Pittston i carpetbagger. They are from New York
and they have no feeling for this area. They don’t have
to breathe the air they will be creating for us with
their method of oil refining, not the big boys. They
will be counting their money down in the Empire State
while we are slowly poisoned.
Something is drastically wrong with a soul.. of a man
who can look out at Passamaquoddy Bay on a sunny day, or
51—1
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248.
any day for that matter, arid want to build a refinery
on it. These are the same people who brought us Vietnam,
only the names are different. These are the same people
who brought you Buffalo Creek, live and in deadly color.
The dam at Buffalo Creek had been deemed unsafe, but
fixing it might have cut into the profits too much.
Pittston has never run an oil refinery, and they want
to try a new method? Come on. Again, send these jokers
back where they came from before they hurt somebody, and
we can just pretend that it was all a bad dream and that
the EPA never got so involved in such blatant bulishit.
Pittston is a company symbolic of the “American way
of life”,, built upon waste and planned obsolescence.
This American way of life is rapidly becoming an American
way of dying. The refinery will be obsolete in about
20 years, and then where will this area be after two
decades of sulfuric acid showers and about 438,000 gallons
of waste oil and water, never mind damage done in the
duration by inevitable spills? It will be a mess, arid
every man will bear the shame of selling off his birth-
right and that of his children. Building this refinery
can result only in profits for a few and poisons for
51—2
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249.
the rest.
As long as there is a demand for oil, there will
be desecration and destruction of the environment to
get that oil, if we don’t exert our God-given right
to defend our way of life from the greed of unscrupulous
corporations.
If you need more information for your study, ask
the people in Buffalo Creek what they think of the
Pittston Company as a good neighbor. Ask the ones
who are still alive, that is.
The planet Earth cannot sustain the American way of
life as it is presently constituted. So why allow a
refinery, whose purpose is to refine more oil? This
will Just encourage the use of more oil, where it should
be discouraged. Ecological considerations must come
before economic ones. We can no longer afford a tech-
nology which robs the environment and returns nothing
except pollution.
What is Pittston offering in return for this
destruction? A few jobs for 20 years, if one doesn’t
die first’? One of the things that they have promised
in their report is that it might be possible to eventually
eliminate the fishing industry. Great, such a deal.
51—3
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250.
Now we get to the real meaty question: what is
Pittston getting in turn for giving this destruction?
Everything. They are getting a place to experiment
with an unproven method in a new business. Now, that
is a hell of a lot right there, but you add the magic
ingredient, good old money, and it is just fat city
right there on Broad Cove.
A basic measure of success in a free enterprise,
capitalistic economy is profit. What never seems to
have been spelled out clearly are the implications of
the profit motive for the management of resources and
the preservation of the environment. The key element,
and fault, in the profit motive is that it doesn’t
provide humanity with any motive to save anything. I
can hardly envision the Pittstons as altruists or
environmentalists, or I dare say they would never build
the thing. I would imagine that if their new method
doesn’t work out too well, and the cost of cleaning
up the air so we could breathe it again cut into their
profits too much, it would be time to either buy a gas
mask or time to get out, if you haven’t already done
so.
51—4
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251.
Mr. Kaulakis and his boys have over the last few
years managed to diddle the local politicians enough
to keep the whole issue away from the choice of the
people in the form of a referendum. The only event
that even approached a referendum was the loss of a
selectman’s seat by a pro—oil selectman a couple of
years ago after an earlier hearing. A few greedy
men are selling Eastport for short—term profits to a
few greedy men from New York, and the Quoddy Bay area
will be paying the price of their new wealth while
receiving no lasting benefits for that loss.
A few folks around here don’t seem to care about
the refinery one way or the other. They obviously
have never been around a refinery for any period of
time. I say let them go to New Jersey and see if
they want that. You too can have a Pulaski Skyway
in your spare time at home. The oil refinery would
just be the beginning of a long line of dependent and
related polluting industries that would hit this area.
Eastport is less than a mile downwind of Pittston,
so we can see what is going to happen there. I lived
in New Jersey for five years and I wouldn’t wish that
51—5
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252.
air on my worst enemy, except maybe Kaulakis. If he
wants to make the pristine air we have here into
something resembling a disaster in a chemical lab,
he should be force-fed with two scuba tanks of his
own product.
The danger in which our environment is being put
by short—sighted “growth” industries confronts us
with a planetary and personal demand, to act as if
we were acting for all mankind. Quick action must be
taken against any person or corporation which is out
of tune with the needs of the people around it. We
eat poison—free foods here and have a life cycle which
maintains its own integrity. Pollution is not an
acceptable form of behavior. No one can own any piece
of the environment and do what he pleases with it.
The planet belongs to everyone, because we are all
dependent on the planet’s good health and balance
for our own health. Allowing Pittston in Eastport
is like cutting our own throats.
The time has come for us to see ourselves as care-
takers of the precious natural gifts around us, rather
than its owners and its masters, and we have a moral
51—6
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obligation to leave the environment in better condition
than we found it. Surely, Pittston cannot by any
stretch of the imagination be included in such a
picture. We can go muddling along and let such
criminals get away with their deadly hypes, but what
will you tell your grandchild when he asks you what
happened to all the fish, and what did they look like
anyway? If we are men worthy of being called men, we
will be able to catch him one and he will be able to
eat it. (Applause)
5 1- 7
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Response to Comments by J. Dorchester
Conmients noted.
The refining method that will be utilized at the Pittston refinery is called a
fuels or hydroskinuning refinery. It is classified by EPA as a “Topping” facility.
This type of refining is not common in the U.S., although very common in other parts
of the world. A refinery of this nature is located on the Gulf Coast in Louisiana
In a basic industry such as petroleum, major installations of the scope and
size of the proposed project are rarely, if ever, terminated or abandoned. Ob-
solescence, whether due to technology advances, or wear and tear, occurs only
gradually and affects only sections of the facility at a given time.
Periodic modernization or replacement of such sections keeps the facility
efficient, effective and competitive with newer installations. Most major oil
refineries in the U. S. are on their original sites which date back to the 1900—
1930 era.
51—8
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tIPDES Permit. Application Number: ML0022420
Corps Permit Application Number: 25—76-367.
As corresponding Secretary for a local organization: For the
Love of Eastport, I have been asked to register an objection
to continuing this comment period for a number of reasons:
First, there has been a lack of copies of the draft
EIS available — personally, I have only seen the Summary
since November 28th. This permits very litt.le time to go
over its comments, to note its omissions, and to secure evi-
dence of its distortions.
Second, We still don’t know what the real plan is,
how much real estate will be involved in the complex, what
areas will be dredged, or how much will be dredged, so how
can we comment on the disposal of the spoil, since we don’t
know how much or where it will be dumped - With modifications,
relocations,, and changes still coming in, this whole project
should be shelved and the entire process begun again when
there are firm plans.
Third, there are still unanswered question concerning
title, right and interest in the site, if it is the site,
and the use of Head Harbor Passage is still denied to this
project for tankers in excess of about 20,000 tons — or less
than 1/10th the size Pittston demands. According to the latest
reports the tanker study Pittston was to produce - tomorrow,
has been set for a later date; thus, whether or not Pittston
can supply the facility - or even rer ove the product by Tanker
is still unknown. Until some of these questions are resolved,
Pittston’s application should be denied and an EIS begun when
modifications, changes, relocations, and omissions can be
kept at a minimum and people asked to comment on the EIS know
that its statements have some relation to the refinery, its
location, and its true impact on the environment. The EIS
should have some relation to reality.
Charles A. Lewis
Corresponding Secretary
For the Lovc o Eastport
7 Custom Street
Eastport, Maine 04631
52—1
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U . S LNv I RONMENIAL 1 (LC r I ON AGUNCY
RLGI0 I , ENFORCEMENT thVISION, PERMITS BRANCH
F. KENNEDY FEDERAL BUILDING
BOSTON, MASSACHUSETTS 02203
RE: NPDES PERMIT APPLICATION NU 1BER: HE0022 t20
CORPS PERMIT APPLICATION NUMBER: 25-76-367
IJ TIL RECENTLY, IT WAS ASSUMED THAT PROGRESS HAS INEVITABLE COSTS
AID THAT PEOPLE OUGHT TO ADAPT OR LEAVE. ONE IS REMINDED OF LORD
CCKE’S FAMOUS STATEMENT, MADE SOME THREE HUNDRED YEARS AGO, THAT
(lIE OUGHT i4€aT TO HAVE SO DELICATE A NOSE THAT ONE CANNOT BEAR THE
ELL OF ?tO( S. HO ’IEVER, WE ARE BOUND TO WONDER HOW TODAY’S Ei1’/IR
‘:1! :, L LA 3 COULD BE SO LOOSELY INTERPRETED BY TIlE IIAI1’ ri )L /i LP
(o iiATEVER) AS TO PERMIT EVEN A CONDITIONAL APPROVAL OF TillS PRO—
JCT: THEN.. OH TOP OF THAT, i\S FROSTING ON PITTSTON’S CAKE, THIS
SEEMS TO U AL im 200 ro 25Q,000 TON TANKERS - BUT 1AINE’S
C(II4IJITIONAL APPROVAL CO’/ERS CHLY 3.00 TO 150,000 TON VESSELS, AND
YET THE EW BRu ’ s :1c1 : PROVINCIAL AND CANADIAN GOVERN?iEIITS o! J::cT
TO PI ,SSAGE OF TANKERS OF LEES THAN 20,000 TONS. Tu, i IS LESS THAN
i/iUm THE SIZE PiTTSTON DIIANDS. SINCE T UE REFINERY CANNOT BE
SUPPLIED, NOR CAN THE P1 OIJ’JCT CE MOVED BY TA1 KER, THE EIS MUST E
DISAPPROVED — THERE I NO PLAN UEFORE IT APPROVED BY THE STATE,
AND THIS EIS IS A3ED ON AN ENTIF ELY DIFFLRENI PROPOSAL. ACCORD-
ING TO LAW TIlE LPA’S ELS MUST AGR WITH THE STATE’S AND CERTAINLY
CANNOT EXCLiED SrANDARDSJ AS SET bY IHE STATE.
52—2
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MEOO22 2O 2
Ii THIS PITTSTON/LPA EIS IS AN EXAMPLE OF WHAT THE EXPERTS ARE CAP-
ABLE OF PRODUCING, THEN, NO WONDER DAMS COLLAPSE IN OUR WEST AToMIC
REACTORS ARE PLANNED ON EARTHQUAKE FAULTS, AND THE RENEWABLE RE-
SOURCES OF OUR ENTIRE COASTAL AREA ARE DISMISSED AS HARDLY WORTHY
OF MENTIONS IHE ELS IS SHOT WITH GLARING ERRORS, OMISSIONS, OR
DELIBERATE FALSIFICATIONS. Ii SUGGESTS THAT LOCAL FISHERIES ARE
OF LITTLE CONSEQUENCE, AND, ANYWAY, HAVE NO FUTURE POTENTIAL, BUT
THE DAILY PAPER REPORTS MAINE FISH LANDINGS UP BY 73 , SEE BANGOR
DAILY dEWS, Nov. 12, 1976 (COPY ATTACHED, EXHIBIT 1).
PITTSTON AND THE EIS SUGGEST, BASED ON MODERN NAVIGATIONAL AIDS,
THAT THE POTENTIAL OF LARGE CATASTROPIC SPILLS DUE TO TANKER GROUND-
INGS OR COLLISION ARE SMALL — THIS, IN SPITE OF THE NARROWNESS OF
HEAD HARBOR PASSAGE, THE NECESSARY CHANGE OF NAVIGATION DIRECTION
IN MID-PASSAGE, THE PINNACLES OF ROCK LESS THAN HALF THE DEPTH OF
LADEN TANKERS, THE DENSE FOGS PECULIAR TO THIS AREA, AND IN THE
FACE OF ALMOST DAILY ACCOUNTS OF EXPLOSIONS SEE TANKER EXPLODES,
BANGOR DAILY t !EWS, MAY 13, 1976, AND MURKY WATERS SEARCHED FOR
SHIP BLAST Viciiris, BANGOR DAILY 1EWS, APRIL 11, 19714 (coPIEs
ATTACHED, EXHIBITS 2 AND 3 RESPECTIVELY),
THE [ IS DOES MENTION THE BALD EAGLE AND THE ARCTIC PEREGRINE FALCON,
ADMITTING THEY ARE ENDANGERED, AND ARE IN THE AREAS HOWEVER, THERE
WAS SCANT MENTION OF THE MOST VULNERABLE BIRDS IN THE IMMEDIATE
AREA - THE ALCIDS. PUFFINS, WHICH NEST NEARBY, ARE MEMBERS OF THE
52—3
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MEOO22L 2O 3
ALCID FAMILY. IF TillS REFINERY IS BUILT THE PUFFINS’ DAYS ARE NUM
BERED, AND LIKE THE GREAT AUK ANOTHER MEMBER OF THIS FAMILY OF BIRDS
WILL BE EXTINCT 1
THE EIS STATES THE AREA HAS NOTHING OF ARCHAEOLOGICAL VALUE. I
ONCE FOUND A STONE AXE AT SHACKFORDS HEAD, DID .CAVE EXPLORING, AND
WONDERED ABOUT THE PARALLEL MOUNDS ON THE LOWER MEADOW OF TUE PENIN-
SULA. HOW WELL WAS THAT AREA TESTED BY EPA?
I FOUND NO MENTION OF PARTRIDGE ON THE SITE, BUT HAVE OBSERVED THE
BIRD THERE. ALSO, A WOODPECKER, KNOWN, I BELIEVE) AS THE NORTHERN
HAIRY WOODPECKER, HAS BEEN SIGHTED ON SHACKFORDS HEAD, AND MAY NEST
THERE, AND THIS SIGHTING WAS WITHIN THE PAST FEW MONTHS.
THE [ IS FAILS TO ALERT THE CITIZENS OF EASTPORT AND THE SURROUNDING
AREA TO THE ALL TOO COMMON CATASTROPIC MISHAPS SUCH AS THE GROUND-
ING/EXPLOSION OF THE POLYCOMMANDER (SEE PROFILES, SUPERTAHKERS--I,
I4EW YORKER, flAY 13, 197 , p, 100), WHICH IfITRODUCED THE NEW DIMEN-
SION OF A FIRE STORM TO SUCH ACCIDENTS, NOR WERE WE INFORMED OF
THE DANGERS OF SUCH EXPLODING BOMBS GOING OFF IN HEAD HARBOR PASS-
AGE AS A RESULT OF COLLISION OR GROUNDING, SUCH AS THE TEXANITA
COLLISION, WHERE THE EXPLOSION ROCKED BU1LUH’ G i iILES INLAND, ALTHOUGR
THE MISHAP TOOK PLACE 23 NAUTICAL MILES AT SEAT (PROFILES, aupra,)
(SEE ALSO, EXHIBIT /4, DISCUSSING 30 TANKER MISHAPS AND DOUBLE
BOTTOMS SAID TO PREVENT PROBABLE SPILLS.)
52—4
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ME0022’420 4
IE ARE ASSURED BY PITTSTON’S VP THAT BOOMS WILL CONTROL THE OIL IN
ACCIDENTAL SPILLS 1 EVEN IN HEAD HARBOR PASSAGE WITH ITS ROILING
CURRENTS, AND YET, IN TRUTH, THE TECHNOLOGY DOES NOT EXIST EQUAL
TO THAT PURPOSE — AND AT THIS POINT IN TIME BOOMS ARE BEING ABAND-
ONED AS HAVING NO USEFUL FUNCTION IN CURRENTS EXCEEDING A-KNOT—AND-
A—HALF (MAINE SUNDAY IELEGRAMJ MAY 12, 1974, p. 20A, COPY ATTACHED,
ExHIBIT 5).
LOCAL HIRELINGS, AND OUT—OF—TOWN PROPONENTS OF A REFINERY HERE,
THERE, ANYWHERE BUT IN THEIR TOWN, PUBLICLY CLAMOR THAT OUR POPU-
LATION IS RAPIDLY DECLINING, THAT THIS IS EAsTp0RT’s LAST CHANCE
AND THE ONLY VIABLE SOLUTION TO ALL OUR ECONOMIC AND ENVIRONMENTAL
PROBLEMS. THE STATEMENTS ARE BLATENT MISREPRESENTATIONS. THE
ISLAND IS NOT BECOMING A GHOST TOWN, WITNESS THE BANGOR DAILY NEWS
OF NOVEMBER 9, 1976, p, 18 (COPY ATTACHED, EXHIBIT 6). FURTHER
EXAMINATION OF THE TAX BENEFITS PROMISED DISCLOSES THAT IN CONTRA
COSTA COUNTY, CALIFORNIA, HOME TO 5 REFINERIES, THE REAL ESTATE TAX
RATE IS THE SECOND HIGHEST OF THE 58 COUNTIES, AND I3ENICIAJ HOME
OF THAT MODERN EXXON REFINERY THE APPLICANT MENTIONED, HAS THE
SECOND HIGHEST CITY REAL PROPERTY TAX IN THE ENTIRE STATE OF CALIF-
ORNIA. (SEE ATTACHED AFFIDAVIT OF NEEL RICH, EXHIBIT 7), How WELL—
HAS THE AY AREA POLLUTION CUNIROL DISTRICT BEEN ABLE TO CONTROL
THE POLLUTION OF THESE REFINERIES? (SEE THE LETTER ATTACHED (Ex-
HIBIT 8).
52—5
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11L0022 LI2Q
WE WERE SOMEWHAT STARTLED TO LEARN THAT BIRDS WILL AVOID TIlE SPILL
AREAS - HOW SOME COMPUTER RUN - OR PSYCHIC - COULD COME UP WITH
THAT FORECAST IS ASTOUNDING, BUT PITTSTON’S BRAND OF SCIENCE IS,
OF COURSE, IN THE FIELD OF FICTION, IN ANY AREA YOU LOOK THIS
DISASTER IS UNNECESSARY, THE AMOUNT TO BE DREDGED FROM DEEP COVE
OR BROAD COVE IS EITHER UNKNOWN, ESTIMATED, OR BEING MODIFIED,
THEREFORE, THE IMPACT ON THE AREA IN WHICH THE SPOIL IS TO BE
DUMPED, IF THAT AREA CAN BE IDENTIFIED, CANNOT BE ASCERTAINED.
ACCORDING TO FIGURES OF THE AMERICAN PETROLEUM INSTITUTE ITSELF,
ONLY ABOUT SO OF THE COUNTRY’S REFINERY CAPACITY IS PRESENTLY
UTILIZED, AND THAT FIGURE WILL DECLINE AS OIL STOCKS ARE DEPLETED.
WE SHOULD BE TURNING TO NEW ENERGY SOURCES AND ATTEMPTING TO BECOME
ENERGY SELF—SUFFICIENT RATHER THAN BUILDING—IN MORE DEPENDENCE ON
FOREIGN OIL SUPPLIERS. THIS DRAFT EIS HAS PARROTED THE APPLICANT’S
STUDY, AND IS SO LACKING IN COVERAGE OF WIDE AREAS OF LOCAL CONCERN
THAT IT SHOULD NOT BE APPROVED. Ii HAS EVEN DELIBERATELY OMITTED
PEOPLE ACROSS THE BAY VITALLY INVOLVED, EVIDENTLY, OUR REMOTENESS
HAS ALREADY CAST US IN THE ROLE OF SACRIFICIAL LAMBS, THE CITY IS
BEING EXPLOITED BY THE SLICK-OPERATORS THE PEOPLE ARE DISTRESSED
BY SALE OF CITY PROPERTY TO THE LOW BIDDER, SADDENED BY THE GIVE-
AWAY OF THE AIRPORT AND THE FAILURE OF THE COUNCIL TO REQUIRE A
PERFORMANCE BOND IN DEFIANCE OF STATE STATUTE. IF THAT WERE NOT
ENOUGH, THE CAVALIER DISMISSAL OF THE PEOPLES’ PETITION FOR A REF-
ERENDUM SUGGESTS THE SUSPICION OF A CONFLICT OF INTERESTS MAY REST
ON FIRM GROUNDS.
52—6
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i1LOO22 42O 6
ro SUMMARIZE, PITTSTON’S TITLE, RIGHT AND INTEREST IN THE LAND IS
EXTREMELY QUESTIONABLE; THE CONTINUALLY CHANGING PLANS, THE MODN
FICATIONS, THE DISTORTIONS, AND THE OMISSIONS MAKE IT ALMOST IM-
POSSIBLE TO COME TO GRIPS WITH THE REAL PLAN, IF ONE EXISTS To
COMMENT ON THIS EIS WHICH SEEMS TO BEAR NO RELATION TO REALITY 1 IS
AN EXERCISE IN FUTILITY - LIKE NAILING JELLO TO THE WALL.
CHARLES A. LEWIS
qi THIRD STREET
EASTPORT, MAINE O 63i
52—7
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Dy Ted Sylvester August this year, 120.7
NEWS Rockland Bureau million poun of fish were
ROCKLAND — The landed at Maine ports, for
landing of fish In Maine a total value of $30.9
(including shcllfish have million. This compared”
increased 73 per cent for with 89 miHion pounds
the first eight months of landed In 1975 through
1976, but income to
fishermen increased only 8 . million.
per cent, according to a The large increase ’1n the
report released Thursday catch can be attributed to a
by the National Marine good herring catch this
Fisheries Service In yearof46.3mffljo ,ounds
cooperation with the Maine ‘through August, an
Department of Marine Increase of 26 mIllion
Resources. The report pounds over the
showed that through corresponding 1975 I eriod.
2 Bangor Doily News, FrIdoy.Nov12,197 1
- Fish landis increase.’
c nditiâns in October have
Q from page 1 been unfavorable, up until
one millIon pounds of that time’.weather
shellfish was landed for a conditions. IQr fishing have
total value of $1.9 million, been generally good,
• Landing in other coastal including the wInter
counties were: Hancock, months when fishermen
• 5.7 million pounds ($1.7 enjoyed good weather
million); Cumberland, 3.9 conditions. Marckoon said
million pounds ($1.6 increased catches of
million); Washington, 2.6 herring and menhaden
million pounds ($1 million),, contributed largely to the
Lincoln, 1.8 million pounds increased catches. He
$95O,43S); York, 1.1 million termed the season, “a good
pounds ($483,207); and herring year,’ Also noted
Sagadahoc, one million was the fact that more
pounds ($210,306). people were entering the
A spokesman at the, fishing business on a small
National Marine Fisheries scale. He said the addition
Statistical Service office of’ numbers of small
here, ‘?etes P. Marekoon, independent fishermen in
cited several factors In the the field contributed to the
increased landings this increased overall catch.
-year., He noted that The spokesman also adde4,
‘a I th?u gh weather ‘I “pricesarealittlebetter.”
T1 ‘ — - . .-r-
‘Other ‘appreelab)à million pöunds,an increase êlam market where $42
I n c r e a sos were In from’ .7.5. mllhoq. pounds millIon was paid for 43
menhaden landings of 17.5 landed In 1975 . through million pounds of clams.
mIlllo pounds, up 4t were Th . dollar value was up
million. Menhaden is used. declines ’ In landings of $1.3 million from the,
solely for fish meal and oll, . ‘ shrJ p (down 4.5’ million prevIous year. The 46.3
and Is not an edible fish. - ‘poIin4s) and scallops, (oft ‘million pounds of herring
Other species show1ngvin , ibo,ooo pounds).’. landed brought a price of $2
Increases in landings : . ‘Ap coyl be expected.’ million, and 15.6 mIllion
included ocean perch and .IobaVo’rh 4. “Is’ the . most’ pounds of meflhaden
cod, up nearly a million lucrative; bus1ne s for brought $1.9 miflion.
pounds each. .Haddock fis) p jnen: 7he 8.97 million. Knox County led the state
showed a slight comebaek’. pounds ‘Janded the first In fish landings for August,
over last year with catches.’. eIg)4’mont ”of. th year (the latest figures,
up about 4 0 0,00Q pounds. ‘ -‘ . .carrled 4 a value of’ $14.5’ available). A total of 7.7
The landings or lobsters ’.ml)llon.’ ‘rbe ne4., lghest million pounds of fish and
were listed at nearly 9. rnOqey .‘ . maker. was Ihet(co,t’d.oapsgez,cOL3)
Maine fish k ndings”up by 3. pErcent
-------
$
LA CORUNA, Spain (UPI) . A
Spanish tanker carrying 110,000 tons
of crude oil ran aground and
exploded at the entrance of La
Coruna harbor, spilling large
quantities of oil Into the sea and
threatening the northwest Spanish
coast with an ecological disaster.
Maritime authorities said two men
were missing — the captain of the
tanker and a port authority employe
directing a fleet of tugs trying to
float the tanker before it caught fire.
The rest of the ship’s crew of 45 was
saved.
The tanker was the Spanish.own
Urqulola carrying crude from the
Persian Gulf. It ran aground on
some sub nergcd rocks as it passed
through a narrow channel linking La
Coruna harbor with the sea.
The national news agency Cifra
reported bu ick smoke pouring from
the wreck câmpletely enveloped La
Coruna, a city of 240,000.
It said a hbge patch of oil was
spreading over the sea off the
northwestern Galiclan coast which
has many vacation resorts and busy
fishing ports.
The explosion shattered windows
along La Conma’s ocean front, but
apparently no one was hurt on land.
The ship ran aground shortly after
noon and the explosion occurçed an
hour later. At 4 p.m., the wreck was
still burning, with smoke covering
the sky as far as the town of
Santiago de Compostela, 40 mItes
away.
The tanker’s third officer. Miguel
Angel Gomex Pena, told reporters
the accident was not caused by any
fault of the ship’s owners or crew.
“The ship was practically
stationary when we felt It touch
bottom very .gently,”he said.
Tanker explodes,
spill is shore threat
3.
Thu
OO Y HSV ’
-------
• v r Doily Hows. lhur%doy. April 11. 1974
Murky waters searched
for ship blast victims
PHILADELPHIA (L PI) Fire ’o1ficfals sakj the it i’,’ Flrem i, 1n - Iid
— Coast Guardsmen and ship “carried a 33-meinber ‘the blaze under. ontroI
firemen searched the crew, 12 of whom were on shortly before’ midnight.
murky Waters of . the sho’e leave at the time of tifl were hosing down the
Delaware Iiive Wednesday the explosions, , ,, wreckage. at daybreak
for the bodjvsof 12 persons The explosions sent shock Wednesday.
reported mi islng in fiery waves rippling for 33 miles, : ‘fl cetise of tha blasts.
explosions that ripped a rattling windows as far which. apparently erupted
• Grevk oil tankerIn two. away a. ?ew Castle, Del., In . one of (he ship’s oft
One crewman, Desta Ge. and blanketed : the t ptks, was not known. Fire
brehedhin,anEthlopliul.waa metrppolitap area .In , an ‘officials,: however, learned
killed late Tuesday when orange glow.: . .. the. tnk r had been forced.
the two blasts lore througl “The whole t area j ist lit to radio for assistancetwo
the mud section of the up,” sajd Arcu secunty days go as the result ofp
! OOO .ton . a as at man. frank Kelly,- ho ndnorfireaboa d. —
umpad off the last of it. witnessed the explosions “Wq . 8ent out an S.O.S.
‘cargo of Venezuelan crude from’ a guardhouse.on the alert :”. said Antonio
oil at the Atlantic Richfield .dock.’ ru was just a ball of Pimantel 9, SeCOnd
Co.’s (A IICO) Fort jjfflIn fire so bright. There was engineer’ on the Ellas. from
Marine Terminal just south such a great force. You just hig hospital bed,: ‘But then
of here. , - ouldn’( see, anythIng, but a member of the
Thirteen persons. flames and smoke.” succeeded.ij putting it out.
Including a pier guard and City Fire Commissioner Itqply lasted ‘fly..
‘a woman crewS member, Joseph Rizzo also . was mInute .”,’ ,
:were injured iii the stunne4by.theforccofthe ‘pj n’antel -told
e x p I o s I o n a; T h e blasts,.,, •. ‘, nve Igators he dId ‘not,
Ph ha delphja fire “The ship juSt :hieW think- lhe earlier flçe and
department said-the apart,’.’ he said., lh, Op1oslons wer* rela-
missing ‘included seven ‘Pieces -I’m talking about .ted.
crewmen, a male halI.ton and ton pieces of
I n t e r p ret e r n d a steel— were just torn righ(
30-year-old mother and her off and,went flying. I neier
three teen-age daughters, saw anything, like this,
all from Baltimore, who before.”
were visiting the captain The ,explosfons left the
aboard ship. , middle of the tanker.
Some of the missing were resting .40 feet biiow on,the ’
feared.trapped lnjhesub-river ’:.bed..and itr
merged portion: of• the smoke-blackened bow and.
650-foot ship. stern , jutting out of the ‘
1Q / I3i/
52—10
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anker Bottom’ Damage Incidents
!z ’nes C. Card 1
Jr !‘e preparation forthe 1973 International Conference on
v -; -pc,m tic,n. the United States was assigned a study on
a!ei b !flast tar.kers. The study, which was comp!eted in
F, tmrv 1973. covered the spectru t of tankers from 21.000
t yto dwt for both product and crude carriers. On the
assvf the study the l’rtited States concluded that segregated
baTLis’. is economically viable aboard tankers of 20,000 dwt or
grest er. and that the segregated ballast capacity should be
ichievrd in part by fitting a double bottom throughout the
rugn length whose height is at least one fifteenth of the beam.
it .is felt that the height was necessary for two reasons. First,
a ts intended that segregated ballast water would be carried
in the double bottoms to significantly reduce the problem of
intentional discharge of oily ballast at sea. Second, the double
bottoms would provide a degree of protection against acciden-
seharge caused by grounding,incidents.
At the natiohal level in January1973. an Advanced Notice
for Proposed Rule Making 1112 was published which informed
the American public that the Coast Guard was considering
construction standards for new tankships whkh would require
g ’egat ed ballast and double bottoms.
The purp”e of this paper is to examine the effectiveness of
dt&’e bottoms in preventing oil outflow from tanker bottom
tianiage. The investigation presumes that the vessel has had
bottom damage which resulted in a breach of the hull. It
brtt1d he pointed out that approximately 75 percent of tank
vecs.! bottom damaging casualties do not result in a breach of
the hull: this paper deals with the remaining 25 percent.
Background
The search to determine the effectiveness of double hot-
kins in reducing oil outflow from tanker stranding or other
bottom damage Is not new. Table 1. developed from Refer.
rices 12—61 shows that a tanker fitted with a double bottom of
approximately B/IS would on the average spill between 37.5
and 92 percent Tess oil than a single-skin tanker in identical
Jisuom-damaging incidents. This spread in effectiveness is in-
teresling because each evaluation of double bottom effective.
ness ,1s5 exactly the same set of information—that contained
•‘Uciitcnnnt ciuninander. ( 1 5CC: stall flnv:,l ar,hiI tt. Merthant
tjrini Trihuiral t)ivi.—ion. OlTice or Merchant Marine Safety. U. S.
f.n*t tsz: ,rrj 1 irnrlers, Washington. I). C.
uii her in lirnckcls designate ltefeu ntps a? cii t iirp:s 1 .cr.
Presented a part of a panel discu .sinn entitled Environmental
l’rutccti,m and Tanker De igri. ” held at Den cr. Cohirailit during the
Spcond Annual ln ers iciety Conference ,,n Tramq .rl;itii .n. Se;,t. 2t ,
sq-a.
• il .f or assrrlis.iis in t1it paper arc the l ’ti%ate i,nei of the
auth. ’ awl are not in he c.nistriied as niricial or refletting the vws of
i.e the Coast Guard at large.
Tabte 1 Comparison of various stud’s to deterrr.ne
double-bottom sUectivencs
in the IMCO Damage Cards 171. The information was gathered
by the IMCO Subcommittee on Subdivision and tability to
be used as a basis for evaluating new subdivision nnd damage
stability requirements for passenger ships. Most cif the dam-
age cards submitted to IMCO are from Co!!istnns, but strand.
lag damage is also recorded.
While each of the studies used the same bosic data, it. is nb.
VIOUS rrom the spread in results that each u ted the data in a
different way. As a source of data to tu Iy the prcilicm of
tanker groundings, the IMCO Damage Cards are the best
available internationally. However, art inve.stigaticm of the
damage cards showed that there are several problems associ-
ated with using this source.
Because of these problems and because there appears to be
no method of using the IMCO Damage Card- data that would
be independent of the methods already used in references f2—
6J, an alternative approach for determining double bottom ef-
fectiveness was sought. Instead of attacking the prnbleai from
a statistical approach using historical stranding damage infor-
mation, a mathematical model could he employed which
viuuld include tanker structural design. operating COnditions
at the time of the casualty, and structural loading from the
rock, ledge or other stranding object. The Coast Guard decid-
ed to pursue such a study along with a study cit cullision in a
research and development contract with M. Roscnhlatt and
Sun Inc. (9J. The study was restricted to ship design and in
particular to the analysis of tanker structure from the view-
point of the cargo containment protection it provides iif the
event of collision and grnundivsg—Lhat is, what prut’ rtiiin is
available with current ucture design practices anci whether
that protection can lie increased appreciably with rnas,.nrth!e
changes in these practices. ‘lhe central purpose of thc lJrc ’j ct
was to develop a structure evaluation pr icedure. nod the b ’rt
of this was the task which cieve!nped the analytical pri’eecure
for evaluation. The procedure was ubdivided into ‘pta ’ tic en-
ergy analysis’ and ‘elastic energy analysis’ with the int rt ice
between the two defined. The initial efflirtin this study cc-
Effr dllveness of Double Bottoms in Preventing Oil Outflow from
Shortly after the Torrey C ,snvcn stranding. worldwide public opinIon began pres uring the m.iri ’one ce r n .
rnun t ly f r pot’ution.free t.,nkcr dcsigns. Perhaps the most widcy discussed Pitior, abat’rm.’fl ‘i’r .’ n
feature’is the double bottom. In U. S. wate’s from January 1959 thro ’j h Ap ii 1q73 there occirred 23 pot.
lution casualties that resulted ft orn tanker bottom damage. The paper cxaminøs aS thes’ acc ntc 0 tte-
te,rnine how etfectve cube bottoms woud have been in reducing their nvmbv r a we! n It ,” amn’r ’ 0?
oil oull’ow. fl tiIt lr icatn that a doahle hr’tlnm whoc., Pusirjht li cmo .Iiftoei.th Itin bt am cosi ’ i1 Iuiv’t !i’ , ,
efIccIive á pr .vontkw Outflow in 27 of tli 30 Casw.”es examined.
Study
Bovets Analysis of Tankers (?f
Se iegated Ba!tast Study—Parts I and II
5egre ated 8isttast Study—Part It (altemEivq
method) P1
MacAd final E.I.S. (5J
Booje Al len analysis of MacAd EJ.S. 161
Effectrve- -
ness.
percent
61
61
37.5
52—11
P.’A ItVE TZCI*1OL Y
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Main. Sunday Telegram 1 M y 12. 1974
0 •
:,
1— 5 ’ -1 —
__ : - - - ‘-
- • .--— . ‘ - -
.. .
S S 5 ... S. 5
. - - ‘1 - 1 ’ t- .. - . • s; -. - . . — .•.
— - . -4. . - — - . JUN - - - - — -
- . - • - -. S S -- - - .-.
-- 5 - 5
t -
. S —.
*
. — a ’ f ’
Oil boont around a tanker docked at Ci%1P station at Cousins Island
Oil Booms Are Nol Ideal Method
To Con fri in Spills Wh i le Offloa ding
By BOB CUMMINGS
Staff Writer
Oil booms are not t’ e answer to con-
taniig au oil spills in Maine.
Despite the talk at environmental
bearings, at sca’e ports the booms don’t
work at all. At others they are effective
only $rt of the time.
This is the message from Paul Soya,
specialist In oil spills for the Department
of Environmental Protection.
I. ..st week the board of the Department
of Environmental Protection, waived
re uIations requiring the booming of
sh ?s loading and unloading oil in Sears-
port, Bucksport and Bangor-Brewer.
The action followed Soya’s recommen-
dation.
He said currents at these ports run too
fast. Any oil that might be spilled just
runs ont under the boom anyway, he
told the board.
An nil boom is a flexible rubber bar-
rier that floats a IoDt under the surface
and protrudes two feet above the surface
when placed in water.
The booms are used to encircle ships.
Theoretically they trap any oil that is
spil’ed into the water.
However currents faster than about a
knot and a hail will sweep the oil under
the booms. During high wind and waves
the oil will escape over the top.
It Is also dangerous under these condi-
tion to put the booms out, since small
boats must be used.
Even In the port of Portland, which
has only minimal currents. 25 per cent
of the ships that docked at Portland
Pipeline during the first four months of
this year were not boomed during the
entire times the ships were loading and
unloading.
Portland Pipeline handled 160 ships
thrcr gh April 30 of this year. Forty of
these ships were not always boomed dur-
ing unloading operations, statistics from
the pipeline show.
Highwinds, ice conditions and rough
seas are the principal reasons why the
booms could not be used all the time In
Portland. Soya said.
He said it isn’t reasible to require
ships to remain at sea until conditions
are suitable for booming.
Conditions are more often unsuitable
for booming during the winter months.
Soya said. On a year round basis, Port-
land Pipeline booms the ships at its
piers about 85 per cent of the time. -
The Pipeline has about seven oil spills
a month, but Soya said he has no statis-.
tics to indicate whether spills are more
apt to occur when the booms are not in
use.
Despite the spills, Soya has praise for
the Pipeline’s operations. “They do an
excellent job considering the volume of
oil they handle.”
The Pipeline handles about 500,000 bar-
rels of oil a day—twice the volume of a
large modern refinery such as is pro-
posed by Gibbs Oil Co. and the Pittston
Co.
Both Gibbs and Pittston have said they
will place oil booms around all the ships
that bring oil Into their respective
ports—Portland and Eastport.
But the experience of Portland Pipeline
Indicates they will have great difficulty
doing this. Soya says.
DEP regulations require all ships do-
- livering oil to hi boomed when wind,
weather and current conditions make
booming feasible nd safe.
Soya said that as an alternative to
booming ships at Bangor. Searsport and
Bucksport. boats will be kept available
to try and pick up any oil that might es-
cape. S _____________
6
52—12
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recent, dramatic increase
In population may only
have succeCded in restoring
the county’s total
population to the 1960 level
of 32,908. The census
bureau estimate for July 1,
1975, is 32,800, a figure
which may have increased
during the past 15 months.
The year 1970 was a
turning point for the
County’s population, but.
only a modest one when
viewed against the
background of a county
wide popuIati n decline
since 1900. The first 70
years of the 20th Century
saw the population drop by
35 per cent, and the
number of towns apd cities
with populations of over
1,000 drop from 15 to 9.
“Drop-out” communities
Include Addison,
Cherryfield, Danforth,
Harrington, Machiasport,
Pembroke and Perry.
Of 46 municipalities in
the county, Baileyvilie
alone (site of Georgia
Pacific’s paper mill, the
county’s largest industrial
plant) has undergone a
population increase during
this century which makes it
the only post-1900
newcomer among the nine
communities of more than
1,000 population.
According to census
bureau figures, the
population Increase of the
1970’s has been distribute4
throughout the county. The
natural increase component
of births over deaths is
estimated at 400, and Uft .
in-migration component Is
estimated at 2,500. Viewed
in terms of population
equivalents of actuaL
municipalities in the
county, natural increase
during the 1970’s has given
the county the equivalent in
population of anothet.
Columbia Falls or
Robbinston, . and
in-migration has produced
the equivalent of another
Macbias.
U I
F?
.1
C . h .. - . ,P ‘ ‘ 9 g
0 • 4fl.’
ounty..s. ows .,10 4 population increase
By Bill Vasques ‘ is. of special significance in
NEWS Correspondent ‘ respect’ to the county.
MACHIAS :The During :the 1960’s, an
county’s population growth ... out-migration of slightly
increased by nearly 10 per more than 3,000 is also
cent during the first five., revealed in census bureau
years of the 1970’s, figures. The population
according to the U growth of the 1970’s
Census Bureau’s update of estimated at 2,900 as
the 1970 national census. . . July 1, 1975, has virtually
The components of the . equalled the population
county’s population growth lo5S, resulting from
included the natural out-migration, of the 1960’s.
increase of births over The county’s population
deaths and new residents, growth during the 1970’s Is
apparently the result of a termed the “fifth highest”
nationwide trend of urban’. among Maine’s 1.6 counties:
to - rural migration. Yet 15, years of seesawing
A third component of the population levels since .1960
population increase, the pidecs the county in a
return of former residents. paradoxical position.. The
-------
I, r!cel. S. Rich, of 271 West IL ;t reet, !tenlcta, California, having First
been duly sworn, depcise and say as fttlow:i:
I am Chairman of an orgaftlzatiott named Renicians for Environmental Action,
which has been in existance for four years. I have bccn requested by Robert
Lee Eden of Portland, Maine to report on tlje number of personnel that work at
the Bentcia Exxon (Uumble) Refinery and ho’i the Exxon Refinery has a fectcd
city and county taxes.
Figures obtained from the Benicia çharther of Commerce state there are 350
. people employed by the Benicia Exxon Refinery. In Talking with an ex-eraployce
of E ocon I have been told when Exxon first started operations in Benicia they
hired 180 people to train as their operational force (refinery technicians).
j out 160 people completed this training . Most of these technicians uerc froai
the Greater San Francisco Bay Area (9 counties make up the Bay Atea). cost of
the remaining employees, including almost all the professional workers (engi-
neers, chemists, etc.), were imported into the area from other Exxon operations
(mainly Texas). Exxon is a non—union refinery, they do not enploy members of the
Oil Chemical, and Atomic L orkers International Union.
:s During a normal swing or graveyard shift about s5 employees ..re on duty.
During day shift about 100 maintenance people are on duty, in addition to the
45 operational employees. I do not know the number of administration type
employees that are on duty during the day. -
The Exxon Refitery is rated as a 72,000 barrel/day operation. The ex—
employee I have talked to stated, Exxon was running over 100,000 barrels/day
z ten ho last worked for the refinery.
I balicve the ta benefits of industry are highly over rated. Contra
Costa County which is adjacent to our county (Solano County), is one
o the most industrialized counties in California. Five of the ix Sm
}‘,snct eo )ayAre:toil refineries re Inc tc’d in Contra (o aC u tLy. Contra
•Costa County has the second ht hcst tax ratc in tIi entire state of talifornia
which is meda up of 56 co nt1.cs . One reason for this is that industry can
d preciatc their facilities and thus rcducc their county and city taxes each
y’ar, while the !rnnleo;Iners tax rate goes up each year to nake up the diffcrence .
5 2—14
-------
j Ii.ii.i%t g 4IIilI• , li.,i•’ t I t (I I II iI *) Ai .. tc I i isiiy t•t •IIItt.it (I
Ci 1.1 furu tii) , Ili., .’rond Iii ht: lc [ t t.i* rat ‘ Iii LII : t ntc
A few years before the enic1a Exxt t Refinery was started a bridge was
built. linking flenicia (Solano Couuly) wi iii tlaftincz (Contra Co .ta County).
Thl no makes it possible to live in Sojano County and work in Contra Costa
County. For this •reasnn , and many othc ts, propc rty values in Bcnicia are
incrciming in spite of Exxon . Solarto County is the only County in the Bay
Area that has not yet put restrictions on growth and it is one of the last
Bay Area counties zherc there is still land left to develop. Solano County
is rapidly developing as people flee the more industrialized and populated
counties of the Bay Area. This present development is referred to as the
“North Bay Tilt” by planners and developers.
In sut ary; because of a population shift in the San Francisco Bay Area,
property values are holding firm or i!.crëasing in Benicia, in spite of Exxon’s
existance. The anount of city and county taxes received each year from Exxon
is decreasing which caused a $60,000 secured shares cut in the Benicia City
School Budget last year . A well established Benicla real.tor has told me that
there is an abnornal turnover of home ownership in the Benicia “Righiands” area;
especially on streets that overlook tt.e Exxon rrfiner •‘hich is 1/2 to 3/4
miles away and dovnwind from the Bertieia “Highlands”.
HEEL S. RICH
____ ç . .
Sutscribed to and sworn to before me this _________ day , 1973.
:; c u
L ‘ ,:;
\ -: ‘ .. NOTARY I’ UI T..lC
I •.•’ I’
(, 1 r,1cl ... ,oii. : ‘. ‘ : .
52—15
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BA\’ REA AIR PCLLUT ON CONTF OL D STR ci
1 ay 25, 1 7
Mrs. 3ean B. Sin, President
West Contra Costa Conservation League
1015 Leneve Place
ichmond, California 94530
Dear 1trs. Sin:
o r 1ett r-t ths Hcn .rabl - Rob r4’- S .Clafr ,
Chairman of th.e Board, has been referred to the
staff for response. In your latter you asked
four .questi,ons which we shall attempt to answer
with. he following information:
I. Your first’question concerns the statute of
limitations wbiâh has expired for :some 17 to 20 viola—
‘tion ioticesi ssued to the Exxon Refining Company. -.
Durir g. the 18-month per od between November, 1973.
and pnil, 1973,’ 109 violation notices were issued.
to the Exxon Company as a result of emissions, in, -
excess of those permitted by our regulations. Penalty
proceedings were recommended far 77 of these notices.
The!balance (32) were not recommended for penalt
ac ion becauseof’ circumstances surrounding the
pa rticular case which made it difficult to proceed
w 1 th legal action. 77 cases recommended for
‘penalty action;. 21 were not processed because-of the
one—year statute of limitations having expired. -
It should beT oInted out that d ining the period- of
consideration for these 21 notices there were a series
of events ‘ihich took place at the District, ‘and with
which I am sure you are familiar, and which ’delayed
‘ oun legal processing activities. These events were
concerned withT .the fact that our former. counsel,
Matthew Walker, was in an accident which incapacitated
him for some 6 to 8 weeks in the early part of 1972.
In May, 1972 the Board appointed a temporary counsel
who worked part time for the District for several
xz onths. A permanent counsel was appointed by the
Board, Mr. David Self, who came on duty t the end 1 .
of November, 1972.
52-16. ..
939 ELLIS STREET o SAN F RANCISCO, CALIFORNIA 94109 ° (4 5)771 -6CO3. E/hLf/31T
-------
Nrs.. Jean B. Sir!
Nay 25, 1973
Page .2
All of these activities interfered with the normal
• legal processing of penalty actions during the period
that the 21..vi9lation notices passed the one—year.
statute of 1i itätiorts.. would like to inform you.,
howe ver, th t ith the present staff of two legal
• counsels an& he formation of a Central Operations.
group in our En fbrcement Division, we are confident
that this situation will not occur again. In fact,
we are so streamlining our procedures at.this time
that we feeL certain that action on most violation
notices which are reco tmended for penalty action
will take p1ace.within a 30-day period from the
date of issue
2. Your secónd question concerns dozen.s of upsets
at Exxon Refine ry, and states that only one break-
down since thé revision to Section 3212 has been.
reported..: -: -
As you know 1 the upset and breakdown sections of
Regulation 2*eré amended on July 7, 1972. Between
August 1, 1972 and Apri4 30, 197 Exxon has reported
to the Distr t ..l49 upset and breakdown conditions.
A preliminary estimate of the cause cf the conditions
which led to the reported upset and breakdowns was
given by- Exxot düring the initial call-in on 134 of
these reports;..The ba1anc of the reported upset
and hreakdo rps(15) are being evaluatedby our Engineer-
ing and Enforcer ent groups as to whether or not they
legally fallwithin the upset and breakdown conditions
out1 ned in th regi’i’1at ion. As soon as this information
is available•we will be happy to forward it to YQU.
3. Your thi d question concerns the denial o-f right
of entry byou r:inspectors at Union and Exxon
The Union oil Conpany has refused us the right of entry
to their cont o .l.rooms but not to other areas of the
refinery. rie.,havc been informed that this is a
corporate polic ’ throughout the USA and that during
upset and b e akdo rn periods only restricted personnel
are permitted ehtry to control rooms. We are presently
meeting with the company to resolve thi matter, and
our counsel has informed us that we may in titute legal
moans if necessary to obtain right of entry wher ever
necessary.
52—17
-------
Mrs. JCcfl I. Si i
4ay 25, 1 )73
Pa e 3
Durin9 th past year Exxrjn a . so has conte ted our
right of entry to their control room We are
p are , s with Union, to take wha.tever legal
action is necessary to gain entry to th sc areas. -
We should point our, however, that we have not had
any diffictltics or refusa1 in obtaining data,
records, or right of entry to the processing areas
of either of these refineries.
4. Your fourth qu tion is concerned with th. fact
that Allied Cheitical in Richmor.d has taken steps to
improva their operation, but that4onsantG—PhillIps
atia-union, with tauch dirtier operations-, have fewer
violation notices.
TLe- nut ber of violation notices icsued to any source
is-dependent upon the number of excessive emissions
recorded- either by bur inspectors through visual
observation, or by excesses to our ground level
tonitoring requiretents for sulfur dioxide.. The
number of violation notices is not necessarily
related to the total emission rate of a particular
source, since partLcularly for sulfur dioxide, stack
heights nd effective dilution of the emissions may
no.t result in ground level violations. We might also
point out that durin the porio January 1, 1972,.
through pril 30. 1973, there were 136 violation
notices issued to.th Al1i d-Standard complexç 114 to
the ?1onsant —Phil1ips coraplex, and 100 to the Union
oil- Company.
It is. c r policy to issue violation notices ,whenever..
excessive enissior.s occur regardless of the size or
eru.ssion rate of the source involved, and we shall -
coi tinue to rigorously enforce the regulation-s adopted
by the Board -of Dir 2ctors.
I hone ths inforr tion i satisfactory. 1f you have
any further questions, picase do not hesitate to let
e know. -
Sincerely, -
I 1
i
b.J . Cal1a jban,
A’lr Pollution Control Officer
!)JC:ld / -
524? 3
-------
Response to Comments by For the Love of Eaatport
Sec I E Is vol. IF 1 .iII—alff Corn increi:tl IflV(,r(cI)V1 Ic 4
p. IV—23f I Marine Transport System
A survey of the channel will be done to identify pinnacles that would
requ’e removal before the channel is utilized by tankers.
p.iII— 1 1 8 Fog
p. 111—13 Existing Socio Eco1’” .
p• VI—1 3ocio Economic impact
p.: 111—159 Archaeological Sites
p. VI—59 Dredging
i The Canadians oppose the transit of oil vessels clown Head Harbor Passage.
Ri Mr. Richard Vine of the State Department notified Mr. John McGlennon of EPA that the
issue of Canadian opposition to tanker passage was not an appropriate subject for
discussion in the EIS. All Federal approvals are contingent upon State DEP
approvals.
52 The DEIS makes no mention of the Alcids-Puffins.
& The Puffins are mentioned on page 310 of Vol. II of the DEIS. The nearest breeding spot for
the Puffins is Macbias Seal Island, located approxImately 35 miles southeast of Eastport.
Because Puffins breed in groups and the nature of their food gathering (diving for small fish)
is such that if Machias Seal Island were hit by an oil spill — the possibility exists that the
colony could be severly impacted.
S3 Groundings and explosions.
3 The navigation aids discussed in the Tanker Operation and Marine Transport
System section of the EIS together with tug assistance and ocher aids make
this possibility unlikely. Explosions In tankers occur very rarely. The
scouring operations are done at sea, and will not take place while the
tankers are entering or leaving Eastport. To prevent these explosions,
tankers are being equipped so that inert gas Is used to fill the compartment
vapor space instead of air.
Found no mention of the Northern Hairy Woodpecker or the partridge on the site.
R4 See FEIS Vol. [ 11—69 Fauna observed during field studies at the proposed refinery site.
(Fall 1975).
52—19
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S5 Booms will not control oil In accidental spills — oil In currents greater
than 1 1/2 knots cannot be controlled.
R5 See the FEIS, Vol. II, page IV—38 ff, Oil Spill Containment and Recovery.
The technology and techniques involving the use of oil booms and associated
skimmers is continually being improved. For example, studies performed by
B.A. Folson and C. Johnson of Ultrasystems, Inc. and presented at the
March 1977 Oil Spill Conference sponsored by the EPA, USCG and API,
demonstrated that a specific streamlined oil boom is capable of retaining
and recovering oil spills in currents up to 6 knots. However, this system
performs best in wave conditions under one foot. Also this oil boom is a
research prototype and not yet available commercially.
S6 Only 80% of the country’s refinery capacity is presently being utilized.
R6 See FEIS, Vol. II, p. IV—l ff.
ST . . . saddened by the giveaway of the airport and the failure of the Council
to require a performance bond in defiance of state statute.
R7 The City of Eastport petitioned the FAA to be released from their contract
— to operate the airport. Pittston has paid for the option to purchase the
airport at some point in the future. However, Pittston cannot purchase the
airport until it is released by the FAA.
A performance bond is required of the main contractor once construction
of the refinery begins.
58 . . . Pittston does not have title, right and interest to the land .
1(8 The Maine BEP has ruled that Pittston has title, right and interest to the
lands in question.
52—20
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• Eastport has been subjected to Pittston’s Public Relations
releases now for almost 10 years. Nevertheless, the people are
still not convinced that the refinery information they have been
giving us is either complete or factual. From information avail-
able to us within a short distance from Eastport, we find that
rather than there being a NECESSITY for refining capacity, there
exists an oversupply condition, and a change in U.S. regulations,
(or even an exception) would swamp this area and New England in
refined products. See The Financial Post, December4, 1976, p. 15,
(copy attached).
We are also disadvantaged in that Pittston’9 PR. efforts
continue’to reiterate hypothetical benefits accruing to Eastport.
We’ve heard of the tax benefits accruing to Eastport, but it has
nev been demonstrated by Pittston or any of the proponents how
Eastport gets those benefits. It has been said that Pittston will
pick up more than 50% of Eastport’s tax —-— but, of course,
Pittston’s base would be far more than 50% of the new tax the
state would require based on the new industrial valuation; and
it has been demonstrated in sworn statement that, one refinery,
or five refineries, do not lead to reduced property tax.: Other
detrimental aspects of such a complex are nowhere described,
such as the hypothetical refinery fire described in the attached
paper. With the residential area downwind fror such a scene,
and. the only road out of town through the smoke and toxic fumes
J 52—21
-------
and past the raging inferno, what are the chances for survival
of the people? Also, more than a thousand marine species of
plants and animals were omitted from the “broad” coverage of the
draft environmental impact statement [ DEIS]. No rare or endang-
ered nwnjnals live in the vicinity of the proposed refinery site
[ according to the DEISJ, yet several families of whales (all but
one of which are on the endangered list) either irthabit the area,
or are frequently encountered here. The refinery’s danger to
the Puffin, because of its nearby nesting area, and-”within--the—
sea” mode of life, is not even mentioned, let alone explored.
As time goes on we. keep piling up evidence f industrial
causes of cancer. The refinery will release various chemical
pollutants to the air and water. Wha * t persistent
levels of pollution do to people? On Friday, December 5, 1952,
static weather conditions turned the air of London, England, into
a deadly menace. A prolonged temperature inversion’ held the City’s
air close to the ground. For five days Greater London was blanketed
in airborn muck. There were 4,000 more deaths than normal for a
five day period. Hospital admissions were 48 per cent higher than
$
average. Respirator ,y illness increased threefold and deaths due to
chronic respiratorj disease increased tenfold. Lest Pittston’s co—
ho ts say it can’t happen here, the same type of static atmospheric
conditions caused a similar incident in Donora, Pennsylvania in
1946 -a town of only 14,000 it had 6,000 residents adversely affected
52—22
-------
.10% seriously. 88 percent of the, asthmatics, 77 percent of those
with heart disease and 79 percent of those with chronic bronchitis
and emphysema were adversely affected. There were 15 to 20 more
deaths than nOrmal during the episode. Allowing for the greater
dLff ...rence in population, Donora paid a higher price forair poll-
ution than London did. Air pollution episodes like these are by
no means uncommon and although alarming, more people are concerned
about the health effects of long-term exposure to air pollution.
The increase in cancer in the last 40 years has been’ 1800 percent.
Yes, eighteen hundred percent The seacoast areas are prone to
the type of inversion incidents just discussed. Many doctors be-
lieve, for that reason, refineries should not be located on the
coast. Think about it, why has Bangor, Portland, and Augusta’s
banking community begun to sing the praises of Pittston and come
out in firm support of locating a refinery “some ihere” in New
England, and particularly in Eastport? ‘Because in our rural set-
ting “it will kill fewer people.” They profess to want the re-
finery “somewhere in New England” but no one in New England wants
this refinery.
Surely, the hearing on December 3, 1976, demonstrated again
what the people of Eastport have been saying since this whole
charade began —-— we don’t want this monstrosity ——— only those
with something to sell to, or something to gain from Pittston or
its employees have ever said they want the refinery.
¼ c c? •
CHARLES A. LEWIS
41 Third Street
52-23 Eastport, Maine 04631
-------
T/lE F1I i C.tAL 9e T ‘:-
: . “a.-.:;
reC # PER t9i C NPSDA ‘1
— — — — I ‘ ‘. t .— ••, ;, , , ,.
• , .. .
i — ‘
out of custOmers
Bj’ ivi. Dxk - . - factor it the shutdown of the Shaheen Pl4nt. Under
• OVi RCAPACflY in the Cantu)ian o l-reflning ‘‘the ‘itew ruling, U.S. refining and marketing
Industry s’iU bxoinc much more acute ovct the ‘ companies c n no lon er pass through the full
next two cars as big new refinery units come on - . processing costs of imported products processed to
stream.’ . . . c:their speei!ication in foreign refineries.
The •siluation is being compounded by the “Something is goin ’rà have to give,” n On-
‘slowing of market gross lb anti the government’s tario oil official has told The Post. :
shnrpcurt a ilmeniofrclinvd-,rothictciporis. . “Either Ottawa is going to have to permit more
• Canadian refining eapacily at present Is np. - product cxpora.sout c it the distress regions, along
proximately two million barrels a day — about. with swap deals. — some already in the planning
I1’ I ahead of the total indicated domestic market stages — with potential -U.S. firms, or cisc a
for refined produ,.ts. This already has produced sizeable chunk of relining capacity is going to have
- price cutting at the gasoline pumps attd has to close dow,
seriously squeezed profit margins. . Even a sharp zesurgence in the economy over the
• But the oi’ersupply is going to be a lot worse by next two-three years would not boost demand for:
• 1978 when sit .dditional 3OO,OOO-3 O,OOO bid of petroleum products sufficiently to absorb this new
additional capacity will have conic on stream in “‘surge of suppy. ‘- - ‘ ‘ . - . :
Ontario and New Brunswick. = ‘ - Higher gn olirie prices, 1a t year’s dip in car
Small wonder the planners of the new Crown sales, and increasing conservation of both motor
petroleum company, PctroCaaada. haiededdcd t and house-hcati,sg fuels have cut the C nadian
stay clear of the refining end of the oil business. “, 1 market for refined products. For some years, up to
From the standpoint of the motorist and 1974, the market had recorded annual gains
oilburningcustoiner. the heavy oversupply is going averaging 5°/s-5½’V,. But last year refinery runs
to mean cut-throal retailer competItion ltd more .- ‘declined — oft 3t/ 5/• front the previous year. The
attractive product prices. . -: forecast is that they will rise 4 ,4’/ ‘ . this year,
The crwf -oil processing plant of the big Indicating a ininiscule IV ’1. gain over the past
:, Pettosar pe ;oehcmical projcct at Sarnia, Ont., is . two years. .
expected to phase into opera’ion next spring. At : ‘. The oversupply situation will vary sharply across
• ultimate designed capacity, it will be producing the country. Taken as -a market unit, the four
ll ,OOO . h/d of refined products. including ‘_Wezrern_g ccs arc fairly well in balance. Inc
aao4iu . s and fiifl t)il . I — — ___________
new Texat à .Cvtäda Ltd. .refinery! at ____________________________________
t4anticoke, Ont., is scheduled to come on stream in ,
March, 1973, with designed capacity 01 95 ,00 -: “P” renning capacity
; lsàè two new i ’nits will boost p s h Oñtario : to take a big jump .
teflnlng capacity by a whopping 37%.Therc’is’ no - •‘ .. - .
way market growth could catch up to this .Ior •, . - -
several years at present annual grow:is rates. • - - . -. •...J - -
Currently. the worst oversupplycOnditions exist , ,.. - -- . . . -
in the Ai!antic Provincà — even with the shut- - , ‘,. cauor cs,aciyv p•i
down of the ShaheiA Nafural Resources refinery at .-‘ ‘ ‘ OF REiINFRIES
come-By-Chance, Nfld. Despite this. Irving Oils ‘ -
Ltd. is nearing completion of a planned doubling - - . -
of .cipacity at its Saint John, NiL, refinery. At a . •. -
reported capacity-of 2S0.000 b/d, this will be the
4argcst refinery in Canada. ‘It will boast Maritirnes
- capacity to about 4 0.000 bid, rougluly70’l. in
excess of th present indictued market.
A change in U.S. regulations, brought in to
protect. the ..U.S. refining industry from rising
product impOrts. hai hit tlw export plans of three
of the Atlanti c rcg oa refiners and has been a major
big Surplus capacity in Alberta from Gulf Oil
Canada and Imperial Oils greatly expanded Ud.
- motion refineries balances out the undcrsupply
situation in British Columbia, Saskatchew n. atid
- Manitoba.
Althosi h the situation at present is not too f r
out of balance in Ontario, this is due to become one
4 ,of the most critical oversupply rcgicnc in two year’s
time, and it seems likely one or more refinery units
will have to hc cIo cd down. 1 here is sonic
speculation that Texaco Canada nsighl dccitlc to
close its 45,000•h/d Port Crcdit refinery once its
flea’ Nanticoke ‘nit is fully opt-r..uive.
Jj-
- - - ‘ -. -
r-, i , ;- .
I... ,,
52—24
-------
IRE FJA RD REFERENCE TO THE PITTSTON REF 1N R? SITE AT EASTflO T, !“IAI ;
EDES APPLICATION NOMBER NEOO22 1 2O - AR iY CORPS PERMIT APPLICATION NO.
5- .76-376
YPOTHETICAL FIRE —. EXPLOS1ON : I2.-t pi o
•,QEXPLOS ION AND FIRE UNDER WORST WEATHER AND ATMOSPHERIC CONDITIONS
AND TIME FACTOR AS SET FORTH IN THE D P- =&’ENVIRONMENTAL IMPACT STAT—
MENT WITH REFERENCE TO THE SAFTEY OF THE POPULATION ON MOOSE ISLAND,
(EASTPORT) .. .US I NG THE EPA’ S £ IS IMFORMAT ION ON ‘INVERS ION ’ qN
-
PAGE 136 VOLUME I I OF THAT REPORT,.. . COMB I NED WITH A PREVA/L NT EAST-
WARD WIND FACTOR AT AN AVERAGE 01 17 MPH WHICH PREVAILS 15 OF THE
TIME FROM JANUARY THROUGH APRIL ACCORDING DIAGRAMS ON PAGE 137’OF VOL-
LiME II AS BEING THE WEATHER AND ATMOSPHERIC CONDITIONS ON THE iSLAND
WERE ESTABLISHED ON A MON ITERING BASIS BENEEN 1931 AND 19k8.
•...ALLOW FOR A CHAIN REACTION OF EXPLOSIONS AND THE BURNING OF THE
CONTENTS OF THE STORAGE TANKS OF THE REFINERY AS THEY ARE LOCATED IN
RELATION TO THE POPULATED AREA OF THE ISLAND. FOR THE PURPOSE OF
ILLUSTRATION OF THIS SCENARIO AN ARTIST’S RENDERING OF THE PROPOSED
REFINERY ON PAGE 212, VOLUME II TOGETHER WITH THE SUPCRIMPOSED MAPS
• -p .4-•’ -
FROM PAGES 195, VOLUME II,(POPULATION-HOUSING CONF IGURAT ION 1 , AND
THE REFINERY SITE MAP FROM PAGE 217, VOLUME II OF THE £15 REPORT.
.
NOTE:
•..IT IS APPARENT THAT THE POPULATION FIRE HAZZARD FACTOR DEMANDS
FURTHER PROVISIONS AND EXPLANATIONS BEYOND THE ONE REFERENCE TO
FIRE SAFETY ON PAGE 2 7( VOLUME II OF THE £15. SUCH QUESTIONS
NEED TO BE RAISED, BASED ON THIS ILLUSTRATED SCENARIO UNDER WEATHER
AND ATMOSPHERIC CONDITIONS WHICH THE EIS SETS FORTH SUCH AS,. OWOULD
THE INITIAL EXPLOSION KILL MORE PEOPLE THAN THE ENSUING SMOKE AND
TOXIC FUME INHALATION,BUT MORE IMPORTANT, COULD THOSE WHO SURVIVED
THESE INITIAL THREATS FiND AN ESCAPE ROUTE FROM THE ISLA ND GIVEN
THE REFINERY BLOCKED NARROW LAND ESCAPE ROUTE AND THE WATER LOCKED
ESCAPE ROUTE TO THE EAST, NORTH AND SOUTH? ...SEE MAP ATTATCHED.
-------
generally reach jnaximum intensity near New Eng1an arid the
Canadian MaritiMe Provinces. One of the worst s crns in
recent years hit Eastport on ‘ebruary 2, 1976. h ts
unusual storm produced, sustained southeasterly w .n s In
excess of 70 mph (miles per hour).
Tropical cyclones of’ the hurricane variety occur Infre-
quently in this area. These late summer and autu=n storms
are more intense than Nor’easters. Of the 11 tro Ical
•cyclones which occurred in the Machiasport coastal area
during the period of record between 1886 Sand 1970, four
reached hurricane intensity.
Inversions . Temperature Inversions refer to situations
when air temperatures in the atmosphere increase rather
than decrease with height resulting In an inverted lapse
• rate. Normally, the greater the distance from the earth’s
surface where heat Is reradlated the colder the aIr, This
pattern is referred to as the normal/environmental lapse
rate.
Inversions occur when warm air overlIes cooler air 3 lImit-
ing its vertical movement. This static condition is
likely to occur when skies are clear with little wind,
resulting In an Intense heat loss during the night through
reradiation. Thus, the ground cools while the air over the
ground remains warm and the stratified air layer remains
stationary. This is called a nocturnal radiation inversion.
Depending on the season, low level Inversions of this sort
occur 20 to 0 percent of the time on the northern Atlantic
Coast. Inversions are the most common meteoro1og cal con-
ditions contributing to Increased air pollution levels for
dispersion of air pollutants is prevented by the absence
of strong winds.
$
Fog . The entire Maine coast, as well as the coasts
of Nova Scotia and Newfoundland to the north and Cape
Cod to the south, are part of the same fog produc .ng
regime.’ These areas are susceptible to occurrences of
varying intensity fog for varying periods o time. The
most severe fog conditions are encountered during the
summer months, at which time the light prevailing
southwesterly winds bring moist, warm air over the cool
water of the area. Radiation of heat from nearby lanìd.
areas or from the top of a pre—existing fog bank tends
to thicken the fog during the dark hours. Thus, the
fogs are more frequent and dense from about midnight
to 8:00 a.m. than later In the day.
•U. S. Department of’ Commerce, Environmental Services Adiinistra—
tion, New England Coastal Fog, Richard Fay, 1967.
136
52—26
-------
Wh\ L) UUhM I flJ J r UU’i h : JM1 h-Mrrw.. tjju tIt-
Average Wind
Velocity, mph
• FEBRUARY
MARCH
Portland, ?Iaine
137
PERIOD OF RECORD 1931-1948
-------
:. .(
(....‘.I . . 8:,id,.*
Ca
52—2
THE PITTSTON Co.
\ ce” Got P\ EASTPORT REF
..f(o ,Fwc II .-123
\ ‘ ‘FIGURE 8
Ii
. ,
N
Jo 1 hnson
Cop.
N
Dog Island
... .,
0
I
0
a
0
- POSSIBLE TR. FFIC OUTES
Iaf nd fjJ PARKIs
— QUCODY VILLAGE BUS ROUTE
POSSIBLE EXTENTIO l OF ROUTE
a
M00110D t Yflt OF
PIT1UON flEFI ERT AND P.S A% AQVODflY T1D. L Pt EK
Iaw.T i r a
1!
1• ”•
-‘I
-------
The design of all oil transf rrir.g operations wIll con-
form to all app1 cab1e re u1atior.s, particularly with
the fol1owin : (1) The State of atne Depart :ent of
Environmental Protection “Oil Discharge ?reve :ion arid
Pollution Control RegulatIons”, (2) The Depart ent of
Transportation, U. S. Coast Guard, “Pollution Prevention,
Vessels ar.d Oil Transfer Facilities”, Volume 37-, —
Number 2 6, Part II, and (3) U. S. Coast Guard, “Security
of Vessels and Waterfront Facilities”, I-lumber CG—239.
‘Fire Protectiqfl . A self—contained fire protection
i item consisting of fire pump stations, distrIbution
piping and application apparatus will be provIded at
each marine terminal. tJnderdeck protection will be
provided at the loading platform by an automatic water
fog system. Provisions will also be made for spraying
foam into manifold areas. Tugs will provide any extra
fire fighting capability required.
Oil Storage and I ovement System . This system sill basic-
ally consist of steel pipelines, storage tanks, pumps and control
valves. It will be the means by which the raw materIal, and the
intermediate and finished products, are moved and stored. There
are to be 66 tanks- in all, with a storage capacity of 13.5
million barrels. The storage tank types and characteristics are
summarized in Table IV—ll. The storage tank and pipeline layout
were previously shown In Figure IV—2.
Transfers to and from the tanks will normally, be controlled
automatically from control stations located near the tanks. The
control procedure will consist of opening/closing valves,
starting/stopping pumps, and accurately monitoring liquid levels
In the tanks. The actions Involved could also be carrIed out
manually. The system will Include both audible and visual warn-
ing devices which will activate when liquid level,s rise to
95 percent of the maximum allowable; if the levels continuft to
rise to 98 percent of maximum allowable, the pumps will shut
down automatically, thereby preventing overfilling and conse-
quent spillage of contents to the ground area around the tanks.
The oil storage and movement system r1ll be ab3ve
gr irid, welded steel. Pittston has agreed to underta :e routine
daIly visual Inspect IOns on the entire tankage and p peiine
network to detect any leakage, and periodic visual a physical
measurement inspections to detect incipient corrosion, stresses,
etc. which may lead to equIpment failure and oil leakage. Any
repairs will be easily made while operations continue. The
over-all oil movement system will also include extensive fire
protection and fire fighting facilities which are described
later. -
2 4 7
52—29
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rABLE IV—11. STOP IGE TANKS
* Horizontal Length
In addition, the oil storage and movement system will be
carefully designed to reduce the amount of hydrocarbon vapors
escaping to the atmosphere. The storage tanks for all raw
materials arid products associated with the refinery will be
selected and designed In accordance with vapor pressure require-
ments as specified in the “Federal Standards of Perforna-. e of
Storage Vessels for Petroieuia Liquidsh ’*. Furtherrn9re, as- re—
quired- by statute, volatile organic compounds with vapor pres-
sures equal to or in excess of 1.5 pounds per square inch
absolute pressure (psia) but less than 11.0 psia will be stored
in tanks equipped with a floating roof, a vapor recover.’ system,
or their equivalent. Products with vapor pressures less than
1.5 psia will be stored in cone roof tanks. Products w1 h vapor
pressures In excess of 11.0 psia will be stored In totally en-
closed pressure vessels of the bullet or spherical shape. All
Federal Ee ±ster, Subpart K, paragraph 60.112, !tarch 8, .974.
2148
52—30
Servicc
No.
Tanks
Capacity:
‘000 BbIs
Dimensions.
i
Diam. Ht.
Crude Oil -
Finished Products
• LPG-C3
• LPG-C 4
* Gasoline
o No.2FuelOil
• No .5 Fuel Oil
Intermediate
• Light Naphtlia
• Heavy Naphtha
• Atino. Gas Oils
• Atino. Residuals
Miscellaneous
10
15
5
6
6
6
7
7
14
14
2
2
3
5,000
27
62
508
2,460
2,280
118
300
705
1,700
110
110
450
264
11
51
120
230
220
100
160
200
252,
100
100
160
52
109
- 5].
42
56
56
• 42
• 42
42
64
40
40
42
Float Roof
Cylinder
Sphere
Float Roof
Cone Roof
Cone Roof
Float Roof
Float Roof
Cone Roof
Cone Roof
S
Cone Roof
Cone Roof
Cone Roof
o
Refinery
Fuel Oil
•
Slops
•
Ballast Water
-------
ARTIST’S RENDITION
AERIAL VIEW FROM THE SOUTHWEST
FIGURE IV-3
LI b
I c
-------
Res 2 onses to Co ents C A. Lewis
Si. Eastport has been subjected to Pittston PR program for the paat ten years.
In the Eastport area there exists an oversupply conditions with respect
to refined products. A change in U.S. policy would swamp the area in
products.
RI. This oversupply of refinery capacity is in Canada and not in the U.S.
S2. Tax benefits that are to go to Eastport have not been adequately outlined.
It has been shown that industrial development does not lead to reduced
taxes.
R2. See FEIS Vol II p. VTE—llff.
S3. The possibility of a refinery fire is not discussed,
R3. See FEIS Vol. II p. IV —53ff, p. X—9.
S4. Wre than a thousand marine species of plants and animals were omitted
from the DEIS. The whales and the puff ins are not even mentioned in
the DEIS.
R4. Co aent noted. See FEIS Vol. II p. VI—28ff, p. 111—109 (revised).
S5. What are the effects on people of low but persistent levels of pollution?
Cites the era iples of London and Donora Pennsylvania and the air pollution
problens that were associated with the inversion.
R5. See FEIS Vol. II p. VI—62ff.
S6. The refinery is proposed for Eastport because in its rural setting, it
will kIU fewer people. The 12/3/76 hearing demonstrated that Eastport
does not want this monstrosity.
R6. Coi uent noted.
52—32
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flFC 16 76
To: U. S. Environmental Protection Agency, Region I, and
U. S. Corps of Engineers
From: Philip Glaser, PhD and Steven Weiss
Subject: Draft Environmental Impact Statement for the Pitts-
ton Refinery in Eastport Maine (NPDES permit appli-
cation # ME 022420, COE permit application #
25-76-367)
Date: 13 December 1976
I testified briefly at the hearing held in Eastport on December
third, and indicated that I would send a letter indicating in
detail some of the concerns I had with the draft of the DEIS,
both ones I mentioned at that hearing and others. This missive
represents that letter.
My affiliation (and that of Mr Weiss, also) is with the
University of Maine at Machias; we are, respectively, Associate
Professor of Science and Adjunct Instructor of Biology. I am
also the First Selectman of the Town of Marshfield. My field
is primarily biostatistics, with an emphasis on applications
in ecology and genetics. Mr Weiss is completing work on a PhD
in entomology specializing in insects in intertidal ecosystems.
We are herein presenting information as individual scientists
rather than as representatives of the University of Maine.
Many of our concerns are related to the possible effects on
the biology of the Washington County 6oast of spilled oil from
either routine operations of the proposed refinery/port or from
marine disasters in the Eastport area. While the probability
of such spiiis may be low (though unknown), we feel that the
potential cost of such potential problems is extremely high, and,
as such demands careful analysis. We feel that the DEIS does
not indicate the requisite care has been adequately demonstrated,
and will cite several specific concerns we have with the DEIS
as approved by Mr MeGlennon on 10/13/76.
On page 87 of the DEIS, it is noted that “high hydrocarbon
levels of 35-64 ppm” exist in Deep Cove from a spiii from a
motor boat kept in the cove; it seems hi h1y unlikely that a
much greater level of hydrocarbons wouldn t be typical when
heavy tanker traffic in Deep Cove is maintained, since the
complexity, size, and number of manipulations concerned with
loading (and unloading) of such ships will certainly exceed
those typical of a small motor boat (which has produced the
noted “high hydrocarbon levels” already noted).
, 3—1
-------
—2—
In page 104, in the list of invertebrates, we have noted the
absence of several species we know to be present, such as
various species of Henrecia. We ass e, however, that the
list of species present in the area supplied by Dr Arthur
McKay includes these, as they are not rare and he will
certainly have them.
On page 106, it is noted that the present clam production for
the Cobscook Bay area is low, due to an oil spill (without
regular tanker traffic), but it is still worth some $2 million.
To invite regular VLCC traffic into this area assures that such
production will be regularly and substantially reduced by oil
spills. We also note that no Canadian clam beds are included
in this discussion, in spite of the statement (12/3/76) that
the effects of the development of the project on the Canadian
environment are to be included. We feel that estimates of
the commercial clam catch for the nearby Canadian beds must
be included in this section.
From the discussion from page 109 through page 122, we have
an indication of the presently assured payrolls (earnings)
at the area of the project right now. This would appear to
be (from the DEIS):
$6,711,000 page 109
6,620,000 116
40,000 117
36,000 120
5,008 000 122
total 18,4l5 cJ00
It would seem that this total may well be underestimation of
the true value, since it does not take into account the non-
commercial fishing, etc. On page 292 the Pittston payroll
is projected to be bout $3,000,000; it would appear that
we are seriously je,pardizing a rather large-industry which
provides relatively extensive (if low paying) jobs for a
relatively small-labor-force industry, in which the highly
paid individuals will be specialists from outside the area
(and the local citizens are likely to end up with the jobs
which pay no better than the ones they presently have by virtue
of fishing).
We note further, that this area is one highly productive in
protein, in the form of fish and in the form of fishmeal.
Since the U. S. foreign policy has been based in part on the
premise that the U. S. will attempt to feed developing (and
developed) nations which are unable to raise adequate food of
their own, and balanced protein is at a high premium in such
a program, and furthermore, that fish meal has been used for
53—2
-------
supplying such protein, that there should be a definite and
explicit consideration of this matter, developed by the U. S.
Department of State, working jointly with the present and
incöniing administrations.
Indeed, while we are concentrating on the energy problems of
New England, there are related problems to consider. New
England also imports much of its food, and the elimination of
food production in the Eastport area will aggravate this situ-
ation in the near future, and possibly profoundly affect it in
the more distant future.
We also note that the direct and indirect effects of oil spills
will affect whales (to some unkown extent), which are endangCred,
redfish, which are endemic to the area, and various species of
ducks and other water birds.
Being familiar with the Downeast coast, and the frequency and
suddenness of onset of the fog here, we are highly concerned
with the navigation of VLCCs in a difficult passage with the
additional streeses caused by the fog. It has been indicated
that no other boats will be under way in the vicinity of an
entering or leaving VLCC (12/3/76). It would appear to us that
it might be difficult to control local traffic in this area,
especially when there is thick fog, and therfore smaller craft
without radar might not be aware of the presence or routing of
a VLCC, or be aware of their own positions. Since some of these
craft are wood, they will not cast good reflections on any radar
set, and since some do not carry radios with which they can
communicate with commercial marine sets, they cannot be kept
informed of VLCC maneuvers taking place. We therefore consider
the situation highly dangerous to local boat traffic, and potentially
dangerous for the tankers. The promise that boats will not bu
brought into port when conditions are not ideal seems to ignore
the reality of commercial transport of oil.
Such commercial transport of crude oil is often contractual for
delivery of a certain load at a certain port at some specified
date or time. No transport company will wish to remain out of
Eastport (in marginal weather) for several days running; such
actions will cost the shipper money, will produce pressures on
VLCC captains to enter the area as soon as possible (whether
safe or not), and pressure from Pittston may also be exerted if
the unrefined crude supplies are nearly or completely exhausted.
If entrance into the area under such conditions (or any other
conditions) leads to a substantial spill, there is another
concern: that of payment of damages. Regardless of whether
Pittston or some carrier is responsible, the damages are likely
to be extremely high. We are not confident that Pittston and/or
53—3
-------
-4-
the carrier are likely to be able to pay for cleanup, damages,
or other claims. In the oil spill off Santa Barbara, California,
a few years ago, the cost of cleaning beaches was approximately
$100 per foot . Those beaches are extremely easy to clean com-
pared to rocky shoreline or mud flats (there is no technology
for cleaning mud flats when a large tidal range exists). Consider
that Cobscook and Passamaquoddy Bays have several hundred miles
of such coast, and estimate some cost of cleaning up such an
environment. Such an estimate should be an integral part of
a complete EIS. In this area, where savings accounts are
generally small, consider who might pay for a family’s living
expenses while liti ation is p}odding along, probably for
years (see Pittston s track record for Buffalo Creek). Another
impact which should be considered and wasn’t.
On page 156, one goal of EPA is identified as to “prevent
significant deterioration” of the environment. The p esent
SO 2 level is described as “typically 3-6 microgram /m ” (p.l56),
and a proposed level (p 159) is 17-22 microgranis/m . THis may
not exceed some arbitrary limit set for urban areas, but still
represents an increase by a factor of as much as 7 or more.
Significant degradation may be defined as exceeding the set
limits, but (as in the case of the noise level increase near
the refinery) may also be defined in terms of a manyfold increase
in the present levels. To ignore this latter category implies
the point of view: “This is what I have to. live in, and so it
is what you will have to suffer, too.” Some of the people who
have chosen to live here have done so because the local pol-
lution levels are.much lower than what EPA considers to be
dangerous. To such people, the proposed degradation may be
significant, and perhaps they should be asked (in an unbiased
fashion) whether they are willing to accept such a change.
On page 193, there is a note of a draft of a Smithsonian
report with regard to conservation priorities. To mention
the existance of such a report is not th same as addressing
the concerns included in such a report. Its contents should
at least be sunnnarized and then discussed directly in terms of
the impact of the construction and normal operation of the port
and refinery, and also the effects on conservation efforts of
abnormal situations. Incidentally, what did the final report
say?
On page 205, there is a justification for the development of
this facility in terms of the reduced distances from this
particular port to the source of crude oil and to the market
areas. Pittston has indicated the expectation of most or all
of the produced oil products being sent to Boston, Portsmouth,
or other southern New England ports. If this is true, it
would seem to make a great deal more sense to move the
refinery and associated facilities to a location in that area,
perhaps using offshore monobouy arrangements for loading and
unloading. Block Island sound might provide an appropriate
53—4
-------
-5—
and partly sheltered location without the problems of currents
and tide and fog.
On page 238, the emergency shutoff valves are described. Given
that the transfer rate is (as stated) lOO,000BPH, this would
mean a quantity of 833.3 barrels would be transferred each
30 seconds. Assuming a linear function and INSTANT response
on the part of the operator, a serious leak in the transfer
system would produce a spill of about 417 barrels (over 17,500
gallons). It would appear that this could pose a serious
threat of oiL spillage and resulting decimation of marine
species.
On page 247, it is stated that “repairs will be easily made...”; :
does not necessarily mean that such repairs will indeed be
readily performed. For example, no indication is made of how
welded repairs might be made in tanks holding such chemicals
as naphtha, gasoline or LPG, especially since leaks may allow
air to enter fixtures as well as allowing products to escape.
Considering the complexity of the structures involved with
the whole facility, it should be indicated just how such
repairs will be made.
On page 253, point 8 indicates that additional treatment
equipment will be needed to cut down sulfur emissions, but
no indication of what nature this equipment will have is
indicated. Furthermore, no indication of its impact is
indicated; does it require more water? More extensive waste
system? More electricity? Does it produce more noise? Does
it represent a safety hazard?
On page 254, there is some indication that Pittston may buy
some 60 megawatts from the local power grid, which means
Bangor Hydroelectric Company. You have not indicated what
effect this will have on the electricity rates throughout the
area served by this utility. It would appear that Bangor Hydro-
electric will be required to run more machinery, including less
efficient units, in order to produce the additional electricity,
and the present customers will have to support the additional
costs of the more expensive electricity. In addition, Pittston
is going to be such a large user that it will get (under present
pricing structures) a highly favorable rate and the smaller
(present) customer will have a yet higher rate. Also, there
presently is no power grid which could deliver 60 M to the
Eastport area, and there is no indication of how such a grid
would be financed. Alternatively, if Pittston is going to
generate its own electricity, where is the EIS for that part
of the refinery installation? What is to be used as a heat
sink? Cooling towers? What effects will that have on fog?
Passamaquoddy Bay? What effects will that have on fog, and
on the biology of the area?
53—5
-------
-6-
On page 274, the possibility of a tnonobouy installation in the
Portland area is discarded as disadvantageous, where it seems
to me that it might be highly advantageous (though there may
be other factors with a Portland area site which could be
seriously disadvantageous). For example, assuming that larger
tankers are more economical (something Pittston has repeatedly
indicated), it could be profitable for Pittston to add pipelines
to nearby exixting (or future) facilities, so that their bouy
could be used to provide loading/unloading facilities to other
refineries. Rent would be charged for this service. This
could allow thE bouy to he used for more hours of the day than
it would be used for a s .ngle refinery of the size Pittston is
proposing for Eastport.
On pages 330 and following, the discussions about air pollution
appears to be in terms of best possible (or perhaps typical)
operating conditions. In many fields, the criteria are based
on worst possible cases, and we feel that it is important to
indicate the problems which would arise under such conditions,
and also to deal constructively with them, indicating such
things as what levels would require that the refinery be closed
down until the problems were corrected, who decides that (and
who he is paid by), what health effects it will have (one time
and repeated basis), and what effects it will have on property.
Perhaps small scale, on site experiments would be req iired.
On page 340 and following pages, EPA discussed a noise level of
70 dBA. T,flijle it is certainly possible to get used to that noise
level and to live in such a situation, medical research in the
past few years has indicated that such noise levels (or even
lower levels) has deleterious effects on health. Such effects
have not been discussed here, and no justification for their
omission has been provided.
There are also a few additional concerns that we have which
result from the testimony proviaed at the hearing at Eastport
or were not presented in either the DEIS or at the hearing. Of
the testimony at the hearing, we felt that since the VLCCs would
be reducing their speeds to 0 knots in the Head harbor Passage
and off Shackford Head, that any simulations of their behavior
should include investigations of their characteristics down to
o knots, rather than the 2 knots used in the models.
In the discussion about the booms to be placed about the VLCC
when it was next to the docking facility, there seemed to be
two points which were inadequately addressed. The first was
that the leading edge of a spill will not be defined by the
location of the booms; it will be determined by the current.
It may well turn out to be perpendicular to the current, thou h
the booms aren’t. The second factor which seemed to be rather
5 3—6
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-7-
lightly glossed over is that of turbulence around the tanker.
Even in a current of 1 knot, there will be a wake (the same as
if the tanker were moving at a knot in open water) and some
resulting turbulance. There seemed to be no concern in the
studies that such turbulence might carry oil under the boom,
or provide enough mixing to allow soluble fractions to enter
the water and be carried off under the boom. Therefore, there
appeared to be little correlation between the study and the
situation described in the DEIS.
While we heard testimony about the use of VLCCs in Head Harbor
Passage from a captain who has handled VLCCs, there has been
no information forthcoming from any pilot licensed to bring
ships into Eastport through the Passage. This appears to be
a major oversight, since such persons are expected to be
familiar with the areas of concern as no others. Are there
no such licensed pilots? If not, where is Pittston going to
get them. If so, where is their information?
In comparing the use of Milford Haven with the possible use of
Eastport, there was a temptation to suggest that the VLCCs
found in each port were likely to be the same. We challenge
that concept on the following basis: in Milford Haven, the
deliveries were (and are) in great part to facilities belonging
to large oil companies which maintain their own VLCC fleets.
The VLCCs which are likely to deliver oil to Eastport are
more likely to be independents registered under Liberian and
Panamanian flags. While that is no guarantee that these ships
will be less competently handled or older (and therefore more
prone to mechanical failure), these ships do seem to contribute
more than their fair share to mishaps to VLCCs. Also, it
appears that Liberia (especially) does not encourage the -
collection of debts from damages done by spillage or other
problems. Again, the question of repayment of shoreowners,
fishermen, etc., for damages may be a long-term proposition.
One final item: during the last decade or two, several
refineries in southern New England have been shut down. While
the reasons for their being closed down may have little to do
with the present application, it would appear reasonable to
suggest that the reasons for this action on the part of Mobil,
Exxon, and some of the other larger oil companies should be
indicated. Furthermore, a clear indication why these same
reasons do not apply to the present project should be given.
While additional criticisms of the DEIS were noted by us, we
believe that others have already covered most of the items we
have noted and not reported above.
53—7
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-8--
(Je would like to thank the EPA and the COE for the opportunity
to testify in Eastport and to submit some of our opinions for
consdierat ion.
53—8
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Responses to Comments by P. Glaser & jjeiss
Si The cost of potential spills is extremely high and therefore the study
deserves careful analysis and the DEIS does not indicate that this care
has been taken.
Ri Comment noted. See revised oil spill section, FEIS, Vol.11, p.IV—38 ff.
S2 On page 87 of the DEIS, it is noted that “high hydrocarbon levels of 35—
64 ppm” exist in Deep Cove from a spi 11 from a motor boat kept in the
cove; it seems highly unlikely that a much greater level of hydrocar-
bons wouldn’t be typical when heavy tanker traffic in Deep Cove is
maintained, since the complexity, size, and number of manipulations
concerned with loading (and unloading) of such ships will certainly
exceed those typical of a small motor boat (which has produced the noted
“high hydrocarbon levels” already noted).
R2 Comment noted.
53 In page 104, in the list of brates, we have noted the absence of
several species we know to be present, such as the various species of
Henrecla. We assume, however, that the list of species present in the
area supplied by Dr. Arthur McKay includes these, as they are not rare
and he will certainly have them.
R3 Comment noted.
s4 We feel that estimates of the commercial clam catch from Canada must be
included. The value of the fish landings will far outweigh any value
obtained from the refinery.
R4 Comment noted. See FEIS Vol. II, p. 111—87, Commercial Invertebrates.
The normal operation of the refinery should not severely impact th
fishing industry in the region. Estimates of all commercial fish
catches in the area are included in the FEIS.
S5 The Eastport area is one highly productive in protein and it is the U.S.
foreign policy to help feed developing and developed nations. There
should be a consideration of this matter developed by the U.S. Depart-
ment of State working with the administration.
R5 Comment noted.
56 New England also imports much of its food, and the elimination of food
production in the Eastport area will aggravate this situation in the
near future, and possibly profoundly affect it in the more distant future.
53—9
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We also note that the direct and indirect effects of oil spills will
affect whales (to some unknown extent), which are endangered, redfish,
which are endemic to the area, and various species of ducks and other
water birds.
R6 Comment noted. The normal operation of the refinery and related
activities will not result in the elimination of food production in
the Eastport area.
/
The effects of a crude oil spill on finfish is not anticipated to be significant
because of their mobility. See FEIS, Vol. II, p. VI—29ff, Oil Spill Effects.
57 It would appear to us that it might be difficult to control local traffic
in this area, especially when there is thick fog, and therefore smaller
craft without radar might not be aware of the presence of routing of a
VLCC, or be aware of their own positions. Since some of these craft are
wood, they will not cast good reflections on any radar set, and since
some do not carry radios with which they can coirununicate with commercial
marine sets, they cannot be kept informed of VLCC maneuvers taking place.
We therefore, consider the situation highly dangerous to local boat traf-
fic, and potentially dangerous for the tankers. The promise that boats
will not be brought into port when conditions are not ideal seems to ig-
nore the reality of commercial transport of oil.
!l The U.S. Coast Guard will regulate the port and control all tanker traffic.
S8 Such commercial transport of crude oil is often contractual for delivery
of a certain load at a certain port at some specified date or time. No
transport company will wish to remain Out of Eastport (in marginal
weather) for several days running; such actions will cost the shipper
money, will produce pressures on VLCC captains to enter the area as soon
as possible (whether safe or not), and pressure from Pittston may also
be exerted if the unrefined crude supplies are nearly or completely
exhaus ted.
R8 The refinery has 20 days of crude storage and Is able to operate at full
capacity for this time period. If weather or other conditions temporarily
limit the crude supply, the refinery will operate at less than capacity.
In the event a cargo is delayed by local conditions from offloading its
cargo, the additional charges are the responsibility of the recipient.
S9 Who will be responsible for the payment of damages resulting from an oil
spill?
R9 See FEIS, Vol. II, p. X—5 ff.
53—10
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Sb EPA is not living up to Its goal of the prevention of significant deteriora-
tion of the environment.
RlO EPA will issue a PSD (Prevention of Significant Deterioration) permit to
the Pittston Co. only if they meet all applicable requirements.
Sll On page 193, there is a note of a draft of a Smithsonian report with
regard to conservation priorities. To mention the existence of such a
report is not the same as addressing the concerns included in such a
report. Its contents should at least be summarized and then discussed
directly in terms of the impact of the construction and normal operation
of the port and refinery, and also the effects on conservation efforts
of abnormal situations. Incidentally, what did the final report say?
Ru The above referenced report was never issued in final form so that dis-
cussion of its comments at this point is inappropriate.
S12 On page 205, there is a justification for the development of this facility
in terms of the reduced distances from this particular port to the source
of crude oil and to the market areas. Pittston has indicated the expecta-
tion of most or all of the produced oil products being sent to Boston,
Portsmouth, or other southern New England ports. If this is true, it
would seem to make a great deal more sense to move the refinery and asso-
ciated facilities to a location in that area, perhaps using offshore mono—
buoy arrangements for loading and unloading. Block Island Sound might
provide an appropriate and partly sheltered location without the problems
of currents and tide and fog.
Rl2 Comment noted. See FEIS Vol. II, p. V—l ff, p. X—42 ff.
Sl3 On page 238, the emergency shutoff valves are described. Given that the
transfer rate is (as stated) 100,000 BPH, this would mean a quantity of
833.3 barrels would be transferred each 30 seconds. Assuming a linear
function and INSTANT response on the part of the operator, a serious leak
in the transfer system would produce a spill of about 417 barrels (over
17,500 gallons). It would appear that this could pose a serious threat
of oil spillage and resulting decimation of marine species.
R13 If an unloading line were to part, oil would spill until the onboard
tanker pumps are turned off or the motor operated valve on the tanker
deck is shut off. Land—based operational personnel at the pier together
with the tanker—based personnel supervise the of f loading of oil. The
greatest quantity of oil would be lost when the off loading is at maximum
capacity — lines under full pressure and pumps operating. When offload—
ing crude oil, four 16—inch loading units are in operation. The crude
is pumped from these lines into two 36—inch lines which connect to the
refinery tank farm. In the event of a break in a 16—inch line, the on—
board tanker pumps would be immediately turned off by supervisory tanker
personnel. At the same time, the motor operated valve on the tanker
deck would be shut off. The land—based operational personnel would also
53—il
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proceed to close the motor operated gate valve on shore. Because of the
immediate drop In the of floading line, the pressure due to the pump shut
down and the closing of the two motor operated valves, the spill emanating
from a complete break would be considerably less than the 200 barrels.
The tanker oil collection trough together with the deck of the tanker
will serve to contain most spills of this nature. Before unloading
operations begin, the tanker is surrounded by containment booms as a
precaution in the event the tanker deck and tanker collection trough
are not adequate for the containment of oil.
In the event of a 36—Inch line break, the procedures that would be taken
to rectify the problem are identical to those outlined for a 16—inch line.
The catastrophic spillage would amount to 400 barrels — but again, this
figure would be considerably reduced because of line pressure loss from
pump shutdown and the effect of closing the two motor operated valves.
Experience has shown that by far the majority of “breaks” in the off—
loading units are not breaks per se, but rather leaks, splits in piping,
etc. Rarely does an of floading unit part completely resulting in crude
losses outlined above.
The boomed area around the VLCC has the capacity to contain spills and
oil quantities of this nature.
S14 On page 247, it is stated that “repairs will be easily made . . •“; this
does not necessarily mean that such repairs will indeed be readily per-
formed. For example, no indication is made of how welded repairs might
be made in tanks holding such chemicals as naphtha, gasoline or LPG,
especially since leaks may allow air to enter fixtures as well as allow-
ing products to escape. Considering the complexity of the structures
involved with the whole facility, it should be indicated just how such
repairs will be made.
R14 All repairs and associated activities are covered and regulated by various
safety and insurance codes. Regulations and procedures are stipulated in
Occupational Safety and Health Administration (OSHA) and American Petro-
leum Institute (API) codes.
515 On page 253, point 8 indicates that additional treatment equipment will
be needed to cut down sulfur emissions, but no indication of what nature
this equipment will have is indicated. Furthermore, no indication of its
impact Is indicated: does it require more water? More extensive waste
system? More electricity? Does it produce more noise? Does it represent
a safety hazard?
R15 The Federal NSPS (New Source Performance Standards) prescribe tail gas
scrubbing.
Also see FEIS, Vol. Il, p. X—37.
53—12
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S16 On page 254, there is some indication that Pittston may buy some 60 mega-
watts from the local power grid, which means bangor Hydroelectric Company.
You have not indicated what effect this will have on the electricity rates
throughout the area served by this utility. It would appear that Bangor
Hydroelectric will be required to run more machinery, including less effi-
cient units, in order to produce the additional electricity, and the
present customers will have to support the additional costs of the more
expensive electricity. In addition, Pittston is going to be such a large
user that It will get (under present pricing structures) a highly favorable
rate and the smaller (present) customer will have a yet higher rate.
Also, there presently is no power grid which could deliver 60 MW to the
Eastport area, and there is no indication of how such a grid would be
financed. Alternatively, if Pittston is going to generate its own elec-
tricity, where is the EIS for that part of the refinery installation?
What is to be used as a heat sink? Cooling towers? What effects will
that have on fog? Passamaquoddy Bay? What effects will that have on
fog, and on the biology of the area?
R16 Under present plans, the refinery will generate its own power with a small
turbine unit firing 0. 1% sulfur fuel, with the flue gas discharging into
the main stacks. Cooling will be with air as the heat sink. Final EIS
contains the Impact of this generation on air quality. However, if it
proves feasible to purchase electric power before final designs are com-
pleted, this will be done with purchases at rates approved by the Maine
Public Utility Commission.
S17 The possibility of a monobüoy installation in the Portland area seems
highly advantageous to me.
Rh Comment noted. See FEIS Vol. II p. v—i ff.
S18 On pages 330 and the following, the discussions about air pollution appears
to be in terms of best possible (or perhaps typical) operating conditions.
In many fields, the criteria are based on worst possible cases, and we
feel that it is important to indicate the problems which would arise under
such conditions, and also to deal constructively with them, indicating
such things as what levels would require that the refinery be closed down
until the problems were corrected, who decides that (and who he is paid
by), what health effects it will have (one time and repeated basis), and
what effects it will have on property. Perhaps small scale, on site
experiments would be required.
R18 Counnent noted. Air emissions were handled In the worst case framework.
Tables VI—l6, VI—18, VI—19 and VI—20 deal with maximum emIssion releases fron
the refinery operations. These maximum emission rates are specified
by permit and the Pittston Co. faces fines and/or revocation of their
permit if these figures are exceeded.
Sl9 On page 340 and following pages, EPA discussed a noise level of 70 dBA.
While it is certainly possible to get used to that noise level and to
live in such a situation, medical research In the past few years has
indicated that such noise levels (or even lower levels) have deleterious
effects on health. Such effects have not been discussed here, and no
justification for their omission has been provided.
53—13
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R19 These subjects are contained in Vol. III DEIS Appendix H.
S20 Of the testimony at the hearing, we felt that since the VLCCs would be
reducing their speeds to 0 knots in the Head Harbor Passage and off
Shackford Head, that any simulations of their behavior should include
investigations of their characteristics down to 0 knots, rather than the
2 knots used in the models.
R20 When the tanker in transit is down into the 2—0 knot range, it is almost
entirely under the control of the assisting tugs and therefore, simula-
tions of the suggested condition would be of no value.
S21 The leading edge of a spill will not be defined by the location of the
booms; it will be determined by the current. It may well turn out to
be perpendicular to the current, though the booms aren’t.
R21 Agreed, the direction of a moving spill will be determined by the current.
Booms will be placed in such a manner that the spills will be contained
through the perpendicular placement of booms to the oil spill or placement
of booms at oblique angles to divert the oil to calmer water for recovery.
See FEIS, Vol. II, p. IV—38ff, Oil Spill Containment and Recovery.
S22 In a current of 1 knot, there will be a wake (the same as if the tanker
were moving at a knot in open water) and some resulting turbulence. There
seemed to be no conóern in the studies that such turbulence might carry
oil under the boom, or provide enough mixing to allow soluble fractions
to enter the water and be carried off under the boom. Therefore, there
appeared to be little correlation between the study and the situation
described in the DEIS. -
R22 See the FEIS, Vol. II, pages IV—38 ff, Oil Spill Containmeut and Recovery.
The technology-and techniques involving the use of oil booms and associated
skimmers is continually being improved. For example, studies performed
by B.A. Folson and C. Johnson of Ultrasystems, Inc. and presented at the
March 1977 011 Spill Conference sponsored by the EPA, U.S.C.G. and API
demonstrated that a specific streamlined oil boom is capable of retaining
and recovering oil spills in currents up to 6 knots. However, this system
performs best in wave conditions under one foot. Also this oil boom is
a research prototype and not yet available commercially.
S23 The DEIS does not contain any information on pilots licensed to bring
ships Into Eastport. Where will Pittston get the pilots and will they
be licensed?
R23 The pilots that Pittston will be using will be trained and licensed.
53—14
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S24 in comparing the use of Milford haven with the possible use of Eastport,
there was a temptation to suggest that the VLCCs found in each port were
likely to be the same. We challenge that concept on the following basis:
In Milford Haven, the deliveries were (and are) in great part to facili-
ties belonging to large oil companies which maintain their own VLCC
fleets. The VLCCs which are likely to deliver oil to Eastport are more
likely to be independents registered under Liberian and Panamanian flags.
While that is no guarantee that these ships will be less competently
handled or older (and therefore more prone to mechanical failure), these
ships do seem to contribute more than their fair share to mishaps to VLCCS.
Also, it appears that Liberia (especially) does not encourage the collec-
tion of debts from damages done by spillage or other problems. Again,
the question of repayment of shoreowners, fishermen, etc., for damages
may be a long—term proposition.
R24 Comments noted. Also see FEIS, Vol. II, p. X—5 ff.
S25 During the last decade or two, several refineries in southern New
England have been shut down. While the reasons for their being
closed down may have little to do with the present application, it
would appear reasonable to suggest that the reasons for this action
on the part of Mobil, Exxon, and some of the other larger oil companies
should be indicated. Furthermore, a clear indication why these same
reasons do not apply to the present project should be given.
R25 Comment noted. The reasons for the shutdown of the above—mentioned
refineries were economic in nature. The proposed refinery and its
economic justifications are explained in the FEIS, Vol. II, p.IV—I ff.
53—15
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Testimony Given by P. Claser at
Dec. 3, 1976, Public Hearin g
MR. GLASER: Gentlemen, I live in Marshfield, Maine,
near Machias. I teach at the University of Maine at
Machias, primarily Biology courses, but some other
science and some math courses. My background is in
Biology in statistics and in computer simulations.
Incidentally, I am also First Selectman of Marshfield,
however, I am talking as a concerned individual rather
than as an employee of the University of Maine or as
an officer of the Town of Marshfield.
I wish to consider the draft of the Environmental
Impact Statement, as I was given an opportunity to
read the summary and Volumes II and III. I have some
fairly specific items which I am concerned about from
Volume II. Before the 13th of this month, I and one
of my colleagues, Mr. Stephen Weiss, will write you
a detailed letter, but I would like to discuss a few
of the points nevertheless.
There are several aspects which concern me, and
some of these have already been discussed, but I would
like to again briefly bring them to your attention.
One is the question of what I consider inadequacies
in the treatment of the question of oil spill, both
in terms of containment and what should happen if it
53—16
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is not successfully contained, which I believe is an
issue that has not been dealt with at all.
In the hearings before the Board of Environmental
Protection, there were some questions here, and rather
than discuss it in detail here I would refer you to
those hearings, which were held in this school in 1974,
concerning, for example, the question of the availability
of hay for absorbing oil after it had been spilled, if
it could not be controlled; furthermore, the disposal
of hay that had been mixed with oil.
One of the things that I have gathered is that not
only does the statement deal with absolute levels in
parts per million or micrograms per liter, or whatever,
of various possible problem chemicals, but that there
has to be some kind of an approach taken with regard
to degradation. And I would like to cite one example
in this case with regard to sulfur dioxide emissions,
as described on page 156 of Volume II. At this point
you have a statement that it is typically .001 to .002
parts per million or 3 to 6 micrograms per cubic meter,
and the proposed refinery may raise this rate to as
much as 17 to 22 micrograms per cubic mete:, which
appe r tc me to be about s much as a e on or
fold increase, which I think is substantial. And just
looking at the figures and saying this is low relative
53—17
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to some arbitrarily set standards I don’t think is
telling the whole story.
If EPA’s responsibility then is indeed to find in
terms of quality of life, people in this area in East-
port and in Washington County, and in neighboring
Canadian areas have a certain quality of life, and
part of the reason that some of them are here is because
of the cleanliness of the environment, and this might
represent a significant degradation in quality of life,
even though it means no exceeding of present standards.
Another point that I would like to raise is that we
are talking repeatedly in this hearing about shortage
of energy. shortage of oil, shortage of electricity,
and this is a very real shortage and it will certainly
be felt much harder, much worse, in the future. There
is another shortage which I would like to see discussed
in some length in the Environmental Impact Statement,
and that is the shortage of protein. This is one that
most parts of the gorld are feeling very much more
severely than we are feeling a shortage of energy.
Indeed, most of the world is malnutritiOfled. And if
our federal policy continues to be that we should supply
food, and particularly protein rich food, to areas of
the world which are not able to grow that or produce
that on their own, we have to consider the continued
53—18
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availability of protein.
Dr. MacKay’s discussion a few minutes ago and those
of some others have indicated that this area is indeed
a rich producer of fish 1 and fish is a good source of
protein in terms of being well balanced in our own
requirements of amino acids. I feel then that if we
are really talking about any significant danger - and
I personally feel that we are - to this, whether it
is from oil spills or anything else — and I think oil
spills are the serious problem here — then I think that
we must discuss the effects not only on our economy.
our state of nutrition in this country, the corresponding
ones in Canada, but how this is going to affect our
policy in terms of feeding the world.
Another item - this is one that I would like you to
check into, because I am not at all confident about
this - some years ago I lived near cast P:o ce, and
at that time I believe Mobil Oil had a refinery in East
Providence, Rhode Island. I understand from some others
that there were refineries in Massachusetts. All of
these I gather have been closed down, although I noticed
in a mention today that instead of what the DEIS said,
that there is no refining capacity in New England, there
had been a little bit of hedging and it was reworded
53—19
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281.
that there was no significant refining capacity, or
something like that. And it seems to me that to have
existing refineries close down says something about
oil management in New England.
Now, whether Pittston is talking or proposing some-
thing that is so completely different in terms of the
breaking down of crude oil into refined products, that
we are entering a wholly new state of technology or
not, I don’t know, because I don’t know anything about
the refineries that no longer are in operation. But
the fact that these refineries were indeed in operation,
and re no longer, says something to me about the need
for refineries and the economic advantages or dis-
advantages of :efineries ir New England.
I do have a number o otner items, but obviously we
are going to be running late andl think that I will—-
MR. McGLENNON: If you want to send them along, I
will be sure that they are considered and included in
the record.
MR. GLASER: O.K., I would like to mention one more
though. (Applause) And that is that in the list of
species, families and so on, generally speaking there
53—20
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282.
has been no indication, with the exception I believe
of the TRIGOM Report, of whether they are common or
rare. This is a step in the right direction 1 but I
think there has to be a further step in the right
direction, and that is what the economic importance
of each of these species is. I realize this is going
to be hard to assess in many cases, and may not be of
great importance in many cases, but I think there are
some where it would be worthwhile.
Thank you.
MR. McGLENNON: Thank you, Dr. Glaser. (Applause)
Could you wait?
MR. STICKNEY: I would like to make just one short
comment about the degradation issue and air emissions.
We are constrained by the laws we are supposed to
enforce and, as you might expect 1 degradation has an
official definition with the allowable amounts of
degradation carefully spelled out for various classes
of areas. The allowable amounts are not zero, and the
emissions here apparently will fall within the allowable
amounts. So whereas we might agree that it is an impact,
or perhaps a significant impact, these air values are
4
53—21
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values which fall, within the official definitions
which are set really to protect the public health and
welfare.
MR. GLASER: I realize that. Mr. Weiss, whose name
I mentioned at the beginning of this, did have the
impression - and both of us will check on this — that
in addition to noting possible problems with specific
levels of various emissions that the whole issue of
quality of life was one that EPA was responsible for
/
investigating, and that is why I suggested it in that
context.
53—22
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Response to Comments by P. Glaser
Comments noted.
See EIS Vol. II p. Commercial Invertebrates iii—.87ff
Oil Spill Effects p VI— 29ff
Air Emissions p VI— 62ff
The availability of hay for use as an absorbing medium for spilled oil is
dependent upon the supply and time of year. Absorbant material such as sorbent
pads, rolls and granules will be kept at the refinery site and additional
quantities warehoused with Metropolitan Petroleum Co., Inc. Disposal of hay and
sorbent materials mixed with oil will be carried out in accordance with all local
and state regulations.
All air emissions must be in compliance with EPA nondegradation
regulations.
At one time there was some limited refining capacity in New England. The last
facility was an Esso facility located in Everett, Massachusetts which closed in
1960. The reasons for its closure were economic in nature.
53—23
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DEC 1 6 ? 76
Rt. 1, J3ox 133
Eastnort, Maine 0L 1 .631
November 11, 1976
U.S. Environmental Protection Agency
hegion I
i nforcement Division, Permits 3ranch
John F. Kennedy Federal Bui1din
oston, ‘assachusetts O?2 ’)3
RE: ME r O22I 1 2O PIPTSTr N APPLTC L’PTON
Dear Sir:
Volume II of the draft environmental impact statement refers
to the source of water for the proposed Pittston refinery but it
does not comment on the condition of the underground and underwater
conduits,
Public hearings at Eastport have shown that the water
cornoany cannot account for about fifty (SO) nercent of the water
which it numps from Boydens Lake. It is not known where the leak-
age occurs. Consequently the conduits are under constant repair.
Wate” cornoany e nployees always seem to be digging up and patching
thepipes. Some of the cinduits are under sea water and a diver
has told me that they are in very poor condi tion,
It is doubtful that a refinery can be kept constantly
operating and the city .adequately protected against fire unless
the system is replaced. In the event of any i ater shortage the
refinery complex wDuld get the water and not the city. In c ce
of fire—-the refinery is adjacent to the only roadway ou 4 - of
Eastport——a leaky systeri an t! nrobability of a mayor break
and water loss in the system is bad to contemplate.
Figure ui—) 4 (geologic map) of t” impact statement shows
the subsurface fracture system in the area as being inferred
whereas, according to the map, it appears to be known. This
fracture system pnsses under the refinery site. A seismic station
at Machais, 1 aine has detected repeated seismic activity during
the past several years. From current earthquake reports throughout
the vorid seismic activity is increasing in frequency and severity.
Si, 9 erely ours,
ones
Ge clog is
54—1
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3y now it should be c vir ent that cnc rgy n eds t be conserved.
Orr ‘ ny of conserving oil I c to dc v 1op tidal energies. The
vc ry best place for this in th Ii8eonterrninous United States
is here-—a refinery doesn’t need to come here--it can be built
elsewhere. It can be located elsewhere in anàrea notvital for
tidal power.
There have been various schemes of placing of dams in
the area for the generation of tidal energy.
A one pool one cpt with just one is usually overlooke
which would be entirely within Maine--the bottling up of Cobscook
Bay by a short darn between Shackford Head and Seward Neck.
The Corpsof ENgineers could undertake such a development--
the first in the United States which would bring credit to the Corps.
Rut should the Corps approve the Pittston apt lication
that opportunity w”uld be gone.
The Environmental Protection Agency was formed, one
hones, to guard our environment as the name “environmental -
protection” implies. The Agency has been given a public trist.
Now I am disturbed when I read in the newspapers that
th ‘n ‘ y not !‘° living u to this trust. I a referring
to the re noval of Mr. Francis Mayo from his post as administrator
of the Great Lakes Region Five.
t would like to paint out that there will soon be a
n ”- administration in Washington. Ford is going so is Simon,
and so is a senator from California, Mr. John Tunney, a
Pittston board t eriber. In view of these and other changes
it 1JoJlfi b’ prudent for the Agency not o be too hasty in its
‘iecisio”.
54—2
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- 2 - (Robert S. Jones)
The impact statement lists a few of the gaseous and
particulate matter that will be dropned on the local people
but it does not say what affects these will have on the people
that reside here and must bear them. What affects does beryllium
have on humans, sulfuric acid, nitrous oxides and other compounds?
Omitted entirely were the unknown affects of the trace elements.
J ven though the refinery has not been built in Maine we are
subjected to an acid rain. whi h is worse on the coast than
inland Maine. This has worsened in the last 20 years.
Maine ranks fo th in the nation in chronic lung disease. On this
will be superimposed the refinery effluents. Can the Agency
guarantee that the location of the refinery here will not decrease
the life snan of those living here?
What many believe to be a glaring omission in the EPA
impact statement is the lack of background informat on on the
apnlicant; that is, since the Agenc5’s missionis environmentai
a substantial part of the impact rep t ought to be about the
environmental background of the Pittston Company.
Supposed that we elected our president, our senators,
our representatives on what they promise and not on what they ‘ r€?
There is ample information available in a thc and or more
newspaper articles, maga inea and books about the Pittston
Company. he Book of the Month Club ‘ 8S
publiseci .8 book on the Pittston. Company--this will
automatically insure that it is a best seller.
About five years ago a mining dump..in Wales gave way
and over 100 school children lost their lives. Stewart Udall,
then Secretary of the Department of the Interior 1 not wanting
such a tragedy to happen in our country had the U.S. eological
54—3
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- 3 - Robert S. Jones
Survey send geologists to visit all mines where dumps or tailing
ponds have been constructed throughout the U.S. Pittston’s
workings on Buffalo Creek l4ere examined. The Pittston Company
was told of the unsafe condition of their tailings pond-—they
should have known it all-along . They were so told by the Federal
inspectors as well as those from the State of West Virginia
again, again, and again.
Pittston took no action until their tailings pond
collapsed and 12S men, women, and children died. Pittston then
went into action-—they blamed the whole thing on God!
Pittston has settled out of court at least $i1 .,Ooo,ooo
in damages and they still have anumber of large suits pending
against them.
Federal inspectors have found the Pittston Company
at fault in the majority of fatal accidents on their property.
In 1971 Federal inspectors filed more than ,OOO safety
violations against Pittston.
Last year while the Pittston Company was before the
Maine Bureau of Environmental Protection it as brought out that
they continued to violate environmental laws. Nevertheless
in their closing statement before the Bureau Pittston had the
temerity to state, “We understand the present day climate of
opinion and we understand the lawand we intend to abide by both.”
Pittston--the company that has brought us strip-mining--
their record is clear and un quivocable—-its bare-boned rec3rd
has been rublished throughout the media of North méri’a.
Can you imagipe the reaction from this headline,
“EPA approves company with worst environmental record?”
Lastly I leave with you a copy of an article appearing
in the Washington Monthly , “The P.ttston Mentality:
Manslaughterat Buffalo Creek.”
. iL it_i-
54—4
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II
Li. 1. :3 *‘M £
1
atn r on
4u’ i-f I
Creek
by Thomas N..Bethell and Davitt McAteer
Repnnt d from The Washingion Monihi
May. 1972
(C
Cop ri ht I91
The W ishington Mor hIy Co.
1O 8 Conn ti u NW
Washington. D.C. OO36
-.-
7
54—5
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Reaponee to Comments by R.S. Jones
Comment noted. The refinery will not endanger the city water supply
system in any way. Because of the improvements that will be required
to meet the refinery d miinds, th tranamiss1 on system will be
reinforced. See FEIS, Vol. II, p. 111—194 and VI—l8ff, Water Supply
System (Existing and Impact).
See FEIS, Vol. II, p. VI—62ff, revised section on air resources;
III—159ff, revised section on tidal power projects; IV—53ff, X—9,
regarding fire protection.
54—6
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U.S. Environmental Protection Agency
Region 1, boston, Ma. 02203
re; proposed oil refinery at z astport, he.
Lbear sirs,
After reading ,olume 1 of your E.I.S.I have some questions.. The report
indicates that sulfate emissions may have an adverse effect on human
health. What is the exact definition of acid mist? What research has your
department done on this subject? Is there any research which is available
on ‘acid mist.?” In what specific way does sulfate emissions combined
with fog affect human health? What parts of the human anatomy would be
adversely effected? Would this adverse effect on human health be perman-
ent? Is there any possibility that acid mist could create a serious health
disability? Could the acid mist affect the flora, fauna, and marine life?
Since acid mist is directly related to sulfate emissions what would be the
estimated amount of 8ulfates discharged per stack, per day? What amount
does your department consider acceptable? Can acid mist be prevented?
Who wil]. monitor the sulfate emissona? Would there be fines imposed if
the acceptable amount of sulfate emissions are exceeded? How much would the
finesbe? How much sulfate emieson would constitute a serious health hazard?
I would appreciate answers to these questions t the present time I
am opposed to an oil refinery at Eaetport. There/too many unanswered quest-
ions. The oil refinery on the Cobscook Bay is a terrible risk
yours truly
Iason Strongin
R.D.htl Box 179
Lubec, Maine o +6
Response:
Comments noted.
See FEIS Vol. II, p. VI—78.
55—1
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21 DEC 1975
College of the Atlantic Dec. 22, 1976
Bar Harbor. Maine
U.S. Environmental Protection Agency
Environmental Impact Statement Group
JFK Federal Building
Boston, MA
Dear Ladies arid Gentlemen,
I would like to take this opportunity to add to the testimony
regarding the Draft Environmental Impact Statement about the
construction of an oil refinery at Eastport, Maine, by the
Pittston Company. I presented oral testimony at the December 3
hearing in Eastport. This letter will summarize the comments I
presented there. In addition, I am including additional material
about the possible impact of the refinery on marine mammals of
that region.
The draft EIS was deficient in the following areas, in my
estiniat ions
1) It did not contain any economic analysis of’ the amount c i’
money and the number of jobs contributed by the fishery
industry in the region which would be impacted by the
refinery and its consequent operations. The final report
should certainly contain an economic analysis of the
impact of spills at various times arid under various
conditions. This should be done in equal detail as was
the analysis of the possible economic benefits of the
project.
2) The draft EIS should be modified to make clear the fact that
the fishery industry is actually very healthy in the
Eastport-Quoddy-Fundy region. Although American fishermen
are currently experiencing some difficulties, Canadian
fishermen are making a great deal of money. The fish
are there in great numbers. However, the Canadian fishermen
either use a different technology (weirs arid stop-seining)
or else obtain government help for purse-seining operaticns.
American fishermen do not receive government help at this
time in sufficient amounts to help them compete with the
Canadians. My personal feeling is that energy and money
should be utilized to to rebuild American participation in
the fishery The Passaznaquoddy Bay area is one of the
most productive regions along the entire east coast of’
the U.S., a fact which has been detailed in numerous
scientific publications arid which has been clearly summarized
by Dr. Arthur McKay of Marine Research Associates, Deer Island
New Brunswick, in testimony presented to the EPA. This
ecosystem can be relied upon to provide food, jobs and money
for hundreds of years to come if’ managed properly. The
introduction of hazardous substances into this system is
sure to jeopardize our harvest from it.
3) The draft EIS fails to assess the possible importance of
the development of a4uaculture projects (or other new
fishery technologies) in the Eastport area. The area is
56—1
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an ideal location for such undertakings, because it obtains
a large energy subsidy from tidal action which brings nutrients
into the surface water, removes wastes, and refreshes the
medium in all respects. The Passainaquoddy Nation, for example,
has been investigating aquaculture projects for several years
as a possible source of income which is consonant with their
interests and experience.
Ii.) The portion of the draft EIS dealing with the effects of
chronic, low—level exposure to oil should be revised in
several ways. First, the calculations of the amount of
oil which would be released during normal refinery operations
are open to serious question, as a result of testimony
presented at Eastport. The large flow rate from the se ’age-
treatment and waste-treatment systems will introduce
substantial amounts of petroleum into the surrounding waters
even if the petroleum content of treated waters is small
when expressed on a per-liter basis,
Furthermore, the estimate of the amount of petroleum
which will be spilled in “minor spills” is in error. The
draft EIS states that the 36-inch pipelines running to shore
will carry 100,000 barrels of oil per hour (p.237) and will
be equipped with fast-action emergency valves capable of
closing in 30 seconds (p. 238). Up to 900 barrels of oil
could escape during the half minute required for the valve to
close, considerably more than the 20-86 barrels per year
which the EIS said would be spilled. Even one spill of
this size would considerably change the impact projected by
the draft EIS.
In addition, the draft EIS should certainly include
information on the known carcinogenic danger of low-level
contamination by oil residues. Data summarized in the
Tanker Advisory Service Report for the first half of 1976
(appended to this letter) show that up to 19 potentially
carcinogenic compounds have been found in crude oil,
including benzo-(a)-pyrene and benz-(a)-anthracene, which are
known carcinogens. Number 6 fuel oil contained up to 330 parts
per million of carcinogenic substances. Crude oil from Kuwait
contained about 12 ppm. Since the refiner ’ would be receiving
crude oil and producing No. 2, No.5, and gasoline, chronic
leakage (or major spills) would introduce known carcinogens
into a food chain which is already relied on for the production
of large amounts of human food. It is important to stress
that these substances cannot be detected by taste, color
or other means which the fishery or consumer normally employ.
The statement that fish caught in the area of a spill are
“not tainted” does not prove that the product does not
contain hazardous substances
5) I think that the draft EIS is j drastic error in accepting
the analysis that operation of the refinery should be
compared with Milford Maven, one of the cleanest oil ports
in the world. This is a complete disregard for statistics
which is hard to comprehend. Events of the past week, in
which a tanker split in half in Los Angeles Harbor, an oil
barge grounded in the Potomac River, and the Argo Merchant
56—2
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Katona-3
grounding ard oil spill jeopardized the entire c eorges Bank
fishery must be considered a forewarning of what will happen
in the Eartport region if a refinery is built. Only one
statistic need. be quoted herei 85% of all accidents involve
human error (see p.79 1 -li, Travers, W.B. arid P.R. Luney, Drilling,
tankers, and oil spills on the Atlantic Outer Continental Shelf,
Science l 9 Li ( 4267):79l-796, Nov. 19, 1976, copy appended
to this letter). In light of this statistic, the operation
of the refinery should certainly be compared with worldwide
statistics, which are summarized in the Tanker Advisory
Center’s 1976 report included below. The people of Eastport
who support the refinery have certainly turned their backs
to the possiblility of major spills, as was evident at the
December 3 hearing. The EPA has an obligation to face this
event as a statistical certainty more honestly arid more
scientifically than was done in the draft EIS. How can the
Pittston Company guarantee that the Argo Merchant disaster
would not happen here.
It should also be pointed out that no data were presented
to compare the climates of Ivlilford Haven and Eastport, and
t e tidal comparisons are not adequate, On December 3, gale
warnings flew outside the auditorium where the hearing was
held in Eastport. Winds upwards of LI.O ] ots were expected.
The temperature was below zero arid the chill factor was -60F .
P ose conditions are not unusual during winter at Eastport.
As the Argo Merchant disaster showed, our technology
not adequate to clean up oil spilled under such conditions.
Furthermore, I severely doubt the ability of humans to
function near water under those conditions, even if the
technology were adequate Finally, the EIS should. contain
a comparison of the frequency of fog, sea smoke, high winds,
arid other conditions which contribute to accidents at
Milford Haven and Eastport in order to better evaluate
the risk of spills.
Concluding this section, the Pittston-sponsored analysis
of tanker performance in wind and tide was deficient. it
did, not include the conditions prevailing on December 3,
nor were company officials prepared to say that tankers would
not operate under such conditions. The final EIS should
certainly contain an evaluation of the performance of tankers
under far worse conditions than the 20 kt winds and 2 kt
currents which were investigated. Furthermore, the limits to
operation of those vessels should. ‘be mentioned.
6) Although I feel that a consideration of the fishery in the
Quoddy region shottid be sufficient reason for discouraging
the installation of an oil refinery in the region, I want
to take this opportunity to mention the possible impact of
that project on marine mammals of the area.
My main research involves studying the distribution,
abundance, and migrations of whales arid porpoises in the
region between Cape Cod arid Nova Scotia. The Passainaquoddy
region is one of the most important habitats for sbme of
these animals along our entire coast. Although some of
this information was mentioned in the draft EIS, the
following points must be stressedt
56—3
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a) Head Harbor Light on Campobello Is. and West Quoddy
Head are two of the best places along ur coast where
people can see cetaceans from land (see p. 6 of Katona
et al A field guide to the whales and seals of the
Gulf of Maine, available from College of the Atlantic,
Bar Itarbor, Maine 011.609, 1975, a COPY enclosed fox
the record). The opportunity for people to see marine
mammals from land is rare, and such fortunate situations
should be preserved.
The same processes which make the Eastpor-t region
productive fishing grounds also make them attractive to
marine mammals. Finback whales, minke whales, and right
whales are the most common large whales of the area.
Humpback whales can also be foundslightly farther
offshore. Harbor porpoises are the main toothed
cetaceans to be found in the area, however white—sided
dolphins and white-beaked dolphins are also seen in
large schools at times. Although there is a great year
to year variation in the distribution of some species,
the following points appear to be true.
Large whales are most commc n in the area from
July through September. Right whales appear to use
the area as a major feeding ground during late summer
and early autumn. Very few right whales survived the
excessive hunting carried on by Europeans, American
Colonists and American whalers during the course of the
past thousand (hunting for this species is known to
have been done in the 11th century) years. No reliable
population estimate exists, but experts suppose that
several hundred right whales remain alive. The Gulf o1
Maine appears to be their major summer habitat. During
Spring they are found in Cape Cod Bay, Massachusetts
Bay and on offshore banks. During late summer they
are found in the Quoddy region and off Grand Ii Ianan Is.
It is clear that the region proposed for the refinery is
a very impor ant part of the range of this eMangered
species. It should be noted that the right whale
may be more susceptible to oil effects than are other
species, because it tends to feed near the surface and
often on the surface. It also skims food from windrows
on the water, where plankton accumulates. Unfortunately,
oil accumulates there,too.
As shown in Whales of the Gulf’ of Maine:1975 (the
1976 report is in preparation now) many finback whales
and harbor porpoises were reported by our observers
in the Quoddy-Grand Manan region during September and
October. The exact number of animals found there is
not yet possible to estimate. However, on a field trip
this year organized the Schoodic Chapter of the Maine
Audubon Society, we were able to observe 67 harbor
porpoises during a L I. hour cruise on September 26.
Results compiled by Dr. David Gaskin of the University of
Guelph, Ontario, Canada, and by our research group,
indicate that the Passarnaquoddy Bay area is the
center of the harbor porpoise population. That is, the
species appears to be mor common in this area than
-------
Katona—5
anywhere else along the whole coast of the United
States.
During Summer of 1976, our research group initiated
a new project on Grand Manan Island in order to study
the whales of that area. Although the distribution of
large whales differed considerably from that in 1975,
large numbers of finback whales and at least 5 right
whales were seen, in addition to hundreds of harbor
porpoises. The results of this project are now being
analyzed, however, they confirm the great importance
of this area as a marine mammal habitat. Additional
studies are needed in order to calculate the numbers
of whales, porpoises, and seals wh .ch frequent the
area. A period of years will be required for obtaining
those results. However, it already appears to be
true that the region is of significant importance as
a marine mammal habitat arid that it should be protected
from deterioration.
I will be glad to supply additional data from
our research files on the dates of marine mammal
sightings made in the Eastport area, along with
numbers and species of animals seen and associated
information. Please notify me if that information would
be useful.
I would like to mention that the Marine Mammal
Commission has recommended that offshore leasing
on the Georges Bank be delayed until the effect on
marine mammals can be predicted more reliably. That
recommendation, which was a matter of public record
before the Argo Merchant catastrophe, was based in
part on the possible deterioration of the habitat of
the right whale. I hope that events in Eastport do
not threaten the habitat of this species at the same
time that other agencies are attempting to maintain
the quality of another important part of its range,
Copies of the Marine Mammal Commission’s report may
be obtained from the Commission, 1625 Eye St in
Washington, D.C.
i appreciate the consideration of the EPA’sPittston EIS group
and hope that these comments are helpful. My personal position is
that I am opposed to the refinery and think that the Eastport area
would be better served by the development of fishery-related efforts
and industries which would not jeopardize the harvest from those
extraordinarily rich waters. These are my personal comments, spoken
as a private citizen.
Yours sincerely,
Steven K. Katona, Ph.D.
Faculty in biology
5 6- 5
Li. enclosures
-------
N DEC 7G
- %t+ IE1
I rnt
!1&HAUS
in
The G Uof4 ne
1975
Gulf of Maine Whale Sighting Network
College of the Atlantic
Bar Harbor 1 Maine 04609
Non-Prolit Organlz.
U.S. POSTAGE PAID
Bar Harbor. ME 04609
Permit No. 47
56—6
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01 iV.a..*’ I tG.iVdPL 1J (H IccL
00 •. =
MARINE MAMMAL COMMISSION
1625 EYE STREET, N. W.
WASHINGTON, DC 20006
8 December 1976
Dr. Steven K. Katona
College of the Atlantic
Bar Harbor, Maine 04609
Dear Steve:
I am forwarding a copy of the Commission’s letter to
the Bureau of Land Management concerning the Draft Environ-
mental Statement for OCS Sale No. 42. Your extensive cri-
tique of the DES was invaluable to the composition of this
letter. Thank you again for providing your comments.
I also have enclosed a form for your use in providing
whatever consent you feel is necessary and desirable to
facilitate consideration of your proposal (MMC-136). Be-
cause the Commission would like to provide a careful and
complete review of your proposal, we may want to disclose
it to outside reviewers and other agencies. Provisions of
the Privacy Act of 1974; 5 U.S.C. 552a, prevent us from dis-
closing personal information (e.g., personal vitae and budget
items such as salaries) to persons outside the Commission,
its staff, and its Committee of Scientific Advisors, without
the written consent of the individuals of whom that informa-
tion pertains. Please return the completed form in the
attached envelope as soon as possible.
Sincerely,
Jane W. Anderson
Assistant to the Scientific
Program Director
Enclosures
56— 7
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Testimony Given by S. Katona at
Dec. 3, 1976, Public Hearing
MR. KATONA: I am Steve Katona. I teach Ecology
and Marine Biology at the College of the Atlantic. i
am speaking as a private citizen. My doctorate was in
Biology, with a speciality in Marine Biology, and right
now my main research is on marine mammals, especially
whales and porpoises.
It is perfectly obv1ou just from our research on
whales that this area is one of extraordinarily high
productivity. It is probably one of the very few
most productive areas in the whole Gulf of Maine.
For that reason I am particularly concerned that the
draft Environmental Impact Statement did not evaluate
the local fishery revenue that is obtained within the
region that would be impacted by any of the activities
surrounding the Pittston proposal.
Although there is data for Washington County as a
whole and for Charlotte County as a whole, it is very
difficult to determine exactly how much damage would
be done, how many jobs would be lost, how many weirs
would have to be cleaned up for any particular spill.
Now, these data are probably available, and computer
simulations or any standard economic analysis would
be possible to simulate typical spills under any given
56—8
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conditions, and I think that the final impact statement
should definitely include as precise an estimate as
possible of the damaçe that would be done to all of
the fisheries.
Furthermore, I think that the draft is deficient in
not evaluating at all the potential of further fishery
or new resources. As Art MacKay has pointed out,
the fishery is thriving just across the border.
I would also like to call attention to the draft
method for evaluating the potential oil spills that
might occur here. I am very puzzled at the method
that was used; namely, the comparison of this site
with Milforci Haven in Wales. On the one hand, at
2:00 P.M. today, Wally Stickney said that data from
all the ports in the world operating on all conditions
must be considered in judging what the potential spill
occurrence would be here. On the other hand, on page
300 of the draft statement it says that none of the
existing data — or it says that worldwide statistics
have little significance in making projections for
specific locations or conditions. I am very puzzled
about that, and I don’t think that it is valid to
assume that this new facility would actually have an
operating and safety record equivalent to what is
acknowledged to be one of the cleanest and best ref inerç
locations in the whole world.
56—9
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to large spills that will occur from tankers, and some
method has to be devised for evaluating the frequency
of those spills. Today tankers spill about 40% of
the 3.3 million tons of oil that enter the ocean each
year. About 80% of those tanker accidents occur in
coastal or harbor regions. 85% of all accidents will
involve human error. Because of that one fact, I am
very uneasy to hear Mr. Kaulakis tell us that in the
final situation itwill be up to pilots and tanker
captains to determine what are safe conditions. That
is where human errors will enter this situation.
Also, although there are some similarities between
the Eastport location and the Milford Haven location,
I think that there are some definite and important
differences, and .1 do not see any data in the impact
statement on these differences. For example, what is
the occurrence of fog in the Milford Haven area? What
are the temperature and climatic differences? Today
nobody seemed to think that it was a very unusual day,
but there were two flags out and there were gale
warnings. The chill factor this morning in Bar Harbor
was minus 60, and I almost got frostbite from being
outside for less than five minutes without gloves. I
56— 10
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287.
want to know what the efficiency would be of people
trying to clean up an oil spill in conditions like
this when they would be working in water.
I also want to know, in view of the fact that
nobody thought that today was a very unusual day and
in gale warnings, meaning winds of something like 40
knots or so, why the simulations that were done on
tanker passage through Head Harbor Passage did not
include winds up to 40 knots, why they stopped at 20
knots. I don’t think that is a very responsible way
to approach a simulation.
Recent articles have indicated that by 1985 there
will be something like two strandings and one collision
or accident for every 50 tanker service years. In fact,
these things rc happening every day. And the Tanker -
Advisory Service in New York, which keeps track of all
tanker casualties throughout the entire world, has
listed 419 partial and total losses for the first and
second quarters of 1976 alone, which involved spillage
of 163,400 tons of oil, the loss of 43 lives, and 20
injuries. These things will happen here, andl want
to know what their effects will be. I think that the
56—11
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288.
final Environmental Impact Statement must evaluate
them more precisely than has been done here.
I am also concerned about the effect of low—level
oil leakage as a result of small spills. For example.
the impact statement says that 20 to 86 barrels per
year will likely be spilled into the waters surrounding
the Pittston refinery. I am very puzzled about that
figure. which seems very low to me, especially in view
of the 36—inch pipeline that will transfer oil from
incoming tankers at a rate of 100,000 barrels per hour
to the refinery site and will require. according to the
impact statement. 30 seconds to shut down. At 100,000
barrels per hour, 30 seconds is sufficient to allow up
to 600 b&rrols of oil to escaoe, which is ten times
rr ro t n t.he r a: irnurn !o -1 vel average spillage suggested
by the report.
Finally, I am rather distressed to find that the
impact statement draft fails entirely to mention any
carcinogenic effects of oil components. Data summarized
by the Tanker Advisory Center Report indicates that crude
oil from Kuwait contains about 12 parts per million of
carcinogenic compounds, including benzopyrene and
56—12
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289.
benzanthracene. No. 6 fuel oil contains 330 parts per
million of these carcinogenic compounds. I think that
the final impact statement certainly ought to consider
the implication of entry of these carcinogenic compounds
into the food chai.n as a result of either low—level
spillage or major disasters.
Thank you. (Applause)
MR. McGLENNON: Thank you, Dr. Katona. Wait a minute,
Wally Stickney would like to make a comment on your
remarks.
MR. STICKNEY: I appreciate your considered comments.
I did want to clarify one issue though, and that is I
agree absolutely with what I wrote on page 300 of the
impact statement, and this is why: the tanker spill
record that is available now is a record composed of
spills emanating from all ports in the world, all sorts
of ships, under all sorts of conditions. You might be
able to rationalize that into a semi—reliable prediction
for, say, the amount of oil spilled in east coast ports,
or the amount of oil spilled in Gulf ports, or some such
thing as that. But to take the data that is available
and predict with any degree of precision what would
56— 13
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happen in a particular port, which would be utilizing
a particular type of ship and a particular port control
system. is very shaky at best. That is our problem and,
as I said before, we will consider any advice that we
get on how better to do that.
56-14
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Response to Comments by S.K. Katona
Si. The DEIS did not contain any economic analysis of the amount of
money and numberof jobs that would be impacted by an oil spill
and refinery operation.
Ri. See FEIS, Vol. II, p. VI—4ff.
S2. The DEIS should be modified to make clear the fact that the
fishing industry is thriving in Eastport—Quoddy Fundy region.
R2. Comment noted. See FEIS, Vol. II, p. III—87ff, Commercial
Invertebrates.
S3. It is my feeling that energy and money should be utilized to
rebuild American participation in the fishing industry.
R3. Comment noted.
S4. The DEIS fails to assess the possible importance of the develop-
ment of aquaculture projects.
R4. See FEIS, Vol. II, p. 111—159.
S5. The portion of the DEIS dealing with the effects of chronic, low—
level exposure to oil and the amounts discharged in the refinery
effluent are in question.
P .5. The amounts are given in mg/I of effluent and also in quantitative
terms of pounds per day and gallons of oil per day.
See FEIS, Vol. II, p. VI—28, 29.
S6. Furthermore, the estimate of the amount of petroleum which will
be spilled in “minor spills” is in error. The draft EIS states
that the 36—inch pipelines running to shore will carry 100,000
barrels of oil per hour (p. 237) and will be çqulpped with fast—
action emergency valves capable of closing in 30 seconds (1. 238).
Up to 900 barrels of oil could escape during the half minute
required for the valve to close, considerably more than the
20—86 barrels per year which the EIS said would be spilled. Even
one spill of this size would considerably change the impact pro-
jected by the draft EIS.
R6. If an unloading line were to part, oil would spill until the on—
board tanker pumps are turned off or the motor operated valve
on the tanker deck is shut off. Land—based operational personnel
at the pier together with the tanker—based personnel supervise
the of floading of oil. The greatest quantity of oil would be
lost when the of f loading is at maximum capacity——lines under full
56—15
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pressure and pumps operating. When of floading crude oil, four
16—inch loading units are in operation. The crude is pumped
from these lines into two 36—inch lines which connect to the
refinery tank farm. In the event of a break in a 16—inch line,
the onboard tanker pumps would be immediately turned off by
supervisory tanker personnel. At the same time, the motor
operated valve on the tanker deck would be shut off. The land—
based operational personnel would also proceed to close the
motor uperated gate valve on shore. Because of the immediate
drop in the offloading line, pressure due to the pump shut
down and the closing of the two motor operated valves, the
spill emanating from a complete break would be considerably
less than the 200 barrels.
The tanker oil collection trough together with the deck of
the tanker will serve to contain most spills of this nature.
Before unloading operations begin, the tanker is surrounded
by containment booms as a precaution in the event the. tanker
deck and tanker collection trough are not adequate for the con-
tainment of oil if a spill should occur.
In the event of a 36—inch line break, the procedures that would
be taken to rectify the problem are identical to those outlined
for a 16—inch line. The catastrophic spillage would amount to
400 barrels——but again this figure would be considerably re-
duced because of line pressure loss from pump shutdown and the
effect of closing the two motor operated valves.
Experience has shown, that by far the majority of “breaks” in
the offloading units are not breaks per se, but rather leaks,
splits in piping, et . Rarely does an offloading unit part
completely resulting in crude losses outlined above. The boomed
area around the VLCC has the capacity to contain all spills and
quantities of oil of this nature.
SI. The DEIS should include information on the known carcinogenic
danger of low—level contamination of oil residues. Up to 19
potentially carcinogenic.compounds have been found in oil.
thronic leakage or major spills would introduce these substances
into the food chain. These substances cannot be detected by
taste, color, or other means which the fishery normally employs.
The statement that fish caught in the area of a spill are “not
tainted” does not prove that the product does not contain hazard-
ous substances.
R7. Releases of these substances from normal refinery operations
will be in very small concentrations and well below levels that
are injurious to human or wildlife health and welfare.
In the event of a substantial spill, the Introduction of these
substances into marine environment will occur and may possibly
5 6—16
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be in quantities deleterious to marine life.
See FEIS, Vol. II, p. VI—56.
S8. The DEIS is in drastic error by accepting the analysis that the
operation of the refinery can be compared to Milford Haven. This
is a complete disregard of statistics which is difficult to
comprehend.
R8. See FEIS, Vol. II, p. X—26ff.
S9. Events of the past week. . .Argo Merchant.. .is only a preview of
what will occur here in Eastport. Eighty—five percent of all
accidents involve human error and, therefore, the operation of
the refinery should be compared with worldwide statistics in
the Tanker Advisory Center’s ATC Report. How can the Pittston
Company guarantee that the Argo Merchant disaster would not
happen here?
R9. Comment noted. The Argo Merchant spill occurred on the open
ocean whereas in Eastport the tanker passage is a semi—enclosed
channel. Furthermore, in the case of Eastport the tankers will
be brought into harbor by trained pilots and the channel will be
equipped with navigational aids.
SlO. No data were presented to compare the climates of Milford Haven
and Eastport. Tidal comparisons were inadequate. On 12/3/76 gale
force winds and temperatures below zero were experienced. The
Argo Merchant clearly showed that our technology is not adequate
to clean up oil spilled under such conditions. The FEIS should
contain comparisons on the frequency of fog, sea smoke, high
winds, etc. Pittston tanker simulation studies did not evaluate
conditions in excess of 20 knot winds and 2 knot currents.
RiO. See FEIS, Vol. II, p. X—26ff.
Sli. The Passamaquoddy Region is one of the most important habitats
for whales and porpoises. Head Harbor light and West Quoddy Head
are two of the best places to see marine mammals from land. These
opportunities are rare and should be preserved.
Ru. Comment noted. The normal operations of the refinery will not
result in this activity being prevented or interrupted.
S12. It should be noted that the right whale may be more susceptible
to oil effects than are other species, because it tends to feed
near the surface and often on the surface. It also skims food
from windrows on the water, where plankton accumulates. Unfor-
tunately, oil accumulates there, too.
56—17
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R12. Comment noted. See FEIS, Vol. I I, p. 111—1091 f, Marine Mammals.
S13 . Studies have shown the Passamaquoddy Bay area as the center
of the harbor porpoise population and other mamm il populations
and, therefore, should be protected from deterioration.
R13. Comment noted. See revised sections, FEIS Vol. II, p. 1II—lOgff.
S14. I will be glad to supply additional data from our research files
on the dates of marine mamal sightings made in the Eastport area,
along with numbers and species of animals seen and associated in-
formation. Please notify me if that information would be useful.
I would like to mention that the Marine Mammal Commission has
recommended that offshore leasing on the Georges Bank be delayed
until the effect on marine mammals can be predicted more reliably.
R14. Comment noted.
56—18
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Testimony Given by H. Stence at the
December 3, 1976 Public Hearing
Mr. Stence: I am Hank Stence fr m Lubec, Maine.
My statements this evening are consisting of three
basic parts. I will try to keep these as short as
possible.
Part one, what I call my short introduction of
general opposition.
57—1
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324.
Part two, why I am opposed to the proposed Pittston
oil refinery at Eastport.
And part three, questions I wish to have answered
by the EPA or other authoritative sources as in
reference to the three—volume impact statement. I have
limited these because of time.
Part one is what I call my short introduction of
general opposition, and I feel this way: From the
conglomeration of all knowledge presented to this date
pro and con, I. with total understanding in mind and
sincere feelings in my heart, have formulated the
following conclusion: that if this proposed oil refinery
is constructcd, the results will be chaotic shambles
because, fc r crie, w iere there is r cwer there is money,
r cj ..here is gre d. There shall
develop a dog eat dog, monstrous monetary gains geared
society to such proportions that few present local
citizens shall ever live their remaining days in con-
tentment.
Now, in part two, I have limited the following
objections to the proposed Pittston refinery to speak
in behalf of basic accepted facts. I realize I cannot
57—2
-------
325.
inject my personal reasons for coming to this area
and wishing to live in this area, just as Pittston
cannot fairly present their reasons for desiring to
build the refinery in Eastport. The fact that must
be analyzed is the total impact of eastern Washington
County. Again, the fact that must be analyzed is the
impact of this area. Thus, for the following 14
reasons I object to the Pittston oil refinery in
Eastport.
1. The Canadian Government still refuses entrance
through Head Harbor Passage of oil carriers of the
very large crude carrier class.
2. The vast responsibilities arid impact consequences
are not a mere local concern; rather this is an inter-
national matter exposing a direct threat to Canadian
fishing and tourist industries.
3. The refinery’s approval will cause involuntary
rezoning of properties not only in Eastport but in
other areas of Washington County.
4. There will be an involuntary land tax increase
as a result of the Pittston plants and secondary
industries such as chemicals and social supportive units,
57—3
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326.
meaning simply when the property value of land goes up
the taxes likewise climb.
5. The unavoidable and cumulative detrimental effect
on all species of fowl, fish, foliage, and human life,
to include a future cause of loss of life in all four
mentioned categories: to simply say there will be accidents.
6. A direct discriminatory effect on all individuals
with fixed incomes, meaning the majority of the surrounding
townspeople with fixed incomes will be unable to meet the
increased cost of living and will be forced to sell their
properties, of which most buyers will be from out-of-state
interests.
7. Cost of living and earned wages will not climb
at a proportionate rate to meet the demand of the majority
of east. a:n shington County.
8. The non-containable, rampant growth rate influenced
by monetary power, an expansion that will equal the
industrial cities of New York and New Jersey within five
to ten years. Related to this question is the uncertain
leadership of all immediate areas to handle proper,
democratic development of such an industrial community.
9. The fishing related industries will diminish to
57—4
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327.
eventual extinction without the need of a large oil
spill by simply being exposed to the allocated 5,000
gallons of transfer spillage allowed for the accepted
standards,, coupled with the allowance of 60 pounds of
oil and grease discharged into the waters daily.
10. The formulative opinion from publicized sources
that Pittston possesses a non-negotiable. negative
attitude stating to the effect that it will be our way
‘or it wont be at all.
11. The m inority will benefit while the majority
of the present employed population will be forced to
the industrialized form of life. The majority of the
benefactors in this proposed refinery are not living
in Maine at this present time.
12. The substantial increase in all forms of crime
that are in cOmmon with greater numbers and with larger
communities.
13. The complete elimination of any possibility of
ever harnessing the tides and natural aquaculture.
14. Organized labor will be forced upon the area
to the extent that very few will be hired from eastern
Washington county, and for each non-union member who
57—5
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328.
is put on the job, they will spend on the average of
four years’ apprenticeship before they are unionized.
Also, unions of associated support systems will cause
pressure on others to unionize.
Now, my final portion here is just to wrap up some
questions I have. In the case of such as today, where
there is a mist prevalent on the water,, how many days
on the average are under such conditions, and what
measures would be taken in the event of an oil spill?
No. 2, is it true that unless very large class crude
carriers of 250,000 DWT be employed •the Pittston proposal
would not be feasible?
No. 3, what detrimental effects do sulfuric acid mist
and other emitted suif ides have on surrounding foliage,
animal life, and bodies of water?
No. 4, in reference to Volume I, page 23, the alter-
natives available to Eastport, I wish to know who is
responsible for the following statement: “Attempts to
vitalize the marine industry has already proven fruitless,
and because of its remote location a deep water port
would not appear to be of value except as an oil port.”
That is Volume I. page 23.
57—6
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Finally, I will end up on this question: What.is
the definition of a protected or sheltered harbor?
Is Shackford Head immune to high winds?
Thank you. (Applause)
Mr. McGlennon: Thank you, Mr. Stence.
57—7
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spc aes to Ovments by’H. Sta ce
S1.Canadian opposition to the USC of head harbor Passage for the transport of VLCCS.
Ri .Mr. Richard Vine, Assistant Secretary of State for Canadian Affairs, in a letter to Mr.
John MeGlennon of EPA, stated that the Canadian Issue of tanker passage was
not an appropriate topic of discussion for the EIS.
$2 . Responsibilities and Impact consequences are an International matter.
R2 See FEIS Vol. II p. VI29ff., Oil Spills and Chapter X.
S3. The refinery will cause rezoning of properties In Eastport and other areas of Washington
County.
R3. See FEIS Vol. II p. VI—lff,Soclo Economic Impact
94. Land tax Increase wilt occur as a result of the refinery and secondary industries.
R4. See FEIS Vol. lIp. VFllff.
S 5. At times when a mist is prevalent on the water what measures will be taken in the event
of an oil spilt?
R 5. If an oil spilt should occur during a period of adverse weather, every effort will be made
to contain and recover the spilt keeping the safety of the spilt crew and equipment foremos’
in mind. It is obviously more difficult to clean up a spill in adverse weather
conditions.
s 6. What are the effects of sulfuric acid mist.
R6. See FEIS, l. LI, p. VI- 78ff.
57—8
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—2—
S 7 • Who is responsible for the statement: :Attempts to vitalize the marine Industry has already
proven fruitless, and because of its . . . as an oil port. DEIS Vol. 1
R7. EPA is responsible for the statement. Attempts to revitalize the marine industry and
industry in general are outlined below.
Ma rifle and Industrial ttcviia [ i za tion
In the recent past, E as (port has endeavored to a [ tract new indus try wl ich would utilize its
municipal port and marine resources. In 1973, the Eastpo -t City Council sent out a brochure
detailing Fastport and what it had to offer in the way of skilled labor and natural resources.
One hundred inquiries were sent to electronics, shoemaking and paper rein ted industries. A
total of six replies were received and none expressed an interest in Eas tport.
The most recent attempt to garner industry into Eastport was In January 1977. City Council
tried to arrange for the use of the Eastport pier as a shipment terminal for potatoes. They
lost the opportunity to Searsport because of the lack of funds for the purchase of an $80,000
sea anchor. Drought—related potato market conditions in Europe motivated this project, and
this, at best, it was a temporary activity.
For the past six years Maine Central Railroad has petitioned the Interstate Commerce Com-
mission for abandonment of service to Eastport in its entirety. ‘fhIs petition was denied and
another filed in October 1974 is pending. Traffic has decreased from 503 cars in 19G7 to an
average of 250 cars per year at present. The City Council has urged the ICC to turn clown the
railroad’s petions for abandonment. This is done with the hope that sufficient industry will
locate in Eastport to justify an economic existence for the Eastport spur which jrescntly d ,cs
not E iz1.
The Council has also mi tinted talks with Georgia — I aci fic and other paper concerns as to the
use of Eastport as a shipping port for pulp. To date, these attempts have been fruitless.
In 1 9G9—J 970 plans were drawn for the construction and opera lion of a plant for (he manufac(ur
of pearl eSSenCe, fish meal and high protein concentrate. The plant, Sen Life Industries, was
heavily subsidized with State funds and after only a few months of pro—operation activities, fil
for bankruptcy in 1973.
57—9
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—3—
AttcrnpLs to specifically revive the fishing in the area have been non—existent except for the
experimetal proj eeL bci rig undertaken by the I ‘assa maquoddy Indian Tribe at Pleasant L’oint
Reservation and a fey small aquaculture projects.
S8. What is the definition of a protucted or sheltered harbor?
R8. A harbor is considered protected when it is almost entirely surrounded by land and pro-
tected from the open sea.
S 9. Is Shackford Head immune to high winds?
P’9. Shacklord Head is not immune to high winds
57—10
-------
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Response to Comments by E. & R. Coakley
Response : Coninents received and noted.
See FEIS Vol. II P. VI—38 ff 011 Spill Effects
P. VI—l ff, Soclo—Economic Impacts
P. 111—36 ff, Current and Tidal Pattern in the area.
P. VI—28 ff, Chronic Discharges
P. IV—23, Marine Transport System
P. 111—118, Fog.
P. 111—159, Federal Projects
P. VI—78, Acid Rain
P. 111—70, Endangered Species
The occurence of a line storm as described in the comment is unclear. What
is described is the seasonal shift in the prevailing winds which occurs
throughout the middle latitudes. Eastport is located at 44° 54’ Latitude and
67° 00’ Longitude, and not the 42nd parallel as noted in the comment. This
information is included in the FEIS Vol. II p. 111—143 ClImatology.
58—6
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DeesRbsf3 1976
D.ar Siz’:
As a physcian concerned with the health hazards in $astport, Maine,
I wish to state a few facts from a professional point of view. The
record shows that a definit, health hazard has existed here for many
years. All attempts to rectify this hazard on the local, state, end
federal levels have been defeated.
At the present time noxious and hazardous f saes are visible and
originate in an area adjacent to the site of the propèsed refinery.
Such ftaies. iiould compound the problem of fwnes from the proposed
refinery.
It is an accessive fact that these refinery f anes contain a high per-
centage of sulphur compound resulting in sulphuric acid ithich is
deleterious to both external and internal body structures, these
include: I.) a serious skin irritant for the healthy and
most serious for those with pre-ex.istant skin disease, 2.) the
cause of irritation and resulting disabling of the eyes. 3.) A
hazard for those with reapiritory problems such as, bronchttus,
.uphyoeme and sinusitis. 4.) to the young and elderly id ose resis-
tance may be less.
These acid fwaes have been the ruination of vegetation around
ref inerys and led to the destruction of stone structures as wi].
The e can be expected of Emstport.
In conclusion my opinion, a severe oil spillage from a tanker
imould have little effect on the health of the people in this area.
There has been much discussion concerning oil spillage, but the health
hazart to the young and old has been totally ignored.
A combination of the present fLines combined with those from a
refinery in association with a typical F.astport fog presents
lethal atmosphere.
From a public health point of view, the citizens can expect an
increase in skin, opthalnic and respiratory problems. And these
14 D
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59—1
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problems can vary from a uui.q c. to deadly consequences.
I submit thes. fact.. have not been given full consideration in the
hearings of the past.
Shott lived economic gain. mist be compared to the permanent hazard
of an active oil ref mary.
Respectfully submitted,
John .. Sullivan M.D.
95 Pleasant Plaee
Kearny, New Jersey 07032
aid
176 Water Street
Eaatport, Maine 0 +631
Response:
Comments noted.
See FEIS Vol. II, p. VI—78
for Information on acid rain.
59-2
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10 DEC ‘ STh
RFD1
Augusta, Maine 04330
December 6, 1976
John NcGlennon, Administrator
Environmental Protection Agency
Room 2303
John F. Kennedy Federal Building
Government Center
Boston, Mass. 02202
Dear Sir:
This letter will serve as a commentary on certain EIS aspects
of the Pittston’s Eastport refinery proposal and to ask questions
which I, and many of my colleagues, believe should be answered.
The decline in sardine canning operations in the Eastport area
can, in part, be attributed to the decrease in the supply of canning
size herring and an unknown percentage of the decline in herring can
be attributed to the unprecedented increase in the fishing of mature
herring stocks outside state territorial waters by foreign vessels,
since New Brunswick has also experienced a comparable decline in
herring stocks.
There is no justification for equating Eastport and its approaches
with the Milforci Raven site. Testimony at the Pittston Oil hearings
more than adequately demonstrated the differences between the two
sites and in particular the vulnerability to an oil spill of renewable
marine resources westerly along the Maine coast and downstream from
Eastport.
To the best of my knowledge, there have been inadequate bioassays
of the effects of different oil fractions on different marine species,
both flora and fauna. My observations of the effects of heavy oil
fractions on marine algae differ from those stated on page 7 of the
Enviro—Sciencea report, Section VII. Furthermore, it has been my
observation that some species are more sensitive to certain fractions.
than are others, and for that reason, I cannot accept without supporting
data the statement that subtida]. animals living above the sediments
would be less likely to be harmed than those living in the sediments.
This might be true of ff.nfish which could escape the area and it would,
of course, apply in the case of Long Cove, Searsport, where extensive
oil residues remain in the sediments five years after the initial spill.
Page 31, Vol. II, of the EPA Draft EIS is grossly in error with
respect to employment since approximately one—third of those employed
in Washington County are employed in the fisheries alone.
61—1
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John McC,lennon —2— December 6, 1976
Page 106. “In 1974, 12 lobster and crab licenses were issued to
individuals in Eastport, and of the 40 or so boats that fish for
lobster in Washington County, it is estimated that possibly 15 use
Cobscook Bay.” The number of boats is completely in error. In 1973,
862 licensed lobster fishermen operated 819 boats; in 1974, there
were 1132 lobster fishermen.
Pages 313—314. Appears to contradict conclusions reached else-
where in the EIS.
Page 360. The EIS fails to consider the extent of contamination
resulting from an oil spill, still trying to limit such contamination
to Eastport alone, a completely false assumption as has been demon-
strated by the many recorded spills in the Gulf of Maine from the
1974 spill at St. John, N. B., to the 1963 spill at West Cod Ledge
at the entrance of Casco Bay.
Vol. III, Page A—6. Comparing fish processing waste with petro—
leum hydrocarbons in their impact on renewable marine resources is
ridiculous. There is no possible way to equate fish oils with petro-
leum oils in their toxic effects on the biota.
Vol. III, page 11. “Generally Pittston has shown such capability
to entrap and remove oil ap 1 is at the Deep Cove product piers.” This
is a statement that is completely without factual support. There is
no evidence whatever that Pittston has either the capability, compe-
tence, or intent to accomplish these objectives.
Vol. III, page 21. “No oil vessel of greater than 70,000 DWT
shall carry oil or refined petroleum product or by—product to or from
Pittston’s marine oil terminal.” This restriction does not appear to
be meaningful. A spill of #2 fuel or gasoline from a less than 70,000
DWT would be much more devastating to renewable marine and estuarine
resources than a comparable size spill from a 250,000 DWT loaded with
crude.
It may be of some significance that the most derogatory information
on product oil spills came from the research by EPA ’s laboratory in
Rhode Island.
The questions which I strongly believe should be answered for the
Maine public are as follows: (The Pittston Company itself has admitted
enough derogatory evidence in its testimony to warrant denial of a
permit to build a refinery at Eastport).
1. Why did EPA in the draft EIS quote national security? This
is not pertinent to the application and should be deleted.
2. How will Pittston meet the new sulphur standards of EPA
scheduled to become effective in September 1977?
61—2
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John McClennon —3- December 6, 1976
3. Since product tankers are BnIaller than the crude oil VLCC’s
and product oils are more toxic than crude, the greatest number of
spiiis and the greatest damage to renewable marine resources will
come from the product tankers. Why has the EIS ignored these problems?
Why has EPA failed to cite these facts?
4. In the November 18, 1976, issue of Science it was stated that
80Z of all oil spills are Intentional. What safeguards will Pittston
employ to combat this practice?
5. In the September 1974 issue of Environment , Vol. 16, No. 7,
it was stated “Some 2.5 million tons of oil are released to the sea
each year from ships. Only 250,000 tons are released in accidents.”
Will EPA consider this extravagant waste of oil and its associated
damage to the oceans in its final EIS on the Pittston application?
6. Should there not be some type of pump device at dockside to
receive oil spilled during plant operations?
7. Pittston will produce large quantities of sulphur because of
the high sulphur crude to be processed. How will Pittston dispose
of this sulphur?
8. In June, July, and August the average number of days when
fog reduces visibility to less than one mile is 750 hours. How will
Pittston be able to bring crude oil in to supply Its refinery under
these conditions?
9. Does EPA consider oil for the manufacture of pulp and paper
and other heavy industry products more important to the U. S. and the
world than the production of food?
10. The presence of hundreds of foreign fishing vessels off the
New England coast for the last 15 to 20 years suggests that the most
advanced countries of the world do not agree with the U. S. on what is
and what Is not important. Has EPA given any consideration to this
situation in evaluating the EIS and the Pittston application?
11. According to the press, Pittston has stated, “Pittston has
said it will not invest significant further amounts of its own money
in the project. Other financing still has not been arranged, company
spokesmen have said.” If this is in fact the situation, how can the
DEP decision be valid if Pittston is not the principal investor in the
project?
12. Oil spills which are sublethal result in unacceptable con-
tamination of seafoods, including lobsters, clams, quahogs, and other
shellfish, in terms of taste. How can equitable damages be assessed
in such a situation and who is to be responsible for enforcement?
13. How will tankers proceed if fog sets in during passage between
East Quoddy Head and Eastport? When fog persists for several days?
61—3
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John McGlennon —4— December 6, 1976
14. Row will proposed tidal dams in the Upper Bay ofFundy
affect the Pittston refinery project?
15. Although navigational aids are alleged to be efficient at
Milford Haven, will they be equally efficient at Eastport considering
the greater severity of climatic, weather, and meteorological condi-
tions in that area?
16. Page 309, Vol. II, states: “Reports by various sources
indicate that the areas impacted by the 10,000—ton ARROW spill in
Chedbucto Bay were adversely affected in localized areas for two to
four years. Over all, however, the fishery was not significantly
affected.” Has EPA verified this statement by consulting Canadian
marine biologists who have studied the effects of the spill?
17. Approximately 28,800 of the 647,000 lobsters in storage
pounds at the time of the NORTHERN GuLF spill were reported to have
been killed by the spill according to pound operators. The distance
from the spill to the strand site was approximately 80 miles. There
is no evidence from the EIS that such distances from spill to lobster
pound have been considered. Why not?
18. Who will be responsible for dismantling and removal of the
refinery when the petroleum supply is exhausted or the refinery is
no longer economically feasible to operate even with heavy federal
and state aubsidie ?
19. Vol. II, page 1: What is meant by the statement “Gasoline
production at the facility will be limited.”? Row limited and for
delivery to what market by what means of conveyance?
20. Vol. II, page ii, Socio—Economic: What is the expected life
of the refinery? -
21. flow long will it take after the refinery becomes obsolete
before recolonization of valuable renewable marine and estuarine
resources in the Eastport area, Washington County, Charlotte County,
N. B., and the remainder of the Maine coast occurs?
22. Has this question (above) really been addressed by the EIS?
23. Page iii, Potential Impacts: This paragraph fails to address
the difference in toxicity among different oil fractions. Why?
24. What volume of oil may be legally discharged into tidal
waters by the refinery?
25. Is this volume (above) within the legal classification of
receiving and adjacent waters?
61—4
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John McGlennon —5- December 6, 1976
26. Page 188. When was Calais moved to “18 to 20 miles south-
west of Eastport”?
27. Pages 199 to 208. How much reliance can be placed on the
accuracy and objectivity of the statements in this section?
28. Why ha8 the EIS completely ignored the publications on the
Searsport and Friendship oil spills? (See enclosed papers).
29. Page 357. “Other effects associated with this facility
would be beneficial, including increased productivity of the City’s
commercial district, employment, tax revenues, and investment in an
area where recent development has been almost nonexistent.” For how
many years will these beneficial effects last?
I trust you will give these comments and questions adequate con—
sideration.
Sincerely,
ROBERT L. DOW
Enclosures
61—5
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LONG TERM WEAThERING CHARACTUISTICS
OP IRANIAN CRUDE OIL: THE WUCE
OP ml “NORTHERN GULP”
0. V. Mayo, 0. 3. Donovan and L. Jiang
D.partae.t of Ch..istry
lowdoin Coll.ge
lru**wdck, Maine 04011
and
Rob.rt L. Dow and John V. hurst, Jr.
Mains Department of Marine Essourcea
Augnsta, Maine 04330
On November 25, 1963, tk. Liberian
tanker Northern Gulf ran aground on West
Cod Ledge, Casco1i , Maine, with a loss
of approzisately 5,000 metric tons of
Iranian Crud. oil. The w•atker was cl.i
northwest winds averaged 17.6 km. per
hour, with a pink gust of 46.4 km. (1]
Much of the oil was rafted eaatward
by an anomalous clockwise eddy tZ) to the
vicinity of lower Penobscot lay where a
south.ast gale on November 30 drove the
oil ashore along more than 64 km. of
coast. The beach area occupied by the
stranded oil between extreme low tide and
above mean high tide was ..ti**ted to be
approximately 16 km 2 .
All commercial shellfish growing
sites, prihcipally soft clam (!
arenaria) , were contaminated bfthe oil.
One regularly sampled soft clam growing
area could not be harvested for a period
of two years following the spill. In
this period the supply of marketable
clams from the affecte4 areas declined
20 percent, or 60 metric tons of edible
meats, as contrasted with an increase of
249 percent or 157 tons in adjacent
uncontaminated control areas. Most of
the loss was caused by unpalatable oily
flavor apparently imparted by repeated
or Continuous reconta,n, nation by oil
entrapped in bottom sediments. Following
the immediate toxic effects (3) the
persistence of the Iranian crude oil
entrapped in bottom sedin nts would
appear to have played a significant but
not exclusive role in the continuing
mortalities observed in these areas
during the subsequent two year period.
These results are in contrast to the
virtually instantaneous mortalities
associated with some fuel oil spills
observed elsewhere on the Maine coast. (43
The total two-year market loss of clams
from the spill is estimated to have been
between a minimum of 60 and a probable
maximum of 209 metric tons of edible
nests.
Within th. spill area were located
five tidal storag. impoundments, con-
taining approximat.ty 647.000 lobsters
( Homarus arnericanus). The largest of the
lobster i i ns, located on Long
Island in Friendship, Maime contained
approxiaately 300,000 lobsters. Iaaedi
ate losses of 2$ ,$00 lobsters, weighing
1S.Z metric tons, were repsrtnd by zhseo
of the impoundment operators.
The dam enclosing the cov• to create
the impoundment prevqnts contamination by
anoutsideoil spill.xcspt und.b
abnormal meteorological conditions.
Those conditions were satisfied as the
store which brought th. oil into the
Friendship impoundment on November 30,
1963, was reported by the U.S. Weath.r
Doreen to have been from the south with
an average wind velocity of 44.1 km/hr. a
maximum of 76.1 km/hr. and a peak gust of
121.6 km/hr. (1) During the preceding
day. th. wind had been from the southeast,
with a maximum sp.ed of 49.6 km/hr and
$ peak gust of 65.6 km/hr.
• The Long Island lobster impoundment
has been checked p.riodica lly following
this initial contamination for visible
evidence of oil residues. It is located
in a rather isolated area which has not
bees •xpos.d to subsequent spills. On
surficial intertidal fin, sediments,
however, oil still persists as a visible
sheen and in subsurface sediments as
entrapped residues, with a strong oily
odor when samples of sediments and of
soft clams are collected.
U ther. had been no r.corded
evidence of either prior or subsequent
contamination of this area by petroleum
hydrocarbons, a study was commenced
during the sier of 1972 to establish
the present state of the hydrocarbon
residues in the sediments and marine life
of this area resulting from the wreck of
the Northern Gulf . The hydrocarbon
content of the area was assayed by gas
chromatography employing a Perkin-Elm .r
model 900 instrument equipped with a
SCOT 50’ OV-l column. Generalized
parameters for instrument operation are
given in reference (5). Sampling
procedures for sediments and organisms
were essentially those outlined by
Bluner. (61 The resolution capability
of the OY-l open tubular columns will
allow (with careful handling) nearly
total separations of the acyclic
isoprenoid series from C 14 to C 20 while
at the same time giving complete separa-
tion of all the linear chain compounds.
This result is observed in figure 1
(sample C-I) where the gas chromatogram
of the original unweathered Agha Jail
crude carried by the Northern Gulf is
shown. Of particular interest was an
area in the northwest corner of the
MARINE POLIL 1JTION MONITORING (Petroleum) SYMPOSIUM AND WORKSHOP
fli;v piii of qi ndards - Gaithersburg, Maryland
May 13-17, 1974
A1—F
-------
Supplement to the Paper “Long Term Weathering Churucterjstjes of
Iranian Crude Oil: The Wreck of the “NORTHCRN GULF”
U. W. Mayo, 0. J. Donovan and L. Jiang
Department of Chemistry
Bowdoin College
Brunswick, Maine 014011
and
Robert L. Dow and John W. Hurst, Jr.
Maine Department of Marine Resources
Augusta, Maine 014330
Table 2 01 that report identifies a 9.5% survival rate through
Novemoer 9, 1973, of the transplanted clams at Friendship Long Island,
while the survival rate of the control area in Scarboro was 78.1% through
Oetolicr 22, 1 )/3. The poor survival in Friendship can be attriLuted to
the (800 ppm oil residue level in the sediments.
The last collection of experimental clams reported in this paper was
made on NovemDer 9, 1973. Careful search was made of the oiled sediments
for any shell-marked soft clams. Of the 21 recovered, only two were still
alive and it was assumed that the search was so thorough none would escape
notice. A recheck of the area on April 9, 19714, refuted the assumption,
since four survivors were found.
The average 1973 growth of these clams prior to transplanting wa
9.3 mm in length, or a monthly growth rate of 1.6 mm. The average growth
of these same clams from June 20, 1973, to April 9, 1Y7’4, was 5.0 mm in
length, or a monthly growth rate of .5 mm, a 65% reduction in the growth
rate aiter transplanting to the oiled area on Friendship Long Island (see
attached table). The annual growth rate of the experimental clams before
transplanting was 18.6 mm, as contrasted with 6.14 mm after transplanting.
61—7
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Rate of survival, of 1,805 Scarboro soft clam. arenari ) , ranging from ‘42 to 59 nm in long diameter,
transplanted on June 20, 1973, to the area oiled by the November 25, 1963, NORTHERN GULF 1-ranian crude
spill on Friendship Long Island, declined to 9.5% by November 9, 1973. Including the 227 clams collected
at monthly intervals after the transplant, the total survival was 12.8%, in contrast to a survival of
78.1% through October 22, 1973, in the control area. Four Friendship transplanted clams sur iived the
1973-74 winter and were collected on April 9, 1974. Growth data are shown in the above table. Reduced
g owth is consistent with the growth rate of native claus in the same oiled area.
ATTAINED SIZE AND LONG DIAMETER
FRIENDSHIP LONG ISLAND SOFT CLAM
Diameter in nm
Total Monthly Annual
Shell * Jan.’73 June’73 Increase Increase Rate Apr.’74
1
44.5
50.1
5.6
.9
10.8
53.i
.3
3.6
2
44.3
50.9
6.6
1.1
13.2
5S 8
t (J
.5
6.0
3
46.2
64.5
18.3
3.1.
37.2
3.b
9.1
1.0
12.1
4
‘42.2
‘48.8
6.6
1 .1
13.2
51.2
2.8
.3
3.7
Mean
44.3
53.6
9.3
16
18.6
58.5
5.0
.5
6.4
I NC R.CML t4TS
PR.ANSPLANTS
_________ Average Percent
Total Monthly Annual Decline in Annual,
Increase In r ase Rate Growth Rate
72
65
-------
—2—
The post-piautthg t’owthi v itc was within the 3.6 to kL2 nvn annual average
,L oWth LdlLg( *it Lilt! ii iL I ye eiwu* in the t xper1iwntui areu on Fr Lentiship
Long Istund. The th’t’Unc of 65% in the annual growth rate of the sur-
viving clams transplanted from Scarboro to Friendship Long Is land can be
attributed to oil residues. This reduction appears to be consistent with
the effects of oil on the growth of clams in Casco Bay reported by
Gilfillari as well as the growth rate of native àlams in the oiled area.
November 19, 1974
61-9
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FOLLUTI
r 1 .
NOVEMBER 1975 - VOLUME 6 NUMBER U
The Ecological, Chemical and Histopathological
Evaluation of an Oil Spill Site
Part I. Ecological Studies
An oil spill into Long Cove, Sesispoet, Main., bepn on
16 March and laded until at least 30 Jun. 1971. It reenited
in immediate and continuing soft clam mortalities which,
based on before and after biolo cs1 eneveys, had by August
1974 exceeded 85% of the estimated SO million market-size
clams occupying the area.
Penobscot Bay, a major portion of the mldcoait embay-
ment of the Gulf of Maine, has a long history of economic-
ally important shellfish production, especially In the upper
bay communities of Searsport and Stockton Springs.
Even during the high sea temperature period of
1947—1963 when proliferating green crab (Carcinus
maenas) and other predator populations had reduced soft
clam (Mya arenana) stocks more than 90% (Dow, 1972),
joint state—municipal management and predator control
programs made the Searsport—Stockton Springs region one
of the six most productive areas in the Gulf of Maine (Fig.
1).
Increased industrial development in the Penobscot River
Valley and adjacent upper bay area, greater human
population density, and expansion of oil handling and
storage facilities rapidly reduced the quality of estuarine
and marine waters overlying clam flats despite state legal
classifications to the contrary. Finally, on 28 June, 1966,
the remaining shellfish growing areas of Searsport and
Stockton Springs were closed because of pollution.
Before the 1966 closure, employment in the production
of clams in the two towns had been approximately 100,
with nearly ten times that number emgaged in recreational
and subsistence fishing. Commercial production alone
averaged more than 135 metric tons annually of edible
meats. Betv7een 7 Xug t an l fl 19 9 an Tnventor
survey of the clam resource in the upper bay was carried
out jointly by the Northeast Shellfish Sanitation Research
Center of the U.S. Public Health Service, the Federal Water
Pollution Control Administration, and the State of Maine’s
Department of Sea and Shore Fisheries (now Department
of Marine Resources), using standard survey methods
developed by the Department in the late 1940’s (Dow,
1952).
Survey results Indicated that the existing crop of
market-size clams In Searsport alone ainounteg to more
than 140 metric tons of edible meats. Of this total approx-
F.g.1 A portion of Cutinc, Maine, qua an l., scale 1:62500,
thowrng the usa of the spill In Long Cove and LittIs River.
164
61—10
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Res ongesto Comrne ts by R.L. Dow
General: See FEIS Vol. II p. VI—29, Oil Spill Effects (revised).
Si DETS Is in error with respect to employment — one third of Washington County is employed
in fishing alone.
Ri See FEIS, Vol. II p. III—l3ff, Soclo—Economic Characteristics.
S2 Page 106 of the draft. “1 n 1074 . . . possible 15 usc Cobscook Bay. This is in error —
1973 — 8t;2 lobster fishermen in 819 boats, 1944 — 1, 132 lobsler fishermen.
E2 The data on p. 106 pertains only to individuals in Easiport.
S3 Page 360. The DEIS fails to consider the extent of contamination resulting from an oil
spill, still trying to limit such contamination to E tport alone, a completely false
assumption as has been demonstrated by the many recorded spills in the Gulf of Maine
from the 1974 spill at St. John, N. B., to the 1963 spill at West Cod Ledge at the entrance
of Casco Bay.
R3 See FEIS Vol. Il, p. VI—38.
s4 Vol. 111, A—63 Comparing fish processing waste with petroleum hydrocarbons in
their impact on renewable marine resources is ridiculous. There is no possible way
to eauate fish oils with petroleum oils in their toxic effects on the biota.
4 No comparisons of fish processing oil and petroleum based oil was made or inferred.
Vol. in, A—63 “Generally Pittston has shown such capability to entrap and remove oil
spills at the Deep Cove product piers.” This is a statement that is completely without
factual support. There is no evidence whatever that Pittston has either the capability,
competence, or intent to accomplish these objectives.
R5 The above quote is froi the Maine Board Order. If the Pittston Co. were to
be licensed by EPA, they would be required to comply with Coast—Guard re-
gulations concerning oil spills.
S6 Vol. 111, page 21. “No oil vessel of greater than 70, 000 DWT shall carry oil or refined
petroleum product or by—product to or from l ittston’ s oil terminal.” This re-
striction does not appear to be meaningful. A spill of 112 fuel or gasoline from a less
than 70, 000 l)WT voulti be mUch more (levastating tO renewable niarine and estuarine
resources than a comparable size spill from a 250,000 DW’r loaded with crude.
61—11
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R6 See PEIS Vol II, p VI—53.
S7 Why did EPA in the draft EIS quote national security? This is not
pertinent to the application and should be deleted.
Ri This information was supplied by FEA.
S8 How will Pittston meet the new sulphur standards of EPA scheduled to be-
come effective in September 1977?
RB See PETS, Vol II p X—37.
S9 Since product tankers are smaller than the crude oil VLCC’s and product
oils are more toxic than crude, the greatest number of spills and the
greatest damage to renewable marine resources will come from the pro-
duct tankers.
R9 See FEIS Vol. II p. VI—29 ff, Oil Spill Impacts, and pages VI —53 ff,
Toxicity.
SlO In the November 18, 1976, issue of Science it was stated that 80% of all
oil spills are intentional. What safeguards will Pittston employ to com-
bat this practice?
RlO The article in Science refers to the dumping of ballast and scour waste
while ships are at sea.
Sli In the September 1974 issue of EnviroflmentVol. 16, No. 7, it was stated
“Some 2,5 million tons of oil are released to the sea each year from ships.
Only 250,000 tons are released in accidents.” Will EPA consider this ex-
travagant waste of oil and its associated damage to the oceans In its
final EIS on the Pittston application?
Ru Comment noted - see preceding question and answer.
S12 Should there not be some type of pump device at dockside to receive oil
spilled during plant operations?
R12 All oil spilled in any area of the “plant” (Refinery or dockside) will
be piped to a separation and the oil skimmed of f the top and put in a slop
tank— eventually to be recovered and refined, See 1 EIS Vol. II p. IV—38ff.
61—12
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S13 Pittston will produce large quantities of sulphur because of the high
sulphur crude to be processed. How will Pittston dispose of this sulphur?
R13 Elemental sulfur will be produced at the rate of 465 metric tons per day.
It will be shipped to market in small tankers of the 10,000 to 15,000
DWT class. Approximately one sulfur carrying tanker will transit Head
Harbor Passage every 21 days.
S14 In June, July, and August the average number of days when fog reduces
visibility to less than one mile is 750 hours. How will Pittston be
able to bring crude oil in to supply its refinery under these conditions?
R14 The refinery has approximately 20 days supply of crude in storage at all
times. If the supply were to drop drastically low, the refinery could
operate at less than full capacity.
S15 Does EPA consider oil for the manufacture of pulp and paper and other heavy
industry products more important to the 13, S 1 and the world than the pro-
duction of food?
Rl5 Comment noted. Both are compatible and important.
S16 Oil spills which are sublethal resu t in una jceptab1e contaminati n of
seafoods, including lobsters, clams, quahogs and other shellfish, in
terms of taste, How can equitable damages be assessed in such a situation
and who is to be responsible for enforcement?
R16 See PEIS, Vol. II, P. X—Sff for types of compensation available.
Sl7 How will tankers proceed if fog sets in during passage between East Quoddy
Head and Eastport? When fog persists for several days?
R17 See FEIS, Vol. U p X .26 ft
Sl8 How will proposed tidal dams in the Upper Bay of ?undy affect the Pittston
refinery project?
R18 See FEIS Vol , II p. 111—159 ff, Other Federal Actions in the Area.
6 1—13
-------
S19 Although n. vigational aids are alleged to he efficient at Milford haven, will they be
equally efficient at Eastport considering the greater severity of climatic, weather,
and meteorological conditions in that area?
R]9 Navigational aide which, would take into account the eeyerit of the climate
are required to be approved by the Coast Guard.
S20 Page 309, Vol. 11, states: “Reports by various sources indicate that the areas impacted
by the 10,000 ton Arrow spill in Chedbucto Bay were adversely affected in localized areas
for two to four years. Over all, however, the fishery was not significantly affected.” Has
EPA verified this statement by consulting Canadian marine biologists who have studied the
effects of the spill?
R20 EPA utilized information and publications authored by Canadian sources in determining
the effects of the Arrow spill along with published material. An example of source
material is the Journal of Fisheries Research Board of Canada .
S21 Approximately 28, 800 of the 647, 000 lobsters in storage pounds at the time of the
Northern Gulf spill were reported to have been killed by the spill according to pound
operators. The distance from the spill to the strand site was approximately 80 miles.
There is no evidence from the EIS that such distances from spill to lobster pound have
been considered. Why not?
R21 Due to the variability of the size, location, nature and content of the spill, the distances
are of questionable value and cannot be generalized. Permanent and portable booms will
protect all lobster pounds in the Deer and Cambobello Islands area. Lobster pound oper-
ators will be instructed in the deployment of the various booms. In the event the pound
operator cannot be located, Pittston personnel will deploy the booms.
s22 Who will be responsible for dismantling and removal of the refinery when the petroleum
supply is exhausted or the refinery is no longer economically feasible to operate even
with heavy federal and state subsidies?
R22 In a basic industry such as petroleum, major installations of the scope and size of the
proposed project are rearely, if ever, terminated or abandoned. Obsolescence, whether
due to technology advances, or wear and tear, occurs only gradually and affects only
sections of the facility at a given time. Periodic modernization or replacement of such
sections keeps the facility efficient, effective and competitive with newer installations
In the unlikely event that the facilities proposed for the Eastport site are abandoned, the
plant would he dismantled, and the salvageable material sold hnd removed from the site.
Earth—moving operations would then restore the site to a condition ready for other uses.
S23 Vol. H, page 1: What is meant by the statement “Gasoline production at the facility will
be limited.”? thow limited and for delivery to what market by what means of conveyance?
61—14
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R23 Most U. S. refineries concentrate their process facilities in the production of gas
and other highly refined fuels. This particular refinery is known as a fuels or hydro-
skimming refinery and utilizes a minimum number of process steps resulting in lower
volumes of pollutants and emissions. The processes exclude thermal conversion processes
such as coking, visebreaking and catalytic cracking which are normally associated with
refineries that principally produce gasoline and other “light ends”. The limited gasoline
that is to be produced, will be shipped by tanker and sold to New England markets.
S24 What is the expected life of the refinery?
R24 In a basic industry such as petroleum, major installations of the scope and size of the
proposed project are rarely, if ever, terminated or abandoned. Obsolescence, whether
due to technology advances, or wear and tear, occurs only gradually and affects only
sections of the facility at a given time.
Periodic modernization or replacement of such sections keeps the facility efficient, effec—
tive and competitive with newer installations.
S 5 flow long will it take after the refinery becomes obsolete before recolognization of valuable
renewable marine and estuarine resources in the Eastport area, Washington County,
Charlotte County, N. B. , and the remainder of the Maine coast occurs? Has this question
been addressed in the DEIS?
R25 See response R 22.
S26 The differences in toxicity among different oil fractions is not addressed.
R26 See FEIS Vol. J p VI- 53ff., Summary of Toxicity Data.
‘S27 What volume of oil may be legally discharged into tidal waters by the refinery?
R27 See FEIS Vol. II p.VI—28 ff, Effluent discharges from the refinery will not exceed the
regulations.
S28 Page 188 Location of Calais is incorrect.
R28 Southwest was changed to northwest in the FEIS.
61—15
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29 Why has the EIS completely ignored the publications on the Searsport and
Priendship oil spills? (See enclosed papers).
R29 The reports were reviewed in the preparation of the EIS.
S30 Page 357. “Other effects associated with this facility would be beneficial,
including increased productivity of the City’s coumiercial district, em-
ployment, tax revenues, and investment in an area where recent development
has been almost nonexistent.” For how many years will these beneficial
effects last? •
R30 See FEIS Vol. II p. VI—l ff, Socio—Economic Impact. These effects will
persist for the life of the project.
61—16
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WARD E H’GH SCHOO’ “ Othci (516) flOSS
‘“ ‘ Guidenc. Off lce(516) 987-3061
Ow w ioa* Physical Education Office (516) 981-3071
Nu,is ’s Office (516) 987-3074
UTAUI T. 14 1W YOlK 11733
ThAUDEUS E. McKNELL , Ed.D Ptincip JOHN F. FOLEY. Ph.D., Di,,ctor of iuialth,
M,ysi& Education. Recreation .ndAMb
DANIEL 8. SWEENEY. Ch.nna’, of GuidIJd
Dec. 6, 1976
U.S. Dept. of Environmental protection
John F. Kennedy Federal Bldg.
Boston, Mass. 022C3
Dear Sir:
In reference to the proposed oil refinery nd marine oil terminal at
Eostport, Maine by Pittston, I hove In my possession the State of
.-aine Dept. of Environmental Protection comments of t arch 12, 1975
and June 4, lc 75.
For the oards consideration :
I. ffect on the Environment
“An oil refinery, oil storage and terminal fad lity will have
some unavoidable irnpactt .LU.
An oiL spill into Long Cove, Searsport, .aIne began on March 16 1971
and lasted until at least June 30, 1971. The Dept. of Maine esources
estimated the spill at 14 metrIc tons. In late March 1971 your agency
determined that all of the clams tested In the Long Cove area were in
a distressed condition. By August 1974 86 of the shellfish population
had died. Studies of ‘other oil spi us indicate that the growth rate of
surviving shellfishwiil decIineó0 . (3) -
2. The Passamaquoddy Power Project
“The prcposed refinery and termi 1 Is not incompatible with the
utlUzafion of this natural resourcehl.i.L.
Twelve thousand signatures on petItions sought to Influence the state
legislature and the tj.S. Conoress for the tidal prcject. In particular,
Representatives Cohen and Emery’and 5enators Muskie nd Hathaway are
either introducing legis latlon for addi i-lone I studies or In the process
of obtaining funds already appropriated. The passage of tankers is clearly
Incompatible with the QuoddyTidal ProJect. (4)
3. The Energy Crisis
Since i-he “energy crisis” our dependence on forzi in oil has
increased from 2O to 4O . The Pittston plant will use foreign oil.
Somewhere at the close of thIs century domestic cii reserves will be
depleted and midway through the next century foreign reserves wHi
follow. The Arabs know this and Are at present attempting to switch
NANCIS G. BANTA ,AssisraotPthwl
LAIJDE FRANK Asâm.t cip
NTHONY J. NAPOLI ,A deraea Mscip
62-1
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to a mu IH—lndus trial ecoricmy. Cli as a lon range so lufi on to the
energy crisis is not the answer. The importation of oil with the ever
rising prices weakens our balance of payment state contributing to
inflation and unemployment.
In he opInion of Juluis F lescher, Pres. of t ’aine Refining end P fro—
chemical Corp. , coastal sites for refineries are undesirable. (
I n a d lii on to the r equ I r eme nt of P 1 t is ton to mont for a I r n we fe r
qua Ii fy, precpera tiona I and continuing, if Is r’es ir3b le for n irv epen—
cent c ency to monitor the environment simulfenecusly.
Kindly provide the following.
I. Copies of 3 t. .S.A. — 1—óO5 3n ! 3E t.. .S.A.
2. .yh2f . re the rrir imuri avironmenf i st n’ r.!s ?
3. h f 7rovi ic;a c H’ i ., ;rrvi ! ror th. ‘n crc n:nf ‘fl r pl nf
s :n f -
. LTy I h inccrmed c i th rcc e’Pr g of r cc. 3, 1976 t Ec st orf,
aine in future proceedings ?
Jn view of the above, the construction of a coastal refinery xviii
lead to the inevitable deferioation of the qua lif of life in an
unique section of these United States, possessing natural beauty,
history nd personal vslues so characteristic of “down
Is a ccmmenf of a local resident.
espective1y yours
v4
uss il 7. ta ig
Ch mf s try
I. aine Dept. of Environmznfal Protection Proceedings, Site 2 —I4 ó—2 2IC
! .arch $2, 1Q75, p. $0
2. jbiJ
3. Dow, .L. . Hurst, j.: . tt The Ecolo iicaI, Chemic l and Hisfop fhoto icaI
Ev3iuafion of n Ti! Spill Sitz”. arin ml l’ tion ‘ul1 tin,
‘/c lurre 6, ‘ur.’hzr ! I , l: I , t. v •
ri ‘! !, ‘r , r”, ‘i ! st, lu tr r ,
P. 7’ —7, —$--,l i’ , (Jun: V !
• — — 7 • / , 7 )
62—2
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Page 4
THE QUODDY TIDES
I know you received hundreds of
letters a year on the Refinery Issue but
I cannot refrain from sending you one
more. The DEP has sent out some of
their findings on permits requested by
Pittston and for the people who didn’t
receive them or have not read them I
would like to make several points.
The refinery will be operating 24
hours a day at a noise level equal to or
in excess of the noise level of the build-
ing phase. They say 60 decibles at Rte.
190. though the Sandford Refinery has
levels of 60 decibles at 2.300 feet. al-
most 1000 feet further than the estimates
Hanging and
refineries
The Environmental Protection Agency
has reached the conclusion that Eastport
is an ideal place for an oil refinery, with
only one drawback, the danger of a tank-
er disaster in the chani’tel leading to the
site. It is like saying that hanging is a
relatively harmless affiar, except for
what it does to your neck.
It is not true, either, that the
damage of a wrecked 250,000 ton tank-
er would have only a local effect. Due to
the counter-clockwise movement o cur-
rents in the Gulf of Maine, any consider-
able spill would have fatal effects on
marine life over a long section of the
coastline. It would take years for the area
to recover from such a calamity. The
fishing industry of Down East Maine
would be terribly damaged. The blow to
clams. bloodworms and lobsters would
be fataL
The refinery itself. having destroyed
a going industry in Maine, in 30 to 50
years. would become a monumeni to
another dead industry, with the exhaus-
tion of fossil fuel. Eastport does not need
another industry in its terminal stages.
as badly as it needs a live industry with
a bright future.
Ed. ote:—The above opinion appeared
in a recent issue of the “Ellsworth
American”.
for this refinery. (60 decibles is like
listening to heavy traffic from 300 feet
they say. The DEP says that at levels of
70 decibles there can be hearing loss).
The projected number of spills a year
is 8-12, fora total of 14-32 barrels but
they say the Welsh refinery has 53-54
spills a year for a total of 206 barrels a
year during 1963 to 1971; and 98 a year
in 1969. 70, and 71. They didn’t give
any figures for more recent years. This
spillage is in addition to the projected
daily discharge of 60 gallons a day, every
day, or 21,900 a year.
They say that the refinery will not
contaminate the shore. It is virtually im-
possible to spill even a small amount of
oil in Eastport and have it stay off the
beach. Several years ago there was a small
spill in one of the factories in Eastport
and the following day there was oil on
the beach as far as Bellier Cove in
Edmunds.
Another problem that we will have to
live with is the one of sulfuric acid
mists. They say it is not a problem be-
cause there are no federal standards
for this emmission. That means it is one
of the t ’iings they do not count, but
one ne*l not be a scientist to know that
b’ea’hing sulft’ric ?cid cannot F’ good
for you. The air will also be con camin-
ated by particles, within the DEP stand-
ards. of course, they say.
The report is not a discussion of !f
the refinery will harm the environment
of the Bay. but rather a discussion of
acceptable levels of harm. The decision
will not be made by tlshermen and others
who live here, but by people who drink
water that has been iccycled through
treatment plants. who swim in pools
that are half chlorine and breathe air
‘ saturated with lead, and who watch the
sewage coming back (like in Long Island
last summer). They think it’s all right.
We should be the ones making the decis-
ion. We should be the ones who decide
that we do or don’t want this belching.
pounding. smelly refinery in our door-
ards not someone who lives in the
middle of New York City or Washing-
ton, D.C. Those people are used to and
don’t mind living in pollution. What
about you’ What about the rest of the
residents of Eastern Washington County
And what are,we getting in return for
the sale of our health and pe có ’ We
are getting 5.000 construction workers
for two years (for whom there is adequ..
ate housing says the report). We are goinj
to lose the little we have left of our fish-
ing industry and the possibilities of Im-
provement through things like aquacul-
lure. In exchange for that we are told
we can perform ‘supportive service’ work
I leave it to you to imagine what those
jobs will be. As for me, I am at a total
loss to know what sort of job I can do,
having no capital to invest in a business
that would be viable and I am su* that
the banks are not likely to lend m tey
to a business with a life expecta qf
two years. The main street of Esstport
will bed lot of bats and honky ta sks.
Clearly we are going to lose away of’
life that is rare and precious. We coin-
plain of the lack of security and of the
crime-but we forget that in comparison
to most places in this country we are
relatively free of that kind of harrasse-
ment. We still have communities and
relationships to each other, though not
ideal, which are a vast improvement
over what most people can expect. I
remembers relative of mine who has a
small baby and lives in New ‘i ork City
saying she realized what she was iving
with one day when she had to go out tc
the shore. She was feeling ditay and
weak and suddenly she knew that if she
were to faint on the street. she would
awake to find her baby gone,
pocket book stolen and God knows
what else. Regardless of how bad we
think Eastport is, we do know that it’s
not that bad yet.
Karen Good
Dennysville. Me.
Ed. Note The E.P.A. will hold a Public
Hearing on the Pittston Refinery Propos-
al t r statements t’roiti the public on
Dec. 3rd, 1:00 PM Eastport Auditorium.
tWe are pleased to receive written “opinions” from our readers and wilt pay for those whi h we publish)
Do You want an oil refinery?
62—3
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Response to Comments by R.T. Stagg
S 1 The refinery is not compatible with the Quoddy Project.
R 1 Vol. II p. 111—159 Proposed Federal Tidal Power Projects.
S 2 A refinery based on foreign oil sources weakens our balance of payment and
contributes to unemployment and inflation.
R 2 See FEIS Vol II, p IV—l ff.
S 3 What are the minimum environmental standards?
* R 3 All environmental standards that must be met are detailed in various sections
of the PEIS.
S 4 What provisions of the law provide for enforcement after a plant is
operational?
R 4 The permitting procedure under the FWPCA (Federal Water Pollution Control
Act) and the CAA (Clean Air Act) provide for the establis ment of penalties
and fines and possible revocation of the permits with respect to operational
procedures in violation of established standards. The NPDES permit, if
issued by the EPA, would contain specific operational conditions for the
plant.
S 5 It is desireable to have an independent agency monitor the environment
simultaneously once operation of the refinery has commenced.
R 5 Comment noted.
S 6 The construction of a coastal refinery will lead to the inevitable de-
terioration of the quality of life in an unique area of the envizonment.
R 6 Comment noted.
62—4
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JOUN A. DON AGHY
REAL ESTATE BROKER
P.O. Box 54
Lubec, Maine
Tel.: 733-4332
December 8, 1976
U.S. Environmental Protection Agency
Region I, Permits Branch
Room 2109, John F. Kennedy Federal Building
Boston, 1assachusetts 02203
Re: The Pittston Project
Application Number: ME0022420
Gentlemen:
This is not intended as a criticism of the people that contributed
to the preparation of the subject Draft Report prepared by the En-
vironmental Protection Agency but as a commentary on a few of the
many facts indicated by prior sworn te timony at Hearings of the
i4aine Legislature and the Maine Bureau of Environmental Protection
both by Metropolitan Oil and by Pittston. (Pittston asked the
B.E.P. that the original Metropolitan Oil data be considered a part
of their subsequent application.)
I ask you to consider the validity and importance of much of the
prior sworn testimony and supporting data as well as its contra-
dictions and indications of the lack of adequate study in some areas
(possibly because the true answer was not desired because of its
anticipated negative effect on the promotion).
It is not illogical to assume that paid attorneys, public relations
people and ‘expert witnesses with apparently limitless financial
incentive were able, through sheer volume of testimony, to pretty
much bury the data and/or information supporting the conclusions of
the opponents because a great preponderance of this latter was of-
fered at a personal. sacrifice in both time and money in most part
by people of very modest circumstances who in many cases were awed
by the applicant’s obvious “clout” which they were so expert in
using.
110w many farmers, fishermen, laborers or small businessmen can afford
to take time off from earning their livelihoods to spend a day wait-
ing before well educated and well dressed strangers “from away ’ for
the opportunity to be squeezed into an unfamiliar, limited time format
63—1
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ME0022420 Donaghy 12/8/76
to speak into a microphone, quite probably for the first time, let
alone to do so while depending on what they were to say into that
microphone to effectively assure the economic survival of themselves
and loved ones7 Another way should be found to let them be heard,
and what better way than by a referendum? This was turned down in
Eastport but not attempted elsewhere except by the Passamaquoddy
tribe as subsequently noted.
The attached Exhibit #1 indicates a little of the basic data show-
ing where, what, and who in the Cobscook Bay area should be consid-
ered as well, as just Eastport on Moose Island which alone is empha-
sized by Pittston as to imj act. There are people living and earn-
ing their livings in Lubec closer to the proposed refinery than most
Eastport residents. Twice a day, in sunshine or fog, rain or snow,
an average 18 foot tide would be pulling “inevitable” (Pittston’s
own description) oil spills from either off or on-loading tankers up
into the Cobscook and its subsidiary bays and coves. Certainly, the
impact uould be considerable on these people and on the natural re-
sources of these waters that lap the shores of Cobscook State Park
and Suffolk University suimner marine biology complex, as well as on
the clam, mussel, periwinkle and scallop beds found in the more than
26,000 acres of flats of the area
In any case, the following points should require answers acceptable
to your Agency from Korky,as Pittston’s Development V.P. was so
affectionately referred to by one of the hearing panelists.
The Indian Governor (Passainaquoddy Governor Moore) spoke of their
vote against the project and of possible conflict with a state fund-
ed power project. I don’t recall hearing him mention an aquaculture
experiment that is also under:.way, along with the hydroelectric
power study, in the waters off Pleasant Point Reservation. Would
this not be in jeopardy also and taxpayers’ money be at risk along
with the welfare of our Indian neighbors?
Scientific testimony relative to the hazards to the ecology, marine
life, protein, etc., brought forth in Maine B.E.P. hearings seems
to have become well buried by the many changes in application, plans
and testimony, but definitely not in the posture of the applicant,
Pittston. As an illustration, Nr. Arnold Kaulakis testifying before
the .E.P., along with his expert on radar, etc. from DECCA, stated
categorically that before Pittston would commit a VLCC to head liar-
bour Passage they were going to have a light installed at East Quoddy
Head, Cainpobello, N.E. that would be visible 20 miles further to sea
and that they would establish 2 radar sites, one on Campobello and
another on a nearby Canadian island, - not only that, but also that
they would not commit a VLCC to Head Harbour Passage without at least
1 ½ miles visibility.
On December 3, 176, I understood him to answer before your panel
that entrance to Head Harbour Passage would be left to the tanker
Captain’s judgment - that he, Kaulakis, had no expertise in these
63—2
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ME0022420 Donaghy 12/8/76
matters. There was not the slightest reference to negotiations
and/or land options that would make passage through these waters
acceptable under conditions set up by themselves. Why not?
Metropolitan’s records indicated, after much questioning at B.E.P.
hearings, that qualified Canadian pilots asked to evaluate the de-
sirability of using VLCC’s in Head Harbour Passage using a scale
of 10, caine up with only 3 ½ points. Further, the pilots asked for
more detailed information on the Passage’s currents before they made
a final report. This data was never provided and these men were no
longer considered as Metropolitan “experts”. Why?
In this same area of feasibility, a report submitted to the U.S. Sen-
ate by the Sub-committee on Air and Water Pollution of its Committee
on Public Works after the hearing at Machiasport in September, 1970,
indicated among many other pertinent points on page 585 that the
world recognized engineering firm of Arthur D. Little, Inc. dismissed
Eastport as a potential site for a refinery because, among other
things, “ The comparatively high tidal currents and narrow approaches
all but eliminate Eastport from further consideration.” There was
much more but this was confirmed in an early engineering report to
Metropolitan Oil and then to Pittston, but suddenly the Harris Company
seemingly reversed its stand, or at least modified it, and told the
B.E.P. that Pittston could get into Eastport. It’s all in the records
of the B.E.P. hearings, but why did Pittston persist when more desir-
able alternative locations are available? Why did the Harris Company
change its recommendation?
With regard to clean-ups, a Pittston expert, a Mr. Green, testified
that booms could not contain a spill in currents over 1 3/4 knots,
nor even divert it if the currents were over 3 knots. On December 3,
Mr. Kaulakis stated that there would be booms put around lobster
paands to protect them. On the Cainpobello shore of the Lubec Narrows
there is a large pound built to hold live lobsters for the Boston and
New York restaurant trade. It is owned by a U.S. citizen. Twice a
day the current in the Narrows has been said to reach a velocity of
12 to 14 knots, and on certain tides, even higher. It doesn’t seem
likely that Mr. Kaulakis’ proposed boom would provide much protec ion.
At one point in Mr. Green’s testimony, in replying to an inquiry as
to the location he would use as his operations base for clean-up of
spills, he blithely pointed on the chart beside him to a point near
the end of the North Road in Campobello, N.B.. That is owned by a
well-to—do retired Massachusetts building contractor who wouldn’t
sell his retirement home for all the tea in China.
In a protein hungry world we in the Lubec - Eastport area get most of
our herring for our canneries and other processing plants, as well as
lobsters, clams and ground fish from Canadian waters so that a spill
that would affect Canadian fisheries would also affect our food supply
and, just as important, would affect the many, if not over paid, jobs
in transportation and in processing, etc., — jobs already “in being”
from a renewable resource and in far greater numbers and of more
63—3
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ME0022420 Donaghy 12/8/76
economic value than would almost certainly be swapped for Pittston’s
300 ‘permanent” jobs because of “inevitable” spills that Pittston
experts have testified to. Canada’s loss would be our loss and our
fisheries’ loss would be ours, not Pittston’s.
Head Harbour Passage is actually considered as internal instead of
international waters because it is inside the “line drawn from Cape
Sable across the entrance of the Bay of Fundy to the mouth of the
river St.Croix t . (See pg. 141, Report - International Boundary
Commission , published Washington, D.C. 1934)
It has been pointed out that if the Bay of Fundy is Canadian and not
international waters, there would be no objection raised to peaceful
passage. Tankers, however, may well be considered bombs of great
magnitude as has been proved in several recent instances where they
have blown up with great loss of life and property damage.
Not only is Head Harbour Passage within the internal waters of Can-
ada but discussion recorded in reports of the Boundary Commission
indicate that the U.S. commissioners made some mention of the right
of passage through Head Harbour Passage but finally, in Article III
of the Treaty of 1910, a channel was established 115 meters on either
side of the international boundary through Lubec Narrows to be the
entrance to Friar Roads (part of which is Eastport Harbor).
( See page 12, Report of the International Boundary Commission ,
published Washington, D.C., 1934 or the subject treaty.)
At the time of the U.S. —Canada boundary settlement in 1925, three
miles from either shore as the boundary is in the Grand Manan Channel
probably was sufficient to delineate High Seas, but in recent years
we have gone to a 12 mile fishing limit and now it is to be 200 miles.
It would seem an appropriate time to come to an agreement as to the
location of the boundary across the Gulf of Maine as well as with re-
gard to the Bay of Fundy. Would it be appropriate to establish the
U.S. - Canadian boundary from Cape Sable to its present end in Grand
Manan Channel with the U.S. owning the West side and the Gulf of Maine,
and the Canadians the East side and the Bay of Fundy? Could joint
jurisdictions be worked out?
Pittston proponents often refer to the Canadian jealously guarded
position toward their own refinery at St. John, N • B.. This, in fact,
is a very different situation. A large tanker going to or f m
St. John has a 40 mile or better channel to use in reaching its des-
tination from the time it enters the Bay of Fundy, with ample depth
regardless of the time of tide. There is no need to wait until the
tide is right or until the fog has “lifted”. Further, these tankers
are unloaded, for the most part, at a mono-buoy close to St. John.
In addition, this is a completely Canadian operation and it can be
readily monitored and regulated by Canadian officials just as is the
rest of the traffic for the year round port of St. John, N.B.
Head Harbour Passage and waters contiguous to it is, during certain
63—4
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ME0022420 Donaghy 12/8/76
seasons, hand lining and hand trawling grounds for small boat
fishermen. How is the safety of lives, boa and gear of these
hard working men to be protected from the passage of tugs, tankers
and miscellaneous water traffic ancillary to the Pittston refinery?
Who is to pay for interruptions since time and tide wait for no mane
and certainly fishing is governed by the time of the tides? It seems
that this should be evaluated in the light of its socio-economic impact
even if there were not to be “inevitable spills.
Several Pittston biased newspaper articles have indicated that the
Canadians have a double standard when it comes to passage of tankers
of their flag through Head Harbour Passage and on up into Passama-
quoddy Bay. A check of Canadian official documents indicates that
the largest tanker to attempt this passage to off load to six smalle.a ’
barges bound for t. Stephen, N.B. was the Irving Glen of 20,000 tons
(roughly 1/12th the size of Pittston’s proposed behemoths). As a re-
sult, Madam Jeanne Sauve , Minister of Environmental Control in Ottawa
addressed the president of Irving Oil on July 17, 1975 to the effect
that it was an unacceptable risk to the area fisheries and recreation
industry and that if such an ill advised venture were attempted again,
she, along with her fellow ministers, would institute legislation that
would bring an immediate halt to such folly. It hardly seems that a
double standard charge is justified except as a Pittston red herring.
The picture displayed at the December 3, 1976 meeting showing 21 naval
vessels anchored in Eastport Harbor after World War I gives the im-
pression of a big harbor at Eastport. What size ships were they?
What was their length? How much water did they draw, etc.? The
harbor is deep, but is it large? Weren’t these vessels actually an-
chored in Canadian as well as in U.S. waters, just as product tankers,
tugs and miscellaneous other freighters would have to be? I under-
stand that one anchorage requirement of each ship has to be allowance
for a 360’ swing at anchor with wind and tides. The Canadian boundary
is only 1200 yards off the Eastport waterfront. -
As has been previously stated, much scientific data detrimental to the
socio—economic effects of the subject project ‘on this area is buried
in many different file drawers of testimony taken over several years
by the Maine B.E.P.. I feel sure William Adams, Chairman of the Maine
B.E.P., would make it available to you upon request. For the sake of
brevity, however, I am attaching QUODDY TIDES clippings of opposition
testimony and suinniaries of what qualified opponents have indicated as
their objections. Mrs. French, Editor, has seemed most accurate in
her reporting of all these proceedings.
There is also a statement from me written while I was a three term
member of the Maine Legislature representing the so-called Lubec
Class of Towns, and more important, there is also a clipping cover-
ing testimony from Arthur MacKay of Deer Island, N.B. whom you heard
in Eastport on December 3, 1976 and from Franklin D. Roosevelt, Jr.
63—5
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ME0022420 Donaghy 12/8/76
not only as a friend of the people in the Quoddy area but also as
spokesman for the Roosevelt-Campobello International Park Commission
of which the present Chairman is Edmund S. Muskie, Senator fvoxn
Maine.
Respectfully yours,
John A. Donaghy j
JAD:md
cc: U.S. Department of Defense
Department of the Army, New England Division
Corps of Engineers
424 Trapelo Road, Waltham, Mass. 02154
Enclosures:
Reference Map - C & GS 801
Exhibit
1. a.Towns - Cobscook area
with area, population, shore miles
b. Location and acreage
mud flats in Cobscook area
2. Copy of QUODDY TIDES article on
Rep. Donaghy’s position on Pittston proposal
3. Copy o Franklin D. Roosevelt, r. ‘S
position as spokesman for Roosevelt—Dampobello
International Park, with 2 Park brochures
4. Opposition statements of E. Lee Rogers, Attorney
for the Maine Department of Marine Resources and
Inland Fish & Game Departments, along with statements
of other scientists and friends of the Cobscook area.
5. Opposition statement of Arthur MacKay
of Deer Island, N.B.
-------
Resoonseto Comments by..J A. Don y
Si Asks EPA to consider the validity and importance of much of the prior sworn testimofl 1 .
El EPA has reviewed the testimony from the BEP hearings.
S2 Pittston has the money and clout to put forth their proposal while the local people don’t
have the time, money or power to speak for themselves. Hold a referendum and lot the
people speak for what they really want.
R2 Comment noted. A referendum is an entirely local matter and is not a matter for Federal
authorities.
S3 The tides will pull inevitable oil spills into Cobscook Bay and affect, t.he 26,000 acres
of various flats in the area. It will impact people in Lubec and Suffolk Univerisity
biology complex as well as the Cobscook State Park.
See FEIS Vol. H p. VI—29ff,Oil Spills, p.111-36 current and Tidal Ranges in the Area.
54 Will the Passamaquoddy Indian power and aquaculture projects be put in jeopardy along
with tax dollars and their welfare?
R4 See FEIS, Vol. II, p. 111—159.
S.5 Findings of the Maine BEP he ring seem to have become buried in a mass of application
and testimony changes. Mr. Arnold Kaulakis testifying before the BEP, along with his
expert on radar, etc. from DECCA, stated categorically that before Pittston would com-
mit a VLCC to Head harbor Passage they were going to have a light installed at East
Quoddy Head, Campobello, N. B. that would be visible 20 miles further to sea and that
they would establish 2 radar sites, one on Campobello and another on a nearby Canadian
island, - not only that, but also that they would not commit a VLCC to Head Harbor Pas-
sage without at least 1 —/2 miles visibility.
On December 3, 1976, 1 understood him to answer before your panel that entrance to
head harbor Passage would be left to the tanker captain’s judgement — that he, Kaulakis,
had no expertise in these matters.
63—7
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g Before operation of the refinery can begin, Pittston must comply with all Maine BEP
orders. I addition the U.S. Coast Guard will be regulating the port.
S.6 Metropolitan’s records indicated, after much questioning at BEP hearings, that qualified
Canadian pilots asked to evaluate the desireability of using VLCCs in Head Harbor Passage
using a scale of 10, came up with only 3 1/2 points. Further, the pilots asked for more
detailed information on the Passage’S currents before they made a final report. This
data was never provided and these men were no longer considered as Metropolitan “experts”.
Why?
L .6 The Canadian pilots made their evaluations before the various channel studies were com-
pleted. These pilots were prohibited by the Canadian government from providing additional
informational exchanges with Pittston.
S ..7 A. D. Little dismissed the Eastport as a site for a refinery because “The comparitively
high tidal currents and narrow approaches all but eliminate Eastport from urther con-
sideration.” The Harris company modiefied its stand and said that Pittston could get into
Eastport. Why did the Harris Company change its recommendation?
R7. The A.D. Little Co. has not made a detailed investigation of the Eastport
site. The Harris Company has never changed its recommendation on the East—
port site. it should be noted that the Harris Co. is a consultant to the
Pittston Co.
5.8 Pittston has committed itself to provide booms for the lobster pounds. On the Campobello
shore of the Lubec Narrows there Is a large pound built to hold live lobsters for the Boston
and New York restaurant trade. Twice a day the current in the Narrows has been said to
reach a velocity of 12 to 14 knots, and on certain tides, even higher. ft doesn’t seem
likely that the proposed booms o uld provide much prOtection.
RB See FEIS, Vol. II, pX-26 U, px—24,
S .9 At one point In Mr. Green’s testimony, in replying to an inquiry as to the location he would
use as his operatlais base for clean—up of spills, he blithely pointed on the chart beside him
to a point near the end of the North Road in Campobello, N. B. That is owned by a well-to-
do retired Massachusetts building contractor who wouldn’t sell his retirement home for all
the tea in China.
R Comment noted.
63—8
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510 A spill that would affect Canadian fisheries would also affect the food supply and employ-
merit of the Lubcc—Eastport area. it would affect a far greater number of jobs than could
be swapped for Pittston’s 300 permanent jobs.
See F1 IS Vol. II p. VI—1, 6ocia—Eeoncmic tmpact, P. Vl—29 ff, Oil Spills..
Head Harbor Passage is actually considered as internal instead of international waters
because it inside the “line drawn from Cape Sable across the entrance of the Bay of
Fundy to the mouth of the river St. Croix”. (See pg. 141, Report — International Boundary
Commission, published Washington, D. C. 1934).
RU- Comment noted.
Tankers may be considered bombs of great magnitude and may result In great damage
to life and property.
R12 Explosions in tankers occur very rarely, The scouring operations are done at sea,
and will not take place while the tankers are entering or leaving Eastport. To
prevent these explos±otis, tankers a-re being equipped so that inert gas is ua d
to fill the compartment vapor space instead of air, thus preventing combustion
conditions
5J A discussion of the 1910 and 1934 Commissions on the boundry between the U. S. and Canada.
Now that the 200 mile fishing limit is in effect, shouldn’t the boundary line across the Gulf
of Maine be determined, as well as the Bay of Fundy? Could joint jurisdictions be worked
out?
R13 Comments and questions noted.
S14 Pittston proponents often refer to the Canadian refinery at St. John N. B. This is a dif-
ferent situation. The conditions are much safer and the t n kers for the most part are
unloaded at. a monobuoy. The facility is totally Canadian and can be readily monitored
and regulated.
Comment noted.
s 5 How is the safety of lures, boats and gear of the small fisherman to be protected from
‘the passageef tugs, tankers, etc. Who is to pay for the interruptions of the fishing
because time and tide wait for no man?
R15 Fishermen and their equipment will not be affected by the passage of boats and tugs to the
Pittston refinery. Tanker passage through Head Harbor Passage and contiguous waters
will not interrupt any type of fishing activity because of the very short duration of the passage.
63—9
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& Pittston biased newspapers say that Canada has a double standard and permits tankers
through Head Harbor Passage that service the St. John refinery. After the passage of
the 20, 000 DWT Irving Glen, the Minister of Environmental Control in Ottawa addressed
the president of Irving oil and said that it was an unacceptable risk to the area fishermen,
etc.
R16 Comment noted.
-817 Were not the ships in the picture shown at the 12/3/76 hearing anchored in Canadian as
—. well as U. S. waters? What was their length? How much water did they draw? One
anchorage requires a 360° swing and the Canadian border is only 1200 yards from the
Eastport waterfront.
Rh The ships seem to be largely if not entirely in U. S. waters. The largest known vessel
coming into and anchoring off Eastport was the Battleship USS Mississippi which had a
length of 624 feet, a beam of 97 feet, and a draft of 30 feet. The USS Caloosahatchee
had the deepest draft, 32 feet and 4 Inches, but was only 553 feet long.
sia Much of the scientific data detrimental to the Socio Economic effect have been buried in
— the testimony gathered by Maine BEP. Mr. William Adams would gladly make it available.
R18 Comment noted. Pittston requested that the BEP hearing be made part of the Information
— utilized by EPA for the preparation of the ETS.
63—10
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Dear tickriey:
I am m -ilinp you this letter with consid-
erable trepidqtion due to the amountof ill will
my nnection with the sub eot has caused
me from certi in sources - sure you can guess
the source. I trust the onten . Of my .ett r
c n be accepted and handled with that in mind
so no undue suffering will be forthcoming.
i y feer of this is the reason I have -ot mailed
this earlier— I couldn’t decide whether I dared
to be that forthrlrht ‘out the z tter. Being an
elderly person, s widow,and now without even my
home, i not eas , 1nce my economic conditi n
what this flU*X whole
1 t era any ‘/iway this can be handled
so it won’t develope into more persecution?
I’ll bemost grateful if it can. The contents
re true ad I hope will beof interest to those
in autrortty and on whom we folks downeast are
n wholly de endant for the future.As a con-
‘cient ou: per on 1 ri kin putting it into
your hands and praying it won t be mis sed Or
misapplied.
“c—
I
JL ” - --
.
64—1
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Barnard Nursing Horiid
C&lais, X .aine
i)6C. 8, ‘76
.vallaCe tickney
U.$. snvir. Frotec. gency
1 ern:it Branch
Boston
Mass. O2 G3
L)ear Sir:
I have lived with the “down—cast” energy subject for flit; yerrs as
reporter and ferture writer for tate and national coverages. Also
as he dof pub iclty r the revival of interest in tidal powor4
Now, chnnges In benefit-costa, technicological advances and widened
scope of pover transmission have made tidal produced energy a tru]y
fec .ole means of large supplies of &ectric energy. Aitho retired
from a daily news ob I ftnd I cannot Ignore what Is gcing on rcund
me in the mat.teiof thre 5 t ofoil in t Is unlitie partof the co st . it
is in the interests of our country that 1 Wish to express ni3 horror
that we should be fcrced to chz nge our economy and life-style from
a # eU—established marine, one as th ort-lived and destructive as
ci i. 1 know the lnsidt a tory of t is better than the average person.
1 hLve dealt with VIPa from President r.ooauvelt and his r etinue in
all these writing years. I knew uextrr F. Cocper and his family per-
sonally (Tidal Power engineer—extraordinary) and still have access
to his p pera. I knew, personally, the engineers who sabotaged the
attempted building of uodd.: Tidal Fowor- in fact my husband and I,
both writers, actually watched its demise fortwo yenrs and. uld 60
nothing tout it. It was a sarj and bitter story for the people of
eastern ine. They hwe never c i 1ete1y recovered from It. I shudder
over the possibility that the reel truth m never be known.
M I point a first feature that failed to appear in any 0
of news media- to date- t e tragic effect that -.uch a change of
economy .Ill have undeniab1y on the marine tod supply of the globe,
even from this small outpost. ‘why 3. n’t it known and admitted to be
a mBtterof grave importarco, t at the ragged coastline of thia north-
east sector Is the natural habitat of a Ina or portion of the sea-
foodsof the or]d? Highest authorities have testified to thIs h”t
somehow It never gets nned.ed irith the fact that t i is the
“cradle of the food-chrlna of the marine worid.”They hrve warned US
many times that oil is destroying those chains as fast a it is
alio d to pollute our rivers, lakes, saitmarshes, estuaries and
oceans. Yet we are being tempted to allow profit-mad oil interests
to * nore everything else.
64—2 /:
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2— Carter
T0day’ k ar gor I ewa tatea that the i ew England Couricil supports
.uch a refinery- that it would eradicate New England’s fuel situa-
tion, yet, F ittston spokesmen have endlessly reiterated that not
one barrel of oil will be made avai)ab e to locã needs, or dealers
That it v il1 all be shipped out to designated destinations of the
parent cmpany S oice.
The article states also that a refinery would provide a guaranteed
oil upply”throughout the next decade or longer”. ie onserisus
s’ver:’where seems to be that ci ]. Is not e e ed to last longer than.
th t. In that event, what becomes of a historic marine port that
even now has far more lucrative economy than the average person
realizes, ar 1 from a very u Irue life-style that can’t be teamed-up
vith oil ithout unestimate damage and .oss 1 of Irrevocable nature, if
and when oil fails.
It says too that the re1 nery wIll create jobs. (This, by ittaton
rc onents) the tune of only 30 oba for local people. The rest
of the much—quoted Z00 jobs to be held by trained outsiders. will that
repl ce the lorg -established fishing industry that,once-ruiried, can
never be re overed?
Since N aine is the actual “cradle’ of sea—foods that fan—out to all
p irts of the globe’s seas, try to estimate the an unt of it that was
destined by an a11-wi o Creator, to Issue from the three thousand
miles of rarged coastline of this one state? Haven’t we a very pre-
cious heritage to protect with everything we’ve got? flow does man
DARE to dtliberately destroy ti -t much of the source of such valuable
food?
unimpeachable authorities have well-documented the fact thet oil
destrpys the flora and fauna of land and sea for unknown j:er ods
or forever.
It ha been recently been discovered at e.at.port (Moose Island),
that the bottom of Its Broad Cove now threatened by the re± r.ery
: lans vJth very deep dradging, arid the tr ousan 8 of tons of sea-
bcttom dumped on Moose lslafld’s .urface, is said to be literally
paved ‘;ith scallop shells proving that there re even ret, unknown
soQrces of supply that havan’t been touched. Dredging that spot
would completely wreck a source of very valu le food.
Aquaculture (sea-farmirig),Ls already proving Itself highly feasible
and profitable but It would be stopped imrediate].y, once an oil
spill occurs.
I)espite all comments by 1 ittstori’s s ckemen ,tO the ccntrary, oIl,
once spilledin Quodd waters, fast running tides, bIg stcrrs,rarged
headlands and beaches, can:.ot be cor tkIned by bcoms and disposed of
as it could alonr sznoothe, floor-level, sandy shores. It would be
miles distant before salvare crews and their coirplicated equIpment
could get into action. Also, the portion that settles to the bottom
andits effect on the procoss of r.stural y the I that is so im-
portant tQ sea-food growth,I deadly to it.
At pub Ic hearings an by the media, k-itt ton has repeatedly admitted
that It hasn’t yet found a supply of crude oil out which this erclves
64—3
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3- Carter
‘ivea rise to the not-too-far-fetched suspicion that Pittston
u.t m. y not intend to build a refinery here. It could turn over its
pitifully few purchases and options of around 300 sores, to Saudi
Arabia (that is reported to have tried to buy into this territory
aroud 4 uoddy Bay) and turn this beautiful, deep, ice-free,w eli-pro-
tected har3or into a deep water port for itsown uses 1 including a
mooring for their many Idle VLCCS now anderIn the high seas for lack
of sufficiently deep anchorage. (;uoddy ha ens ‘be oneof the few
spot3 sufficiently deep for thispurpose. If that took place, the behe-
moths could tug at anthor for the rest of the time It t kes to rust cut
such hulks. Or perha they’d pile up on nearby islands in the first
bir uoddy tale. The whole bay could become a atery waste, j ood lbr
notnlng to anyone.
l ther efinery iere built without sure certainy of supply, it could
do the same thing h oOse island - make it a waste-land of rusting
pipes, buildings, tanks and equi ’nent of no use to anyone. This his—
tone spot that goes back to the OOs would be a perfect ezarnple of
mans utter d€ poIlâtio of one of the few remaining betiuty spots of
America, still UNdespoi]ed now, but needing protection. A 1 this . r
the s ke of a greedy ring otindustnialists.
it is the site of the first Custom House on the ntlantic ast- perhaps
In America. Of the only international 1-’ark in tne world.(It ncw attracts
ar.und l O,000 soeflic beauty lovers in 3eason. It is the scone of
numberless historic events that should be perpetuated instead of sacri-
ficed. Of Revolutionary ‘.ar periods. It ha thu famous ?niar Hoads
thht r’itts ton Intends dredging and despoiling for an oil terminal • There
are many small towns w th• rich history sach of , hich oculd be me
“Little N&lliqinaburgs” with a bit of help from a bicentenn1ally -minded
n-tlon. it has the biggest whiz$ool and the biggest lobster pound In
the ‘ onld. ‘and endless more treasures and natural resources and attrac-
tions that some day will be mourned, if destroyed for s h blatant
de ’ecration as an oil refinery.
Ju t one lone road provides access and exit Cr tne Island. In case or
are .nery flash fire, inhabitants would be completely trapped. ater
escape wo.:ld be impossible foe’ oursting tanks would flood the surround-
ing waters with burningoil. Lubec and sny of the Island fishing towns
.na vlllares would be In the path of fire , great I ; the record of
uch uestructIon. harves, weirs and piers would be wiped out.
z stport’ waterfront,(’thrice burned flat and rebuilt) is doomed to
ieing razed on the ay 1de, to make room fOr metal repafr sheds for the
oir tankera.AcrOss the street, VIctorian brick buildings and some fine
examples of wooden Victorian blocks vcrtb preserving, are to be turned
into grog shops with apartments above for female entertainers that
1-ittston says re necessary to keep long-voyage crews ontented vhen they
reech port.
Fittsto&s moutt pIece when asked about refinery operation rushes the
subject aside with the ren ark that there be no flash fires or anything
else to disturb the town, becauseit will be extremely RClloperated.
Yet the company ha3 a f ’Iphtening record of -&nccmpetency at running thei
other buelnesses (remember Buffalo Creek), 1nd are famous for their
failure to settle tragic losses of lives and omes.
64—4
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4-Carter
And £-‘ittston has .evt r before oper ted o e,en b ulit a refinery. They
intend.’o gut their ex or1ence at the exponse of the whdle valuable,
historic breath-takIn 1y beautiful and life-supporting 1-assainacuoddy
area.
I wonder if it is known that the uig bay came tithin a hairs-breadth
or becoming the Scapa .o of North rIca just before the sudden close
of’ orld ar o. y husband and I sat on an astport headland one
day 1 rep r& d to take 4 pics of the first ontlngent of warships to
arr ve there at a scheduled hour. . e had been alerted by our bigger
news channels) The unexpected end o ’ the war Intercepted them,we were
told. later, and headed them for home ports instead. Such a .faøi]4ty
of that kind might be needed again some iay by eitheror both of the
two closely located nations. To think of the possibility of its being
bartt red for anything but national welfare and safety is beyond words.
ou1d it ever be allowed to take place) In this ..aso, it would be like
the thirt:r piecesof silver ( tLose measly thirty jobs offerad boil
folks.) SInce it is contiguous to a nearby friendly, much-marriage-
related “foreign” country, Canadc and the United States have far too
much In common despite minor admInistrative spats.
Also, there’. the awful threat of’ . uoddy’s clean,1nv .gorating air and
water ecorning frighteningly pollut’d with refinery dIscharges. Our
famous 3umner Pike of Lubec,(former Atomic nergy Commissioner )
warned via the press just before hia death, of the Inescapable mnct
thr.t lo;i-lylng • uoddy fogs during periods of utter calm that cai Ja3t
for days, oven v eeks,wouldsurely mix with the quantitiesof articulates,
n1tro en oxides, nonmethane hydrocarbons, sulfur oxides besides r ercury,
beryllium and lead, whIch would become a mixture of deadly sulph uric
acid. He described a situation here ever thing would be dripping with
it.
Fittston’s pitiful ern ,4oyment figures shrink into oblivion in corn-
parisort with those of the 6000 laborers and 1200 office workers who were
on the job at ,uoddy in 1935 for what uld have been the first
successful tidal power project in the vorld, had Dexter Cooper’ plans,
f’igures and buiness principles been a1lov ed to prevail and the project
go on to completion. France has it instead and is now undergoing extensi
Cooper wa calledt for onsu1tatIon and advice at that time. NOw it
is producing electric energy, 13 entirely freeof pollutants and is a
beauty Fpot dra: ing an enormous tourist business. A movie of it is
being shov n in ast ort this very evening. I’ve seen the brochures and
they are unbelieveably beautiful. Fr -nce is more than happy with it.
One point tout which there has been no publicity astporters have
been brow—beaten so persistently during the years that pittston has been
tryiri to locate there, they are weary beyond words. b any are afraid
ex)ress themselves even to close friends. They have been threatened
,with their families, livelihood, homes, cars,a ssets nd prestige.
br ibeShaVe been given and promises of pie-In-the-sky to certain officiaL
if the refinery plan p es through. roperties have been declared unfit
for u e - I had one of’ the best built Colonial-Victorian hom in the
city, deliberately and faisly declared unfit because I could not
keep it open for occ pancy during my husbandIs Farkinsofl illness (he died
last April) o since it was ,ndemned, I had to lose it to demolition.
64—5
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Carter
It could 4 have ben a tine home for five families, all ap trnents
with separate entran ea arid many beautiful antique features • Iaa
79 years old but look many years younger and am still keeping
active, here at this Nursing Home (temporarily, I hope). I
finishing a book and writing music- m ’ hobbies. I am only one of mart p
who have suffered severely by this wIxle thing.
Instead of a refinery and a questionable new life-s t ile r 4 at port
needsto be helped to a return to the marine stronghold It used to be
and that could happen now 1 with an influx of people who love the pince
and are returning to it. In this era of Dyna—ships, aquaculture 1 return
to marine transportation and sardines back in our waters in better
supply than in years, it would be easily possi3le for astpcr.t to
remain the marine port it has always been, and even better In many
rays. lt is a gem of architeóture that merely needs help. It is
surrounded by natural beauty and FULL of historic things that biUST
not be wiped Qut by an oil ooMpliZ.
Even a referendum which has been denied us so far, mlrht not help
fOr the sim le reason teat astpo ’bers are sO afraid of retaliations
and reprisals 1 they don t know how to proceed with any step.
I believe this country could get cut or the energy jam and dominatIon
by oil if each sector could make a busineasof developing the kind of
energy they naturally have at their feet. ttetweon coal, tidal, 3cl r
wind and -eotherxnal, surely the U.S. could provi k the3e various
kinds of energy so no one portlcri of us :tc Li be subject to another
part 1 because of enerc ’ needs. d how free we would be from the danrer
of nuclear,power, with its terrible possibilites and waste problem
nerica IS still ricti 1 despite present d.itfi itles. And I believe
5he Is capable of staying so it she will make the most of such
blessed posribilities a these mentioned and stop runnin ’ after a
dangerous will-o-the-wisp.
The assinine proclivities of our r atIon are revealed In one in tance
by the building of that big oil pipe from the north, before the
facts of transportation thru Valdez and Cook Strai-%’t ‘were thoroughly
investigated. I’m ashamed of our engIneers It is Interesting sinee
we have an identical situation here In our nead 1 . rbor •assage that
has a center strip of arp ledge running down the middle of the
entrance to the Bay, Mith equally fast currents flowing thru ‘.t brekk—
neck pace, and no room for tankers to maneuvor when necessary.
Pittston’s stubucrrin eas out that passage is revealing as to their
fitness to take over this territory for such u e. May Cod save us
from such an outcome. We took a turrible beating with the deiberate
sabotape of the early Quoddy 1 rojeot and have never qite recovered
Now we are being “used” again by outside intere ’ts. why can’t we be
protected from t .Is, and given a hrit of help to stay in ou’ own natural
caterory. We re a hard—working people,of integrity, ie;pite the many
chargeãnade against us durinr uoh episodes.Thia one wil) be the last
straw t 4 Or a very worthwhile but persecuted breed of”down-easters. ”
sincerely yours,
L..
64—6
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Response to Comments by C.B. Carter
Si. 1’avors afl(I SLIl)j)01t S ‘I’i( %I Power.
Ri. Comm’ nt noted.
S2. The coastline of the northeastern sector is the natural habitat of a major portion of the
seafoods of the world. Oil is destroying the food chains or the “cradle of food chains ”.
R2. Comment noted.
S3. Not one barrel of oil will be made available to local needs or dealers.
R3. The Pittston Company has stated that it will seek supply contracts with oil dealers in
the State of Maine.
S4. Oil is not expected to last longer than a decade.
R4. See FEIS Vol. II p. IV—lff.
S5. The refinery will only create 30 jobs for local people.
R5. See FEIS Vol. II Vt 4,Employment.
56. Dredging will completely wreck a source of valuable food.
R6. See FEIS Vol. Ii p. VI— 59, Dredging.
S7. Aquaculture wOuld be destroyed by an oil spill.
Ri. See FEIS Vol. II p. 111—159.
S8. Once oil Is spilled in Quoddy waters, it will not be controllable and will
devastate seafood growth.
R8. See FEIS Vol. II p. VI—29.
S9. If the refinery were built without a certainty of supply, It could turn Moose Island into a
wasteland of rusting pipes, buildings and tanks.
R9. See FEIS, Yo1. II, p.IV—Uf.
Sb. The area is too rich in historical places and events to be destroyed by an oil refinery.
Rio. The proposed oil refinery will not endanger any historical f aces or locations of historical
events.
6 - 7
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311. There Is only one access road from the island. In the event of a fire, the Inhabitants would
be trapped.
R].1. See FEIS Vol. II p. IV—53ff, p. X—9.
S12. Eaetport’s waterfront will be drastically changed. to the detriment of the town.
R12. Comment noted. See FEIS Vol. II j Vi’g, Socio Economic Impacts.
S13. Pittston’s corporate record and their inexperience in building refineries are reasons the
refinery should be turned down. They will gain experience at our expense.
gj3, Comment noted.
S14. Eastport’s harbor should be preserved for national welfare and safety and not bartered
for 30 jobs like the “thirty pieces of silver”.
R14. Comment noted.
S15 Pittston’s employment figures shrInk Into oblivion in comparison to the Quoddy workforce.
R15. Comment noted.
Slé. Eastporters have been browbeaten by Pittston and their efforts to locate here.
R16. Comment noted.
S17. Eastport needs to be returned to the marine stronghold it once was -- eo Ie are returning
and the fish catch is up. The area Is still rich despite its difficulties.
RU-. Comment noted.
S18. The country should not be dependent upon only one source - oil. Each sector should
develop the resources at their feet. The channel, Head Harbor Passage, is too
dangerous despite Pittston’s comment to the contrary. We are being used by outsiders
and this is the last straw for a very worthwhile but persecuted breed of “downeasters”.
R18. Comment noted. See FEIS Vol. Ii p. IV—21f.
64—8
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47 Capen Avenue
astmort, Maine 04631
9 December 1976
r. wallace Stickney
U.S. Ehvironmenta l Protection Agency
Permits t3ranch, Enforcement Division
Region I
J..’ ..K. Federal Building
Boston, Mass. 02203
Ref? Application iTo. Mg0022420
Proposed C I I Refinery, The Pittston Co.
3 December 1976 ffearing; Draft EIS
Dear Sir:
I have been a resident and property owner in Eastport for
the past 5 years. For most of that time I have been employed
by the Calais School Department as a Special Education Assistant
at the Calais Elementary School.
When I chose to move to Sastpcrt from my parents’ home near
Boston, it was because I felt that the environment here in
northern Maine would both physically and spiritually allow me
to follow a simple, self—sufficient, healthy way of life. (Page
29, DEIS I seem to be described here as an “tirban dweller
seeking new lifestyle”.) I came partially to satisfy an
inherent desire to become part of a more natural world, and
though my scientific knowledge is limited, I have taken great
pleasure in becoming more and more aware of the many forms of
wild plant and animal life in this area.
I am gravely concerned — even fearful — at the ecological 1mph-
cations of constructing and operating an Oil refinery here in
astport, or anywhere along the Maine Coast. I understand that
the purpose of the 3 December hearing is to specifically explore
only those facts which can clarify an evaluation of the DEIS;
however, I believe that personal opinion and expression of
emotional reaction are equally as relevant as presentation of
factual data. I would, therefore, like to express’ my opposition
to the proposed refinery, and hope that my comments will be
received as seriously as I have considered them.
I cannot accept such an “irreversible and Irretrievable commit—
ment of resources” to a non—renewable energy source which will
65—1
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P’r. Wallace 9tickney
1 002?420
Pare two
result in the abandonment of the rc finery in 30 to 40 years.
I reali’ e the need for industrial development, and economic
growth in the area, but this development must be compatible
with the pristine rural atmosphere, so that an ecological
balance is ensured and conserved. Primary concern should
be for very long term future needs, not just those of the
newt 50 years. The Sastport/Cobscook ‘Ray region offers
several sources of local, natural, renewable energy reserves——
including fish and shellfish, and the plentiful forms of
lower marine life necessary to a mariculture industry——
which would not drastically impact the area. The Pittston
reVnery conflicts directly with the former COS Quoddy
Pida . Po r Dam project, as well as with the Passamaquoddy
Indians’ alternate energy plans. According to the Bangor
Daily News , Wednesday, December 8, a preliminary feasibility
study has been conmieted for a mini—tidal power project’at
the Pleasant Point Reservation, and federal agencies have
been consulted concerning funds for a first—year feasibility
study. The same article also described a small aquaculture
program at the Reserv ation which was active during the
summer of 1976, and which studied the effects of ay waters
on sea trout arid Suropean oysters. 1 3y the time the world’s
oil reserves are depleted, it will be much too late to
reconsider, as one major oil spill could prove irreparably
fatal to most of the area’s resources. 40 years of chronic,
low—volume waste and oil discharges (60 gpd, p. 299 DSI )-
will leave us few options when the refinery is shut down
and Pittston moves away.
gastport it self cannot be Isolated from surrounding commu-
nities in terms of environmental impact. A very wide area,
encompassing Maritime ‘ anada and the entire coast of Maine,
is jeopardi7ed by the proposed refinery. The Smithsonian
Institute has pronosed that the Cobscook Bay area and the
Downeast area be listed as Conservation Priority 7 ones
(p. 193, DBIS). In view of the endangered species of wild-
life which inhabit the coast north from PTachias, this
recommendation bears further investigation.. According to
the DSIS, both the Arctic peregrine falcon and the northern
bald eagle are known to frequent the Bastport area. What
will the I zpact of the refinery be on the 5 active nests
and t ie 14 northern bald eagles found here? “These birds
have been seen as close as one mile from the site boundary9
(imrs, p. 102) What will the Impact be on the Kead Harbour
65—2
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! r. T fallace cjtickney
P 0022420
Page three
Passage migration routes of the finback and right whales
(also on the Endangered Species List)? Itearby achias Sea].
Island and atinicus Rock serve as the last two nestii g
grounds for the only existing remnants of Alcids found in
the US: Puffins, Razorbills, and Gufllemots — considered
to be the most vulnerable birds on earth to the impact of
an oil spill. The DBIS states:
“Particularly sensitive areas of the bay were
evaluated with respect to possible oil spill
effects, including achiaa Seal Island, where
any large concentrations of oil could easily
ext irpate the small colonies of Common Puffins
and Razorbills, and adversely impact the Arôtic
‘l’erns found there.” (p. 310)
What provisions have been made to protect these birds and
their nesting grounds? Are they to be sacrificed?
The ‘E’A reports that just one refinery in N ew England
won’t substantially reduce cost to consumers (!EA Addendum,
p. 3), implying an immediate need for 3 or 4 new refineries
in the area. If the Pittston refinery is constructed, other
coastal areas of paine will be that much more vulnerable
to pressure for additional refineries. Therefore the entire
paine coast becomes endangered by Pittston’s proposal.
As a “source of public and private recreation and solace
from the pressures of an industrialized society”!, and as
a region of spectacular natural beauty, the 3,000 miles of
1 aine seacoast are unique and unequalled in the world.
I suggest that astport and the coast of PTairie be considered
an Endangered Specie, and that stringent control be exercised
to prevent Its becoming sri Industrial wasteland. This
country’s “G arden” State Is horrifying proof of refineries’
powers of devastation.
* ajne Revised Statutes, Title 38, Chapter 3, Sub—
hapter 11—A, Section 542.
65—3
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Mr. “tallace 3 tickney
MEOO 224 20
Page four
John McGlennon stated on December 3 that Pittsto z’s previous
corporate record is not relevant to the’ DEIS evaluation.
However, Mr. Kaulakia was consistently unable to respond
to questions posed by !2A/CO m nbers, and his attitude
of careless amusement was appalllugr when questioned about
the DEIS, Mr. K auIakie’ smiling reply was, in effect, “I
really don’t know; T’v’e just skimméd1t I haven’t had time
to read it” Most of his other responses were equally
vague, evasive, and unprepared; for example, when asked
what facilities were planned for servicing smaller tankers
and auxiliary tugs, he had no answer. As a spokesman for
the Pittston Company, Mr. Kaulakis represented the corpora-
tion very irresponsibly, and heightened Pittston’s well—
known reputation for negligence. LIVES WERE L0S L’ at
Buffalo Creek because of Pittston’s carelessness, and this
cannot be forgiven and forgotten as long as Pittston repre-
sentatives continue to display such casual unconcern.
I was also disturbed tro find that much of the actual
‘ nvironmental Impact information in the DEIS is incomplete
or of questionable validity. Spill predictions could not
be made for iastport not only because there is no local
data basis for prediction, but also because existing spill
41r ta itself is inaccurate when applied to any particular
port. “The validity of comparing !astport with other ports
such as ? i1ford Haven has also b en questioned”, because
maximum currents are somewhat greater at Eastport where
there is also a greater frequency of fog. (p. 307) Equally
expert witnesses presented conflicting testimony regarding
low vs. high accident potential at astoort vs. Milford
Haven. Pittston’s simulation studies of tanker performance,
considered by the DEIS as essential in the settlement of
navigational/spill issues, were carried out using no —wind/
no—tide varia les, where currents never exceeded 2 knots——
hardly “worst case” conditions. I am not convinced th&&
this has been adequately researched, particularly in light
of the effects of spilled oil on the marine ecosystem as
discussed on p iges 308—314 of the DEIS.
65—4
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Mr.. Wall ice Stickney
M OO2242O
Dae five
I would also I ike to comment on Mr. MeGlennon’s decision to
adjourn the December 3 hearing before all registered speakers
were heard. his was the first (and only) opportunity for
each and every astport resident to express his opinion
concerning the proposed refinery face—to—-face with the
board. An article published in the December 2 Calais
Advertiser stated that the hearing would resume the following
day if there was an indication that all speakers could not
be accomodated during the available time on ‘riday. Marry
registered speakers left the hearing late riday night under
the assumption that they could return in the morning.. Some
of these were high school students whose curfews prevented
them from remaining until the scheduled lltOO PM closing.
I think It is important to understand that many of these
speakers may now lack the confidence or the conviction to
express their views in.a letter——and that the premature
a 1journment will act as an impediment to direct, immediate
communication between the people and their governmental
representatives. The DEIS presupposes that Eastport as a
community is “receptive” to Pittston’s propOsal—I wonder
how valid this statement would be, had every potential
speaker been given equal opportunity.
I would like to thank you, Mr. Stickney, for your attention.
It is my understanding that the Pittston Company is obligated
to reply to each letter received by the EPA/COE . I am
looking forward to their comments.
Sincerely,
Liese Elerin
cc: Col. Tohn Chandler
Army Corps of i! ngineers
65—5
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R.ponee. to i ntj by L. Elena
Si. The refinery will be abandoned hi 30 — 40 years.
El. En a basic industry such as petroleum, major Installations of the scope and size of the
proposed project are rarely., if ever, terminated Or abandoned. Obsolescence, whether
due to technology advances, or wear and tear, occurs only gradually and affects only
sections of the facility at a given time.
Periodic modernization or replacement of such sections keeps the facility effecient, effective
and competitive with newer installations.
S2. The refinery conflicts with the Quoddy Dam and Power Project.
R2. See FEIS Vol. II p. iZI—.l59.*f, Other PedSral Actions.
S . • . . The Pleasant Point Reservation aquaculture project will be doomed.
R3. See FEIS Vol. II p. III—159ff.
S4. ‘What effect will the refinery have on the Northern Bald Eagle and the Arctic
Peregrine Falcon and their nesting areas?
R4. It is anticipated that there will be no detrimental impacts on the nesting
areas or the birds th iselvee as a result of the refinery operation.
S5. Head Harbor Passage serves as the migration t oute of the finback and right
whales — Impact?
R5. It is anticipated that no longterm adverse impacts should occur due to the use
of Head Harbor Passage as the tanker route. See FEIS, Vol. II, p. VI—38ff.
S6. What provisions have been made to protect the Puff ins, Razorbills and Arctic
Terns? -
R6. Measures taken for these particular birds are the same that will be utilized
in the event of any oil apili. See PEtS Vol. II p. IV—38ff.
S7. Requests that the coast of Maine be considered as an Endangered Species.
R7. Cosuent. noted.
S8. Much of the Information In the DEIS is Incomplete and of questionable validity.
R8. Conmient noted.
S9. The hearing should have been extended to Saturday so that all speakers could have been
accommodated.
R9. Comment noted.
65—6
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teL Day 733.4375
Tel. Night 733.2822
RIER PROS., INC.
Lubec , Maine 04652
USED and REBUILT CANNING EQUIPMENT
Buy—SeU—Tr4.
13 DEC 1975
Dec. 9, 1976
U. S. i nvironmental Protection Agency
Region #1
Boston, Mass. O2 O3
Dear Sirs
As you can see by my letterhead ma e my 1ivin
in sardine factory equip 1 ew.. I’ve a1 o owned and op cated two
sardine factot’ies, a pearl essence factory and fish meal plant.
At present, I am drawing up final plans for a sardine facLor ’
museum geared to the tourist trade.
I am also on the school Board here in Lubec.
It appears that eveh a “clean” oil refinery will ruin
the local fishing industry.
It is equally true that the oil refinery will reverse the
present trend of dozens of retirement couples mnovin into Lubec
and what tourist in his right mind would want to see an oil
refinery?
Finally, have you considered the catastrophic. effect on
the taxpayers of Lubec of providing an education for 200 to 300
construction worker’s children.
Very truly yours,
Response:
Comment noted.
See FEIS Vol. II p. VI—4ff,
p. VI—29,
66—1
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JL J% .
JL__—fl
ST T B1OLO IST ’ OCI TLOll
BOX 648 — SANFORD. MAINE 04073
Dr. Jan F. Sassaman
Vice President, SBA
Unity, Maine 014988
Mr. John McGlennon
Regional Administrator
U.S. Environmental Protection Agency
Region 1
John F. Kennedy Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
10 December 1976
On behalf of the Board of Directors of the Maine State Biologists Association,
this letter is submitted to comment on the D.E.I.S. concerning the proposed
issuance of federal permits to the Pittston Company of New York for construction
of a 250,000 BPD oil refinery and marine terminal in Eastport, Maine. Before
continuing, I want to commend you on a thorough D.E.I.S. for the proposed
project and for an enlightening hearing at Eastport on 3 December 1976.
I will confine my comments to three specific areas: several topics that were
mentioned in depth at the Eastport hearings which I feel bear further discus-
sion; several topics which were either not discussed during the Eastport
hearings or only discussed lightly which I feel merit additional discussion
in the final E.I.S.; and several errors in the D.E.I.S. which, while probably
not of major significance, certainly should be attended to before publication
of the final E.I.S.
With respect to areas of the DE.I.S. discussed at the 3 December hearings
at Eastport, I am particularly concerned about the failure of the D.E.I.S. to
consider provisions, comments, and requirements imposed upon the Pittston
Company by the Maine Department of Environmental Protection. These concerns
of the state are outlined n some detail in Section A of Volume III: Appendices
of the D.E.I.S. Of particular concern is the fact that the Maine Department
of Environmental Protection will require the Pittston Company to obtain Canadian
approval for VLCC passage in Canadian waters before issuing any permits for
IF
11 1F iF
67—1
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*, J ohn McGIennon
10 December 1976
Page 2
the project. At the hearings on 3 December the Canadian authorities made it
explicitly clear that they would not grant approval for the transit of VLCC’s
through Read Harbor Passage. In addition, the Maine Department of Environmental
Protection indicates it will restriàt the Pittston Company to vessels no larger
than 150,000 WP, yet the D.E.I.S. consistantly predicates its analyses on the
assumption that 250,000 DWT VLCC’S will be used to transport crude oil to the
Eastport tac 1ity. A third concern over the inconsistency between the D. E.I . S.
and the Maine Department of Environmental Protection Board Order is the fact that
the Pittston Company has not filed for other permits or licenses required by
the Board of Environmental Protection, including waste discharge and air
licensing procedures. The final E.I.S. should attend to the permits and licenses
required by state and local agencies prior to construction and operation of the
refinery.
During the hearing on 3 December, some mention was made of the Passamaquoddy
Tidal. Power Project and the possible effect of the proposed Pittston project upon
the future of the tidal power project. The page of text in the D.E.I.S. which
discusses the relationship of the Pittston project to the tidal project is
totally inadequate and figure 111-38, which purports to show the preliminary
site plan for both the proposed refinery and Passamaquoddy Tidal Power
Project, is totally inadequate and shows nothing. If indeed the Passamaquoddy
Tidal. Power Project is to remain viable, a more thorough examination of the
effects and alternatives of the Pittston project should be examined in the final
E.I.S.
Another area of concern raised repeatedly at the hearing dealt with the safety
of transit for VLCC’S through Read Harbor Passage. With the limitations of
fog (750 hours of fog per year or 31.25 days of fog per year), the limitations
of wind, and the limitations of current, it seems unlikely that many daylight
hours are going to be found in any given week for the transit of VLCC’ e through
Read Harbor Passage. The Maine Department of &ivironmøntal Protection has already
indicated that VLCC transit through Head Harbor Passage will be restricted to
daylight hours. It would seem appropriate that the final E.I.S. direct some
attention to consideration of the percentage of daylight hours during which a
VLCC r rn,y permissab].y trar.Eit rrom ast uoddy !!ead to the ef ncry.
It should be noted that in Volume 2 of the D.E.I.S. wind speed is discussed in
terms of the average monthly wind speeds for the Portland area (figures 111—25
to 111—27). Although you do state that available records from Eastport agree
with the Portland data, use of Portland data to support transit of VLCC’ s to
Eastport is certainly not logical. In addition, I might point out that average
monthly wind 8peeds is really not the issue. The issue is the percentage of
wind speed in excess of safe limits for VLCC’S in transit through Head Harbor
Passage. The computer simulations of VLCC passages through Head Harbor Passage
conducted by the Pittston Company consultant should include more severe types of
climactic conditions (typical. of Eastport) that can be encountered in these
67-2
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Mr. John McGlennon
10 December 19T6
Page 3
waters than those conditions included in the simulations presented 3 December.
These further simulatior should be incorporated in the final E.I.S.
I would like to address myself to several questions that were either ignored
during the hearings or were touched on very lightly. First of all, I continue
to be concerned about the fate of the airport property as a result of Pittston’s
proposed activity. Considerable discussion occurs in the D.E.I.S. about the
fact that the Eastport Airport is not extensively used, has a low traffic load,
and needs repair. If the refinery is constructed, the increased population in
the area and the increased traffic, due to the industrial nature of the project,
will certainly increase the use of an airport. It seems that we have a circular
form of argument. We have an airport in Eastport that is not being used, there-
fore let us build a refinery on it. Since construction will then generate a
further need for an airport, we will build one in Calais or elsewhere to replace
the one that has been disbanded. Further attention should be given to the
future use of the airport.
A second area of concern is the navigational aids system which will be required
for safe passage of VLCC’s through Head Harbor Passage. Pittston’s “navigational
aids” plan must be reviewed and approved by the Coast Guard prior to its
implementation according to page 9 of Volume 2 of the D.E.I.S. Has this plan
been considered and approved by the United States Coast Guard at this date? On
page 2l! of Volume 2 of the D.E.I.S. a rather sophisticated system of naviga-
tional aids is proposed. Will these navigational aids be installed and main-
tained by the United States Coast Guard or some other governmental agency? If
so, what will they cost the taxpayer?
On page 299 of Volume 2 of the D.E.I.S. a spillage of 20 barrels per year is
projected for Eastport amounting “to less than 0.00002 percent of all the oil
handled” per year. This figure is very commendable. As you point out, it is
ten times better than the spillage figure for Portland, Maine. It appears -that
this figure was derived by comparing the proposed Eastport operation with a
similar operation now underway in Milford Haven, England. Oil spillage is caused
by a number of factors: weather, ships, human error, acts of God. It seems patently
r di.cu1ous to compare oil spillage in an ongoing harbor operation in England
with proposed spillage for a proposed facility in Maine. The comparison between
Milford Haven and Eastport is seemingly . ustified in page 300 of Volume 2 of the
D.E.I.S. The “several reasons” for “meaningful and statistically significant”
comparison, however, deal with known characteristics at Milford Haven; large
sample size, extensive and complete records, and size of vessels. These character-
istics are as yet unknown for Eastport. Only the characteristics of hydrolo
and oceanography are common to Milford Haven and Eastport. Therefore, comparisons
between these two ports should be limited to these known characteristics.
In Volume 2 of the D.E.I.S., much is made about the need for United States based
refineries to increase national security in times of oil embargo by allowing
larger reserves of available oil. However, on page 201 of Volume 2 of the D.E.I.S.,
it is indicated that “product inventory plus crude stocks in storage and afloat
mean that a typical East Coast refinery has 65 to 70 days of assured supply”.
67—3
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Mr. John McGlennon
10 December 1976
Pagel
do not constitute a secure situation. This limited supply is hardly sufficient
justification for building an East Coast refinery to improve national security
in times of oil embargo. A national independence from foreign oil will not be
assured by building more refineries, but rather by developing energy sources
independent of foreign oil reserves.
Several times in the D.E.I.S, mention Is made of the water supply in the
Eastport area. At peak loads Eastport currently uses approximately 50,000
gallons of water per day; however, the plan, if built as proposed, will utilize
approximately two million gallons of water per day. This is a 500% increase in
daily water use for Eastport. The present water supply is delivered via a pipe-
line which is ten inches in diameter during part of Its course but with the main
portion of the line approximately eight inches in diameter. Will an eight inch
diameter pipe provide a sufficient flow for the two and a half million gallons
of water to be used per day? In addition, some restriction should be provided
so that the T50,000 gallon stand—by surface reservoir near route 190 will not
be utilized by the refinery so as to reserve the supply for emergency uses in
the Eastport area.
} y last concern deals with questions of clarity and inaccuracy in the D.E.I.S.
First of all, let me point out a few areas where the clarity of the D,E.I.S.
can be improved. Several of the figures, notable figures 111—12, 111—13, and
111—17 can be clarified by indicating exactly where the Pittston Corporation
plans to place the piers for off—loading crude oil and on—loading refined
petroleum products. In addition, fIgures 111—12 and 111—13 are confusing due
to small numbers which appear to be hand written and are illegible. Somehow
these figures should be enlarged or the figures redrawn to facilitate under-
standing of the presentation. In addition, I find figure 111—18 on page 71 of
Volume 2 unclear. I assume the hatched area indicates the tidal eXcursions for
some object dropped in the middle of the hatched area, but the lack of hatching
in the waters between Eastport, Deer Island and Campobello Island is unclear
to me. Somehov it would improve the D.E.I.S. if this figure were clarified in
some way or the discussion of tidal excursions was expanded in the text of the
final E.I.S.
Several errors in the D.E.I.S., particularly with regard to scientific names,
are glaringly apparent to the eyes of a zoologist. On page 99 of Volume 2, the
generic name for the red fox is misspelled. It should be Vulpes not Vuples . On
page 100 of Volume 2, the generic name of the common crow is misspelled. It
should be Corvus , not Corrus . OD tbe sa’ne page (100), there is a typographical
error In the next to the last paragraph. The common name of the grouse in
question is the “rutted grouse” not the “ruffled grouse”. In addition, on page
188 of Volume 2, you have located the city of Calais 18—20 miles “southwest” of
Eaatport. I believe you mean 18—20 miles northwest of Eastport. On page 192 of
Volume 2 and on page 8 of Volume 1 of the D.E.I.S., it is claimed that Eastport’s
Central Congregational Church dates back to 1529. r history may be in error,
but a date of 1529 appears to me far too early for the British colonization of
the northeast.
67—4
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Mr. John MaGlennon
10 December 1976
Page 5
Finally, with respect to errors in the D.E.I.S., I would like to call your
attention to page F—1O of Volume 3: Appendices. Page F- .10 deals with the
amphibians and reptiles “probably occurring in the area of the proposed site”
and is based on Roger Conant’s A Field Guide to the Reptiles and Aiiphibians
(1958). Roger Conant’s Field Guide was updated by the publication in 1975 of
a second edition, and I would like to call your attention to this publication.
Based on Conant’s second edition, your table F—5 should be corrected as shown
in my addendum, Table 1.
I hope this letter will be of use to you as your agency prepares the final
E.I.S. for the Pittston Project. Please feel free to call on the State
Biologists’ Association if we can be of any further assistance to you.
I look forward to reviewing the final E.I.S.
Sincerely,
iCJca 44 a(J i 4
Jan’F. Sasea an , Ph.D.
Vice—President for the State Biologists’ Association
JFS:dm
cc Maine Natural Resources Council
Maine Department of vironmental Protection
Governor of Maine
67—5
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‘Table I.
Table 1. Pir *iibians and Reptiles %1 ose Geographical Ranges Nay Tncl x the Area
of the Proposed Site.
( X)tCt4 NAME SCIE 4TTFIC NAME
C. m1kIi &apping Turtle Q e1ydra serpentina
*StirI(pot Sternothaerus Od3ratus
Wx,d Turtle C1 iInys Inscuipta
Eastern Painted Turtle thrysanys picta
Northern Red—bellied &iake Storeria occipitxznaculata
Eastern Garter &iake Thainophissirtalis
(Northern Ribbcti & ake) T. sauriTis
Northern Rin ieck & ake 1 Iadophis pixictatus
Northern Black Racer Cohter cmstrictor
Eastern 9 oth Grean ake O *ieodrys vernalis
Northern Water iake Natrix sipedon
(Tr zblay’ s Sala ander) kthystcxna tre thlayi
BitE-spotted Sa1 nder A. laterale
Spotted SalanEnder A maculati,n
Red-spotted Nawt toptha11TIIR viridescens
Northern Dusky Sa1i ni der Du iathus fuscus
Northern 1k -lined Sai der Eury ea bislineata
Red-backed Salanander Piethoch cinereus
(Four-toed Salanander) Hemidactyliun scutatun
knarican Toad Bufo ricanus
Northern Spring Peeper r].a cruc{ r
(Cray Tree Frog) .11. ‘ versicolor
Bullfrog lana catesbeiana
Green Frog 1anitans
Northern Leopard Frog pipiens
Mink Frog l septentricrialis
Pickerel Frog palustris
&,od Frog R. sylvatica
*Eastport is east of the eastern limits of the range of this species according to
Ccmant.
Paz entheses indicate those species having geogranhical ranges not kncx n to include
the Eastport area but have ranges surrotmding the Eastport area.
67—6
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Responses to Comments by J. Sassaman
Si. Pittston must obtain Canadian approval for VLCC passage in Canadian waters.
Ri. Mr. Richard Vine, Assistant Secretary of State for Canadian Affairs, in
a letter to Mr. John McGlennon of EPA, stated that the Canadian issue
of tanker passage was not an appropriate topic of discussion for the EIS.
S2. Maine DEP is restricting the refinery to use of tankers of less than
150,000 DWT. Pittston has not filed other permits or licenses required
by DEP
R2. The Pittston Co. must comply with all Maine as well as Federal permits.
S3. The DEIS does not discuss the Quoddy Project in relation to the proposed
project in sufficient detail.
R3. Comment noted. See FEIS Vol. II p. 111—159.
S4. It seems unlikely that sufficient daylight hours will be found for transit
of VLCC’s if given the limitation of fog,. wind and currents.
R4. Approximately one VLCC will be entering and leaving the refinery per week.
This is a total of 104 VLCC movements per year.
S5. Use of Portland data for wind speed is not appropriate for the VLCC traffic.
Further computer simulations should be undertaken to evaluate tanker per—
forinance under more severe conditions.
R5. Further real time simulation studies will be undertaken in compliance with
the Maine BEP order. The Pittston Co. has contracted with the New York
Maritime Research Center (Kings Point, N.Y.) to perform this work in co
oii.eration with the Coast Guard and the State of Maine.
S6. The fate of the airport property as a result of Pittston’s proposal should
be given further attention. The refinery viii generate an increased
need for the airport and produces a circular form of agreement.
R6. Comment noted. -
S7. Has Pittston’s navaids plan been considered and approved by the U,S C.G?
Who will install and maintain the system?
R7. At this time, the navaids plan has not been reviewed 1 y the Coast Guard.
The installation and maintenance will, be by either/or combined appropriate
government agencies and the Pittston Co.
67—7
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ss. Only the characteristics of hydrnk gy and oceanography are common to Milford Haven
and Eastport. Therefore, comparisons between these two ports should be limited to
these known characteristics.
R8. Comment noted.
59. The part of the DEIS that states ‘ roduct inventory plus crude stocks in storage and
afloat mean that a typical East Coast refinery has 65 to 70 days of assured supply”,
does not constitute a secure situation. A national independence from foreign oil Will
not be assured by building more refineries, but rather by develo ing energy sources
independent of foreign oil reserves.
R9. Comment noted. See FEIS Vol. II ag a IV-1 ff .
SlO. The Pittston project will Increase the demand on the Eastport Water supply by 500%.
Will the transmission system have the capacity to handle this load? A provision should
be made that the reservoir near Route 190 not be utilized by the refinery.
RIO. Pittston will draw the refinery water needs from the Eastport Water Company and the
reservoir near Route 190 will not be utilized. The transmission system will be upgraded
to safely provide the required volume of water for processing. Facts and tigures for
Eastport’s water supply are as follows:
Safe Yield. — 8.5 MGD
Main reservoir drainage area = 14.3 m 2
Perry reservoir drainage area 3.83 m 2
Total drainage area 18.13 m 2
Capacity of S. Meadow Road (I erry) =20 MG
Storage capacity of Boyden Lake = EasIly 10 bIllion gallons
AU figures are from Mr. Robert E. Johnstone, Eastport Water Company, February
1977. Present fluctuation Is due to leakage from the dam and after it is repaired, the
effect of the refinery will cause a fluctuation of only a few lncnes.
Sil. Several flgure need clarification In the DEIS. Figures 111-12,13,17, and 18. Numbers
need to be enIarged, pier locations put In and the tidal excursions delineated.
all. Comment Noted.
S12. On page 99 of Volume 2, the generic name for the red fox is misspelled. It should be
Vulpes not Vuples . On page 100 of Volume 2, the generic name of the common crow
is misspelled. It should be Corvus , not Corrus . On the same page (100), there is a
typographical error in the next to the last paragraph. The common name of the grouse
in question is the “ruffed grouse” not the “ruffled grouse”. In addition, on page 188 of
67—8
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Volume 2, you have located the city of Calais 18-20 miles outhwest” of Eastport. I
believe you mean 18—20 miles northwest of Eastport. On page 192 of Volume 2 and on
page 8 of Volume 1 of the DEIS, It is claimed that Eastport’s Central Congregational
church dates back to 1529. My history may be in error, but a date of 1529 appears to
me far too early for the British colonization of the northeast.
R12, Comment noted and appropriate changes made.
S13. Roger Conant’s A Field Guide to the Reptiles and Amphibians was updated by a 1975
publication and the addendum to bring the list up to date is attached.
RD. Comment noted and addendum was added to Appendix P ,
67—9
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GEOMARINE ASSOCIATES LTD.
.0. BOX 41 HALIFAX NOVA SCOTIA CANADA B3J 2L4
(5112 PRINCE STREET) (902) 422.7932 TELEX 019-21828
December 10, 1976
1 97L
WallaceE. Stickney, P.E.
Di rector
Environmental Policy Coordination Office
U.S. Environmental Protection Agency
Region I, Enforcement Division
Permits Branch
John F. Kennedy Federal Building Re: NPDES Application No.
Boston, Mass. 02203 ME0022420 and Corps Appli-
cation No. 25—76—367, Eastport
Dear Mr. Stickney: Refinery of Pittston Co.
We have had an opportunity to study the Draft Environmental
Impact Study for this project and wish to make a few comments
for the public record.
Geomarine Associates has carried out electronically
controlled marine surveys In Head Harbour Passage in 1975 and 1976.
We have surveyed areas between Campobello Island to Casco Island
to Deer Island as well as from Wilson’s Beach to Pope Islet to
Chocolate Cove on Deer Island. We have also surveyed from
Campobello to Indian Island and Deer Island both north and south
of Indian Island.
The surveys for our clients Involved deep-towed side-scan
sonar, 3.5 kHz sub—bottom profiler, surface-towed boomer and
ship-mounted bathymetry. We believe our surveys are the only
modern marine surveys in the area. We wish to note: -
1. Head Harbour Passage was mainly surveyed by the British
Admiralty in 181i7 using only sextant and lead line and without
the benefit of electronic navigation or modern sounders. The
only modern work is a Canadian shoal survey in the Friar Roads
area a year or so ago. We have found one onshore control point
to be as much as 200 metres (600 ft) in error relative to the
geodetic control net. This is half a ship’s length. We therefore
urge extreme caution In using presently published charts (eg ,
Figure 1V-7, Volume ii ) and would recommend a re-survey of much
of the Head Harbour Passage area.
2. We also note that other than our detailed work for our
client, little contoured depth data Is available and the true
shape of the channel Is really not known.
68—1
NSULTANTS IN MARINE AND PETROLEUM GEOLOGY AND GEOPHYSICS
-------
Mr. Wallace E. Stickney -2- December 10, 1976
In this regard, we strongly question the use of Figure IV-5,
Volume II. We find this figure quite unrepresentative of the
true picture and in our mind It is an unacceptable figure. We
would suggest It be made to scale and that a separate figure
also made to show a tanker broadside - I.e., across the channel.
This would give a true picture of Just how narrow the passage is.
We would also suggest a large-scale plan view of Head Harbour
Passage be included contoured at a 10 or 20 ft interval using
both the modern data where available and ancient data where
necessary. The 75 ft. contour line below mean low water then
outlines the passage one is really dealing with. This simple
data product Is not available In the E.I.S. as It presently
stands — only a small scale chart with broad channel boundaries is
included.
3. On Page 51, paragraph 2, we would suggest that the
14 1 1W widths of the passage are Immaterial - the mean low water
width at the 75 ft contour is the key element and this section
does not make it entirely clear It Is the 75 ft contour width
that Is being dealt with though we suspect it Is.
4. Our sub-bottom sediment and depth to bedrock surveys
show that thewalls of Head Harbour Passage are very often solid
rock with little soft sediment to cushion a tanker should it go
astray. There Is no documentation In the E.I.S. of hazards other
than depth as one proceeds down Head Harbour Passage. We would
suggest that a rock wall presents more concern than a soft bank
yet there Is no mapping of this. Again, Figure IV-5, Volume H
s possibly misleading in this regard. We would suggest the
final E.I.S. should show the bottom types along the passage.
5. We also note that should there be a spill in Head
Harbour Passage, the tidal currents will soon distribute the
oil very widely and there is no mapping of the shoreline types
and clean up problems in the Head Harbour-Friar Roads area or
in the other various estuaries within a 5 mile area. We expect
this is mandatory before any cleanup program could be designed.
6. It is only planned to pick up a pilot with his/her
high precision, carry-on, electronic navigation package “just
off East Quoddy Head. One look at the passage in past the
shoals south of Grand Manan Island would suggest this plan be
reconsidered and that the tankers be under shore control within
10 miles of Machias Seal Island.
7. The E.IS. suggests there will be I VLCC/week and
2 smaller product “Handy” or barge tankers/day, that movements
through Head Harbour Passage will be generally at slack water,
in daylight hours and that one won’t have a VLCC in the passage
68—2
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68—3
Mr. Wallace E. Stickney -3- December 10, 1976
at the same time as a product carrier. We have an uneasy feeling
that there may not be enough full slack-water, passage-periods
in a year that occur entirely In daylight hours to supply the
refinery proposed and that the refineries’ size may be restricted
by this fact. We did not see any discussion of this in the E. I .S.
Only one tidal cycle was shown in Figure IV-8. No account Is
taken of further reductions In time for movements because of fog,
wind or storm conditions, etc.
8. We note that on Page 192—3, no Canadian parks or
conservation areas were noted - indeed, the Roosevelt inter-
national Park on Campobello Island is administered by an
international body! In a general observation, we note that
there is often a severe lack of Canadian data in the report despite
the proposed refinery being located almost on the border and the
report is severely weakened because of this. We suspect that
Pittston’s almost exclusive use of U.S. consultants lead to this
bias.
We would suggest that in the future if the project is to
procede that Pittston will be required to produce considerable
new data In Head Harbour Passage and around Dear and Campobello
Islands and that Pittston must be required to use locally—based
Canadian expertise which we contend will lead to much more
complete studies.
9. Finally, there is concern expressed in the E.i.S. over
locating an alternative such as a single-point mooring or another
refinery site outside U.S. territory on Canadian soil because of
“security” concerns. We believe such concerns repeated verbatim
(and presumably accepted) by the E.P.A. must be tempered by noting
that all Input and output of the refinery must pass through
Canadian waters and is therefore subject to exactly the same
concerns. We also note that the Portland to Montreal and Manitoba
to Sarnia pipelines are on U.S. territory entirely and that any
Prudoe Bay to Mackenzie line will be exclusively on Canadian
ground. While It may be acceptable for a private company to
use such security arguments before E.P.A., it Is certainly not
incumbent upon E.P.A. to accept and repeat such arguments without
some discussion.
We trust the above remarks will be of use to you and we
would like to express interest in the final E.I.S. when issued.
If we can be of further assistance, please do not hesitate to
contact us.
Yours truly,
S r
ARIJf Alan Ruffma
cc; Col. J. Chandler, J. McGlennon, President
Maine Dept. of Env. Protect., W. Adams,
Roy Robinson, Dr. RH. Cook, Dr. D. Scarrett
-------
Response to Comments by A. Ruffman
si. Various cohccrns arc expressed ragnrding thc depth of LI(’ad harbor Passage and Its
make up.
RI. A sonar survey of the chàñnel to prove it to s 75 foot depth Will be d ne.
S2. There is no documentation in the DEIS of hazards such as rock wall as opposed to soft
bank. Suggest that the FEIS show bottom types along the passage.
R2. Ai aitcvey to prove -a 75-foot chsanelra1 ngot1 ”eati r ;rdut€ will: be ddne
S3. We also note that should there be a spill in Head Harbor Passage, the tidal currents will
soon distribute the oil very widely and there is no mapping of the shoreline types and
clean up problems in the Head Harbor—Friar Roads area or in the other various estuaries
within a 5—mile area. We expect this is mandatory before any cleanup program could be
designed.
R3. See oi spill section FEIS Vol. U p. VI- fl ff.
$4. Prefers that tankers be under shore control within 10 miles of Machias, Seal Island.
R4. Comment noted.
s5. We have an uneasy feeling that there may not be enough full slack water passage periods
in a year that occur entirely in daylight hours to supply the proposed refinery and that
its size may be restricted because of this. No account is taken of further reductions due
to fog, wind or storm conditions. -
R.5. Pittston estimates that approximately 468 tankers will enter Eastport annually to service
the refinery. Approximately 50 of these will be VLCCS, arriving once every 7 to 10
days. These wiU proceed directly from sea to berth on one ebb tide, and berth at slack-
water. The product tankers, however, can enter from sea and anchor at Friar Roads
before proceeding to berth at slack, on the same tide. ( this basis, using a carefully
planned schedule, two or three product tankers can enter and berth on one tide while
meeting conditions as presently stipulated by BEP orders. With only one ebb tide
utilized per day, 50 VLCCs and 630 to 945 product tanker entrances could be made a
year. If weather were to interfere 20% of the time, there would still be plenty of oppor-
tunity to bring in the 468 tankers annually that the plan calls for. Furthermore, there
will be two ebb tides daily in the daylight hours for a substantial part of the year.
S6. The report is weakened because no Canadian parks or conservation areas were noted.
68—4
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R6. It is expected that the only Canadian park or conservation area
that would be affected by this project is Campobello International
Park. See comments from the Roosevelt Campobel].o International
Park Commission (p. 9—if f).
Also see FEIS Vol. II p. VI— 62ff.
68—5
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10 December 1976
13 DEC I97
John A.S. McGlennon
U.S. Environmental Protection Agency
Region I NPDES Application #ME 0022420
Enforcement Division, Permits Branch
John F. Kennedy Federal Building
Boston, Ma. 02203
Dear Mr. McGlennon:
I am a private citizen writing to you about the proposed Issuance of
federal permits to the Pittston Company for the construction of an oil
refinery and marine terminal at Eastport, Maine. I own property in the
Cobscook Bay area and am familiar with the waters in the Eastport area.
My purpose in writing is not to argue for or against the refinery but to
note certain aspects of the proposed project which did not appear to be
adequately covered in the draft statement and to raise questions which
occurred to me as I read the report.
1) Eastport—Cobscook area — Although the report dealt extensively
with many features of the existing environment, especially in the local
Eastport area, it failed to remark on the peculiar nature of the proposed
refinery location and to note that the environment of the entire Cobscook
Bay area is directly linked to the proposed Eastport site. A source of
marine pollutants emanating from the location could have a dual detrimental
effect, both on the Lubec—Campobello side and in the Bay area. Through the
passage between Shackford Head and Cooper Ledges flows essentially all water
in and out of the Cobscook Bay area. Although It is difficult to tell from
the report exactly the velocity of maximum speed of flow in this area, it
is somewhere between 2.9 knots (p. 61) to 4—5 knots (p. 65). Because of
the decreased depth as the water enters the Bay the current increases in
many places; around Falls Island it reaches 7—9 knots. Debris and presum-
ably oil and other pollutants spilled at Shackford Head are carried rapidly
into Cobscook, Dennys, Whiting Bays and the smaller coves and indented
areas. Because of the speed of the current and the nature of the bay area,
the potential for rapid diffusion of a pollutant are great. The Quoddy
Tides , 26 November 1976 reported the 29 June St. John, N.B. spill of “less
than 500 barrels.” By 4 July “Wlndrows of oil appeared in Cobscook Bay,
Johnson Bay, etc...” This, from a spill 60 miles away. Although the
chances of a spill may be small, the effect could be extremely great because
of the site of the spill and the nature of the Bay area.
The report fails to take nxre than passing note of certain unique char-
acteristics of the Bay area. The Dennys River supports the second largest
Atlantic salmon run on the east coast; at a time when private, state and
federal sources are spending thousands of dollars to re—establish salmon
runs in the Connecticut and other rivers, some mention of the possible ef-
fects of the refinery should be made. The cotiunent (Volume I, p. 14) that
there is “no tourist recreational or summer residential development to en-
danger” is possibly valid now, but anyone who has witnessed the spectacular
increase in land prices in the Bay area (before the plans for the refinery)
69—1
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John A.S. McGlennon
10 December 1976
Page 2
and the development move eastward along the Maine coast, must be aware
that this potential has already been recognized. Just because an area of
great resources and natural beauty is relatively undiscovered as yet, does
not appear a good argument for construction of the refinery. Although
Reversing Falls in Pembroke is noted (p. 38), no mention is made of the
fact that it is the only “reversing” tidal phenomenon of such magnitude on
the east coast, and the site of a small but uniquely sited park. A sig-
nificant portion of the Bay shore area is taken up by Moosehorn National
Wildlife Refuge. Unless stringent control measures are taken at the re-
finery site, damage to these areas could be extensive. Compared to almost
any other coastal area in the east, Cobscook Bay is unspoiled and this is
used as an argument for refinery construction; imagine the furor if one
sought to put a similar complex in the middle of the Everglades or the
Quetico—Superior area.
2a) The technical details of tanker passage and off-loading are dif—
Licult for the layman to absorb. Two comeents are made with regards to
the comparison with Milford Haven. Table IV-8 notes that the channel at
Eastport is “straight”, yet a look at the chart (IV—7) would indicate
that tankers entering must make close to a 90° turn (E—F—G) at the narrow-
est part of the channel in order to reach their berths. Table IV—8 claims
no “cross currents”, but a look at figure 111—14, 15 indicates considerable
cross movement in and around Treat Island. This is reinforced by personal
observation.
2b) The reports note that crude tankers will berth at slack tide
(Figure IV—8, Table IV—8). One infers that off—loading must then be during
the peak of tidal cycle (4—5 knots) and that oil spills will be contained
by booms. Even given the existence of adequate skii rs, it is difficult
to believe that booms effective at 1—2 knots will be of much use at i—5
knots. The paragraph on Unloading Facilities (p 237) is not reassuring
in this context. Rough calculations indicate that crude oil will be trans-
ferred through one of the two 36 inch lines at 800 barrels/minute and that
“fast action” valves close in 30 seconds. Even under the best of circuni—
stances, a minimum of 400 barrels would spill if the line should part.
Given the current conditions, this amount would spread rapidly into the Bay.
3) There are many other statements in the report that make the reader
uneasy:
a) Vol. I, p. 23 — “attempts to revitalize the Ma4ne industry
have already proved fruitless...” What effort has been made? What will
be the effect of the 200 mile limit and decreased foreign competition? Is
it too soon to say the industry is doomed?
b) Vol. I, p. II — It is difficult to understand some of the state—
meats in the ‘Need for proposed action’ in view of the apparent facts
69—2
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John A.S. McGlennon
10 December 1976
Page 3
presented in the N.Y. Times editorial (enclosed) and other projections.
The Eastport refinery is, by its nature and geography, a viable operation
only In terms of overseas crude oil. It is hard to conceive of an opera-
tion less well placed for domestic or Ala kg oil. Reliance on such a
refinery would appear to “leave this country more than ever at the mercy
of the OPEC producers.” I realize that this is not a primary concern of
the EPA, but the logic used to justify the site selection is difficult to
follow. Will the siting of a refinery in Eastport in addition to the pro-
jected decline in oil reserves and use after 1985—90 contribu te to a boom
and bust economy based on cost and uncertainty acrtaiely i supply?
How does the Georges Bank exploration effect the oil supply?
c) Vol. II, p. 308 — Even recognizing that probabilities of an
oil spill of 500 tons (I assume from p. 300 & table Vi—]) that 100 tons
equals 700 barrels so a “severe” spill equals 3500 barrels is difficult
to predict, the figure of one “severe” spill in eight years is scary,
eàpecially in view of the effects of the current. This coupled with the
statement (VII, p. 310) on the Maine resource base and the effect of an
oil spill (VII, p. 105) in Cobscook Bay are disquieting.
d) Coastal land is an increasingly limited and valuable resource
in terms of recreation and in terms of the productivity of the seas. Is
it too valuable to use for a refinery, especially in an area not now con-
taminated with pollutants and when the effects of pollution from the site
may, by virtue of the nature of the area produce great side effects? In
view of the offshore oil development is a mono—buoying alternative a
safer approach? “The Council on Environmental Quality and the U.S. Coast
Guard have repeatedly expressed support for mono—buoy deepwater ports 20
to 30 miles offshore. . .“ (Environmental Quality 1976 - Annual Report of
the Council on Environmental Quality, p. 624).
The conunents enclosed are made with the full realization that many
factors influence the siting of an oil port and refinery. Not the least
of these, of course, is the attitude of the people of Eastport and the
Bay area. As one who does not live full time in the area nor draw a
majority of his livelihood from it, it is difficult to speak to the social
and economic factors. I am not “anti oil” in general nor “anti oil” in
eastern Maine, but the choice of the refinery site in view of its potential
effect on the entire Bay area appears to be open to question. When one
couples this with the unusual passage, the apparent desire of the country
to become less dependent on foreign oil, alternative offloading arrange-
ments proposed and the possible effects of a single industry domination of
the area, the situation is very unclear.
I hope these comments are useful.
Mark H. Boyer, M.D., M.P.H.
665 Huntington Avenue
Boston, Ma. 02115
cc: The Pittston Company
69—3
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NY Times
e
I
TooMuchOi?N
When the Alaskan pipeline was first being proposed 5 ubstitüted for Indonesian (not an eaSy Thing to dot
some seven years ago, the argument Was that the mechanically or economically in view Of ,the heaviness
United States was becoming dangei ousIy depende t on of one and the lightness of the other) there will still, be
foreign oil, that we needed to etploit every drop of a West Coist surplus and one that will grow larger as
the resourte for ourseI và *nd get it out of the ground the Al* fr C yield rises, from Its initial 600,000 barrels
in a hurry, no matter what the environmental hazards, a day to an even tual t5 ,piui n.
Even then, some skept c suggested that the oil. would * * —‘
eventually be sent to Japan bqtthat Chile WU iCath.,, ? v that the pipeliàe ‘has been laid, with biffl as of
Ingly denle& . dollars at stake and ‘the economy of Alaska in the hal-
The’UnIt.4 States was then Importing less fl ancb, the question cannot be one of “shutting in” the
percent of Its ci i NOW, j hqnit is impactIng 40 peicent oil, even’ temporarily, but 0 f distributing it effectively.
,nd ‘the oil from Prudboe Bay Is scheduled to go into One proposal Is to pipe It fron Long Beach. California,
the pipeline in a year or so, we are tald ’that this Alaskan to Midland, texas, taking advantage of an abandoned
crude will be a glut en the West Coast market after all. naWr gas, line. Caiifornia’s Coastal Zoning.Cbmnuisslon
The Stau dard Oil Compsay of Ohio owns more fesri that the’ oil transfer might add signiflonntly to the.
than half th. production, wants permission to ship the alnsady polluted air of the Los Angeles region. Alterna-
tuei to Japsn., Jfl payment, the Japseam would tive hive b propoe J from Bu tish Columbia
J uy Mldedst crude oll end have It shipped direct ‘to Edi ienton, Alberta; from Port Angeles, Wa*i gton, ’
Ameriom East Coast refineries, with both the United to eaittp k, Minnesota; nd across Guatemala to the
States an4 Japan savIng on sl IVping casts. ãuiit Oi Mexico; .
The achàne might. be laujnious ’ except for one over- Any c i these lines would take Ime and might well
riding fact: it would leav this coWutiy more than ever Involve some environmbntal damage, but In tha long
at the Asercy of the OFEC prodoceneEa to RIce and as runs some onó Of them may be esscntIaL More fmznedi-
to potential cutofts. Frink 2uib; head, of the Federal italy, the problem will be to distribute tile initial .1 low
Ener Adp nigtrslioa, puts the matter succlnctIy “It Ii from the Prudhor Bay well s . . S
nOt In the nation’s best hiterest to let that oil go abroad.” if ft Is no(to go to4apan, then ft
iurpn n g our-supply on the West Coast Is being East by tankei#moving throd h the Panama C i.
attributed by lame of tM companles. to I lowering or . SOHIO and other companies’oontend that there are bt
d n”d due to a reduced gnwth i te to conservation, . enough tankers, since under the Jones Act only Ameiican
and to the opening lost July o( the Elk Hills Naval vessels may be used to cerry United States products
Petroleum Resarve In California. .Thè first .two Eactors f torn ouie American port to ‘another. Mr. Zarb, whose
are regrettably toot m est to account fOr most of the aèency has made a long study øf the subject, says that
change and the Elk Iflh1 p ’j represents less than ther, are enough tankers so does tl e Maritime
15 percent of We4 Coast requl enents. A pouthly pig- Mmlnistratloa, which should know.
nificant factor is.the Importing ci’ 400,000 barrels a day g th a should nevertheless prove to be too few of
of lndon,len oil by Stand.id Of Califoruila. This corn- them to carry the load, then It would be up to Congress
psny finds It . oro profItable to Import nmlan oil, to amend the Jones Act. Too much has been said about
g which f t oins, than to ndbe oft from the North slope, the valued Alaskan oil in reducing American ds en ence
.1st wblth—unllke ’Standaid of Ohio—it has only an ‘on foreign sources, for it to be exported now and the
interest. ‘. , country made more dependent than evçr on the energy
Evoi If the. Elk Hills flow Is atciuped and Alaskan oil resouwca, of foreign states.,
69—4
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Response to Comments by MH. Boyer
si. The DEIS failed to note that Eastport is an m egraL part of th Cobscook Bay area and
the DEIS deals exclusively with the Easiport area.
Ri. The FEIS dealt with the project and associated impacts on the surrounding areas.
S2. An oil spill coupled with the tides and currents in the area could have great detrimental
effects on the Cobscoolc Bay region.
R2. Comment noted. See FEIS Vol. II p. VI—291f,Ojl Spill Effects.
3. The DEIS fails to make more than a passing note of the Atlantic salmon and Dennys River.
R3. There will be no adverse impacts on the Atlantic salmon due to the itormal
operation of the refinery. Oil in the refinery effluent will be below the Federal regu-
lations and will not be in sufficient concentrations to adversely affect the migrating
fish.
S4. Land values have skyrocketed and the area has potential for tourist and recreational
areas. Stringent control measures must be taken at the refinery site to prevent damages
to these areas. (Reversing Falls in Pembroke and Moosehorn National Wildlife Refuge,
etc.)
R4. Comment noted.
s5. The technical details of the tanker passage are difficult for the laymen to understand.
The passage is described as straight when it makes a 900 turn at points (E—F-G). The
DEIS claims no cross currents, but Figures 111—14 and 15 indicate otherwise.
R5.When a tanker has reached point E, its speed is essentially 0 knots and has begun its
berthing procedures with tug assistance. The transit of the passage by the tanker and
the berthing of the ship are separate operations. Figures 111—14 and 15 show currents
but these are parallel currents to the position of the tanker. The ships will encounter
essentially no cross currents during transit.
S6.Tankers will berth at slack tide and presumable offload at the peaks of the tidal cycle
when currents are running at. (4—5 knots). Oil cannot be contained in such currents by
present methods.
R6.See PEIS Vol. Ii p. IV—38ff,Oil SpiliConthinment and Recovery. The maximum currents
in the VLCC pier area at anytime are listed in Table ill-fl and shown in Figure 111—17.
Pittston has provided a specific pier location In the Shackford Head area in currents of
less than 1 knot. Oil spills can be contained and removed in currents of 1 knot perpen-
dicular to an oil boom,. Oil can be removed from currents in excess of 1 knot through
the deployment of booms at a 300 angle to move the oil to slower waters for recovery.
The technology for containment and recovery of spilled oil is continually being im-
proved. For example, studies performed by B.A. Folson and C. Johnson of TJltrasystems
Inc. and presented at the March 1977 oil Spill Conference sponsoredby the EPA, IJSCG,
and API demonstrated that a specif Ic streamlined oil boom is capable of retaining and
recovering oil spills In currents up to 6 knots. However this system performs opti—
-------
many in wave conditions under 1 foot. Also this oil boom is a research proto-
type and is not yet available coninercially.
S7. If a 36” unloading line were to part a minimum of 400 barrels would spill even with the
fast action closing vaLves.
R7. If the unloading line were to part, oil would spill until the on—board t rn ker pump hnd
been turned off or the Motor Operated Tanker Valve shut. Located on the pier will be
land—based operational personnel coupled with the tanker-based personnel to sulnrvise
the offloading of oil. In the event of a break, the pump would be shut down by tanker
personnel supervising the offloading. The motor-operated tanker valve would also be
activated by pier personnel and would be completely shut in 30 seconds. The figure of
400 barrels spilling in 30 seconds would be significantly reduced due to the pump shut-
off and subsequent line pressure loss and the effect of the tanker valve closing thus
reducing flow.
sa. Attempts to revitalize. . . have failed.
R8 In the recent past, Eastport has endeavored to attract new industry which would utilize
its municipal port and marine resources. In 1973, the Eastport City Council sent out a
brochure detailing Eastport and what it bad to offer in the way of skilled labor and natural
resources. One hundred inquiries were sent to electronics, shoemaking and paper related
industrleè,, A total of six replies were received and none expressed an interest in Eastport.
The most recent attempt to garner industry into Eastport was in January 1977. City
Council tried to arrange for the use of the Eastport pier as a shipment terminal for
potatoes. They lost the opportunity to Searsport because of the lack of funds for the
purchase of an $80,000 sea anchor. Drought-related potato market conditions in Europe
motivated this project, and this, at best, was a temporary activity.
For the past six years Maine Central Railroad has petitioned the Interstate Commerce
Commission for abandonment of service to Eastport in its entirety. This petition was
denied and another filed in October 1974 is pending. Traffic has decreased from 503
cars in 1967 to an average of 250 cars per year at present. The City Council has urged
the ICC to turn down the railroad’s petitions for abandonment. This is done with the hope
that sufficient industry will locate in Eastport to justify an economic existence for the
Eastport spir which presently does notE r
The Council has also initiated talks with Georgia—Pacific and other paper concerns as to
the use of Eastport as a shipping port for pulp. To date, these attempts have been fruit-
less.
fn 1969-1970 pLans were drawn for the construction and operation of a plant for the ma u-
facture of pearl essence, fish mean and high protein concentrate. The plant, Sea Life
Industires, was heavily subsidized with State funds and after only a few months of pre—
operation activities, filed for bankruptcy in 1973.
Attempts to specifically revive the fishing in the area have been non-existent except for
the experimental project being undertaken by the Passamaquoddy Indian Tribe at Pleasant
Point Reservation aid several small aquaculture projects.
69-6
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S9. The Eastport refinery is only viable in terms of overseas oil and not in a position to
refine domestic or Alaskan oil. The refinery will leave the U. S. at the mercy of OPEC
to a greater degree than at present. Will the decine in oil supply and use result in a
boom and bust situation in Eastport? How does the Georges Bank exploration affect the
oil supply?
R9. The refinery is viable with any source of crude and Is capable of refining
such. See FEIS Vol.11 p. IV—lff.
S10.Vol. II p. 308 — Even recognizing that probabilities of an oil spill of 500 tons (I assume
from p. 300 and table VT—i) that 100 tons equals 700 barrels so a ‘severe” spill equals
3500 barrels is difficult to predict, the figure of one “severe”spill in eight years is scary,
especially in view of the effects of the current. This coupled with the statement (Vt!,
p. 310) on the Maine resource base and the effect of an oil spill (V I I, p. 105) in Cobscook
Bay are disquieting.
RiO comments noted.
Sii.Coastal land is limited and valuable, is it too valuable for use as an oil refinery? The
CEQ favors monobuoy, deepwater ports.
R.ueomments noted. See FEIS Vol. II p. V—il ff with respect to l4onomooring off of
Lubec.
69—7
-------
23 Stony w I I o.e’J
port Jeffe cn, New york
Wovenber 3, 97
r ew EngIan ‘)IVIS ion,(J.S.Army Corpsof n Ineers
424 Trar)elo c oad
jalthem, assachusetis 02154
To a I I if may concern;
,‘y public comments regarding an oil refinery in Eastport, ;.a;r ———
easo s why Pitfstcn Co. of t ”ew York does not belong on the coast of paine
F INDINGS . FACT C DE
oept. of Env nr.entaI protection
. pccs it icn tron anidien jc.v’t Ic rzscIv issu cf ss - fircIJ—
C ne’ .
2. Sclic waste— sutphurize—rr’ nswer, “ unlikely tc live u7 tc ex—
ti
3. ff ns iv . .rs— a tz ssi.n c ntrc l - r 6 s’ r, “un’ikely”
4. r ct r cf lic r.t—”? cr reputeticn Ic live up te stcn rc s”
5. Ire f ‘ Ic c v rcn t—”— z rd fVz , f.: , e fi r r -c : y s :rc r kcs
E t’rt cnc cf ;rrz .1 icult: crt In t!c crl:. ’ xccHerf
rca ( :: “ ri t stcn sIrul r .:t t.C l lr r’ inf f js :y • The ti
r c’ ‘ii Ii n s v: j I I I ir it t r t f tr I ‘5 t: ; t’.z I r v:s ‘ Is
an I! y, t rcfr , ; ir st th: I’ s s I si-’z f’r t .— ‘n
crc ’tc c’cscsfcAy taki r tF!ir c,ut st y t cxNtin c--:, r ’.
1u ’ec - stpcrt m ,’ zx erI nce fire h z. r s teg’rc r’t c ’- . le tc
han:l:.) I
6. CII i l! — iv ys _ssi!. .k :n t li! l’ f. cccur i ny tires over, why
submit th un’erlyin sea to ey Its toll in gra !ual death and d c y
Evidence a •e rs ic have more re scns e ainst than for a cM refinery
on the untouched, uncontaminated coast of Itaine.
I do not f I the f fh Pi fts ten Co. will live fr their rar t in kecr—
ifl ? :.aii c safe for cnvirnrrentaI purposes and protection, hut will only
Succeed in doing whôt pjft ton wants fcr Pittston. Like the ‘ursin ’ Horre
scanda Is of ew york City , the profits are for the Company and when it
hurts their pocketbook they will nd keep up with the j high standards
you may impose upon them and will enevitably fall back on lowering 1hz
standards lo the least possible imcunt neccessary which likely II
elevate Offensive Odors, etc. etc. etc.......
To r.ecc.nsjder a DA!: at this time Is of utmcst irportance. Why shculd
Pittston dc whats best for pittston, why not paine do whots best of t:ainc.
Overpopu;jf being what It is It is the necessary tine to recc.nsider
the importance of en electrical power plant, and will certainly bring
Ifl fleccess y jobs an keep the coast of Paine clean nd Pure.
-------
December 3, 1976
REAScNS : HY PITTSTON OIL REF IN Y CESN’T 3ELO i 1 EASTPO T, t’AINE
The b st way for me to descrIbe how I feel about the ccast of
lame is to take writings from books of popular authors exactly In
this regard.
I. Louise Dickznson ich— “State of tame,” “The Peninsula,” and last
but not e;st , “ The Coast of 1 .eine.”
“ c dern life is increasingly corrupt with motive and profit and
contempt, but the coast sti It has kindly habits, a strong heavy sea
smell,
Summer folk came and built cottages — the people who made 3ar harbour
Into a resort had no hiterest in ??aine Life or tradition and were sim-
ply buying a beautiful siteand climate for their )‘ own worLdly
pleasures. They succeeded in dlstroying it.
The State of t;aine has pzrsauded•itself to print “vacation “ on If’s
license plates recreation business I its setting its own birthright.”
2. Gerald Warner 9racc— “The Island,” “Between Jind and Wafer”
“ The most dramatic play of coastal weather is the norfhweslerner,
the “cold front” that sweeps downout of Canada with a rush of art ic
air. The big ones go on for two days •r d two nites in the winter the
1ntens e cold comes with them. Perhaps of quality of clear dry air with
lf?som4randeur.
.3S,t nothing in the world’s land or sea is more beautiful than
w*+er—a the mornings after a greet norfhwcstcrncr. The air seemsfresh—
er, the wafer an intense blue with pale infinity of the sky. The
t’..Inz cc ist in the winter can se ..m opprczs,sivz with a week long north—
westerners an with zero days and nites or with northeasferljes blizzards.
3. Clinton Trombridge— “The crow Island Jcurnal”
“ An Island is it’s coast— it is th tide —ore than anythinq else
that gi s fi cw Ic ccastlir :pury n oliv :s5 ti’af N o szs es.
Rocks en I dges provide a solidity to which ol nfs and 3niT.a Is
aliki may cling wliTle th warfT 7 the folld H efc give t ern life again
io losi re T1oiThatui 7tc hi u Tcusoisgcr óT T
be miserly with its opulence is to distroy our hold on the plinef and
lose the sense of wondzr and respect for life thal are the basis for
c!j, r ora I I
. .,_rat- :..a.... s s : T”c i .t’ .-3r.; .311 Ii”in in ccar c . th . ID5;
c r Tz1 CI i “ C s1 :‘‘r u .-ir iJ1: r .—
In 1hz remote future we may inhabit a vist Disnzy in. and take our pleas-
ure in c serving pneuratic wildlife and plastic mountains an: artificial
snow. •vaten is merely a cream. Sgis the coast of t aine.
I :any will cling to it’,in sentiment and longing In order to esca e\fhe
anxieties and compulsions for a fcc crowded world.
Response: Typed by Louise Staqc of Port Jefferson
Comments noted. Long Is lend, New Vorl
Also see FEIS, Vol II, p.IY—53f
Vol III,p.A—5l—A7 70—2
-------
0022420
U.S.E .P. A.
egiOfl I
Enforcement Division; Permits Branch
John F. Kennedy Federal Building
Boston, Mass chUsett3 02203
Facts for your consideration:
1. There-:is only one road (Rte. 190) to Eastport and it is a two—lane
niacadain right—of—way. Since the proposed oil refinery is northwest to
westerly of the residential area of Eastport, the Rte 190 will pass very
close to the refinery, there will be no way out for the residents, and
thus, no way in for rescue apparatus in case of fire, explosion or other
disaster.
2. It is interesting to note that on December 3, 1976 the Big Money Men
showed up in force to support an oil refinery at Eastport — their interest
being profit for their companies and thus for themselves. They couldn’t
care less about Eastport or its people.
3. One constantly hears of the “Povery in Eastport”, — of the unemploy-
ment, etc. You should know that there are two banking institutions in
Eastport (Merrill Trust, a full service bank, and Eastport Savings B nb),
having total assets of 12 million dollars. (And no Rockefeilers in Eastport’
Please note the attached list of current businesses in Eastport.
4. The Navigational Aids which were glossed over, will be sophisticated
electronic device expected to be located on Canadian islands on each side
of Head Harbor Passage. Athe the December 3, 1976 hearing ,then Col. Chandler
asked Mr. Kaulakis about the navigational aids, Mr. Kaulakis answered “The
natives will not talk with us 0 . It should be noted that the 0 Natives” are
the residents of those same Canadian islands.
5. All else aside, the experts admit there will be a suiphurous stack
discharge which is deadly — especially during fog. There are approximately
4500 human beings living in the Eastport area. Surely now, this one fact
should cause consternation.
6. One local fisherman stated for the record that he believed himself
to be the only full—time fisherman in the Eastport/Perry area. This wan
(who was a witness for the Pittston Company during the Maine Department
of Environmental Protection hearings), referred only to the American side
and made no mention of the Canadian side. The answer lies in the fact
that the Canadian fi hermen are subsidized by their government, while our
American fisherman are on their own. Mr. Arthur McKay of Canada stated
at the hearing that some 3000 Canadian fishermen earn a yearly income
of $5,000,000 in nearby waters.
7. Please see the attached newspaper clipping, an Associated Press dispatch
from the Bangor Daily News of December 8, 1976. Note that the navigational
71—1
-------
Page 2
#ME 0022420
tJ.S.E,P.A.
Region I
Enforcement Division: Permits Branch
John F. Kennedy Federal Building
Boston, Massachusetts 02203
hazard is a channel SIX THOUSAND (6000) feet wide with a small island Of
twenty (20) feet maximum width, whereas Head Harbor Passage is given at
only ONE TH0U8i 1 D (1000) feet. Please think about it.
J. Harry Hu’ tohison
13 Boynton Street
Eastport, Maine 04631
71—2
-------
ME 0022420
5. s • E • P • A.
egiOfl I
orcernent Division; Permits Branch
Tohn F. Kennedy Federal Building
3ostofl, Massachusetts 02203
The follov ing is a list of the types and numbers of businesses
Ln Eastport at the current time.
barber 1
Eairdresser 6
1orist 1
Eardware stores 2
pharmacy 1
eweler I
urniture stores 2
supermarkets 2
banks 2
undertaker 1
ift Shop 1
Dress shop 2
amily clothing store 1
[ obacco/Ne vspaper shop 1
pizza shop 2 (one nev ly opened)
uitique shop 1
estaurants 3 (one seasonal)
v sales/repair 2
dvertising and printing 2
otels 2 (one seasonal)
uto body shops 2
1unibing and heating companie8 3
fuel oil disbrjbutors 2
i-as stations 5
Lawyers 2
Physicians 2
rchitect 1
Insurance gents 4
Real Estate Brokers 4
Sardine cannery 1 (seasonal)
Herring packing plants 2 (seasonal)
Christmas wreath decorating 1 (seasona
Christmas wreath makers 4 (seasonal)
Bakery 1 (seasonal)
Hot—dog take—out stand 1 (seasonal)
Newspaper I (bi—monthly- - 36 pages)
Fish meal fertilizer plant I
Fish scale (pearl essence) plant I
Woolen mill (Guilford Industries)
Mustard mill 1
Hospital 1
Neighborhood grocery stores 5
(one opened this month)
Privately owned water company 1
Privately owned electric company 1
Five and Ten cent store I
Liquor Store 1
In addition to the above there are 1075 telephones and 7 churches — one
seasonal. It should be noted that most of the above employ people
to work for them.
71—3
-------
3l Banger Doily News. Wednesday, December 8, 1976
i_V
Alaskan
ANCHORAGE, Alaska
(AP I — With the opening of
the trans Alaska pipeline
just seven months away,
some serious questions
about oil tanker safety
remain unanswered,
according to. state and
Coast Guard officials.
The last stretch of pipe
was laid Sunday on stormy
: Fhompson Pass, and the
SOO mile pipeline seems
certain to meet its
:scheduled opening date of
‘rnidl9l7..
But the result of two
recently completed state
Studies have r$sed doubts
Eabout tanker safety. Last
:.Thursday one day after
-results of the studies leaked
.:out, the state, Coast Guard
, and industry announced
they would meet Dec. 14 to
consider implications of the
studies.
One study said at least . , ,
mao pçiden s arfl1k
s _ jupçitanaets ply
their wa o1ffe
lQwer states cThying
Alaska chide oil — Wth
. spiflag Totainni n re uian
i rnon allons. ThfI
1iidy, was laSeu un
jtaiia cai anii sis !
ejy Jl w
anw eoes not take into
a navgation
1az rd at the mouth of
Valdez Harbor. -
‘the hazard, known as
“Middle Rock,” is a chunk
of land almost in the
middle of the
OOO.footwi4 channeL
i 6etween is aM ) ThCtU
mcter 1tha marine
:light standing about 25 feet
above the water.
- r
• A second styd; simulated
•tfilfFe by s yock T1t
1iiid that the rock.p 5 ? dT
nr1 p’ e in avoid
monitoring the
environmental impact of
the pipeline.
But a state source said
Alaska had only decided to
commission the studies
because of inaction by the
Coast Guard and industry.
“We waited and waited for
someone else to do a study
of the probability of tanker
accidents and a simulation
of traffic past the rock in
Valdez Narrows, but finally
decided to do it ourselves.
We’ve been stonewalled on
this by the industry and the
Coast Guard, although the
Coast Guard just may not
know:”
Coast Guard Adm. John
safety
Hayes, asked why the
Coast Guard hadn’t done a
simulation of traffic
through the narrows, said
the test used unproved
techiques. -He added,
“Valdez is not so unique
that there are. not similar
problems elsewhere in the
world. It’s not fair to say
we are suddenly
recognizing the problem.”
He also said the Coast
Guard is examining data
developed by the study. lie
noted the Coast Guard has
the prerogative of closing
the port if wind and wave
conditions make the nar-
rows impassable.
Hayes said he didn’t
eyed
know yet how often such
closures might be
necessary. Ayked when this
knowledge would be
available, he said, “before
the pipeline begins
operation.”
Port closures of more
than four or five days could
exceed the storage capacity
of Valdez holding tanks,
resulting in a shutdown of
the pipeline. Champion said
closures aren’t likely to last
thrat. Long, but Alyeska
Pipeline Service Co. should
be prepared for them.
Alyeska is the consortium
of eight major oil :flrms
building the $8 billion
pipeline.
bil tanker
•i ne rpçi. sou’e came
Ti ouSjjLcto,e ió iU
stu es were dOne
for the office of state
- Pipeline Coor nator Chuck
Champion; charged with
71—4
-------
t4df L
Q ) t .i-i
ME 0022420 DE ‘ 1”
U.S.E.P.A.
tegion 1
Enforcement Division, Permits Branch
John P. Kennedy Pederal Building
Boston, Massachusetts 02203
A point not brought up at the hearings is that Moose Island
(Eastport) has only one road leading in to it and one road leading out of
it. There is no other place a road eould be constructed on the city
side of the refinery site. In case of fire, almost a certainty at an
oil refinery, the city itself (the most populous area of the island)
could be cut off completely with no possible way of escape except by
boat. With our high seas, storms, fog, extreme cold weather, and almost
constant wind, this is frightening. e re we, the residents of Eastport,
expendable?” Yes according to Governor Longley, the Maine Department
of Environmental Protection, and the Pittston Company.
The United States Environmental Protection Agency is our last hope.
Governor Longley was elected, in part, because he stated he was opposed
to an oil refinery here. Once elected he reversed his stand and is now
shoulder to shoulder with industry. He has replaced, and, Is replacing,
those on the Maine Department of Environmental Protection who were con-
cerned about the environment with industry-oriented people. Now it
has become the Department of Industrial Protection. Even your own E.I.S.
study seems to indicate that a refinery must go somewhere so it might as
well be in Eastport -Downcast and out of the way. I hope I’m wrong,
but I received that impression as I read the study. Maybe a refinery
does have to go somewhere in the Northeast. But *hy in such a hazardous
place as Eastport? And WHY MUST it be built and operated by a company
with such a rotten corporate image as the Pittston Company?
One other thing has bothered people here. Mr. Kaulakis, being
on such a friendly and first name basis with the E.P.A. and the Army
Corps of Engineers, leads a lot of us to doubt the possibility of and
unbiased report. Again, I hope I’m wrong.
I’m enclosing a copy of an editorial that John Cole ran in the
Maine Times on 3 December 1976. It just may not be as “far out” as it
seems.
When they become available, would you please send me a copy of the
hearing testimony from the Eastport Hearing? Also, when you’ve
completed your E.P.A. study I’d like a copy of It. Is it necessary to
request it again? Thank you.
Nancy R. Hutchison
13 Boynton Street o Il—f- (
Eastport, Maine 04631
71—5
-------
Maine Times
December 3, 1976
it’s-a smash
Memo to: Cecil B. Socko
Hollywood, Calif.
Dear CR,
After “Towering Inferno,” “Poseidon,” “ arthquake,”
“Flood,” and your other crash-and-burn disaster epics which have
been so boffo at the box office for the past three years, I know you
must be up against it for more shattering scenarios. After all, it’s
tough, evet for you, to come up with a fresh catastrophe every six
months, especially one that has a sense of novelty and freshness.
Well, I’ve got one for you. Could be the biggest thing
you’ve ever done, CB, and it’s topical, too.
There’s a small city in the eastermnost part of Maine (and I
mean small, about 2,500) on what’s almost an island. There’s just
one road off the place. It’s called Eastport, it’s on the water, and,
guess what, it’s at the end of a 10-mile deepwater channel called
Head Harbor Pas age. (How’s that for a name that hasn’t been
overused?)
Well, CB, you wont believe this, but some outfit wants to
bring supertankers down that channel to unload at a big oil re-
finery the outfit wants to build in Eastport. There’s plenty of fog,
fast currents, rocks and storms. (Begin to get the picture?)
No one has ever seen a supertanker explode onihe screen
before, but when they see “Oilocaust!” (working title) they’ll see
it in wraparound-stereo. I think the boat should blow at dawn, in
the fog. You could get some great shots of the orange flames
against the silver mist.
Tlke burning oil covers the water in Head Harbor Passage,
floats in at ‘10 mph on the incoming tide (no one spots it for
awhile, to build suspense). It reaches the docks at the refmery,
they begin to burn. Then comes the smasher. Burt Reynolds
(playing the Passamaquoddy Indian that townfolk have ostracized)
dies trying to keep the flames .from reaching a storage tank at the
dock. That blows, other thnlrfi blow, the refinery begins to pop.
As the morning sun rises, so does the southwest breeze.
Flames from the refinery fire spread into the town (a bunch of -.
wooden buildings) and 2,500 folks try to leave at the same time on
just one road.
The whole place goes; neighbor fights neighbor trying to
escape — you can do this stuff better than anyone. CR. And, for
the big finish, just when the audience is limp, the tide turns,
carries burning crude oil up into Passamaquoddy Bay where
Canadian fishing boats, docks and buildings begin to burn. The
Canadian bossman gets on the phone to the President of the U.S.
and says if something isn’t done, Canada will declare war.
The film closes with a shot of nuclear weapons being loaded
on Russian planes with Canadian markings.
The best thing, CR, is it’s all so believable. Just about
every tanker captain who’s seen the place says it’s the worst oil
port in the world and the most dangerous passage in the trade.
Besides, I’ve already got 1,000 Eaatporters signed up as extras. A
• fellow named Kaulakis has agreed to play the skipper of the
doomed supertanker.
What do you think, CB? It’s a smash, right. (IN( )
71—6
-------
Response to Comments b J.H. Hutchinson
Si. There is only one access road to and from Eastport and in the event of a
fire, etc., there would be no way out for the residents.
Ri. See FEIS Vol. II p. IV—53ff, X—9.
S2. At the December 3, 1976, hearing big money men showed up in force. They
couldn’t care less about the people of Eastport
R2. Comment noted.
S3. The total assets of the two Eastport bAnks total over $12 million.
1 (3. Comment noted.
S4. The navigational aids were glossed over at the hearing and when Cal. Chandler
questioned Mr. Kaulakis as to their number and location...Canadians would
not talk with us.
R4. The comment refers to the location of navaids and the probability that they
would be located on Canadian Islands. When Col. Chandler questioned Mr.
Kaulakis more specifically he did not know the answer because of the
Canadian Ministry’s of Transport opposition to the project to date, that
they would not discuss technical details as to the location of the navaids
at this time.
This comment apparently refers to both the conventional buoys located in
the water, and to the electronic gear located on land. At this time, the
exact locations of the buoys cannot be established due to continued Canadian
opposition.
S5. The sulfurous discharge and fog is deadly.
R5. See FEIS Vol. II p. VI—78ff.
S6. One local fisherman stated that he believed himself to be the only full—time
fisherman in the Eastport/Perry area. He didn’t take into consideration
the Canadians and the fact that they are profitable with the aid of govern-
ment subsidies.
R6. Comment noted.
S7. There is a navigational hazard in the middle of the 6,000 foot wide Valdez
Harbor and Head Harbor Passage is only 1,000 feet. Please think about it.
Ri. Comments noted.
The narowest part of the proposed channel to Eastport is 1,600 feet wide
and 75 feet deep.
71—7
-------
DATE 12_/f c)/?
/5(? . i .ipec.
fTLEN
A TTENTION
SUBJECT
tcr ,
6?
URGENT
0 SOON AS POSSIBLE
9 DNOR EDED
t
(3 £(?,J4a0 QA C t 1 _-
c -c ,R
—EAb-i-ru1cr7crr,JMI .r .t vILt
40 Washington Street
[ STPORT, MAINE 04631
Phone 853-4628
ro
(A/’Z (
t1 s , Jifl I 4 t Y pft . TILc 7 44 C-y
ea rs t 4 cJ.( 1
Yc -ifrv F; 4 4
7 41’Pti e -a C.1 a
MESSA GE
2:1-
1’ tz L7 Tc>
3-q I t’Z c
rLc-7-(
JC,y
k ’c , r- 4- L.A.) f_f 1 -iiJ TE OF REPLY
(°L-b’ c& L.i ’O_ OLL 4 tv” J ‘tHv) rr f1 c-t ’, -- ø alL O 7V (/ I”ticrt LU 2 t ,
T tiucrt.J 4T L-i 1 4 i,ç ‘i- 4- c’ — i-c.. 1 frt 4) I,’o
r: P ii 7 S 16 /& 1 - (-5 fL i’-’ P - O ?1/ W ’f P
‘tci f4 P1/
t.i4 SIGNEO 3 J £i. - ___
14 DEC 976
1’
, c y .‘ i V 0 , ,e cy, sJv2 i .i ,- Ir i-i ‘.4 r ‘r —t I L ,4t Q ‘
: -t,t tJ/ r c, • i-( L
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S.. / rt f #4- c -SI.. (2 J - 2 c fri-i,- r’h ô ’ % , 0 ‘
q -, ‘C £-
Response:
Actual tests of tankers in the proposed route will take place in a fully loaded
ballast condition before oil tankers are permitted to transit the passage.
72—1
-------
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‘‘ ‘••-,- I 1I ’•.’ ’•’
• L A LQ t L u
• b oJ¼
f 5 AL(’.(
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LQ
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73—1
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73-2
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tW QQ )
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aJ ai a- q P fL
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( a F QL) )
Response : Coimnent received and noted. Boyden Lake is sufficient to
supply the refinery’s needs with a potential drawdown of only 2
inches(Mr. R.E. Johnston, Eastport Water Company). A number of ap—
proriate requirements and conditions of the Maine BEP permit may
be included in the EPA permit. After the issuance of the FEIS no
Federal Action may take place for 30 calendar days. This period is
to allow for comments from any interested parties.
Pittston. in cooperation with the State of Maine and the U.S.
Coast Guard will undertake real time simulation studies of tanker
passage at the National Maritime Research Center, Kings Point, N.Y.
. JL C O 9 (A O
aUQ4L,
/
‘/( J Qj
(5 ?
& L
73—3
-------
Crcws Neck
Lubec, Maine
01+652
December 10, 1976
U.S. Environmental Protection Agency
Permits Branch, Enforcement Division
J.F.K. Building
Bcsto 02203
Re N.P.D.E.S. permit ME00221+20
Sirs:
I live at the tip of Crows Neck jutting into Cobscook Bay where pro-
tein laden waters of the Bay of Fundy and the Gulf of Maine flood
thousands of acres of mud flats, coves and beaches. Cobscook is a
natural environment of much varied marine life and ducks and deer that
we Maniacs down here call Paradise. It is a privileg and an hcnor to
us that we can witness seal feeding in our coves in the quiet at sun-
rise. We are proud that finback and rig it whales are commonly sighted
in Passainaquoddy Bay and in Head Harbor Passage. We fish believing
there is a wealth of fish in these waters to be caught. We plan to
farm oysters. Currently, I am farming at Crows Neck to improve timber
and hay production.
What we do know, and this is supported in the Environmental Impact
Statement draft, is that an oil refinery, regardlesss of who runs it
(I have serious reservations about Pittston’s experience in oil hand-
ling and processing, and in their corporate and public responsibility),
and oil laden super t n1cers, regardless cf whc is piloting them, will
profoundly affect the clarL cter and quality of the aquatic and land
envircn cnt.
Lore to the point, let us address ourselves to the .I.S. craft about
which ycu have ashed us to coai. erit (I ttr- ride. the hearin in
i astncrt 1 ccen 1Ter 3 ‘out I a to lecve efcre sped ing at 7 P.1.. to do
fan;, chores). On the lio1e I c:;nnct acccit tie draft’s atterpt to show
that the econciric benefits of tie ret’inery outwei any change that rr:a
occur. In fact the E.l.S. is pittifully weak in the compilation of 1 nT
conclusions drawn from its data relatinc to oil spills, chronic and
74—1
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severe, their frequency and impact, both short and long tern.
Specifically, I am critical of the 1 i1ford Haven study and compari-
son to Eastport in th .t it does not elabor te how the two ports
compare in incidence of fog, ranges of tides and speed and n :t .re of
currents. The E.I.S. in Vol. II, p. 300 merely says “the tidal range,
the currents, the channel depth aná width, the sea approaches, the ex-
panse of water surrounding the channel, and the adjacent land terrain
at l ilford Haven ar all similar to Eastport in many ways.” Table
IV—8, Vol. II, p. 221 provides scanty details but no figures dealing
with fog. I would suggest that a “f g factor t ’ be included in cal-
culations that might more accurately reflect probable chronic spillage.
I might also suggest that the 22 to 86 barrels per year spilled may
have additional meaning if a potential for severe spills were included.
Reading the draft the 22 barrel per year projection for Eastport based
on 1 ilford Haven as a model facility had little credibility when it is
considered that during the 9 years studied there were + severe spills.
When these spills are considered it Is possible, for example, to come
up with a figure that 5 4.l#.L4. barrels were spilled per year.
From my viewpoint, then, and at the very least, an oil port adds up to
high risk and questionable return, no matter how we cut the cookie.
Please do additional study of oil impact and spill probability which
will pay due respect to the natural environment.
Ag a final comment, no where in the report is it detailed how the
Pittston Company would be held liable for damages to local industry,
and the environment should a severe spill occur, not to n ention long
term damage due to chronic spillage. Volume II, p. 309, does state
that booms will be available to lobster pounds but who will maintain
and operate these booms? How effective are they in light of the fact
that Ealne B.E.P. granted variances to oil terminals in the Penobscot
River at Brewer and Bangzr, because according to the Bangor Daily
News of December 2, “fast currents In the tidal river make booming im-.
practical .“?
In conclusion, I would like to say that 1 suppoit the report of G overnor
Longley of the kaine Land and ‘later Resources Councul, which was released
December 2, 1976, and the continued opposition of the Canadian govern-
ment pointing to the inherent dangers of’ oil handling to marine and other
wildlife and to related local industries.
I appreciate your efforts to date on the behalf of the people and natural
resources of I aine and I want to thank you for conducting a baL nced
h rin’ despite ti e frct that irony folks had to leave prior to its con-
c lug ion.
S el
JazQ H. Buehner
74—2
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Resp nses to Comments by J.H. Buehner
Si. The Cobscook Bay area is rich In natural resources and it is a privilege to
live here. We believe that there is a wealth of fish to be caught in the waters.
The refinery, regardless of who runs it, will affect the quality of the a4ua-
culture and land environments.
R2. Comment noted. See FEIS Vol. II p. III—159ff, p. VI—iff.
S2. He cannot accept the draft’s attempt to show that the economic benefits of
the refinery will bring any change that may occur. The DEIS is also weak
with respect to oil spills — chronic and severe — and their associated impact.
R2. Comment noted. See FEIS Vol. II p. Vl—29ff, Oil Spill Effects.
S3. He is critical of the comparison of Eastport with Milford Haven. Fog, ranges
of tide and speed, and the nature of currents must also be compared. A “fog
factor” should be included in the calculation of spills, The oil spill ana-
lysis of Milford Haven has little creditability because of the exclusion of
•severe spills.
R3. See FEIS Vol. II p. X—26 (response to statement #2). See FEIS Vol. II
Table IV—9, for a comparison of the ports of Eastport and Milford Haven.
See FEIS Vol. II p. Vl—381f regarding severe oil, spills.
S4. An oil port adds up to high risk and questionable return. Please do an
additional study of oil Impact and spill probability which will pay due
respect to natural environment.
R4. Comment noted.
S5. The report does not detail how Pittston will be held liable for the damages
from an oil spill.
R5. See FEIS Vol. II p. X—Sff.
S6. Who will maintain and operate the booms that Pittston will provide for
the lobster pounds?
R6. Pittston will provide the boom and pound operators will be instructed in
their use. In the event of a spill, the pound operators will be notified
to position their booms. If they cannot be contacted, Pittston will deploy
the booms.
Si. How effective are the booms?
Ri. See FEIS Vol. II p. IV—38ff.
S8. He supports the findings of the Maine Land and Water Resources Council
(Gov. Longely).
R8. Comment noted.
74—3
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57 3C 7 10. e 2 O ’
0 Dt 976
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Response:
Comments noted.
See FEIS Vol. II p. IV—23,
p. VI—59, p. X—26U,
75—1
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Response:
Coimnents noted.
See FEIS Vol II. p. 111—159, Other Federal Projects in the Area.
Both projects are compatible and would benefit the energy position of the United
States and the State of Maine. ____________
76—2
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1 DLG i 76
COMMENT ON DRAFT ENVIRONMENTAL IMPACT STATEMENT ON
A PROPOSED PETROLEUM REFINERY IN EASTPORT, MAINE
NPDES Permit Application Number: ME0022420
corps Permit Application Number: 25—76—367
The First Selectman, the Chairman of the Planning Board, and the
Secretary of the Planning Board of the Town of Isle au Haut, Maine
appreciate the opportunity to comment on the draft Environmental
Impact Statement on a proposed retroleum refinery in Eastport, Maine.
Isle au Haut is a small town lying between Penobscot Bay and Jerico
Bay. it is in what the draft Environmental Impact Statement calls the
“Penobscot/Blue Hill Bay” area.
We are concerned that the draft EIS does not adequately consider
hazards to the fisheries in terms of specific areas which may be affected.
The draft EIS does not contain any oil spill trajectory studies
along the lines of those held up by the Council on Environmental Quality
as “models of the sort of work which should be done in any terminal area
under consideration” ( OCS Oil and Gas, An Environmental Assessment , Vol. V,
“Oil Spill Trajectory Studies for Atlantic Coast and Gulf of Alaska” p. 77).
The draft EIS does rc ognize the general surface southwesterly current in
—1—
77—1
-------
the Gulf of Maine, the shoreward bottom currents, the tidal patterns
at Eastport, and the Portland wind roses (Vol. II, pp. 59—77, 134—141);
but it does not attempt to pull them together and apply them to the
spill problem. The deficiency is serious.
In the draft EIS we are unable to find any examination of spills
from the oil terminal at St. John, New Brunswick although they too feed
into the same general current pattern. If statistics on St. John spills
are available, they may furnish an input into meaningful trajectory
analyses. Perhaps they might better serve as an emperical check on such
analyses. We attach a press report of a spiii from a supertanker unloading
at St. John last June which evidently caused concern as far away as Machias
Seal Island. While the currents are much stronger in Grand Manan Channel
than further west, Machias Seal is about the same distance from St. John
as Mount Desert is from Eastport.
We are concerned about hazards from tanker and barge traffic of
products to New England and New York markets as well as hazards from
VLCCs. The hazards from the product traffic are demonstrably real. The
Seventh Annual Report of The Council on Environmental Quality notes
The Implications of large spills were again
demonstrated in February 1976 when a barge
carrying heavy heating oil sank and released
approximately 820,000 gallons in Chesapeake
Bay. It was the worst spill in the Bay’s history.
The full amount of damage was not immediately
apparent because the oil first sank below the
surface rather than floating on top of the water,
as would normally be expected. Within 2 weeks,
—2—
77—2
-------
however, an estimated 20,000 birds died, and
widespread damage was forseen for the area’s
valuable fisheries from Smith Point (Va.) —
Tangier Island (Md.) to lower Chesapeake Bay.
(CEQ Seventh Report , P. 25)
The proposed refinery at Eastport emphasizes production of
heavy home heating and industrial oil to an unusual extent. Apparently
176,900 barrels per day or more than 7,400,000 gallons per day are
envisaged (draft EIS Vol. II, p. 250).
Product tankering and barging form an integral part of the Eastport
refinery concept just as supertanker importing of crude does. The draft
EIS mentions the subject a number of times in connection with facilities,
immediate approaches, and economics. But we cannot find that the draft
EIS considers tanker and barge routes or the problem of spillage from
those routes.
The draft EIS describes the Penobscot/Blue Hill Bay area as the
“center of Maine’s lobster, clam and fishing industry” (Vol. II, p. 279).
This appears to be considered an argument for preferring an Eastport site
to a Penobscot/Blue Hill Bay site. It may be that. But is it not much
more an argument for preferring no site — or a site far to the southwest,
“downstream” from the “center of Maine’s lobster, clam and fishing industry”
and also able to reach the chief prospective markets without endangering
the fishing in question?
—3—
77—3
-------
The draft EIS concludes with an observation that
The operation of the refinery represents
the commitment of the community, region
and State, to accept the risk ... that an
accident could affect all or portions of
the fisheries in the area. (Vol. II, p. 360)
What area? The draft EIS doesn’t indicate over what area the
fisheries are to be endangered. It seems not to have really addressed
the problem.
We have great difficulty understanding how an Agency charged
with protecting the environment can seriously consider jeopardizing
a renewable resource (fish) for the sake of an activity dependent on
a non—renewable resource (oil) which the world is consuming as fast
as it can. The principal argument for the refinery is the economy of
scale in bulk transportation. This is also a principal environmental
hazard. We don’t see why oil being more expensive in New England
wouldn’t stimulate the use of alternative sources of energy and even
the development of renewable sources — to the great long term advantage
of the environment and people everywhere. On the other hand, we can
see that a case of sorts can be made for a refinery in the Portland
area or western Maine. Such a location would avoid some hazards to the
water.
We urge that, at the very least, the final EIS carefully consider
the impact of the proposed Eastport refinery on fisheries by specific
area.
—4—
77—4
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For Jack MacDonald, First Selectman, Isle au Haut, and Harold
W. Turner, Chairman Planning Board, Isle au Haut,
December 12, 1976 -
F. A. Eustis II
Secretary, Planning Board
Isle au Haut
—5—
77—5
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( \? f \P’d
\ 1 dLJ
tTh r t ’ ‘ r
‘ q (r 4
,— ,— “r-’ ‘,rir ’ 1 -mr, r’-’ ‘-j— —
L L CdJL.w
In late June. as this arti-
cle was being prepared, the
supertankor J.R. Gray,
owned by the Chevron Ship..
ping Co., a subsidiary of the
Chevron Oil Co., experl-
encod a ptll while unloading
at Saint John, New Bruns-
vi ck. At th time o th 3 spIll,
the 233,C ;O-ton tanker was
discharging crude oil
through a pair ol 18-inch
hoses to a monobuoy in the
outer harbor. Tho vessel
slipped its mooring and the
hosos, then under 160
pounds of pressure per
square Inch, were torn apart.
Since the entire region
was enveloped by a thick
baiik of fog, the exact size of
the spill could not be deter-
mined. The slick traveled
southwest — straight for Ma-
chlas Seal Island, 80M0 GO
miles away. Boforo dissipat-
ing in the ocean and atmo-
sphere, the crudo oil Ira-
volad r ore than 50 miles. it
come a .hore sti along tho
Now Brunswick coast, pollut-
ed Eastport and Wost Quod-
dy Head in Maine, and
fouled the lower reaches of
the Saint Croix River.
Because heavy fog per-
sisted throughout the latter
part of June in the polluted
area, It was impossible to
determine if any of New
England’s alcids were killed.
The slick did not reach Ma-
chias Seal but bocause of
the fog, no one could deter-
mine just how close it came.
Clearly, It was loss than 20
miles from the razorbilis and
pucriris and perhaps closer
than 10 mIles.
Shortly aftor the fog
cleared, William Gill, an alcid
specialist employed by the
Maine Audubon Society,
wont to Machlas Seal to
chock on conditions there.
Although he found no dead
or dying alclds on the island,
ho discovered several badly
ollod auks white returning to
the mainland. Thus, it seems
entirety possible that some
of the Machias Seal birds,
while-searching for food, did
encounter the slick and died
at sea.
—W.B.W.
Boston Globe , Sunday November 28, 1976
77—6
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Responses to Co ents by F.A. Eustis
Si. We are concerned that the (traIt ELS do s not adequately consider hazards to the fisheries
in terms of specific areas which may he affected.
‘l’hc DE [ S does nut contain any oil a pi t 1 trajectory studies. The DEIS does not put the
factor of wind, currents and tides together to determine their effcet on an oil spill.
No statistics on spills from St. John are included. They may furnish an input into
meaningful trajectory analyses.
RI. See Expanded Oil Spill Section in FEIS Vol. II p. VI- 29 ff, Oil Spill Effects.
s2. The DEIS does not consider product tanker and barge routes or the problem of spillage
from those routes.
R2. Product tanker routes and spills resulting from tankers in transit, will be handled in
accordance with applicable regulations.
In the event of an oil spill that occurs beyond the immediate site area and approach
waters, Pittston will make its oil spill equipment, personnel and expertise immediately
available if these resources can be effectively employed and safely deployed and operated,
and if cognizant authorities approve, and if approval and direction is given by cognizant
authorities as called for by the applicable regulations.
s3. They would prefer a site “downstream” from the “center of Maine’s lobster, clam and
fishing industry” where the refinery would be able to reach the chief prosçective markets
without endangering the fishing in question.
R3. Comment noted. See FEIS Vol. II p. VI-l ff, p. X-42ff.
S4. The DEIS has not addressed the “area” in which the fisheries would he damaged in the
event of a spill.
R4. See the expanded oil spill section FEIS Vol. Hp. vi—29ff,Oil Spill Effects.
S5. They have great difficulty understanding how EPA can consider jeopardizing fish for oil.
The more expensive cost of oil in New England should stimulate the use of alternative
sources of energy and renewable sources — to the long term advantage of the people and
environment.
R5. Comment noted. See FEIS Vol. 1111 IV—iff.
77—7
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13 DEC 1976
U S Environmental Protect1 n Agency
Region I
Enforcement Division, Permits Branch
JFK Federal Building
Boston, Massachusetts Re: MEOO22L1.20
Dear Mr. MoGlennon:
While it may be true that the Pittston proposal was originally foisted
upon us because Its perpetrators were under the Impression that they were
dealing with a “receptive local community,” the fact of the matter Is that
the local populace is far from receptive. The only persons really in favor
are those businessmen who stand to gain monetarily. I think the testimony
on 12/3/76 Is a perfect example of thIB, the bankers and. chamber of comrn—
erce hacks almost droolIng at the prospect; However, I heard few If any of
the little guys, the ones who are out of work and would go to work for
Pittston, testifying, Where were they, it, as the businessmen tell us,
they would. be the ones to benefit.
Secondly, Mr. Ross t s comments on how easily the present school system could
accommodate a doubling of population Is naive, not to say simplistic. With
a present school population of 250.260, the high school faoIl tiea are
crowded, To double that population would cause much more disruptiOn than
Mr. Rose Is willing to admit, It would probably mean a new school wou3 d
have to be built, with double sessions during the construction phase of
the school, with the consequent disruption of the educational process.
Your DEIS comment on housing Is equally lacking. There is certainly not
an abundance of housing in this area, even counting the substandard hous-
ing in Quoddy Village. Any substantial ## Influx of workers would have
to live In some kind of temporary housing. There Is just not enough
decent housing here to accommodate the present population, much of which
lives In what a construction worker would regard as very substandard
housing.
Wh11 I am not qualified to comment on the scientific aspects of the DEIS,
I can only hope It 18 not as fraught with error, inaccuracy and omission
as the rest of the document, W y was it necessary to use Portland weather
as a data base, for example, when there has been a weather station here
for over fifty years?
SIri erely,
• (1 j. i) . : /L
• George Lehigh I
• / / / /L L
7 Ci tome Street / - -:( I’-
Eastport, Maine
i
O
Response
Comment noted.
See FEIS Vol. II p. III—ll3ff,
p. VI—iff, p. VI—22, VI—l4ff.
78—1
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U3 àt*4 P tCtt* A omcy,
.RegLo I . Enfarc 1 asj Ptvidtops.
P2to*4)(iu$ O2 O3 ..
! isI1 f4!u ::
•i
am Pc.tpt c t and ?ami*kç with the nt.nta of VoI’2 a d
et.th.DraftJnv4j onmente1 impact Statement. concerning the P$ttston
Oil çaf1z r= and )Iajine Terminal, in £astport,
M I r.*Ld.ntb$ Trescott whese Work takes him away tram b. area
; nsun*bl eto .atf#n i the Dec 3 publir hearing, am $hü submttttn
*7. s snts by:: 1*tter. .
-l -; . - i- :. .
- ‘ ,1I tepo4 uema rather coatZy and very rosiplete, fl
b2cOrPOnt.. ;tbe ,leadinge and findings of Pjttsenn which alope have ?.
run:ir .tOaaiW,Mjjl4On$ of dollars and yearn of energy to prepa , t
iw. ’ an impressive work. It is, however, sJ.qn1ticently4efic cnt im one
of u a oj importa nce, The report ncwher’ øt ee that it.
has m?rutjniDm only one thin slice of a very large pie. It eompløtely.
misleads the rude; into believing that by bping aware or t)i. .. ,.
facts within the repOrt he is aware at the tOtil
Pictur*i.Vor )naid ed of years such reports have led the a u.ri as p.ep$.
down. ga; ).n path to environmental dete* zattpn and m i d . dia !aatort r
t*; Lk**Gt .vbich. have perhaps never before been seen cj the face of.
• thIq ‘.plar t, As a government agency and environment*1 prot tion ‘
agency.’ 31mU* apart through the neqliqcnt error QC omiasiofl 1 t.akeet h.
Saith Df:thS Aa.ric ai citizen in hiu govørnmen and rapes Mm with It 1 ‘:,
• .cbvtously. this letter can in no way come doe, to dec q th.
largs sectian.of thepi. you have omitted.- t woui4 ake many —
a ditLonalyeari Of work and millions of doUars to be don lw *an
hichvotal4 ee close to equaling thh work which h45 gone into the ...., ‘
i r*ft and refinery to dat .. The tinw, thejnon.y, ar. not .vai able
, j,’ :noç vjfl . they ever be,, Jgbo y etancfn 10 mako a fInancta prf1t
.frOas h.1 report, Without the p fij motive there would .
reii’rY, ’ pitt.tom and itø stock hojders are building the ’ .
fjp flp ney, no matteg the consequences, ?hnt’ pa .q
cmitted:plctur.. Why ii it not in the report? “Items
aad three yea*’s of unopposed publ4c relations g4 lobbythi
pittiton hive bombardej and brainwashed the reader of this.. r por .int.
feel,ing .forteble with living in the prowimity at a o4 sp443,
timebo** and env ronmenta disaster”
“ ‘.-•
*• 1,, •. . .. •- .• .-,‘ -. •
The fdsnl government under the 4’4n. of onvtron.enti$ pret.cti
‘:impIa tth. aam profit mot vs game with puhltc funds. Thiais-
i*fOrgi 1.abl., . The. e vironmental protnctlon nqency 1heul,d )* apemdth
ual va llia s and i .rgiee to protect the pnvironM*nt,, ot.g4v
cred cS;t an oU refinery whose total impact in the long çun
* nv jcn.nt4l d.t.riation..no matter how careft4 .t ia,,sia matt.r,,
aany Sinai or penaltys it pays. That’s another part of be. picture2 .
.iei t : .it? Where is it in your ri ’port-7 “Items The federa*..goveusm.at ’
1Ckno l gsably spending public funds to lcn4 pr.edencotoam oil i-’.’
rIfii.r operation which by its own admissiofl in the long runwil 44
tó. psIl*io . . d nvircnm.ntal det.eriatlonnf the coast ot Wa*hia*.s
9— I
-------
— I
• $ etPui’psrts at the pie leek Ilk .? What *1*e
t* luds4 i the enwironmental impeat statement? Wh.rs 40 the rect
tI t the public feel. protected zind accuro hec*ua• t t uut is.
itional and 5ate vernm.nt and there so rsl*.d nvtronmental
protectiom Agencies, These aqenct.s are in srtuaUty the puppets
t.tbe -p .rfu1 protit motivated corpor $ ona which in 3 e long run
br. the funds and coetscta to i fluenco the economically oriented
peiticians and representatives who 4n the aoverninerit, Under the
praaemt a 7of ci(cumetane.. the environmental protection ag.no es
:Msr*ly tamp0ratiIYiWeVent the profit lust of corporations from sobbflisq
the emviromzen,t, 1j at once ( for e mmpW the refineries otBayonne
N J.a.y or Beaumoi t Texas). ?h.y are in no way effectiv, protectors
of 11emvirooment. True enviroemental protectors would never wi l linglp,
k.taay:emti y i.t which would increase tPE probabil4ty orcb*nc*
thettb ..:emviroam. t rould su1te r det.riat.4an a; be harmed ( just as
t.he.-?smtgon wos44 never 3 t usiiia have a navel bas. in Washington ,,
,..iemtbough the Pussiane premised to une it a!ver.eJy, That’s
whit oem iqht c ii i pyotect on. . The envi ronmentiU protection we have
mo is xwththg more than reguhat ions whirh temporar i ly slew damn the
rat. cf st.xiation) !tems The reader ahou3d be fully aware that the
PassemaqUoddy environment i presently under o protect io, eç -
rpr motstion within the federal or state gnvernment. It’s i t.qrity’
emd iue. is only being conveyed b the overwhelmed, helpl•adn
tbevgbts and actiOns of a concerned majority who have mJsguid.4 a I$ h
oremf.tthiatheirgovernment, -
& tb. omitted section of the pie should deal. with the t v.s pt
,tb indigenous plant and anim sl population. We14 over aim humdred
epsci.sr.preeentj.ng many bill ona of l$vlnci creatures I Volume III •
*ppesdiz 1) are pert of the quoddy environment. Minimal observation
conclusively..deumn.trates that each of these creatures wants to Jiva
and not. to d i., The oil refinery is an obvious threat to the livea
- of thes. creatures.. “Itesi, The legal a,epresentatives of lens than &
2000 living hemaa cg.aturoa in kastport, Maine have *ndisc;Iminately :.
decided upon the potential f.t of many billions of living organisms
with vlw they share the q.oqrsphl c environment, lhaa overwhelming
emjorit*f. living Organisms in the area (including people) desire
:envixois”untal quality and life, Their 0* eJtproeeecI desire are. bejns
overpowered and ridden roughshod by a foreigh corporation(. ittaton, )IV )
email minority of i ndividua l s . * -
• .. - .1- - —
-. d Z ge on? Where in your re)ort are the potent 1*1 effects at
eUp water c m mariom maimirnis which are supposedly protected from death
by.f.dsral law? They are dependant upon microscopic plankton for food.
V**,*tOm, the ultimate too1,is iffecterl by nil, Where are the d.tria
effects of oily water on the lobeteF larva pnly the mature lobster is
-inoladed -in your aport., the IarvaJIF danqerouajy susceptable to oil
kiU)..WMre is the diminishing avallabiUty-ot oil mentionedj ihLc4 vdi
*ska the ref inety outdated nd wrnecnsie ry in ten or fifteen year.?)Wher.
is I listtnq of alternative energy ro ’ nurcos? Where is the affect 01
and •il refinery upon the scenery at the rent of us at Cobacxoli-( the-’:
re is.ry cam’t be seen from Iastport but it can be seen from the rest
ef -the hey, sp.cially Lubec. Where iii the effect of developed .
4 ese does not feel comfortable dumping his trash th ctmrcb
( -
/
-------
-. .
J1FLU , f gosims about dumping ti p13 PØUI .$i ’
a.Jtm yerd), Iconid go on. So aou ld you. t whO wiUp1 yo .,
to. v it. t re1ider of thi? report? You are ec iicatiag tb. pub l4e
to what Ptttstona men. wants them to learn • Who will teach them t . : ..
C’ a r. inery, : ‘ j
• “I
AU:ot. ms age potent ial1 ’ Fatty Ueaçmt .,.OK when th •.evtroememt
,:.t*C , ,.b!urr . whefl ur environment I a atreasful;, .H v.aanyitua :
:-reaUy v t It? Where is it n your reportj’ “Itls;., WAkNUG.*’ho
zs.otM t y deterinine4 that a deteflated envjroflmentje
:d.t 3.ms t*1 to 5uP helith, ‘That which befalleth thè’ Qn!a of mefl
•eial4,th bee. • .bø the one dieth pa dieth, the otberp yea 1 fr.bey.
hive: $14 breath” $cclesiastee 3,18, :
I . ,
-, rhiv ’t got the years, or energy to writs the remi ef the ‘
4 ! POrt’.I.hsw only the inclination. I don’t know t( ’ uev
‘that.’$Vem .f you d d who’s paying you to toUow itc’ Not’ )‘oUç
(1ac1•jS , $ Not aie....nobody. Thus no eonp1etp r.pOrt.p tte$ *
. ho3.J1l th’cøzdm don’t they? You, I , and the envira $e t s naIl ,,- “
di t.Wtdsr the feat of the powerful men with money! Pecha pa 50 1 $fl
• fact sheuld go Into the report. “I tern; this report, only r.preasf*a
• .1O% óf the’snvjr or ente1 impact of the Pittston Oil Pefinery,. . :.
.xem isdsr ,‘ i1 .detri*ental test irony and evidence gatasti the
refin .r7 jé unavailabl, due to lack of funds, Ick of gowrna mt
kntagrit nd . .emvironment iJ protection aqenciem the er .,
. . ciaithre v Lcb cares, and the personal a ln of the pownrful. faw. w . ,,
hongjithe L nity granted a corporation gain at the expena . Of the
ii’ ib1tc.. ” the gavironment” Shouldn’t •t ln *st that statement app.ut..
‘h/li,.
ye;
79—3
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1(e ponses to Comments by MJ. Cohen
Si. The report has been well written for only a very small part of the pie.
Pittston and its stockholders are building the refinery to make money.
The federal government is playing with public funds and this is unfor—
giveable. The public feels secure because of federal agencies and their
duty to the public — they are miHguided. All of the billions of living
organisms in the area, including 2,000 people, had their potential fate
decided by the legal representatives of Eastport.
RI Comments noted.
S2. The effects of oily water on marine m i mtsls is not discussed What are
the effect8 of oily water on lobster larvae?
R2. The lobster larvae are harmed by lover concentrations of oil that is the
mature lobster. From mid—June to mid September, the lobster larvae in-
habit the upper 2—3 meters of the water column and therefore would en-
counter a greater probability of being adversely affected by an oil spill.
S3. The diminishing availability of oil is not considered nor is the aesthetic
impact.
R3. It is true that the known supply of oil is diminishing, but as new tech-
nologies and increased drilling come about, more oil may be found.
From land, the visual Impact will not be significant because of the topography of Moose
Island and the location of the residential communities, The high ridge ground splits the -
Island basically into two parts, effective isolating the site on the westerly half from the
Eastport community which lies on the downward slope of the easterly half. Only the 300
foot stacks would be visible, and only from a few sections of the town, The visual iminct
from the highway entering Moose Island will be reduced by the 100 foot buffer zone of trees
between the refinery proper and the boundary fence line. Furthermore, the principal
structures will be 1,000 feet or more away, and on downward sightline. From most of
Quoddy Village, which lies on the far side of a 100 foot hill that faces the site, the refinery
will not be visible exceit for possible the stacks. The view from the Point Pleasant Indian
Reservation in Perry will be virtually obstructed by Quoddy Village.
S4. Who will pay to write the remainder of the report? You are educating the
public in what Pittston wants them to know. Re doesn’t have the time or
the energy to write the remainder of the report.
R4. EPA is the responsible Federal agency on this project and has prepared the
FEIS.
79—4
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U.S. EfJVIRONt’lENTAL PROTECTION AGENCY
REGION I, E F0RCEME 4T DIVISIOr , PERMITS BRANCH 1976
JOHN F. KENNEDY FEDERAL LUILDING
BOSTONJ MASSACHUSETTS 02203
RE: NPDES PERMIT APPLICATION U BER: MEOO22 12O
CORPS PERMIT APPLICATION NUMBER: 25-76-367
I strongly object to the weighing of the economy in with other fac-
tors as part of the environment. The economy is synthetic; that
is, it is man-made, whereas the other considerations to be weighed
such as water, air and land qualities, with all the varieties of
life forms that inhabit them are natural. The inherent character
of the economy is predatory and inclined to rape the natural ele-
ments to the glorification of its own ends.
Nan is the creator of this, and, as he is a proud qreature, te .nds to
look upon his handiwork with favor. I fear that this predisposition
will carry a weight more than likely to tip the scales in favor of
economic factors, rather than the vital elements of the eco-system.
It would take several volumes to explain all the complexities of
the economy, which would be too much for this small report; never-
theless, I feel it important enough to give a brief summary of just
what it is (including the Standard of hiving, with which it is often
equated) and its effects, not only upon the eco—systemn, but, perhaps
more importantly, upon the people who live under its influence.
80-1
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The econcmy is based solidly on production. Alas for industry, pro-
duction is only one—half of a healthy economy; consumption should be
equally important. Thus, a dilemma: more goods than the average con-
sumer needs. What to do about this lop—sided Frankenstein? Cut back
on output? Perish the thought! Create instead a climate which will
facilitate the consumer’s ability, need, and psychological need; i.e;
want o psychological dependence upon buying much and often to consux e,
often beyond the bounds of reason.
To quote an. authority:
“By the mid—fifties American goods producers were achieving a
fabulous.output, and the output with automation promised to keep get-
ting more fabulous. Since 1940, gross national product had soared
more than 400 per cent; and man-hour productivity was doubling about
every quarter century.
“One way of viewing this full, rich life the people were achie-
ving was the glowing one that everyone could enjoy an ever-higher
standard of living. That view was thoroughly publicized. But there
was another way of viewing it: that we must consume more and more,
whether we want to or not, for the good of the economy.”*
The Standard of Living is determined, not upon the z eeds of the peo-
ple, not upon the point at which living becomes comfortable, not even,
indeed, at a point approaching affluent, but upon the abi]ty of the
people to consume. In other words it is not set at l1 but subject to
the vagaries of the economy itself. It is not what it was ten years
ago, nor will be what is ten years from now, yet people seem to have
formed an opinion somewhere along the way that if one cannot “keep up
with the Joneses” by buying at least two cars and the garages to house
them, three T.V. sets (one at least in living color), a fur coat for
the wife, innumerable “step-saving” objects and gadgets strung all
throughout the house and the surrounding grounds, most of which are
in the kitchen if they are of any real use at all, plus some form of
expensive “recreation” equipment such as golf clubs, snowmobile, boat,
membership in a tennis club (or at least the presence of one in the
80—2
-------
communityj not to ment .on the ability to travel at least a hundred
miles on one’s vacation, then the person is below Standard of Liv-
ing; ergo, a pauper, and in dire need of financial assistance from
some luckier portion of the society, before the hapless creature
dies of embarrassment, or, worse yet, has to live with it, which of
course cannot be borne.
Obviously here we have a case of valuing quantity over quality,
based on “facts” which have no meaning as they are based upon an
elusive, fluctuating, hypothetical point which varies from day to
day and is arbitrary and dubious at best.
“We have no proof that more material goods such as more cars
or more gadgets has made anyone happier—in fact the evidence seems
to point in the opposite direction.”
We should “recognize that possessions were meant to serve life,
and that life comes first.”
“We are being carried along by a process that is becoming an
end in itself and which threatens to overwhelm us...there is a loss
of a sense of proportion in living....”
In short, the benefits that would accrue to us consist of having to
continually work ourselves into an earlier and earlier grave that we
may spend more to buy more of what we already have nough of: more
cars, which it may surprise you to hear that we happen to have, and
you don’t see too many beat-up old jalopies, either, more CB sets
(did you know there are more CB sets than households in Eastport?},
more T.V. sets (yes, we have them, and many in color, too), more
(and more expensive) boats, which we do riot lack, snowmobiles, which
there seems to be a glut of, etc, and these benefits all for the high-
er good of the economy. Is this needful? Seriously, Is it even rea-
sonable?
And what is to become of a people traditionally set in tlieir ways,
forced into this more accelerated, more fabricated and unreal land—
80—3
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scape, uprooted from their own cultural heritage and alienated?
This is a matter with deep ramifications, which I am not prepared
to go into here, but it deserves your every consideration.
Other matters deserving of more attention than they have been get—
ting are:
1) The question of the airport. Why has no mention of the existing
ruling that an alternate facility must be found before an airport
can be closed? And why has no action been taken? Furthermore, as
seems to be parr for the course, the people have had no say in this
matter?’
2) The terrain of Shackford Head is not flat, to make an extreme un-
derstatement. Those huge tanks cannot possibly be set upon it with—
out extensive alterations. This should be looked into, as it brings
to mind other questions, such as the extent of the alterations, the
manner and materials used, and the disposal of the excess land. Not
to mention that all this must be done without defacing the Nutt pro-
perty. If the alterations are extensive enough, will they provide
her with a helicopter in order to gain access to here land?
3) There is only one road out of town-past the refinery site. Should
some emergency arise this is extremely unwise and unsafe. Have any
plans been made to complement this rather near-sighted factor? And
who is going to pay for all this?
I could continue, but as I have at least touched upon a few points
that deserve your attention, I close with the hope that I haven’t
wasted my time (or yours).
KATHRYN A. LEWIS
41 TIIIRD STREET
EASTPORT ME. 04631
80-4
-------
* ]] quotations are from THE HIDDEN PERSUADERS by Vance Packard,
Van Rees Press New York 1957. I sincerely recommend it. In the
event you choose to dismiss this material as hopelessly outdated,
Zmention a much more recent volume on the same theme: SUBLIMINAL
SEDUCTION by Wilson Bryan Key, Prentice-Hall;Inc. l97Z - ’
**your information is incorrect. On page 188, Vol II of the EIS,
you state that an alternate site was located and approved by the
City of Calais and was subsequently approved by the FAA. Fact:
The City of Calais took a sum of money from the Ci of Eastport
to “look into the possiblities” of a site in Calai.s, which the
FAA prematurely announced that it “might” approve, pending study.
However, and I quote from the Bangor Daily News, April 29,. 1974,
That proposal, since (wasi rejected by municipal officials in
Calais.” Today, the site is being utilized by an expanding Voca-
tiona 1. school and already has had several buildings set upon it.
Incidentally, if. you fQllow your own directions to Calais, you
truly will be “all at sea Look at any map and you will see-your
mistake. With information like this in your book, one could ea—
sily get the feeling that so many holes are creating a Draft ElS.
80—5
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Responses to Con ents by K.A. Lewis
Si. She strongI objects to the weighing ot the economy itYwith other factors as part of the
environment. Man is led to believe that he wants and needs more and more. What is
to become of people traditionally set in their ways, forced into this more accelerated,
more fabricated and unreal landscape, uprooted from their own cultural heritage and
alienated?
Rl . Comment noted.
s • The question of the airport. Why has no mention of the existing ruling that an alternate
facility must be found before an airport can be closed? And why has no action been taken?
Furthermore, as seems to be parr for the course, the people have had no say in this matter.
R2. The FAA has determined that an alternate facility is not necessary. Also see
FEIS Vol. II p. VI—i.
80—6
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Testimony Given by R. Klyver at.
the Dec. 3, 1976 Public Hearing
MR. KLYVER: My name is Richard Klyver. I am self-
employed and I live in Eastport. I would like to address
myself to one particular area that I think has not been
stressed enough. I think there is a lot of information
Response:
The safety record of VLCC’s and the ports on which they call do not bear out
these claims. Ships and systems utilized by Pittston will comply with all
rules and regulations of the U.S. Coast Guard. AU pilots will be licensed
by the U.S. Coast Guard where appropriate. Pilots will comply with all
international regulations and standards set up by INCO, the Intergovernmental
Maritime Consultative Organization. Only pilots licensed to transit Head
Harbor Passage will bring tankers to their berths.
Also see FEIS Vol. II p. X—26ff, VI—36.
81—1
-------
339.
that has not come down about the VLCCS themselves,
particularly insofar as their structural weaknesses
and their safety record, which I think is abominable.
These ships seem to have the worst safety record of
all ships.
In October of 1972 the Japanese Ministry of Transport
censured two of the biggest shipyards in the country
for negligence in construction. Ships cracked soon
after launching, and a high rate of defective workman-
ship on ships built between 1962 and 1969, years of
the most intensive supertanker construction, some ships
were sailing with vital parts unwelded. Now, the ships
built in this period were mainly of the 150,000 DWT to
250.000 JT capacity . which is the type that Pittston
would be using. These - :ps also, to economize, were
built with only one boiler, one propeller, and this
gives them far less capacity to maneuver and it makes
them far more prone to breakdown, plus shoddy materials
being used, many of these ships have broken down at sea
continuously and in positions where they were totally
helpless and found themselves going aground without any
help.
81—2
-------
340.
The second aspect is the flag of convenience area.
These are companies that fly the Panamanian, Liberian,
Costa Rican, and Lebanon flags. These are countries
that have very lax restrictions in safety standards.
Many of the crews of these ships do not have licenses.
Navigational equipment especially on the flags of
convenience ships is often defunct or considerably off.
Aboard the Arrow, the tanker that went aground in Nova
Scotia, there was no radar, no echo sounder, the gyro-
compass was three degrees out of whack, and the officer
on deck had no license. Captain W. L. D. Bagley, writing
in the Safety at Sea December of 1966 issue said that
“Supertankers with faulty VHF or radar were so numerous
that channel pilots had ceased to report them.”
D ing a 10-year period from 1959 to 19 S , 13,379
accidents occurred to tankers throughout the world.
The total number of tankers afloat for this period was
50,559. That is an incredible percentage.
One of the accidents that comes to my mind that I
think is a very horrendous thing, and is always an
imminent possibility that such a thing could happen in
Eastport , considering the condition of these ships and
81—3
-------
the crews that run them, is the case of the Polly
Commander which ran aground off Spain. It spilled
16,000 tons of crude oil, which caught fire and caused
a fire storm, raising hurricane force winds which
carried oil mist aloft, which condensed and caine down
as black rains on towns and farms.
Finally, I would like to say, in terms of the
environment, a lot of people have said that oil spills,
particularly the one at Chedabucto Bay in Nova Scotia
has been cited as having done no damage whatsoever to
the environment., we have to keep in mind that oil is
tremendously variable. Every shipment of oil is
different, every oil spill is different, every situation
is totally different. Many of these oil spills do a
tremendous degree of damage because of the type of oil
and the type of conditions involved. Others don’t seem
to do any at all. This area is not a cut and dried
situation by any means. But I do think the important
thing is that the ships coming in here I think would be
of the 150,000 DWT capacity to 250,000 DWT capacity,
and thc’se ships b ’ and large. most of the ones that were
constructed, are of very poor construction, they would
81—4
-------
342.
be manned by crews — I am sure Pittston would be using
flags of convenience ships — they would be manned by
crews, many of them, without licenses, and many of them
not the best mariners, the best sort of people to man
these ships, and I think that is a very disasterous
situation, imminently disasterous situation. I think
it could result very probably in a major oil spill.
Thank you. (Applause)
MR. McGLENNON: Thank you, Mr. Klyver.
81—5
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OfFICERs 01 THE
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Natbnal Parks & ConservatkDn Association. 1701 Eighteenth Street. NW.. Washington. D.C. 200
telephone (202) 265-2717 printed on recycled par
82—1
DEt 21 W
December 15, 1976
Regional Administrator
U.S. Environmental Protection Agency
Room 2203
John F. Kennedy Federal Building
Boston, Massachusetts 02203
To the Administrator
Dear Sir:
The National Parks and Conservation Association (NPCA),
established in 1919, is an independent, private, non—profit,
public service organization, educational and scientific in
character. Its responsibilities relate primarily to pro-
tecting the national parks and monuments of America, in which
it endeavors to cooperate with the National ParIs Service while
functioning as a constructive critic, and to restoring the
whole environment. NPCA represents 45,000 members nationwide.
NPCA welcomes this opportunity to comment upon the Draft
Environmental Impact Statement for the Pittston Company’s
proposed oil refinery and marine terminal at Eastport, Maine,
NPCA’s opposition to the project is based upon the poten-
tially serious environmental impacts of an oil spill. The
Association believes that the possibilities of a spill and
major adverse effects from it are greatly increased by the
doubts which surround the enforceability of the Board of
Environmental Protection’s conditions on tanker specifications
and navigation procedures.
If BEP grants application to the Pittston Company, Pittston
may be able to avoid compliance with BEP’s conditions because
a recent court case may have established a precedent. In
Atlantic Richfield v. Evans in the Federal District Court
for Western Washington it was ruled that federal law, which
does not require double bottoms in oil tankers, pre—empted
a state law which set double bottoms as a requrement for
entry into Puget Sound. The Board’s order for segregated
ballast and double bottoms on tankers over 30,000 dwt is
stricter than present Coast Guard standards.
BEP’s (or perhaps EPA’s-.—the DEIS is unclear) authority
is also called into question in reference to the Passamaquoddy
tidal power project. Volume II, page 194 states, “The
-------
Regional Administrator
Det ember 15, 1976
page two
Pittston Company has been advised that in the event the tidal
power project is authorized and constructed, there would be
operational and waterborne restraints of shipment of their
crude and finished projects (sic).” If Passamaquoddy were to
be authorized, it is not difficult to predict the following
scenario:
Certain alterations to the refinery and berthing
procedures must be made, LAccording to Dr. John
Chapple, a geographer from Boston who testified at
the public hearing in Eastport on December 3, 1976,
the largest locks in the world would have to be
constructed to enable the tankers to reach the
terminal, This information is from the Maine Times
article of December 10, 1976.) Pittston announces
that the cost of adaptation will be too great and
it will have to close or increase prices to cover
the costs, with serious adverse economic effects
to Eaatport. (Dr. Chapple estimated the cost at
$85 million at the hearing.) Dispute will lead to
a decision that the project cannot be constructed,
or to a lengthy delay until the port is no longer
in use, and the opportunity for timely development
of a renewable energy resource will be lost.
A discussion of the mechanics, costs, and
authorities involved in adapting the refinery
should be provided in a later EIS.
It should be emphasized that the Canadian government may not
permit the tankers to use Head Harbor Passage to reach the
refinery site.
The Washington Post reported on December 5, 1976 that “the
State IWpartmefl t Tcons ders vessels proceeding to or departing
from U.S. ports through Head Harbor Passage enjoy the right of
innocent passage under international law.” As this letter is
being written, the State Department is awaiting a statement
from the Canadian government with documentation on the issue of
innocent passage. Resolution of this issue could be months,
even years, away, by which time the entire nature of the project
could be altered. Before EPA issues permits to the Pittston
Company and before Pittston invests more time and money into the
project, some agreement should be reached with the Canadian
government.
In addition, Pittston has rejected the one possible alternative
to using berthing piers requiring navigation through the inter-
national passage. On the grounds that a monomooring system
would have greater risk of oil spills, more difficult maintenance
and operation, and safety hazards to personnel (volume II, page 285),
Pittston has said no to the system.
82 —2
-------
z egionai. Director
December 15, 1976
page three
When EPA prepares a final environmental impact statement,
there are several items which NPCA believes should be in the
document, including responses to the prededing statements and
questions.
1. The DEIS does not but should discuss the possibility that
a refinery at Eastport may be used to process oil from the Mid—
Atlantic and North Atlantic outer continental shelf (OCS). The
DEISon OCS Lease No. 40 explained that Mid—Atlantic oil is
expected to replace most foreign imports, ai the ships used
would be of 70,000 dwt of less (Section III. A.2.d.) estimates
the Bureau of Land Management. More ships would be needed to
carry comparable amounts of oil, so the traffic in Eastport would
be increased, as would be the probability of collision. Further-
more, operational discharge pollution may increase dloser to
shore because tankers would not be traveling deep ocean areas
where oily bilge is generally discharged at present. A final
E lS must deal with questions on the development of OCS oil and
its possible processing by a refinery at Eastport. How much
OCS oil would be handled by the Pittston facilities? What will
be the environmental impacts of operational discharges from the
wells to the refinery? What will be the probability and effects
of spills while the oil is in transit? What will be the proba-
bility and effects of spills due to increased traffic in the
Eastport region? Who will have the authority to regulate the
size and construction of tankers? etc.
2. More discussion should be provided on the inonobuoy alternative,
particularly in view of the Canadian stance.
While not advocating the use of the nionobuoy, it is possible
that technological advances can reduce the safety hazards to
personnel and the difficulties of maintenance, two main Pittston
objections to the system. The MIT study referred to in the DEIS
(volume II, page 286—7) would seem to refute their concern for
increased risk of oil spills, assuming that the system were well
maintained.
More information should be provided also on the impacts and
possibility of crude oil reaching the shore in the Machias Bay
area.
Finally, all research of the monobuoy alternative should
continue, keeping in mind the potential for, and potential
advantages of the Passamaquoddy tidal power project.
3. Information should be provided on the effects of air pollution
on nearby state and national parks and wildlife refuges.
The DEIS failed to discuss the potential impacts of the
increased air pollution on Acadia National Park, Moosehorn
National Wildlife Refuge, Quoddy Head State Park, Cobscook
State Park, and St. Croix National Monument. What will be the
effects on the flora and fauna of these natural areas when “the
project will significantly affect the levels of pollutants,
82—3
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Regional Director
December 15, 1976
page four
particularly sulfur oxides, nitrogen oxides, and lead levels..?”
(volume II, pages 323-4) While Maine and Federal 24—hour
standards should not be exceeded by the operation of the project,
data regarding the effects of air pollution on nearby parks
should be shown so that a better assessment of the project can
be made
4. A more thorough discussion of dredging is necessary.
The DRIB did not but should have provided information on
siltation in the dredged areas. Detailed data on the amounts
of material which will have to be removed, and on the frequency
of maintenance dredging should be included in a later statement.
In addition, information on disposal sites for material removed
by maintenance dredging should be given.
5. Information on anchoring prooedures in the event that a
ship cannot berth during bad weather should be in a later EIS.
A discussion of this item must be provided because the weather
which would preclude ships entering Head Harbor Passage would be
conducive to groundings and collisions.
The DEIS failed to provide discussion for clean—up of spills
of the sulfur products made during refining.
7. The DRIB is confusing regarding tanker size. On page 225
of volume II it is stated: “On the average, traffic will consist
of one 250,000 I*T VL C a rriving and leaving per week...” On
page 28! of the same volume: “The project as proposed calls for
the delivery of crude oil in VLCC’g of up to 250,000 DWT in size.”
The Board of Environmental Protection’s orderThtates that tankers
of not greater than 149,999 1 T will be used to transport oil into
Eastport. If EPA has based some if its research on the use of
$250,000 1*!T tankers, major revisions to deal with the project
as outlined by BEP are called for in a later EIS.
The DRIB does not provide enough Information on the possibility
of OCS development, the monobuoy alternative, effects of air
pollution on area parks and refuges, maintenance dredging,
anchoring provisions for adverse weather conditions, and clean
up plans for sulfur products. Data on these items must be
included in a later RIB so that a better assessment of the project
can be made. Finally, assurances must be provided that the Board’s
order can be enforced.
At this point, however, when the final RIB should be put out
is the key question. The conflict over the rights of innocent
passage should be resolved before an FEIS Is published. If the
Company has rights to alter or halt the Passamaquoddy tidal
power project, judgement of the refinery and marine terminal
must be deferred, at least until Corps of Engineers finishes
re—evaluating and updating the project.
82—4
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Regional Director
December 15, 1976
page five
NPCA opposes construction of an oil refinery and marine
terminal for Eastport, Maine because of the potential for major
adverse environmental impacts. We appreciate this opportunity
to comment, and request that this letter be included in the
FEIS. We hope that the FEIS will not be published until after
the question of innocent passage is decided and after a Passania—
quoddy feasibility study is completed.
REM:ll
auX
Administrative A
Communication and Environment
82—5
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Responses to Comnents. by R. Mo yneaux
Si. Pittston may be able to avoid compliance with BEP’s conditions because
of precedents set regarding state and federal requirements on the speci-
fications and operation of tankers. EPA’s authority is questioned with
respect to the Passamaquoddy Tidal project and the Pittston refinery.
The Canadian issue should be resolved before EPA issues permits and
Pittston spends additional monies on the project.
Ri. Coninent noted.
S2. The FEIS should discuss the possibility that the Eastport refinery will•
process oil from the U.S. outer continental shelf (OCS). How much oil
would be handled by the refinery? What will be the operational impacts
associated with OCS development on the refinery? What vii]. be the effects
due to increased traffic in the Eastport region? Who will have the author-
ities to regulate size and construction of tankers, etc?
P.2. The development OCS oil is in the planning stages at present. If and when
oil from the OcS becomes available for processing, economic forces will
determine where the oil will be shipped for processing into products
for consumption. The information required for these determinations cannot
be. obtained until the estimated time of oil availability from the OCS
is known.
S3. More discussion should be provided on the monobuoy alternative, particularly
in view of the Canadian position and the advantages of the Passamaquoddy
tidal power project.
R3. Cosnients noted. See FEIS Vol. II p. V—llff, p. X—42, p. 111—159.
S4. Information should be provided on the effects of air pollution on nearby
state and national parks.
R4. See FEIS Vol. II p. VI- 62ff.
S5. A more thorough discussion of dredging is necessary along with the schedule
of maintenance dredging and its subsequent disposal.
R5. See FEIS Vol. II p. VI—59ff, Dredging. Maintenance dredging may not be
required in this case because of the scouring action of the tides, there-
fore, no disposal of maintenance dredging material is required.
S6. Information on anchoring procedures in the event that ships are not able to
berth (i.e., bad weather) should be provided.
R6. In the event that weather conditions are predicted that would preclude
the use of the channel before the ship enters it. the ships will be so
advised and would delay their approach ustil conditions were favorable.
In the event of an emergency after entering the channel such as a power
failure on the ship, the tanker would be held stationary in the center of
the channel by tugs until the emergency situation is resolved. Alternatively,
the tanker could be turned around and headed out at any point of the tide, or
it could be anchored safely and out of the way in Friar Roads until repairs
were completed.
S7. The DEIS failed to provide discussion for clean up of spills of sulfur
products made during refining.
82—6
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Ri. Elemental molten sulfur will be produced at the rate of 465 metric tons
per day. It will be shipped to market in small tankers of the 10,000 —
15,000 DWT Class. Therefore, approximately one sulfur carrying tanker
will transit Head Harbor Passage every 21 days. In the event that molten
sulfur would enter the water, it would solidify into chunks and sink.
There would be no detrimental effects to the marine ecology since elemental
sulfur is insoluble and unreactive In water.
S8. The DEIS is confusing regarding tanker size.
R8. This is noted and is discussed In the FEIS Vol. II p. V—15,
S9. The r is should not be published until the 1.3.S.C.G. finishes its updating
of the Quoddy Project. The NPCA opposes the refinery project because of
the potential adverse effects.
R9 . Comment noted. The Corps of Engineers is updating the Quoddy project, not
the Coast Guard.
82—7
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December Zi, J. Io
Kris Larson
High Street
East flachias, Haine 04630
U.S. Environmental Protection Agency
Attn. : Florence Hunter Response:
J.F. Kennedy Federal 3uilding Comment noted.
3oston, H ssachusetts 02203 See FEIS Vol. II p. VI-29ff.
Dear Ms. Munter:
Thank— rou for the copies of the LI.S. £t for the Proposed iittston Oil icrin ry.
They arrived yentr rday along with the ract Thect nd your letter.
Since the cut—off date for the cor ment period j the 20th of this month I i 1 1
offer ny viewpoint briefly now:
The recent disa tor of the tanker, argo ::crchant, off rnntuckr t 11 ’ ‘)O the tO X tOfle
for the Pittston Refinery in astport. I kno of ‘t lo ist one C n irn nn’ znrm: ‘ ich
de’rotecl half its front page to the oil spill and there arc prob’hlv oth’ ’-r. : ith t - i
occurring after Canada has alre c1y made known its onposition to the refinery they sur—
edly will here to their decision now.
Personally I op ose the refinery in J .st ort ht2cause of what s ich i11 .tr t e
area would precipitate. The provailinq current !einrj south’•7cstcrly, n s ill rou!d ‘.)C
c rrioc 1 down the coart and thus affect every clan bed and fishinq area of Uort”e te
haine. ‘be rgo spill could he as high as 6,r!OO,000 gallons. If a ittr ton t:ni
broke apart in trend harbour pansaqc it could r. ill over 5( ,CO0,tY O .11on
d ntec1 lisanter. J3esides / rthur IlciZay of J’ r Isle has presenteri nroof thrt t c
(shrir p), would he destroyed by an oil sDiil, thus shutting the door on a hey rco1o; c 1
chain.
Small industries, well dispersed in as iinqton County, would be of iuch rent r
econor iic fe: sibilty.
—
Th nk—’;ou for extending the comuent period and thank—you for your tirte.
tours ver’ ’ truly,
ri3 Lars n
-------
— .av q
i ’7
Ingalls Head
Grand Manan Island
December 2t , 1976
u .S. Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Attention: application MEOu22Li.21i. (Oil Refinery and Marine Terminal)
Dear E.P.A.;
The ])raft Environmental Impact $tatement (EIS) for a proposed oil
refinery and marine terminal at Eastport Maine has several critical
limitations. As it stands, this violates the National &ivironmental
Policy Act (NEPA) and subsequent regulations. rubelieve it is
impossible to make a fair and considerate decision on the project
without additional Information.
A failure to describe marine imnsportation routes outside of
Head Harbour Passage — is possibly the statement’s most glax’ing
deficiency. It says; “The products made from the proposed project
will be shipped out almost exclusively by tankers and barges, ! *
Yet there is no description of the type, operating condition
and transportation routes of these vessels. Moreover, they are not
likely to receive the same maintenance or have the equivalent
navigational equipment of the VLCC’ ,
ApproaohiBjto the refinery site through Head Harbour Passage
are described in the report. I assume that outside the passage
the VLCCS would travel along the most protected shipping lanes.
But, after leaving the passage, what are the travel routes of the
tankers and barges that will carry the refined product out of
Eastport? Will they go through theGrand Manan Chaimel?
What navigational hazards might they encounter? What has been the
experience of shipping in the region?
The refined products carried In these boats are far more lethal
to marine organisms than crude oil. They are 2,000 tImes as lethal
to fintish, clams,mussels andsoallops; 1O,OuO times as lethal to
lobster, crab and shrimp; and 100,000 times as lethal to larvae. **
Furthermore, the hydrocarbons of these refined grades are more
soluble and are easily distributed through the water column.
*EIS 21j9
*IfEIS p. 312
The KLS might bn more mplete if a mai tx or other system for
dispiaying environm ntai 111 act .nd their Inter-relationships
added. This would help to determine if all impacts have been
considered, (ie dulse) And how the environment will be . tfeoted
over a long period of time, (qg. for about two weeks each years’
new lobsters float on top of the water.).
84—1
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Is it known how quickly they dissipate? is this controllable? The
report contains no description of mitigating measures for a spill of
refined products.
The EiS does not adequately consider the question of negligence
or the procedures for compensation when oil affects marine resources
A proposed permit condition requires the Pittston Company to clean
any spill inside of Head Harbour Passage. But who is responsible for
wanaging a spill outside of the passage? What are their working plans?*
Who is responsible f or compensation payments, and who is eligible to
receive those payments? Is the fisherman to accept the liability of
even greater exposure to risks? Will it consequently leecome difficult
to attract adequate levels of financial support?** Equity questions
such as tnese daou].d be discussed now - in the evaluation stage -
rather than later, at the moment of impact.
For people who have invested a lifetime on the sea there may be
considerations other than economic. Their’s is one of the most direct
and harmonious relationships a man an have with the natural environment
A dollar value on fish landings does not measure this relationship
adequately. *41*
I hope that these comments will receive your kind attention .
Sincerely,
Bill Cunrdng1 iam
Rockwood Lane RPD 2
Lincoln, Massachusetts 01773
* A spill in the vicinity of Macbias Seal laland could result in
a major internations 3 incident; t is one place that both the
U.S. and Canada would rush in to clean up.
Please refer to C guidelines for preparation of EISa 1 00.8(a)(3)(ii
PR vol.38 no.147
refer to NEPA sections 101(b)(4); 102(A); 102(B),
and to C guidelines for preparation of EISa 1 00.2(b)(3)
84—2
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Responses to Comments yB. Cunningham
Si. The DEIS fails to discuss the type, operating conditions and transportation
routes of the product tankers.
Ri. The routes that will be utilized by product tankers after leaving Head
Harbor Passage will depend upon the destinationof the particular product
being transported. Established sea routes will be utilized by the product
tankers and all maritime laws will be strictly followed.
S2. What measures will be taken to control a spillage of products. The effects
are much greater than those of crude. The refined grades are much more
soluble and more easily distributed throughout the water column.
R2. See FEIS Vol. El p. IV—l8ff.
S3. Who is responsible for clean—up and liability for damages resulting from a
possible spill? Secondary impacts?
R3. See FEIS Vol. II p. X—5ff.
S4. The change in lifestyle cannot be measured in monetary terms.
R4. Comment noted.
84—3
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Response:
Comments noted.
See FEIS Vol.11 p. IV—53ff,
p. X—9.
85—3
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December 27, 1976
To Whom It May Concern,
“Jo
I too ask for a community referendum.
For the last year I have been in the planning stages of setting up my own private
Aquaculture business. The specie r intend to cultivate is the common blue mussel ( Mytilus
edulis ) by raft techniques. From preliminary analysis of my summer data of experimental
testplots and natural beds I feel an economically viable business can be established.
Many more people within the Passamaquoddy—Cobscook region could become employed in
mussel aquaculture once a practical design could be proven.
My credentials include Laboratory Director of Aquaculture for Pleasant Point, Perry
Maine, and researcher at the University of Maine Ira C. Darling Center, Walpole. At
the research station I was raising larval ea ècallops ( Placopectin magellanicius) .
What protection will I as an indvidual have to insure that monitoring of oil discharges
will take place or be accurate? The Pittston Company has already had regulations changed
and have been granted extensions to deadlines for collecting environmental data.
In case of a major spill, who will pay for my ruined business? And in the years
while the ocean tries to cleanse itself?
In case of excessive oil discharges who will pay for my tainted shellfish? My taxeS
or Pittston?
I realize oil refineries are necessary, my major objections are: The Pittston Company’s
record ‘ for human and environmental disregard, Head Harbor Passage’ dangers and the
strifethat is developing between the two countries.
Please send me a copy of the final EIS.
S ievrt R ,gga
Box 32A
Robbinstion, Maine
O46 j
86—1
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, onses to Connuentsby S. Riggs
The monitoring of the refinery effluent is stipulated in the National Pollutant
Discharge Elimination System permit. ‘The permit conditions and monitoring re—
quireiaents are shown in the FEIS Vol. III p. A—li — A—21. (Effluents Limitations
and Monitoring Requirements.)
See FEIS Vol. II p. X—5ff.
86—2
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Published by Stirling & Alice Lambert
87—1
Tel. (506) 747-2921
TUZ JITII1S
LAMBERTVILLE DEER ISLAND, N.B.. CANADA LOG 2E0
December 28, 1976
JAN 4 197
ME 0022424
U.S. Environmental Protection Agency
Enforcemet Division, Permits Branch,
John F. Kennedy Federal Bldg.,
Boston, Mass. 02203
Gentlemen:
I am not sure whether or not your invitation for comments re: Pittston’s appli-
cation was extended to Canadian residents as well as to residents of the U.S.,
but since I live on Deer Island, New Brunswick (just across a narrow passage from
Eastport) which would very much be affected by an oil spill and other effects of
an oil refmery, I am prompted to take pen in hand and list some of my obser-
vations/comments herein.
I am sure others will speak out on the effects a possible oil spill would have
on the fishing industry, so I will not repeat them here. I was born here and have
lived here all of my life (47 years) and I live here by choice — not out of necessity.
I am a printer and a photographer and since I get quite a bit of business out of
Eastport, an oil refinery there would quite possibly increase my earnings substan-
tially. However, the risks of said refinery would more than cancel any possible
benefits I could ever receive. An oil spifi in this area — and it would happen even-
tually — would wipe out the lifestyles that I, and thousands of other residents
around this Bay, believe is our birthright.
I have sailed the tides of this area for years as part of my vocation and for recre-
ation and I would not trade our clean air and crystal clear waters for Pittston’s
entire payroll for a year.
I noted that a Pittston spokesman said the tankers would be brought in during
slack tide. I can tell you from years of observation there is no such thing as slack
tide in the area they are referring to. When the tide turns, either ebb or flood,
it begins running back in one direction in places before it ceases running in the
other direction in another location. Couple this with the dense fogs we experience
for a number of weeks each year — and with the very narrow passages involved
— and a disaster is inevitable.
Because of the tides, which would circulate an oil spill rapidly (regardless of
wind direction) any attempt to contain said spill would be an exercise in futility.
This risk is just too great for me to accept. There are not that many places left
on this continent as unspoiled and as beautiful as this area. And there are not
that many places where the risks would be as great as in this area with its narrow
passages and its surging tides.
next page, please - - - -
A Summer Time guide to C’harlatte coiint i Men, Rrnn n ,ir.h P’ Fnct
ffl__ -
-------
Page2. ME 0022424
An oil refinery at Eastport and the transport of oil through Head Harbour Pas-
sage is an open invitation to an inevitable disaster of the greatest magnitude.
I trust and pray that you will weigh all the facts carefully before reaching your
decision on this very important matter.
Respectfully yours,
Stirling Lainbert
P.S. I am enclosing a copy of The Summer Times which may illustrate, in some small
way, what we have to lose in the event of an oil spill.
Response:
Comment noted.
See FEIS Vol.11 p. VI—29ff,
X-26ff, VI—36,
87—2
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022420
9 K y Street
Eastport, Maine
Dec. 28, 1976
U. S. Environmental Protection Agency
Permits Branch, Enforcement Division
ohn F. Eennedy federal Building
Boston, Massachusetts 02203
Dear sirs,
My background is neither impressive or remarkable, and is mentioned
here only because I feel it has peoularly fitted me to see the proposed oil
refinery at Eastport from many points of view. Also, I’ve listened attentively
to the testimony given at every public hearing and some private ones held here
and recorded many hours on tape. Hundreds of press reports and the magazine
articles describing aetport in sorry terms, as long ago as 15 years, have not
gone unnoticed. The April 1973 Pittston Prospectus, together with the 3 Vol.
E. I. Statement have been carefully eTRmlned.
From the days of whaling ships around Cane Horn, my mother’ a people
followed the sea, and I have lived moat of my life near the sea. First in New
York, then Connecticut, later New teraey and now, on the coast of Maine. As an
engineer for Union Carbide, my father designed pressure vessels and gas crack-
ing devices with the complicated piping layout necessary for volatile ch icals
and gases. Before that he designed precipitatora for Cantrel Research in Bound
Brook, one of the largest makers of air cleaning and recovery devices in the
world. As you know, New Jersey is the moat highly industrialized state, a real
polution problem, and now has one of the highest rates of unemployment in the
nation.
So, eltbough we lived in the Somerset Hills away from most of the
dread.tul polution of industrial New Jersey, we knew about it • Bayonne, where
Mr Kaulakis hae said he enjoys living, was not unfamiliar to us. “ I live 12
miles from the Bayway Refinery, “ he said at a 1973 hearing, “And I like it
Thy, at night It’s like a beautiful, big Christmas tree, all lighted upt
Wouldn’t like to see a big, beautiful, Christmas tree all lighted up in
EASTPORT? ” His question earned more pathos than humor as 3.4 V& not his
Intention to explain what makes such trees light up, or of the noxious fumes
and particulatee spewed to the atmosphere.
Eastport Is an island with only OZ access road and that borders the
land of the proposed refinery. With fire and explosion the ever present danger
of any refinery, how many people could possibly escape the resulting holocaust?
Why does no one see, and warn of this terrible over-sight? When I asked at a
Planning Board meeting recently that it be considered, Mr Kaulakis feebly
protested its relevance and the chairman quickly put an end to the discussion.
88—1
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Page 2 02242O
“Or, as happened off Spain a while back, a eupership will catch fire
at sea. It’s oil will burn with such ferocity that it’s heat will cause
rainstorms that will pelt a hu inland area with oily rain. Crops will be
ruined, cattle killed, people made ill, millions, perhaps billions, -—— of
dollars worth of property coated with oil.”
(National Observer, Nov. 16, 1974 review of Noel koetert’s “Supership”)
This describes the situation not only for Zaet ort, but Cainpobello,
Deer Island, Lubec, P nbroke and all areas not far away • AlsO, Pittston’ a
muck use of the word “Products” as in “Products Pier” act. is designed to
conceal rather than reveal, what it will be like to have a 70,000 ton ship each
day loaded with molten sulfur leave port and navigate Head Harbor in the other
direction. Not only the risk of potentially explosive ships sailing in both
directions if not in port, but barrels and tanks of the most volatile chemicals
in storage and use, Naptba, Hydrogen and Liquitled Petroleum Gases.
At the Dec. 3rd bearing in Eaetport, Dr. Zda attempted to make it
quite clear that his conclusions of esfe passage for large tankers through Head
Harbor were based entirely on controlled conditions at the Davidson xoerimental
Thnk of Stevens Institute at 20 knot winds. When I mentioned to Dr. 34a that 20
knots wee a slight breeze here, while 35, 45 and 55 were co n with much higher
velocity in. storm and—-- what then? Much later in the evening. Dr. Zda told
if the winds were more than 20 knot., the ships would wait. He had no chance
to anmeer my, “Where would they wait?” because Mr laulekis came and hurried him
away.
World travelers say. they’ve seen no more beautiful scenery than the
Zaetport area. Others have called it the last unspoiled coast of Maine. The
ithaonian Institution draft report oX 1973 for the Maine Center for Natural
Areas, the Cobacook Bay Downcast Area were listed as Conservation Priority Zones.
iou1d wonderful, clean, sea air (sometimes jokingly sold in cenR to
tourists) become befouled 24 hours every day in the year, with 4,042 pounds of
sulfur dioxide each hour? Also, “various quantities of polutants like sulfur
oxides, nitrogen oxides, hydrocarbons, particulate. and trace amounts of mercury,
lead and beryl1ii ”? XI S
The dreadful odors and emission. that come from the Mean Corp. and
made much of by the Pittston Co. who say their own befouling of the atmosphere
will hardly be noticed becauae of it---- these are very bad and sometimes
intolerable • but not necessary. They have precipitatore. It’s cheaper not to use them
them . We all hope one day the Mearl Corp. will be compelled to use their
precipitetors and everything will be different.
It seems to y of us that the L I. Statement put nor. trust in the
findings offered by the Pittston Co. than was necessary or wise. A little like
asking the fox to guard the hen pen. It isn’t a company with high reoutation
of integrity and on more than one occasion here in Xastport, the iron fist baa
88—2
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Page 3 } O 22420
been plainly visible beneath the velvet glove of Mi. Kaulakie. Enviro-Scienco
Inc., 114 Cayuga St., Rockawey, N. . has no telephone listing. Irving Cohen
has a telephone at that address but does not se to have the usual licence
required by the State of New 3ersey for this type of work.
It was the oil companies who beguiled u.s to turn from coal, the ol].
companies led us to dependence on foreign oil. Now a large conglomerate has
discovered Eastport. Only those who are ignorant of the facts, or greedy for
profit could recommend a refinery and petrochemical complex be built at Sastport,
because of the unthinkable consequences.
The tremendous tides will be here long after all of us are forgotten.
The unmeasured potential benefit to so many without spoiling everything, or any
thing, can be realized as soon as the never ending power of the tides is harnassed.
The neople of EAstoort have been bombarded with Quoddy Talk for 51 years.
Every election it is dusted off and soon after, quietly laid on the shelf in a
dark corner. They certainly cannot be blamed for feeling spent and disillusioned
about it. The grandious promises of a large conglomerate, wise in the uses of
publicity and guile, are very oersuasive to those who hope for a better way of life
and to all who are greedy for personal profit.
Many here are not only disillusioned, they are bitter because of the
shabby used in the handling of the Passamaquoddy Power Project all
these years----rigbt up to the present time. The last few crumbs tossed out from
Washington for yet another feasibility study was mean and penurious, compared to
the amount poured out for Diokey-Lincoin and other projects. The people who hoped
for so much, and wor1 d so hard. to see the Tidal Power Project become a reality,
have become weary and disheartened after years of promises, more studies, and the
word “unfe isib3.e.”
The Tidal Power Project is feasible. It was feasible many years ago and
would have cost much less than now, but because it was labeled “unfeasible” then,
we all hope more wisdom now, will not allow the same mistake to be made. If the
Army Corp. of Engineers want to have Quoddy built, thea can see that it will be
built. Every penny spent for tidal power will come back again with the energy
ever renewable, over, and over, and over again. All the exciting trips to the
moon and Mars are costly beyond belief, yet do not provide one foot-pound of
energy here on earth.
Owning a farm in Pembroke for 18 years, and living in Eastport for 10,
I know well the difficult situation of Washington County, the unbearable tax
load, the need for work, the hard winters with oil at 46 a gallon. Pittston
has said right along the oil will not be sold here and the price of it will not
be less. The products of the refinery are to go to other New England states.
I am not unmindful of the needs of Eastoort and Washington County, the need for
rehabilitation and planned growth. The grF,ateat need is for leadership. Heavy
industry will bring enormous orofits to only a few while it distroys all that is
priceless. The lobe cannot be filled by many who live here.
8 - 3
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Page 4 ME022420
No one, not one 2erson will say he doesn’t Want QUOdd7e V8fl fl Ofl
the City Council and others who have done everything they can to help Pittston
conquer E stport and. the State of Maine,if asked, even they will not say they
don’t want Quoddy. The answer from those who live here is always the same • “Oh,
Yes! wouldn’t it be wonderful?--- But We’ll never Ret it.” When esked, “Why?”
One man added, “ ruet because it’ a astport.”
To Dut into words the thoughts Of nany-- --
We hope, the 3 large banking houses, and all the other large cor oratione who
were given preferred tii ie at the Dec. 3rd hearing in Easttort, but do not live
here, we hope all of thea will have second thoughts about their eagerness to
see misery compounded for profit.
We hope. “The Action Coninittee of 50” who hide their Identity beneath the cloak
of Arthur rohnaon and the Univ. of Maine, may realize the folly of being devious.
‘ e hope, the ZPA. the Army Corp., and all others who can if they went to, find
out what baa been batpening down here, and protect Eaatport frozzL being sold down
the river only to beo a shambles for large rofIta to those who would bring It
about.
Eastoort can have a renaissance, and the whole area be benefitted. But
it oan never ooi about by the distruction of all that is left of it. We cannot
live on beautiful scenery and clean, fresh air. But we can die without it.
!Whera there is vision the people peri*h.”
Sincerely yours,
4. 4€j ’o
(lire) M.iria n B. Myers
88-4
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Responses to Conunents by M.B. Myers
Elemental molten sulfur will be produced at the rate of 465 metric tons per
day. It will be 8hipped to market in small tankers of 10,000 — 15,000 DWT
class. Therefore, approximately one sulfur carrying tanker will transit Head
Harbor Passage every 21 days. In the event that molten sulfur would enter
the water, it would solidify into chunks and sink. There would be no detri-
mental effects to the marine ecology since elemental sulfur is insoluble and
unreactive in water.
Also see FEIS Vol. II p. IV—23ff, VI—62ff, VI—l9ff, III—159ff, IV—53ff, X—9.
88—5
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JP 1 N 6 1977
College of the Atlantic
Bar Harh r Maine
January 3, 1977
Mr. John McGlennon
Regional Administrator
U.S. Environmental Protection Agency
Region 1
Boston, Mass. 02203
Dear Sir:
I have recently had the opportunity of reading the Draft
Environmental Impact Statement relative to the Proposed
Issuance of Federal Permits to the Pittston Company of New
York for the construction of a 250,000 Barrel/Day Oil Refinery
and Marine Terminal at Eastport, Maine. I begin with the
assumption that an EIS should refer to all real environmental
and social costs, and on this basis want to make several comments
on aspects of which I have had some professional or personal
experience. The first is an environmental question; the
second Is social.
1.) I have a Ph.D. In biology and have studied sea bird
populations on the New England Coast for several decades.
I have censused the seabirds of the coast of Maine and
reviewed published documents on the historical changes
in seabird numbers during the last 75 years. A report
on this work was published in The Journal, Bird Banding ,
in 1973. I believe that the Draft EIS gives too little
recognition to the predictable damage that will occur to
local seabird populations if oil tanker traffic increases.
a.) As you doubtlessly know, both chronic and major
oil spills can be dealt with in the same statistical
terms as geologists use for river floods. One can be
confident that oil spills, like river floods, will
occur at a given frequency. Experience indicates
that where shipping is moderately heavy, oil spills
kill seabirds faster than the populations can re-
cover. The Nantucket Shoals were flooded with oil
in 1953, when the Fort Mercer and ?endleton went
aground, and in 1976, when the Argo Merchant grounded.
The twenty five years between spills might have been
enough for sea duck populations such as Common Elders,
White Winged Scoters and Old Squaws to Increase again
if there had not been smaller spills approximately
every other year during the time between.
89—1
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Along the coast of eastern Maine there are
breeding,migration and wintering grounds for major
elements of several seabird species of the western
North Atlantic. Important breeding grounds of some
widely scatterd and numerous species such as Common
Elders, Arctic Terns and Black Guillemots occur there.
In addition, there are “special” species which have
smaller populations but these species deserve special
consideration because of their limited breeding
distribution in U.S. Coastal waters. These include
Leach’s Petrels, Laughing Culls, Razor Bills and
Atlantic Puffins. Except for a tiny and seriously
endangered outpost in Massachusetts, the only breeding
populations of Leach’s Petrels on the Atlantic Coast
of the U.S. are on outer Maine islands. A relict
population of Razor Bills, the closest living relative
of the nov—extinct Great Auk, breed on Machias Seal
Island south of Grand Manan Island. in New Brunswick,
on Old Man Island in Maine, and on Matinicus Rock
in Maine. Atlantic Puffina breed only on Machias
Seal Island and Matinicus Rock. Both species are
virtually absent from nearby Canadian Maritime Pro-
vinces, New Brunswick and Nova Scotia. Certain of
these species are especially vulnerable to oil spills.
These include the Common Elders, Black Guillemots,
Razorbills and Puffins. In addition to supplying
breeding grounds for these species, the coastal waters
of central and eastern Maine supply important wintering
or migratory habitat for seabirds of several species —
some numerous, some very rare. These species include
Common Loons, Red-Throated Loons, Horned Grebes, Red—
necked Grebes, Harlequin Ducks, Old Squaws, Common
Goldeneye, Barrows Goldeneye, Bufflehead, Red—breasted
Mergaosers, Black Scoters, Surf Scoters and White—
winged Scoters.
The experience of many students of seabirds has
shown that local populations, which tend to be self
contained, will be seriously damaged and perhaps
eliminated from locations within the area subjected
to repeated oil spills.
b). Not only do oil spills kill seabirds directly. They
also have an impact on the food resources of many
species. Evidence indicates that in addition to
contaminating the flesh of molluscs,hyd’rocarbons
seriously affect the behavior and reproduction of
shrimp and shrimp like crustaceans. These species
form the food of some seabirds, or are the food of
baitfish such as herring or sandlaunce, which are
the staple diet of others.
89—2
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2.) I have been doing research on Alaskan Seabirds on
contract with NOAA, making baseline studies for the Outez
Continental Shelf environmental Assessment Program. As
a result of personal (not professional) experience with
the impact of oil industry on small towns in Alaska, I
would like to make some comments.
a.) Environmental Impact Statement fails to give
proper emphasis to the impact of construction wQrkers
and oil company personnel upon small isolated villages
and towna. The people of eastern Maine should know
about events of the last 4 years in Alaskan towns
8uch as Valdez, Cordova, or Nome where there have
been spectacular increases in stealing, gambling,
prostitution, and crimes of violence. Pressure on
existing housing is especially serious. The proponents
of development don’t acknowledge the damage done to
vulnerable human elements of a simple community, They
talk only about those who profit by development and
ignore those whose lives are disrupted by change in
their way of life. It is the poor people who suffer
the most (fishermen, wood cutters, as well as farmers)
and whose standard of living is most damaged by the
influx of workers competing for jobs, by rising costS
and taxes to pay for the inevitable expansion of
schools, highways and other municipal facilities.
These people are unable to plead their case.
One need go no further than Sudbury, Framingham,
or Way].and in Massachusetts for an overview to get a
skeptical judgement on what happens to living costs
and taxes when industry is brought in to the town
“to broaden the tax base”.
b.) Of special importance in the complex of character—
i tjca which make up eastern Maine is its remoteness
from urban people, pressure and technology. Species
of wild life persist there now which have been driven from
once suitable habitat further west, where people are
now more densely gathered.
People move to Maine or return because of the
non—urban life that can still be led here. It is the
essence of sensible regional planning to allow a mix
of types of economy and life styles not to homogenize
the whole landscape into a mosaic of industry and suburbs.
In conclusion, it seems to me that the Impact Statement
evades what should be its major point. A large refinery should
be even more successful at the edges of an industrial complex,
if one could indeed be successfully operated at Eastport with
89—3
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due consideration for environmental and social costs. The
larger human populations around such an industrial complex will
profit more by the industries presence and keep a watchful eye
in order to ensure that high standards of environmental pro-
tection are met.
When oil spills do occur, the results will be relatively
obvious: oiling of rocks and beaches. In contrast, oil spi1l
in a remote area whose biological systems have not been simpli-
fied by the effects of human presence produce major effects
which are obscure and difficult to demonstrate, although no
less serious and pervasive.
Sincerely,
William H. Drury
Faculty Member in Biology
WHD/crw
89—4
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Responses to Comments by W.H. Drury
Si. The DEIS gives too little recognition to the predictable damage that will
occur to local seabird population if oil tanker traffic increases. Experience
Indicates that where shipping is moderately heavy, oil spiiis kill seabirds
faster than population can recover.
RI. Comment noted. Sections of the FE1S Vol. II p. VI—29ff, Oil Spill Effects,
p. IV—38ff, Oil Spill Containment and Recovery and p. VI—28ff, Chronic
Discharges.
S2. The coast of eastern Maine is an important breeding grpund of several seabird
species. The outer Maine islands are one of two outposts for the breeding
of Leach’s Petrels. Altantic Puffins breed only on Machias Seal Island
and Matinicus Rock. The coastal waters of central and eastern Maine supply
important wintering and migratory habitat for seabirds. Local populations
of seabirds, which tend to be self—contained will be,seriously damaged or
eliminated from areas subjected to repeated oil spills.
R2. Comment noted. See FEIS Vol. II p. VI—29ff, Oil Spill Effects,
S3. Oil Spill also impact on the food resources of many species of seabirds.
Hydrocarbons can seriously affect the behavior and reproduction of shrimp
and shrimp—like crustaceans.
R3. Comment noted.
S4. The DEIS fails to give proper emphasis on the impact of construction workers
and oil company personnel upon small isolated villages and towns. It is the
poor who will suffer the most — fishermen, woodcutters, and farmers. It will
be their standard of living that will be damaged by the Influx of workers
competing for jobs, by rising costs and taxes to pay for expansion of schools,
highways and other municipal facilities. These people cannot plead their
case. One needs to go no further than Sudhurry, Framingham to see what happens
to taxes when industry Is brought into town to “broaden the tax base”.
R4. Comment noted. See FEIS Vol. II p. VI—4ff, VI—liff.
S5. A special characteristic of eastern Maine is its remoteness from urban
people and its associated pressures and technologies. People move to Maine
or return because of the non—urban lifestyle that can be carried on there.
A mix of all types of economy and lifestyles is needed, not a homogenized
landscape of industry and suburbs.
R5. Comment noted.
S6. The DEIS misses its major point — a refinery should be even more successful
on the edges of an industrial complex. The larger populations around such
an industrial complex will profit more by industry’s presence and keep a
watchful eye to Insure that high standards of environmental protection are
met.
R7. Comment noted. See FEIS Vol. II p. IV—lff.
S7. When oil spills do occur, the results will be relatively obvious: oiling
of rocks and beaches. In contrast, oil spills in a remote area whose biologi-
cal systems have not been simplified by the effects of human presence produce
major effects which are obscure and difficult to demonstrate, although no
less serious and pervasive.
Ri. Comment noted.
89—5
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Response:
Comments noted.
‘ See FEIS Vol. II p. VI—78ff.
LUBEC MAINE
i -•LT-LU - I
14th January 1977.
Department of Environmental Proteotion,
State of Maine,
Augusta,
Maine.
Dear Sirs,
re. Proposed Pittston Eastport Refinery emissions
I read that Pittston has requested to activate its
application for an air emissions license in Eastport. As I
live only two miles from the proposed “refinery” (actually a
desulfuring plant) site, I am concerned about the amount of
sulfur dioxide erisaions into the atmosphere, no matter how
high the stack. Pittston stated in their own report that they
will send up two tons of sulfur dioxide per hour .
You are undoubtedly aware that we have been known to
have solid fog with temperature inversions for weeks during the
month of July. During such times emissions spread over the
entire area and stay put, for lack of air movement. Under uoh
circumstances, the sulfur would combine with the fog, resulting
in the creation of sulfuric aoid. This acid would settle,
killing all vegetation; viz. Sudbury, Ontario. The harm would
affect not only Eastport, but Lubeo, Campobello and Deer Island
at a minimum. It could easily affect Nova Scotia, given the
right wind conditions. Exxon at their Milford Haven refinery
in Wales handled a similar type of oil with the same sulfur
problem. Sulfur removal techniques were used to eliminate this
sulfur hazard (as the surrounding vegetation happens to be a
British Royal Park). Why oan’t Pittston do the same?
I will leave it to the chemists and biologists to
evaluate the effect of the sulfuric acid on the waters of the
Bay of Fundy and the Gulf of Maine.
My impression is that we are dealing with an oil
company not of the first rank and that those of us living in
the surrounding area will pay the price of the cost cutting.
After absorbing all the polution hazard we will not even have
the benefit locally of lower oil prices. Is this what the
State of Maine oalls progress?
Yours truly,
EPA Regional Office — Boston
90—1
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PORT ON Tr DRAFT
SNVThONM NTAL IMPACT STATE!’ MT BY THE
U.S. ENVIRONMENTAL PROTECTION AGENCY
ONC RNTh THE PROPOSED EASTPORT
REIFIN Y AND ! ARINE TERNIMAL
By
TRANSPORT CANADA,
FISI S ADENV ON NT CANADA,
and
DEPT . OF ENVIRON !ENT, ? W JNSWIC
DEC B!R 1976
91—1
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INRODUC I I
The foUowing conments i the Draft Environmental Impact statement
for a proposed oil refinery and marine terninal at Eastport, !4a ne, have
been prepared from a series of individual coianents written by off ers
of Fisheries arid Environment Canada, Transport Canada, and. of the Department
of ivironment, Province of New Brunswick. This report does not seek to
address aB. aspects of the Impact Statement; co mients are rather restricted
to three specific areas:
a) the Canadian environment and the renewable resource—
based àconoc y where they are like1 y to be impacted by
the proposed action;
b) enviro menta3. factors or actions in the U.S.A., which u ay
have a transboundary effect;
c) scientific met’ odology , completeness, arid the validity of
corciusions.
In general the report foflows the same order as the impact
statement; thus, on casual reading, it may appear that a subject is
raised twice or more. Where appropriate, ccsmnents are listed under the
same headings as the or1-gi nal or the pagination is given.
91—2
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-2—
SU! ARY
In general, the draft EIS conforms to the basic format of most
environmental impact statements. The topics covered included a description
of the study area; a description of the proposed action and consideration of
the major alternatives; the environmental L’npacts of the proposal and possible
countermeasures.
In general, it is felt cLat to provide a more meaningZt Ibasis
for analysis the ES should include a greater variety and quantity of
information on Canadian and tranaboundary environmental factors, on the
Canadian resources at risk, on the proposal itself, and on the possible
alternatives.
The following areas of impact are noted as being of special
concern to Canadian officials:
a) forests, soils, freshwater fisheries and land values in
Canada arid the U.S.A.;
b) aquatic marine rsources of the Passai aquoddy area arid the
mouth of the Bay of indy;
c) air resources dowflwind of the refinery site;
d) recreation and fisnir.g interests in Cav M waters.
Also of concorm are the effects of
a) process effluents on Car-adia.i ma—ine resources;
b) dredging and blasting on marine mammal and fishery resources;
c) oil spill on Canadian recreational arid fishery resources;
d) gaseous emissions downwind on fresh water quality, soil
chemistry, forestry arid fishery resources;
e) spills of L arid molten sulfur at dockside or in transit;
t) interference by tanker traffic with small recreational arid
fishing craft.
Finally the ZS could be improved by the inclusion of a detailed
analysis of the economic disbenefits of the project in the two countries,
p3iis an estimate of the impacts, environmental or socio—economc, of
collapse or abandonment of the project once established.
91—3
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91—4
-3 —
D TAIL D OC1’2 NTS
The following detailed co im ents are keyed to the appropriate
headings of the original:
I. Descrit,tion of ,dstiri wiront
Soclo—Econamic Characteristics
Given that there are not likely to be any socio-economic benefits
to Charlotte County, New &‘tmswick, from the proposed action, it is perhaps
reasonable that only cursory attention should be paid to the transborder
population. However, since many environmental disbenefits and costs will
be directly felt by Charlotte County residents, it is essential that the
eocio-eccnoriic climate of the tranaborder area be carefully described so
that possible impacts can be assessed. Thus, although statements are made
that Charlotte County population increased, there is no adequate assessr ent
of population changes or employment. The additional data in Appendix C
refer exclusively to Washington Cotmty, Maine.
P. 31 and 34. Decline of fisheries and likely closure of plants.
It .s fairly clear now that management stratcgies for the District 4X
herring fisheries are working and that s!iortage of fish should not be a
reason for closure.
P. 35. up1oyment in Charlotte Cow Lty. It would be more meaningful
it the 2,850 people engaged in the fishing industry were shown as 36 of
the work force. The inland and coastal comminities are more or less fully
dependent upon the fisheries for their prosperity. Since bath fisheries
and tourism are susceptible to impact from the Pittston proposal, a full-
assessment of the relative significance of these two industries to the
local economy should be made. )!uch of the data is available in Tech. Rep. 4 g1)
of the Fisheries Research Board of Canada which is referenced in the . I. S.
P. 37. Apart fron Roosevelt International Park, no reference is
made to Canadian recreational facilities which i tight be im acted.
of Physical, Biological, Socioe onaiic and other factors relevant
to potential oil s ii1s in the Passarnaquoddy region of the Bay of Func y.
Fish. Re , Board Can. Tech. Rep. 4 ’S, 19?4._
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91—5
Aquatic Resources
Freshwater h’.rdro1o -
This section considers the fresh surface waters in the vicinity
of the proposed refinery. Unfort.unately, the e cLstixig water chemistry of
Canadian and U.S. lakes and rivers is not provided. This is an important
point since the possibility of increased ambient 502 level and the potential
for acid rainfall could alter pH levels in these 1 kes and riversto the
detriment of fishery stocks. Since such alterations depend on the buffering
capacity of the waters involved, an indication of at least total alkalinity
for these waters is necessary. The only data provided are records for such
parameters as flow, runoff and rainfall. This information, although useful
in other respects, will not allow accurate prediction of changes in pH and
subsequent fishery irpact.
Marine Hydro1o
Although the ma ne terminal proper is planned for U.S. waters,
untoward events at the terminal will inevitably have repercussions on the
Canadian side of the international boundary. It is thus essential that
the hydrography of the whole area be accurately described and thoroughly
understood.
Physical Oceano rst,hic _ Peature s (Channel )
The description of the navigation channel (p. 51) fails to include
any mention of a 9 fathom patch (54. ft.) indicated on Canadian Chart 4373
(Campobeflo Island) approdi ately 1 cable inside Canadian waters tat, 44 53. N.
Long. 66 5 ,2 N, but not shown on other hydrographic charts of the region.
This omission may have led American Chart makers to believe that the reading
was no longer valid. Hydrographic officials in Canada and British Admiralty
survey officials in ngland confirm that this 54 ft. sounding is verified
by the original survey data, and the patch is latown to local fishermen.
This patch is less than the -ilnimum depth required for the safe passage of
large oil tankers.
Additionally, the minizrr rn channel width is measured at 1500 ft.
rather than the 1650 ft. shown on p. 51.
p. 59. Tidal currents. The statement as written implies that the
“second study” was a co—operative venture by Atlantic Oceanographic Laboratory
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—5 --
and Hydrocon Inc. This could be misleading; the Canadian sf udies, it
should be noted, were conpietely independent.
P. 60. Current velocities off Shaekford Head. The distinction
between “greatest mean hourl: ve1oc ity” .ancI ina d.num velocity is not discussed.
Frequently it is the occasional xtrer tes that cause structures to fail rather
than the sustained, average stresses. In this respect summary Table 111.10
(p. 65) contains several inaccuracies. Scrutiny of Appendix 1) shows maxLmuni
current at Station 3 is at least 4.2 knobs (rather than 4.0), at Station 4,
3 ,5 knots (rather than 3.0), and at Station 5, 6.0 knàts (rather than 5.0).
Thus the extreme velocity recorded off Shackford Head was twice the “greatest
mean hourly velocity” shown on p. 60.
The station 5 meter was at a depth of 26 ft. below MLW ca pared
with 5 meters for Stations 1 -4. A pendix Fig. 1)4, by Atlantic Oceanographic
Laboratory, is incorrectly attributed to G Inc.
The statement that currents off Sroad Cove are consistent in
direction and speed is difficult to interpret and possibly difficult to
substantiate. Examination of Ap endix Pig. D5 shows ma dmum currents may
be similar or as much as 2-3 knots different in succeeding tides (e.g. Feb. 13,
16, 17, 1973, etc.).
P. 66. The data to substantiate the claim that “slack!’ water
(V4 l kt) lasts 50—12) minutes at Deep Cove are obscure. First, the location
of D Station 2 (Appendix Fig. 1)6) is not given. It may be Station BC 2
near Estes Head, but this, although in 80 ft. of water, is close inshore and
more relevant to the old proposed Ester Head pier than the current proposal
for Shackford Head. Station #5, which appears to be less than 1 tankerlength.
directly off the pier, gives a better indication of the minixnizn current -
speeds likely to be encountered by vessels manoeuvering near the pier. Note
that of the 19 slack water periods between 1 arch 4 and 9, 1973, currents
did not register lower than 1 knot during five, and an a further three the
1 knot minimum velocity was only sustained motneritarily. The record, for the
month shows that on appro d.mately 13 of 111 “slacks” the current did not
drop below 1 know at the 26 ft. depth. On appro d.mately 6 tides (not
necessarily correspondin _to the sai e “slacks”) the current at 53 ft. depth
did not reach Or drop significantly below 1 knot.
91—6
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91—7
Ma drnum currents in the berthing area are sho n to be approxinately
1.75 Ia iots along the 75—ft. contour. It is not stated at what depth the
meters were moored. Transposition of stations (Fig. III 16) onto the
bathymetric chart (Fig. III 13) sho’ :s Station 6, (in appro dinat.e1y 78 ft. of
water) to have currents exceeding 1. 2 nots 5? of the ti’n , and Station 9
(in 72 ft. of water) to have ’ currents in excess of 2 Imots 15 of the time.
This implies that the current regime, navigational hazards and difficulty of
spill containi ent and clean—up are likely’ to be more severe tha the E.I.S.
suggests.
It has also not been noted that currents may flow in different
directions at different depths particularly at or about the turn of the tide.
This is clearly sho ’tn on Foresters diagrams. rther, it should be remembered
that the times of high and low water and their “slack” current periods may
be up to l- hours out of phase. The implications of these factors on pilotage
and navigation scheduling should be considered.
P. 81. There is no iestion that the water of the Passanoquoddy
area as a whole is vertically well—mixed; ho rever, Table III 15 does not
illustrate this phenomenon.
Ecolo. ’ — Flora
This section considers terrestrial vegetation. The physical area
described, ‘however, is quite small and limited to the “site area” (undefined)
in the immediate vicinity of the proposed refinery. !!ore data on vegetation
(especially for Canadian forests) should be included.
Eco1o t — Fauna
In this section, there is very limited infon tation on bertthic
invertebrates, plankton and algae from Canadian waters. More of the available
data should he utilized and assessed.
Information on commercial species and avifauna in bath American
and Canadian marine waters could better be presented in a manner that pinpoints
the location of fishing gear, shellfish beds, breeding colonies, and nursery
areas. As the data are mat presented, only landed values and species lists
are available, and this information is not sufficient for predicting the
implications of an oil spill. For example:
P. 105. Clam flats. Charlotte County has slzailar but less extensive
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91-8
clam flats. Production fran these beds is currently estimated at 2 million
lb. per year and provides emloyrnent for approx. 150 people. Current
research within the Canadian Fisheries and 4arine Ser riee on depuration will
Boon enable a further 900 acres of clam beds to be brought into production,
roughly doubling the harvest. In addition, clams represen a considerable
recreational resource. -
P. 112. Scallops. As with clams, scallops are fished both commer—
cial].y and recreaticnally (by divers). Si ific ant a’nounts are sold directly-
“over the side of the boat” and are not recorded in any official statistics.
P. 118, Plankton. The whole question of primary productivity of
the Quoddy area is currently being actively explored. Plankton productivity
of the classical school cannot acco’int for the high fisheries productivity
of the area. Sane 100,000 tons of fish are removed annually. Thus, the
source of ener ’ into the area must be sought elsewhere. This ener t must
come from littoral and sublittoral seaweeds, bacterial degradation of
sedimentary organic matter subsequently recycled by benthic sec!imentary
feeders and littoral primary production by dinoflagellates on intertidal
soft sediments. All of these mechanisms are vulnerable to one or more fon s
of oil contamination or the use of dispersants for clean—up.
P. 1ZL. Atlantic herring, etc. The suggestion that weirs operate
mostly in the Perryr region of Passamaquoddy Bay is incorrec:t. There are in
excess of 250 weirs in Charlotte Comty, N.B., with a c rre t average replace-
aent value estimated at $15,000 each. A map of their distribution is in
Technical Report 428 (referred above). The interpretation of herring stock
structure given on p. 123 is no longer accurate and should be up-dated (see.
Hare 19762). There is also an apparent error (p. 123) in the interpretation
of Table III 32, which does give dollar values for herring landings from
weirs. Table III 32 indicates that some 60 million lb. of herring out of a
Bay of P mdy total of about 260 million were caught in weirs. These 60
million lb. would be worth about $1.95 million in 1974, $2.22 million in 1975
and $2.66 mill 4 on in 1976.
In addition, a fleet of 51 Canadian seiners catch herring at a
variety of locations within the mouth of the Bay of indy. The price of such
2) Hare, G.!i. An atlas of the major Atlantic coast fish and invertebrate
p i-n, ipq i w’cn+ 4i . S pq ! , irj i-t, Pich.
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herring is now up to 105 a ton. Until recently a large portion (75 ) of
the mobile fleet catch went for reduction; now over 6o goes to food, and
next year it is anticipated 10O of sales wi].l be for food.
Technical Report 42 , Chapter 6, s ximarizes the significance of
the herring and other fisheries to the econom:r of Charlotte County and south-
western Nova Scotia. The E.I.S. would be imorQved by the inclusion of a
s xnmary clearly identifying all the natural rene!rable resources put at risk,
together with current investment, regardless of nationality, thus relating
the8e fisheries to people and their way of life.
The month of the Bay of indy has long been regarded as a funnel
through which birds move during migration. In addition, several aquatic
species occupy that region as breeding habitat or wintering habitat. Therefore,
substantial numbers of birds are found there year-round. Many members of the
species important aesthetically or for recreation, both in Canada and in the
United States, inhabit the region most directly threatened by the proposed
development. The highly mobile seasonal avian resources of the Quoddy
region cannot be considered simply from the isolated perspective of that
region. Nor can the effects of a major oil spill, be projected as a stationary
event.
The Passanaquoddy area is a major overwintering site for Black
Thick, sea ducks, and seabird. In addition, that location is a si ificant
c igration stop for Atlantic brent, and phalaropes. In one case alone,
American Birds (February 1974) noted that “the regular gathering of phalaropes
in Passarnaquoddy Bay off Eastport, Me., was estimated to contain as many as
a million birds Sept. 2 (1973) ..., considerably more than the previous
high estimate there (100,000 on Aug. 2]., 1971 ...) but nonetheless easily
conceivable”.
The Grand Manan Ax hipe1ago supports major breeding colonies of
herring gull, Arctic tern, Leach’s storm petrel, and common eider. ]:n
addition, it should be noted that cor:r on puffin, razorbil, and black
g ii 11emot breed there. Paffins and razorbil].s are especially significant
as they are relatively scarce in the Maritime Provinces, where their principal
range is restricted mainly to the Grand Nanan Archipelago. These highly
highly acquatic species have a very low re roductive potential. The assertion
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that the c on eider is not co ron around Eastport, it should also be
noted, does not accord with Appendix Table F. 26. Such birds are in fact
c m on in Passa aquoddy area during
Air Resources
ii tato1o tv
The clinatologica ]. data presented in the 2.I.S. are useful and
interesting but incomplete, and the interpretations are sometimes open to
question. This is of importance to Canada for two reasons. First, because
the prevailing widna are westerly, Canada is largely do inu3.nd of gaseous
ei .ssions from the refinery. Secondly, because safe navigation is so highly
wsathez -dependent, it is important that the c1ir’ te be carefully and accurately
described.
The statement (p. 132) that the average annual rainfall is about
40 inches does not accord witif Tables 111—36 arid 111—37. As the latter
accurately show, the average annual total precipitation is 41.14 inches, of
idiich the mean a.nrrua]. snowfall accounts for appro dinate1y 7.]]. inches of
water equivalent, leavin 34.03 inches as rainfall. The stat ent that
there are, on the average, 12 thunderstoms “per season” is confusing; it
should be “per year”. ft 1 n earlier US’ 1B sumary of Eastport data states that
the greatest monthly snowfall was 53.7 inches in anuary 1952, which does
not agree with the data on pages 132 and 133. The contention (p. 134) that
“normally the last freezing temperature in the spring occurs by April 28”
is questionable, as this is more likely to be the mean or median date of last
spring frost. In half of a].]. years frost will occur before October 23. The
173 days “without freezing ternperatures” (p. 134) represents the interval
between the mean date of last spring frost and first autunn frost. There
will be numerous other days as well between late October and late April when
the temperatures remain above the freezing point.
The statement that 1969 to 1971 had higher than average fog
frequencies is questionable and is made without supporting evidence to show
the actual average.
Table 111—39, p. 151, gives duration and frequency of “fog, snow,
rain and vapor at astport ” for 1969 through 1971, although a footnote says
“compiled from Quoddy Read fog data”. There are no definitions of hat
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91 —Il
—10—
constitutes “vapor”. The figures are presu.i ab1y averages for 36 consecutiire
months, which is a very sr all sa p1e for statistical treatment of c1imatolo .c*3.
records. Ueither the year—to—year variability nor the extremes are indicated.
The table is, therefore, of limited value, although tt does suggest that fog
can persist for up to at least 4 days .
The statement that fog is more frequent arid dense from midnight to
0$ OO may be correct but is misleading in that it implies that th daylight
hours are largely clear. The habit of sunmer fogs in this area is to burn
off in late morning towards noon and to reform again about 3:00 in the afternoon.
The first paragraph of page 143 is an extended way of waying that Eastport
is the foggiest place on th American eastern seaboard.
From the navigation point of view, the significant factor is not
the occurrence and duration of the fog, but the frequency and length of the
clear weather periods, and their relation, if any, to the tidal cycle. In
this respect, the Harris I report (3 P exhibit 26I) ) and the Technical
Report 42 , Chapter 9, which address the cuestion of fog on port performance
are more pertinent than duration arid return period analyses.
Fog is also important in that oil spills are at present mdetectable
in fog ,r weather. Canadian experience in the Bay of Fundy at Canaport can
be used to support this point.
On page 136, the statement is made that U tropica]. cyclones
occurred in the area between l 6 and 1970. This figure should be verified,
for a paper by Hope and Neumann (1971) suggests that the risk of tropical
storm occurrence is higher than this implies.
Storms and pressure systems. The impact of rapid weather changes,
co mnon during colder months, should be more thoroughly assessed. These
winter storms are frequently rapidly ioving, difficult to forecast, arid of
far greater impact on terminal operation thsn the much rar r tropical cyclones.
Air iality -
Page 136, paragraph 4. Advection type inversions are not mentioned.
Judging from the frequency of fog, these are probably of significance, and
their implication should ‘ e assessed.
3) Ilaine Board of Environrient Protection, astport Hearings, Exhibit 26D.
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II. Pescripti n of the Project
Marine Transoort $y tem
The comparison between MUford Haven a id Eastport Table VI — 8
(p. 221) is in many ways misleading and incomplete:
The channel at Eastport is by no means straight; it has a ()O turn
at the mid-point aid 84° of turn In ‘ the last 2 miles.
Cross currents up to 2 knots develop at at least 5 locations a.lozig
the intended route: at the nouth of Heed Harbour Passage, Harbourde Lite,
Western Passage, Friar Roads and off the berthing areas. The turning area
mentioned in table VI—8 is not identified, and thus the figure of 4 VLCC
lengths cannot be verified.
The weather, though discussed earlier, is riot mentioned here.
Eastport is generally co1d r and foggier than Milford Haven. “Slack” water
for berthing has already been defined as “currents less than 1 knot” and
cannot be guaranteed at Eastport (as noted above). Another siguificant
difference is that Milford Haven is not located in a high-productivity
fisheries area.
Containment and clean-up procedures at Milford do not rely on
booming but rather on the liberal use of dispersants 1 . which cannot safely
be used in biologically significant areas.
Aids to Navi atiori
According to intoz on av i1 hle in CariMa , the electronic
ch r ne1 guidance system upon which the Pittston Company ba ôs their
navigation proposal is an experimental channel gqid nce ranging system
which has been tested at Mi].ford Haven and has been found to suffer from
reflections off other objects in the area. Our latest information is that
Milford Haven has dropped plans for instAllation of a full system. Even -
if effective, this system, would simply aid the operator in visual iden-
tification of the channel and would not, in itself, assist in preventing
groundings or collisions.
Proposals and suggestions concerning the capability of r 4er
equipment appear optimistic. A 48-mile range scale on the rador does
not necessarily indicate a worlcthg range of 48 miles; it is in fact
91—12
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—12-.
uni.ikely that targets could be detected at a greater distance than 2ff nd.les
from the sites indicated in the proposal, except under ideal climatic
conditions. In h a’uy sea conditions and in precipitation, the effective
range would be considerably less.
MF conmiunications are not considered adequate in modern traffic
systems 7 which operate entirely on VHF. -F\ rther, Canadian operating
experience, does not confirm that, duplicated equipment ‘will guarantee 1QC
availability.
Transit and Berthin Procedures
The draft EIS refers in a number of places to the Maine Board of
Environmental Protection orders on the Eastport project. In this context,
it can be noted that the descriptions of the transit and berthing procedures
are, in parts, at variance with condition Dl imposed by the Maine order
of June 4, 1975, and. conditions D8 (double bottons vs conventional ships),
1)3, D4, and D5 of the order 12 March 1975. Should condition DS prevail,
for example, channel depth and dredging requirements might well be
difZerent .
As suggested above, a number of corrections are necessary in this
section. For example, in map IV—7c p. 231, the 75—foot contour line
includes areas of less than 75 feet off Friar Bay, and a 9—fathom patch
between Eastport and Welshpool, 1 cable inside the Canadian boundary 4 .
Fog frequencies will have significant effect on the operation of
a refinery and marine ternd.nal complex in the Eastport area. Insofar as
navigation in the of indy and T id rhôu assage is concerned, the
frequent occurences of thick, n f±. n peraistent fog wi -li complicate
scheduling which is alr y tide-dependent . The whole question of meteor-.
logical constraints, including the rate of change in weather conditions, on
port operation and performance should be more thoroughly addressed.
The figures given in table IV 9 (p. 233) and the description of
VLCC irniard transit (p. 226) are reasonable except for the following points:
I. Tugs will have to be made fast at the entrance to Head
Harbour passage to aid in deceleration with a following
tide, and to counteract any sheer.
4. Canadian Hydrographic Chart 4373 Campobello Island
91—13
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2. It is debatable whether the current in the latter part of the
transit would be 1/2 or 3/4 of a knot for reasons mentioned
earlier.
3. There are at least 5 areas of the passage where cross currents
can be expected.
4. The times of high water ar I high water slacic are not necessary
synchronous. The proposal does not discuss the implications
of this fact, nor of the fact that tidal currents may flow in
opposite dire tions at different depths.
With reference to berthing maneuvers. If the pilot has successfully
positioned the ship two to three hundred feet off the berth, it could be
p shed into place and positioned with respect to the manifold in 30 nxLnutes.
However, Caitedian exnerience is that the mooring could be expected to take
another 1. to 2 hours before the ship would be considered secured safely in
the increasing tidal flow. Turning and bacid.ng the vessel prior to berthing
would cause dd1tiona1 complications, particularly since the control depth
area is only )O feet longer than the VLCC. The Canadian Termpol code re-
ccmeends for Canadian ports a control depth area exteM(rig 1 design ship
length fore and aft of the sid point of the berth.
In this regard it should be noted that information on areas to be
dredged does not appear in the EIS, and Canadian coi ent is based on
information t*en from the public notice issued by USACO o’i 12 Oct. 1976..
The product tanker scherhil{ng table VI—lO (p. 234) would not seen to
comply with de nrI of prudent navigation in that speeds of 9 knots are
excessive. Escorting tugs would not be able to come alongside and made fast
at this speed. For ships in excess of 30,000 dwt the schedule would have
to be increased by at least Z) minutes, pitting these tankers outside ‘the time
frames given.
Oil Spill. Containment and Recovery
Oil spill, containment and recovery are not adequrte].y addressed.
There is, for example, no assessment of the effectiveness of the equipment
proposed, nor of its adequacy. The technical detitls of the booming
procedures are not developed. How, for ex amp1e, are the anchor and anchor
line assemblies deployed? A recent paper by McCracken of Leonardo, N.J. 5
91—14
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—14.-
shows diversionary boom capability is reduced in wave conditions to as little
as 0.5 knot, above which speed oil loss occurs. ven under calm conditions,
oil cannot be contained above current speeds of 1.6 knots. Oil loss normally
begins to occur at 0.7 knots perpendicular to the boom rather than at 1 knot,
as suggested in the Statement ( iilgram and Van Houten — YIT).
Wind and other weather ph norne a such as freezing spray and storms
will severely limit and hamper oil spill recovery techniques.
The applicants’ own witnesses ( astport Hearings Vol. 5)indicated
that there were days during the current and bathymetric surveys in winter
when it was too rough for 24—ft. vessels tomanoetwer off Broad Cove. Yet
this is the same sized vessel proposed for spill containment and clean—up.
Canadian consensus is that booming proposals for the piers i’iould
be ineffective, and that recovery of free oil in the passages would be
impossible owing to the high current speeds. Soiled oil wcld be oartly
washed ashore onto th ac es ., t —iaixed i 4’ e j bulent areas an
partly taken out to sea.
Oil Refir.inz Process System
There is very little information on the sulfur plant (see p. 253)
and it is not clear what emissions are involved, nor whether they are included
in the No. ‘a 1 and 2 stack emission tabulations in Tables Vi-4 and Vi—5.
The statement (p. 253) that “further treatment will be required to meet
BACT requirement” is not reasruring, especially in view of the apoarent lack
of further discussion of this unit and its effluents.
A brief reference on page 254 alludes to a proposal for switching
to very low sulfur content fuel “in the event of an adverse short—time weather
inversion”. Details on this proPosal are not found elsewhere in the EIS.
Since inversions due to the coastal climate can be expected to occur quite
frequently (see p. 136), the topic is of major interest. No definition is
given here as to what constitutes an “adverse” inversion, nor what may be
considered a “short—time” duration. There is no indication of how these
conditions are to be assessed b the operating personnel so that the decision
to switch fuels can be made. In at least one known instance (the Coleson
Cove steam generating plant near Saint John, N.B.) a detailed daily program
has had to be set up for tjie measurement of surface and upper air data
at the site. These data are then considered by meteorologists who also have
91—15
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91—16
—15. . ’
access to current and forecast surface and upper air data on a continental
scale. Using all available in.tormation, a compiter-produced forecast of
stabilit!y and dispersion conditions is then passed to the operating engineers
at the plant to enable them to foresee when and for how long a switch to low
sulfur fuels uiist be made. It is difficult to see, from the abbreviated
statement on page 254. of the ElS, how the Eastport refinery could do without
a comparable objective system based on observed and predic1 ed conditions.
In the absence or details on such a system, promises to reduce sulfur
esissions during inversion occurrences are impossible to evel”ntèrneaningfully.
Waste Disoosa]. Systems
Without further definition of “the cd.niunim racticab1e amounts
and concentrations” (part 257), it is 1 1 r1y difficult to attach precise
me n 4 ng to p 1 oaises concerning poibition coz*.rol end abatement systems.
IU Pro .lect Alternatives
Figure V—i evaluating alternate site locations using a subjective
scale. Oil spiM risks have not been incorporated here. Moreover, the
table indicates that the Eastport site is excellent in terms of navigational
approaches, a dispitable r&4ng in view of the 1f ’igth and intricacy of Head
U—.
The matrix in Figure V—i is not persuasive. For example, under
“ay llithility of 3. 3. service”, Eastport is given top marks although
elsewhere in the ElS we read that the rail line is so deteriorated that a
2) mph Bmit has been imposed and the operator has applied for abandonment.
ftr the rem {thng ]3 alternatives, the rating for this factor is either zero
( none or not possible) or 1 (usable or possible). If this rating alone were
reduced from “exceuentl’ to “fair”, the matrix value for Eastport would then
equal . that for Hancock Point.
In general, the significance of the matrix as currently established
is questionable, especially given the comparatively few factors considered.
Although Eastport rates first of fourteen alternate locations by this
analysis, a Canadian East Coast Oil Ports Study, which ranks 22 Canadian
locations based on a number of factors ranging from navigational haiard
to resource vulnerability, rates the Passamaquoddy Bay area (including Head
Harbour Passage) as the least acceptable location for an oil. poit. The
ranking. factors used in EPS’s statement could well be expanded to include
such additional factors as environmental sensitivities in order to produce
a more meaningful analysis.
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-16- .
In addition, the subsequent assessment of alternative sites does
not consider Canadian resources arid socio—econontic factors in the Quoddy
area; none of the other three sites have th important fisheries base centered
on Hea i Harbour Passage. The statement that the impact of an ci]. spill wou24
be greatest at Penobscot./B].ue Hill cannot be substantiated from the data
presented. A fuller assessment of re].at ve navigational risks would also
be necessary for complete comparison of the various sites.
91—17
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91—18
TV. Bnvironmcntsl I acts
ocio—Eco!torlics
The statement lacks reference to impacts on Canadian recreation
resources ai and around Deer Island, Cai pobello Island and the Ch irlotte
County shores, SL’ ilarly, ther& is no assessment of the likely ix±er±’erence
by tanker traffic with the e d.sting Canadian fishei ies traffic.
Aouatic Eesources
Freshwater
The conclusion that “no freshwater bodies will be affected by either
construction or operation” is subject to question. No consideration has
apparently been given to possible acidification of lakes and increases in
heavy’ metal concentrations and subsequent fish stock damage due to increased
ambient levels of SO and the possibility of acid rain dot nwind. Damage
to freshwater lakes caused by airborne 502 is well—known. Since prevailing
s r winds in the astport area are mainly from the south est, damae to
freshwater lakes and rivers In Canada is a definite possibility and should
be given greater consideration.
Iim act of o tine Peftner’- )ischari es
Gi Marine fater ( iality
The earlier sections of the draft describe the waste water treat —
aim t processes as opposed to the q i l Ity of the wastes themselves. The only
figure given for i aste water quality is the maximum permitted concentration
of oil. The implication, although nowhere stated, is that the waste would
be recycled if it failed to meet this specification.
A inusber of questions are thus germane: (a) ‘Ahat are the sizes
of waste holding basins and how long can the plant tolerate an interruption
in the waste water treatment system before either the refinery must shut
down, or untreated wastes be released? (b) tlhat would the waste water
quality be if untreated wastes were discharged? (c) !hat are the plume
dispersal patterns like, and what effect will they have during normal
operation or during upset conditions, on the process water of fish processing
canpanies?
The potential impacts of treated refinery process effluent appears
to have considered only in the statement that the discharge must com ly w th
EPA’s Ni’u S and ? aine’ a 1ater Quality Standards. Treatment of this question
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91—i9
—
so— e impact, but this cannot be assessed in the absence of relevant data,
Specifically:
(a) What toxic chemicals will be rolased into marine waters (only oil
and grease are considered, what about phenols, ammonia, suiphides)?
(b) What will be the ambient concentrations of these chem3 cals?
(c) That are the lethal and sublethal tolerance levels of the marine
biota in the area likely to be affected?
(d) What will the environmental and economic implications be?
- Oil Spills due to Tanker Accidents
A mtnber of statements in this section are open to question. The
Z) barrels per annum spillage projected for Eastport is not well substarrtiated.
The data base for i ilford Haven, which has been chosen for basing projections,
is inadeqtiate for meaningful analysis. There are also a number of differences
between the two ports. For e zemple, it should be bonie in mind that the
winter climate of r:ilford Havin is considerably milder than ast ort’ s, and
the perfoi nance of men world.ng outdoors in cold weather is seriously
reduced. This will be reflected in increased likelihood of poor wor1c anship
and slower responses.
There are also different attitudes to at ? !ilford, where
dispersants are used for all but heavy residual oils. !ilford experience
is that oil cannot be contaized in the channel where ma dznum tidal velocities
are 2+ knots.
p. 306. Oil spills due to accidents. It would probably be fairer
to say that the only agreement was that large spills would be infrecuent but
inevitable, Nilford Haven has ex erienced some 7 spills in excess of 100
tons between 1960 and 1975. Thus the estimate of one per years for
Eastport is not unreasonable, ho•rever speculative. It might be more a pr
priate in this regard to com are astport with ports where weather conditions
and other factors are more s!nilar.
Potential ffects of a Still
The E.I.S. does not assess the likely distribution of oil following
a significant spill, nor the natural, human and capital resources likely to
be impacted, nor the response capabilities of the applicant. It is stated
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91—20
that “the specific impacts to an area will depend on the size and conditioris
of spillage, and, thus cannot be fully evaluated unless these specifics
are known” (p. 314). &ich an attitude, taken to its ultis:tate conclusion,
implies that the question of clean—up a d containment need not be addressed
until a spill occurs. The E.I.S. does nat discuss whether appropriate
techniques are available and would be used.
It should be noted in the context of oil spill effects that the
absence of successful legs]. claims for damage is .no guarantee that biological
damage did not in fact occur, A major spill during any season could have
a siguificant impact on birds which breed in Canada and from Which Canadians
derive enjoyment and benefit. The E.I.S. does not relate the avian
resources to human recreation and values. Oil poU*xtion could be devastating
to most of the species frequenting the area, parttcularLy those species iith
lo i reproductive rates. In the long tenn, it should also be noted, chronic
pollution could be more serious than a massive spill. Oil released to the
Quodd and adjacent regions would move back and forth through the area,
this rendering the potential mortality significantly higher than that of a
one—pass event. -
The tem itation a id pressure to apply a diapersant in thc cvcnt of
a large, uncontrollable spill would be high. The potential inpact of such
action could be as great, if not a greater, threat to marine organisms than
oil Itself, affecting the avian resource by diminishing primary and secondary
production.
Additionally, it should be noted that the possibility of an
accidental spill or release of molten sulfur or LPG is riot mentioned, nor
are the possible imoacts discussed.
co1o
The simlnary account of tb reactions of living organisms to oil
is accurate as far as it goes; 1- ..e- ‘, there is no extension of these facts
to the conditions prevaiiin - . - sritport rea, and in particular to the
vulnerability of th i .r es and other re ources. The fact that no
connection ha5 been drawn between ht man health and oil—tainted shellfish is
iir*naterial f the reason .s because the product cannot be sold.
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—20—
Most of the material to be dredged is rock, and will therefore
have to be blasted. The table of adverse Impacts and mitigating measures
does not consider the effect of blasting on the marine fauna; there is an
extensive literature on such adverse effects.
Has the effect of dredging orf the current regIme s, i.e. direction
and velocity, in the areas of the propossd piers been assessed? ‘1hat will
be the effect on currents of having ships moored alongside?
Air Resources
There is insufficient information in the E.LS. to permit
evaluation of the transport of sulfur oxides and ozone or ozone precursors
to agricultural and forest areas of southwestern New Brunswick and western
Nova Scotia where farm crops and forest gro th may be affected. The range
of “50 miles or more do inwInd of Eastport” (p. 326) includes parts of these
Canadian provinces.
Heavy metals will a].so be dispersed. The effects of even
“trace” quantities downwind in Canadian territory can be expected to be
cumulative, and there is increasing evidence that such materials may be
transoorted for distances of u to several hundred kilorieters. The discrep-.
andes between the estimates of lead, beryllium, and mercury- emissions in
Tables ‘1 1—4 and ‘11—5 are disturbin , especially in. the cas€ of lead where
one est5.mate is 7,700 times greater than the other. The higher estimate of
200 grams per day’ amounts to 73,000 grains per year, much of which can be
expected to be deposited on the land, lakes and rivers of New Bruns zick
and Nova Scotia.
The daily tonnages of oxides of sulfur and nitrogen transported
by the prev l ling winds, can be expected to au nent the growing problem
of acid rain in downwind Canadian territory.
No data are presented, apart from a brief non— ntitative
statement on page 331, of the emissions of hydro en sulfide, and th ere is no
mention of mercaptans or other organosulfide compounds.
The question of acid mists is raised briefly on page 330. Given
prevailing wind directions dunn; most fog occurrences, the greatest
proportion of any such mists formed would advect aw r from the Eastport source
toward southwestern New Brunswick. Adverse effects would thus be much
91—21
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greater for human and animal populations in New Br.inst.’ick than in Maine.
Insufficerit data are presented to perxit the necessary evaluation of this
pot enti l-ly serious inpact. The statement on page 330 that “in about 10 per
cent of the occurre nces (of fog), the f g height uill be great enough to
cause sulfur dioxide to be emitted directly into the tog” is open to q iestion
due to lack of supoorting infoi ation. The only mention of stack height
noted in the retort is a figure of 300 feet in appendix G, but it is not
clear whether this is a design height or an assumed height, nor is it
certain that 51] . 802 sissicns would occur through these stacks. Neither
is evidence presented to shoi, that 90 of all fog banks are less than 300
feet thick.
! !cnitorirL
In several places in the E.I.S,, allusions are made to the
desirability of a continuous po ra to monitor air ‘ality thir’ing the
operation of the refinery. There do not appear to be any details on ‘ here
these monitoring stations would be located, who would operate them, who
would be responsible for the conplilation of data, nor. what use ‘iould be
made of the results.
Solid tqastes
The E.I.S. does no fully exanine the problems associated with
the clean-up of any oil spi 11 • Solid wastes thus generated could corne fro
)imdreds of miles of coast line In the event of a major spill. Disposal
sites for Canadian and U.S. clean-up needs are not considered.
91—22
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Response to Comments by Transport Canada, Fisheries
and Environment Canada, and Dept. of Environments, N.B .
See Vol. II, p. III—3lff, Marine Hydrology.
See Vol. II, p. III—7Off, Aquatic Ecology.
See Vol. II, p. VI—38ff, Aquatic Resources.
See Vol. II, p. IV—23ff, Marine Transport System.
See Vol. II, p. IV—38ff, and p. VI—28ff, Oil Spills.
See Vol. II, p. III—124ff and p. VI—62, AIr Resources.
See Vol. II, p. VI—lff, Soclo—Economic Impacts.
See Vol. II, p. X—42ff, Alternatives.
91—23
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Commercial Towing
Charter Service
EAST COAST FERRIES LTD.
DEER ISLAND, NEW BRUNSWICK, CANADA 3 N 4 - 1977
D*c.a,b.* 23, 1976
De*.t S4.4 4 :
tilt /igtrs iU .wtd w Wi R4*s. sad c .n.cs.tn. h* it.uewit .. ttj4i4. .L .h
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pg t j4 1J ... Jj a4 i .g1 tec - •n* betwtwL D.*t 4.gjid, Ii. B.
mad C.iip*Lit44 ., R • B • ; iJ .th..t &e.twun D *4 2* L.n.d, 11.8 • and m.Ap ..It,
7h. gn.ta tt2.n.L Tw ha.. bw .petaL2,i a4 fl*a444. f.4t ,t çima*
end, a4.th.*sgh i t a Lst t .petatL.n, ha. 2udA4i q.towrt & pac t
and 4.mrLq. th e.a. on ta . .u.U L.c.L na.4 end. c.M.LL4Ja . . (u . . .ncta.u4
ch*dzz4 .e). 7k. n .. a.* ?a.ta .. Cmapa& .12. (1969) ha.. p.t.usn ta it
d4Lcc.44ia. end a 4Aaç 4 .p*4a.t nq 4 d4•SL 4.4 flOW S4R C4 4(4Sd.
7k... 7.4tL* . , C44ty4JI pmpL *, .iita*abU. . ., U.ut 1. . 1 J . . .SII.. (Rd
.th*4 . .S., wouLd •. 1L5i5144tttj Ct•44 the p.a.th . La.tçe . 4. cat.t j4ng.
Ue . . . .€.L . p 4. cad .LJ4 end !t.a g a.ta2na.L m tp.*.t, Dhir2**.
7k. j mqu..ncç .,f c.t.ubiq, the ptmua4.anc . . .th& 4t4*flç4fL O
CW44aM , a*d h. q ..taat d #eA.anc . 4A. 44* . CA .s tt uwoLu.4 a ..k. . t i i
• ii.i...t hg g.td .u . 44. .tLLaa.fl 0 , 1. OUt pat.t.
2 would a tgcL .gt* 2Lc.4.Uhtq cap .a. . th. ) .tg t £jwttin.wz.t.e4.
2 pjc.t St . aa*p2 •iz k. PW . ..t.n Cenpsn4 ‘4 p4. iO..mL a.. weU s..
u4th4.e Ie.potta . &eca auL:’Le.
92—1
Owners and Operators of the Deer island -- Eastport and Deer island -- Campobello Car Ferries
-------
..OUIlitdfCIdI $ UWdI
Charter Service
EAST COAST FERRIES LTD.
DEER ISLAND, NEW BRUNSWICK, CANADA
Cip (m 4 a Lgh t 4 weLL 4Imce2ued k k. 2 L.nd cuauMI W* b rn m
Ds t hew 8 wi..wLcL
92—2
U44 4 1/ C ! t’-L,
—
kle.Lck IU*44aL £LMa4
Response:
Co ents noted.
See FEIS Vol. II p. IV—23ff,
X—26ff.
Ow,icn and Operators of the Deer Island - Eaziport and Deer Island - Campobeilo Car Ferries
-------
P. 0. Jox, A,
l1sworth, t:aine, 6O5
Oct. 26, 1976,
New ng1and ivision,
U. 3. Army Corps of Ligine rs,
t’24 Trapelo Road,
Waltham, Massachusetts, 0215k’
Gentlemen:
I write you, that we are opposed to the proposed refinery in E astport Laine
by the Pittston Co.
I have written several letters to various hoards and or nz ticns regarding
one important question and as yet to receive an answer. The question is, just
wtiat effect will a vessel as long as a super tanker, drawing 50 to 60 feet of
water, and displacing the water in its passage have on the control of the ship
in the tricky currents of Head Harbor, especially. The displaced water after
the passage has to rush in to fill the void created by the displacement, just
what will this do as to the control of the ship plus the unknown currents
that are even in action at full tide. The fact that there are so many whirlpools
around the area proves to me that the bottom of the passage must have
a very irregular bottom to create such an action.
The ape Cod Canal, before the U. S. Army ngineers took charge was
always a hazard, and. vessels of a limited draft were allowed use of the Canal.
I can full well remember the washing away of .nks along the canal by the rush
of water to fill the void of the ships displacement of said water.
Z OCT 976
There are many other factors that make the use of .astport as a Port
of entry for oil unwise and dangerous and you are ju t as we’l aware of them all
as I am, therfore will not write further on these.
93-1
-------
2
Oil spills will be made regardless of all safeguards, Fasport, though
has tides and currents that will make in nearly impossible to contain them,
The oil spills that are not contained threaten the lively hood of many
more people than the refinery wou].d empB,. My chief worry is not so much
for Fastport itself but for the thousands who obtain their living from the sea
and also those who enjoy the beauty of the sea.
Y ur5.. truly,
.\ ‘ 1 j c
.4mund ( • Latham
--
Response to Coiiments by E.H. Lathain
Comments noted.
The effect of
a VLCC and the associated displacement of water during transit should be minimal
because of the channel characteristics and the slow transit of the VLCCs. The
VLCC movenEnts will be made known to all boats that utilize the channel
Also see FEIS, Vol. II, p. IV—2lff, and p. IV—40 ff.
93—2
-------
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94—5
-------
Re ponse to Co!mnents by S. McDugald
Conments noted.
The proposed channel, Head Harbor Passage, is a wide channel £ or tankers of the
VLCC class and even wider for vessels of considerable less draft such as fishing
vessels. There will be adequate notice before the time of tanker passage through
the channel. Tankers in transit prot ad at very low speed, and fishing boats
would have ample time, if needed, to alter their course. If a fishing boat or
other vessel is disabled in the passage, this information would be known by the
harbor authorities. In the event a boat is disabled and the fact is not recog—
nized until the tanker is in transit, the tanker will reduce its speed and if
necessary, one of the tugs accompanying the tanker would come to the disabled
boat’s assistance. FuTtberi)o e, It should be noted that the Coaét Guard will.
regulate tanker traffic.
The navigation aids discussed in the Tanker Operation and Marine Transport
system section of the EIS together with tug assistance and other aids minimize
the possibility of tanker groundings. Explosions in tankers occur very rarely.
The scouring operations are done at sea, and will not take place while the
tankers are entering or leaving Eastport. To prevent these explosions, tankers
are being equipped so that inert gas is used to fill the compartment vapor space
instead of air.
Also see PEIS Vol. II, p. VI—28 ff, p. X—26 ff, p. X—9, p. IV—53 £1.
94—6
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VOLUME IV
RESPONSE TO OTENTS
PART B
FINAL
ENVIRONMENTAL If PACT STATEENT
PROPOSED ISSUANCE OF FEDERAL
PERMITS TO
THE PlTTSTON COMPANY OF NEW YORK
FOR THE CONSTRUCTION OF A
250,000 BARREL/DAY OlL REFINERY
AND MARINE TERMINAL—EASTPORTJ MAINE
PREPARED BY:
U,S, ENVIRONMENTAL PROTECTION AGENCY
REGION L BOSTON, MA 02203
-------
Volume IV contains responses to comeents on the DZIS received fron
Federal., State and local agencies and from the public sector. Due to
the large number of comeents, this volume has been divided into two parts.
Part A contains those c ents from Y.dera]., State, and local aganciea
as well as coma nts from the public sector that require specific response..
All co* . ts are answered either in a block on the appropriate letter or
on separate pages iisdiately folloving the letter. In addition, text
changes have also been made in Volume II of the FEIS, particularly in the
areas of socio—econoaics, air resources, and marine biology/oil spills.
Also, Volume II contains a n i Chapter X which includes responses to the
most characteristic c ents that were received. Consequently, the first
part of this volume includes a response index which assigns a ccmaent/
response n er as well as indicates where in Volume II Information can be
found with respect to a given agency’s or individual’s c ants. All pages
in this volume are ni ered in a format which indicates the comaant/
response number For example, p. 5—1]. would be the eleventh page under
col!nent/response 5.
The index also includes a key to the type of c snts received, as
follows:
SE — Socio—Economic
NE — Marine Ecology
PR — Fisheries Resources
RN — Hydrography and Navigation
AR — Air Resources
A — Alternatives
0 -Other
Part B contains comaents received from the public sector that tend to
express general opinions on the project and therefore require no specific
response. The first section of Part B includes an index of c ents with
numbers designed in a similar- fashion as in Part A.
I
-------
Index of Reeponsea
3. R.P. Eiden. U.S. Coast
Guard
A: Xa12
HN: VI—36, X-26tt, 11—5,
IV—38
SE: Vt- .Jtt, x—i3ff
0: 111—50) 111—52, IV—53 ,
VI —29
ME: W- 3, VI—38, VI-59,
X —23 .
AR: VI —73
2. S.R. Galler. U.S. Dept.
of C erce
- ME: 11140, IX-38 , XI—38,
X—5, VI —59 VI- .38ff
0: X *9, 111—166
SE: VI- tf
PR: 111—87, VI —28ff
MN: X —26ft.
A: X—JI2tt
10. A.W. DiSilvestre. U.S.
Sec. of the Treaaur!z1
0: Cosnt noted
11. LI. chais, U.S. ICC
SE: X—l’I
12. C.8. Buçbanon. U.S. MUD,
Region I
: VI 1ZItt , X—6fr
33. M.D. Woon .U .S. Fish &
Wild3ite ervice
J : Cou .nt noted
1 $. 5.3. Doreinuek U.S. Dept.
of Interior
T 77 2ff
ME: VI—38tf, VI —28ff,
VI—59tf
0: X—35, X—kl, X—35
3, W.G. Gordon, U.S. Nat.
Marine Fisheries Serv .
NE: Co ent noted.
F.3.M. Hodsoll U.S. Dept.
of Cousterce -
0: Co ussnt noted
15. D.R. King U.S. Dept.
of State
0: Comment noted
16. K. Janitz , U.S. Dept.
of State
0: Comment noted
9. LW.
ye it
ME:
UN:
AR:
Stevens, Roose —
Campobe].].o IPC
IV—38
VI- .36
VI—91, VI—78, vI—63,
vi—6 s, X—31
X—e?rr
VI—36, X—26ff
IV—38rr, x—5rr, VI—38ff
VI—iff, X—3
1—3
18..R. Garver, J. Chandler
Corps of Eñ ginéex’e
ME: VI —38ff, IV—38ff,
X—5ff
RN: VI—36, X—26ff
SE: X—lk, vI—irr
0 : X— $1, III—159ft
19. J.D. McDermott, Advisory
Council on Historic Preservation
0 : X l$1 --
5. 0. Liii . Nati. Ocean Survey
MN: Xu .31
6.
7.
8.
17. S. Jeliinek , Council on
Envii’onmenta1 a1ity
R.E.
Philpott U.S.
PEA
0:
Conmmnt noted
J.L.
Reed,, U.S. PEA
0:
Comment noted
R.W.
Mitchell , U.S.
FEA
0:
IV —lff
A
MN:
ME:.
SE:
0:
VI—59ft,
ii
-------
20. Pass rnaquoddy Tribe , 32. J. Boone, Town of
Perry Andrews, N.B .
SE: —1ff, IV—lff, SE: Comment noted
111-159
33. R.J. Ryan, Calais Econ .
21. M.F. Marsha Maine Deft. Development Board
of Inland isheries SE: Comment nObed
Wildlife
ME: Comment noted 34. A. Bates, Calais Econ.
Development Board. .
22. Maine Land & Water SE: Comment not A
I esources Council
o : X—47 35. E.G. McKeon, Bangor
SE: VI—lO, X2ff, VIl4ff, Dept. of Development
I-7ff, VI-l8ff, VI-24fr, SE: Comment noted
X—13, VI-].lff
0 : 111—159, X—1O, VI—20, X—10
RN: X—26ff
A : X—42ff 36. F.M. More].l, S.Port1an
23. R.A. Gitfen Maine State _______________________
Planning Ofhce lIE
S
0 : 111— 1 66 SE: X—2, VI —2
ME: VI—28tr, IV —38fr
21$. M. Barnes, Eastport
City CouncIl 37. A.J. West 1 Cobscook Ba
SE: Comment noted Laboratory, Boston
ME: VI—28ff, VI—59rf
25. E. Baxter, Eastport
Planning Board 38, K, Good, Dennysvjlje , ME
SE: Comment noted ________________________
AR: VI—75ff
26. 8. Blanch Eastport
___________________ ME: IV—38fr
Planning hoard
SE: Conunent noted 39. J.E. Chappe? , North-
eastern Univ. 1 Boston
27. W. Harding, Eastport 0: 111—159
Police Dept . MN: X—26ff
SE: Comment noted ME: IV—38fr, VI—25
_________________ SE: VI —iff, X—2ff
28. R. Flagg, Eastport
Fire Dept .
SE: Comment noted 40. R.G. Wolfe, Terre Haute ,
IN
29. M. Conti, Eastport ME: VI—28rr
Fire Dept. 0: 111—159, X l$9
SE: Comment noted AR: VI—62rf
30. R. Maholland, Eastport 1 $l. p.s. Mathews, Alleton, p
Law Enforcement
SE: Comment j ted
0: IV—2
SE: VI—2tf , X—2ff
31. E.J. Barnes, Office
of Town Ngr., Lubec
SE: Comment noted
iii
-------
112. A&E. Webb 1 Wint rport 1 ME
SE: IV..53ft, X-9
AR: VI—78ff
113, D. Walker, Sunbury Shores
Arts & Nature Center
ME: IV—38ff
AR: VI—78ff
1111. M. Hodgina Trescott, ME
AR: VI—78tf
RN: IV—23ff, X—26fr
115. C. Sunde Trescott , ME
AR: VI—7 tf, IV—6orr ,
X..37
116. 3 . Lehigh, Colby College,
Watervifle
SE: X—1l, VI—2Q
ME ’ IV—38’
1I7, D. Hodgina, Eastport. ME
AR: VI—78ft, VI—62tf
148. D. Dowley, Quoddy Bay
Fish CoOp, Eaitport
0: See comments by
M. McGleannon in
Vol. IV
119 ’ C. Herter Council of
Maine
A: X—112ff
ME: IV—3’Bfr, VI—38ff,
VI—28ff
HN: X—26ff
0: 111—159, 111—166
SE: VI—].ff, X—3, VI—l8ff,
VI—iZIff, VI—22
50. A MacKay, Rep. Bay of
Fundy Weir Fisherman’s
Association
ME: VI—28ff, X-lSff,
X-.23ff, see response
by Dr. Edward Gel—
fillan, consulting
oceanographer
51. h Dorchester Lubec. ME
0: Coxi ent noted
52. CA. Lewis For the
Love of Eaatport
ME: IV—3Btt, III—iO7tf
0: 111—69, IV—53tt
RN: X—26tt
SE: V—i, TI—lift, X—9
AR: VI —22ff
53. P. Olasaer Ur iv. of Maine
FR: 111—87
RN: X-26tt
AR: VI—9lff,
0: IV—52
ME: IV—38ff, VI—28rr
A: X 1$2ff
511.
R,
Jones, Eastport , ME
SE:
VI—20, X—lO, IV —53 ,
X- 9
AR:
VI—62ff
0:
III—159ff
J.
Strogen, Lubec
ME
AR:
VI—T8ff
56. S.IC. Katona, College
of the Atlantic 1 ME
FR: 111—81
0: 111—159
ME: VI—28ft, VI—56ff,
III— lO9tt
57. H. Stence , Lubec , ME
AR: VI—78ff
0: X 119
SE: VI—ifT, VI—liff
ME: VI—28ft
58. E.&R. Coakley , W. Pem-
broke, ME
ME: VI —38ft, VI —28ff
SE: VI—iff
HN: IV—23tf, X—26tf
0: 111—159
IV—6off, X—37
55.
iv
-------
59. J.E. Sullivan. Kearney
68. A. Rut fman, Haiitax .
NJ
AR: VI—78
60. G. Fatula. Cherry Lane
Farm. ME
SE: Comments noted
61. RL. Dow 1 Augusta 1 ME
ME: VI—28ft, IV—38ff ,
VI—38ff, VI—53ff
AR: X —3lff
FR: X—24ff
0: III—159ff
HN: X —26ff
SE: VI—9
62. R.T. Stagg. Setauket ,
NY
0: 159ff
63. J.A. Donaghy. Lubec 1 ME
ME: VI—29ff ’
0: III—159ff, X— 1 47
FR: X—24
SE: VI— ff
6 . G.B. Carter. Calais 1
ME
0: IV—lff, III—159ft,
VI—27ft
SE: VI—2tf, VI—lff, VI—9
ME: VI—59ft, VI—29ff
MN: VI—36
6 . L. Elerin. Eastport ,
ME
0: III—159ff
ME: IV—38ff
66. J. Rier Lubec, ME
SE: VI—29ff
67. J. Sassainan, Sanford ,
ME
0: X— 49, X— I7, III—159ff,
IV—1 f I ’
HN: VI—36, X—26f1’
SE: VI—20, X—11
N.S .
MN: X—26ft
ME: VI—28ff
69. MM, Boyer, Boston, .
MA
ME: vi —28ff, IV—38ff
0: V—lift
70. 1. Stagg, Port Jefferson,
New York
SE: IV—45, 111—19, X—9
0: Vol. III, A—5lff
ME: VI—Z8 .ff
71. J.H. HutchisOflIL
Eastport. ME
SE: IV— 3ff, X—9
HN: 111—36, X—26ff
AR: vI—78ff
72. B. Cecirr , Eastport, .
ME
MN: X—26ff
73. M. Otis, Perry, ME
SE: 111—20, X—1]
74. JH. Buehner , . Lubec
ME
ME: VI—28ft, 1X—38ff
SE: X—5
75. J.P. Grady, Eastport ,
ME
MN: IX—23fT, X—26ff
ME: VI—59ff
76. R.J. Smith, Camden ,
ME
0: iII—159ff ’
V
-------
77. P.A, Euatj II. Sec . 87. S. Lambez’t . Deep Ie1an
Plan. Bd.. Isle au N.B. Canada
Haut 1 ME HN: VI—36, X—26ff
ME: VI —28ff, IV-.38fr ME: VI 28rr
A: X-42ff
0: IV—irr 88. M.B. Myers Eaatpop
ME
78. G. Lehigh 1 Eaatpopt , 0: III—159rr
ME SE: IV 53fr, X—
: VI—22, Vi —ilirr
89. W.H. Drury 1 Bar Harboz
79. M.J. Cohen 1 Lubec 1 ME ME
ME: VI—28rf : VI —28fr, IX—38f
0: X—i4 ]. SE: VI-Ji, VI—5
80, LA. Lewis 1 Eaatport , 90. D , Pike Lube ME
ME AR: VI-. 2ff
SE: VI—].
9].. . Transport Canad
8i. R. Klyvep 1 Eastpo ’t Canada
ME ME: VI —38fr, III—3lft,
MN: X—26rr, VI—36 III—iott, IV_38rr,
___________________ IV—28, VI 28
82. R. Molyneaux. Nat]. . AR: VI—62, III—].2 1 $ft
Parka & Conservation MN: IX—23rr
Association SE: VI— lfr
0: X—17 — A: X— 2ff
A: V—l2ff
AR: VI —62ff 92. L. Dale Sarteau 1 Deer
ME: VI—59rr Island, N.B. Canad
RN: X—26fr RN: IV—23rr, X—26rf
83. K. Larson, E. Machjas , 93. ! JI. Lathain, EllSwOpth,
ME ___________
: VI —28rr i: IV—27fr, IV—38ff
____________________ 9 l. S. MODURO1d, Eastport 1 ME
8 . B. Cunningh , Linco1 i : X—2 tf
ME: VT-28fr
ME: IV—38fr
SE: X—5
85. S. Bahrt, Pembroke 1
ME
SE: IV —53ff, X—9
86. S. Riggs, Rob1 so ,
ME
SE: X—5
vi
-------
Source
No. Name or Affiliation
Issues Raised
s ME
PR. IH IAR [ A 1
-
The response to
all
the following
was “Convnent
noted .
— I —— —
— — — —
—
I
95 8. Barnes, Eastport, ME
96 P.P. Thornton, Neil, Inc. Scarborough, ME
97 fLU. & N.E. Clement, Eaatport, ME
98 fJ.G. Haynes, Assoc. Gen. Contractors, Augusta, N
99 W.L. Wilson, Calais, ME
100 1W.L Flagg, Furniture, Eastport, ME
101 G. Jackson, isangor, ME
102 L.V. Smith, Jonesport, NE
103 S.C. Shaw, WiUis ton, VT
104 3. McGrath, & L. Levesqua, Statler Tissue,
Augusta, NE
105 T.M. Armstrong, Biddeford, ME
106 E.W. Thurlow, Cent. Me. Power Co., Augusta, ME
107 B.C. Brill, Lincoinville Telephone Co., ME
108 v.a. Rupert, Blue Bill, ME
109 H.L. Vose, Kaatport, ME
110 M.L.& C.M. Small, Eastport, ME
111 K. Cline, Eastport, ME
112 3.1’. Jaffray, Jr. Pittsfield, ME
113 J.K. Keefe, Econ. Res. Assoc., Waterville, ME
114 J.P. Kelley, Jr., Rotary Club, Calais, ME
115 A.L. Moore, Waterville Savings Bank, Me
116 E.M. Holmes, Winterport, NE
117 .. f.P. Foley, Eastport, ME
118 C. Peters, Jr., Eastport Water Co., ME
119 1M.P. Norton, Yarmouth, ME
120 fN. Davis, Fredericton, N.E.
121 IM.C. Wells, Jr., Assoc. Industries of N*4ne ,
Augusta, ME
122 !L.B. Hoxie, Eastport, ME
123 R.S. Jones, Eastport, ME
124 R.M. Stolkner, Insurance Rep., Bangor, NE
125 ‘L.M. Throckmorton, Cutler, ME
126 J.G. Dudle, Alexander, ME
127 C. Weeks, Eliot, ME
128 ‘H. Stence, Lubec, ME
129 Mr. & Mrs. A. Townsend, Sr., Eastport, ME
fl 3 O N. Taylor, Eastport, ME
131 G. Ganong, Pembroke, ME
G.L. Cole, Cole Express, Bangor, ME
133 ,R.W. Lyon, Eastport, 1E
l34 L.W. Gueters].oh, Pine Plaines, Ne. York
l35 J. Collins, Eastport, ME -
I
I
x
I
I
x
i
x
x
x
x
x
x
x
I
x
x
x
I
x
I
x
I
I
vii
-------
Item
tie.
Source
Name or MfL1iatio
SE
Isi
use
Raised
—
136 A.M. Roth 1 University of New Brtmsvjck, Prsder- X X X
icton, N,3.
137 C. Severs, Trescott, Maine x x
138 IF.P. Jones, Lubec, 1€ x x x x
139 C. Goddard, Eastport, tIE X X X
140 ‘Mr. Donaghy, Lubec, ME I I I X
141 R. Roes, Superintendnet of Schools, Easport, HF X
142 J. Dorchester, Crows Neck, ME I I I 1 1
143 E.P. Kroonenberger, Brookline, M&
144 A.J. Haug, Eastport, ME I
145 N. Sunde, Lubac, ME X I
146 A. Harris, Cândidate for Council, Eaatport,ME I
147 Dr. ti. Eda, Stevens Inst. of Tech., Hoboken, N.J
148 D.P. Hoult, M.I.T., C ridgs, M& X
149 B. Gilfillan, Bidgelov Laboratory for Ocean z x
Science. West Boothbay, ME
150 A.H. Penla.on, Rsp.Dist. 10, Mains st. Leg. I
151 J.C.Bates, Physician, Eastport, ME I
152 H. Richardson, Eastport tism. Hosp., Eastport, ME I
153 C. Marshall, Maine Maritime Academy, Castjns, HF I
154 W.C.Bullock, Jr., Merril Trust Co., Bangor, H! I
155 V. Thomas, Canal National Bank, Sàuth Freeport,H I
156 N. Cohen., Coy. Ezec. Council, Eaatport, HE I
157 Capt. D. Kennedy, VLCC Pilot, Belfast, ME
158 P. Merril, Herri]. Transport Co., Portland, ME I
159 C.M. Neil 7 , Economic Resources Council of Maine I
160 H. Loring, Construction & Bldg. Trades Council. I
161 R.R.Reny/p.C. Emerson, Maine State Chamber of I
Comeerce, Portland, ME
162 B. Cram, Natioanj. Executive Reserve, Bangor, ME X
163 N. Davis, ilachiasport, ME I
164 1 Dr. J. Comejto, U. of Maine, Machias, ME I I
165 W. Yerxa, Sam.Ely Corn. Services, Inc., South I I
Princeton, ii
166 C.C. Arsenault, Eastport Mae. RoBp., Eastport, HI I
167 if. C. Welles, Jr. Assoc. md. of ME, Eastport, NE X
168 R.N. Haskell, Bangor Hydro—Elec Co., Bangor, ME I
169 A.M. Johnson, The Action Committee of 50, Bangor I
170 W.}f. Haselton, Depositors Trust Co., Augusta, ME I
171 H. Hodgins, Lubec, iIE X I X
172 R.M. Smith, Bath Iron Works Corp., Bath, ME X
173 I.NcConchie , Owls Head, ME I
174 B.L. Peters, Maine Central U Co., Portland, tIE
175 L.V. Smith, Pres. Wash. Co. Chamber of Coneterce, X
Jonesport, 1E
I
viii.
-------
Item
No.
.
Source
Name or Affiliation
Issues Raised
—
SE MEI
FR li+N
AR
A
0.
176 D. Bradshaw, Deensyville, ME X X
177 B.J. Smith, Camden, ME x x
178 R.R. Keezer, Eastport, ME
179 L. Conti, & Co—signets, Eastport, ME
180 H.S. Stanton, Cuilford Industries, Eastport, ME X
181 D.F. Turner, l4earl Corp., Eaatport, HE
182 A.P. Nay, Pembroke, ME X X X
183 M. Conti, Eaatport, HE
184 P. Leighton, Eastport, ME
185 CM. Small, Eastport, ME X
186 R. Emery, Eastport, ME
187 D.L. Brooks, Friends of Intelligent Land Use,
Ketmebunkport, ME
188 D. Cohen, Lubec, ME X X
189 E. Blackmore, Pres. Maine Lobsterman’s Assoc.,
Stonlngton, ME X
190 F. Trocco, Lubec, ME I X I
191 K.J. Leighton, Eastport, ME
192 B. Lehigh, Eastport, NE
193 B. Nagusky—Trocco, Lubec, ME X
194 R.J. Shinners, Great Northern Paper, Millinocket X
195 J.E. Chappel, Northeastern Univ., Boston, HE
196 Comment No. 265
197 Doc and H. Hodgins, Trescott, ME X
198 R.& D.Csenge, Perry, ME X X
199 M.M. Kearney, New Sharon, ME
200 Comment No. 270
201 IM. Standen, Eastport, ME X
202 1 B. Esler, Foxeraft, HE
203 P. Robinson, Brooksville, ME
204 ‘. & H. Birdsall, Blue Hill, ME X X
205 R.S. Jones, Eastport, ME
206 R.L. Grindal, Bangor, ME
207 C.W. Brown, Monson, lIE
208 I.J. Donaghy, Lubec, ME X X
209 E.E. Brown, Monson, HE
210 I.E. Chappell, Jr. Northeastern Univ., Boston,MA
211 .L. Holmes, Machias, ME X
212 .1. Holmes, Eastport, NE X
213 .A. Hofferman, Eastport, ME
214 1.M. Hefferman, Eastport, ME
215 L Kent, Co—signers, Monmouth, ME X X X
216 T.A. Donaghy, Lubec, ME
217 i.G. Lehigh, Eastport, lIE
218 i.H. Smith, Pembroke, ME
219 LB. Norton, HarborniaSter, Jonesport, ME X X
220 ‘.E. Herrill, Merrill Transport Co., Portland,HE X
lx
-------
Ite m
No.
Source
Name or Aff41( tjon
Issue. Rais.d
221 . luff, Pree., Wshington Co. Ch er of Cow., X
Calias, ME
222 A. Bell, Township of Edmond—Wash. Co., ME X X
223 R. Merrill, Lubec, ME I I I
224 R.J. Peacock, Sun Oil, Lubec, ME
223 R.s. Peacock, Pres. U. Peacock Ca”n4ng, Lub.c I
226 1. Otis, Perry, ME x x
227 . Good, W.C.C. Manufacturer, Dsnnsyvjlle, 1€ I I I
228 4.B. Pike, Homes Packing Co.., Eastport, ME I I I
229 Ir. Alvard, Lincoln, ME x x
230 C. Croata, Bus. Rap. I.ocal #4 - O.E., ME I
231 R. Conti, Eastport, ME x
232 (.c. Morrison, Perry, ME X x x
233 ;. Davis, Eaaport, ME I
234 It. Cooke, Esatport, ME I
235 r. Er 4an I I X
236 t.c. Mah n,- Calaia C2i. .r of Cosrce, Calai.,Ml I
237 1. Leigh, Eastport, ME
238 fr. Reavey, Pa. samaquoddy Tidal Power Advocates I
239 It. Cuay, Eastport, ME
240 r. Xlyver, Eastpor’t, ME
241 Callahan, Eastport, tIE X
242 urrent , Shead Men.H.S., ME(Poll)
243 It. & Mrs. R. Jamieson,(Gaeta, Italy) Eastport,M]
244 ..Kiuney, Eastport, ME C X
245 .H. Blanch, Sentinel Insurance Agency, Eaatport I
246 . Cohen, Meeber, Gov. Exec. Council, Eastport I
24V . Mills, Representative, Eastport, ME
248 . Hajke, LB., canada X
249 etition I
250 ;.j. Cook, Washington County, ME
251 r. Unobekey, Unobskey’s Fashion Center, Calajs,ME I
252 alaió Lions Club, Calais, ME I
253 . ieezer, Federson Agency, Inc., Eastport, ME I
254 . Mitchell, Eastport Little League, Easport, ME
255 :. . Hauscom, Action Agency, Realtors, Machias,ME I
256 .j. King, The New England Council, Boston, M& I
257 r.L. Armstrong, Merrill Trust Co.,Lincoln, ME I
258 . Stagg, Port Jefferson, N.Y.
259 . Sitason, Eastport, ME
260 .B. Jackson, Honmouth, ME - I I
261 .j. Boone, St. Andrews, N.B., Canada I I
262 . Snyder, Whiting, NE I
263 .W. Brydon, Calais, ME X
264 . Grandmaison, Loch Union No. 545—SHWA, Lewisto C
65 . Sunde, Trescott, ME I
x
-------
It 1fl
No.
Source
Name or Affiliation
Issues Raised
SE 4E FR 11944 *1
A
0-
x
I
I
x
266
267
268
269
270
271
272
273
274
275
276
277
278
279
280
281
282
283
284
285
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305.
306
307
308
1309
1310
T.McDugald, Eastport, ME
P. Segien, Eastpozt, ME
V.C. Nickerson, Service Master of Maine, Inc.
Portland, ME
A. Harris, Peregrine Assoc., Eastport, ME
F.A. Brown, Brown & Tibbette, Caleis, ME
T.C. Naughton, New York, N.Y.
H. Spencer, East Rockaway, N.Y.
E.Fishbein, Eastport, ME
P. Trocco, Eastport, ME
N.J. Bradshaw, Dennsyvi]ie, ME
L. Szatkowski, Robbinston, ME
B.M. Shotweil, Kennebunkport, ME
S.B. Miller, Kennebimkport, ME
M. Speer, New York, N.Y.
H. Mullis, Cooper, NE
W. McGarvey, Noose Island, ME
H. Cohen, Trescott, ME
S.C. Levin, The Counseling Center, Bangor, ME
D. Cohen, Killington , VT
t.J. Cohen, Lubec, ME
B. F.. M. Mickevieg, Wilmington, MA
C. Aylward, Lincoln, ME
L.M. Healy, New York, N.Y.
M.D. Lathain, Ellsworth, ME
Mrs. P. Clukey, Vexted, ME
H.M. Merrill, Jr., Quoddy Bay Co—op, Inc. Lubec
C.S. Morrison, Perry, ME
E.B. Ebershaw, Hanover, N.H.
L.W. Guetersloh, Pine Plains, N.Y.
W.J. Armstrong, Wazvick, R.I.
Passamquocldy Tibe, Perry ME
D. Dowley, Quoddy Bay Fish Corp. ,ME
Mr. & Mrs. B. Dudley, Eastport
J.W. Anderson, ilarine Mannal Coin., Wash., D.C.
G.N. Ewing, Canadian Hydrographic Ser., Ottawa
Canada
R. Richardson, Deer IslaDd, ME
M. Majke, The N.B. Fed. of Naturalists, Canada
G.W. Barnes, Engineers, Topshant, ME
M.C. Casey, Bernardini Co., Calais, ME
J. Lowe, Eastport, ME
E.K . Warmell, Woodland, ME
J. Fouls, Eastport, UE
Mr. & Mrs. H. Dudley, Eastport, ME
R.L. Violette, Hascall & Hall, Inc., Portland,NE
S. Cainick, Eastport, F.
I
x
I
I
x
I
I
.1
x
I
I
I
I
I
I
I
I
x
I
I
I
x
x
I
I
I
I
I
I
I
I
I
r
I
I
I
I
x
x
I
I
I
x
x
x
x
x
x
I
xi
-------
—-
Item
No.
Source
Was. or
Isiues Raised
sE ‘i
—
—
r
—
ii+ii
—
—
u
—
—
A
—
—
o
311 w.c. FrsstOlt,Kennebunk, ME X
312 R.A. Dyer, III, Portland, ME
313 w.j. Weck, Cainbro Corp., Pittsfield, NE I
314 F.W. Frost, Ca].ais Federal Savings, ME
315 J. Wilson, Jr., Marietta Ceaent, S. Portland,ZIE I
316 c.V. Starbird, Starbird Li er, Strong, ME X
31.7 J.A. Saunders, Saunders Mfg. Co., WinthropME X
318 s.c. Noyas, S.C. Noyes Co., Rangeley, ME
319 H. Loachie & E. Leiuhoefer, Robinstco, ME I
320 A. Magee, St. Mdrewa Civil Trudt, LB., Canada
321 N. Conti, Eaatport, NE
xl i
-------
THE FOLLOWING COMMENTS HAVE BEEN RECEIVED AND NOTED
-------
>?ei ’1. ,‘ /776
/LCI v L/ 1 C&
C
7 d Z €’ f d
ha ”m i a/ I,v 0 d
4 ,X d
L4
d z ,n’ J V i
7L
95—1
-------
2A
_-i 4 a’- ’ 4—/
& €k4a4d t J’ °’ tva2Z L
Io-t 2Z w &ó - 0’
d d4; — ‘ ‘ ?(d/’
) 7 4j J ‘ 4 ) 44c) ( Qf4t1 34 /
ud4’ d 1 ç
L ) k O &/ai
J Az) dAdo 1 1
j e a’xd 2 , Pal/U
k flZ& ;1
2thX t /d”i 4/ ’ %A
_ 7 ôg ’ ,4 —z
rfl Lh ô
2 2
9 i
do t( W
p.
95—2
-------
a
L - )
-La4/ ztY
&4 1 >27
95—3
-------
o Thornton Neill Inc.
Rigby Road
Scarborough, Maine 04074
P.O. Box 8420 • Portland, Mcun. 04104
(207) 883-4323
November 22, 1976
Permits Branch, Enforcement Division
Environmental Protection Agency
kennedy Federal Building
Boston, Mass. 02203
Gentlemen:
I would like to take this opportunity to announce the
support of Thornton Neill, Inc. as one thousand percent
in favor of the Pittston Refinery at Eastport, Maine.
I am firmly convinced that this project would be of
great benefit to all the residents of the State of
Maine.
Very truly yours,
THORNTON NEILL I C.
Peter P. Thornton
President
PPT/pal
96—1
-------
L 9 Capen Avenue
Eastport, Ilaine
November 22, 1976
U.S. Environmental Protection Agency
Region 1
Boston, Ma. 02203
Gentlemen:
Please be advised that we heartily support the construction
of an oil refinery by the Pittston Company in Eastport, Maine.
We are both natives of Eastport and have seen our home town
go down bill during the past few years and feel that it it time
we had an industry that will help build it up to where it used to
be.
9 fg4 )
Robert W. Clement
Marion E. Clement
97—1
-------
cc: Mr. McGlennon 11/30/76
Wally Stlckney
ASSOCIATED GENE CONTRACTORS
INC.
P.O. BOX N AUGUSTA, MAINE 04330 TEL 622-4741
JERRY G. HAYNES, Ezcutlvs Dk.ctor
November 23, 1976
Mr. Richard Kepp].er
Environmental Protection Agency
Region I
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. Keppler:
I am vriting on behalf of the nearly two hundred and fifty members of the
Associated General Contractors of Maine to express their concerns as you
approach the December 3rd hearing date on the proposed Eaetport refinery
project.
Maine has a construction labor force of approximately 22 thousand. The
effects of the recession, coupled with a legislative moratorium on school
construction, has seen construction industry unemployment levels range from
10% to 20% through this year and last year. Currently, most construction
firms in the state are working below capacity. And much of the major work
is or a non-recurring nature, such as l O—year—life vastevater treatment aM
collection projects. Much of this work, both public and private, will be
winding down in 1977. Maine urgently needs a. continuing flow of construction
projects large and small if this major industry is to remain responsive to
state needs.
We are well aware of the environmental concerns surrounding the Esstport
project, but remain persuaded that new construction and operational, tech-
nologies are available to remove the major detrimental factors.
Coupling the foregoing factors with a possible, partial solution to Maine’s
geographic oil supply problem leads this association to a position of whole-
hearted support of the Eastport refinery project.
Please feel free to make this letter a part of the public proceedings on
December 3rd, and to call upon is at any time if we may be of further
assistance.
o s,
t / Jerry 0. Haynes
ecutive Director
98—1
-------
OFFICERS
P ..s,. h .nt
FRED A CLOIJOII. JR
B .. Casra .Ie Co.p
Vt.’ P esd.’nI
GALENL COLE
s E.p..ss Bang..
V ’ - 1 ’Ie .donl
WILLIAM B I4AGGETT
Iron Wad.. Corpo . ’aI,on. B .IK
Irs asu, . ’,
RONALOW WASHBURN
Vih. T, .nbe .Ia,th Inc Augusta
E .eculo D.IPCIO,
MERRILL C WELLES, JR
Oft.ce Manage.
PWZ.Y1 P4 5W /BY
DIRECYORS
DANNY B BARBATO
Sem.conducto, So P II .nl
ROBERT N BASS
G H Bass & Co W,IIon
DAVID P BICKNELL
B.rkn,’II Manolaclur.. Co Roclili nd
WILLIAM C BULLOCK. JR
U.w,,II Ba.*iIusos Co Ba..qo .
BFIINARDB ESIBY
I) Wa..,.n Co W . Ibeoo
ROSERTC. EAII 1RUI 1N
F In.’ Co W.,uns,IIe
JOHN T 0 (1 (110. JR
SI INg, . Paps. Co Bucksgo .t
LOB(N K IIUTCHINSOR
Snu II.*O .Ih MaCh. p . CO , PO .IIWId
PETER F KING
Cnn. ,, ’, R,.bg. . CO.npan . ‘.IWa. I lls
FREDE RICK W KNEELAND
Janus. Wye.an I Son. M.IIKIdg.
PAUl. K McCANN
G..ai N .slWnn Papsq Co
RI(HAROJ MOWN
Klr .n.bec J000WI , AugunI.
RICHARD A MORRELL
Orun arc CnuI A LWnbe. Co 8,uhSw.ck
LAuRA NAWFEL
I H Iha*,. C.r .W .1IP.V,II.
P ANIJRFWSNIXOH
Oco, P . ’. Cont ..ny B.loqOI
A J POLACKV/Y;H
‘.‘ .. .“rnone Corurwalran, Saco
ELRIN W IHURI OW
(rotral M ,.rup Powe .Co. Augusta
WALTERE 1RAWS
R ,’ , .t
ADVISORY COMMITTEE
ELBERT LI PRINCE Ch .,man
EMP SnIps Inc. FaImpuIR
GAl 1111 COlt
( 0 • u ” . IL,nCI ,W
ru I AI 1! II I OIISIFP
II ,‘ . .n S A r . ’.In.IK IL.,IIn ,VIC O .
RAYM,)Nt) A ( EI(iFEI
( I lIrn,
JOHN I UOULO JR
SI II,’q,s P . ’ .g . . Co R’ .rkspo .I
PAL P11 ISPICIWL ION
Cr . I ’,ttcI. pI .I
I II II
N .1 P,r.o.l , (:aonng Co. L,b .r
StIT. ’ W RUt I
° ‘It, ’ P.,rthc Cuspopaton Woodland
HUUIIC SALJNO€RS
Saunde,. U.n. We .Ib .o
Associated Industries of Maine
2 Central Plaza Augusta, Maine 04330 (207) 623-4568
November 24, 1976
Mr. A. F. Kaulakjs
The Pittston Company
380 Madison Avenue
New York, New York
Dear Corky:
The enclosed was sent to Mr. Xeppler
from Jerry Haynes of Associated General
Contractors of Maine per my request.
Sinc
ph
p
Merrill C. Welles, Jr.
Executive Director
Servini Maine Industry For Fifty-five Years
98—2
-------
ASSOCIATED GENER,6 L CONTRACTORS
‘I
“a’..,.,
‘/ -‘4’/.’
(‘ ; / 1 ;ç ?
1 INC.
P.O. BOX N AUGUSTA. MAINE 04330 TEL. 622.4741
JERRY G. HAYNES, Executive Okector
November 23, 1976
Mr. Richard Keppler
Environmental. Protection Agency
Region I
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Pear Hr. Keppler;
X am writing on behalf of the nearly two hundred and fifty members of the
Associated General Contractors of Maine to express their concerns as you
approach the December 3rd hearing date on the proposed Eestport refinery
project.
Maine has a construction labor force of approximately 22 thousand. The
efreets of the recession, coupled with a legislative moratorium on school
construction, has seen construction industry unemployment levels range from
io% to 20% through this year and last year. Currently, most construction
firms in the state are working below capacity. And much of the major work
is of a non—recuxTiflg nature, such as 0-year—lifc wastevater treatment and
collection projects. Much of this work, both public and private, will be
winding down in 1977. Maine urgently needs a continuing flow of coirtruetion
projects large and small if this major industry is to remain responsive to
state needs.
We are veil aware of the environmental concerns surrounding the Eastport
pr ct, but r rnain pers .w.ded that new construction and opcr t1cnal tech-
nologies are available to remove the major detrimental factors.
Coupling the foregoing factors with n possible, partini solution to Maine’s
geographic oil supply problem leads thJ ; zt: soe1ntLnn t.o a po ition of wholo—
hearted support of the Eastport ref incry projec 1.
Please feel free to make this letter a part of the public proceedings on
December 3rd, and to call upon us at any time if we may be of further
assistance.
Vi ltruly o 8,
,./ 7
//.Tv rry t;. Ilnynen
hxecutivc lii rector
98—3 -.
-------
‘o
4._
,4/,- • ; j ‘Yc
L
-
/ th
Qa
7t 3
/
C e VON
99—1
-------
FLAGG’S
Csi,auss4io 1573
FURNITURE
BEDDING - FLOOR COVEMNe - JUVENILE FURNITURE
TEL. 853-4262 EA51polty. MAINE 04531
Now, 23, 1976
U, S nvironsent Protection Agency
Region I Persit X io. 25.. 76 - 367
John 7. K.nn.dy flld.
Boston, Mu ,. 02203
G.nt l.ns
I would ilk, to go on reeord as favoring the construction of
th. proposed Pittston Oil Refinery, hers in Eutport.
For ser years we hews watched the fishing industry decline
our young psopi. leave for s loysent elsewhere, our hos
decay, and ow’ sidewalks det.riorats.
With the lang. increase in taxea the Cit7 would receive, it
could afford to rebuild it, streets and sidewalks, build parks
and beautify the city generally. With year..rousd enpic nt
people could restore their boa.,, l av . thefr property and
sak . it a sore attractive oosoity in which to liv..
A gigantic industry such as this would benefit all the surround-
11* area econoi icafly, and would boost the soral. of area
residents g eatiy, I believe,
Aa oimsr & proprietor of on. of the oldest business conoerne
in the City of Eaatport, I highly endors. the construction of
the proposed Pittston Oil Refinery.
V.r r tr1] r yours,
6- j/ 4 4f
4.
V. Ro iieoa ?lagg
RtZCE1V O
WRP/s
Q 4 . b 916
BRM9Ck
100—1
-------
(*0w ... 5 .7447
GLENN JAcKON
151 R 0ADWAY
RANGON. MAINt 04401
Permits Branch, Enforcement Division November 24, 1976
Environmental Protection Agency
Kennedy Federal Building
Boston, Mass 02203
Dear Sirs:
I support the construction of an oil refinery to be built in the
Eastport, Maine area, as soon as possible without any undue bureaucratic
delays.
The price of the Alaskian pipeline tripled while all of the
environmentalists fooled around for four years trying to block it. Lets
not let this happen here in the State of Maine.
GJ - dd
101—1
-------
Joneaport, Maine
21 . iioventber 1976
U. S. Environment Protection Agency
John F. k ennedy Building
508t0n, Mass. 02203
Gentlemen: Re: egion I Permit No. 2 -76-367.
I would like to urge approval for the Pittston Company to
ereot an oil refinery at astport, Maine.
The im act on t ie Eastern area of Washington Couflty s economy
luring the construction period, and the operation of this
refinery would be comparable to the rain showers in a desert,
due to the high unemployment rate in the area, especially due
to the loss of the many sardine canneries over a period of
years when Aa8t ort was t.ne ardine apitol of the World, and
i 0 ING iaa come here uo replace this loss which has had an
enormous effect on the economy.
it was due to ti40 favorable location of ast ort, it’s deep
water harbors and the plentiful sup ly of herring that at one
time made this area very A roa erous, but now conditions have
cnan,ed, and no longer is tnis city in the Saforable area of
the herring sujj4y, but it does have the same favorable deep
water harbors that can be used for oil tankers. Eastport is
oa able of having a large industry, and it’s resources,
especially the mighty d3ep Atlantic ocean that surrounds this
island city should no be left to slumber in it’s idle state,
but used o it’s fulle t capacities to help make several thousand
human beings klapFier as they would be able to earn a good
livliehood, ed cate their children and maintain a strong and
healthy society so much needed in these days.
Gentlen n, we have just been through the presidential campaign
and have listened to the many statements concerning the high
unemployment in this country, the lagging economy etc. Now we
nave an op , ortunit right here to help bolster this economy, also
to bring ,rodLcta th it is so much needed, and to give us the
opportunity to rely more on our own, mather than foreign products.
.tleaae, let’s get on with this rojeot and help make this country
edolLomioal ly healthier, eople haA pier, and our country stronger.
I am a retired banker with over forty years experience in this
art of the country, past president of the Wash. County hamber
of and the Wash. Couiity . oonomic ev. Corp., which I
feel gives me a pretty good i4ea of tht, •oono nic condition here.
V. ily y ry 2 I)..
102—1
-------
j o
. (hirman, e r.bers of the o jd ‘,f ...hviro ental Prot.ation ! ty n se
is La rcnce /. smith, I lie at ionesport Maine. I an a retired banker
wit . over Zi O ye w ex .. erience, ost of it in Was Maine.
I am past ‘esident of the jn tcn ounty Cnaitber - . f ec r,roe, st
president f the t r. otnty Soonoric Develo , rnen .orpora . oz . I
believe r y association w t. t.. e ec le in tLie area ns given .iie a pretty
good doa us o t: e oondit..on of ti e here, n d ontle ien, I believe
o .r eoonom7 is in a stats of consti ation j
eor exas,1e— it is liko a 3m .al]. boy i..tho is cons tipnted nd wort’ let his
mother give hiri t... necessary laxative to reli ie r is con. -c ’ , a d
tL e oes on his cond on wordona and could lead to o. C ic .cr s.
There is held for o r cons;., ted c nd .tion, we need not ; t r .i
. ne. iojment rste, beoa..se t..e edi ne is av !1atlo, & z a; . al rao .rco
to be developed by the . tttston ‘ onpw 7 r s the c.re w&i;th t s . the
deep waters of t. e Atlztio cean to float t. .e tankers as t e 1 bring
CrL4e oil to t4 e refiner).
aat , ort is capable of havinG ao.. et .i: big as it is one of the few 5 oti
on the i’tla.ntic coast v .tn deep :ater hnrbors, it was ones the sqMin.
ca4tol of the world, but n i t u t is .tstor7.
.ntl.& n, I ‘gs tn a roval of ti . iittaton’s a lication to erect an
oil refiner 1 in ...a8t ort— ‘do need the on lo inent— me need ll e oil and
be b rod c te to help nak. us a strong, tree inde eadent iation. Je ...at
have a bealtl y ecoz.omy, we m st have ener to iXI C .
C’jLJ , HJN J L, U ..LO (A ? CPLE i C2 1 A)D .IUC1i 1’... - iILC:. - i? C? 2&IY
. d ( z; 2 t A IOU, Li .V. rA A )VA ’2AGi C? J
L ICAI qiAL Jii*.. LLJ i•iA P k J.... r ; i i
FR .. S zrE : cciri .u. . JG .:L;2Io ., 1’ t •) • .2fi ZLL In
1i AS ’i , iN i iLL I.. Li . iUi .t £ .:i .....
Th6re is no need t or a 44 h u.ne:4ioyment coz i;ion here i.: this ur. — Let
us get on with the job while tiere is still an O ort .xiity.
102—2
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CL!
OV W. Oak Hill Rd.
Will.iaton, Vt.
Octousr 3 ), 1976
Wallace Stickn.y
U.S. nviroranantal Protection Agency
Boston, flees. 02203
tsar Sir,
I have an oninion on the Pittston’ ‘a propose]. to construct a refin—
•ry on Cobscook Bay in Kastport, Maine ch would like to share with you in
hopes that per’ith ’.ion will not be granted for them to proceed.Mth construction.
I was a follower of the nroceedings of Pittston’s initial apolication with
the Maine flspartment of nvi.ronmentsl Protection two tears ago and witnessed
with incre. ing disgust their m.r conflicting statements and studies contradic-
ting their owii çrofe sional researcher’s findings as to the auitaoil.ity of the
1 o d Head area for an oil receiving, r.tining, and transport capacity. It
was quite obvious to ie at that time tnat Pittston would stoop to no dece tiv
limit to pressure the i oard of Environmental Protection to aprnove them. Bei
sensitive to the economic needs of the conmaumity and their dual role of ropre-
aentativee to th. public interest (which seems to be largely defined oy’ .r big
industry’s interest in a certain coseminity) as well as environmental guardians,
it is isey to iii Ui BJ.P. elected to pass the refinery conditionally,
dsp.iwllng on Canada’s prohiuition of oil trónsport through Head Harbour Psseag•
to r.li.v. them of the responsibility for turning Pittston’s outrageous proposal
down. At that time, Pittston acknowledged that the condition, effectively pre-
cluded operation of the refinery.
To knowledge, none of the B.E.?.’s conditions nor Canada’s restriction.
have been repealed or withdrawn. Mor has Pittston indicated how they plan to
operat . in compliance with thee. r.gulationa. (Are they going to construct a
landing strip f or 200,000 ton flying oil aupsrtankars’?) This would suggest that
Pittston’s applieation to the Ars r Corps of Engineers for a construction permit
is another attnmpt to muscle in on Maine’s high nvironmenta1 standard. &y rqtro—
actively forcing public acceptance of operation of an .ztsting blight on the
theory that once it is given a Corps of rngineere go—ahead, public opposition
will thdndlm in helplessness.
To v ., this type of high-level public swindling ha. got to b headsd off at
every possible crossroads. This is wher you confront than now. Please demon—
strate the responstoility and integrity of the nvironnental Protection Agency
and the Ars y Corps of gineers by seeing that Pittston has viable and not
environmentally d.triaental means of complying with Mains’s H.LP. conditions
before allowing them to proceed.
It is my feeling that sualler, laaor—int.naivs industries would better oen—
efit th. township of aetport and surrounding coewmnities in the long run, with-
out inteifering, as woule the Pittston rofinery, witP mar.y of the citisen’s pres-
ent mm ii i. cf liviihood nor precluding controlled, carefuliy planned, compatible
.conorir development. Please preserve for astport this fre Coe of choice.
312
3 .117 C. 3
103—1
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5T*TLC Tissue COMPANY - P. 0. eox 587 AUQUSTA .MASNe 04330 TCLCPMONE AREA Cobe 207 623-473 1
November 24, 1976
Mr. Richard Keppler
Region One
Environmental Protection Agency
JFK Building
Boston, Mass. 02203
Dear Mr. Keppler:
Although some of the furor has diminished, the energy
crisis is still with us. Moreover, in spite of energy
conservation programs both in the homes and within
industries, the petroleum situation in the State of
Maine continues to become more costly and in tight
supply as time goes on particularly as we approach the
winter months.
Therefore, it behooves us in the New England States to
make every possible effort that will insure a continuing
supply of oil to meet our requirements at a reasonable
cost. This is extremely important to industries in our
northern region in order to maintain its competitive
edge in today’s markets and insure a good employment
situation for the people in our area.
We urge you to favorably consider the oil refinery pro-
posal at Eastport by the Pittston Company because of its
economic and social benefits to the State of Maine. It
is believed that such an activity would greatly benefit
both residents and industries in this region in the years
to come.
Needless to say, full time operation at our plant is
extremely vital to the economy of Augusta and the central
Maine area. It may interest you to know that we manu-
facture household paper products involving bathroom and
facial tissues, paper napkins, and paper towels which are
•egarded as every day necessities usually found on
rocery stores’ shelves.
It is no secret that both people and industries are being
lured to locate in the south to alleviate high living and
operational costs thus causing a serious economic impact
in the northern areas of our country, particularly New
Eng land.
STATLER
104—1
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Mr. Richard Kepp].er
November 24, 1976
Page Two
We feel certain that you recognize the economic stimulant
to Maine in general if the oil, refinery proposal at
Eastport was approved and will, be guided accordingly.
It has been said many times that energy is everyone’s
concern, but never has it been more timely — “We’re all
in this thing together.”
Very truly yours,
I cien Le sque t
Manager,
l v ’
cc: B. Minchello
McGrath
Plant Manager
104—2
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cc: Mr. McGlennon 11/30/76
Mr. Stickney
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Central Maine Power Company
GENERAL OFFICE, EDISON DRIVE, AUGUSTA, MAINE 04336 2O 623-3521
November 26, 1976
Mr. John A. S. McGlennon
Regional A&inistrator
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
The publication of notice for the December 3, 1976
hearing of the Environmental Protection Agency on the
proposed Pittston Company oil refinery at Eastport, Maine
prompts me to write you at this time informing you of
Central Maine Power Company’s position relative to the
refinery.
The State of Maine relies on petrolenm products to
meet almost all of its energy needs for transportation
and home heating. In addition, it depends upon petroletmi
by-products as a primary energy source to produce about
one-third of its electricity, and it is expected that this
dependence upon petrolenm products will increase in the
years to come. At the present time none of these products
are produced within the State and all must be brought here
from other locations either domestic or foreign.
The location of a refinery within the State of Maine
will bring with it increased facilities for storage and
should offer a greater reliability of supply to the entire
region. Also there is potential for further savings to
local users of the refinery’s products.
We are the largest electric utility in the State of
Maine and as such are a heavy consnmer of gasoline, residual
oil and No. 2 oil. Our 360,000 customers look to us to
provide them with reliable electric service while holding
down their electric costs to the maximnm extent that we can.
106—1
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Mr. John A. S. McGlennon -2- November 26, 1976
The proposed oil refinery at Eastport is one further step
in that direction.
Although Central Maine Power Company has no knowledge
of the envircmmental concerns relating to the Pittston
Project, we do urge that those concerns be viewed in the
light of potential benefits accruing to the region from
the proposed project. A careful weighing of benefits
versus cost should be a factor in your final decision.
V.ry t Iy y s,
K. V. Th. 1ov
Prs.idemt
106—2
-------
Tdephone (207) 763-9911
Lincoinvijie TePephone Covnpanq
LF.D. No.1
Lk coInvIfle. Mc*w 04$49
November 26, 1976
Permits Branch, Enforcement Div sion
Environmental Protection Agency
Kennedy Federal Building
Boston, Mass. 02203
Dear Sires
I am writing in support of the construction of the Pittston
oil refinery at Eaetport, Maine.
As a small business man in rural Maine, I can see and do see
a great need for a source of psirolews products for transportation,
agriculture and home heating. If these products increase very much
in cost, or became scarce, there will be serious effects on hundreds
of peopi. who live and farm in this area of the state. Our econoi
right now is best described as “marginal”.
The acute need for the jobs that this refinery’ would provide is
too obvious to need ar y stressing by me.
Sinesre
107—1
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108—1
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)(ov.ab.r 26, 1.976
U.S.K.PJ. sgion #1
Znforcsent Div.-Peruit Branch
J.F.K. iilding.
Boston, Mass. 02203
To Whos It May Concern,
i am an S.stporter. I attended Primary, Orawnar and Shead Memorial
T{igh Schools graduating in l9Wi . I served 20 months in the U.S. Navy,
part of which was during World War II. I left E.stport in 19 j7 and went
to work for the Washington Suburban Sanitary Comaiasion, Ryattavtlla,
Maryland. I retired from W.S.S.C. in I ceWer 197h and returned to
Eaetport February 1975. 1 have purchased a home here and expect to
remaininthi.areatherestofmyhtfe. Mywife andlha’veafair
retirement income which i controlled by the Washington -Baltimore cost
of living index. I do not need employment, therefore I feel that I can
give you an unbiased opinion concerning an oil refinery in Eastport.
During ther years I worked in Maryland, my wife aid family spent
many happy vacations in Eastport Sadly, though, we never looked to
see what had been added to th. town bat -what had been torn down. I told
my wife and fily many times that my heart went out to the proud people
of Eastport that were hanging on hoping for the ecddy Dam which, as
long as the goveroment clings to it’s present ecancmic feasibility
condition, will never be built.
I sincerely feel that lastport is * dying City. The high unsmplu asnt
and the d.lapidat.d condition of the town is indictative.
Although I frankly would rather see something other th an oil
refinery I must say that Pittston is the only company that ii willing to
invest 500 million dollar. or nor. in my town.
I not concerned about a possible odor, having meshed the Maarl
Corporation all the.. years. I am concerned about oil spill. but
however, we g le our livs .very day on the roads vithout too much
concern so to ga ls an oil spills to save a town tan ‘t all that bad.
I look at this oil refinery as the economic savior of my town.
With the increase in the tax bass I can an, a transdoue and much needed
capitol improvement prop. I can see new stm.ts, sidewalks, storm
drains, sewers, high school, hospital, etc. We can rebuild the front
street and make it the tourist attraction it should be. With the
steady payroll the people of the town can repair and maintain their
hos as they would like to. Once again I can Ses the front street
of Eentport on a Saturday night full of psopi., with aon in their
pocket. shopping in our stores.
As I said bsfcr., I not that excited about an oil. refinery
but this is all we’ve got so ists get on with it.
4cz .’ ‘
1 ry L. V...
29 Washington St.
1091 I.stport, Ms. 0 .63l
-------
41 Boynton Street
Eaatport, ?42ine 04831
November 26, 1976
U. S. Environmental Protection Aqenci
Region I. Permit No. 25-76-367
John F. Kennedy Building
Boston, Mass. 02203
Dear SirB:
As natives of this area and year-round residents of
Eastport, Mzine, we are writing to convey our strongest
support of the Pittston Company ‘e refinery application.
You m’uat take into consideration that if additional
refinery cavacity is needed in this country, a more
appropriate site location cannot be found. In this moet
easterly area of the nation, far u4 ay from the mainstream
of bueineae and industry, exiáta 6 0 cores of scrub brush
and broken beer bottles - suited exactly to an industry
such as this. To the east (some 20 air miles) across the
border in Canada, a nuclear power plant is nearing oo ’rp let-
ion while a refinery i -a in overation in the some area.
This is in our backyard? - not some remote area of the
Canadian northeast. The Canadians have seen the natural
potential of deep water and otherwise uninhabitable land
areas. We can and should do no less than they have done.
Yours truly,
‘Carleton . Small
1 t 4 i
&iureen L. •9maii
110—1
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DEC2 1 7
Harris Point Road
East ort, M ne 01 631
Nov. 29, 1976
yT• 3. Environmental protection Ap nev
eoion I
!oston, Mass. 02?03
gentlemen: re: Pronosed Issuance of
Fpt era1 Permits to
the ! ttston Co. of N.”.
I am in favor of the Pittston Co. buildlnp a
refinery in st ort, for the followi reasons:
1. Eastport desoeratelv needs emeloyment
that noes not de nd on a Canadian fish
eunnly. We are given a cuota, when the
quota is filled, oneratlons have to cease.
Th emn1oyment is great in the fish induetrv.
2. We need a new tax base to help take care
of our Waste Dianceal nroblems, and our Hosoital,
to remain in ooeratlon, must have help.
3. We have a population of only about 1900
oeoole. The island has suoported O00 in
the Dast. It would help us gain back some
of this lost opu1at1on. The migration of
our vounp oeople might be halted.
h. There is only one i jor Industry in the
County. Pittston would ceDtainly not over-
whelm a County the size of this one.
c. Last, Eastport is becomin a retirement town.
People who lived their entire lives in and for
heavy industry, and In big industrial eenters,
now want no development that will sooil their
country living. We also have an element that
doesn’t want to work. Emolovment ooportunities
would cut Into our need for such monstrous wel-
fare services, I for one, am tired of big,
strong,healthy voting oeople lining up for
handouts.
Thank “or for yoUr consideration.
rs. ulv, LI
9a tb//6 (‘A t i
Mrs. Kathlee Cline
Harris Pt, Pd.
Eaetport, Maine 01 63l
111—1
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Pittsfield, Maine
November 29, 1976
Permits Branch, Enforcement Division
Environmental Protection Agency
Kennedy Federal Building
Boston, Mass. 02203
Gentlemen:
Although I will not be able to attend the December
3rd Environmental Impact Hearing on the proposed Pittston
Refinery, I would like to express my support of the project.
Realistically, no matter how extensive the precautions
taken, ( and I hope they would be extensive), this project
would still pose an environmental risk. However, I believe that
that risk is a small one, especially when compared to the
tremendous economical benefits that this refinery would bring
to the people of Maine.
I urge you to approve the proposed Pittston Refinery
at Eastport.
JFJ : nr
112—1
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38 Johnson }Iei hts
WaterviLle, Maine 04901
November 30, 1976
Permits Branch, Enforcement Divis ion
Environmental Protection Agency
Kennedy Federal Building
Boston, ldaeaachusetts 02203
Dear Sirs
New England, as you know, is an EI .ERGY deficit area. We in
Maine have both unemployment and underemployment rates that
are far above the national figures. For the period 1968 to
1974 it was my pleasure to serve as Commissioner of the Maine
Department of Commerce and Industry. During this period of
time I became acutely aware of the need to produce a balanced
economy. The three Vs - Economics, ENER( Y, and Environment
became the vital ingredients in any plant location.
It was my pleasure to work with the Governor of Maine and the
Coimnjssioner of Environmental Proteott6z , in working out
legislation in regard to site location and oil pollution con-
trol. Both of these pieces of legislation became law and both
became the basis of the positive decision by the State of Maine
on the refinery location.
later I was to become President of t: e National Association of
State Development Agencies - as such, many coastal states
adopted legislation similar to 1 aine ’s.
Any industry that can pass the strict site selection laws and
the oil pollution control laws of this state should not present
any problems for Federal Environmental Policy to do the same.
As an Honorary Life ii ember and a Fellow iv mber of the American
Industrial Develor ment Council, I would be negligent not to men-
tion the dramatic economic .effect the refinery will have oh the
most economically depressed County in the East. During the three
years the refinery is being built the labor force will be nearly
six times its normal size. Once the refinery is in operation
manufacturing jobs should double (378—678) and those. 300 new
113—1
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manufacturing jobs should have the following impact of
$3,108,000 on personal income
$l, 4.7O,00O on bank deposits
$1,695,000 impact on retail sales
I would be less than honest if I did not say there would be
problems, but I do feel the net effect will be positive for
Washington County, Iviaine, New England and the Nation.
I do hope you arrive at a positive conclusion soon.
Sincerely,
K. Keefe, Ii.L.i../F.lvJ./C.I.D.
jk
1 V%—
-------
( /::- : L e,: /. _$‘
l{()’FARY CLUB
CALiUS, MAINE
Mrrl. CV nJ fl’C(I?IC$iIafg 1 !: I i.øi.. SI. Croix 11o14
U.S. Environmental Protection Agency
Region I
Boston. MA 02203
The CALAIS ROTARY CLUB, consisting of 40 members and representing
a cross—section of the business and professional men of Calais, Maine,
has voted to endorse the application of Pittston Company for the con-
struction and operation of an oil refinery at Eastport, Maine.
Members of the Club supported the resolution by a wide margin,
there having been no negative votes and only 3 abstentions. While
concern has been expressed for environmental considerations the con-
sensus is that both state and federal environmental agencies are deserving
of our confidence and are fully capable now of enforcing in a reasonable
manner all applicable anti—pollution l*ws and regulations.
We recognize the very acute need of both Eastport and the
Washington County area generally for a long term solution to its
economic problems.
We have seen study after study and heard politicians, committees,
commissions, panels and other visiting experts reach countless con-
clusions and propose a multitude of solutions for our economic problems.
To date we have seen no results of any magnitude ever realized, and the
problems still persist.
We find the Pittston Refinery a solid, substantial project within
the realm of possibility and one that is clearly capable of adding
substantially to our tax base as well as providing job opportunities and
a real stimulus to our economy over a long term period of several
decades.
We therefore endorse it, subject only to the reasonable application
of all relevant state and federal environmental controls.
THE CALAIS ROTARY CLUB
Dated: November 24, 1976
114—1
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cc: Wally Stickney, EPCO
Mr. McGlennon 12/2f 7
_ v’ o
Arv WAT R\/It ‘ S VIN ANI <
£•TAaLISMfO ,•.•
WA1CRYILLE PITT PICLD
AI FICLD
November 30, 1976
Mr. Richard Keppler
Region One
Environmental Protection Agency
JFK Building
Boston, Massachusetts 02203
Dear Mr. Keppler:
The purpose of this letter is to place our bank on record as being in support
of the construction of an oil refinery at Eastport, Maine. We feel certain that
the construction of an oil refinery under the environmental regulations as they
now exist for both state and federal agencies, would be most unlikely to create
an environmental problem of any type and certainly would be most beneficial to
the economy of the entire Eastport and surrounding area. It would also enhance
the supply of low sulphur oil throughout our state as well as to the other states
in the northeast region of our nation who, because of their geographic location,
must consume a great quantity of heating oil during the winter months.
It is not anticipated that our bank would receive any of the benefits of monies
expended for construction or for the operation and maintenance of the refinery it-
self in the future years inasmuch as we are located some 100 miles away from the
site of the refinery. In our opinion, it will be of inestimable value to an
econouically depressed area such as Washington County here in our state. 1 feel
it would be rather presumptuous of us to attempt to recite to you the projected
payroll to be incurred as a result of the construction together with the creation
of new jobs necessary to operate the facility on a continuing basis. Then, also,
there are those new opportunities of employment which would be created by the
providers of goods and services needed by the refinery in its daily operation. The
state and lor al taxes would be, in our estimation, a very sizable amount of dollars
which, of course, would be of direct benefit to the Eastport community as well as
indirectly to the State of Maine through the use of sales and other taxes.
It is also our feeling that this refinery could quite easily become a catalyst
for the location of other industry, either related or unrelated to the oil refining
industry, which would have an increasing beneficial effect to the entire area. I
am sure that there are many, many additional reasons which I could cite in support
of this refinery but which would be rather repetitious to you inasmuch as I am sure
you now have this information available to you.
It is our considered opinion that this project does warrant your favorable
consideration and we do feel that a refinery built in compliance with the existing
environmental laws would not produce any greater risk of polution to the land, sea
or air than now exists as a result of refineries located only a short distance from
Eastport, Maine in the Canadian Provinces. We are further convinced that we here
in )t no an have both a good clean healthy environment together with an industry
WATEOVILL( MAINE 04901 ./ (LEPPlOP4E 207 e73-3301 — PIrISPIELO. MAINE om •i . TELEPHONE 207 4S7 .))44
—LJ.rAIRFIELO, MAINE 04937 TELtPH0P4E aoi S3.OaSS
115—1
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ltr. Richard X.ppl.r .2— Ilovsub.r 30, 1976
which would bring great financial aaeistance to an area that ha. experienced a
aerious decline in it. scoacey over a nuaber of year..
Thank you for thu opportunity to expres. our viewpoint to your agency.
Sincerely,
L.$L
Pr.sid.ut
A IM/jaf
115—2
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DFC2
V
Main Street
Winterport, Maine
04496
November 30, 1976
U. S. Envjron ental Protection Agency
Region 1, Enforcement Division
Permits Branch
John F. Kennedy ederal Building
Boston, Mass. 02203 iNc. 0022420
Sirs:
I write in regard to the hearings at Eastport December 3
concerning a proposed oil refinery there, hearings which I
cannot attend without neglecting my duties to the public
elsewhere.
Thanks to my knowledge, limited but real, of navigation and
Maine tides, it is inconceivable to me that Pittston or any
other firm can continually bring oil tankers through the
approaches to Eastport without sooner or later, not just oil
spills but major destruction of a tanker and a oatastrophic
ruin of sea life in that region and for many miles along the
coast. That will mean diminution of the fishing and recrea-
tion industries. Pittston admits they want much larger and
more underpowered vessels than have so far been approved for
this operation because they will be more economical, but those
huger tankers are going to make the likelihood of shipwreok
and destru tion of sea, shore, fish- and bird-life even
more catastrophic.
The refinery itself sounds fine for employment, but just
look at Bayonne, New Jersey. Is there no unemployment there?
Is not Bayonne, with many similar communities, made unbear-
ably ugly by precisely such establishments? Mrs. Holmes and
I i oved away from New Jersey thirty-seven years ago to find
a part of the east fit to live in, and gladly put up with a
modest income to do so. Tet now the very thing we fled pur-
sues us and would destroy the Maine coast, one of the major
resources of the eastern U. S.
Nor does the harsh, inhuman, overly materialistic attitude
of Pittston Corporation officials in reference to their dis-
aster in ?lest Virginia (which killed other people) in any
way quiet my apprehension.
I am prepared to use less oil or go without, have done so be-
fore now. But I am not prepared, without protest, to see the
quality of life in Eastern Maine ruined be greed—obsessed
persons who have yet to learn th.t they should be caretakers
of the earth, not ruthless exploiters, and hence diminishers
of it.
8tnesrsi7,
& L 6 -i-’
Idward L o1*.e
116—1
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$
December 1, 1976
United states E. P. A.
John F. Kennedy Federal Building
Boston, Mass. 02203
Gentlemen;
I wish to go on record as a legal resident of Capiden,
Maine and as the Assessor of Ea8tport, Maine 8 be1n
WhoI hearted1y in favor of the oil refinery of the
Pittston Company proposed for Eaatport.
I consider myself conservationally and. environmentally
oriented and feel that the above project has extremely
beneficial merits far in excess of any of it’s dis-
advantages.
I feel further that the pollution of Washington County,
Ilnine resulting from the historically depressed state
of the ecconomy can be greatly alleviated by the Pittston
refinery and this benefit greatly outweighs any risk of
accidental and correctable pollution resulting therefrom.
I am a Certified Maine Assessor appointed as the single
Assessor of Eastport for a contract term and I fully
realize all of the attendant problems and benefits the
Pittston project will involve for the City.
Z’ie P. Foley,
Assessor, Eastport
I’ PF : kmd
cc Public hearing at Eastport, Dec. 3, 1976
117—1
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OEC7 16
P.O. B.x 83
Connty Read
Eaatp.rt, )Iaine O i63l
Deaber 2, 1976
tJ.$. Revtrceaental Protection Agency
Ragi.a I
f•rc eate Division, Persits rs*ch
John F. Kennedy Federal Building
Boston, Massachusetts 02203
NPDI3 Peruit Application
N ed,er: MR O22l42O
Coz s Pereit Application
er: 25.-76.’367
I y- nane t. George Peters, Jr.. I have bean a resident of the City
if etp.rt all of 37 yearw, an warned and have two ifl sons.
We love tbi3 city and hop. to b. able to stay here. Thi. is why
I an veiy wuch in favor of the Pittston Conpsny’e proposal to build an
•il Z’etiDOXy herse
I an enpicyod by the astport Water Conpawy and hold the position
of nanagsr, )b’ wife is anployed by the Eastport Monoxial Hospital and
work. in the Medical Records Departaant. Our base was built eight
year. ago with our oi hands and is located only a few hundred rest
f run th. proposed refinery site. We realise our hone will scat airiLy
lose its value if the refinery is built. A Pittston r.preaast.ttve
explained the site, noise factor, tc., to us. He also stated that the
caspawy was not interested in our hone but in the laid. He said if vs
wars interested in selling they were iat.rest.d in biq’tng. It wsald
break our hearts to see cur hone tore dean as it took us Liv. year. to
build.
118—1
-------
.2-
Under these circ tancae on. i.rnald thiek vs would not be In favor
ct th. refinery. Yet sy wif, and I have weighed the facts — 1) Whan
cur chtldran gran up they will have to leave this city; as their chances
of finding a reasonably secure job will be next te nil. 2) Tb. hospital
is very likely to close, leaving sy wife without a Job. 3) Water rates
will probably rise, asking it vexy difficult to nanag. and try to collect
fz p.op). I have knoim all sy life. This situation already
exists, with so easy people eut of jobs.
I an an avid hunter and ftshezaan. bexy spare ninats I have I
spend either on the watr or in the woods. virceatal]y, I believe
ther. is not that wock left to barn and b.lisve that the D.LP. with
their strict regulations will ‘ — d strict enforc..snt.
If the refinery I . built vs stand t. lose sons; but gain each nor.
by being abi. to have oar feaily together and the opportunity to verb and
better ourselves. W hays ala. considered the hinges a refinery will
bring bnt lacking back on th. last ftfte yem as are ear. we can cop
with just aboat aiqthing. Most of our friends have had to move &w*y to
f lad *0* to sW,pert their filies; as no longer have even a aevie
theater; stores have closed; easy houses have ben torn d and
very fan nan osea built; moat of the land that was free to roan, whes
I as. a l1 bay, has bean purchased people who consider everyone
a trespasser.
The city will change regardless, if s refinery is built or sot.
The cs]y difference is easy of the people, syssif and fily included,
will not be abl, to remain hers to see then if the refinery ii not built.
These are only sy pers.mal viess c c the proposed refinery. I
sincerely b.liev. I have trtsd to lock at th. situation openly. Tb.
pecpl. In this area are, for the east part, bard asiting people and deserve
the .pp.rtsaity to asks a dcset living.
118—2 Os. ’j. Peters, Jr.
-------
46 Main St.
Yarmouth, Maine
Nov. 29, 1976
Environmental Protection Agency
John F. Kennedy Center
Poston, ?lass.
Dear Sirs:
Although I will be unable to attend Friday’s hearing on the
Pittston issue, I would like my opinion to be considered by the
EPA.
As the owner of land near Eastport and a resident of the state
of Maine, I feel that granting approval to the Pittston Company for
construction of their refinery would be a gross mistake.
A8ide from the established adverse effects of air, water,
and noise nollutiori, the construction and operation of an oil
refinery in Eastport would be a giant step backward for residents
of the area and the state of Maine.
An industry based on a non—renewable resource will not solve
the economic problems of Eastport, but ultimately make them worse.
When the oil runs out, the fishing will be much poorer than it
now is, and may even be nonexistant. The slight economic boom
generated by the refinery will suddenly and dramatically turn
into a dismal bust.
The only benefits to be derived from construction of a
refinery in Eastport will be realized by out of state construction
workers and the Pittston boys. Eastport and all of ? airie will
gain nothing.
119—1
-------
(2)
We will be left with scourged fishing grounds and a violated
coastline. The coast of a unique, precious, end inspiring
tlace will be forever changed.
Since the EPA is the deciding factor in this question, I
ask you to consider long—term econo nics, eociolo , aesthetics,
and ecology. Your only va lid decision can be to send the
Pittston boys packing. Save a coastline and a way of life.
We don’t want Pittston in East!,ort or any oart of Maine.
Rea ecif
Mark F. Norton
119—2
-------
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120—2
-------
PAIUS (Retter) — Fronce’s coastline—
disfigured by developers, saturated with
swynner vacationers and despoiled by fac-
tories—faces rapid ruin, ecologlats say.
So the Frendi govermuent, ott to atop tlds
pellinell dedrudion of the comitry’s natural
heritage, has set ups national trast. Its ebief
aim Is to buy up thui*s of coedline and pit
thorn perinanei*ly under date Iretection.
11w CoaMal Presorvation Association, wtitdi
has a moded budget of 12.4 million for Its flrd
year, is modelled on the BriJak NaiJ vtai Tred.
Association chief Dominic Legrmn said: “The
National mM served as ow mod . Our aim Is
to buy up land, protect it, and open it to the
public. ‘11w Englith have bean doing It fur 00
years so why shoulib ’t we?
“It Is very Unportad to get on with the Job of
protecting ow coastltt . In 10 years It will be
too late.”
Tracing the development of France’s
co.atline, he noted how sharply the problem
had worsened.
At the tern of the cextury, aemide resorts like
Deauville, BIarrItz and Nice became 1W-
hmable bit only 10,000 people weil to them on
vacation each year.
In 1000, paId holidays were Infroduced In
France and the figure rose to a million. Todey,
12 million French clttsesas ge to the seaside on
vacation every year and goverimseit 4l ka
show the nwnber could double by the year 2000.
1 agrbr pointed ott that 12,000 lwa*ei
are built on the coast by Frencionen every
year.
“Added to this, there is the boom develop-
ment of sud lndodrles as tool and potrocbç-
micals on the coast,” he said. “Dm*lrk , I A
Havre and Foe take up greet drotches of
coast”
To avoid local arpiabbles, the association has
divided the 2,200 mIles of coastline tile five sec-
tors wbidi put forward likoly plots for pur-
chase.
Thea a councjl of 3 ( 1 wIse men decide wtidi
projects will be given the go-akead. ThIs year
they have agreed to 20 and Lagrin said: “We
hope to have made ow flrd purchases by the
aid oftheyear.”
14. esplalned that altar buying each idles of
land, the amocidlon would have It cleaned up,
tortAd any contrutthin w ataoevar-, maintain
It In naturul a date a pilhle and have
local authorities wh’nb it.
Their fird big t Is to make a huge in-
ventory of the Frmdi coastline, mapph every
creek aid Inlet, tease where they can Intervene
moot elfedively.
LeØn said: “The Britieb did the same thing
with the countryside ceinmlssien. The Swedes
and Amerl is have done it too. The Canadians
also cunplded a hugely expetsive ecological
tnveI i tOi7.”
Lugrin, whose association also hopes to
encoirage4he French to donate properti in
their wills, drs.aed that France Is not alone.
“Contria around the world all have the
same problems and we all only have the same
means for limiting the damage,” he said.
F t nce Buys Coastline
‘To Protect Its Ecology
120—3
-------
Sir: I read with con-
corned interest the letter
written by Barbara Lehigh
of Eastport. Maine.
published In the Gleaner on
.tugust 28. The writer
expressed great concern
about the proposed oil re-
finery at Eastport and the
luherty that the Governor
of Maine. James Longley.
has taken in making a
slatement to the Canadian
energy minister about
that the penpic of East-
port wanted.
I would like the writer to
know that many people in
New Brunswick share the
concern of the people ot
Eastport both for their
sake and our own, and I
would like you to publish
thi, letter from the U.S.
Department of the Interior
which I received after a
letter had been sent to that
department to express my
concern about the
proposed refinery at
Eastport
Freder icton
itatement will have to be
prepared which must
define any potential ad-
verse effects. It will in-
chide full public input.
assuriOg that all interested
individuals and or-
ganizat ions will have an.
opportunity to express
whatever concerns they
may have.
A broader issue, which
as -yet has not been fully
addressed, is the question
of oil talkers which would
service such a facility.
passing through Canadian
territorial waters on their
way to Eaatpcrt. In order
for this to happen, the
Canadian gov.r ment
must apee to such a
proposal. Formal dis-
cussions on this iuue
remain to be initiated
between our Governments.
The Issue of the oil
refinery isa complex one
relating to the energy
needs of the New England
area. the economic
problems of Maine, and the
maintenance, as you
rightfully point out, of the
envjronm,ntaj quality
including the cultural
values of our two coun-
tries.
Thank you for ex-
pressing your concerns on
this important issue.
Sincerely yours,
Russell E. Dickeenon
Acting Director
I. ..
Letters to the Editor of tl
port Relineri-
(‘ampobello International
l’ark
awe delighted that
our visit to President
Rooscv It s cottage was a
re arding one and that
ou have such a keen
appreciation of the value of
preserving our historic
sites for future
generations. The park is a
unique example of in-
ternational cooperation,
and as a joint memorial b
(‘anada and the United
States stands as a symbol
of the close relationship
between our two countries.
We also appreciate your
deep concern over any
possible adverse effects
that an oil refinery located
across the bay in Easiport.
Maine. might have upon
the perk. It is our under-
standing that while pro-
liminar discussions are
being heid and the State of
Maine is actively con-
sidering a proposal to build
Mario.i Davis the oil refinery tou
mentioned, that no
decision will be reached
br some tirpe to come.
The enclosure
Mrs. Marion E. Davis
541 Wooclstock Road
Fredericton
New Brunswick. Canada
Dear Mrs. Davis.
On behalf of Mrs. Gerald
H. Ford. shark you (or
our letter concerning
tour visit to Roosevelt
A number of steps
remain to be taken by the
St ate, and various legal
review jwocedures at both
the State and Federal
levels must be undertaken
prior to any firm decision.
In addition. an
environmental impact
I.
120—4
-------
OCT27 976
Associated Industries of Maine
2 Central Plaza AuUusta, Maine 04330 (207) 623-4568
FREDA C.LOUC H.JR
B-CAsca . e Co.p.
Yc. Pp , -. .lont
GALENL COLE
Coes F .0e . Bango.
VP , .s oJ, 1 n 1
WIWAN ( HAGGEIT
Barn Iron WI Corooraton. B1h
RONALDW WASHBURN
V.Ies TInOnrIandi. Inc.. Augusta
EoicuIo Doeclor
UERRILL C WELLES. JR
eM ana ,ef
PEGGY L HARVEY
NECTOfiS:
DANNY E BARBATO
Fa.,clc.k$ Srn ondcactor So. Po,IIn
PO&RTN BASS
0 H taasslCo.W,It.p
DAVID P BICENFU.
B.ckr .cII tanuIacIu.ng Co.. Roctiland
WI LLIANC BULLOCK. JR
I err.lI Ban Nar,sCo.. Bangor
SERHAROS ESTEY
S D VIa,rcn Co
ROBE PT 0 FAIRBURN
key .s F .b ’e CO Wate y,fls
JOHN T ( OULD .ja
SI R-.., P pe - C . Bucaupa.,
LOREN K HUTCHINSON
SGUIIc .nIh LIaCIX..,Co Po .t I nd ___________________________________________________________________________
PETEIIF KING
Con .o . . PIN Cor”w . P’riq . I Ii
FREO€flCk W ANCELAHO
Jasp . W,rfliO S Son. U.We.dga _______________________________________________________
PAIJLK M,CANN
G ..aI No I0 rn Pap. ,. Co
WCHARDJ MOWN
inc-nat. Auguols
RIC.HAROA MONI4ELL
S,.,n ..c.c.k Coat I Lu”bsc Co.. B’unIw.cI ,
LAURA NA%;FEL
C H .UtU* tp Co . Wi t.r ., I I,
P AtiOflI WS NIXON
Deaø nw ,. Cornoany. Bangor
A J POLACKWICI . ,
U .pn.-nt C’.c.o .aI,on Stuco
ELWt 1 11 IHJR LOW
Ce t U ,n 0 P0w. Co . Augusta
WALILPE TRAVIS
Bangor £ AroOslook Ra.I .oad Co.. Bangor
ADVISORY COMMITTEE:
ELOER II PRINCE Cha.,man
LUP sans Inc . F 5 1 0o.JIh
GAL(I4 COLE
Cc. . (.,. -t .s
NOWAIOL COUSINS
6.. .t Ao .js!., .. Pa .I,OadCo Bangor
RA .tCYJ(t A (i tt,I ’fl
tn*,ion
JOHN F GOULD. JR
St Pc, r p Co .OucIisport
RALPH KHCIW( TON
C . ’t, ‘Cot 0 t,O0 H., , 5 I1 0
ROITLII’ PtA t)I(
II J P.. C.nnn CO
KEIT tlO p rc
C. tXp.a Corpo .aI.on. Woogland
HUGH C SAUNOERS
Saun .W., B oa Wstb .o
Sri-ring Maine Indusin’ F r FzJt •fi ,e )‘ci,rs
October 22, 1976
Mr. Richard Keppler
Environmental. Protection Agency
Region One
John F. Kennedy Building
Boston, Massachusetts
Dear Mr. Keppler:
This is to respond to your inquiry as to
whether this association would present its
position on socio economic benefits to be
derived from the Pittston Company’s application
to site a refinery in Eastport. The Board of
Directors of AIM has voted affirmatively and
1an to present their testimony at the hearing
to be held on December 3 in Eastport. I am —
Itopeftit that ‘iou wiTi notify us of our Tace
on the agenda for that day .
Sincerely,
errill C. Welles,
Executive Director
ph
cc: Fred A. Clough
President, A.I.M.
OFFICERS:
121—1
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(
NoV 7e Nt. 1, Po 133
EastDort, I’a ne 01 4 E31
October 2 , 197L
New En la d Division
U.S. Ar-n Corps of Er gneers
Tra ,eio i oao
Walthar, ?ass. O21 L.
Ne: P ’ psed Pjttston refiper i at Eastport, Maine
Dear Sirs:
TNe Pittston Compar ha made apolic-ation to the U.S.
Army Corps of Engineers as well as t other agencies of the
Federal S3vernment t c’nistruct sr d operate a refinery at
Eastport, Maine.
if the U.S. Arnj Corns of Engineers ever expects to .uild
a tida) power project at Ea3tport consisting of a one pool
desi r. by damtng Cobscook 3 between Shaekford Head and S€war
N.c (See J.S.’.S. 15’ and 7. ” Eastpnrt, Mair e quadrang.es)
then the a prova]. of the Pittston app1ic tion would prevent this!
The Pittstor. tanker termir.als would preclude the tidal project.
in tine, as oIl supplies dwindle around the world ,the tidal
project becomes more feasible. So ou peopli had better consider
thIs--it wuld see c saise for the Corps to keco its options open.
SI ersl o ’s,
•1
bert S. ,i9lles
Geologist ‘../
123—1
-------
October 28, 1976
MA *ACHU•ETTS MUTUAL LWE INSURANCE C ANY
SP*INGIIftD. MA*$ACHU$ETT% DUll
RICHARD M. STOLKNER. CLU
ASSOCI ATE
S MAR LOW T CET
MAINE 04401
(207) 947-1306
Mr. John JyjacGlennaxi
Administrator
E.P.A., Region 1
John F. Kennedy Bldg.
Boston, Mass.
Dear Mr. NacGlennan:
New England generally, and Maine specifically,
has not done its share in the area of oil refining.
I believe that the Pittston Co. should be allowed
to build a refinery in Eaatport. I realize that this
refinery will do little in the way of reducing my
oil or gasoline prices, but I firmly believe we in
Maine must share the risk of possible oil spills
with other areas of the world,
The economic impact of this refinery will help
Eastport as well as the surrounding towns.
Thank you f or taking the time to allow me to
share my thoughts with you.
Crdij y
Richard N. Sto]Jm.r, CLU
cc: A.F.Kau.lakis, Vice President
Pittston Company
330 Madison Avenue
New York, N.Y.
DAVID A. MARLEY
0EHE AL AGENT
SOUTH PORTLAND. MAINE
-2 PIOV
124—i
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Post .ffjce : ox 286
Cutler, .: ine 04626
Cetober 29th, 1976
nviornnental 2rotection A ency
J.:.i . rederal bui1diri-
oston, assac iusetts
. S: Pittston refinery at Zastport, aine
I will be o?enin, a retail fabric store in .Iachias, the
county seat, around tne first of the year, so I feel I am
qualified to answer your request for more statei ients from
business on the icipact of tne refinery.
For the 3—5 years of construction, tnere has ot to be a
2-way boom in tt e area’s economics. The first part will.
be the impact of new money that will. provide jobs for a
reat percenta3e of the local people, t u h mostly in
u iskilled—labor type jobs. The second will be the ar-
rival of new, skilled workers to do the technical parts
of the construction. ( usiness no doubt will benefit,
both from the availability of rnore money and from the in-
crease in possible number of customers.)
:owever, once construction is completed, I can not see
anyt in but a complete turnaround in the picture, nro-
bably to a situation far worse than now exists. The
jobs for which local people are qualified, i.e. unskilled,
will vanish. new, s alIer set of skilled workers will
ap7ear to run the refinery and the port, but not in such
numbers as construction required. ny businessman wno
is dependant on the now—departed money and people is otn ,
to be in trouble. Worse yet, the laborers now without
jobs will probably have contracted debts based on the in-
corne they nad durin construction and will be unable to
pay. Towns in the area will have had to increase their
services, espicall.y schools, to accot uaodate the earlier
wave of new workers, but will not need nearly as much for
those runnin ttie refinery. Payin off these now-unneeded
buildL -s will ave a bad effect on the whole state due to
the uni?or i property tax law.
Jobs are certainly needed in ashin ton County, but of a
perT Pnent nature end for those whose families have lived
here for ;enerattons. xcept for a very few, I can not
see iow Pittston’s pronises of e’ econonic den can cone
true.
L nda M. Throckmorton
125—1
V
-------
V
mL t i ‘ +‘ /%/? 3’
PJTfSTON ( J IXa
permit sought biD
A refinery construction permit has bee
requested from the U.S. Corps of Engineers by
the it1sta i Company. I , 30 i4’
Colonel John Chandler, head of Lb. Corp. ‘
New F g aiid Division office in Waltham,
Mass., said the Army Engineers and Lb.
Environmental Protection Agency (EPA) will
hold a joint public hearing on lb. permit
request in Eaatport. No dat. has been sat.
The permit application is a solid affirmation
by the Pittston Company that they plan to go
ahead with the refinery, despite unsuccessful
effort. at getting approval needed for tanker
movement by the Canadian government.
Pittston proposes to construct a 250,000-bar-
rel a day refinery on Coobscoch Bay. Tb.
handling facilities would consist of two piers.
Dredging of 35& 000 cubIc yards of sand arid
the supertanbers would unload.
rial would be disposed of on land.
Colonel Chandler said that anyon. wishIng to
comment on the construction permit should do
on th, economic impact of
entire project are being sollcitd from W
He for the E
much data on the economic effect. of the (1
refinery for inclusion in the envi,eamen ’ -
impact statement. U
The reason he speculated, i. that there’s
been a problem of getting people to tabS the
project seriously because of unresolved prob-
lems with the Canadians.
PiUsto received conditional approval from
the Maine Board of Environm nta} Protection
IBEP). There is no indication those conditions
have been met.
03 NOV 1976
126—1
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GANONG’S POULTRY FARM
Pembroke, Maine 04666 1
• NOV 1976
November 5, 1976
U. S • vironmentai. Protectionkgency
Region 1
John P. Xenne&y Building
Boston, Was.. 02203
Permit 1ó. 25—76—367
Dear Sir:
Pleqee acoept my oo ents on the Pitt stan Company
propoesi for a oil ref in.z’y at stport, Waine.
A. a lifelong resident of this area I fee]. t t this
mould be much needed asset to $h. areas eucony.
In addition to Jobs in the efinez’y Itself, Job.
SIll be provided by related services to tb. refinery.
Wore Job . will mean more peopl. thua g1 1 iu my
business a chance to exps , therefore would need
people ‘to wo t.
11th the eafegard. that we have now in regard to
•nv1ro ent If eel that the ecolgy 11l be ..11
protected.
Thank you for time.
imc.rely, )
Gordon Osnong
131—1
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Co/fl 5 re
DEPENDABLE SERVICE SINCE 1917
GENERAL OFFICES
w
444 PERRY ROAD BANGOR, MAINE 04401 TELEPHONE 207 942-7311
GALEN L. COLE
P ESIDE .T
November 5, 1976
Mr. John McGlennon, Director
EPA Region I
John F. Kennedy Federal Building
Boston, Massachusetts 02109
Dear Mr. McGlennon:
Coles Express, a Maine based motor common carrier serving the State
for 59 years, wishes to go on record 8troflgly in support of the Pittston Eastport
Refinery, for several reasons.
First, the economic plight of the people of Washington County, whose
unemployment rate, I believe, exceeds that of any other area of the State of Maine,
could be significantly helped by the employment and growth that would be generated
by an oil refinery. Washington County, an area several times as large as the State
of Rhode Island, but with a population of less than 30, 000 people has been disadvantaged
for generations. Our company serves the entire State of Maine and has been the
principal carrier serving Washington County for several years. If an oil refinery
is located in Washington County, Coles Express would definitely establish a large
truck terminal there, employing a dozen or more people and offering an overnight small
shipment service from all major points in the State of Maine and as far south as Boston.
From previous experience we know a truck terminal accelerates economic growth.
As the homes in Maine require more heat than other states in New England,
and far mere than our more southern neighbors, the reduced transportation costs by
having a refinery in our State would be most helpful to our citizens.
In closing, may I add the possibility of the Pittston oil refinery Is the best ray
of hope Washington County has had in several decades. I hope your office may see fit
to act favorably on the Pittston Company’s request.
Sincerely,
Galen L. Cole
l lijijt .\e,i FLI,;,/)iI.’ire LIJ: ,aci’lgk’t1.r alki GI,,111h,1,
1i2—1
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Statement of Cole. Express at EPA Hearing, Eastport, Maine December 3, 1976
Coles Express Is a Maine based motot common carrier serving the State of
Maine, Southern New Hampshire, State of Massachusetts and the Canadian Maritime
Provinces. Our company has served Maine longer than any other motor common
carrier. It is a well known fact that the economic plight of the people of Washington
County, whose unemployment rate has exceeded that of the State of Maine and New
England, could be significantly helped by the employment and growth that would be
generated by an oil refinery. Washington County, an area several times larger than
the State of Rhode Island, but with a population less than 30, 000 people, has been
disadvantaged for generations. Our company has been the primary motor common
carrier of general freight serving Washington County for several years.
If an oil refinery is located in Washington County, Coles Express would Immediately
construct a large truck terminal In this County employing a dozen or more people and
would offer an overnight service on small shipments to and from this area, and the
reut of the State of Maine, and as far south as Boston, Massachusetts. A full-service
terminal, which would be the only one In Washington County, produces benefits not
unlike that of a major highway system and since It ’s purpose is to perform a service
to the immediate area,it serves as a magnet and sales tool In enticing additional
industry to the area. The fact that customers can be assured on a regular basis of
their small shipments, as well as large shipments, being at a local terminal early in
the morning, would allow Washington County the same service that is perforrncd at
metropolitan areas throughout the country. Statistics are available In our borne off i t
in Ilangor to substantiate that the last new terminal constructed by our company in
the State of Maine five years ago has grown from a two man service bcIor’ a terminal
to one which requires 25 employees today. An oil refinery in Washington County would
132—2
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be a stimulus for many companies, including our own, to makc a positive cornmitmcnt
which would hclp not only Eaatport but all of Washington County, and for that matter
the entire State of Maine. As the homes in Maine require more heat than other states
in New England, and far more than our southern neighbors, the reduced transportation
costs by having a refinery in Maine would be of significant help to our citizens.
In closing, I would add that in our opinion the possibility of the Pittston oil
refinery coming to this area is the best ray of hope Washington County has had in
several decades. Colee Express wants to participate in the growth that a Pittston
oil refinery would generate.
L2
Galen L. Cole, President
Colca Express
132—3
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november 5, TQ76
Fastoort, Me.
Dear Sir;
I’am writting in regards to the Pittston orooosai for Pastoor$-.
I’am a retired fish factory worker, I live in the Senior rifizen
Housing Development in Eaetport. I ‘am very much in Favor of $his
industrial development. The fishing inriustry anti bbe city itself
has reached it lowest level. This orolect is lust what this area
needs. Please help us out by aDprovtnq of this oroif’cfr.
eaa r ’ s
I ‘ -
133—1
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13 DEC 1 ió
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U.$ Eavironseatal Pr.t.ction Agency
R.gio l
leaton, Ma. S 2O3
To lbs. It y Cancers,
C.ac.zaing the pr.po.ed oil refiner, at Iutp.rts In volvae 1, pass 1k,
of the 1.1.1. yea stats the Pitt.* Oil Coapsay aaint*ia. that at 1 5 .tport
they have a °receptive cosnity” ...tbst is y.t te ha pr.v.n. That. has
be.. a. vets ef tb. pe.pl. iav.lv.d. dec.adly, tb. eu refinery at
Sa.tp.rt d ee. net •aly affect th, little area of £utp.rt — it affect.
the satin Cebec.ek and Pea q .oddy b.y ans* *a.tp.rt ha. •aly 21.2 •ho*.
siX.. en the bay but the cuneunities of D.na vi11e, Perry, Peabreke,
deudc, ibiting, Tr.sc.tt, and Labse have 277.9 share sues en the
C.hsceok/Passas.queddy bay area. Tb. opiates ef thea. s 4 ties eheald
be c.soted sad heard. .th.ir claa flats sad . ‘Iap ,b.d. are at stake.
That, in lea toeris. during the svr sths all al.ag the ebc.k.
Piskiag , testis, sad ferest prsdacts its the life bleed ef thea. sos-
.‘s.itie.. Ihat gain .sald tksee c.—u-4ti.. ether the. Matpert have sith
the building ef a. .t l refinery en the t. .b.ce.k My. lernber - ask any
flahera.a an the ebsceok and ha’ 11 tell ye. - vMt ,er ye. drop into the
C.bsc..k stay. there and d..e .’ t go ant to the Atlantic • Tb.. tidal pattern
is seab that debri. gee. fre. s os sswaity sher• te another. The se-s&11.d
acceptable .il spills fran Pitt... Oil Co op s .y .e.1d affect all the..
• — 4%j • It seal. ruja the bscsok y, Th, delicate Marine lit., a*d
the pe.pl. she depend apes the bay fer a living.
Glenn Myers - -
Tresced t, Main.
ec tt a
137—1
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13 Main St..
Lubec, Maine 1 04652 \
Dec. 6, 1976
U .S. Envtronaental Protection Agency
aEgion 1
Enforcement Division,’ Permits Branch
dohn. F. X ennedy Federal Building
Boston, Mass. #MEOC2* Ø
Sirs,
As a new resident of Lubec, Maine, Naturally I am deeply concerned
about the controversy in Eastport, about the oil refinery and the
problem o ttansporting oil into Eastport..
May my votse be heard, in protest to the methods thus far discussed,
regarding the transport of oil, into Eastport. There is no need for me
to enumerate all the hazards of the gigantic oil nkers trying to
get through 1ead darbor, and getting strajided onlte submerged mount iin-
tops that have become the innumbera ble hidden rocks and obstacles..
The refinery cannot operate without the oil thus ’brought in.
ilowever, should there be such a development, please comsider the
geographic location of Eastport, the island connected to the mainland
by a narrow causway. Should there be any kind of accident in the
refinery, such as explosions, etc., the single road out of Eastport
woulcinot permit any kind of escape. The hm&ocaust would resemble the
one that took place in the Wi1*ington, Delaware R 0 tver, last winter.
Not on1 would Eastport residents be trappöd there, but also, the
Lubec areI, including North Lubec, and Lubec proper, would be in peril.
There is no need to discuss what has already been so ably put forth,
regarding the effect of a growiag po u1atton in the tiny area where
Eastport is located. All kinds of social and health problems would
res 1t.
The Pittston peop,. e have a very bad record of irresponsibilty and
lacK of integrity, which must be regarded as a factor in their pushing
the construction of the refiner ’ and all of the attendant accessories..
I hope that you can succeed in stopping this nightmarishproject
before any more money is wasted, any more people miseducated, any
more threats to the I ra ile environment that keeps these local fishing
comrnunites alive.
There is nb dobt that Eastport and Lubec, and many other local
communties are in bad economic shape, and we do need some kind of
industry. These towns are becoming ghost towns. But we do not need to
have the+njured to the point of total distruction
ncerely y urs,
(mrs.) Florence • Jones
10 c I 16
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MR. DONAGHY: Thank you. Mr. McGlennon. I will
t y to keep well under the three minutes, doapite what
I have in front of me.
MR. McGLENNON: Thank you.
MR. DONAGHY: I do this in appreciation for your
being so kind to listen to the facts given to you by
the gentleman from Deer Island, our Canadian neighbor.
I would like to point out first that much has been
said about Eastport, although some of your speakers
have been front Lubec. This is a community thing. not
just Eastport. The reason for this is that Lubec,
part of it, is less than a mile away from the refinery
site. As a matter of fact, much of Lubec is closer to
the refinery than the Village of Eastport. As a matter
of fact, the population of Lubec is within 40. or was
in 1970, and we have had quite a growth of retirees
and this sort of thing, people that want a different
way of life. They have come into the area, and I don’t
think they would have come had they known that Pittston
was close on their heels; that is, not necessarily with
140—1
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334.
the refinery but the means of getting the oil into
that refinery.
But just to give you an example, something that
has not been brought up, the fact that L,ubec has 98.1
shore miles, as opposed to Eastport’s 21. Trescott,
the home of some of these folks that say they are from
Lubec - actually they live in Trescott - they have 51.9
miles along the shore on Cobscook Bay, just above the
refinery. Edmunds, where Mr. Allen Bell spoke very
convincingly here, at least to my mind, they have 38.8
shore miles. It is in that area that the Moosehorn
Game Preserve and the State of Maine Cobscook Bay Park
is, with close to a million dollars worth of work that
has been done in the area, where Suffolk University has
a sum.iier school on marine life and the aquaculture studies
for the area. I could go on with Pembroke, Perry, and
Dennyaville, all around and affected by the tides in
Cobscook Bay.
Just one more point along that line. In the Cobscook
Bay area, as far as marine life is concerned, there are
19,489 acres of tidal flats, 6,490 acres of intertidal
flats, making a total of 25,979 acres of flats, where
140—2
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335.
marine worms, clams, mussels, you name it, would be
ruined if you had these continuous inevitable spills
as admitted to by the Pittston Company.
Speaking of Pittston, they started out back with
Metropolitan Oil., I think the name of the outfit - it
is in the records anyway — by the name of Harris Company,
and they told Metropolitan Oil that this wasn’t a very
good place to have a refinery, and then they told the
same thing, as I recall, to Pittston. But then they
put in a third report and said this is a fine place.
So I am going back to the report of the Comittee on
Public Works of the United States Senate, headed up
here in the eubconmtittee by our own Senator Muskie,
and in that report, on page 585, it tells what Arthur
1). Little. Inc., said about Eastport as an oil. port.
This was one of the ten ports that they were surveying
to find, out where an oil port would be viable in the
State of Maine. And of Eastport they say, “The
ccnçaratively high tidal currents and narrow approaches
all but eliminate Eaatport from further consideration.
Supertankers could only. enter or leave the port in
slack water with the assistance of numerous tugs. This
14 0—3
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336.
could involve delays of many hours and risks which seem
too great in light of alternative locations. The only
approaches to Eastport or any other location in Passa—
maquoddy Bay and Cobscook Bay are through Canadian
waters. Because’ of the extremely hazardous approaches,
the very common fog, the fact that all oil pollution
in these passages would be extremely difficult to control,
the Canadian Government might impose further restrictions
on the use of this port.
“Finally, Passamaquoddy Bay has been considered for
many years for the development of a tidal hydro—electric
facility. If this tidal power ever comes to fruition,
the port facility might very well be sacrificed.”
This is from our own Senator Muskie’s hearings.
MR. McGLENb ON: I re you al nost through, Mr. Donaghy?
MR. DOI AGHY: Then besides that, I would recommend
that you gentlemen do a little bit of studying of the
report of the international Boundary Commission which
establishes the boundary between the United States and
Canada. This particular book. I don’t think it has beer
bound since 1934, but there is available hearings and
reports practically every year since that date. In this
140—4
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337.
book you will find that there is a passage into Friar’s
Bay. It is through the Narrows between Lubec and
Campobello, and I believe it is 115 meters — don’t hold
me to the exact — on either side o the international
boundary. Since that channel was negotiated there ha
been a bridge put between Lubec and Cainpobello , however,
it would seem that there would have to be some new
boundary negotiations before we found a way legally,
unless we throw out all the prior efforts that have
been made by the U.S. Boundary Comission and renege
on what we have agreed to in the past. I think we can
well listen to what our Canadian neighbors have to say
now, rather than wait until after the Boundary Commission
has to go into this 1!’ dctail.
i’nonk you. ( p!:*1 u e)
MR. McGLENNON: Thank you, Mr. Donaghy.
-------
Hr. Chairman:
My name is Philip Rosa end I am Superintendent of Schools for
Union #104, which includes the City of Eastport.
I have reviewed the section of the report dealing with schools and
find the information to be correct.
The report mentions that the expected increase in school enrollments
would cause some difficulty on the secondary level. This points out the
major problem that hae existed in Eaatport in education, an insufficient
tax base to provide sufficient funds to solve our needs.
Eastport has one of the two high schools in Washington County stilt
educating secondary students in an antiquated building. Although we
are in the process of building a new elementary school with State
assistance, our secondary plant is definitely lacking. Built in 1917,
it is not adequate for today’s education. Unless there is a major increase
in the tax base, I cannot foresee any possibility for a modern school
plant that would provide our secondary students with the educational
opportunities ’ they should be receiving.
The area does not provide our young people with employment opportunities.
Our graduates are faced with seeking employment in low level skill areas
locally or leaving the area. We cannot afford to continue to export
our youth. More diversified and lucrative employment opportunities must
be provided locally for our graduates.
The salary schedule for Eastport teachers La one of the lowest in
Maine. The present tax base is not sufficient to permit us to pay
salaries equal to other areas in the State.
If education in Eastport is to become comparable, it must have the
necessary monies which the City cannot presently provide.
141—1
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115.
I have reviewed the section of the report dealing
with schools and find the information to be correct.
The report mentions that the expected increase in
school enrollments would cause some difficulty on the
secondary level. This points out the major problem
that has existed in Eastport in education, an
insufficient tax base to provide sufficient funds to
solve our needs.
Eastport has one of the two high schools in Washing-
ton County still educating secondary students in an
old building. Although we are in the process of
building a new elementary school with state assistance,
our secondary plant is definitely lacking. Built in
1917. it is not adequate for today’s education. Unless
there is a major increase in the tax base, I cannot
foresee any possibility for a modern high school plant
that would provide our secondary students with the
educational opportunities they should be receiving.
The area does not provide our young people with
employment opportunities. Our graduates are faced
with seeking employment in low level skill areas
locally or leaving the area. we cannot afford to
141—2
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116.
continue to export our youth. More diversified and
lucrative employment opportunities must be provided
locally for our graduates.
The salary schedule for Eastport teachers is one
of the lowest in Maine. The present tax base is not
sufficient to permit us to pay salaries equal to
other areas in the state.
If education in Eastport is to become comparable.
it must have the necessary monies which the city cannot
presently provide.
Thank you.
MR. McGLENNON: Thank you, sir. I guess, Mr. Ross.
we have a question.
MR. STICKNEY: Thank you. Mr. McGlennort. The question
is that also in the staLe comments there was some
reservation that our prediction of the increased student
load based on the number of new families was low, that
we had made an incorrect prediction. Have you given
that any thought?
MR. ROSS: I don’t really know what effect the number
of families coming in would have in terms of children.
I have reacted in terms of the figures given. I am not
141—3
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117.
too concerned in terms of numbers if monies are there.
We can set up temporary classrooms, we can hire more
staff; I think that problem can be solved as it
develops. It has been solved in other areas, and I
am sure we can solve it here.
MR. McGLENNON: Thank you, Mr. Ross. Mr. Blanch
from the Planning Board.
14 1—4
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December 2nd, 1976
Mr. William Adams
Department of Environmental Protection
State House
Augusta, ME 04333
Dear Bill:
I am writing in support of the Pittston
Company’s application to build an oil refinery at
Eastport. This support is based on a number of
obvious economic facts but in particular on the
assumption that the DEP would insure that the
proper environmental controls and safeguards were
a part of the design and engineering of the project.
With our area dependent so heavily on imported
oil and recognizing our cold climate and the needs
for oil to maintain the industry that supports the
Maine economy, a local refinery would be a real
benefit.
The construction of a major facility in this
depressed area would have a real boon to the—area
and after it was started would provide new jobs and
taxes, both of which are sorely needed.
With kind regards.
Sincerely ,
I/
L /!t [ ’ t(W4(
/jjv /
144—1
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$ D.c.ib.r 2,1976
United Statee Environnental Prot.ction Ag.ncy
Region #1, £nforc.asnt Division, P.rsits Division
J.F.X. P.deral Building
Boston 02203
Dear Sire,
Pl.as. ‘vsto th. proposed oil r.fin.ry at Eaatport, Main.. Pleas.
protect on. of the last natural and uaoontaainated coastal environ—
seats on the eaet.ra s.aboard. An oil refinery reached only by pass-
ing through son. of th. scat tr.ach.roua seas of th. .aetira As.rican
coast can only sean disaster to the wild life, s.a life, th. sea, sad
eventual to th.p.opl. who liv. her.. If your departsent i. otual1y
dedicated to prot.cting the eavirona.nt I can not understand how you
can approve such an .*viroassatally distractive sob....
50 School Street
Lab.c, Maiai, 04652
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MR. HARRIS: My name is Allen Harris. I live in
Eastport and I am running for the city council. I am
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190.
the only councilman that I have ever known of having
to write down his platform taking cognizance of the
fact that there is an oil refinery being planned •to
be situated in Eastport.
This oil refinery, as I am sure you all know, began
in the 60s as a small tank farm for the Metropolitan
Oil Company. In fact, in 1967, 1968 and ‘69, I believe,
the options were first given for the largest parcel
they needed to implement this project by our city
council. In 1971, still under the guise of the Metro-
politan Oil Company, this small tank farm for Georgia-
Pacific became a refinery. Very little detailed infor-
mation was given about it. Such information was forth-
coming in April of 1973, when the Pittston Company applied
for permits from the BEP in Maine to begin construction,
and they had to make this information public.
Well, I went to that meeting by mistake, because I
am from New Jersey and I have seen small refineries, and
I would have been willing to accept a small refinery in
this town. I did not expect to see 650 acres, to hear
about supertankers, and to find out about the Pittston
Company and its lousy corporate record. So when we left
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191.
that meeting. I went out and met with some other people
and we decided to petition, because the magnitude of
this project was away beyond the scope of what anyone
had anticipated or could possibly know about. It had
been purposely suppressed and kept low-profile. I was
told that we would go out in this community, especially
as we were hippies, outsiders, sunv ter people, whatever
we have been called. you know, who voiced opposition
to this project, I was told I wouldn’t get anyone to
sign that petition. We went out in four days andwe
got 500 — well, we totaled 584 registered voters, and
we did the most of it in four days. Within three weeks
we presented that petition to the Eastport City Council.
Two of the councilmen signed that petition. It was
endorsed by the major newspapers in Maine and Governor
Curtis. It did not represent the opinion of outsiders,
newcomers. suuuner people; it represented, by and large.
the opinion of 584 registered voters in Eastport. most
of whom were indigenous Eastporters.
I have never contended that the majority of those
people wished to stop this refinery or were opposed to
it. I would say that I did not encounter the incredible
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192.
enthusiasm I have seen here tonight from some of the
outsiders that Pittston has managed to talk into coming
here to speak for them: I mean businessmen from other
parts of the state. I found that the people here, a lot
of them are for it because they believe that if they
didn’t have it the town would die and there would be
nothing else here, but when I talked to them I found
that they didn’t have very much information about the
facts involved in th. case. Almost to the man or the
woman that I spoke to. they said, even the ones who
personally favored it. that they wanted to see it come
to a vote in this town, and if the people of this town
voted that they did not want this refinery built here,
they would accede to that mandate.
Well. I presented it to the council. It was defeated
by a vote of three to two. It was condemned by all of
the self-appointed spokesmen who spoke here tonight for
the people of Eastport. The thamber of Q merce in
this town condemned it unanimously. Well, it was thrown
in the garbage.
Since then. I think the people of Eastport have known
more about it than most of these people probably that
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193.
are in this room right now that have come from away
to testify for the Pittston Company. They are being
asked to accept the risks and dangers. That gentleman
who spoke from some other county, whatever constituency
he represents, could talk about the dangers and risks
and how they are quite necessary. Well, I might agree
with him that they were quite necessary if they were
in his backyard, but he can come here and talk about
them because he believes that it is necessary for the
overall picture of this state and this county.
Pittston has talked about minimizing risks. When
I read about explosions that have taken place, you can
talk about minimizing risks, and then you can go on to
say it is very hard to quantify risks. You know, I
mean, I have read about a nunther of tankers that have
blown up. the one that blew up in the Delaware Rivers
two years ago in particular - I have the clipping -
and I have read of others. And I know I can document
it because I have a thing I got here from the Coast
Guard in Washington, D.C. of casualties, United States’
ships, for the years ‘73 to the present, ‘75. I do
not say that they are conunon because there were only
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194.
twenty explosions that took place. But you just need
one small explosion in this town and this town will
be a ghost town. And that to me is very important
because you are talking about saving Eastport. When
you talked about saving Eaatport, Eastport is a place;
it is not just a geographical area. It is an historical
and coninunity entity, and it is made up of the people
of this town.
I can tell you that you will not hear many local
people speak out like I have, and there are reasons.
You look at this incredible array of pomp and power
that they have brought here, and you expect the working
man in this town to stand up and say he is against
Pittston? (Applause)
MR. McGLENNON: Let the gontle: an finish. Would
you try to conclude your remarks as soon as possible.
MR. HARRIS: I will conclude my remarks. I think
that before when he spoke the consideration went beyond
the — almost all the evidence that has been submitted
so far has referred to the economic impact, and the
economic impact they are referring to, as far as I could
see it, doesn’t refer very much to the people of Eastport.
146—6
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195.
I go out campaigning door to door, and I did it when
I petitioned, and I have done it in the last four days.
My biggest base of support is the young people in this
community who are supposedly going to benefit from this
refinery.
I was told last night by two people that chey would
not speak out publicly because they hoped if this
refinery caine in that they could get jobs to earn enough
money to get out of here. I spoke to a woman 67 years
old who told me that when the fog comes in she has
trouble breathing now. And you are talking about three
weeks of fog, and you talk about the possibility that
it might happon or it cc id happen that you will have
sulfuric ac: i fcrmjr’ .n t - e ai , nd cther zulfaLe
cc pc uac ay i av n adverse effect
on human health. Well, if that “may” possibly ever does
come to be, is the Pittston refinery going to close down?
The people here have been exposed to this for four
years. They know the facts and they should be allowed
to vote on it.
Another problem is expansion. I want to know how
are you going to stop this company from expanding? By
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196.
your own little sununary there - and I read the big book
on this - you predict by 1985 that there will be a need
for six refineries of this size. I don’t see anything
that is going to stop them, if they make the kind of
profits I think they are coming in here to make from
doubling the size of that. In fact, last night someone
told me it is a matter of public record that Mr. Kaulakis
stated in an Augusta hearing that they already had
contingency plans to n ve this refinery to 500.000
barrels. And there is nothing in our zoning laws and
there is nothing that I see in any of these protection
agencies that is going to stop them, nothing. In fact-—
MR. McGLENNON: Thank you. Mr. Harris.
MR. HkRRIS: O.K. But what I want to say in conclusion.
since you have made the fact that conTnunity impact is
very important in this thing 1 and I consider that to bring
it in against the will of the majority of the people would
be devastating, that you make a condition - and I hope
it is not the condition that would keep them out - but
you make it a necessary condition for them being issued
any permits that it go to a public referendum in this
town, where people can vote in the privacy of a booth
146—8
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197.
and no one knows what they said, for it or against it.
And I. myself, if they vote for it, as I said in the
paper, I am not going to speak or act against it any
further; I will just accept that decision. And I am
sure that all of the people from our business community
will go along with me. you know, and I gully believe
that they should be fully franchised to cast their vote
too.
146—9
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And with that, if I may. -ould wt’ have our thrr e
c xperts follow in surcession. Dr. Eda please.
MR. ED : My name is Haruzo Eda. I am a research
engineer at the Davidson Laboratory. and an associate
professor with the Department of Ocean Engineering.
Stevens Institute of Technology. Castle Point Station.’
New Jersey. The Pittston Company of New York requested
that I study the maneuverability of 250.000 DWT tankers
and 80,000 £MT tankers in environments similar to those
in Head Harbor Passage and Eastport Harbor, Maine.
Before I sumarize the work I have done and the
results. I would like to briefly outline my background
for you. I have been employed at the Davidson Laboratory.
Stevens Institute of Technology, since 1961. During
that time I have been actively engaged in research on
stability and control of ships and underwater bodies.
At the laboratory I have been working under various
projects sponsored by the U.S. Coast Guard. U.S. Maritime
Administration, u.s. Army Corps of Engineers, and Office
of Naval Research.. I am a member of the Panel H-1O
(Ship Controllability) of the Society of Naval Architects
and Marine Engineers; a member of the Maneuvering
Comittee of the International Towing Tank Conferences
and the American Towing Tank Conferences; and I am a
member of the Society of Naval Architect and Marine
Engineers, and Society of Sigma XI.
I hold a Bachelor and Doctoral Degrees from Osaka
p niversity in Japan, and a Masters Deqree from Stevens
- 147-t
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55.
Institute of Technology. Appended to my full report
which I am sul xnitting for the record is my complete
resume and bibliography.
In undertaking this study, I have used hydrodynainic
coefficients determined in tank tests on 250,000 DWT
tankers, and estimated hydrodynaznic coefficients for
.80.000 DWT tankers in the deep an shallow waters. I
have used actual current patterns, including cross-
currents, similar to those in Head Harbor Passage and
the Coast and Geodetic Survey chart data on the depths
and lengths of Head Harbor Passage.
The mathematical model used in this study was formu-
lated on the basis of extensive studies at the Davidson
Laboratories over a period of 15 years. and it has been
validated with full—scale ship trials. Those models
have been used for such varied purposes as ship design,
waterway improvement, harbor design, vessel traffic
analysis, and ship captain’s pilotage training for VLCCs.
Similar math models have been used on the computers at
Stevens Institute of Technology under various projects
for the U.S. Coast Guard and the Army Corps of Engineers.
For example. I have used this model in the course of the
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56.
research program for the U.S. Coast Guard on an 80,000
EMT tanker entering New York Harbor. I have used the
model for the Army Corps of Engineers in a study
entitled “Atlantic—Pacific Interoceanic Canal Study”.
The 250,000 DW’r tanker was considered in this particular
study for the Corps of Engineers. Similar models are
presently being used at the shiphandling simulator
recently completed by the U.S. Maritime Administration
at Kings Point. Long Island, and also at the shiphandling
simulator of the Marine Safety International at LaGuardia
Airport.
In the study done on Head Harbor Passage, I have
assumed in all cases that the tankers are fully aded.
The model does not include the effect of t ’c stance
on the tankers since the objective of the dy was to
establish the responses of the ships to their own control
systems. Anticipatory maneuvering to account for the
effects of wind and tide were also not included.
Before sumarizing the results of this study. I should
outline for you the ten different cases that I ran on
the computer simulation in arriving at these conclusions.
Eight of the cases invOlved fully-loaded 250,000 DWT
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57.
tankers. Of these eight cases, three were used as base
cases. Of these three, one was computed using no tide
and no wind with a constant six knot speed of the tanker.
The other two cases were run with .47 knots of tide both
ebb and flood, no wind, and a constant six knot speed.
One case was run with no wind and no tide, but with the
speed of the tanker changing from six knots at the
entrance of Head Harbor Passage decreasing to two knots.
Two additional runs were made with the fully-loaded
250.000 DWT tankers with a tide running at 2.7 knots in
both directions, with the tanker changing its speed from
six to two knots. Two runs were made where the tanker
encountered 2.7 knots of tide in both directions and a
wind velocity of twenty knots from the northwest.
Finally, two runs were made with a fully—loaded 80,000
1Y. T tanker encountering 2.7 knots of tide in both
directions, with a speed changing from six to two knots
with no wind factor involved.
The current conditions which I chose were used to
bracket those conditions that a tanker could reasonably
be expected to encounter using the Head Harbor Passage
under the Pittston Company proposed approach format.
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58.
The aerodynamic characteristics of the tanker was
determined on the basis of wind tunnel test results
of this tanker configurations.
Let me briefly summarize the results of my studies:
1. A 250.000 T tanker can maintain a trajectory
close to the desired track in the channel in currents
up to at least 2.7 knots without tug assistance and
without anticipatory control input to account for the
effects of wind and tide.
2. Winds up to at least 20 knots from the most
adverse directions introduced no serious problem in
ship control during the transit.
3. An 80.000 ‘JT tanker will maintain a trajectory
with slightly smaller deviations from the desired track
than a 250.000 ! ‘JT tanker.
4. With anticipatory control input such as provided
by a pilot, the deviations observed in these studies
would be even smaller.
Thank you.
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MR. HOULT: Mr. C1i trman, my namc is David P. )kult ,.
I am on the staff of the Mechanical Engineering Department
of M.I.T.. having served as an associate professor until
last year when I became a Senior Research 1 ssociate
in the Department. I am also engaged in consulting
through Hoult & Company, Inc., of which I am President.
My field of specialty is fluid mechanics. I was
involved in the early research and development work
at M.I.T. which established the basic relationships
and parameters between the variables that determine
how effective floating booms are in containing oil
slicks. One of these formulas which is known as the
}Ioult—Cross equation defines the relationship between
current speed and angle, type of oil, and height of
boom needed to effectively contain oil within such a
barrier. My publications in this field since 1969
include eight papers, six reports, and two books. A
list of these publications is being submitted for the
record.
The plans which have been submitted for the Eastport
project include various oil spill prevention measures,
inãluding the use of flexible booms. These are deployed
around the moored tankers to retain any accidental oil
spills which might occur outside of the rigidly boomed
area directly underneath the ship—to—pier transfer
148—1
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60.
loading lines. The effectiveness of containment by
booms in the Shackford Head area has been an issue
because the currents which flow there range in speed
from 0 to more than two knots, depending upon the
time of tide and the distance from shore. However,
these currents flow essentially parallel to the planned
pier and to the vessels that will be moored there.
I have taken an independent look at the proposed
design layout as set forth in the draft LIS. and
particularly at what impact the presence of a moored
tanker would have on the effectiveness of the proposed
booming system around the tanker.
My studies are based on the bathymetry at the site,
the measured currents at the site, and the proposed
locatim of the docks and the VLCCS. In addition, I
made a visual inspection of the site from a small boat
and verbally reviewed the data of the current surveys
in the area.
In simpler geometries than Shackford Head, when an
oil barrier is deployed in a U shape to contain oil
spilled in a current, it has been found that the barrier
begins to leak from the lowest part of the U when the
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61.
current reaches 1 knot perpendicular to the barrier.
On the other hand, if one can deploy a barrier in a
straight line at a small angle to the current, it can
be used to deflect oil drifting with the current, at
currents substantially greater than one knot, provided
the oil does not form a deep pool with a leading edge
perpendicular to the current. In practice, of course,
skimmers are placed at such points to keep the oil
level down, and to remove the oil for appropriate
disposal. Tests, as reflected on page 238 of the draft
EIS, show that oil can be contained without skimmers
in currents of two knots parallel to the boom surface
and one knot perpendicular to the surface.
The peak currents off Shackford Head range from one
to more than two knots. it is clearly desirable from
an oil pollution control viewpoint to moor the ship in
an area where the currents are low.
However, one can design and operate a satisfactory
oil pollution control system in currents greater than
one knot by using barriers to deflect the spilled Oil
from regions where the currents are greater than one
knot to regions where the currents are less than
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62.
one knot. One needs to so configure the arrangement
of booms and skimers that a deep pool of oil is formed
and then removed from the regions where the currents
are low. Whereas little engineering design and test
effort are required to get a good oil, pollution control
system: i.e., one which removes virtually all the oil
spilled, when the currents are less than one knot, more
effort is required when the currents are higher. But
it is certainly feasible and practical to design and
operate oil pollution control systems at currents in
excess of two knots.
In considering such systems. it should be recognized
that the current pattern around the moored ship does
not amount to a simple uniform flow. There are two
reasons for this. First, without the ship present. the
current surveys reported in the EIS show that there is
a substantial change in the speed of currents as one
goes offshore from Shackford Head. Second, these current
surveys do not take account of the substantial hydro-
dynamic effects of the presence of the ship, the dock.
and the effect of dredging on the current pattern around
the ship.
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C?
Roughly, the moored ship at Shackford head may be
thought of as an obstruction to the tidal flow. Due
to the large size of the ship, and the relatively little
amount of water under her keel when the ship is moored
at the VLCC pier, the presence of the ship and the pier
structure substantially reduces the current near the
ship.
One can estimate the size of these effects by going
through the following steps: Fitst, one can establish
that there is a good correlation between the present
bottom depth, averaged along a constant current contour,
and the current associated with that contour. What I
mean by that is in deeper water off Shackford Head the
currents flow faster. Conceptually. c: then divides
the flow into scver 1 channels, c: :c:: th a
specific current contour. It turns out that the hydraulic
radius of each channel is, to a fair approximation, the
average depth of the channel. So the correlation of
current decreasing as depth decreases amounts to an
empirical rule similar to those long used by civil and
sanitary engineers in estimating the currents in canals
and sewers. This is called Manning’s equation.
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64
To determine the effect of the ship and the dredging.
one estimates the change in average hydrualic radius
along a channel; i.e. a current contour, brought about
by the presence of the ship anddredging. Using this
modified hydraulic radius, one can use the same empirical
rule (Manning’s equation) to estimate the change in
current due to the ship and the dredging. -
With a large size ship such as proposed for use at
Eastport (250,000 CWT) and a modest amount of dredging,
this calculation predicts large decreases in currents
around the ship when the ship is located in water as deep
as that found at the Shackford Head location. For example.
if the moored ship were located on the 1.75 knot contour
off Shackford Head, the current is reduced nearly 40% to
about 1.1 knots because of the presence of the ship. On
the other hand, if the ship is located on the 1.2 knot
contour, as in the draft LIS. the current is reduced
approximately 20% to 1 knot. The percentage reduction
in this instance is somewhat less because of the effect
of more dredging and shallower surrounding water.
In sunvnary then, my review of the booming system as
deployed in the draft EIS 1 that is placed at an angle
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65.
such that the current specd will be one knot perpen-
dicular to the boom, and with skimmers located at
appropriate points to remove oil deflected by the boom,
will be effective even without allowance for the effect
of the moored tanker on the flow of the tidal currents.
The large effect of the tanker hull and the pier
structures on the hydrodynamic flow will give the
barrier system as designed a considerable margin of
performance over that claimed in the EIS because no
allowance was made in the design of the booms and in
the placement of the piers for the impact of the vessel
and the structures.
Thank you very much.
l48—
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149. G1LFILLEN: M i. Chai*man ladi iJ nt1 cmnn:
my name is Edward Gilfillen. I live in rt I’ cthbay
Harbor. Maine. where I am cmployod by the Bigelow
Laboratory for Ocean Sciences as a Research Scientist.
My formal education includes a B.A. in Zoology from
Yale University. a Master of Science in Biological
Oceanography from the University of British Columbia,
and a Ph.D. in Biological Oceanography also from the
University of British Columbia. I have been active in
149—1
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66.
the field of oil pollution research since 1971. I
have published five scientific papers on the subject
and have authored six unpublished reports. A complete
resume and bibliography will be forthcoming.
I have read the draft envirorunental impact statement,
and basically I have no quarrel with the facts as
presented in it. There are, however, aji iiøber.of points
which were raised in the EIS which have occasioned
comment by the press and which I feel should be put into
perspective by reference to actual experiences at oil
spill sites.
The first of these points concerns.the i q—t
effects of a large oil spill on the region’s herring
-
stocks. It is true th. t herring eggs and larvae which
are in th water coJ r underneath an oil slick would
probably be adversely affected, however, once the slick
is no longer present no further harm should result.
There is no evidence resulting from the investigations
of the aftereffects of the Arrow oil spill that herring
migrations or distributions were significantly affected.
The food chain magnification of petroleum-derived
hydrocarbons, such as has occurred with DDT, was once
149—2
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thought to be a serious problem, but now no longer
appears to be so. The herring is a planktivorous fish.
and although the plankton conununity was shown to suffer
underneath the Torrey Canyon oil slick, there is no
evidence of adverse long—term effects induced in
plankton cormnunities by oil spills once the slick is
gone. Hence, the food supply of the herring should be
unaffected, except possibly for a short time while the
oil slick covers a significant portion of the water’s
surface. It is difficult to imagine any long—term
effects; i.e., over years. of an oil spill on either
the herring themselves or on their food supply.
As regards the possible tainting of the flesh of
groundfish, the areas where this occurs are those where
chronic large releases of oil occur and where large
an unts of oil are incorporated in sediments. It seems
unlikely at Eastport. because of the depth of water and
because of the circulation, that large amounts of oil
would reach the deep bottom sediments, and hence, this
should not be a problem. Winter flounder do feed in
the intertidal zone and there is a possibility that
their flesh might become tainted. However, winter
149—3
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flounder caught in Casco Bay. which is one of the east
coast’s largest oil ports. do not appear to be tainted.
Hence, the risk of tainting of the flesh of groundfish
appears to be low.
I am not familiar with data showing long-term
reductions in landings of finfish as a result of an oil
spill. It may be argued that often fishery statistics
do not give a particularly accurate representation of
the yield of a given fishery, and that as a result small
effecta resulting from oil would be missed. This is a
valid argument, however • if small effects do occur, they
are as small or smaller than the normal year to year
variation in landings, and the probability that even a
large oil spill will destroy the fishing industry at
Eastport for a two to four year period appears to be
remote.
The effects of oil on fixed fishing gear, such as
weirs, and on processing plants’ water supplies, should
be transitory. although troublesome, and confined t a
relatively short period following the oil spill.
The situation with respect to lobsters is that although
larval lobsters are quite vulnerable to floating oil
149—4
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69.
slicks the adult animals of coumiercial size appear
to be extremely resistant to oil. In the case of the
oiling of a lobster pound at Friendship, Maine by
crude oil from the “Northern Gulf” in 1963, approxi-
mately a quarter of a million lobsters were in the
pound when it was oiled. Although the shor s of the
pound were covered with two to fotir inches of oil.
there was no significant mortality amongst the lobsters.
A small stretch of shoreline was cleaned and the lobsters
were removed from the pound and subsequently sold.
There was no report of their flesh having been tainted.
Subsequent to the sale of the lobsters, the pound was
cleaned with Oil-Go, which is a very toxic dispersant.
This pound remains in use and has one of the lowest
mortality rates of any in Maine. Admittedly. the oil
in question was crude oil which was weathered - it had
‘been at sea. I think, about ten days — and less of the
pound was oiled than would have been if the pound had
not been in use and, hence. been empty. However, this
.xp.ri.nc. does show that pounded lobsters do not appear
to be extremely vulnerabl, to oil spills.
Following a spill of crude oil from the tanker “.7. R.
lU—S
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70.
Grey”, lobsters in floating cars were reported killed
by oil at Dipper Harbor, New Brunswick. Experiments
were performed at the Marine Research Laboratory at
St. Andrews, New Brunswick, in which it was hoped that
a cause and effect relationship between death of lobsters
and exposure to crude oil could be developed. At Dipper
Harbor only those lobsters in the upper layers of each
car were killed. The experiment which was performed
consisted of exposing lobsters packed in the upper part
of lobster cars to varying concentrations of oil in a
flow—through system. The water level was made to
fluctuate approximately three inches to simulate wave
action. The lobsters were alternately covered and
uncovered. Lobsters were exposed to a one—sixteenth
inch slick of oil under heavy agitation by a pump, as
well as to a one—quarter inch slick which was not
agitated. Both fresh oil from the J. R. Grey and
weathered oil from Dipper Harbor were used. The experi—
meñts ran ten days. At the end of that time no mortality
had occurred either in the controls or in any of the
experimental tanks. After this ten-day period the
lobsters were cooked, and a taste panel could not detect
149—6
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1c..utt’ttion o or ’ rr.’r. ti1 of 1.Lvir. . c wo s u t to
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• • — - :.• • -
IbU J
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MT4. FENLASON: Mr. Chairman and members of the
committee, I am Representative Harold Fenlason of the
State Legislature. representing District 101. which
is in Washington and Aroostook Counties. I live in
Washington County, and I have been in this county for
all my life. I think I know fairly well the needs and
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the type of living that we have in the county. My
comments will be very brief, and will be concerned
mainly with the needs of Eastport, of Washington
County. the State of Maine, and the United States
of America in providing adequate supplies of energy
to meet the ever increasing demand.
We are all conscious of two great pressures which
are somewhat antagonistic toward each other. We must
have a constantly increasing supply of energy to
maintain our standard of living, and we must do all
that we can to protect our environmental resources.
As with all controversial problems, we are not going
to be able to make everybody supremely happy. A
problem of this sort must be solved by the beet c m-
promise that .:ill provide i onahie CCOi i. C ar..
environmental stability.
I assume that everyone in this meeting has examined
the report supplied by the U.S. Environmental Protection
Agency. I also assume that every person here can find
parts of the report which would bolster his own view-
point. whether it be pro or con, on the project. Such
a weighty and detailed set of documents does show how
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98.
much work has been done on many, many phases of this
proposal. It does seem that there is great encourage-
ment and promise in the fact that so many possible
difficulties have been studied and procedures suggested
by which they can be overcome.
The most important factor for good living all over
the country is the steady and constant increase in
demand for power in all, forms. We are faced with a
serious decision. Do we cut back on the use of power
to provide easier and better living for our people,
or do we keep on striving for methods and ways to
produce power in every possible form. It just doesn’t
seem possible that citizens are going to be willing
and content to return to bucksawing wood and walking
to the grocery store. It is probable that people can
learn to adjust to any set of physical circumstances.
but it is much more simple to go forward in economic
affluence and good living than it is to reduce our
demands for more and better service.
Rather than blocking power development in New England.
and more particularly in Maine. we should be trying to
increase production in any area that will improve the
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economy. In this part of the country we are poor.
We need more industry and we need more activities
which will help our people to make a living. We have
large areas of open lands and waters. While we must
take definite steps to protect our natural resources.
we cannot afford to let all of the country revert to
its “natural” state. If we should. become convinced
that we need nothing but the so-called natural beauty.
perhaps we should just go away somewhere and leave
the whole area to the rich retirees from other states
who seem to have great expertise on how the State of
t4ainers should live. I think the time has come for
people who live here, and have lived here for generations.
to review our needs and to make our own decisions f:
the implementation of our own style of living. h. ’-’e
managed to survive, with many handicaps, for a long
period of time. We certainly have made vast improvements
in our way of life in the last fifty or more years. We
must continue to go forward. Our present moderate measure
of success and progress in living conditions cannot be
allowed to deteriorate.
I would like to dwell briefly on the dangers inherent
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100.
in the construction of an oil refinery and in the
transportation of crude oil, to the site. There are
dangers and there are hazards. Many of these are
outlined in detail in the report of the Environmental
Protection Agency. Also given in detail are proposed
methods and means for avoiding trouble and damage to
the environment. Danger, of course there is danger.
There is danger in every facet of our living, and we
survive all kinds of dangers by taking reasonable and
effective precautions.
I will close by repeating: we need this refinery,
for several reasons: to improve the economy of a
sorely distressed area, to help insure a continued
supply of oil which i.s competitive in price for Maine
and New England, o picvi one of the needed links
in a vast system for bringing adequate supplies of
power to this country.
Thank you.
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JAMES C. SATES. M. 0.
a. WAHSNOTON •TNEET
EAS1POST. MAINE 04551
TSl.KPNONE s•a. 54$
November 30, 1976
U.S. Environmental Protection Agency
Region I
Enforoements Divis ion, Permits Branch
John F. Kennedy Federal Building
Boston, Massachusetts 02203
NPDES Permit Application
Number: ME00221120
Corps Permit Application
Number: 2S-76-367
Gentlemen;
My name is James C. Bates. I have been a practicing
physician in Eastport for the past thirty-eight ysars, otherthan
for short periods in Calais and Quoddy Village. Also, during
most of that time I have been the Administrator of either the
Quoddy or the Eastport Memorial Hospitals. I now hold that
position at the Eastport Memorial.
My coimiunication is prompted by your invitation to those
who wish to express their opinions on the presumed effects of a
major industrial complex on our coivmnxnity.
There were some thirteen factors identified in the Oct. 22nd
issue of the Quoddy Tides upon thich one could coement. It is
my hope that the matter of health and welfare of the residents
will properly fit into one of these catagories, for both of
these factors are of most vital importance to every citizen,
regardless of his or her residence..
When I speak of health I refer to the provision of adequate
health care. In reference to welfare, I do not wish to limit, its
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meaning only to thoae requiring assistance in the time of need.
Rather, it encompasses a much broader scope that includes such
things as happiness, peace of mind, well being, end, hopefully,
prosperity.
Thus, the decision to be rendered will vitally effect our
conmiurilty for many, many yeara to coma.
To substantiate my reasons for this statement may I be per-
mitted to recall briefly the past and present of the provision
of health care, with its related effect on the general welfare
or a community?
In 191i4 the Eastport Memorial Hospital was established.
Throughout many years it was a busy institution in which the great
majority of the area residents had their babies, their operations,
were treated for their illnesses, and, for those who needed a
comforting place in which to spend their final days they were cared
for by concerned and sympathetic personnel.
However, in recent years the hospital has been unable to
adequately fulfill Its role in providing health care for a variety
of reasons, I.e. reduction In the services provided by the local
physicians, a diminishing population resulting in less utilization
of the facility, Increasingly stringent State and Federal regula-
tions, and an inability to attract new physicians because of the
somewhat shabby appearance of the conumrnlty, It’s uncertain future,
and the lack of a modern hospital. Nor have hundreds of letters,
scores of replies, end a dozen visits by prospective physicians
been of any avail, because of several of the aforenmntioned reasons.
All In all, a picture of diminishing available medical service.
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- .3 —
Obviously, it now becomes not too difficult to fore oe the
future of the hospital should not there soon be a population
increase and an economic improvement in the area. Since the
hospital ii the key to the provision of health care, it is equally
easy to realize the “domino effect on the unavailability of
physicians, nin”ees and all those providing health services to the
comeunity. It wiil indeed be a sad day when its people will no
longer be able to obtain prompt attention for their health problems.
Many people have already stated they would not remain in Eastport.
The tact that the hospital has served the conmiunity well, will
be of little consolation to those who will need to travel a distance
of twenty—eight alias end there, hopefully, obtain their medical
care.
One need not to be reminded of the economic effect on the
coi’usu ity of the possible closing of the hospital. Although small
In comparison to large oozn iinIt lee, the loss of an annual pa roll
of $il 6,00O and expenditures for other services of $100,000 will
have its profound deleterious effect.
And now, conversely, If approval is granted for a major
industrial complex and, perhaps along with related industries to
locate In Eastport, it undoubtedly will, provide an entirely different
picture In the provision of health care and the welfare to its
residents.
An influx of people over a period of years will require the
services of more health personnel, and the facility in which to
provide It. Admittedly, there can be some difficulties in providing
this service. However, the situation would essentially be no
different than In the Quoddy days, at ithich time a new hospital
was constructed, several new doctors and related hospital personnel
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moved into the area. Thus, services beoaae available when the
need was determined.
It 18 my sincere belier that failure to approve construction
of any Industrial development could soon sound the “death knell”,
of the hospital and the entire medical care to the community.
Conversely, Its approval will not only retain Its present status,
but more importantly, greatly improve the provision of l alth care,
the welfare and the well being of the community.
As of this date the hospital is facing a crisis. We have
requested an extension of time for the reissuing of Ite annual
license from Dec. 31, 1976 to Feb. 5, 1977. Your decision is of
such vital Importance to the hospital that we feel this time-extension
request was justifiable. It Is my belief that State and Federal
authorities wiLL grant this request.
Shou..Ld, however, the permit ror construction be denied there
remains a definite question in my mind whether the hospital should
even attempt to make the alterations necessary for reltoenaing.
Recent reductions by the State below reimbursable costs could well
place such a financial burden upon the generosity of our citizens,
or upon the taxpayer, that it would become en impossibility. Neither
Is there any assurance that ur license would be granted If the
economic future of the community still remains in doubt.
I fully appreciate the desire of those who wish to have Eastport
maintain its “status quo”. However, with the many complex problems
facing a community today in complying with Governmental requirements
It seems rather obvious that it must either go ahead, or go backward.
Its future, indeed, to me, is doomed unless there are to be drastic
i.mprovement a.
There are those who tear an influx of people as tho It were
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—5—
another form of pollution. The cider residents will, however,
recall that Quoddy, the National Youth Administration end the Sea
Bees days did not wreck havoc to the community. No days were
brighter in Eaatport when the Army Corp of Engineers started to
build Quoddy. Circumstances beyond control precluded its completion.
There are those who fear pollution of the environment. I am
aware of references to possible formation of sulfuric acid and
noise. However, it Is my belief that State and Federal Environ-
mental Protection regulations, with their strict enforcement, can
only make Eastport a much better place In i iIch to live.
My comments have been limited to the presumed effects on the
health and welfare by the denial or the approval of an application
of a major industrial complex to locate in the City of Eaatport.
However, one cannot have lived In a community for thirtyu’eight
years, been involved in its administration for a portion of that
tine, and endeavored to Imporve its status - - and still be unaware
of the economic “downgrade” that has transpired. This aspect of
our community can beet, however, be presented by other citizens
more directly involved in the business world.
May I express my appreciation to you, should you have continued
to read my thoughts. They have been given in a sense of deep
sincerity, and of utmost concern for the citizens of Eaetport.
34 4 r 1y,
, -
( aai- C. Bates, M.D.
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Eastport Memorial Hospital
The Eastevnmost Hospital in the United States of Ametica
Easiport . Ma In. 04831 T .IspIions 853.2531
November 30, 1976
U.S. Environmental Protection Agency
Region I
Enforoementa Division, Permits Branch
John F. Kennedy Federal Building
Boston, Massachusetts 02203
NPDES permit Application
Number: MF002214.20
Corps Permit Application
Number: 2 -76—367
Gentlemen:
At the November 8th meeting of the Board of
Trustees of the Eastport Memorial Hospital, the motion
was passed unanimously “that the Board go on record to
endorse any proposed economic industrial development in
Eastport providing it oompliea with .11 government and
E.P.A. regulations.”
Ha Riohar son
President, Board of Trustees
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133.
MR. RICHARDSON: Gentlemen, at the November 8th
meeting of the Board of Trustees of the Eastport
Memorial Hospital, a motion was passed unanimously
by those present that the Board go on record to
endorse any proposed economic industrial development
in Eastport , providing it complies with all government
and EPA regulations. Thank you. Harry Richardson 1
President of the Board of Trustees.
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MR. MARSHALL: Mr. Chairman, my name is George
Marshall. I am Director of Development and Placement
at Maine Maritime Academy. I am here as the personal
representative of Admiral Edward A. Rogcrs, Supcrint-
dent of I4a r t aritime Ho e :
regret that he cannot be here in person. but he had a
prior commitment to attend important meetings in
Washington. D.C. Accordingly. I will read a letter
addressed to you from Admiral Rogers.
“Mr. McGlennon:
This is to certify that I have authorized Commander
George M. Marshall to read the following statement on
134.
behalf of Maine Maritime Academy at the hearings
concerned with the Pittston Project and scheduled
to be held at Shead Memorial High School on 3 December
1976. in Eastport. Maine:
‘The superintendent of Maine Maritime Academy
considers the Pittston Company. Eastport. Maine
project as a source of job opportunities for Academy
graduates aboard U. S. flag tankers and tugs, as
pilots and in marine support positions ashore. In
this respect I support the Pittston project.’
Sincerely, Admiral E. A. Rogers.”
153—1
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M,%JNE M/tKI’IIMI: AAI)IMY
CAST1NE, MAINE (M421
1 December 1976
Mr. John A. McGlennon
Administrator, E.P.A., Region 1
2203 3. F. Kennedy Federal Building
Boston, Massachusetts 02203
Re: The ?ittston Company, Eastport, Maine Project
Dear Mr. McGlennon:
This is to certify that I have authorized CDR George M.
Plarshall to read the following statement on behalf of
Maine Maritime Academy at the hearings concerned with
the above project and scheduled to be held at Shead
Memorial High School on 3 December 1976, in Eastport,
Maine:
The Superintendent of Maine Maritime Academy considers
the Pittston Company, Eastport, Maine project as a source
of job opportunities for Academy graduates aboard U. S.
flag tankers and tugs, as pilots and in marine support
positions ashore. In this respect I support the Pittston
project.
Sincerely,
, . A. RODGE
1 ”R.ADM, US 1S
SUPERINTENDENT
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JTATDfnFr OF WILLIAM C. BULLOCK, JR., PRESIDENT, MERRILL BANKSHARES
‘OMPANT, BANCOI, MAINE AND PRESIDENT OF THE MERRILL TRUST COMPANY,
WITH BRANCHES LOCATED IN EASTPORT, CALAIS, ODLAND, MAChAS AND
JOU POrr, MAINE.
EPA Il AlINC - EASTPORT, MAINE - DECEMBER 3, 1976
CO?Q TS (IN DRAFTED ENVIRONMENThL IMPACT STATEMENT:
Merrill Bankahares Company is one of the largest banking
oTgan.izations in the State and through its predecessor companies
has been in business for over one hundred years. During that
period our bank has been very aware of the unique economic problems
of Washington County and its banking needs. Today, we employ some
. S/y
50 people in our - Itrt . branch locations and we are, by far, the
largest financial institution in the County.
There is no question that Washington County has been and
continues to be one of the most financially depressed counties in
our State. Over the years we have seen both Federal and State
economic solutions, such as the Quoddy Tidal project and many others
promi3ed but never coming to fruition.
We believe at these hearings today that the subject of
environmental impact and risk—taking has already been covered. After
extensive hearings by our own State of Maine Department of Environmental
Protection an affirmative vote by the Board to issue a license to the
proposed Pittston Refinery was given. Today, our company wishes to
address itself to the most favorable effects that this project will
have on the economic advancement of Eastport, Washington County, Bangor
and the v ole State of Maine.
154 1
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As a .eaber of the Action Coit tee of 50 vs supported the
non—biased study undertaken by Dr. Arthur Johnson of the University
of Maine on the socio—econonic iapact . of the proposed refinery. We
have reviewed this study and endorse it with the caveat that, if
anything, it is overly conservative. It is the opinion of our bank
that the .ultiplier effect of added payroll and industry in the
County would be in the neighborhood of $7 to $9 million in bank
deposit. which, in itself, would provide additional bank funds for
investment in WaIh(ngton County in cons mer, real estate and
coercial loan. end support . awhere between three and six addi-
tional banking facilities.
Already our bank has received approval for a second branch in
E.stport which would require a capital inveltuent in the vicinity of
$100,000 and provide an annual payroll in the neighborhood of $30,000
to $50,000. Manming five other bank branches, we are talking about
a capital investment in our industry alone between $500,000 and $750,000
and added payroll between $150,000 and $250,000. This is just an in-
dication of what this st inportant undertaking would be to the
i king industry alone is the County.
As a most important manber of the business co nity in Wash—
i jton County, our bank has been concerned with the environmental
iNpact of the proposed Pittston Refinery. We are satisfied that the
Maine Department of Environmental Protection’s decision to grant a
licemee for the refinery, after a oat thorough environmental examination,
-------
aseures us that the enviranuent will continue to be protected.
Consequently, our bank, today, wishes to be placed on record at this
hearing as being most strongly in favor of the Pittston Company’s
application to construct an oil refinery in Eastport.
154—3
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Mr. Chairman, my name (a Widg.ry Thomas. I live in South Freeport, Maine. I
am Chairman of the Board of the Canal National Bank and President of Canal
Corporation, a bank holding company.
Because economic Impact is now recognized In the State of Maine and throughout the
United States as part of the environment, I would speak of the economic desirability
of the proposed Pittston refinery in Eastport, Maine. We should recognize the need
of most Maine citizens to earn a living wage so that they may enjoy the benefits of
Maine’s environment.
Washington County with its critically high unemployment rates, needs a massive InfUsion
of both capital and development effort which will result In substantial employment In
order to alleviate its critical unemployment situation. It would seem to me that the
expenditure of nearly $700,000,000 on the refinery and the resultant employment will
have the effect of substantially easing the troubled economic condition of this area. The
investment of private capital, In my opinion, l the ideal economic stimulant for eastern
Maine. in th. banking Industry we recognize the Improvement on the lives of ill of the
citizens of a wide area of such a large Increase In income to the economy of an area
as the $0 to 30 million annual construction payroll that Is forecast will be paid during
the construction of the refinery. We are very committed to the value of the permanent jobs
that arc created after the refinery is built. It is my understanding that approxImately 300
permanent Jobs will be provided and that 200 other workers will be employed in contractural
services; and. finally that, indirectly, 600 additIonal jobs will result from thc presence of
the refinery. 1100 new Jobs in a distressed area such as Washington County will obviously
hay, a most beneficial permanent economic impact.
The 300 basIc refinery or manufacturing Jobs alone, according to the latest statistics
155—1
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available to me, would result in approximately 33,000,000 in personal income, and
would result in ultimately 31,500,000 in bank denosits and Si. 700,000 in additional retail
sales. I am sure that the federal officials recognize the multiplier effect that manu-
facturing dollars have on the economy of any area because they provide a constant sourae
of new money which has this multiplier effect. And I wish to stress, a refinery, in the
sense that It takes a raw product and turns It into S different product, is a manufacturer.
As past president of the Maine Bankers Association and president of a statewide banking
operation, I am concerned with the economy of the State of Maine as a whole and feel
just as strongly about trying to improve the economy of Washington County and Eastport
as I do of Cumberiand County where our head office is located.
During my term as president of Maine Bankers Association, I traveled extensively throughout
the state and found that a cross section of people with whom I talked were desirous of
obtaining the Pittston refinery for Maine.
Finally, I state that I am an enthusiastic sailor and have cruised my boat the entire coast
of Maine and recognize the precious resource of our coast - and firmly believe that it must
be protected. I have been through the Lubr Narrows and Head Harbor Passage to sail
with
into and around Passamaquoddy Bay. It is my opinion that/the present federal and state
requirements for protection, the Eastport refinery will not have any adverse effect on the
Maine coast and viJl be a distinct asset to Maine, New England, and the entire northeast
quadrant of the United States.
•1
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101.
MR. COHEN: Mr. Chairman, my name is Nathan Cohen.
I am presently serving as a member of the Governor’s
Executive Council of the State of Maine. Washington
and Aroostook Counties make up the Seventh District
of Maine 4 which I represent.
For the past 30 years I have been a resident of
Eastport. 28 of these years were spent operating a
clothing store on our Main Street, from which I retired
two years ago. I am very interested in civic and
political affairs, having seryed on the Eastport City
Council, presided over the Washington County Chamber
of Commerce and the Washington County Development
Corporation. I have served as a member of the Small
Business Administration Advisory Council and the Maine
Health Facility Authority, along with many other state
and local organizations.
During the past years I have watched with dismay
and disappointment the steady decline in the economy
of our area. No one knows any better than I the strong
efforts that have been made to reverse this unfortunate
situation. In many cases tax reductions and other
156—1
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c 9
102.
attractions were offered to bring new industry into
this area. recall of two such industries who
located here for a short time, but either left the
area or were forced to go out of business. The reason
for this is a rather simple one: due to our geographi-
cal situation, location, we are just too far away from
the market. Transportation costs for bringing the raw
materials here and shipping out the finished product
are just too great. Industry just cannot compete with
these added costs. If only we could solve this problem
by just picking up Eastport and transplanting this
area near Boston, New York. Philadelphia, or some
larger area, but this we know is an impossibility.
When this universe was created, Eastport was blessed
with a great natural resource, which is practically
untouched. I am referring to our well protected deep
harbor. The Pittston Company has recognized the
potential of this harbor and has developed a proposal
to build an oil refinery in Eastport.
We should be deeply concerned to learn that 98% of
all homes in Maine are heated by oil, and that 60% of
all electricity generated in Maine is through the use
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103.
of fuel oil, when the national average is only 36%.
There is not a single refinery operating in the six
New England States. Washington County is larger in
area than the combined states of Maryland and Delaware.
and the location of Eastport in this county appears
to be the ideal setting for an oil refinery.
Former Energy Chief William Simon, in a speech in
Boston in 1974. urged New Er)gland to do everything it
could to locate an oil refinery in this area. “Here
in New England. where consumption exceeds 1 million
barrels a day. there isn’t a single refinery operation
in the entire six state area. For your sake, as well
as for the nation, this region must do all it can to
encourage any refining capacity. capacity keyed to the
product needs of the region capacity. capacity built
in a responsible way with the greatest possible economic
development.”
Rogers C. Morton, Interior Secretary. stated that
the reluctance of some persons in comunities such as
Eastport. Maine and Durham, New Hampshire in the con—
struction of refineries is “understandable but outdated.”
In fact, he said that the public had not bothered to
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104.
find out how clean a modern refinery can be. “How
many people in New England or in my own State of
Maryland know anything about how clean and attractive
a modern refinery can be? How many people have visited
the ARCO plant in Ferndale, Washington, the Exxon plant
in Benicia, California, or the Mobil plant in Joliet,
Illinois? The mental image of a refinery to nine out
of ten people on the eastern seaboard is something
that stinks, smokes, fouls up the water, turns paint
yellow, and is a general nuisance.”
This area has gone far too long as an economically
depressed section of our country, with a record number
of people on welfare, unemployment, food stamps, and
other forms of assistance. People here do not want
charity. They want good paying jobs assuring them of
a decent living. I do not think that that is too much
to ask. The time has come for us to become a part of
growing America. Construction of the Pittston oil
refinery and the satellite industries which would migrate
here would create new jobs. This refinery would estab-
lish a new tax base for Eastport and Washington County.
These are but a few of the many benefits that will be
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105.
derived from the building of this refinery.
Gentlemen. thank you for giving me the opportunity
to express my views on the proposed Pittston Oil
Ref inery in Eastport.
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141.
Captain David Kennedy.
MR. KENNEDY: Gentlemen, my name is David Kennedy.
I am a seafaring man, former tanker master, Panama
Canal Pilot, and more recently VLCC pilot in the St.
Croix, Virgin Island, refinery area. I am here as an
independent, unpaid observer, working as a citizen of
Maine and because I realize I am one of the very few
VLCC pilots in this area or in the United States at
the present time.
I want to speak only on the technical aspects of
bringing VLCCs into Eastport. When the proposal was
first made, I addressed the Pittston Company and the
State of Maine, telling them my qualifications and
expressing an interest in what they planned to do.
I worked with the Pittston Company at various times,
always as an independent, and they opened their books
to me, so to speak, with their full knowledge of what
they planned to do, how they planned to bring VLCCs in.
I determined after a period of time, a period of
study, that properly done with a high degree of precision
and support that the plan is viable and VLCCs and other
tankers can indeed be brought into Eastport on a regular
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142.
basis safely. It requires perhaps not so much a
departure from traditional piloting methods as a
heightened degree of precision and the use of tech-
niques which have evolved in harbors which accept
VLCCS. I refer in particular to electronic aids
which give the exact approach speeds, radar positioning.
as well as computer forecasting of the projected path
and the estimated time of making each turn of comuni—
cationa in which the control pilot does very little
except work with the ship itself, and he has supporting
pilots to take care of communications. This team
effort works out very well, and I recormnended it to
Pittston and they accept my recommendations.
In connection with this particular plan, I would
like to makc thi e prop Dsols. or rather concur in one
and make two others. The first one I regard as very
it çortant, perhaps not so much to me - I am confident
that the job can be done safely, but there are many
people who are not sure that this task of bringing
VL.CCs or other ships in with the current situation.
the tidal situation here, is a safe and practical thing
to do. The proposal to b j ,nq a vessel, I would say a
bQ
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143.
100.000 ton ship, into this area with three or four
tugboats, bring it in as we would bring it in if there
were a dock there, hold it in the dock area, bring it
back out again under varying conditions, is an excellent
one and it should be done before the first pile is
driven.
The second proposal would be to make use of the
recent technological advance which is called the ship
simulator. Dr. Eda, a man who I have great respect
for and have worked with before, has assisted in the
development of this ship simulator. What he has done
with a computer can be done by actually building a
mock-up of a pilot house of any size ship that you
care o. ha ir ; a £r . a.L mock—up of the harbor intended,
and ha’ n a T -c! rocced ‘ ha ’ harbor in
accordance with the ,com.iiands given by the control
person, and a TV screen actually changes in front of
him as if he were looking out at the bow of the ship.
With this as a tool — it is not a substitute for actual
training on a ship, but used as a tool, it can give
vital information before the actual fact of, as was
mentioned earlier, the degree of tide that can be safely
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144.
handled, the times of tide when it would be best to
avoid movements. This is a present fact that can be
put into use on this project, and I would strongly
recommend it.
My last reconmiendation has to do with the fact that
in my experience very wise and dedicated practical
operations men have had their recommendations contro-
verted by accountants. Accountants generally take over
corporations. They look at things in terms of cost
effectiveness, and it is very hard to justify something
which is a safety recommendation in terms of its cost
effectiveness. I have no doubt that Pittston intends
to carry out what they have proposed. Indeed, in my
time of working with them, I know of no other company
that has gone as far as they have to close the fearful
and unconscionable gap which lies between the level of
our technDlogy in our harbors and that of the technology
in Europe. for example. They propose to close that gap
intheir plan for developing Eastport. In order to see
that their operations men are not contraver ted by their
accountants, I would like to see a watchdog commission
established which would have the necessary authority
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145.
to stop any operation which would be a deviation from
an agreed upon plan, and which would in effect see to
it that Pittston at all times did what they had proposed
to do.
I believe that these three suggestions will go a
long way towards allaying the fears of responsible
people who do care ab3ut this state and do care about
this area and actually have valid fears as to the safety
of this.
Thank you.
MR. McGLENHON: Thank you, Captain Kennedy. Wait
a minute, Captain Kennedy.
MR. STICKNEY: Captain Kennedy, have you operated
a ship with a pz rt control system in use?
M . KENNEDY: Yes, sir, I was part of developing a
port control system in St. Croix.
MR. STICKNEY: And do you operate down there under
low visibility conditions and that sort of thing?
MR. KENNEDY: No, sir. That would only happen in
squalls, and of course you would not come in during a
squall.
MR. STICKNEY: So that was for separation of traffic
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146.
more th3n anything else?
MR. KENNEDY: No, sir. It was an integrated system
with the objective of bringing the ship from the open
sea to a safe berth alongside, and it was a comprehensive
system. It was not a traffic system. I am at present
working in a traffic system in New York Harbor. I am
on the advisory cixmnittee there.
MR. STICKNEY: Just out of curiosity, because we read
abo .zt it so much, say mid—way down the passage at 4 knots.
if a ship had to stop. how long a distance would it take
to stop it?
MR. KE JEDY: Off the top of my head I would say, at
4 knots. a 250.000 ton ship. neglecting the tide, would
stop in approximately six—teflths of a mile. If u have
a knot of tide, it would takc a bit ‘onger.
MR. STICKNEY: Thank you.
157—6
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JW RR1’L.L TRA N SYPO’F T COL
$037 ORE5T AVrNUE. Po,,-fl ANO. MAINE 04$04
AM(A ( ObI 20? 1)7 6II
flecer’ter 1, V)76
The “erters f the k rirr ’ Bn rd
rittston ‘efirery
( ‘.er;t1et en:
‘y nare is r u1 ‘errill of rnrtland, ‘aine. I ar 1nve1 ” vi Ir tho transnnrtatic’n
t usine s, 1ur’cr r ,anufacturinr, and 1. usir.ess ‘e’rn1e,r nt in ‘ aire I sreai’ for
over ( , ‘ ‘( ‘ ‘aire “ erLirm nnc,nle frnr t.3 corrunitie thrr,urlrut
“aire t’ arc crncern d at out ‘air ’s ecrnrrv anr arc• i’ryinus for rnv l f this
rlttstOn “ firery rroiect !v’re In F st” rt. I have att c ed shretc r their
sirn tures and the tc :ns the” are fror.
I stronril” tI!’rert this nro ’ncpd refinery, ar !iav r’en crrnsic cratle research
on the adarta i1it” of the r rn.1ect to thi’ area. asIcn11v, I ro not krot ’i of a
rore adaoVt5lp location. “a’ ’ I nare a fei reasons:
1. The availability to ferelen oil, hich we are rore de’ endent en each year.
2. The closeness to the East Coast off—shore drillino as it develons .
3. The deer ater anc! nrotected harbor. iastrcrt i an c,ldtire sea nrt
that has h d larec fishing’ vessels and lame sailinn shl s trounht intn
the harbor on a daf lv bacis since this country was first settled. Just
ston ?nd ana1 ze the fact that an’s flrr ‘ -ith thc ability and technn!nr’y
to build a 7 (Y) millinn dnl1 r refinery certainly is cc ’rrotont to ‘ lan
for tIie successful deliver” nf the source of su p1y of its raw raterial
in a safe and nrdcrl ’ ranner.
— I SERVING NORTHERN NEW ENGLAND
‘158—1
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-.2 - (j! )
It rust be recr,t’nlzed that to do ctherilse ould leonardize the
success of the i4wle pro.lect. They il1 not be this neolfoent. I
have he2n fart liar and dealt ‘ith the Pittston Ccrnanv off and on for
rany years and the resoonsibilltu 1th hlch they handle their or ’ ration.
I have never found thor iacPinr’ for careful and cr’r”otent action.
urnp “nu not to let sore cronic, n.’rative, scare tactics, a crall
ser’rent of our state’s ,onulatirn, ef’ect v ur nesitiy thinl:inv’ about
(astoort l’arbor .
4. e all are farqiar idtl! the 1 nd to ? e occiriel and the aroa ti h
develr’ r d. The location Is rost ii’eal.
S. P’n riace it ‘aine reot 4 s the ec.’ nory t t this nri i.ct •‘ii1 d ’oio
•nwore t ian %‘as iinoton fount”, and ‘artlcu)arl? Eastoort. You :iust
vwed to looP around.
6. Thc State of taIne, one of the ciliest nc’rth.’estcrn states located
within 500 rIles f close to 50 pdlllon pooulatien as well as sn’e
of the rost heavily crnspntrated enero ’ us ln? iants In the feuntry,
is ertitled to have located In Its state a wnfect f this size that
will assure stead ’ e,’ølovrent and stc d tax revernrn -to our cnrcunittes
and state.
7. The spin off developrent in this are., as ‘-eli as tlireui4inut the ctate,
t’hich involves evervthf no fror rotels to rachine shops to ianitorial
services, and so It roes, tho l1 t Is cndlv ss and “alne needs this
type nf oro iect to orovide ctiverzf fled “ots, The torPinr ran needs a
better chance.
-------
.3—
I knot: you have the oh f1r ures and the tax firrurec that this wiU ‘enerate
so will not d ell on the detail of ecrrnoclc irpact. I do wish to say that
I have been to ne : r.odern refineries in Louisiana. I have been to Prudhoe Bay
in Alaska and ecn the deveinprent of that ‘ rn. ect, I have visited dth the
Fluor C rnnration in ins rnrole , California, one of our c utry’s leadinr’
desinners of refincriec, and have seen nersenall:’ th i’reat care nd action
that tales v’lacc to !‘ulld a ry ipct of this ra”natuc e that is oreratinrally
attractive) envirnnr’Cnt?ll protective nf our natural resources, ir nrr’ves
our ctrndard of livino and Is dv!clrrned tc protect the health of the area.
“any of us have tafled and visited with ‘ enr’le livine in a re’iner, crwrunity.
They h’ve told and shr n us the satisfactien and cnrpataMlltv of beln ’ in
the sare cor unit” with a ‘rnlect of thIs t ”e and ‘e in “aine are anxicus
f r the o irrtunity to have this refinery *,rri 4 Cct by ritt tnn be niven rierrission
to bec one a rea Ii t’.
! t r.ore can y say — ‘.e ant it — ‘ reed it — and c’re entitled to It,
!?e urrcntly rer uest your favnrable decision.
Sinned_______________
nd attac”ed supporters for the
rttts ton r efinery
PF /b t
158—3
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W i ths . sfgi.d ii. iro wsrtta po l, ..d irs $at.rsstad Is the fwtww
of Ins w1t , re iad bsttsr Jsbs rsq t ths £. P. . to ap tius bofidhug
of tb. rsflasry b, Ptttt tt’ , o at Eastport P 1 l t C($11 SWM T
mrs P xcy.
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1S —4
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by
CLARK H. NEILY (,4 j1
At The
HEARING IN EASTPORT, MAINE ON THE PROPOSED PITTSTON OIL REFINERY
Mr. Chairman and members of this hearing body, my name is Clark Neily,
a resident of Gorham, Maine, I am Executive Director of the Economic
Resources Council of Maine and have been authorized by Its Board of
Directors to speak in support of the proposed P1 ttston refinery at
Eastport.
The Economic Resources Council of Mainess membership is composed of large
and small corporations as well as individuals from throughout the State of
Maine and numbering approximately 500 in its membership. The above number
of members has not been expanded to include collective memberships such as
unions, nor does it Include large numbers of employees of member companies.
I am also authorized to speak In support of the proposed Pittston refinery
by the Industrial Development Council of Maine which is composed of approxi-
mately 85 individuals from throughout the State of Maine whose primary
ençloyment is in the field of business or industrial development. I am
President of this organization.
Because I am not qualified to speak on the technical aspects of the location
of the refinery and pier in Eastport, I would therefore stress the economic
159—1
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Statcrncnt by Clark Nclly
Oece.ther 3, 1976
Page -2-
implications of the location of this refinery in Maine.
We in Maine. must find a way to take advantage of the deep navigable
waters along Our coast. The Maine coast along with its woodlands represent
Maine’s greatest natural assets.
I a. told that If you measured Maine’s coastline with all its indentations
that It would actually be 3,000 miles long. It seems to us that at least
o or three of these 3,000 miles might well be used for heavy Industry.
We have been advised that this refinery, If built, will result in the
1oyment, over a three year period, of an average of 1500 construction
workers with a $20,000,000 to $30 000,000 annual payroll. The permanent
loy.ent is estimated to be 300 people directly employed by the refinery;
200 people employed In contractural services for the refinery and approxi-
mately 600 jobs Indirectly brought about by the presence of the refinery.
I, too, was one of 51 Maine citizens who journeyed to New Orleans and
have inspected an absolutely clean refinery (Gulf’s Alliance Refinery on
the Mississippi) and also have landed on drill rigs in the Gulf of Mexico.
I know first hand that we can have clean refineries without any appreciable
damage to our environment.
159—2
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Statement by Clark Nelly
Deccmber 3, 1976
Page -3- ._
For most of the last twenty years I have worked in various development
positions dedicating most of my efforts toward trying to create new jobs
in the State of Maine, and to make at least some of the areas of Maine
economically more prosperous. I know what these construction jobs and what
the permanent jobs mean, not just to Eastport and Washington County, but
also to the State of Maine. It is very hard to measure the effect of each
dollar spent in wages In such a project, but almost every economist agrees
that there’ll be a multiplier effect of that dollar turning over at least
four times before it gets put away permanently in a bank account, and some
economists say up to seven times.
The State of Maine has two major problems at this time. The first is
unemployment, and this project certainly speaks to the problem of en 1oyment.
The second is taxation. The State of Maine now ranks approximately 10th from
the top in per capita tax burden which its citizens bear. It also ranks 42nd
from the top in average income per capita. We keep trying to address ourselves
to these major problems of unemployment and the burden of taxation in a fairly
poor state.
While Maine has one of the highest unemployment rates in the country
Washington County has the highest in the State. Unemployment in Eastport
Itself has been estimated to range from 22% in August of 1975, when seasonal
159—3
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Statt’mcstt by Clark Molly
Deccu ,er 3, 1976
Page - 4 - (2)
e p1oyment was at its high point for the year,to 43% in January of 1976.
In the last analysis undertaken of income per capita, the per capita
Income for Eastport was only $2,118 which is 45% below the national
average. It is not difficult to see therefore why the young working
age native population of Eastport has been forced to leave the area to
seek employment in other areas of the country. It’s not that these young
people want to leave, It’s that they must leave In order to earn a living.
The preliminary Environmental Impact Statement seems to indicate that
environmental considerations have been satisfied, and certainly we recognize
that the State of Maine’s Board Of Environmental !rotectlon which very carefully
scrutinizes all of the development proposals of the State and took two years
to scrutinize the Pittston proposal was finally satisfied. If these agencies
are satisfied that there is going to be no environmental degradation as a
result of the Pittston Refinery being built In Eastport, then we cannot
conceive of any group having the right to deprive Maine citizens of the
economic opportunities presented through this proposal. We feel that It is
selfish and narrow of these groups to deprive Maine citizens of job opportunities,
of tax relief through the additional taxes provided through such a facility, and
the provision of refined petroleum products within the State itself assuring us
of a more constant and guaranteed source of supply.
59—4
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iii
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Gulf’s new 180,000 bbd Alliance Refinery is one of the l irgest
grass roots refinery ever built in the U.S. Since it went on
stream in January 1972, Alliance has been producing a range of
products including gasoline, heating oil and jet fuels which
are delivered to markets between Louisiana and the North East
through the Colonial Pipeline system.
159—6
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( -3,
FACT SHEET
ALLIANCE REFINERY
GULF OIL COMPANY - U.S.
BELLE CHASSE, LOUISIANA
PHYSICAL DATA
Alliance Refinery is located on a 700 acre tract on the West Bank of
the Mississippi River at Myrtle Grove, Louisiana, 20 miles south of
lie, Orleans.
Site preparation began in 1969. Some 2,300,000 cubic yards of sand
van dredged from the Mississippi River to raise and slope the site and
300,000 cubic yards of clam shell fill spread for road and working sur-
faces. About 25,000 timber and steel piles were drive 1,850,000 feet,
or 340 miles, to support operating units. 75,000 cubic yards of concrete
and 10,000 tons of structural steel were used in building the refinery
and 1,000,000 feet of piping of all sizes was installed.
Brown & Root, prime contractors, employed 2,400 men including 350 engineers
in constructing the refiner ’, the largest single building project ever under-
taken by Gulf.
The refinery went on stream early in 1972. It employs about 350 people,
including 110 contract maintenance people.
159—7
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APACITY AND PROCI SSFS
Alliance is one of the nation’s largest grass roots refineries. It
is capable of processing about 180,000 barrels of crude oil per day.
Major installations include:
160,000 b/d atmospheric and vacui unit
72,000 bId fluid catalytic cracking unit
28,000 b/d HF alkylation unit
41,000 b/d naphfining unit — Gulf designed naphta hydrogenation unit
22,000 b/d Gulf iner — Gulf designed jet fuel hydrogenation unit
16,000 b/d Gulf iner — Gulf designed cracked furnace oil hydrogenation unit
37,500 bid catalytic reforming unit
22,500 bId aeroo*atic extraction unit to extract benzene, toluene and
zylenes with sulfolane
4,600 b/d thersal hydrodealkylation unit to convert toluenc to benzene
16,000 b/d delayed coking unit
40 Ton/day sulfur recovery unit
The refinery has an oil storage capacity of some 5,600,000 barrels which
includes 41 tanks and 11 hortonspheres.
159—8
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! LEFTNIKY PR0CF SI S AND EIIELCON!;F.KVATIAN
Fuel to run the plant comes from refinery gases, supplemented by outside
natural gas. Two 350,000 pound per hour CO boilers, operating on off—gases
from the Fluid Catalytic Cracking Unit’s regenerator, product’ most of the
refinery’s steam demands.
Most electricity is purchased from an outside supplier, but before the
off—gases from the FCC’s regenerator enter the CO boiler they pass through
a power recovery train consisting of a gas turbine expander, blower, motor-
generator and steam turbine to generate about 20 percent of the refinery’s
electricity requirements.
CRUDE CHARGE AN!) PRODUCTS
Crude oil is supplied by Gulf’s onshore and offshore South Louisiana wells.
The crude comes to Alliance through a 37—mile, 18—inch pipeline from Gulf’s
Bay Ilarchand pumping station. iso and normal butanes are delivered by barge.
Products move through a 144—mile, 20—inch pipeline to an input station on the
Colonial Pipeline System at Collins, Mississippi. Petroleum coke is loaded by
conveyor belt onto barges tied up to one of the two docks serving the refinery.
The other dock can accoemodate barges and tankers up to 50,000 tons for water
shipment of LI’ gas, benzene , carbon black fecdstock and prime fuels.
Finished prime fuels are not stored at Alliance Refinery. Instcad, individual.
blending stocks are held in tanks and the finished product blended as it is
moved into the transmission pipeline or to the dock for barge or tanker shipment.
Gasoline blending is controlled by analyzers that continuously monitor research
Octane number, motor octane number, vapor pressure and critical distillation
points.
159—9
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The refinery’s product. include: Rotor gasolines, jet fuels, diesel fuels,
home heating oil, propane, benzene, carbon black feedstock, sulfur and
petroleum iuke.
!Y ROt 1ENTAL CONTROL
The amount of water needed by the refinery has been minimized. Sixty percent
of the cooling is done by air.
What water is used is analyzed upriver from the plant, treated for impurities
on entering, and re—cycled whenever possible. Clean water is kept separate
from pollutants and fed directly back into the river. Waste water is segregated
into five separate sever systems and treated according to degree and type of
contamination to avoid upsetting the ecology of the river.
Air conservation facilities include special treatment equipment to prevent
pollution by carbon monoxide and sulfur dioxide. Flare stacks with smokeless
tips, floating roof tanks to minimize evaporation and a gas detection system
control the emission of light hydrocarbons into the atmosphere.
Oxygen monitors on heaters and boilers prevent the discharge of smoke and
special separators control the emission of particulate. into the atmosphere.
159—10
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STATEMENT
by
HAROLD G. LORIt4G
At The
HEARD G IN EASTPORT, MAINE ON THE PROPOSED PITTSTON OIL REFINERY
Mr. Chairman, representatives of the Army Corps of Engineers and of the
Federal Aviation Adn. nistration, my name is Harold G. Loring and I am
president of Construction and Building Trades Council of the State of
Maine. We now have between 4,000 and 5,000 Maine construction workers
as tnenters of this Council and when we add the families of these members
it would mean that we now speak on behalf of over 15,000 Maine citizens.
We are deeply interested in supporting the Pittston Refinery, not only for
the obvious reason that it will offer employment to members of our various
construction unions, but also because we feel that it will be good for all
of the people of Maine.
We know that the construction work force is estimated to peak at 2,300 people
with an average annual construction work force over a three year period of
over 1500 and average annual payroll of $20,000,000 to $30,000,000. There
are some who say that this is temporary employment. To those of us in the
construction industry, this represents permanent employment because it’s
by piecing together a number of major projects such as the Pittston project
that permanency is given to employment in the construction trades. In regard
to such a series of construction projects 1 we have been most fortunate in
1G 0—1
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tatcment by Harold G. bring
Der.ember 3, 1976
Page -2-
this past year In having a number of major expansions of various paper
companies within Maine which provided substantial employment to construction
trade unions. However, this expansion work taJdng place with our paper
companies is drawing to a close. We must now do everything possible to
reduce the unemployment gap whith will be created when these major projects
are completed. I doubt that there Is anyone in this room that does not
recognize the degree of importance of the construction Industry to the
State of Maine and how vital It Is to Maine’s economy. The proposed
Pittston Refinery will go far toward filling the unemployment gap that
we now face. We would therefore urge as strongly as possible, that this
project be allowed to move ahead.
In conclusion, It seems to us that If it’s good for the Northeast to have a
refinery In New England; if It’s good for the State of Maine to have refined
petroleum products iirinedlately available to the citizens of this State; if it’s
good for Washington County which} s been a county with very high unemployment
figures; if it’s good for the Town of Eastport because of the tax benefits
wnich are also shared with the State of Maine and finally, if it’s good for
the construction industry -— then why can we not have this project move
forward. It seems to the construction Industry that every aspect of this
proposal has been examined from an environmental point of view with extreme
thoroughness, in fact, in the construction Industry we feel that it has been
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Stattiflent by Harold G. Loring
December 3, 1976
almost too thorough. We would therefore, recognizing that there are
absolutely clean refineries in the United States, and that there are all
kinds of safeguards that have been developed to guarantee the clean and
safe operation of this refinery, do no other than urge Inriediate approval
of It.
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Dei.einber 3, 1976 ( —
THE UND RSIG ’ ID CITI1(!.S OF I’MNE are conc rnnd with the’ r.ono nic and rn’rgy future
of Maine and supf ort construction of the Pittston refinery at Eastport.
Auddled heroto are petitions bearing 420 sIgn turcs from rc idcnts of th following
eighty four (34) Maine convnunities
Auburn Gardiner New Gloucester South Paris
Augusta Gorham Uorr1dg ’ock South Portland
Bangor Gray North r,onmouth South Windham
Bethel Greene North Yarmouth St Albans
Biddeford Hartford Old Orchard Beach Standish
Bingham liollis Center Old Town Turner
Brewer Jay Oxford Vassalboro
Brunswick Kennebunkport Philips Wales
Buckfield Leeds Poland Wash iflgton
Cape Elizabeth Lewiston Portland Watcrboro
Caribou Lim lngton Pownal Westbrook
Casco Lisbon FaUs Raymond West Bath
Cornish litchf leld Readfield West Fal, outh
Cuøuberland Livermore Rockland Wilton
Cumberland Center Livermore Falls Rumford Windham
Dennys ille Machias Sabattus Windsor
Dexter Mechanic Falls Saco Winslow
Dixfield Mexico Sanford Wiscas .it
East Poland Monmouth Scarhoro Wootwich
Farm lngdale Mount Vernon Sebago Lake Yarmouth
Farieington Naples South liarpswell
Freeport
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‘4
35 —
STATB2 T
)br e is Robert H. Rez y, or Dainariscotta. I n Chairman of Tbe Maine
State Chamber of Cou erce.
The Maine State Ch iber or Casierce, fow Led in 1889, is the oldest state
chamber in the nation. Otu broad based business organization represents all 10031
ch uitbers or ca erce, statewide trade associations and all types of Maine busii ss
and Industry. The Cbiiib,r also links business and the const ner tIucxi a its
widely acclaiaed c iz or couz il.
We endorse the proposed Pittston Canp - Refinery at Eastport, Maine and
have supported this project since it was ilrst proposed. Maine is highly dependent
on the natsra]. reso ncss of its unique coastline and we have groat ccz ern for
the protection of anr marine and coastal enroim ont. Maine aixi New Ei ]and are
also dependent on iorei i oil and are very poorly prepared to cope with ener r
shortages and the need for lou-sulrur oil. Consequently, we reel that we must
accept sane degree oZ risk of envirorriental dinago, but we believe that sufficient
clean-up tec1mo].o r and expertise exist to alloii us to move ahead safely with this
project to assist in solving sane of our prob1 ns withont creating new ones.
The construction and operation of the proposed refinery will be or great
benerit to a chronically eccmcrd.ca]iy distressed area in Maine, that has for yi ars
sought relief fran. projects that haven’t materialized. Benefits to the taxpayer
and the cons snor i u1a provide a hoa1t r Input to an area sorely In need of such
With all of the unse.ccessful refinery proposals that have been made for Maine
In the past eight or nine years, the Pittston plan has particular significance
with the approval granted I the State’s Board or Envirannental Protection. After
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‘C
2.
two lears of iuteneivs i eetigati i aM c -eu pzbU ity, &uing iditch the
Mati State Ghaber of C erce tidos aM. suppwtLv. puibBn stat.waeuts that
i re aired c Maine telsvl.diat, we behave the euvir eut& f t u have been
We feel that the Pitttai C pax r has d onstrated the c iaci1 to saX e]y
aM operate a ref in.17 at Eastport, Main. aM we atr ig].y rsc aM that
giveusut .u i t be *uv1ded in carz71z tZd.s roJ.ct forward.
C*,doe.] the Stats Cb.4.r of C src. is interested In a good suvIxo t,
bet we are also lnt.re.tsd 1* the en .nvir .nt — the rights OX en 4-’ ii-vt a1
toworkata jobata].i’rlngwsgs scale.
Ws believ, the proposed rsfin.ay vil.1 enabi . a sis .abl . .e. nt of the
aM i p1ayed in WaaW tc Cv wtj to reach that a1.
161—2
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$ ‘ \1/ U NJ t L T1 T C 1—$/\IVI EL V- C)F ( C)IV1 - r1C Fi
L44 1W
4 1/ Ct ’iGRfSS ‘ ui(( i. PORRArii). p.*,titiI 4 I1 ) ‘ ;/. ‘i’i
October 28, 1976
Mr. Wallace E. Stickney, P.E.
Director
vironmeritai. Policy Coordination Office
U. S. vironmental Protection Agency
Region I
John F. Kennedy Federal Building
Boston, 14k O2 )3
Dear Mr. Stickney;
Because I will be out of the country on
December 3rd at the time of the public hcarin s
in Eastport, I am suboitting the enclosed written
statement exoressing the views of the aano State
Chamber of Commerce on the Pittston Company
refinery at Eastport, Ilaine.
Cordially yours,
cLcY-L
Paul C. flncrson
President
PCE/m
end.
, 3.; —
VI ( • M / I I ! itI.J’,I Nt S I . I• f :
161—3
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STAT 1U2IT B!
PAUL C. fl4 SCN
PR ID!74T, M?INE STAI!E cHAMBF. OF cc$Q1EI E
k77 cCI oB S ST I
MAINE okm
PB fl PITTSTU( CHPANT
R Th ! AT ZAS ORT, )4ADIE
OCTVB 28, 1976
161—4
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THE MAINE STATE CHM 3EH OF CO .U4ERCE, FOUNDED iN 1889, IS TIlE
OLD T STATE CHAMBER IN THE NATION. OUR BROAD BASED BUSINESS
ORGAI4IZATION REPRESINTS ALL lOCAL CHAMBERS OF COMMERCE, STATEWIDE
TRADE ASSOCIATIONS AND ALL TYPES OF MAINE BUSINESS AND JIWUSTHY. THE
CHAMBER ALSO LINKS BUSINESS AND THE CONSUMER THROUGH ITS WIDELY
ACCLAIMED CONSUMER COUNTIL.
WE EWDORSE THE PROPOSED PITTSTON COMPANY REFINERY AT EASTPORT,
MAINE AND HAVE SUPPORTED THIS PROJEET SINCE IT WAS FIRST PROPOSED. MAINE
IS HIGHLY DEPERDENT ON THE NATURAL RESOURCES OF ITS UNIQUE COASTLINE AND
WE HAVE GREAT CONCERN FOR THE PROTECTION OF OUR MARINE AND COASTAL
VIROM1Ü1T. MAINE AND NEW ERGLAND ARE ALSO DEFEDDEWT ON FOREIGN OIL
AND ARE VERY POORLY PREPARED TO COPE WITH E ’1ERGY SHORTAGES AND THE NEED
FOR 1.0W-SULFUR OIL. CONS UERTLY, WE FEEL THAT WE MUST ACCEPT SOME
DEXREE OF RISK OF EWVIRONME TAL DAMAGE, BUT WE BELIEVE THAT SUYFICIE! T
CLEAN-UP P HNOL0GY AND EXPERTISE EXIST TO ALLOW US TO MOVE AHEAD SAFE1Y
WITH THIS PROJECT TO ASSIST IN SOLVING SOME OF OUR PROBLU•IS WITHOUT
CREATING NEW ONES.
THE CONSTRUCTION MiD OPERATION OF THE PROPOSED REFINERY WILL BE OF
GREAT BEREFIT TO A CHRONICALLY ECONOMICALLY DISTRESSED AREA IN MAINE,
ThAT HAS FOR YEARS SOUGhT RELIEF FR )M PROJECTS THAT HAVER’ T MATERIALIZED.
BE EFr [ ¶10 THE TAXI’AY1 R AND THE COiNSUNEP WOULD PROVYDE A HEALTHY INPUT 10
AN AREA SORELY IN NEED OF SUCH SUPPORT.
WITH ALL OF THE UNSUCCESSFUL REFINERY PROPOSALS THAT HAVE BEEN MADE
FOP MAINE IN TIlE PAST EIGHT OP NINE YEARS, TIlE PI STON PLAN HAS PM TICULAH
SIGNIFICANCE WITH TILE APPROVAL GRANTED BY THE STATE’S BOARD OF ERVIHON-
MFMAL PROTECTION. AFTER T JO YEARS OF INTENSIVE INVESTIGATION AND
161—5
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cz
CURR121T PUBLICITY, WRING IICH ThE MAINE STATE CHAMBER OF C(1 1ERCE
‘NICE MADE SUPPORTIVE PUBLIC STATfl1 Th THAT WERE AJJ ) ON MAINE TELEVISION,
WE BELIEVE TI VIRO!*(E TAL FACTOIG HAVE B SUFFICIE4TLY EXPIDR ).
WE F . ThAT THE PITTSTON C(*WANY HAS DDIONSTRATED THE CAPACITY TO
BUILD AND ERATE A B ThERY AT EA.STPORT, MAINE A1 D WE STRONGLY
RECCJ4ThD THAT GOV (U T SUPPORT BE PROVID ) IN CARRYING THIS PPOJ T
) RWARD.
161—6
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I
NOV i
E I-4 1 B F D F c i i
4 ‘IT.RIY P1 ’ 1 T ANL .4
October 28, 1976
Mr. W&l’ ce E. Stick ey, P.E.
Director
Jkwironmental Policy Coordination Office
U. S. viromnental Protection Agency
Region I
John F. Kennedy Federal Building
Boston, MA O2 )3
Dear Mr. Stickney:
Because I will be out of the country on
December 3rd at the time of the public hearings
in F aatport, I am submitting the encloaed written
statement expressing the viewe of the Maine State
Chamber of Coemerce on the Pittston Company
refinery at atport, Maine.
Cordial].y yours,
Paul C • ereon
Presi dent
PCE/m
end.
K.’NG MAINE
161—7
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STAT IT BY
PAUL C ON
MflIZ E’tA t c&um 0 ? CCN Z
k77 G W R p r
P0 wlD, MABIB okm
PZ,FI Pi T $ CtIMI!
£ MD I I
c ,-i’ 28, 1976
161—0
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THE MAINE STATE CHAMBER OF COMMERCE, FOUNDED IN 1889, IS
OLD T STATE CHAMBER IN THE NATION. OUR BROAD BASED BUSIN1 S
ORGANIZATION RPR 4TS ALL lOCAL CRAMB OF COP*1 E, STAT IDE
TRADE ASSOCIATIONS AND ALL TYP OF MAINE BUSIN S AND INDUSTRY. THE
CHAMBER ALSO LINKS BUSIN S AND THE CONSUMER THROUGN ITS WID LY
ACCLAD1ED CONSUMER OO1JNTIL.
WE I24DORSE THE PROPOSED PITJ PON COMPANY REFINERY AT EA.S ORT,
MAINE AND HAVE SUPPORTED THIS PROJ T SINCE IT WAS FIRST PROPOSED. MAINE
IS BIGNLY D1P 4D T ON THE NATURAL R SOURC OF ITS UNIQUE COAS’IIINE AND
WE HAVE GREAT CONC 4 FOR THE PROT TION OF OUR MARINE AND COASTAL
fl1VIRONM 4T. MAINE AND N W !24GLAND ARE AlSO DERThD 2 T ON FOR GN OIL
AND ARE VERY POORLY PREFAPED TO COPE WITH 24ERGY SHORTAGER AND THE NEED
FOR 10W-SULFUR OIL. CONS1 U 1’LY, WE F L THAT WE MUST ACCIPT SOME
OF RISK OF 24VIRONMERTAL DAMAGE, BUT WE B LIEVE THAT iuii.LCIERT
CLEAN-UP T RJ4OIDGY AND ERTISE EUST TO ALlOW US TO MOVE AHEAD SAFELY
WITH THIS PROJ T TO ASSIST IN SOLVING SOME OF OUR PROBL IS ViT UT
CREATING NW ON .
THE CONSTRUCTION AND OPERATION OF THE PROPOSED REFINERY WILL BE OF
GREAT B 4EFIT TO A CHRONICALLY ONCMICAILY DISTR SED AREA IN MAINE,
THAT HAS FOR YEARS SOUGRT P1LTW FROM PROJ TS THAT HAV W P MATERIALIZED.
TO THE TAXPAYER AND TEE CONSUMER ‘ )11D PROVIDE A HEALTHY INPUT TO
P14 AREA SORELY IN N OF SUCH SUPPORT.
WITH ALL OF THE UNSUCCRSSFUL REFINERY PROPOSALS THAT HAVE BXF l MADE
FOR MAINE IN THE PAST EIGRT OR NINE YEARS, THE PITTSTON PLAN HAS PARTICULAR
SIGNIFICANCE WITH THE APPROVAL GRANTED BY THE STATE’S BOARD OF 21VIRON-
M ITAL PROT TION. Ari i YEARS OF INT ISIVE INVERTIGATION AND
161—9
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-2-
o Ic 1 rr u&tcn’r, Wbi$G M&ThE s?A ca* s or
1 xvicz MA 8 W Okrjv PUBLIC 8’Z*T I UT V 3 4IJ C I I MWIB TBL VISICI(,
VI IBLIZVI Z vij IIlI?AL ?AC U E&VZ RW uzz-J. i rnJ UFW .
VI AT B P L’I.lI COIWANT EAS __________ CAPAwxr ‘IV
WBLT Ui ABD A k - i z AT MAINE AJW VI S JY
____ AT G UI I? SUPPORT BE P )VI DI CARRYING ThIS P1 T
. • •1
•
70 .
161—10
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171.
MR. CRAM: Mr. Chairman and members of the committee:
My name is Bartlett Cram. I au an industrial and
economic development consultant in Bangor. Formerly I
was in steamship operations, and I am going to confine
my talk today in connection with that.
During President Eisenhower’s Administration, they
formed the National Executive Reserve, the United States
Government, and I became a member of the Maritime
Commission Reserve. I am still a member of that group
and one of five operating men in the United States. I
am a trustee of the Belknap Oceanographic Operation at
Boothbay, and I am a member of the Management Assistance
Committee of the Small Business Administration in
Washington and represent New England.
Why did Pittston pick Eastport? The reason they did
it is because they have done their homework. In running
a refinery, one of the biggest ingredients is trans-
portation, and there are two, not one but two, very
important aspects of transportation that come into this
location, We have all heard about the deep water port
162—1
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172.
and so forth, and I feel that it is splendid. I think
the original arrangement of Pittston in the very
beginning showed that they were interested in doing
the job right, and anybody that flies on an airplane
tâday on a regular scheduled plane comes into port on
the Decca system. Every ship that comes in here when
Pittston starts operating will come in on the Deeca
system. And if we trust our lives to the airlines to
bring us in safely. why can’t we trust our lives, as
far as pollution is concerned, to bring in the tankers
into Eastport.
Now, the second point which very few people know
about is this: Eastport is in a very unique location.
If you take the sk z off an orange or the cover off a
baseball, it isn’t a squa , .t is round. The earth
is round, and there is what is known as the great circle
routes. So if you took two big tankers and had them in
Capetown. South Africa. and they were the same size and
the same specd, one went to Norfolk, Virginia and one
went to Eastport. the one that cme to Eastport would
get here a whole day earlier. That is at least $40,000.
When it went back to the Far East it would save another
162—2
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173.
$40,000.
Now, with the mix that Pittston has put up here on
the board, part of their operation is going to be making
gasoline. They don’t normally sell that, so they have
got to sell that on the open market and they have got
to compete with the giants, the seven sisters. And how
are they going to do it? Because they have picked a
location that they can lick the pants off them. If you
had a ship leave here going to Europe, it would go to
Bishop’s Rock, which is right off England. And if a
ship left Bayonne or Marcus Hook, it would take them
at least a day longer to get to Bishop’s Rock. If a
ship was going to go from here to the Mediterranean,
Gibra]ter. it would get there a day earlier than one
from New York or from Norfolk. Now, if you were going
to go to the Argentine, Uruguay, or the hump of Brazil.
you would find that the ship that left Eastport , believe
it or not, would get there quicker than the one from
Norfolk.
Thank you very much.
162—3
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163—1
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163—2
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178.
MR. McGLENNON: Thank you Mr. Davis.
MR. COMMITO: My name is Dr. John Conunito. I have
a Bachelor’s Degree in Ecology from Cornell University
and a PhD. in Marine Ecology from the Duke Marine Lab.
I am presently employed at the University of Maine at
Macbias as an Assistant Professor of Marine Ecology.
I am a member of the American Society of Lixnnology
and Oceanography, the American Institute of Biological
Sciences, and the Ecological Society of America.
A few years ago, the Department of Ocean Engineering
at I assachusetts Institute of Technology, on a sea grant
program, made a stt dy of the Macbias Bay area as to its
suitability for supertanker use. Their study showed
that a large sununer oil spill would spread from Canada
to Cape Cod. Their projections indicated that these
spills, although smaller ones perhaps. would occur, woufd
not be mere probabilities, but would be certaintiel.
Washington County alone has landings of invertebrate
animals, such as clams and baitwormi. of 6.7 million
164—1
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179.
dollars per year. I have been studying sand flats
along the east coast from Nova Scotia to Florida. Oil
spills would decimate clam and baitworm flats in
Washington County. and my research has indicated that
it would take from two to six years before such flats
could return to their normal state. We cannot afford
to lose this source of income or the independent life-
style of the fishermen in Washington County.
Thank you. (Applause)
MR. McGLENNON: Thank you, Dr. Convnito.
164—2
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7rcfe led 4 £Zst. rx a. rgMcef0- 1 ME c c.
• ‘ los.) C 1 rtq 1 SII( - d r ,1 e y zf
I come here today both as an individual, who is a Maine native and life—
long resident, a clam-digger, wood-cutter, teacher, social worker and car-
psnter, and as a . er of S.. Sly C-o--— ii4ty Services Inc., a state-idde
non-prof it, graze—roots, educational association of Main people, one of whose
alas is to encourage that the earth’ a resources be used wisely, utilizing
practice. consistent with sound environeental and ecological priinciples.
Ye p . ote the concept of trusterty, or stewardship, of th. earth and her
resources, for, as our planetbs needless technological and po ilation growth
crashes against the finite natur. of the earth’s limits, both in terms of
space and resources, it is essential that we iediately begin to reorder
our i 1 titutiozaa and plan towards establishing a s.nr, stabilized economy
in harmony with our envir .- ,it, rather than distructive towards it.
Although there is sufficient solar .ngrgy falling on just the cant i ntal
U.S. along to supply us with 500 times our estimated energy needs for the
year 2000, we cautious to pomp pstrolei cut of the earth, burning it up
at a proditious rats, and leaving nuns for future generations to utiliu
for medicine, synthetic organs, etc. A reaso abl. person might ask NWhy?N
Th, answer lies in the incredible political and economic power of those large
corporations who stand to profit f ran such exploit ion. The gas engine has
become the miliston. around our society’ • neck, for our increasing dependence
on foreign onrces for this dwindling resource is wrecking economic havoc,
as is reflected in our international trade situation, and directly, by in-
flation, m .plu yaeot and general enonosic sluggishness. As Maine is the
poorest state in Mew Zogland (indeed, one of the po.rest in the nation)
and Washington Cty the poorest county in Main., the effects are even sore
keenly felt here. In the face of this grin econo 4 c outlook, and the poli—
ticid structure’s reluctance to con. up with i vativ., posibive alternatives
that are coanity outrollsd, doncratic and sensitive to the eco-syst..,
Industry has con. to be regarded as something good virtually for it’s own sake
11:3 regardless of it’. effects on land and people.
As a result soms individual. of whom stand to gain substantially)
t support the conc.pt of the Pittston refinery’s being built hers at Iastport,
despite the likelihood of devious eco ’logical damage. This damage might well
take the form of a major oil spill in Paseamaquoddy Bay, a likely possiblity
considering the narr ss of Need Harbor passage, the imesus. size (150,000
tonal) of th. proposed apertai*.rs, th, height of the tides, the strong
currents and whirlpools, the fog and erratic nature of the weather in the
region, as well as the fact that ny of the super taz* rs which will be
165—1
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navigating these waters will be of “flag of convenience” registry, notorious
for poor standarös of safety (many times crews on such ebipe are not even
fully trained to operate all, the complicated navagational aids on board).
Even more pervasive are the “incidental” spillages which even the oil companies
admit will occur. These alone should be quite sufficient to wipe out what
is left of the fishing industry and will be particularly destructive of shell-
fish that have traditionally provided both income and sustenance to local
coastal residents. Plus the long—term effects of sulfur/sulfuric acid from
the refinery stacks raining down upon the inhavitanta of Moore Island and the
surrounding bay.
far can we trust Pittston? Not very, judging by the experience of
residents of Buffalo Creek, V. Virginia. There in 1972, three dams construc-
ted 0 f coal mine wastes by the Pittston Corporation on the upper Buffalo
Creek gave way, sending a 30 foot wall of sludge and water crashing down the
valley where it virtually destroyed 16 co initieh, killing dozena of people.
Though these dams had been amstructed in violation of V, Virginia laws, and
without consulting either an engineer ora soil .ci.ntitst, Pittston ocontinues
to evade legal responsiblity, thoughj they certainly can not evade the moral
responsib lity.
(Pittst on)Decisiona jf %M/J4&”/Xh JiA( will be made in an executive’ s
office suite in New York, far ‘from the stench and waste thom decisions might
well cause. /JWi Long after the building boom has came and gone, Eaatport will
in effect be a colony, a fiafdom, dominated politically and economically
by the Pittston Corp. This perversion has already begun, for FPjttetou has
already exet ed enough influence to prevent the people of Eastport from having
the opportunity to choose, by referendum, whether or not they wish to see this
refinery built on their island, one of the last, unique and relatively un-
spoiled portions of the Maine coast. j In such an atmosphere, true democracy
can not exist.
Recently, Wm. Adams Jr., Comeisatoner of the Maine Dept. of Environmental
Protection made the following statement. “ I an concerned that a pro! ifera—
tion of ‘enviroomentally sound’ (italics mineP developeents may create a
Maine that none of us envisi on... 1 am concerned that we have not made the
enviroomental, socialogical and political decisions which must be made if
that changø is to be to our liking... Maine cannot rely upon environmental
laws to preserve our lifestyles. Environmental law, are no panacea against
changes to landscape or lifestyles , and people ‘who think so are in for a
rude shock.”
Therefor, Jto preserve our lifestyle we need local, not corporate/out—
of-state, control of our resources. We .ast utilize these resources prudently
+n ,.a+ +K ha .4 Ksua.v, naaA nf W a 4 ..a .,ae.nl a
-------
rather than ahoy the. to be exploited for the bnif it of a fsw powerful
øut—of-itate interests. The consequences of zr failure to do so, will be
that our children’s children will inherit a world whose dowry will hive
been squandered by people ignorant of the basic - relationships between econo-
aics and nature/entropy. -
165—3
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} — t Aç 1tcitirn . :-)5 — — o. Ofl2242O
( rp -.t A ’ % ’ ‘r
56. Key Street
Eaatport. Maine
197 Decambr 3, 1976
U. S. ivironinental Agency
Region 1 Permit i3ranch
John F. Kennedy liuilding
Boston, Mass.
My name is Claire C. Arsenault, Registered Nurse
employed at the Eastport Memorial Hospital.
This letter was written By ma wit tne consent of the
undersigned employees of the Eastport Memorial. Hospital.
We favor the expectation that the Pittston Oil Refinery
soon will reach its’ objective of overcoming the many obstacles
which has been, so to speak, blackening its’ building in
Eastport, Maine.
We cannot consider the thought of our local hol ital
coming to a close and the many to become unemployed.
We also speak with compassion of our E aatport residents
whether eldersy or very young Our two Doctors are now
overworked, and soon canno t ti load. If each citizen
woull only look deep within and think, it not yourself.
it is for sure one very dear to you has bad many the close
call and are alive today because of the Eaatport Memorial
Hospital., Doctors, and the Staff.
Thirty miles or possibly one hundred and. thirty miles
f or treatment of shock, hemmorhage, birth, heart attack,
etc. can cause m n .ny a life. Then the queation.Is there
a doctor immediately available even then?
As for pollution, of course we must consider, bat
Pittston Company has given us just reason to believe they
can overcome thi. particular obstacle.
We ask Eaatporters, again think back in years past,
we have overcome many types of pollution in our time; and
many living to a great old age, probably longer than they
do today.
Under industry, do we stok to reali7e the way D is
going, sure its’ for our protection, but are they considering
the average individual? No matter what they impose upon
the city or utilities, w• are paying across the board.
Through rising costs and rate raises we are payting doubly,
first. ma an individual and secondly through the citytaisa,
as we are the city. Therefore industry is imperative for
us to even survive.
e/ zI ( “ (7/Ji 1 ceiti ii
166—1
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166—2
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Statement of Associated Industries of Maine
EPA Hearing, Eastport Maine, December 3, 1976
Convsents on Draft Environmental Impact Statement
Associated industries of Maine is an association of over 200
Maine businesses and is a non-profit Maine corporation. A.I.t1. was
founded 56 years ago to advance the free enterprise system and to pro
mote economic growth in the state of Maine.
We are desirous of making several points at this hearing today
on behalf of our members.
There can be little argument that historically, Washington County
is one of Maine’s leas a countie5. Chronic unemployment, slug-
gish development and lack of economic opportunity has depressed its
past, retarded its growth and threatens its future.Lia’ ‘- .
These hearings today center on the issue of trade off’s, environ-
mental risk-taking vs. economic advancement.
Maine’s Department of Environmental Protection held exhaustive
hearings on all aspects of environmental concerns. It is not our
purpose to go over that ground today. Associated Industries of Maine
accepts the DEP’s verdict on environmental issues, that there are
sufficient safeguards contained in the Pittston Company’s proposal
to make a 250,000 barrel per day refinery environmentally ac eptablc.
It is noteworthy that throughout this lengthy hearing process on
environmental criteria, that economic factOri were not considered duo
to the provision . of ilaine’s Site Location Law.
Associated Industries of Maine believes that with an extensive
examination of environmental data and an affirmative vote by Maine’s
own DEl ’ Commission, n.- dc on the basis of these cnvironmcnt l risks,
it is now valid to consider and evaluate the positive elements of
an investment of this magnitude in the state of Maine.
167—1
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11
Statement of Associated industries of Main. Page 2.
The Pittston Company has indicated that approximately $00 million
dollars of investment will be made in this part of Eastern Maine.
The impact of this can be best evaluated by experts such as Dr.
Arthur Johnso n, a qualified economist.
However, A.I.M. would point out that this amount of investment
by. Pittston Company represents a unique opportunity for Eaatport,
Washington County and l4aine. Seldom, if ever, ha. one town and one
county had the prospect of a single enterpris, of this size. Rarely
has a single privately owned company been ready and anxious to in-
vest this kind of capital in Mains.
Noteworthy as well is th. nature of this opportunity. North-
eastern Maine, Washington County and Eastport have historically been
promised *uch and delivered little.
Projects, proposals and schcaos that fail to materialize year
after year while traditional economic activity declines make hope
and opportunity difficult to sustain.
Tb. proais.s of the past were all subject to the whim of
Washington. D.C. and the attitudes of a distant Congress. Quoddy
has remained a concept, not a reality for forty years. Dickey Dam
has been awaiting a substantial Congressional coitment for fifteen
years. Each of these proposals was pronoted on th. basis of economic
advancement for eastern hams.
The Pittston proposal does not rely on the Congress, nor docs
it require an appropriation of tax dollars at a time when tax rcvsnues
in Washington are in a state of flux. Pittston’s refinery would be
built and financed by tried and tested methods, by the private sector.
It would not be the creation of Congress nor of the Federal Govern-
167—2
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II
Statement of Associated Industries of Maine Page 3.
ment and thus, would not be subject to the policy fluctuations that
can close, restrict or Cut back federally created installations.
Hearings were recently held on an 83% cut back at Loring Air Force
Base. It remains to be seen what the verdict will be on that
Federal base but there is no threat of a similar situation on the
Pittston’s refinery.
Without reliance on federal financing or state backed bonds
or loans, Pittston’s investment in Eastport will be both substantial
and long term. Thus, the economic stability for this region would
be assured.
There is demonstrated need for refined oil products both in
Maine and New England. Our reliance on oil is a fact. Our supply
of oil must be assured. Location of an oil refinery in ilaine will
attract industries here and a surety of supply will cnhanc the
likelihood of expansions among existing businesses.
With the I4aine Department of Environmental Protection’s decision
to grant a license to the Pittston Company assuring us of sound
environmental examination, this Association wishes to put itself on
the record of this hearing as being strongly in favor of tile Pittston
Company’s application to construct an oil refinery in Ettstport,
Maine.
errill C. cll s, Jr.
I xccutivc Director
Associated Industries of Tlainc
167—3
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TP 2 U1 (HI, )tTh W 1W kLw; AT KA iW
IECP3III9 ( 3. 1 Yfi
1 r name is Robert N. )Iatlcdll, I am Chairman of the Bourd and
Chief Executive Officer of 1k ngor Uydro-. lectric Company, tho inve tori
ovnel electx’ià utility aorving óubatantiaU.y nil of i ortheuetern Maine
with èlcetric service.
Fitt y years ago, this very m nth, I nomplcted r first major
nt:1r.coriisg aeeignment — the construction ot a 33,000 volt tronomioolcm
line along the coastal area, Ellsuorth to Ea3tport, a project that for
the first ti brciught rcliablc central station eervico to more than
twenty c —” w4tiea along the n w tranami scion nnJ diutributiou ten.
Over these pant fifty years, l -l9’/6, I have had major reaporudbil-
ities related to the c’inztge trim an all hydro..electric gt nt ration r irce
to a combination of I iro and oil, then to our current mix of hydro, oil
and maclour ti ’ ippI.y our uuerri vit.h more than one billion kilcisatt hours
each year.
To meet the Ju rt abc*&t certain year-t y-year increases required to
maintain the r th —t - little or no availab1 hydxo
sources that can he oven re c nab1y cost competitive, and I include tidal
168—1
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powr:r, on ‘c’ nomLe uI) urIJ.ty, making PAulrie, at lca:;t, ub twtt ul1y
16’I
depcndcnt upon indu ;triui type fuel ol]. and nu lear our es. Uut be
all of that s it may, I have no thowjtthat any of my t timony, o
far, adds such, if an rLhing, to what mieht help in your final conclusions.
I hope, however, that n y final brief cc*nmento, reflecting fifty
yearn of personal observations of the eeoxic ny of V1aTh.In ton County,
Justify your considerution. Parenthetically, these oh:;ervations do
not reflect the self—interest of an official seeking new business for
hi3 Company. The proposetl refinery will, have enerat:ing capacity to meet
iL electric power requirements.
In n r opinion there 1 no area in Maine that is in n re desperate
need of payrofls than Wash ni ton County. The magnitude of this factor
has been wtequately pre enL.cd to you here today, and my only plea to you
is that in your decis:i.onz you give careful consideration to what to me
is a stutborn fact, and it is this. Your decisions may well be that last
chance for the present and future generations In Washintcton County to gain
for themselves an earning level decently compaz able to Just about all other
areas of Uaine.
168—2
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Report on the
Socio-Economic Impact of the
Proposed Pittston Project
at Eastport, Maine
Submitted by
The Action Comittee of 50
43 I1 1no1s Avenue
Bangor, Maine 044W
Prepared by
Arthur H. Johnson, Ph.D.
Assisted by
Abu H. Huq, Ph.D. and Wayne 14. O’leary, $.A.
Dece.**r 3, 1976
169-1
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• .
Tik . Afl! IJ Sit
YSLUPHONE ZO7.SZ3.472t
Cj)OSi11) IIC(H1i
21$ WATER SYRStY. AUGUSTA. MAIMS 04230
December 3, 1976
Mr. 3ch ,. A. Mc i. .nno:L, Ad14.
E.P.A. Regional $1
2203 J. F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
I appreciate this opportunity to present iry views on
the Pittston oil refinery proposed for Eaatport. I regret
that other commitments make it in possible for me to attend
the December 3 hearing personally, but am happy to enter this.
letter into the record.
In my opinion, the economic and financial benefits
which would accrue to the State of Maine as a result of the
proposed refinery provide persuasive arguments for its approval.
I want to make clear from the outset, however, that I am well
aware of the legitimate environmental considerations that must
be carefully evaluated. But neither I nor my colleagues have
any ‘ xpertiae in this area, and I must therefore leave the
we h!n of these ies ee to cther hc ar mcr klgc bl
—— and ultimately, of course, to the regulatory authorities.
It has become almost axiomatic to describe Maine as
underdeveloped vis-a-vis other parts of the United States. In
fact, I think some of us have a subconscious tendency to cul-
tivate this image —— the concept of rural poverty retains a
false gentility long since lost by the urban poor. But thi
endless supply of statistics bearing out i. aine’s economic
status and the fact that the majority of our citizens are
denied the standard of living commonly enjoyed elsewhere is
an unromantic, sobering reality that commends our attention.
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Mr. John A. McGlennon
December 3, 1976
Pags 2
During the recent recession, for instance, the
unemployment rate in the State peaked at 10.4 percent in the
third quarter .of 1975. By contrast, the natioual. peak was
8.7 percent. Furthermore, thit differential has existed
consistently for many years. In 1971, the Maine unemployment
rate averaged 7, 6 percent, versus 5.9 percent nationwide; the
1972 figures were 7.0 percent in Maine and 5.6 percent nationally;
5.9 and 4.9 percent, respectively in 1973; and 6.7 and 5.6 per—
cent in 1974. During 1976 the comparison has been less odious
— in June, 7.6 percent of the Maine labor force was out of
wU , only sligiitly a ove the national rate of 7 • 5 percent.
But there seems little reason to expect a permanent improvement
in Maine’ a standing and, in any case, 7.6 percent unemployment
is unconscionably high, in Maine or anywhere.
It is also important to recognize that, within a state
as large in area and diverse in character as Maine, statewide
averages can mask pockets of severe unemployment and poverty.
For instance, the 1975 unemployment figure inc 1 uded Sagadahoc
and snn.bec Counties, with rates of only 7,8 and 7 • 6 percent
respectively, but it also included Washington and Somerset
Counties, with rates of 12.2 and 13.6 percent, respectively.
All in. all, it can hardly be denied that Maine needs additional
jab., and in some sections the need is desperate.
Similar facts emerge in the area of personal income.
While per capita incom, has risen steadily in the State in
terms of constant dollars, a significant part of the increase
has been eaten away by inflation. In addition, the per capita
income in the State, although shoving wholeeoi e improvement
rc1 tcd to thc nat oneJ. avcragc, tccd at only abcut !2 per-
cent of that average in the 1974—75 period. During the 1960’s,
Plaine ranked 38th among th. states in per capita income, and
recent data indicate it has now fallen to 43rd.
There is an endless supply of such statistics, but
I have tried to reinforc, the point that the Mains economy
sorely needs th. shot in the axm that a new industry such
as the proposed refinery and it. ancillary businesses would
bring it. In fact, the importation f scm. types of industry
is, in my opinion, the solution. I know very little about
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Mr. John A. McGlennon
December 3, 1976
Page 3
the operations of a refinery and therefore can’t comment on
the technical details of the proposal. I can, however,
emphasize the widespread benefits that the many new jobs
and a capital investment in the neighborhood of $500 million
would bring to the state.
These figures are impressive for their ripple effect.
The additional income of these new jobholders would be in
large part spent on goods and services within the state, with•
a heavy concentration in one of the regions with the most
acute economic need. Furthermore, the refinery itself would
probably continue to draw on local service support with both
direct and indirect ties to its daily operations, giving
additional stimulus to the general economy.
Not all of the newly injected personal income would
be spent directly, of course. A significant part would be
saved probably in the form of deposits with banks having
offices in the area, thus entering the economic mainstream
as lendable funds for business expansion, housing, or other
worthwhile ventures requiring capital. The invigorated
economy, at the same time, could well be a productive user
of the lendable funds being generated. (I would hasten to
add that we do not have banking offices in the area referred
to.)
This interdependence is a necessary ingredient if the
export of funds, which can be a severe problem in some
developing areas, is to be avoided. The banking community
can and should play a key role in redistributing the funds
that would flow into the community as a result of an industry
such as that proposed for Eastport, so as to maximize its
favorable impact. But this cannot be accomplished without
such an industry.
No single industry, not even one as important as an
oil refinery, will solve all of the State’s economic problems.
But we must begin and welcome any industry, that proves har-
monious with the State’s values, work force and resources.
Sincerely,
Wallace N. Haselton
Chairman
Depositors Trust Company
WMB:rb
170—3
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237.
Th
( INSj_ . iy name is Marian Hodgins from Lubec.
Many of us are not well versed in the sciences or
mathematics. which precludes our understanding or even
attempts to understand most of the Environmental Impact
Statement.
The large portion of the population around here are
not business people, but they are old people, retirees,
farmers, claniners, fishermen, woodsmen. My family and
I have a farm on the Cobscook Bay waterways. Those of
us who are in these categories are not used to speaking
in public and will not. It is very intimidating, but
I will try.
I do not want an oil refinery for these reasons:
It will change our way of life so that it will n t e
recognizable.
I do not want sixty gallons of crude oil dumped into
Cobscook Bay. which is my bay, every day, let alone the
threat of an oil spill.
I do not want the one to two tons of sulfur dioxide
spewing from the Pittston chimneys every hour, especially
when there is one of those month long fogs for which
171—1
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238.
Eastport is famous.
I do not want 2,300 people to move into the area.
Incidentally, those who are smugly saying that it is
only the outsiders who are against oil should think
about the changes these 2,300 people will make.
I do not want new roads, schcols, houses, trailers,
shopping centers, beer joints, houses, gas stations,
and other satellite businesses, and so on.
I think that we should all look to conservation
methods rather than always increasing our greed to
allow for such things as electric hair fluffers and
plastic Christmas trees, for these are the sort of
things that the petrochemical industry brings us.
We have not ever been allowed to vote on this issue,
and this is supposed to be a democracy? This hearing
was well advertised and should be well represented.
On that basis, I would like to ask everyone here who
is against the oil refinery to stand up before they
say you can’t. (Applause)
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pI4 J•:Nl1:I) AV I:A ;rI ’cn4r UI:AD t k: ; i n i I ’ i’ri’: ror.s u,•:u1 NKll•v_ I’uc)I ’() ;Ar.
As a leadcr in Maine’s coastal industrial
conununity, the Bath Iron Works has a continuing interest in
the development of an oil refinery in the State’s tidewater
area. •Whcn we address the issue of environmental impact. wea e
talking in part about the quality of life, and as a major Maine
employer intensely concerned with the welfare of its skilled work-
force. Bath Iron Works translates a refinery such as the one
proposed here by the Pittston Company as better jobs and more jobs.
As one of thc nation’s leading shipyards, Bath iron
Works has watched with cautious optimism the progress of oil
exploration on the Outer Continental Shelf (OCS) • and we see
profitable interactions between such shelf development off Maine
and any refinery capacity on our Coast.
Cast Coast product delivery from the Pittston
refinery could move primarily by tankcrs in the capacity rauqc
suitable for CnnA1:r JCtI t) aml rrp. r nt 83t.h iron Wor)cn. In thn
past, such work. espocially in the repair and ovcrhaut field,
172—1
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paqe 2
has been placed in shi pya-rds closcr to astablislieci ocean trade
routes. To have Eastport traffi.c cro ing our doorstep, the
Kennebec RivOr entrance, would sharpen our competitive position
immeasurably.
Speculation has been cautious about the possibility
of petroleum products from a Maine refinery reducinq the State’s
high cost for fuels, especially heating oil. 131W has not hesitated
in recent years to publicly state that, in the highLy cumDetitive
American shipbuilding industry, Maine’s cold winters, isolation
and resultant high heating costs have unfavorably impacted the
Shipyard’s bidding position.
For this reason, even the most modest price benefits
passed on by a Maine refinery to consumers would enhance BIW’s chanc
of securinq millions 01 dollars in contracts, which otherwise might
go to SOLI thorn shipyards.
For instance, a week acjo IEEW lost a $7. 5—million
contract by $ 105 • 001) to a coinpct:1 tor Whoflo nh I pya rd I n next: door
to a major mid-atlantic refinery complex. This l.4’ bid difference
172—2
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I’aqo 3
can easily be translated into the hijhcr cost of providiny heat
in that contract to have hwl ii accorn 1 ,tinhcd in M.inc.
This only serves to illustrate that Maine industry
as a whole needs even the marginal benefits implicit in having
a major refinery built on our Coast. The broadened industrial
tax base and the potential for an improved supply and/or cheaper
source of fuels would not only vitalize existLng industry, but
encourage more industrial developmont across the state.
These arqunw nts are familiar to any major industrial
expansion, but we must keep in mind that the Pittston proposal
stands alone in Maine in terms of dollar impact. A 700 million
dollar investment payinq estimated annual taxes of $7-million
cannot he I p but improve Maine’ a economic hen 1. th.
Permit mc to restate my last point more graphically.
No other state on the F.ast Coast wàuld benefit more per capita
than Maine from taxes. jobs and investment of a refinery such as
this. Other testimony today diacussea the economic pllqht of
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Page 4
Washington County, a vast area of great undeveloped potential.
The nega Li ye econoin I C 0 1 JP0(f rapli i ca 1. i no l.a Li on do no L sLop at
the Washington County line, but reach outward to every corner
of the StaLe in varying degrees.
For this reason, Maine industry recognizes the
N tlston proposal as not just i boon to Washin tort County and
Maine. We see it as one of the few major industrial undertakings
whose economics of scale can overcome the area’s negative geography
without (legradirig the environment.
The Maine Coast is valuable in many ways and thus
it is seen as threatened in many ways. Ucre in Washington County,
perhaps one of the grcatcnt threats is that J.aiidowners will slowly
have to give up large holdings because the area’s economy can’t
support the residents’ growing financial needs.
Maine’s indusLry is trying to mccl the challenge
of creating the jobs necessary to llc’ ’ property-Owners throughout
the Stale tue c i içjlt i ly of opportwd Ly 10 ,iiikc an adcqu i to i. iv I tag.
It is not enough to look at this refinery and say that ONLY 50 or
172—4
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Page 5
ONLY 100 Maine re iddnL5 may ultimately work [ Lilt-time at the
Pitt ;1on refinery. I ven t) more john nu’asin that; many more people
who will not be forced off their land and whose children will pro-
vide part of a potential workforcc in the next jcncration of
Maine’s industrial expansion.
These are economic realities confronted by Maine
industry every day. Our expansion must sometimes be measured
in small increments in one rationale to measure bigger gains in
the longer term. With this in mind, we recognize that this proposal
is not a final solution to ihc economic woes of ibis county or of
the State.
But it is a bold and decisive step in the proper
direction that asks only modest compromise from the two sides of
the question. This proposal has already survived scrutiny by
one of the nation’s most rigorous state environmental agencies.
The Bath Iron Works joins Maine’s other leadincj indu Lrinu in urging
similar approval of this permit npplicatlon before you today.
Thank you.
Robert M. Smith
Bath Iron Wdrks Corporation Director of Industrial and
(‘r ...uu,injIy Rt’I T.inns
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STATEMENT
by i.13
IRVING McCONCHIE
At The
HEARING IN EASTPORT, MAINE ON THE PROPOSED PITTSTON OIL’ REFINERY
My name is Irving McConchle. I’m a lobster fisherman from Owls Head, Maine,
and I am whole heartedly in favor of an oil refinery at Eastport.
I have been a full-time lobsterman since 1946, fishing in the waters of
Penobscot Bay off Rockland. No one has greater reason for concern about
possible adverse effects of an oil refinery than those of us who earn our
livelihood from the sea. Because of this concern, in October 1974 I traveled,
at nw own expense with 51 other Maine citizens, to personally lmspect oil
refineries and offshore drilling platforms in the Gulf of Mexico off Louisiana.
I had every opportunity to quiz not only oil company officials, but also state
officials, fishermen, and environmental groups.
Before going to Louisiana, I was concerned and confused about the many
conflicting statements being made on locating oil refineries on the Coast of
Maine. As we approached by helicopter from the offshore drilling platform, I
had an excellent opportunity to observe the Gulf’s New Alliance Oil Refinery
located on the banks of the Mississippi River. I was especially on the lookout
for possible oil leaks into the river from the refinery. I saw none . I repeat --
Isaw none . Also there was no visible smoke or flames coming from the stacks of
the refinery —— just a small amount of steam coming from the coolers at the refinery.
Walking around the 300 acre refinery gave me an opportunity to be on the lookout
173—1
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Statement by !rving McConchi•
Dece er 3, 1976
Page -2-
for oil leakage from the maize of pipes and valves. 1 saw none. I might
add that the housekeeping at the refinery was superior to many operations I
have seen In various Industries. I feel that a modern refinery Is totally
acceptable as the kind of a facility that we want to locate on the Coast of
P 1ne.
Our group of fifty-one men and women from ine met with the head of the
Louisiana Audubon Society, the Louisiana Clean Air Association, the Sierra
Club, the Seafood Producers’ Association, the Coissioners of Air, Water
Pollution, and Fisheries for the State of Louisiana. The environmental groups
accused the oil Industry of disregard for State water and air pollution laws. I
specifically asked the ComeIssioners of Air, Water Pollution If the refineries were
responsible for any of the violations they were often being accused of. The
Coissioners stated e hat1cally that this was not the case. They also stated
that the State and National Envlrotuiental laws were being met by the oil refineries.
I believe their statement was that the oil refineries were good ne1ghbors . The
Executive Secretary of the Louisiana Seafood Producers Association was asked If the
refineries were responsible for any reduction of their natural resources. He
stated that the fish catch Is far greater now and the value of the catch far more
than It was before the refineries were constructed In Louisiana, even recognizing
the Inflation factor.
173—2
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Statement by Irving McConchle
December 3, 1976
Page —3—
I returned from Louisiana convinced that State and Federal Environmental
standards are strong enough to protect our air and water and that the
expertise is available to construct a clean refinery on the Coast of Maine.
As far as tanker travel along the Maine Coast, I can only point out that oil
has been transported in large quantity since World War II. I have observed
hundreds of tankers going to Searsport, and the Port of Portland has been
number two on the East Coast of the United States in tanker arrivals. The
State of Maine, to y knowledge, has had no long—term effect from any spills
that may have occurred In that time period.
Lobstering is my business. I would not present this statement if I thought an
oil refinery would hurt our industry. I strongly suspect that objections to
a refinery come from those who have not seen such activity or who are not
willing to SEE.
Lobstering and refineries are not an either or proposition. Our nation can no
longer afford the luxury of private preserves for either fishermen or oilmen.
With todays technology, I feel comfortable that a modern refinery should be
constructed in Eastport.
Let’s get a move on without further delay!
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- by’ Cs ws1 flr ad . b e the U. 3. nvIr— .-.al
— pi. -tlci Ag - fti,f , I y ned rthe Teratosi
‘ k.
1tocs er 3, 1176
The 1 aft E L 1 —---- ” ’ 1 ct atemcit Iaausd by the U. 8. Eviroivintol Protoctioi
Acioy toi ” ” 10/18/71 rsfsr s as pss 183 to the C rs1 Raflrosd Co i !j
1aa(j,tI flv Ayers t1 to Eutpcrt, a dk e 17 alice. The report itotes,
“An upplI aII to bL. t.t. Commsroe Coisaissios (EC) for 1 ” mse ’ the service
a1tos r van tmaed dons to 1171. Asether peittlos icr via flied In Octthsr, 1974.
bet motto. Ma beci tobsi C. this to dote. 7be lIne Is “ 1 ” 'r 4 to a condftloa sate .so b
to psrall frsIM trs to o ste o ft at .pssdo to 30 ails . per hour.” Altho lb.
or. 1—tate XöOt, farther p4-’—ti ’v I. a ç. rkte .
As Ib1L for “ -“ --- g d the Eastport ) asok was flied with the ICC by Mime
Cs *1 ci *.,-..J.,r 3, 111$. HearIngs were held c i 2 $ mad 9, 1970 I i l*ii b.fore an
I CC besr — -‘ ‘ . to bto report , the “r f thet “losses macb as those sr1ciced
v i the t...iiA tb. ccnektorsd a biL.. . c m laterstate aua erce.” As further fosed thet even
V Zaatport sbeet ” srlsaea fetawe Ia frial grewth ‘he Vast b 1 rd weuld be l o.sd ou
lb. . sotid sbWsrs ad reostvsrs to estag the r*l1 servicee at nearby Ayers Jtmctlco.”
sptio.s to the sanals’s report were tiled, and by dectolos doted aslary 22, 1971, an
ICC rsv baird disagreed with bearIng ev.I hl,r, s’ tli , “We are convinced that the
bra line, with the re is& to be received from the w Pals Pearl pteá, will not Incur
sigaifloset lossem In the fature.” Tb. review beard predicted traffic on the branch would
doetg . an a result the sew facility. The sew P ita Pearl plant was sever ocnetructed
lbs pruj.otad Inerssa to truffle sever matorIaUs.d. to foot, traffic baa declIned, to
bsr, 1074, C.etral again petitioned the tot.rskts Commerce Commission for ibis-
lbs Issiport Pauch. Truffle ci the branch Ma averaged lee. thea 250 cars per
174— 1
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7 5 51 C 1970. k 1975 eazicsd en the br** k totaled 235, ooapsred to 399 In 1169 when
G first Ip4 aL&OO for L t wsa ftle&
) ia Central oon’to,w to absorb mthsta te f ncIal losses en the operatIon of this
branch line with extraordinarily small cartoedings and heavy mkb vl.’l 0 coats. During the
peat few In order to maintain safe Ops ’atjc cc the braavh through the winter, Maine
Central fo It necessary to spend about $50,000 In basic n r” e on the Un .. Large
operating bases en the Eaatport Branch adversely affect the overall operation of Maine Central
flafiroad and tie ability to serve its b reda of shlp ir . and have a potentially serious
adverse environmental in p.ct on traneportaticn In n.h . . Central territory.
This Information Is presented to the EPA beonon. the ICC ha.. deterred preparation
01 en ecvi . ---- Ii . t statement for th, proposed han ukment pending availability of
the EPA aanlysis of the environmental Impacts that would result from approval of the Pittston
zef zy The r.I H ..hlp of the Eaatport Breach to the Pittston refinery Is
olen . At present time several mUse of the branch are laid with 60-pound rail and the
line I . In poor ocuditlon due to mi .tantIal deferred maintenance over the peat several years.
Tb. paeity of th. branch is only 168,000 poimde and power to operate the tine Is limited to
a smell 44-ton locomotive. In order to upgrade the Eaatport Branch to a p city of 263.000
pound., which capacity would be required to carry construction materials to the site of the
ref biery and handle 20,000-gallon tank cars, the line should be completely rebuilt at a coat
r% h1g well Into seven figures. At its present capacity, the line osimot even be used to carry
a eabstantial amo mt of construction materials. Mfttne Central does not have the resources
to upgrad, the line to sufficient capacity to handle large tank care and construction material
and en far en meeting Pittston’s needs, thre Is no rallresd from Ayers Jenctlon to Eaatport
with the exos 1 gloc of a right-of-way. Pittston Coiupsn r has not Intervened In the abndonment
proceedings as a protestant.
174- 2
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is. o bslW, thsrdoro, that the r floed as pr:y coe.trectsd has a. direct
Mp bl to the vl U ti1 toj 4 1 of the Pittston r.fb y. R also OSS be canchiled
that the pm.i . . zoftosry ha. a. reIst’o Ip to the .nvtron 1 th pout of lb. ab w’onm .et
01 she ..sport anok. We thsis&re, uris . inalron estaI Psotectics Agency to Isform
th b 1 Li to Coloneros Coa la. that the Use s. Its p z cudft1cs does ....t affect
,Ir-——-—th1 IJ t c i She proposed refto zy and, ocs rseIy, Sb, refinery could lot
jt the co,tr -tsI h ,t 01 lbs proposed rafiroed sheadosmist. TbIs would allow the
icc in , k It. Sh.-a” as t!ttS of the 01 the ias oi’t Branch.
Bradisy I . Peters
Aaslatent to President
Maine Cosiral Railroad C pany
174— 3
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(t
___ 9
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rthcr explanation Is appropriate’
An appttcatlon for abandonment of the Eastport Branch was filed with the ICC by Mah c
Central on November 3, 1069. HearIngs were held on June S and 9, 1970 in Calais before an
ICC hearing examiner. In his report, the examiner found that “losses such as those cxpcr!enced
on the branch must be considered a burden on interstate commerce.” lie further found that even
U Eastport should experience future industrial growth “no great burden would be Imposed upon
the affected shippers and receivers in using the rail services at nearby Ayers Junction.”
Exceptions to the examiner’s report were filed, and by decision dated January 22. 1971, an
ICC roview board disa rced with the hearing examiner, st .itIn , “We are convinced that the
branch line, with the revenues to be received from the new Pals Pearl plant, will not Incur
significant losses in the future.” The jeview board predicted that traffic on the branch would
more than double as a result of the now facility. The new Pats Pearl plant was never constructed
and the projected Increase in traffic never materialized. in fact, traffic has declined. In
October, 1974, MaIne Central again petitioned the Interstate Coinn.crce Commission for aban-
donment of the Eastport Branch. Traffic on the branch ha averaged less than 250 cars per
year since 1970. in 3975 carloadings on the branch totaled 235, compared to 299 in 1909 when
the first application for abandonment was tiled.
Maine Central continues to absorb substantial financial losses on the operation of this
branch line with extraordinarily small carloadirn ’. .‘ d heavy maintenance costs.
) L E operating losses on the Eastport Branch adversely affect the overall operation ot l lalne Central
Railroad and its ability to serve its hundreds of shippers and have a potentially serious
adverse environmental impact on transportation in Maine Central territory.
This Information is presented to the EPA because the ICC has deferred preparation
c i an environmental impact statement for the proposed abandonment pending availability of
the EPA analysis of the environmental impacts that would result from approval of the Pittston
refinery application. The relationship of the Eastport Branch to the Pittston refinery Is
cloudy. At the present t1m2 several miles of the branch are laid with 60-pound rail and the
line is In poor condition due to suJuitantial deferred maintenance over the past several years.
The capacity of the branch Is only 168,000 pounds and power to operate the line Is limited to
17 4—4
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a small 44-ton locomotive. in order to upgrade the Eastport Branch to a capacity of 263,000
pounds, which capacity would be required to carry construction materials to the site of the
refinery and handle 20, 000-gaUou tank cars, the line should be completely rebuilt at a cost
running well Into seven figures. At its present capacity, the line caimot even be used to carry
any stthsl*ntIal amount of conebuntlon materials. Maine Central doc not have the resources
to gr*de the line to sufficient capacity to handle large tank cars and construction material
aM-ag far s.a meeting Pittston’s needs, there Is no railroad from Ayers Junction to F astport
with the exception of a right-of-way. Pittston Company has not Intt•ivened In the abandonment
prococdings as a protcstanL
Is our belief, therefore, that the railroad as presently conutructed has no dtrcct
r.latlonuldp to the environmental Impact of the Pittston refinery. it also can be concludoti
that the Pittston refinery baa no relationship to the envIronmental Impact of the abandonment
of the Eaatport Branch. We, therefore, urge the Environmental Protection Agency to Inform
the interstato Commerce Commission that the line to its present .ondIt ton does ._ affect
the envtronmsn l Impact of the proposed refinery and, conversely, th’ refinery could not
affect the environmental Impact of tho proposed railroad abandonment. This would allow the
ICC to proceed in its delthcrattona on the merits of the abandonment of the Eastport flranch.
174—5
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; . eiir , u i ttk() io. rd t. i1V rtn. ncn tal t’rotnotionl it
Is La’ r.: co ‘I. .. i,ith. I li.o ai. Jonosport, :1rLI no. I ant a rotirod 1 anker
wit. ovot O ‘iu - ox ’orionc’ , ost or .t in a:;.ijnrL
£ em I I1 )I’ tue) ‘asz:jzt tcfl ‘OUXtt 1 tta:nbor of c’ v ?co, . Zi t
rosidont 1’ the ‘as ti;. t. n Uotnt !.cc’nor tc Mveio 1 m on . orporat.ion. I
b ,I1ove g. a cLation wLtj L&tu JU( I c iii t Lis area tts ;ivon no a prot t’
good ldoa :18 O Lb condition or tue hero, a::d Cuntlenen, I
r cconom i in a state of consti ation
or OXLs le— i i3 ].iko a su al1 boy who is constipated nd wont’ let his
mothcr j’ru hit. ; oc sar laxative to roltcv hi Conuiti.on, and as
ti ne oe on lila c nd c on wordons and could l ci.d to o . .o’ c :iic .. onB .
Thero is h l for our cons; . 1 .at d c nd tion, we need not ha’o cats ri ;h
x.o . 1oj:i uht r C, lJ ca 30 t dic xte is av: llablc, a nacu;’al r so i’co
to be dovoIc .’d uj L.i fttston ‘ornpony as tiLed are waitin. t use tho
‘loop watera of t..e Atl fltiO t.cean to float t.e tankers as they bring
crude (iii tc t o ‘of nory.
1.astk,ort I; ca ablo of liuvir; sot. et ..J.: ; bi as it is or.e of tne s ot
‘z t:.e ‘tGia.Lti.c Co st w:.tri deep :ator rbo s, it was once tho srdine
ca itOi of the ot’1d, but now L i t iz .istory.
ont1o: n, i. o t. ’ a .•rov:t]. cf tt,e ittstonz a .’lication to erect an
,fl. rofii r in .. L rt— . need t’ o 1O; I13flt .e need all ‘. o ,tl and
t e b Ls licl ) iake us e. str , free indopCLldOflt hation. Jo :.. s
iave a rs. alziy ‘ .. .. i .ro -1LSL liRvo nrui y to L XI YE .
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i . i t FU Cui .1; .
There is no need for une:. 1 oj tent condition hero in this aro : .— Let
us get on ho job while tiere is still an o ortu nity.
175—1
-------
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176—2
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MR. BRADSUAW: Mr. Chairman and ladies and gentlemen:
My name is Dean Bradshaw and I am a resident of Dennys-
yule. My qualifications are a Master’s Degree in.
176—3
-------
cbs.
Civil Engineering. In addition, I hold a professional
engineering license.
I know very little about the technical aspects of
oil refineries, and I have not studied air or sea water
pollution to any great degree. However, I have read
the executive summary of the EIS and I have also looked
through the other volumes. Mr. Chairman, I suhnit to
you that the draft Environmental Impact Statement is
improperly biased, and that the authors of this document
are in the position of advocating the proposed project.
protest this advocacy and I respectfully request that
you correct this. I believe the proper position of an
agency charged with protecting the environment is one
of resistance to any proposed degradation of the environ-
ment, rather than encouraging industry to disperse into
the countryside and along the sea coast in order to spare
already polluted areas of additional burdens.
In the executive summary, Volume I, there is a section
entitled “Environmental Impacts of the Proposed Project”.
In this section there is a discussion of some impacts
associated with the refinery. As may be expected. the
socio—economic impacts are discussed as favorable
176—4
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and presented as positive. The discussions of impacts
on land use, marine water, air quality, present the
impacts as unfavorable or mostly negative. But in
many of these discussions the authors chose to make a
rebuttal of the unfavorable aspects. often on a point
for point basis, and in these discussions the negative
aspects are sometimes belittled. I ask you, is this
the proper way to discuss a negative impact to the
environment in a document prepared by the EPA? I submit
to you that it is not.
For example, on page 27 in the executive aun nary,
there is a discussion of routine discharges of oil and
grease in treated wastewater. It uses the term “small
quantities of oil and gas” to describe the introduction
of new pollutants into Deep Cove. Under the allowable
limits of the proposed permit, the discharge concen-
tration is 15 milligrams per liter. At this concen-
tration the refinery will be allowed to routinely dump
400 pounds of oil and grease in treated ballast and
process wastewater. During rainstorms they will be
permitted to dump up to 500 pounds. Using the smaller
number, this will accumulate to nearly 150,000 pounds
176—5
-------
per year of refinery operation. This is no small amount,
but rather a huge amount whet you consider that the
routine spills will add even more oil to these waters.
Even without considering the effect of a catastrophic
major spill from a tanker accident, would anyone here
care to eat clams from the impact area after a year or
two of refinery operation? I would not.
In zuninary, I would like to go on record as being
opposed to the construction of the refinery project in
Eastport. In addition 1 I move that the draft of the
EIS be rejected and that a more properly written
document be presented, one that is not biased and one
that concerns itself with the impact area, not with
the needs of industry.
Lastly, I prcp se that a referendwn directed to the
citizens of the impact area is the only valid method
to determine whether or not the refinery should be
built in Eastport.
Thank you, Mr. Chairman.
MR. McGLENNON: Thank you, Mr. Bradshaw. I have
discovered that bias is in the eyes of the beholder.
• 15 Mr. David Foote here? Is Ivan Hanscom here?
176—6
-------
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177—2
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December 7, 1976
Mr. John McGlennon
Regional Administrator
U.S. Enviromental Protection Agency
Region I
Boston, Massachusetts 02203
Dear Sir:
It seems to be a sad state of affairs when a life—long native
of Eastport has to take a back seat on the future of his own
City from strangers who come to Saatport Rnd tell us what we
can or cannot do. I have struggled here for forty—nine years
and my ancestors have lived here since the area was founded,
and I feel, both highly ignored end imposed upon, by people
from another State dictating to me and my City.
I eat in the Auditorium on Friday, December 3, 1976, and listened
to the same rhetoric from the retired well—to—do’s, the summer
artiste and just plain filthy knap—eack and sneaker crowd that I
have listened to for the last three years. I sat from 2 00 P.M.
to 10:40 with a half—hour break for supper. I listened to a
Canadian who spoke for one—half hour on a three minute tinie limit,
and in all fairness to the many who didn’t get a chance to speak,
this was uncalled for. This same Canadian is also very misinformed
on Canadian fisherman. I sell “ marine insurance “ to these fisher-
man and most of them say it would not hurt fishing as they ‘lsh
outside the bay. Unfortunately, they are afraid to speak out be-
cause of the noney they borrow from the Canadian Gove’iiment and the
repercussions that could be brought 4 againet them.
‘7rhen I looked into the bleaches and saw complete strangers dominat—
1mg the audience, I knew what was happening. I’ve worked on the
road in Washington County for five years as an outside salesman for
Sears Roebuck; I had a soft—drink business for three year.; I was
credit manager for a hardware chain for three year., and have been
a manager—salesman for Penderson Agency “ Thr five years. For
sixteen years I have traveled In every town, every back road, street
in Washington County. I am willing to bet I know this County end
Its people as well as any man in It, end seventy per—cent of the
people in the audi ice were strangers to me Many interested
people who favor the Refinery were working or tired and had house
work to do and couldn’t go to the Hearing, but the food stamp and
free check people or the retired wealthy were there as always.
1 I I t
178—1
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—2—
I feel we are unfairly represented by these people, who are
8tr flger8 to our City, and hope your decision will take this
opinion In conaIder ’.tIon.
Yours respectfully,
Harold R. eezer
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178—2
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179—2
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MR. STANTON: Mr. Chairman and conv ittee , my name is (] )
Harry Stanton. I am Plant Manager for Guilford Industries
of Eastport. Maine. We are a manufacturer of woolen
spun yarns and local employers of 70 to. 150 year-round
employees.
We at Guilford are in favor of any industry, including
Pittston, that would come into this area and boost its
economy, provided that it is able to meet the state and
federal regulations. We feel that additional industry
is needed and would benefit us and the surrounding
businesses in the communities and the state.
Thank you very much.
MR. McGL.ENNON: Thank you. Mr. Stanton.
180—1
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o ber 7, 1976
John i c1cnnon
ihriaw.1 Adainintrator
Unitc t 3tct% a nvironw - to1 Protection # gcncy
R ton 1.
John F. KeTmody Bui1d1ni
Bo3tUl, ieee. 02203
Dear Johns
After attending the hcnrisw e thnt uero h2ld to Caflpoxt on )ee bor 3, 197ó,
I laft in d irrçuoet . bout one hatr prior to tha cloaIn of the he x1nge.
Before I eon4emn the a de.irab1e sc mcnt that odv .4 ’ *tci tho bearin o lot
we olc. tfy wyeelf to you ce thee. p op:Le (lid itot.
I rnis& ttn(l c atect in tSetpart later to x h*to fron Runnon Colle in
Jun. of 1971. I th roturned to r tp rt o bocee. eeployod i t the 1 c rl C t1c-
the city. l xr ozt iplo . r to a well a1 position of treas ILticul liy
wife and two children, ego and 5 era e.cttv. in the ceewunity. 14y srifo b bongs to
the netrcrt Junior Douni T blo eM is a 3unday 3choel tr ch ,r at our chwch. The
rni tions to uht h I belong eras Fuzvly Jz’ycecf’, -i3m or diro tor, Eaetpert
c ormnl pit l finr’ico ooewittre, “ atport onin,j Bo r i oi Apj vice chntr—
r n, Ncmbor Citis Advisory itte,; Irri) sic bor Anchor Lo’Jlco 1 ni hta of Pythtsss
Teat w bar, stport Charter Review ieeic. evvl date k a3tport 5 iool C itt...
Now let we a ik you if you rusitee whet the c smtty iavo1v áit might be for
the predosin nt ne smt that the attes iod our hasrinCe.
Approxiwately 2 % of the people were stport reoldents, áothc 10 iere State
bu tne3c*un a’vi the root being pi onents that ceec from who knows where. f Ihr’
25 tport,..re ide nts the majority at ht’nd u’ ro fr rs the oino’:ity unt irrb 1 . The-
un enirablee era eleuin taking over our city as their n bers tnorc eo. Thtr being
- ttrtbut& to no r 1’l tiey rcquirrii.,nto for vnlfar and the t1 b 1jty of chc’ p
b19Chtc housing cand ittcn3. Our City Ooueetl has mode every oU ’rt poariblo to re—
‘ ieee thee. he 1th hezer4-.ub-.tanderd oon&ttiaie.ns con be .ubetrnciatcd by the rcco
!Iever the lees, this bUi htex1 aree is a haven for into tmdeetx ble type. Could we Pr
it esl iese of the $240,000 reod,od food uteep r. )eet. for the ftrst month
period of t976?
Vitho ccontai. expensias tide nr sàciety will smdoubtly retail na cconL ic
conditions ieakon.
iel-r
-------
)eeewber 7, 1976
dppcnents any he new ob te etilewe a xef Lia. This Is absurd, the
new charter eal1 tor referadewe on ord3 cee only this o3ect wets not created
by as Inancs.
I1 i ,i y facts vaxe left out th2rta1 the siij s but hOpefully doeiaastl on pep .
‘Ty wifee p 5 z .ts are Cviodian, Her dM has two h rrtnC w.i cne of which will be
the closeet woir to the acteal refinery sit., ehou 14 it be builvt. lie Is also
acimbax of Cti irlott. coi tty weirmetne eneociMion hizi tine no etr n’ feelings either
way. ThOse people thttt era for it would not dnre show their scntisants,far the New
Br msvlck 1 board holds title to 9O. cf all the boats from ties area. hts is a
boaid of sew not raise rn re ulati ne eit* as us ax, aec tomet to,
In comelusi us (my f ly) hops jaw zewlies the szie.tx. . si J it pe ca1n-
ate the sseti eut have bsew iw 1, ob5bly will continu, to be , iy vocal abo ft
this project y oth .ject inelulin 1u My suid It use a reality..
Jnc.r a Ly,
l L—2
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tt e 1 63t
)eceeber 7, 1976
John McGlanncsa
Regional Administrator
United States Environmental Protection Agency
Region 1
John F. Kennedy Building
Boston, Mass. 02203
Dear Johnz
After attending the hearings that were held in stport on December 3, 1976,
I left in diaguest about one hour prior to the closing of the hearings.
Before I condemn the undesirable segment that predominated the hearings let
me classify syseif to you as theme people did not.
I wan raised and edi ated in .atport later to grathate from Hueson College in
June of 1971. I then returned to stpOrt to become employed at the Mean Corporation,
the citys largest employer to a well paid position of transporation —az ager. My
wife and two children, age 3 and 5 are active in the c wttty. My wife belongs to
the Ti stport Junior Ro a d Table and is a Sunday School teacher at our church. The
organisations to which I belong ares Fuidy Ja rcees, Theasurer; director, Eastport
Memorial Hospital; finance committee, Eastport Zoning Boaxd of Appeals; vice chair-
man, Member Citisens Advisory Committee; D member Anchor Lndge might. of Pythias;
pest member, atport Charter Review C iastcn ; candidate, Eastport School Committee.
Nov let me ask you if you realis, what the c unity involvement might be for
the predominant segment that the attended our hearings.
Approximately 2 of the people were E atport residents, another 1C$ were State
businessmen and the rest being opponents that case from who Iwows where. Of the
stport residents the majority at hand were from the minority undesirable.. These
uulesirables are slowing taking over our city as their n abers increase. This being
attributed to no residency requirements for welfar, and the availability of cheep
blighted housing conditions. Our City Council has med. every effort possible to re-
sove these health hazard-sub-standard conditions as can be substanctated by the record.
Never the lees, this blighted area is a hayen for this undesirable type. Could we have
a breakdown of the $2 0, 000 received by food stamp recipients for the first month
period of 1976?
Without economic expansion this new society will im4oubtly prevail as economic
conditions weaken.
181—3
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December 7, 1976
Opponents say the new charter allows a ref erentha. This is absurd, the
new charter calls for referenduss on ordinances only this project was not created
by an ordinance.
Many facts were left out during the hearings but hopefully documented on paper.
My wtiee parents are Capa4 Ian. Her dad has two herring weirs one of which will be
the closest weir to the actuml refinery site, should it be built, lie is also a
saber of Charlotte county weirsana association k i has no strong feelings either
y. Those people that are for t would not dare show their sentiaente,for the New
Brusawick loan board holds title to 9C of all the boats from the area. This is a
bos d of men not rules and reiulaticns such as we are accustomed to.
In conclusion we (my f.aily) hop, you realize the undesirable segment predomin-
atad the meeting nd have been and probably will continue to be very vocal about
this project or any other project tncl thng uoddy should it become a reality.
Sincerely,
181—4
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A 1 i /9,70
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December 8, 1976
Mr. John KcG].ennon
Regional Administrator
U .S. Zavironnental Protection Agency
Region I
Boston, Jaeeachueette 02203
Dear Sir:
Thi, letter is being written for the purpose of ehitriag with
yen my feelings of utter dismay over nany of the nroc..dings
during the Rearing held in !aetport on December 3, 1976. A.
a nativ• of this ares and year—round resident of Ea.tport, I
re.,nt the planned disruptive antics of a highly vocal minority
of newcomers snd stranger. who attempt to lock out industrial
development of kind. This rtinority of loafer. i,rid maling.rere
is so intent onTIving off the land and taking advantage of a —
thing available to pror their frei living rid. t) st they totally
resent the eacroaehs.nt to this barren corner of th. world any type
of work—rslatd income-producing activity .ze.pt panhandling.
I want to r.it.rat. support of Pitt.tons applications. I
know, fron ezpsri.a.., that a h.a y majority of responsibi.,
working, full—tim. residents agree with me
To s truly,
Carleto I. Small
41 ynton street
Eaatport, !aine 04631
185-1
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DAVID L. BROOKS
ATTORNEY AND COUNSELOR AT LAW
Nollill w,CK ocv,cz
MA*kfT ITE T . $OX 41$
MOEllI aE$wIcL MAINE OSSOS
ao 4w
KENNESIINK. LOWIS V’ ‘4W . orr,cg
EAcM TMEIT
EENNESUNKPONT. MAINE 0404
December 8, 1976
U. S. Environmental Protection Agency
Region I, Enforcement Division
Permits Branch, John F. Kennedy Federal Building
Boston, Massachusetts 02203
Gentlemen:
On behalf of Friends of Intelligent Land Use (FOIL), the largest active
environmental group in Southern Maine which was formed originally to oppose
the NEECO refinery project proposed for the Town of Sanford, Maine, I would
like to voice our opposition to the refinery proposal of the Pittston Company
for the Town of Eastport, Maine.
Our opposition is based on several valid and objective reasons, much to
numerous to detail In this letter. However, although we recognize that our
opinions may lack the expertise necessary to qualify as “testimony”, still
we thought you would be interested to know that, even though the approval
of the Eastport refinery might relieve some of the pressure to build a
refinery in Sanford, we still firmly oppose the refinery proposal for Eastport.
DLB/vrc
R c fully yours,
David L. Brooks
Chairman, Friends of Intelligent Land Use
•Z °DEC
187—1
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Dec. ri, 1976
.qu1.tory Branch
11ev England Division, Corps of tnglneere
424 ?rapelo Road
Waltham Nasa. 02154
Dear SIrA!a.,
Unfortunately, because— my profession keeps me traveling, I have
just received the nVironmcntaI irpact statci ent regarding the Pittston
Cii Refinery PropoaaP. I find that I have only five days to again voice
ny view about the proposed Tittston project:, nd do so with a heavy hea-
hoping only that it will have wine positive effect in maintaininq
the integrity of the Cobscuc* fl ’ area. Sometimes I feel ao if a letter
like thi. does no qnod...that. Ir tb, . board I am In a minority of people
who feel that the Pittston refinery i* detrlr!rntal to the Cobscook area.
Ply fear that the majority of the people who are aep inst the refinery
are silent, I believe is an aecurate one Ny friend’, my neiqhboric
are sitting home throurihty cnnviociri thdt the 1 olitical biqwiqsN
have already made the decinionand there is no u o firthting it. The
cc- ion folk can’t stop pohitiral doings,’ th.’y say. “If it doesn’t
happen here Canada will give in. Nothtni viii save us now.” I feel,
on th. other hand, that there 1:; ii r h.ince my voice v iii be heard and
hopefully it won’t he on deaf ear ’ . J just want you to remember that
there is a silent majority nut there, local people as well a people
‘from avay who don’t feel that the inclusion of industry to an area
tnique in its rural aspect Is the way to qo. They.cherish what they
hive and see no nec!d for it In bcome mother N.Y., Hoston, or Portland.
They don’t speek and that’s unfortuhit.’.
I have read the E.I.S. st t. ’ mcnt and fee) that the risk of bringing
such an industry to Cobscook flay it; unconscionable. I don’t have to
tell you about the flora and auna that have been pushed further and
further dow i the roa it to I i , 4 Lb&m’etvea luwneast” • And now - the
e old story, we’ll create tess.. h.,bttat for them and they’ll be pushed
l 8-2
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further on, that is if they SUFViV . Thos ’ whal e s T ve seen in Head
Harbor Passage, along with aH the other wildlife are just as vital
to a sane world as the p oplQ who inhabit the earth, W holier as we
lose our natural b .tat 3 to lut ion and industry we cry because our
shorelines are rap diy de inq nnc3 no we re ready.to desecrate yet
another area. &n4 hy and f whom? For Fittston It s unfortunate
..that I have riot the cce ;i to a 1 the articles that’. rel&tø to Plttstori’s
mishandling of projects that tnt’v have been in lved in before, The
newspapers are full of such Stes . Maybe the following quote will
give you some feeling for the r p ny that nays they ‘ ...agree to
underta):e routine daily v mtI r octionn on the entire tsnkaqe and
pipeling network to detect any 1o kigo, ann periodic visual and
physical measurerent inspect ions to detect. incipient corrosion, stresses,
etc. which may lead to equip rert failure and oil leakaqe.” (E.T.S, p.247)
Please keep in mind the Al ;ka pipeline and the numerous infractions
of promises and then see if you can rationalize to yourselves that
Pittston will, keep its upromin .1
wTran. el, Virg3nla ir)Ok like a menoply board after the
players have finished their c amo, The narrow highway which
forms the center of towii i.s lined on both sides by rows of
identical houses. Farther up the side of the mountain there
are a few somewhat hu-qer hour;cs hacked aqainst the scars the
strip miners hk*vr oIt t t top of the ridqe.
But there are no qrand hotols, no park places or Broadways
in Tramn el because Trammel represents the game of Monopoly
as it is plnyed in r’ a1 Jjfc American free enterprise
style and the winner in the game, the directors and shareholders
In the naronou h Pittston Company - thesamo people who brought
us the uffilo rreek ctisa ter in 107? in which l2 died -
which nuns the Clinchfield Coal Co. mines atound Trammel, are
not. about , th -ir hor in he narrow soot filled valley
with acid polluted trearns inbt.P& d of sidewalks and strip—
mined hills for backyards.
Trammel is a cer us taker i iradise everyone in town is an
emnloyee of Clinchfield CoaJ Co. U’ITTSTON). More accurately
if you don’t york for t.h” empany you don’t stay in Trani’nel,
The hous es the squat corn any store building, the church are
all as much the property of CiLnchfield Coal as the coal which
is daily duq out ot Moss , the ompany’s newest mine 20 mileS
from town. Airroet any fcmily ihat decides to buck the company
finds itself job hunting and hQU hunting the same day.
-------
—1—
Perhap. the onl oxce .twn to this rul* Ln Trammel is the
Tiller family. They havi Mtayee$ on in their. house halfway
up the hill bocauso John Tillr, a foreman at Moss *3 knows
) to get coal out of the ground better then alst any
othr Man aUves and because the men who run Clinehfjeld
Coal are justifiably tearful of the consequences of tryinc
to fight folk who have already stood up to them and othera
in so many attlev.w (Hillbilly Women - X.Kahn, 1974)
hy does history cnnsistr ntly repeat Itself? flow many times do
peopl, that are living in rura L areas have to be battered around, left
at the eercy of corp6rate pohIei sf policiei; vhieh most orten don’t
•1
take into account the needs of the local population. Remember that
your. decision affects the Wash nqton County resident; that my life
and the li s of y neighbors wUl be ffr c1:r’d by a handful of men
who hopefully realize that industry has rear .od other areas of th’
country and that industrializathin ran and should remain in areas that.
ar. set up to handle such r’ uderni7. ation and technologic advances.
I am ttrd of empty promisc . ‘We’ll build the husk pipeline’
to keep our country self—sufficient.” Sn now whero Is that oil going?
To Japan. Does that make sense? Pm not sure It does. It seems
absolut•ly pitiful to destroy Cub cook flay; the risk and the cost i
just too great....It seems to me thdt all concerned should go to bed
tonight and dream dreams instead of niqhtmare& .
Sincerely.
lY1 ss.iV cV S).-
188—4
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c i
MAINE LOBSTERMEN’S ASSOCIATION, INC.
TELEPHONE 207-367-2409 BOX 128 STONING-rON. MAINE o4eei
EDWARD A. BLACKMORE PRESIDENT
•13 DE.C December 9, 1976
ME 0022 420
US, nvironmental Protection Agency
Permits Branch, Enforcement Division
J.F. Kennedy Federal Building
Boston, Mass. 02203
Gentlemen:
At this time I would like to state that the Maine Lobstermen’s
Association is positively opposed to the possible construction of’
an oil refinery at Eastport by the Pittston Oil Company•
The possible adverse environmental impact on coastal Maine is
totally unacceptable. A major oil spill could devistate the coast
of Maine. Has Pittston guaranteed to financially support all
persons whose lives and livelihood are affected by any and all oil
spills? If the answer is yes, oil refinery construction on the
coast of Maine would still be undesirable to Maine fishing and
coastal interests.
There has been no guarantee of nore economical or even plenti-
ful oil for use by Maine people if a refinery is constructed. Any
possible benefits (if there are any) other than to a handful of
people in the Eastport area, are far over-shadowed by the environ-
mental dancers of water and air pollution.
Weather conditions along the Maine coast are probably the moat
unpredictable and most severe of any place on the Eamt Coast of
the United States. There is no possible guarantee that a major oil
spill will not happen. ven with todays modern technology for oil
transportation, there is no fail—safe method. Modern electronic
equipment works well under good weather conditions. However, it
is a well k ow fact that electronic equipment performance deteri-.
orates as weather conditions deteriorate. Judgements will have to
be made by humans, and of course wi] . ) be subject to human error.
The Canadian government has taken a stand opposed to the move-
ment of oil taniers through Head harbor Passage. They do not feel
it safe to navigate large oil tankers through such a narrow channel
in an area subject to violent weather conditior s and daily tides
aYeragtng 18 feet. If the Canadian government feels that the in—
evitable oil spills would be detrimental to her fishing industry
M d castline, should not the United States be even more concerned
when the currents (often in excess of 2.5 knots) run in our direc-
ti ?
189—1
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MAINE LOBSTERMEN’S ASSOCIATION, INC.
TELEPHONE 207-307.2401 lOX 125 $TONINOTON, MAINE 04011
EOWA D A. BLACI MO L. P U1DENT
Maine is well known for its clean air and unpolluted
waters, this is our heritage. 4e want it to be our childrens
a*i our grandchildreus heritage. Maine fishermen have no
intention of sellirg this heritage or giving it away, and we
certainly hope that no agency of the state or feaeral govern-
ment will allow it to be taken from us.
Sinosrely,
Sdir A. lackmore
President
LAB aho
cc: Barbara Lehigh
N.E. Div. Army Corps of Engineers
189—2
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Deceaber 9, 1976
fr. Jo A. NoOlennon
sgiona1 £ inistrator
viroatal Protection Agency
ohe 7. [ .nnsdy &dlding
Ho.ton, Mass. 02203
Dear Mr. Mo0laononz
r. I vie involved in. stateseat nods by Mr. Dcc Hobgino
(so doctor) of Lubec at the E.P.A. hearing in Ea .tport on Dec. 3rd.
I 1d like to • a rebuttal to hi. statasant.
In M 1973 the City Council voted not to bold a f•y
ci the Pittston oil pians for ZaMport. My in reason far
voting sgdn.t a rster wbiu via because there was not eacigh
infoivitici available far the psopla to a an intelligent
decision. 3iicb a n i aartant decision s ld not, in r opinion
ho based on poxu ti q *li Because of this I believe that
the realts of a refrasdvi mdsr thos . condition viuld not be
objective or valid,
My tan, as a n Ea . ort Coupci1 expired Dscb.r 1973.
This via the s year I voted not to bold a referentha. I
ches. to seek another toxw of the Council for a .o ysar period,
The people of Ee.stport vint to the polls Decsabsr 10th and
voted. I received the highest n r of votes cast. (proof enclo..d)
In Mr. Hobgin. statent he stated that I got beat in the election,
His testiacoy via anything but the truth,
I
I rs— 4 you - trp1 , ii
f .m th J. Leightom
191—1
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.jt’I CO C t
This is to certi ’ t t tr.e FCCQrde of the City of aetport,
::ei e. & ,: t ‘o1iowin votee ceat for Kenneth Leighton
ir the : urLiCi .i E1ectiox helc Dec. 10, 1973 for T o Year
Te or City Courcil:
i’OR C0 .CILJ : For Tvo car re — Vote for 1)
C’D 11, J n k . had 192 Votee
Urad , Jol-.xi £. had 2 + Votes
Leightor, Kenneth had 3E3 Votes.
. true co y
tteet:
City CIerk Laet,ort,1’ ne
December C, ].97(
191—2
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Deoe3bez’ 9, 1976
#IS 0022420 ______________________________
Your or.dibi].tty ii on th lini, A . 1oyee..
JJ4A
rb.rs Lshig
7 C *t House Stret
sstport, Katne 0ie6 1
‘ 0
192—1
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cbsr 9, 1976;
1egalator aranea
Nw EàQland Division, Corps of Znginseg .
$a ltb .a ,IIaes... ‘02154
• 1’I nat through th Invironmental Impact Statesent rigarding
fittsto ’ proposed oil refinery and marine terminal several que..
tioaia and .tass 0% concern came to mind. My background and educa’.
•tio La in the tLe ld of natural sciences p 1 am presently working
t her of th s ecological, biologjcai, and natural science.,
SmrrLslDgly,. soat of my quest ions do not even relate to the 00*
logical hizuds posed by the oil ref inery. I feel that the chemce
of *.pill.U* nois., sir and water pollution, odor, threats to
squatjc animal, and plants, and any other environmenta3. impacte it
vill’b*y. on the ares are deb itabjo. Pittston say. that the r•f in -
.*y 1111 comply with ?ederal and State Enviro,wentsl Protection
£gem y regulations, they say that use of sonar will. cut down o
the psaibility et a spill; they say they vi i) employ a spill con .’
tab,pt system; they say they will use the latest technological
•tVatrót. to ainimit . environmental. damages. Were aU these aesur-
sacn de prtor to approval of the Alaskan pip.lin.? Or, are we
1 stemiag tO rs hollow promises?
no on. can say Pittston ygj , comply with present Stan-:
dardap and,! don’t (eel knowledgeable enough, or enough of a
psythic, to predict what Pittston won’t do • My fears are for
ths’probl less tangibl. and more aesthetic. My concern is
for d erior.tion of the quality of life ( jj, life) in the ares
Surzis d&ng. the proposed refinery, an ares which Ma until sow.
escaped.. industrill devejopoent, There ar. not enough undeveloped.
emejtifi.d ,. unindustriaiised, unpolluted areas in America; for
s ciety to nione the virtual rape” of an almost pristine corn’.
* iityi* inexcusable, If there .xi . any feasible alternative
lOca%Losof this facility or a comparable facility - in an il .’..
resdy opulatd, developed urea, thón I say e iplor. that. po.eibil
ity . and do so v th all th. money, tim., energy, and resources
tt*t- bvioualy wer, available for the Eastport study,
CC
19 .i
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-2—
F ]or• that eesibility, but before doing so let’s ask our-
— qus.t v ass. is it to build an oil. refinery in
e yr 1976 at all? How forvard-thlnking and progressive are
vs v &1I.d monuments to n.an-renewablc ronourcnn? Are we build-
ing M l ref jn.ry to serve the needs of generations to corns, or
the idiat. profit mot vrn of a few? As vo quickly approach the
day vii our aoyce of oil will be depl tod, or so I am told, are
ftv is the * Ss Ages to assume another oil refinery is a
su{ s.a,1tyt
L i ii if V. da 4.CL that an oil ref tnery is a must, we must
resUme t the IMen we make here is permanent and effects
for ge tions to t the Cjtu tat community, t vote for
myself, childr , sad grandchildren to keep Soston, Doatonj
Portlaplip a4 Zastport, Matport.
Sincerely,
Roth Nagusky-Trocco
Luboc Resident
93—2,
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Great Northern Paper
o company of
Gv.ot Nerlh.rn Nokoosa Corporation
Robert J. Shinnors
Vice P. v idwnt Opera tions
December 10, 1976
Mr. Richard Keppler
Region One
Environnental Protection Agency
JFK Building
Boston, tiassachusetts 02203
Dear Sir:
Great Northern Paper Company Is a manufacturer of paper and lumber in
the State of Maine with mills at t i11inocket, East flillinocket and Ashland.
pproximateIy 4,000 persons are employed in company operations with an
annual payroll of nearly $50 million.
In the paper mills, we use 2 1/4 million barrels of No. 6 oil to
generate electricity and provide steam for process. Great Northern also
operates a hydroelectric system, generates steam and electricity by burning
bark and conducts an energy conservation program.
If the Pittston refinery obtains the necessary permits for construction
and operation, the project is favored by Great Northern. An Eastport
refinery would have a favorable positive li pact on Maine and the state’s
industrial community as well as becoming a potential source of energy for
Great Northern.
Studies indicate custocers of the refinery In the northeast may receive
savings in transportation. It certainly will provide Maine customers with
an additional supply source in this region.
I rec uest that this letter be placed tn the file of the December 3
public hearing.
Sincerely
-------
10 Dec. 1976
Mr. John )4cGlennon
Regional Adainfatrator, District I
Environaental Protection Agaucy
John F. Kennedy Federal Building
Boston, Mass.
Dear Mr. McGlennon:
As a follow-up to ey coweents in wy letter of 21 Nove er, about the applica—
tion for a refinery perait by the Pittston Co., in Eastport, Maine, let ne
say the following:
I appreciated the rather even—banded, tolerant way you ran the bearings in
E.atport, and the incisive way you questioned the Pittston witnesses. There
are, however, two points I wish to sake on the general subject of balance and
just allotaent of ti at the hearing: (1) Because of the fact that all the
general public c ts case after 5:00, and continued to the vicinity of mid-
night (I left syseif around 10, beIng weary with a long drive end car trouble),
the anti—refinery couts tended to reach a saslier audience and even to be
dilguted in nusber, as seas of the public drifted avay because of the lateness
of the hour and never did co ut before the panel. Most of those speaking
after 5 p. c. did oppose the refinery, as you recall. Therefo.re, the sched-
uling alon, aids the anti-Pittston case appear weaker than it should have--
e.g. if the bearings had bsgim at 9 as instead of 1 p.. ben so, as you
suet have, noticed, the audience seewed o,erwhel ti gly against th. refinery,
and a great aeny peopie got in their c nts against it and in favor of al-
t.rnative ideas such as tidal power. (2) You said at one point that it is
inappropriat, to dwell on th. character of the applicant, Pittston Co. There
was only one lone voice dissenting free this opinion. I too wish to dissent,
and .to point out that the aeny vague features of the p Pittston case—whether
or not it will perforc slaulation studies of oil spills (La you rightly pointed
out to as, we need sure ezact inforeation on this subject, and it cannot be
obtained without such studies), whether or not it would pay for a lock if the
tidal power des. were constructed, etc.—depe d a1n1y on the good will and
integrity of Pittston, unless firs guarantees are instituted. The background
and character of the firs therefore plays a great part in deciding whether or
not they will re 4 ” true to the spirit of the negotiations. In connection
with this whole issue I enclose for your inspection an article & T. B.thsll
and D. MoAteer frow Washington Monthly, May 1972, titled “The Pittston Mental-
ity: Manslaughter on Buffalo Creek,” copies of which have been widely distrib-
uted around Eastport by Robert S. Jones, retired USGS geologist who lives in
the city and spoke at the hearing. Thu reveals great doubt as to the eincer’
ity of the Pittston firs in following enwironsental precautions, to say the
least. Perhap. you have been sent a copy already, but in cue not, here it is.
ur sincerely,
do Dept. of Earth Sciences
Morthsutern Thiiv., Boston, Mess. 02115
195—1
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t li y:
aa iat hter oii
u a o Crec ek
by ThOmas Nt Bethell and Davitt McAteer
RepdnWd from The WSIPJV4ION hlo.uhiy
May, 1972
Cop riçhI
The Wuhlngion Monthly Co.
1028 (onn *kut . e..
Wa tiân ion. D.C. OO36
/
)
195-2
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SI .e..mboft’s e iSo’ of
fls W- ’Os MimiNg isd edit.” of Coal
Puss D.’us *4* . .’ ‘S . lS i ,a
1 N.*’ C4.’ fr . she S .1
L i ‘ eL.
.lVdo CfveL in Loise County. us
,emsssbly typIc for sit. soudusut
pat of West Vir nla-a king. winding
below.. viaking between steep ridges
thsidesf thin ZO t&cs
from the town of Saunders. at its
htadwaecrs to the town of Man.
whore the creek empties into the
Cuyandoite Ri ei. which flows north
to join the Ohio RiSCT at Huntington.
The uasuow valley is just wide cnou
b the cr eek. the. raikond. and In
idumut unsu ding line of cbmpsny-
bdt houses stret:Iung aIort both
sides of the ira ks. there are o ,casion-
ii wide places in the balky where
iuibutams flow into Buffalo Creek.
and in the wide pla .es there used to
be towns—small towns that nohody
oecv heard of. $aies like Kistler,
Crown. Acco i)le. Braeholm. Faoco.
urea. Amherstdale. Robinette. La-
statue. Cnies. Stowc. Lundale. Cmne
to. l.ouad*. and PariJee. Some of the
-- come From coal onipanws thai
no lougee e ust. As coal lown% go.
these were old. most of them built
before Wotid War I. They were in
earvthg stages or dedine. Some of
then. were one wnch more thou port-
office addiemes The old frame twO-
family houses were settling univenly.
Some had collapsed altogether.
Othes. considering their age and the
haste with which they had bee.. built,
were in surpminglygoodshzpe.Aaa
general rule. ii a house was freshly
painted you could assume that a
workir.; miner lwed there.
The population of Buffalo Creek
has fluctuated with the times, declin-
ing when the indusst) declined, re-
covering when the industry r ered.
In 1970. coal had its best ycar .mce
947, and a rosy glow of optimism
suffused National Coat Asiociation
predktions for the future. Big coor
£anie or ned new mines along Buf-
falo Creek and stepped up rroduction
in their old ones
When oid coows up out or the
ground. the impurities that ci’m with
it are sqauted out in preparation
plants—tippici. as they are more cotw
manly called. The coat rolls away in
long black trains, the impurities stay
behind, and something has to hc done
with them. They have a way of
accumulating with sta ring speed: a
loss of raw coal generally cuntamsup
-------
to 5 tier tint tr.tn “* tn .aterial.
j h.ut4lliiig the
ol r .,l iint — .11 Iifl ’.
will scl ’arale naI I l’ntt’j.i.ls iii tons of
w .$tc iw r iL li;ic,s hjse dilkrenl
names fur at • b ” or l.ig” or
“cidm ’ — but uI J! ter oai call j .
still l:a ’. to h ; tied ume Iwre. In the
rowdcd h’ll. .s s • f t ’ .t Virgtnu.
finding j’Ia .’. ti’ pile slag i’ a problem
of major rr P1 .r on As a
rule. no ePgineet 1’. es:r calkil in to
consult on the anti safest loea•
(ions. Insteid. the tompaity superin-
tendent simrly htist around for some
sacant Spa eonvt’ment to his tipple.
and the slag is dian’pv.l there. either
by trucks climbing up a mountainside
and dumping down thy ‘ .h’pe. or by an
aerial tramway slntng between peaks
and dumping in the middle. Whatever
v’stcm is used, the slag is piled up
t.ntil it is higher ‘tan th dumping
spot, and then a new pile is started.
Facing the Cub
Since t°4 a tipple has bec’i in
operation at the head of Buffalo
Creek. The plant was huilt by the
Lorado Coal Mining Company. a
niu,tly local outfit Uut sold out to
the Ihiulalo Mining (ompany in 1964.
Buffalo Mining, in turn. sold out in
l ’t70 to the Pittston Comnp.niy. .hiich
i ’ headqsiartervd in Nesi York and is
th largest ind! re mIknt proiliicer of
oal in the Untied St.itec M I this time
the tipple continued in ( eration.
And all ths time it grew. OrigInally
desagned to rro coal from a single
mine. it was expanded periodically as
new mines, were opened nearby. By
l°72 Pittston wj operating a tOtal of
eight mines in the Buflalo Creek
s’tcinit - live of Iltem underground.
three of them stripping joba. The coal
from all eight was iroccssed in the
singie tipple. On aserape. the tipple
opcrahd sic da% c a week, two lufts a
day, handling about 5.00 ions of raw
i.u .J daily. aJaipping tnii about 4.. (X)
tons of cleaned coal on the lunie
Chesapeake and Ohio trains. That
meant that esery dii) a thousand toni
13
ol pub. more or less. had ti’ he
dumped.
Three tributaries nun into Botfalo
(‘reek imear the Pittston tipple. Fn in
1947 until about 1955. the refuse was
dumped along the hillside a few hun-
dred yards upstream from the tipple,
hut by 1955 the available space was
mostly exhausted and the tippic began
dumping a little farther away, across
the mouth of a small hollow where
the Middle Fork tributary met the
creek. At first the gob p1k grew
slowly— it had to. because most of the
hulluw behind it was occupied by
miners living in cOfltp3ny houses. But
when production at the tipple in-
creased, the growing gob pile began to
menace the houses, and the miners
were forced out. The houses were
abandoned—some of them were
knocked clown for the lumber—and
the gc b was dumped whir’: the . iad
stood. The tamflies mo ’ed away. :ume
of them out of West Virginia entirely,
some of them only a few hundre4
yards. wtthng in vacant houses mi the
small com.nunhty of Saunden. which
stoon taclnj the gob pile at the
intersection of Middle Fork and Buf-
falo Cteek.
Saunders W s Cots.
The gob rUe stew, and grew, and
grew more swiftly as the tipple kept
expanding production. At first this
gruw .i uc black mountain was only an
eyesore. Laic’ it became a source of
air pollution and a fire hazard. Gob
piles may be nothing hut waste. but
mitch of that waste is Ilammable. and
a combination of compaction rod
oxidation can result in spontaneous
combustion. Once a fire gets going
deep within a gob pile. extinguishing
ills nearly impossible. The fue smoul-
ders. sometimes bursts into open
flame. fouls the sky with acrid smoke.
and occasionally produces an explo-
sion. The fc’denal Bureau of Mines h
spent millions of dollars In research On
the problem. but the end result ii that
hundreds of gob piles are umouldesing
in the Appalachia. coalfk4ds right
now, and nothing is
them. The gob p11
began burning year
s mnou ldcr ing.
As the dumpin
oilier prcih)cm aru,
va.t quantities of ‘.
ingicf larating proCt
be a scarce comim
Weit Virginia. Partl
with a reliable yea’
water, partly to s.
Slate regulations
pollution. Buffalo
build a serics of scit
(previously the cc
water had simply be
into Buffalo Creek,
tions of people
there). The ponds
building retaining a
immedial ty convS
top of the hur Mi .
By that time the
stupefying proporti
10-story office lii
a ross. stretchingba
more than a quartet
down through the;
across the top. the’
Fork ran slu ishly
stream of Buffalo
the water was a
using the material
mine waste. No ci’
right mind would pP
tion of a dam from
mari a coil enD,
confirm—Nit no em
pears. was consulted
In operation. ii
not only contained
thc hilis. hut rcfus.
from the tipple.
would settle out amis
be piped hack to ti
of thc ponds imru.
small soluatne of wa
ii sdted up within a t
second dam was bui,
tarthc’r upstream. W
operating 1u ll lit
500.000 gallons uMi
ing back between 4(
ut wask-rdkd wit
-------
_________ — — . • — —.—..- — -
a. . a.e -a 4 S
13
or k s. had t he
‘aries run into Uulr lo
httst,rn tupplc. IOHA
“I 1955. 11w was
the hiIt ide a few bun-
tream from the tipple,
ht available space was
d and the tipple began
e Iarthcr away, acruv
a small hollow where
‘rk Itibutaty met the
.1 the gob iile gi w
to. because most of the
it was occupied by
company houses. But
‘on at the tipple in-
wing gob pile began to
riuses. and the miners
but. The houses were
‘me of them were
for the lumber-aM
imped where thc d
-lies moved away, :ume
West Virginia entirely.
• osdy a few hundrel
fl vacant houses sa the
1) oF Saunders. which
the gob pile at the
Middle Fork and Bia(-
‘e grew, and pew. and
Itty as the tippic kept
‘duction. At first this
¼ mountain was only an
it bcc anw a source of
nd a fire haiard. Gob
•lOthiflg t ’III J 5t . bItt
AJ%te is flammable, and
of compaction and
t utt in s ’unt1nCoUS
a lire geb gning
• oh pile. cx%ingui hing
ns iblc. 1 he fire smotil’
ics burst’. ilito open
e ,ky with acrid smoke.
Uv produces an explo-
r4 Bureau of Mines has
‘f dollars in rcs ’arch on
‘ut the end resuI . is that
h piles arv ‘.mouklrnng
chian coalficids right
now, and nothing is being done about
them. The gob pile at Middle Fork
began burning years ago and kept on
s,nuu ldcriflg.
As the dumping continued, an-
other problem arose. Tipples require
vast quantities of water in the clean-
ing.separa ting process. but water can
bc a scarce commodity at times In
West Virginia. Partly to provide Uscif
with a reliable year-round supply of
watct, partly to comply with new
state regulations governing stream
pollution. Buffalo Mining began to
build a series of settling ponds in 1964
tprevlouslY the contanunated wash
water had simply been sluiced directly
into Buffalo Creek, despite the objec-
tions of people who liked to fish
there). The ponds were created by
budding retaining dams In the most
immediately convenient location-on
top of thc.huge Middle Fork gob pile.
By that tune the pile had reached
stupefying proportons: as high as a
lOstory aWice building. 600 feet
across. stretching back into the hollow
more than a quarter of a mile. Seeping
down through the pile and wandering
across the top. the wawss of Middle
Fork ran sluggishly to Join the main
stream of Buffalo Creek. Damming
the water was a relatively easy task.
using the material closest at hand:
mine waste. No civil engrneer In his
rq ht mind would permit the construe-
lion of a darn from such materials —as
many a crsI1 engineer would later
confirm--hut no engineer. It now ap
pears. was consulted.
In opemlion. the settling ponds
nut only .ontaincij runoff water from
the hills. hut refuse-filled waler piped
from 1 1w tipple. The solid r fusc
woukt settle out and clear water could
he piped hack to th tipple. The first
of the ponds impounded a relatively
small vidume of water. however, and
•t silted up within a couple of years. A
second dam was built in l%7. slightly
Iarther,i.pslrcam. When the tipple was
opvrjtsng full blast, It required
500.000 ptlons of waters day, pump-
ing back between 400 and 500 p11cm
of waste -filled waler every minute.
Some of the wab,r wOUld seep out
through the porous dam. but the
waste settling to the bottom- 500
tons cvcr day —rapidly filled the.
pond, and a third darn was built in
1970. Again, no engineering was in-
volved. ju%t truckloads of mine waste,
a buUdozcr to push them around, and
presto! a dam grew across the hollow,
built of nothing hut junk, standing on
a foundation of slime and silt and
dead trues. The trees were there be-
cause nobody bad bothered to cut
them down. It was simpler and faster
just to dump on top of them.
In West Virginia. February means
snow and rain. February meant it this
year. as always. In Login County.
there were heavy snows and flash
floods—but they were, as the state
meteorologist would later point out,
“nothing uncommon.” At the head of
Buffalo Creek. the waters rose behind
Pittston’s makeshift dam. Early on the
morning of February 26. Pittston’s
local mine boss, Steve Dasovich. sent a
bulldozer operator up the access road
to tire dam with instructions to ut a
Jramage ditch to relieve thc pressure
from the swollen lake. The access road
winds around a mountaistide. with
the dam out of sight much of the way.
When 11w bulldi’i.cr operator finally
caine around the last bend and looked
through the rain at the dam. he saw
with a sudden. t rriM shock that It
wasn t there.
The dam was got’. and 21 million
cubic feet of water and an immeas-
urable mass of’ mud J1.J rock and coal
wastes were charging tucaugh the nar-
row valley of Buffalo Creek. From
where he sat on his sud ’nl . useless
machine. th buildo?cr opt ntur could
look down toward the lit Ii town of
Saunders--a town consisting .1 noth-
ing more than a church and -‘.ne two
dozen houses. Now it consi.ied of
nothing at all. ausnders was gone,
eradicated eompktcl . Beyond iauw
den, the valley cursed i ’iay out of
catbt. but the air was filled w.tb the
terrifying sound of the flood bearir 1
down on the IS communities In Its
path.
-------
I. were no sijip or fcdeiul rv .$amatlon
a ir 0* rip. t.nIn , _ ,,,, , reii”ircments. flu money had to be
fliers’ are no l g hc.ap on Pjrk ‘pent on hindlnp up the wnunds. It
m d no floods wiH ever w h must havc been the best of all pos ihle
through the offices of Joseph P. world’. unless you lired near one of
Routh iir.kss the isl.ind of Manhattan Rotith’s mines. I1 , of course, didn’t.
sinks into the sea. Thirty-five (loots Routh kept himself busy with
up in the Pan Americ.u building, the other conquests, plCkh)ç up coal corn-
.hairm in of the Pittston Company has panics in kentucky, West Virginia,
a comm.indir.g view. When he looks and Virginia, buying up Inicking corn-
down to the street bclow. he can see panics and warehouses in New York,
Brinks armored tnscks moving the entargsng his oil-distnbut.Ing opera-
wealth of America from place to lions, hatching long-range plans for a
place. The irv ks belont to J giant refineiy on the Maine coast.
Routh. A good ‘deal of the money Money flowed from Routh’s various
does, coo. holdingi into his Manhattan office in a
Routh Is 79 now, and he has ii never-ending stream, and Routh
making money longer than most men bouht Brinks, Inc., to cany the cash
h3ve been alive, lie was already a In his own armored cars.
power to be reckoned with when the
Pittston Company. which then oper- M Act of
ated 3 dozen anthracite mines in
Pennsylvania, stumbled Into bank- Despite abundant evidence that he
nipicy during the Depression. A was in no danger of going soIl, Routh
friend at Manuta turcn Tnzst sug- decided In 1969 to bring In a new
gested to Routh that he take over the president. He looked around for a
company and lecd it out o( the man to match his own toughness and
wIljcrncss. The bank sweetened the ‘found one—a 53-year-old native of
offer with a S 10-million luan—cssen ’ West Virginia named Nicholas T.
tiatly unsecured, since there would be Camicia who had already made a mark
no wa to recoup the loss if Pittston in the Industry as a notable scrambler.
went under-and Routh moved in. “The coal Industry Is run by men who
Anthrncite. he concluded, was a dying got where they are by not being nice,”
industry. The future lay In the vast says one former federal ofltclal in a
bituminous flelds of Virginia and West position to know. “and when Cemicla
Virçinia. He unloaded most of Pittc- smiles, you can hear his jaws making a
tons properties in Pennsylvania and special effort.” Routh liked him fine.
began bu ring up tracts of coal in But Camicla already had a good
central Appalachia. job when Routh approached him
At a time when coal prices fluctu- about taking over Pittston. Routh
sled wildly, he h I discovered that reportedly told him to writc ’ his own
the best way to tear loose a chunk of ticket, possibly remembering his own
coal in time to take advantage of reluctance to sign on until Manufac-
favorable trends was to strip it from turers Trust gave him the 510 million
the mountainsides, rather than go to play with. Camicis did. In fact.
through the difficult, two-year-or- wnte his own ticket, putting his ug-
more process of engineering and con- nature to a contract that has never
strucling a deep mine. By 1930, when been publicized, but makes fascInating
strip-mining was stilt an infant Indus- reading In the archives of the Securl-
try In Appalachia and conservationists tics and Exchange Commission. The
hadn’t the foggiest notion of the contract runs until 1.976 and guaran-
plague to come, one of kouth’s corn- tees Camicla Aol only a minimun
panics, Compass Coal, was profitably salary of $100000 (increased now to
tearing the hills of Harrison County, 5134,000). but stipulates that a tie-
West Virginia, to shreds. Since there ferred salary .1 525,000 will be set
• j J ea,
paid’
• install
tired: 1.
ht’fur t
appears
at Itactivi
show,
pickcdt
imately
378.000
market
Was livül
Chieago
him up:
to New
buy his P
him. cc
within
hattan. I
reported,
his emp
If e
Routh
industry
pelled
dgned
te I ifld’
make c.
su—y,•
1970 P1
third at
tnctal1u
one cot
Routh (
oiler it’
however
with th
deliver
the ncz
age of
twice th ..
Pitist
last yen
twice ..
for-one
pany ru
working
veloprr
gn ; i Itt.
mirte r4
pleased I
195-4
-------
• feãssl ftdltMatiOIl
money had to be
• np the wounds. It
ic best of aR puisiNc
)%i lived near o’c of
‘e. of course, didn’t.
himself busy with
‘Kking up coat corn-
ky. West Virginia,
ing up trucking corn-
owes in New York,
•distnbuting opera-
n fane plans for a
the Maine coast.
in Routh’s various
tanbattan office in a
re a, and Routh
;., to catty the cash
dears.
nt evidence that be
of going soft, Routh
to bring in a new
ked around for a
own toughness and
•ycar.old native of
mcd Nicholas T.
trendy made a mark
i notable scrambler.
are by men who
by not being nice.”
edcmI official in a
‘and when Canada
er his jaws making a
uth liked him fine.
keady hid a good
approached him
r Pittston Routh
m to wtiie his owe
nciiibering h own
on until Manufac-
‘len the $10 million
tnicsa did. in fact.
ci. putting his rig-
.k:* that has never
it makes fascinating
hives of the Secure’
Commission. The
1976 and geuran-
only a ininimun
(increased now to
‘palates that a de
S.00O will be set
aside each ) ear. compounded. and
paid out to him in I 20 monthly
installment’ whenever he quits or get;
flred ii he rcachc retirement e ’c
hefurs’ that. happens. lie also quahfle%
for a hefty penile. The coeflract also
appears to have Includ ed ,nrne highly
attractive stock options: SEC records
show. for example. that Camicia
pickcd up 7.200 shares, worth approx-
imatt4y. $270,000, for a price of
S78.000—tess thin a third of their
market value. That wasn’t all. Cainicia
was living comfortat4y in an exclusive
Qlica o suburb when Routh signed
him up: in return for agreeing to move
to New York, Canucia got Pittston to
buy his house for $90000 and furnish
him, cost-free, an equivalent home
within commuting distance of Man-
hattan. He went to work for Joe Routh,
reportedly satisfied with the terms of
his employment.
If ever there was any doubt that
Routh and Carnicia were a pair of
industey touchdown-twins, It was dir-
pclkd earl) in 1970. when Pittston
signed a contract with the Japanese
steel industry. The Japanese wanted a
mi-term con tract and were wifling to
make concessions to get rcliable
supply of American coking coal. By
1970 Pittston had pined control of a
third of all the avaikbk commer .ial
metallurgical coal in the U. S , and no
one could offer more reliability than
Routh and Camicia. The) would not
oiler it without certain stipulations.
however. The contract they ‘igned
with the Japanese calls for Pittston to
deliver 140 million tons of coal over
the next 10 years at a reported aver-
age of SI $ per ion, which is about
twice the going rate elsewhere.
Pittston’s directors were so happy
last year that they boosted diiidcnds
twice and voted themselves a three-
for-one stock split to boot. ‘(he corn-
pany now has more than 50 mines
working with nine more under de-
vdopmcnt. and there is no end to the
good times in sight.
is everybody happy? No Fcderal
mine inspectors in Appalachia are not
pleased with Pittston’s safety record.
195.u7
they never have beet padwularty
pleased with it. but the past couple of
yeai have been e pecialIy had. Nine
miners lost their lives in 1971 in
Pittston mines (Iwo of them in the
newly acquired Buffalo Mining divi-
sion). another 743 were seriously
hurt. and the company’s accident fre-
quency rate was one of the highest in
the coal iiidustry. The record in 1970
was even worse: IS dead. Investigators
found that in a solid majority of the
fatal accidents bad management prac-
tices (rathcr than pcrsonal careless-
ness) were to blame. “The company
appears to b c sincere in ifs desire for
health and safety throughout its
mines.” one inspector wrote. “This
desire.” he added dnly, “is not always
fulfilled.” Not always. All told, some
98 men have been killed in Pittston’s
mines in the past decade, and a 1963
explosion in which 22 mci, died still
ranks as one of the worst of recent
disasters. Three or four thousand men
have been seriously injured or maimed
in the company’s mines since 1962.
and the Ii. 5. Public Health Service
estimates that as many as 5,000 Pitta-
ton minus may have developed
pneumoconiosis during that time. The
profit margin of thie ne Japanese
contract is a reported 24 per cent.
almost three times the normal profit
margin in the coal industry; )ou can’t
help marveling at how much of th it
money will be going back to the
diublud derelicts living out their lives
In Appalachia after destroying them-
selves to help make Joe Routh a
millionaire for the third or fourth
time.
Pittston’s stockholders don’t ha’e
to concern themselves with such
things. because they don’t hear about
them. The company’s handsome four’
color annual reports talk about
money. not abuut people. There .ae
pictures of freshly pain* ’d oil storage
tanks. spotless amiore& trucks, gleam-
ing computer banks—and aerial pic-
tures of the long. black Coal trains
winding their way through seemin tly
virgin Appalachian valleys. The pic-
tures are taken with care: on the
-------
inside Puck cover of the 1971 report
there is a color shot of lo ely hills and
hollows with a sturdy complex of
mine huililings prominent in the fore-
ground. “Aerial view of the Lorado
Mine or newly acquired Buffalo Min-
ing Company. ’ the caption reads.
Beyond the mine. railroad tracks
stretch away. disappearing behind a
hill. If you could see beyond that hill.
ybu would see the massise. smouldcr-
ing gob p1k that stood at the itcad of
Buffalo Crock, and on top of it the
jeny -hu4t dams thai Pittston used
with its prcraration plant. Rut those
things are not part of the picture, not
part of the annual r por(. As far as
Pittston s stockholders were con-
cerned. they never existed—not until
the morning of February 26. when
suddenly the dams collapsed and the
burning gob pile erupted and all bell
broke loose.
Heli.opters were still thrashing
back and forth bctwcc, Buffalo Creek
and the nearest hospitals when report-
ers began calling l’tttstun’s New York
headquarters to find out what the
company bad been doing to cause
such a monstrous disaster. (‘amicia
and Routh weren’t available, wouldn’t
answer the telephones, wouldn’t re-
turn calls. Fin3ll), Mary Walton or the
Charleston Ga:etie flushed out a Pitts-
ton lawyer who iniisted on remaining
anonymous. hut was wilting to give
the company’s point of view. “It was
an act of God.” he said.
Dasuvich’s Yardstick
“‘Act of God is a legal term.”
Robert W iJfjll remarked when he
heard jhout Pittston’s explanation of
the flood. “There art’ other legal
terms -terms like ‘involuntary man-
slaughter because of stupidity’ and
‘cnunina) negligence.’” Weediall is the
We i Virginia state climatologist the
man who keeps track of basic acts of
God such as rain and snow, He was in
,. better posi; .or. than anyone else to
know whether there could be any
possibility that Pittston’s dam had
colapsed from natural causes., and he
was convinced that it had not -coutd
not have—not by any stretch of the
imagination. There had been heavy
rainfall in Logan County during the
week of February 26. and eunsidera-
ble flooding. But it was nothing un-
common for February, Wcedfall said,
and he had the statistics to prove it.
When reporters called hint they were
impressed with his conviction. PiUs-
ton officials had catted. too, looking
for ways to document their private
Theory of divine intervention. Weed-
fall wasn’t much help.
Nor were the technical specialists
of the Department of the Inlerior who
,rived from Washington end, In the
aftermath of the disaster. poked and.
probcd among the ruins in search of
clues. The U. S. Geological Survey
sent a crew, as did the Bureau of
Mines: the Bureau of Reclamation
summoned a former chief of its Earth
Dams Section f orn r ’tirei ,ent. The
investigatora examined the remains of
the dam in microscopic detail. inter-
viewcd Pittston workers and company
officials (who would not talk to rc-
portcrst. and pieced together a con-
vincing iccount of what had happened
and why. lone of the investigators
showed any doubt that the dams had
beer. badly engineered. Ered Walker.
the retired Bureau of Reclamation
expert. went further. refusing to use
the word “dam” to describe the struc-
ture. “Locally these barriers are
called darns, but to me this is unac-
ceptable nomenclature.” he wrote.
“These structures were created by
persons completely unfamiliar with
dam design, construction, and ma-
terials. and by construction methods
thu are completely unacceptable to
engineers specializing in darn design.”
West Vitgini law. Walker noted,
“requires permits, approval of plans.
and inspection during construction for
impoundments more than 10 feet
deep. I was unable to find that such
requirements had ever been complied
with.” Suggesting that siinaL u puieri-
lially disastrous situations could be
found elsewhere in the coatrields.
Walker commented scathin&y that
“lurtunaich , ,,,. ,..,
built in
sheds jbiwi 11. ... -.
ii an consid—
th.od ttaiard is
Pittston’s
fluosh hazard
Is) hate bepir
24-exactly 4i
alleJ darn cot
.intl Steve Das
the situation.
cut of Thust
S
in its Buffalo .ti. —
ti ls was supe
The water wa
e l t’l Ille Ihie
inspector had
previous day
the water seen
below the top
or six fee’. A. ’
of Mines repc
“agreed that 4 -
nsmg water p
lapse or !)oo , .L._
report makes
concerned oi :
water overfl v
to have been
Sihilil) that ths
way. esen the
ibly in places
01 it had give
year earlier d
ary. 1971. ( l _
struction then.
hacked up
little damage.) ,
stick into the
dam. with the
foot below th ,
raining: Dasovi
keep an eye on
Kent as ha
later to check I
water was tip z
ajin was still
in an imposir
belou rh .’ d
checking the
hours. He fou
about an inch
on February 2i
with the aid
195—8 ’
-------
wi-could
tdi of the
c i i heavy
hiring the
.ons&dera
)ihlng un.
dMl said,
prove it.
they were
ion. Nt is-
. looking
‘ii private
on. Weed-
‘ peciaIitU
Icrior who
id, In the
-oked and.
search of
d Survey
of
clamation
fits Earth
..eitt. The
maim of
‘.iil. inter..
company
ilk to rc
:r a con-
uappened
estigaton
dams had
.1 Walker,
ilamation
n; to use
the struc-
ness are
• is smac-
•e wrote.
cated by
liar with
and ma-
methods
ptsbk to
I design.”
c i noted.
of p t aia.
eel ion for
tO (cci
that such
complied
ar p0km-
could bc
oaUiclds.
IgJy that
“Iurtunulcty mu%t of thcsc harrlâs arc
built in valleys that hate , ,mall water-
‘.hcth ab.wc thene. as appart?ndy bide
if amy comickratiun is given to thu
fluod harard involved.”
Ptilsiou’s cussideralion of the
flood hazard eel Buffalo Creek secim
to have beprn at 4 p.m. on Febnsaiy
24-exactly 40 hours before the so.
u*lled dam collapsed--when Jack Kent
and Steve Dasovich drove up to survey
the situation. Kent was superintend-
ent of Pittston’s stripping operatioin
in its Buffalo Mining division; Daso
vich was supermtendent of the tipple.
The water was rising behind the new-
e u of the three damu. A I c tkral mint
Inspector had driven past on the
previous day and recalled later that
the water seemed to be about 15 feet
below the top; now it was within live
or six fee’. According to the Darea’t
of Mires report. Kent and Dssovich
“agreed that neither the dam nor tie
rising water presen ’ed danpsr of col-
lapse or flooding at that ume?’ inc
report m4kcs clear that tht.y wire
concerned wely with the possibility of
waler ovvtfl”wln, the dam. they seem
to have born untroubled by the ros-
sibdit) that the dam might simply gne
way. even though it was settling vis-
ibly in places—and even though part
of it h d ven way almost esacily a
year earlier during the rains of Febru-
ar). 1971. (It had been under con-
struction then. with not mu h waler
backed up behind I I , and there was
little damage.) Kent stuck a measuring
stick into the sludgy surface of the
dam. with the top of the stick about a
foot below the top of the dam. It was
raining: Dasotich and Kent decided to
keep an eye on things.
Kent ujs back at the dam 4 hours
later to check his measuring stick. The
water was up about a foot and a half.
Rain as still falling. Kent. who lives
in an imposing home a few miles
below the dam . decided to start
checking the water level every two
hours. 1k found that it was nsung
boui an inch an hour. At 3:30 a.ue.
on Febsuary 26. peering at the slick
with the aid of a flashlight. Kent saw
to his alarm that the water uas rising
failer two inches an hour maybe
more. An hour later thee ,..el was up
three inchcs more and the nwasunng
stick wa’ almost covered. Kent tele-
phoned Dasovich and asked him to
come take a look. By the lime Daso-
vich armed the click had disappeared
entirely and the water was only about
a foot below thc top of the dam.
According to the Bureau of Mines
investigators. Dasovich decided to cut
a ditch across the dam: he had some
drainage pipe on hand and intended to
use it to relieve the pressure. He called
some of Jack Kent’s strip-mine bull-
doztr opcr tun at home and h Id
them to go to the stripping operation
-some three or four miles away-and
bring their machines to the dam.
Kent, meanwhile, made some calls,
too: “he telephoned several families in
the Lorado and Sounders area after iis
4:30 am. e,eeemjnation.” Boreau ira-
vestigatoss reported. “and advised
them of the ‘sheg vater and the
r.ossibil :y of ti;e dam c erfhtwun .”
Three hours befort the dane hrckc, in
oilier words. the disaster had been
foreseen by someone in a position to
do something about it. A telephone
call to the state police—who could
have traseled the entire length of
Buffalo Creek by 7 a.m.. ortkrin a
general evacuation—might have caved
more than a hundred lives. But the
call was never made, And the drainage
ditch was never dug. because the dam
had given way before the bulldozers
arrived.
Valking in Soup
You can find Jack Kent at home—
his house is on high Vound and
wrvie d the flood untouched—tut he
doesn ’t like to talk to reporters. His
eyes t il eser thing: there is no need
(or word . Dacosich scem to have
disappeared entirely—he was in a near-
by hospital alter the flood, being
treated for shock. and nurses aiJ later
that be wJs hysterical, blaming hija-
sell for the trap. ’dy. Still later he was
reported to have been admitted to a
I.
I
I
-------
prlV3tc pcytliurnc clink tdl later.
released. The fcikral investigators
have not c i talked to him and sonic
of them. knowing now what they do
about the darn. see no need. “He
knows what was tip there.” one of
them said. “He’ll always know what
was up there.”
Other men knew, too. In the com-
munity of Saunders there was general
concern about the safety of the dam.
and on the niht of February 5. most
of the families who Ii ed nearby de-
cided. on their own, to takc refuge in
a cchooihou c five mnile down the
creek at Lorado. The decision saved
th’ir hves: the schoolhouse survived
thc flood. but when the families re-
turned to Caunders to look for their
homes, there was nothing to be found.
No homes. not even the foundations;
everything wjs gone. everything ex-
cept an appalling sea of slowly set-
ding. black. foul-smelling sludge.
Off and on during the night, in the
last few hours before the darn broke,
miners went up to have a look at
it—there sscr rumors spreading that it
was coin; to go. but no one really
seemed to know. Dacovich reportedly
was telling people that things were
under control. Aboit ti:30 a.m.,
according to the federal reports, a
miner saw ominous signs of what was
coming. “The dam was moving like a
bridge mosec under heisv traffic,” he
remembered later. “W ter was coming
through tli dam. not litlidi. hut it
was causing 1 1w lower taLe to flu up
fact.” By 7:,iU. a_cording t’i another
e ewitnCcc .count. “the tup of the
dam was &n*ng hj,,k and forth.
the darn sjs settling tltutn and shov-
ing fnrwjmd. ” Tr) ing to walk any-
where in lime vicinity of the damn w s
“like w.ilktng in soup ii had gotten
real, rejl mutes . buddy. all the way
down. I gtm in the car and got the hell
out of there.”
The lop of the daiti was lower on
one’ side thjn ott the other. apparently
from foundation settling, and now the
top waS iuimipii sijil fuillier. with a
momentum that could not have been
stopped by ian army of buildozcrs.
Ons’ ol’ the several kikmjl reports
th ontcs that tIme jtei level ruse
quickl during the night. nut just
because rain was fallitig. l ’,it because
the dam had been collapsing slowly
into the lake fur several liotus. But
even while the rain comitiiiuetj. the
tipple went on pumping its OO gal-
lons a minute into the sludgy lake
behind the dam.
30-foot Flood
Whatever happened in the night. it
was morning now, and there was
enough light to see what was happen-
ing. Apparently no one saw the actual
moment when the dam finally gave
way. It seems to have happened very
fast, the dam settling until water was
running across the top, the water
cutting a cleft into the dam. more
water hurrying through. and then
complete and total coilap, .i ,, and mil-
lions of gallons of water and hundreds
of thousands of tons of sludge stream-
ing across the top of the slag pile at
the beginning of catastrophe,
The water cascaded into the burn.
ing section of the slag heap and
erupted in a volcanic explosion. Men
were coming off shift at the tipple and
saw what was happening they saw a
mushroom cloud burst into the air
from the c’splosion. saw mud and rock
thrown t00 feet into the sky, saw the
winthhivld . cit their pick-up trucks
covered with steaming mud. They
raced back up the road and tried to
use the telephonc at the tipple to send
out a warning but the line was al-
ready dcad. The tipple was safe—it
was upstream, up another fork 01’ the
creek, out of the path of the destnzc-
tion- ’but the men weie cut off from
the main stream of Buffalo Creek and
*hcrc was no way they could help
anyone. They could only watch as the
water and sludge crested over the lop
of the exploding g b pik and burst
into the valley. “boiling up like dry
flour when you pour water on it.”
The flood traveled at first at a
speed of at least 30 miles an hour—in
a solid wail 20 or 30 feet high. Pcopk
who sw ii coming as
th Bullaki Creek r ’
time to throw their
turn around wherever
and head hack down
on their horns, flashi
trying to warn other i
i heard the explosions I
know what was happe
very little time to d
takes a few seconds
wits when you see a,,
bearing down on you,
you live in a valley
only a few exits—hoW’
right angles to the it
most of the people
like being in the barr
seeing the bullet con
nowhere to go.
That so many pco
something of a miracfJ
people livcd in the pa ’
Probably a thousand
in it. battered, left Sb
times badly hurt, but.
wreckage of 16 co
bodies of 118. peo
found. There are oth
the final toll may be c i
The Only Life They K
What happens aft
such magnitude? The
of course, and inquirie’
in %Vest Virginia. But,
affairs, the official re
have a common thi
Farmingion mine dii”
• miners. it was an lntç
assistant secrctasy wh
- “We don’t know wi
• happen, but they do.’
mine explosion that
Kentucky. it was a
director of the Burea
said: “We can almost
these every year.” Wi;,
bodies was til! conti
Counts’, West Virg,i
Arch Moøre w s alrea*
• Pittston Company: t’
dam had served a ‘i i,
. .‘,, -S •‘ ‘,•
-------
ho saw II cuming as the> headcd up
he Buflalo Crveli road barely had
Ims to throw their cars into reverse.
uris around wherever there wai room.
isd head back downstream. leaning
in thSlt hoistS. flashing their lights,
tying to warn other people who had
teari the explosions but still did not
now what was happening. There was
eiy little tinie to do anything. It
takes a few seconds to collect your
wits when you see a wall of water
bearing down on you, especially when
you live in * valley where there are
only a few ejuts-hoflows tunning at
right angles to the main valley. For
most of the people who died, It was
like being in the barrel of a gun and
seemg the bullet coining. There was
nowhere to go.
That so many people did escape is
something of a miracle. Nearly 5.000
people lived in the path of the flood.
Probably a thousand were caught up
in It, battered, left shaken and some-
times badly hurt, but alive. From the
wreckage of 16 communities, the
bodies of I 10 people have been
found. There are others still missing:
the Ilavi toll may be close to ISO.
Tb. Only Life They Knew
What happens after a disaster of
mc l i mageitude? There are inquines.
of comae. and inquiries are under way
In West Virginia. But in Appalachian
affairs, the official response tends to
have a common theme. After the
Fa,mlngton mine disaster killed 78
miners, it was an Intcnor Department
assistant secretary who said brightly:
“We don’t know why these thin
happen, but they do.” After the 1970
mine explosion that killed 38 men in
Kentucky. it was a newt) installed
director of the Bureau of Mines who
said: “We can almost expect one of
these every year.” While the search for
bodies was still continuing in Logan
County. West. Virgmus Governor
Arch Moore was already defending the
Pittston Company: the sludge-built
m had served a ‘1ogi aI and coo-
siniclive” use by ftltcflng mine wastv 5
that would otherwise have gone unfil-
tered into Buffalo Crack. ft didn’:
seem to matter much how the thing
was built. The state lepsiature chose
not to investigate, instead, leaving to
the governor the selection of an off >-
clal commission which would be told
to report back by the end of summer.
it’s easy to say that the dam
shouldn’t have been there,” Moore
said at one point. ‘ But it had been
there for 25 years.” lie was technical-
ly wrong, of course, but the inference
seemed to be that if a hazard simply
exists long enough. it has a right to be
left alone. And by the same token, the
Governor made it painfully clear that
he would ask the same treatment for
the problems of West Virpnia. The
real tragedy, he said, a tragedy gi eater
even than what had befallen the
people of Buffalo Creek, was the
unflattering coverage of West Virginia
in the national press.
In fact there had been precious
little of that. The flood had been on
page one for two or three days, but it
was eclipsed by the President’s tour
through China (from Shanghai. where
be learned of the flood. Nixon sent an
e*preulon of regret, con ludiitg from
a distance of many thousands of miles
that it was a terrible “natural disaster”
and promising speedy federal aid). and
within a week it would be forgotten,
dismissed as one of those things—
Time. for example. observed that the
people of Buffalo Creek would i ve
been well-advised to live elsewhere,
but that they had stayed on in the
shadow of the smouldenng gob pile
presumaNy hccausc “that was the
only life they knew.”
Passing the Buck to God
The Interior Dcpjrtmcnt. mean-
while. explained through .44si 5 1.mt
Secretaty liollis Dole Iliji there w *s.
in its opinion, no federal rcsponsihil-
ny in the matter. de pitc the fa a that
regulations within the 1 ’h ’) Federal
Coal Mine Health and S at’ety ct
specifically cover the construction and
‘is
is.
$4
IW
4 y
Ut
i i
il-
it
$
I ’
II
C
195 —11
-------
U C o oh piles and retamln lmn.
uo indications tliiat the
CCII I!WI)* i’iiltt inose to a ’
liOI .4 ’.1iil t PittstOfl. IItIlC 5 it U.J*
prodd d by an outrj cd Uur ’. u.i
Capitol 11111 lht’rc s as no otitriged
Congi.ss to he inupist.
‘ nuht l ’ c rutiflI br doubt. in
any c iii. about the ki’id ol action
that lnt nor v oulqj take esen it it
I. r e(t to do soincthinr. The
Department is r netant to think of
itself as a r UljtflF) agen y. or as a
federal cop. and an iig all of the
subo linatc agcfl ies itItt Intenor.
the LLreau ut Mines is a standout
examp e o one that has refused to
grasp the idea of representing the
public interest, The problem might
not be serious ii a system of counter-
vailing puv.er were in operation if.
for example, the people of Buffalo
Creek could have counted on the
Unitcd Mine urkcrs to represent
them against the overv,bclndng re-
sour s .tnd indifferen .e of the Pitts-
ton Company. There h,,d been scat-
tered efforts along Bufftto Creek to
protcst against the slag heaps and the
sludg. d i,n -petitiu s had been circu-
lated, attention had been demanded.
But the effort never went anywhere.
and it never went anywhere partly
bc:ausc no powerful organization-
like the union—chose to push it. The
union hasn’t pushed much of anything
in some time, except perhaps the
frintc b ,mcfits available to its rjnt:ing
officers. The result is that on one side
of the equation there Is a powerful
industry decply dedicated to its own
interests; on the other side thcre Is,
most of the time, nothing at all. And
in the mid tlc. where there should be
an even-handed .avernmcnt agency,
there is instead the Bureau of Mines,
an organiiation so encrusted with age
and bureaucracy that it will not even
support its own inspectors when they
try to do their jobs.
They had, for example, been trying
to do their jobs at Pittston’s mines.
trying to cut down the number of
men killed in needless accidents. Over
the past year they had slapped thou-
sands ot bIO$atII)fl flffli % on the
Coltipan). The idea is that th ns’tiee,.
wilt cost money: get lined often
enough and hard enouplt. the hlk ’ory
sot ” .. and you will bt ifl safety-
COfl,.,nflIS iii the cstrenw. It hasn’t
worked that way. Thanks to a highly
esnnplex jcsc nicnt ss stelil set up in
% j limgtun b) a loriner lobbyist who
i noss in charge of the Bureau’s
Iunes-eolkctioui operation. Pittston has
been able to deter. scemui tly indefin-
it ly. any payment for its sins. SpeciE-
i ally, over the past year inspectors
had fined Pittston a total of
51.303315 for safety violations. As
of April I, the company had appealed
every one of the notices it had re-
ceived, and had paid a grand total of
$275 to the government.
Meanwhile, on Buffalo Creek, the
invesligations continue, the reports
arc compiled, the survivors try to plan’
a future; the mines, only briefly di i-
nipted by the raging flood. are back at
work, and the long trains roll. One
month after the disaster. Pittston set
up an offi c to process claims—with-
out. however, accepting liability. The
company’s offieial view is still that
God did it• and if, by any chance,
God should pass the buck hack down,
“we believe that the investigations of
the tragedy have not prugreiiied to the
point where it is possible to assess
responsibility.” It’s po cihl that such
a point will never be reached. Who
was responsible, for example, for de-
ciding to spend $90000 to buy
Nicholas Camicia ’s house, but not to
spend the $50000 that it might have
cost—according to one of the Iedcral
reports—to build a safe dam at the
head of Buffalo Creek’ There us
sticky questions like that rising in the
aftermath of the disaster. questions
that will be hard to answer. “There ii
never peace in West Virginia because
there is never justice,” said Mother
Jones, the fiery hell-raiser of West
Virginia’s early labor wars. On Buffalo
Creek these days there is a strange
kind of quiet, a peacefulness of sorts,
but it is not the kind that comes with
— 0
.3. I2’
-------
•;
4?c r l au1,
‘4
-------
\. /‘orE
•;u .rcr.t, ir it
. fror- e u ofu1,
proai% •;; i;. •
t t : ;.c .on
m c t ta IG i ould eot —
duct 3 3t the
hir :;cf..1.f. tudont
In or io: .oe what
their i’ r ,*. uore on
the ret
Tho hopotull .’
wee unh d nfld roi .’.
latic, .: I 1Iiwe
the t Jo : ...(j I
pore it ‘ct rna nti at
food ;xt ) . ctton cf t. e
1 i n the
o o&.
Taoa tra t e q .cte-
you t1 .r1:
e pro or c i r3rmner;’
: ho t1. t* }U .1t ta
; !1otL);W .:‘ 2’ •:ou—rc c—
i! t 0 you
•: 1afl r fl1O1’ to
JU3tiO. if t.so ‘o •
f ir ori .t bu5lt in
yuur tC:1; 3) Iould
io p ’o : ‘ nrioth r
duntrj • . Teflon ?
j ) If t’’utd y rc’
joct or : :or a1t.o i
tvo wi •‘ •vtlt in
port, w jou wnnt
tho rof..;n y? !) T o cu
intend • live nod wc Ht
ft : t:c ’t St t cro
ian’t r cit i r,1
6) Jou1 .tu
UuT (:fl I( P ii’ the i
ftnor t i built in
uotpart? 7) (f jou
bud tjo opportuntt/
wo.21,d ou uork toz’
Pittaton if t io rofin—
ui : :: Il ?
Contin,’)( pli;o 2
11. H. .
I i)i JCiJfli1
The Mstional :or or
Soaint’j Suduotion :tl1
bo hold T 1ada7 , -
cer or 16, the Oot —
vit, peptod in the
at a achool-wtdo c c —
sor b1:. 1tr,ib1c
Junio e arid ontot’e
it: an .icadortt
£rado point of t 5 or
hithsr and who rout.
tie roquirenento ior
leadership. eøpvlce
end oLax aotor will be
inducted. Interacted
r ronte nr.d the cn-
eral publto sn in-
vtted to attend.
CHRISTMAS
CONCERT
On t oe ,tb r 2 it
7 OO the i.cuitpoi t
Munic Departr e t will
porfoprt ite gnual
Cnrictrrns concert in
t :o ftUditOpiU1fl.i Ttto
boCtnnorC’, ro raor
arid hiCh school honde
will be p.r orrttn ..
A4r teeIon Sc free.
Tie hoad Ut h ar.d
Ia o pcCttnC to re-
esivo it.s now ur2i-
tome hotorø the con—
eort.. U they do riot
arrive botoro it the
band uttl net. bo prc—
fornin on the ditto.
A fcw band onion—
dnro era loft ttnd
they will be aold at
the concept. AAaoa
w 11 be “t ftlr4
oft ror the I O tend.
The co rtdy 9 u.r
RoU. er, T uz ”, r.c
Std:god b the 1 • . ., .
two :ce).K ceo. Th
i’ls.y t tae atte t d y
o f i s t.ud tzuc t)r.ce
s1thou h ir 1
1e thin doni: d.
p i x’a cpiick—
1 with n. ch s:.ap—
ati er.d. act .c rt. Ihe
to cobbe o, uirit
Cal h tr :*n ! :
tcverMon, por?. nyt?c
the twø t.icb1 r. awa—
teu .;obbura v r
•Z.foctisel .
Ttc hi b1iL .ts os:
tho play iere r led—
dar cer e ; ho .’ t e
cart 1io to d i e ;o
th fl .oo to Lop fio
bair . . c1o ’t9r? PUtS a
pie 5n t o fr.i of
ick ’ Rz cc! 3.l (who
1J00 1B Ii t& •/)Ct i
discipliciiinu i • ! 1—
da t)
The eti—
j cd tl tioI:
the r wit di t
eecu 1:0 n tic the r i—
nor e t .koa orde b ’
the coot.
This firct play O
the S. . . t):is :tca
ioe a verj auccesarul
pc’luct ’. i. Th1.r ) it
er.or ta riuch E.nthy—
sinem. Tbe . b. .
should be quite ac-
tive in tb prin .
(J [ ’Wcz
‘ I c .
ii’
, g - t çr3(/
3S -
PLAY E\ EW
-------
cU 1 ENi sTA? F
Co_!.dl ‘..c .Zt °‘‘;‘!
Sr. & It)t?
Advi oc
toi f:
& i . •
i i. Loh .i
Enron A u’ .r5cn
Josx no AYtP t
I r.nie
Suean !)n is
Audroj N) f
PIT 15 TON
POLL
Proci p ., 1
&Oc vzt; .,rt ro —
dont.e L.J ..o coaplt;tc
the rc c’. tL.o pol’.
o thn s badi a
nofl—I’c’G S t4 o. 1; e.
3.
t e u. i.u1-flivo r —
oulto .ore a fo11o zz:
1) ;7 on, J4
ta 2) ,o, ?&; no,
t . ;.) :.o j,e, i..o
f , ) .. it.. 14.) gus,
52 flOa 2( iii. 5) 21
ruo, ! ‘ ro, 22 in.
6) ,5
2O ii. 7) L2.
LU;. no. 17.: in.
ort
Ye a Zn.
1) !;3 i ,: 1
a) i 2 )O.
Ii. ) ri;. so:.’ 3o.
5) ;‘O, 1’, 35;
6) 22; i,. .: JL
7) 3! 2?’
Plcit.snnt t’i nt
.: t n.
:L) 32 . (.3.:
2) f; .:, il;
3) : i; . 6.
I ) 16; :9
) 16. LL O,
6) ,. O.
7) 3 . 3.; o•:
Ut tcr PJacce
Yoe Jo in.
2) 68; 32 0.
2) 16; 76: C:.
3) 3L;, ; 6
1 ) ni,: 1 9; 10
5) 2 GL ?
h) ( 3:: (t’
7) 3
et oj ‘ore,th
K t’ j Vronch
robor Gnrdn r
Carroll flowerd
Kim Lohi h
Ti. Gary toute
Kathy :io.rtin
Peter 1oDonold
ondj t orrinon
Deceriham’ lot W)! OJ
e7c tln( dn for Sheod
:U6b. d?o tn .rt ilth,
tho ci oorloedero h md to
:csu ’ thoiz untfor mt to
& chool (ulttch ,on ob—
jocl od to oro by t
c ororc than th play..
ore). ?ho pep rally
duriu actLvtt pertid
srbored ar interoet—
tnj colleotSon of
octol—eplritad ‘.0 —
vi t! e.. T. ±s tnal *ded
kttc, c! . ore, c ntoate,
innmta tr. - thu biud,
cud Pito iz:troduct&on at
tt . ‘16—’?? pL yur
acu1 enoorload3ro. The
• t iree oo’mt est .mud iut i
o pertictoamtion.. ‘1US
Sopt1a 1oroc uomm tL cmot o-
nai in oo’ tcct ; t.n e —
ntO S tOOk fir t. for
thotr tI L1rq: O tl o
5oh o1 rotr, coc t -“
po tor co. tc:t wi .“,rz
as to1low ‘ii•ct. ,
Vtc i ?er1o ; cecc .l
.niero Sol ood; t rd,
Karen pirtnoy. !tI
worth it to ci ick oraund
o m tmo ,jn wal1 tar
trtctr criatl7tt7.
Alco ü . t ue 1-0117,
t ..ioh looted oil aCtor—
noon, Ir. Lincoln
or. ozotttn( opooch ac—
conpAniod P7 poppy nu—
ate which th. tpac r
tonn Jo od u ound the
• . jr t . (w.mch to e nry—
O 3 O b,S ,utt*aeflt).
Suo n 1 .ewtman
tovo ott1o
Sasi&n Fettic
.v tn Ptmy
Tisekyr Pobinoo.
Tim !e C. ttorth
i OGor nc
:4r. !luns.l1 .a ep.sem
JRA alac trmpr u1va,
*nd ehoul rtun on—
thuet ur. ror te up— /
oa tin e t on .
ttio ptm i.L ipc. on end f’
O CttOfl(lIt. W3 .t. VO ’ .1.
oncou3.,L 1 l .I . .1 i
t t t ? O t’ e torch
itte pa do ct .t’tod
frau c’ . . v, r. . :1.1] •.
rind p ’ov ’.ded •;otand
town, ‘ft thu nrch—
ore a trm . L the \ -
U*7. ?hn naSt, ;ertj
( ar.t3 I .’ hc .rodo
wore t .r. eo. . .. dorn
ond tcl .,t er. o1’ch
ca’i’ ; no .: .o rl e
was eru o iot”¼ to
out tnthr. •rao’1n
cold! ‘, I
Tho u’rmt) •i the
bonfir , ‘uae a 4 nt
W.n t uj rc1V2 ..od the
battorj field. t 11 ,(
i: ethorud uncZ
orroeped Wt E t ‘ttper . ,
neonc i. net 1 1.uhoe’ ;! ‘
neocot) uca bt: tod. ‘•“
After o)ie,rin orated.
to e t,ull Giult bon J
tho tnna end ceeer—
leodrmro XI it C17
parted for ti
Jrii
PEP RALLY ESU1TS
-------
L T . 04 A!! LDITOR
At the C.P.A. l.caring
the ? rtiaM
herald r ,rted that an
dit r f:a he i -li
3 hol st teC that ho
epresente i t e school
bdy in saying that the
atho ,1 was opposed to
10 i’efirn’y. hnt
?*Ofl yes sr lf and
vould like to apol—
oeize to an7thing I
night ha said which
13$ nntrts. I belivc
that the Ik’r ld tn.
fairly tti’ne(’ a . istEke
of : na into the 3or
• pc’iAt, of :iy sp : ch I
t: e to sv td say—
irg so,cthirig 3. te that
bi t I r arsce6 o iv
thut i p es on
I ap3lt i2M end h e
t et the ol) £ p s
tb0 !!.Pi h5 Ur bi aô
a d realiStil !e I :c ici
li c to .acl this i33
n on ro arc- tist i.
01 my pa !:.
I W’3U1i ii: to S ’
one r.o e thirty how vor:
I hc D1 : r.: c: cusos
f.(on pe l t to i: ;:
t1 ey dLd aot s eak ut
I third: ti t anyoz ’
vas o et ‘tec. ot i. have
t o’ en if they wanted
to.
It t’ ji h to be
ha!ard yo carx : ot he
a: ra)d tc ts : !t3 in
!1: C3C y* r ; a
al t’ z t t i
pf r. b to •ict s” .:i1c—
i g at alt. t’ n! ; t
.‘:t s• oia ta.:c o van—
ti ó ot sri:’ catt :h
ht t’ ycri s
sthply Ltia iu e y ,t l’-t
Iiii qet a tay it.
I h. ord that sore
Y o]e i”it n anf y
t .cr to the 1 i:rald
41P)Ut y
I i,n. I .a].a1.dr tLLs
i.ctt n a 4 wotild like to
e1 thu Cz’rer t ct nail.
L TT TO T1.E cJ ITM
I an a student of
s.;.i;.&. in good standing.
I have an oh3eetton to
raise to yot’r att nti,n
co cer in ur roe nt
poll. I f cl the ording
of the poll’s questions
could lead the person
fil:ing ou the eoll to
inpli other han whet h
actually t.lt. I feel
you did an oxtrenely
poor Job on this poll. ard
past polls.
ZD. OTE,
All, polls that tho
Current conducts are
written by the edit x’g
and an atter: t is zedo to
‘reap the roll as ample,
door, and uribiasec a.
possible. e v,u3.d liloa
the p son who wrote th5.L
let cr to neke rpccific
ar utinents not
ttons. :e tot3.d l t to
thprov our rolls and ‘4t’
your help to will bj ably
to. ThAflk you tar you ’
letter,
To the Editor:
I c re r rd to th. !i’t-
st otteroit axic s ct
Dec. , 197’ . .c Ic l
thnt it was ui tair for :
SI’ Dd I h Sehcol ebu’s”
to r rescnt t i’ ::
Cehool without cit e-
lected to do so. ..v
f cl thece optz4on:
at ctly o . :
tec l thic student I ’t r.o
ri.p t to o t ic hi&
stutca st £houl ht. rc—
trected fro i tho ..1.a.
i ccords.
Few Con
. tudorita
(ilease see statement
in previous oolui’in.- 4 1 .)
TIHi CWtkErie O S
LEV’ERS 10 ¶ iW i 1iITQ ,
I’LgASB ur ‘fUEl IN ?LI
BO t IN ?.I. LAIN }WUI .
•.% 7
)
To the Editor.
The Sopho.ore
lasu itu ’t been do—
1 .iv’ too ouch, noted
_‘ t: e
f t te Jadi.’ I& r4t ns’
;Janco. Is it because
of y’or lende ’ahtp?
No. The r osan the
C1USL1 h s? .’ ‘otten
off the ound is du
to the lu:k or intre:
and per i t’ ation in
class a frjr . the
att•ndap*c at class
acetinge as been
nood o rnl lo’;. If
this keep: • , we
von’t Lit a)LjthirL
done this ‘ ir.
The cp:.a who art
not tnte e : and
‘efu’35 t3 co.:’prate
. re ususi ‘ e same
zvs wu :.o :. l the
omp,u itii . ‘out
he .‘ * t unds.
A tho nuent
:att, ‘1h or.
scnior , ‘il1 not
tJvor have O!kugh
i ono r to ‘ ‘ a year-
ook . V:o...1.,’t that
a rea. stjnct1c :
The .irst to
r,r !untc r Si.JIS
thrtt )i ’t ‘vs a
;estr hook I
So ces. (... lass
.,i’7r c s
•.,et f O-
nr on e e . oj? . ts
;hat wiL r;. :e $W)c
‘one.” n 1 bia’nt
v.1r; •... ‘. on the
)rec;’1on ..
‘i. (*..CiRj
o t . e V ti
W’ ) ‘a. i e the
rost cC ’ ti o .ame roont
:.n the cc. oc’l to a
Chrict ic,s dt !attons
oontoat.
fc:(.% 7
(hi,. r;cr.zt J -e , oph—
onoro! ar. I:vin Onc.
L t-4
-------
j 3 DEC 1
2
4( 7 ff&
2 44f
,/‘ /,x
I
/
I
5 IfrC
-------
cJ
z Z7± -6 7’
i -TL ‘
LQ
7 ø
-
1 7 ) S_
/ t4 r -
• A - ‘ v- 4 — ‘o f A - e
6LG m€ 9
• A
4 r
S
gr. ‘&í
,e rt ( ,_.
197—2
-------
AL k
.i,-•1
e ee 1_
- /—F 4 2 :A#L*
44’ 9
fr ?
/
-------
J - 1
6t4 7
‘ - p v ? z &
197—4
-------
13 DEC Dnlla
Crow Neck
Treacott, Ye. 04652
tT.5. nvtron ental Protection agency -
ee1on I; Bo cort, as achusetts, 02203 4bti
i tlemen:
y name h Dallo . ?odri.n . I own a 1le of shore line on
tr irht ny —- a part or th Cobecoo c syste . I also manape the
f1el o’ t ’ 3 oin1nr farrns ‘t hioh provide hay !or y cattle and
cheep. \‘e ar. a sxtll r i1y fai ’ that 18 flOW self—sustaining after
five yet r i oF 1nten 1v effort. I vi b t’ corn ent on the Draft
!nviro t 1 ITpact t,.teient (‘D!IS) re 022A20 ( P!) and
25T -Y7 (Amy Oor oF ri tneera).
th k this rot, n]. p ‘fere it not for the fact
2ttt to h ‘sa y de onetrateO th tr eu1:1ron ,eatal irree o sibilit7
in the tnee ertd at fTh lo Cre&; and v rtoua overn, ent a enc1es
have br u’ht u dt a ters on the crier o he Teton Darn fiasco,
one w u1 te i4 to dia tss a ropoe l for art ott refinery at Ea.stport
as frivolous. ‘Ynfortunately, the deadly results of unchecked greed
and beaurocratto empire buildlnp has led us to confront this
irrationality as a possible real event.
I am shoèked at the stance and aualttyof the DEIS Volune I
verges on being a misleading, unethical summary of Volumes II and III.
‘rolu e II, which I suspect, is mostly Pittston’s effort, is so devoid
of ec-holarahip and orderly reaearch that it reminds one of a term
paper sub attted to a profepeor who is known to weigh his students’
efforta. vn1 m. TI! struck me a. an honest effort on thc part of the
EPA staff to deal with some of the critical issues involved. The
aecou tia work is a classics], example of orderly research and
presentation. One could collate text and tables easily and under-
standably. The oi.ititazldtng weakness of the whole DEIS is the lack
of fundamental data germane to EM pprt and the process of refining
-------
-2—
Pittston proposes. The work of Volu ie III is athost negated by
the lactc of i nitiRl condition data.
It is certainly be.yond : y ability and your patience for me to
atter pt to ov iluate, in its entirety, the D IS. I wish to say,
however, •bef r roinr to two specific areas, that it seeis a
very shnbby ertort was nade when one considers the magnitude of the
—— b ,th in ir paet nd dollars. It hardly approaches satis—
fythv t r 1 w, as outjti ed in the appendices.
I shou].d like nov to enter that labyrinth in Volut e III
dealtnc tth the emis ’ions analysis:
(1) y td not Pittrton supply Teteorologtcal data for
tport? They have been Located there for ten years.
(2) :; y s there not a clear definItive description of the
hy r —1flfl in process ? One would like to see the
)r osed chernical engir.eerin inputs, yields, and losses.
(t) hy Is there not a chemical analysts of the proposed crude
3t1 to be used? I want to know what I .e in a typical gallon
of this Persian Gulf ‘ht h sulfur crude:
a) How e uch sulfur?
b) Eow much lead, mercury-, and beryt].ium?
c) How many carcinogens?
(4) ?hat sulfates, eulfidee nd oxides are formed and what
is their fate? ftth scrubbere where do the oxides
collect rnr’d inw are they disposed?
(5) I’d like to see the Gaussian Steady State equation and
the coefficient values that were used to model the
stack emissions.
(6) I’d like to knowwhy’ numerical analysts weren’t hired to
mode]. the actual conditio 7 gt 6 astport, using the wind,
-------
rain, rog, snow, temperature, and terrain data that
actually occurs there.
The discussion in ‘Iolu:ne 111 pertaining to emissions is based
on an urban iodel r odifted to approxthate Eastport terrain usi
Portland meteorological data. The sulfur dioxide and nitrogen oxide
inputs ere, s far as I can ascertain, mere guesses (and these
Euesses vary from volurne to volui ie.) Why? ‘hy is the cornputer
Pro ra r (oodel) so insensitive to wind shear variances? A parameter
a critic l es “md in a fo plagued area seems not to affect the
,ropre” . Thy 1 1 Is it reasor.nble to hypothesize a constant 5 YP}j
wind et the base of those tec e, as was done? Why tdn’t the
P) de-’sn !‘ .ttston give thei’ solid data?
I append a stateiient from the Bangor Daily sews which says in
essence that the EPA has failed to come to grips with ambient air
ouality etanda s in the first piece. If this is, in fact, true ——
how can rational en then conclude fr’rn the above maligned cortputer
model that 2itt tCU will not worsen the air ouality in Eaatport and
environs? In fact, I suspect this su mor is the first time anyone
really D Ir with the current air ouality in astport —- a
very good insight into the integrity of this applicant.
The najor plant —toxic pollutants are sulfur dioxide (So 2 ),
fluorine (F), ozone (03), and per oxyacetyal nitrate. Concentrations
of .25 parts per million (ppm) of SO 2 end .01 ppm of O over a
period of hours will injure plants. Sulfur dioxide is a relatively
short ltvec V’ospheric pollutant because 1t is readily oxidized
to sulfur trioxide (303) and finally to sulfuric acid mist and
sulfate particles. Ozone is a photochemical oxidant. Photochemical
oxidants are the products of atmospheric reactions involving
hydrocarbons, oxides of nitrogen, and sunlight.
197—7
-------
-4-
Now, for the mouth on July, 49 violations of the Federal
prt’nary ozone standards were recorded (In Eastport), with a maximum
value recorded of .152 ppm, or almost twice the Pedezal Standard
(.O ppm)” (Pg 15 ‘?ol II).
EVERY !ICTJR Pittston plans to emit froc their stackS 2 tons o
SO 2 and 4/5 of a ton of nitr3gen oxides. (pg G-8, Vol. Ill).
‘Despite the scarcity of research findings, however, the
possibility of the interaction of $02 from the proposed Pittston
refir 4 ery with fog in the Eastport area and the possible resultant
formation of sulfuric acid nIst and other sulfates is of concern
because of the possible hu’ an health effects related to sulfates.”
(pg 330 Vol. II).
“...the high incidence of fog in the Eastport area, as well as
the occurrences of 03 violations and significant S02 emissions,
indicate a potential for the formation of acid mists and other
sulfate compounds.” (pg. 331, Vol II).
!very ten days in June, July, and August.the 2 tons of SO 2
and 4/5 tons of nitrogen oxides will go directly into a fog bank!
I would .like to know why Pittston should be licensed to
expose us to this kind of a disaster. Are we do die for
capitalism as those in 3ngland did in the sixties? Are so many of
us expendable, as sacrifices to corporate greed and irreaponsibilit-?
The State of Maine ranks fourth in the United States in
incidents of lung diseases. The soil of Zastport and the surrounding
area is now so acid from Northeast industrial air pollution it is
necessary to lime fields regularly and persistently to produce
mtnthu rase yields. I want to know if Pittston is going to be
liable for the medical problems of the people they will. poIson?
WI].]. Pittston supply me and my colleagues lime for our fields?
i.97—8
-------
Does the goverruaent and Pittston have a plan to talcecare of the
acid baths we will inevitably suffer? I want to know before the fact
what the limits of my subsidy of this oil refinery are goti to be.
Ai I to offer ‘ r childrens’ luns to this oonglo erate to waste as
they di the people at Buffalo Creek?
Can the who :c ows better tl-.an ny of us, that SO 2
concevtratione in the air hav ’ lessened appreciably over the
last cix years, r3o: Lly, ethic ].ly, and leraUy license a pollution
source of the a n1tude of the ?1tteton hl h sulfur crude oil scheme
in an area already in v o1ation of ?ederal Czone levels? I can’t
believe th s. I have this uneasy feeling that this insane plan
parallels the stratepy used in the ‘Ttetn m iar. Threaten X —— then
offer (. ‘ verybody si!hs with relief -- forgetting that any
part of . is imro al, indecent, inhurnane, and a damned ehatk.
ffavin lapsed into the r etaphysical -- I’d like to conclude this
cry in the wilderness with a few comments on the “receptivity of the
community.” I apologize to those of you that think, but in the end,
the political solutions usually are the ones that kill us.
The fact of the matter is that it is not known what the
ordinary people of astport think about the refinery. A petition
to have a vote on the refinery with more signatures than the number
of people that voted in the previous election was presented to the
Eastport city council. .. A )‘r. Leighton who Was president of the
Council and t’ o of his colleagues took the position that as
elected representatives they would make the decisions. The vote
not to hold an advisory election was 3—2iTst,o councilmen for the
advisory vote had signed the petition. Subsecuently, Leighton was
defeated for the Council it an election that saw an anti—ott man
elected. Superficially, you might guess Eaetport was against oil
Leic’hton immediately opened an of 4 c; as Pittston agent and openly,
-------
U
for a chanpe, conducted Pittston bueines .
The Governor of this State was elected on an anti-oil platform.
He subsequently changed.posttlons; and, in the opinion of some,
*riously weakened the ; ine Poard of r.vironmental Pro ection (P e)
by hi! appo nt ient .
Two stst a encies —— t}:e Department of Inland a e and
?isherlez an ne other led suits via the Stete Attorney General
to set aside the Ma .ne P conditional per !1its as unsound.
hen you ‘t.tr the iuck, you find that the “people” have tried
to speak. ‘ e voted a bottle return bill in over the dire threats
of the busIness commun Ity. ‘ ‘ll vote this oil refinery out if
given a ct ance. Thy haven’t we had a vote? Thy hasn’t Pittston
appealed to the people of ast ort to see if they (Pittston) are
welcome?
The business community is notoriously suspect when It comes
to leadIn - us to NIrvana. Growth, expansion, and progress are
anachrontsis. e must conser’ie, - “ ‘e must protect high
protein yielding areaED 4 4 1e must have an energy policy. Eopefully,
carter and h .s people will shut these oil people off. The
autornobile, c ncrete, and oil people do not carry a sane vision
of the resent or future.
. re T e to rape the rest of our environment, and our children’s
future to o r eI.r conditioners to enable us to breath our own filth?.
3.97—10
-------
4 7 i’ k
— I .
I -
• t 4 L _ -t 7 i’t
_.L. .
;;-< L
• %-
a-..
,e
( £ -Qi 6 . _;%
c
A
/1e€ - -
& (‘ X i- I
/y 7 &ô - - L1O
U.S.
‘z.
198—1.
-------
ct9
New Sharon, Maine 0 955
December 10, 1976
Environmental Protection Agency
RegIon 1 Permits Branch
JFK Federal Building
Boston, Mass.
Dear Sirs:
I had planned to write to your Agency urging that
Pittston not be granted permission to establish an oil
refinery anywhere on the Maine coast and stating the
reasons for my strong feelings on this subject. How-
ever, after reading the two letters to the editor of the
Bangor Daily iews (which were published on December 9th)
and are enclosed herewith, I feel that these persons who
live in the Lastport area, are much better qualified to
speak than I and have stated the positions of the many
Maine citizens who are opposed to the Eastport refinery,
In particular, verj well. I urge you to read these
letters and take these positions into account as you
weigh the pros and cons of this important issue.
Thank you.
SinS cerely,
.4arie .!. Kearney
! flC.
199—1
-------
Useless tro gedy
Positive alt emative
w
TaTh. Editor:
All of us here in the Northeast
enOslal region of Mains share three
Gd•glveai blessings, which the
psopis of the rest of this country
may never have had, or have
sacrificed to the greed and industrial
blindness of “Corporative Big
Business.”
We still have 1) the big sky 2)
crystal clean air 3) supportive
waters teeming with fish.
Why then are we not
reconsidering the Pauamaquoddy
natural tidal power project as a
positive alternative to the building of
the Pittston Oil refinery. The
construction and supervision of the
Dam would bring jib. to people of
the area without the accompanying
pollution. It would boost the fishing
industries rather than destroy them.
Once Pittston Company gets Its
tentacles Into the deep port at
Eestport, the Passamaquoddy
project can never be realized. There
will be no opportunity for hindsight.
Do we really want to sacrifice
this geographical heritage on the
altar of a possibility of 100 or less
temporary jobs which wlH bring with
them the gamble of oil spills.
mechanIcal failures, explosions and
fires?
If you agree that this Is too much
risk, write to your Chamber of
Commerce — or to the
Environmental Protection Agency
Region 1 Pesmits Branch, JFK
Federal BuildIng, Boston , Mass.
“NO’ to Pittston’s application.
“YES” to Pasumaquoddy Tidal
Dam.
Audrey Snyder
To The Editor:
It is unfair that “area businessmen”
and the Pittston Company L’e such a
wide forum in your newspaper.
Especially just before the hearing on
Dec. 3. There a lot more of us
“ordinary” people than you might
expect, and most of us do not think an
oil refinery iseither necessary orthink
“Pittston’s proposal is beneficial” in
ANY respect. Perhaps the Pittston
people forgot to mention a few facts to
the businessmen. For instance:
1. The peopled Eastport hav. not
been allowed to vote on the issue.
2. The refinery chimneys will spew
two tons of sulfur dioxide into the air
hourly (that Is on good days when the
scrubbers are working). Try farming.
for Instance, with a cover of those
acids on your pastures and hayfields.
3. The refinery will discharge a
minimum of 60 gallons of crudsoil into
Passamaquoddy Bay every day. This,
too, ison gooddays when nomistakel
are made.
4. The au’ In Eastport, and along the
rest of the coast, Is already in violation
of the federal standards for name
levels. Fog, the area’s nemesis, holds
these poisons down among ul
sometimes for weeks en end, and they
are poIsons. (Incidentally, the
environmental reports are based on
weather down in Portland, not in foggy
old Eastport.)
These are just a few examples, and
they may sound unimportant to people
who have never lived around oil
refineries or bad air. which permeate
every aspecto( one’s life.
It is naive and Ignorant or just plain
unethical to be in favor of an oil
refinery in Eastport I remember how
excited some people were when 15 new
families moved into the L,ubec area in
one season. Wait until 2300 people
move into the Eastport area. The
people around here won’t even
recognize their homeland, what with
the new restaurants, beer joints,
movIe theatres, sewers, housing.
roads, crime, schools, churches,
shopping centers. etc. (The Pittstons
already own the land the l1tle L.eague
plays on.) Just Imagine the thousands
of truckloads of materials the
Plttsions will need. Vhat a mess it will
be!
The arguments against it go on and
on. The argument.s for it are mostly
generated by the Pittston Company so
they can make their millions yearly.
Even Pittston has admitted that oil
and gas prices will not be affected.
They will continue to rise as the oil
supplies continue to be depleted.
We want to vote on it. If the people
want it. then they can have it. I will be
long gone, trying to find a spot on the
globe where big business and big
government still do not have a toe•
hold, and where people are clever.
independent and self .sufficlent as they
still are here.
Trescott
Marlan L Hodgms
199-2
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Vot yLs - ;
DEC
ThE U$l OF TK $ CA O
AIDI MIJNS S*IPPt.SD CNU.O*SN HP 4 aiu u
aL3 dj Z ‘ 11aa ,
I
200—1
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V I
169 Water Street .uecember 10, 1976
E stport, Meine
04631
Mr. wallace Stickney
United St tea tvironment l
k rotection Agency
J iforceaent Division
Permits Branch
John F. Kennedy Peder L Building
Boston, M eepchuaetts
02203
ft s Pittston ionp uy’ e proposed oil refinery in gsetport,
Pi p ins
Applicption number; I4 )O22424
iieer Mr. Sticicney:
I r m M rk StRnden, n iglieh teecher t Shspd MesoriRl
High School in Esetport, M ins. I a writing in order to
express my opposition to the proposed Pittston oil refin.ry.
I was born in southern Mains nd m presently in my
second yeer ‘ . .n gsatport resident nad tepoher. In the
me ntime, I hed the misfortune of growing up in New Jersey,
one of the most disgusting pl oee on the continent for it
oil refineries nd heivy induetrir’lisetion. I h ve returned
to !4sajne bec uee it is one of the few life—giving, s ne re e
left in the B st.
j. a feerful th t Meine in geneml, nd Br stport in
p rticul r, will be llured by short—sighted specul tors who
don’t give dpmn bout the Ch o they creete. I hey. lived
with th t oh os, nd I’m convinced that my perspective is
vplusbl e.
There re elot of fruatrpted people in this town who
hpven’t been heard on this oil issue. Thus frr, we heve not
open gr nted legal referendum. he B.P.A.’s public he ringe
on December 3rd were lessons in subtle distortion nd bi a.
K ul-kia h dn’t done his homework, but none of the uthoritiea
seemed to notice. Severpi opponents of oil presented intelligent
Dnd sensitive rguments, but these leo seemed to go unnoticed.
The he ’ring officit ’la cleered out in e hurry, for whetever
re eon.
201—1
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with i 11 du• reepsat, I would esk th.t yo e • th.
psopi. end the .nvix’onat rather t * aarleis b±g i.1a.e.
int.reets.
Thank you for your ptt . tio .
R..p.ctfull$ . bmttt.d,
Xark St i
201—2
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L-A )// z fr á o X&2
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14 DEC 76
S
tTl A
202—1
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3$ DEC
1.’
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pAl,
)koV 17
I,
peQ’ %, FL .
.tb
m J
40
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203—j
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RFD1, Box 63
Blue Hill, Maine 04614
December 10, 1976
ME 0022420
u. ,. nv1ronmental rotecticn Agency
Permits Branch, nforcement Division
John r’• Kennedy Federal ui1ding
Bcton, Pass. 02203
Re: Pittston R.finery Application
Gentlemen:
hy wife and I wish to express our d..p.st concern about the proposed
location of a Pittston oil refinery at .stport, lame. For th. follow-
ing reasons, we hope that a permit for- construction wifl. not be issued,
nor any plant built • These reasons may be grouped under thre. main head-
ings: 1 • can sequences of hitching the economy of the E* st port area to
a declinng resource, oil, and an irresponsible corporation, Pittston;
2. navigational factors in Hsad Hsrbor Passage and along the liaine Coast
create the risk of substantial environmental damage through oil spills;
and 3. the exclusion of more suitabl. energy alternatives which would
be of more benefit to Maine.
1. To us it is shortsighted to permit the construction of a refin—
cry, perhaps leading to development of a p.tro—chemical complex, which
will become a coll.cticn of unusable buildings when the supply of crude
oil fails, as fail it must within a few years or decades at the most.
Whót will the by then inflated population of Eaatport do when the refin-
ery closes down? Is there any guarante. required of the Pittston Campany
concerning removal of the buildings which will serve to obstruct alter-
native forms of development? It might be pertinent to comment at this
point on the environmental record of the Pittston Company involving as
it does environmentally irresponsible mining operations in Appalachia
and also to what extent we may rely on any assurances they make concerning
the prevention of oil spills.
2. The experts hired by Pittston hold that navigation is safe for
very large tankers, but experts of many kinds have been proven wrong
in recen’L years, and not all experts agree that such navigation is safe.
Havi navigated Head Harbor Passage myself,and consulted the charts
end current tables, it is quite clear to me, a layman, that unacceptable
ris attend the use of any tankers in this passage, and particularly
of very large tankers. It has been noted that tidal currents on the lain.
Coast would tend to spreec any oil spill in a westerly direction along
the coast, thus edv :rsely effecting the entire Maine fishing industry
and tourism. Also, most l ’rge tanker tonnage is under foreign.flags and
is built and powered to ste ords lower than prevailing is U.S built
and operated ships. It 1 - 3. ly that these substandard tenkefs will
204—1
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page 2 — ME 0022420
ittston a%efinery h ’plication
supply at least part of the oil to Eestport.
3. The overnor of Z. ine, James L.ongley, has just been quoted
to t e effect that lame should not be expectec- to supply energy to
other states at the c xpense of Maine’s own environment. While this
comnent was made in connecUon with Dickey Lincoln, it could equally
be made with regard to Pittston at £astport. To this we might add that
an Eastport refinery would preclude a hydro¾electric project at £‘assa—
maquoddy which would be far more suitable to Maine’s energy needs end
would cWnstitute a far more appropriate energy technology for l.aine in
being self renwing, relatively non polluting, and compatibl. with
aquaculture projects.
e know you understand the supreme importanc. of decisions suc
as this. Maine, of all states, standi perhaps the best chance to sat-
isfy its energy needs in a non polluting, self renewing way. Why not
help to let Maine show the way in this respect by turning do Pittston’s
proposal, instead of cciiden ing Maine to suffer the sam. kind of devel-
opment which has deformed the more industrial and energy intensive arsam
of the nation.
Your consideration of these points will be very much appreciated.
cj, f14 1i
Paul 3. Birdsall and
Mary W. Birdsall
cc; u. . Dept. of Defense
.al them, I-.ass.
.7.’
— __ •
- % t 33
,‘
204—2
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Rt. 1, Box 133
Eastoort, Maine OL 631
December 10, 1976
Mr. J,. hn A. S. McGlennon
Region I Administrator
Environmental Protection Agency
John F. Kennedy F 5 deral Building
Boston, Massachusetts 02203 U 4 ,
RE: ME 0022L .20 The Pittston Company I
Dear Mr. McGlennon,
In regard to the above applicant’s desire to obtain your
Agency’s approval to construct and service a refinery at Eastport
may I suggest that it would be prudent to consider the affect
upon you Agency in approving the a’rnltcati.on.
Although it can be said that an applicant’s background has
no bearing on the Agency’s decision the pressure from those
aroueed citizens whose combined deeds resulted in the formation
of your Agency in the first place could have some far-reaching
consequences for your organization.
The background of the slipshod Pittston Company is well-
known. All the Agency needs to do is to contact either the
U. S. Bureau of Reclamation, the U.S. Bureau of Mines, or the
U. S. Depart ,ent of the Interior. In the Denartment of the
Interior a Mr. William B. Davies, of the U.S. Geological Survey,
Reston, Virginia (telephone 860-61 .21) can be consulted. He
has been in court with the Pittston Company.
Your Agency ala has the problem of dealing with your
counterpart in Canada who has exoressed disapproval of the
Pittston Company. Not only has disapproval been expressed
by Environment Canada but by both the Canadian Federal and
Provincial Governments.
Finally you will need to consider that the communications
media will have a field day if your Agency approves the
Pittston “o”rnany with hea ’1ines like, “! PA approves company
with worst environmental record.”
We in Eastport perfer not to have our marine nurseries
threated nor have our lungs invaded by a refinery’s effluents.
Geologist
205— 1
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Q4 r 2
. . ( £ m-9 -’ %z
//0.
10 DEC J976
v>4 ,e i
L
206—I
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7 /c
4- f j%4 Z
207—1
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P. 0. Box 54
Lubec, Maine 04652
December 10,1976 .
Mr. John A. S. ilcGlennon
Regional Administrator
U.S. Environmental Protection Agency
Permits l3ranch, Enforcement i.ivision
Room 2109, John F. Kennedy Federal Building
boston, Massachusetts 02203
Re: The Pittston Project
ME0022420
Dear Mr. McGlennon:
At the hearing which you conducted in Eastport recently I did not
ask to speak as I thought my observations would probably only echo
those of many of the other opponents of the above project. I sin a
college graduate (Bates - a very down-to-earth small college), a
grandmother, definitely not an environmentalist as such but in-
creasingly conscious of the inter-relations of forces in the world
around us and the intricate but delicate balances therein. I sin also
extremely conscious of the need for new industry in this area. My
husband and I, after living TM away TM for some years, moved back to
Lubec in 1950 but in order for us to live here, he has had to spend
much time in other places where he could sell more life insurance
which not enough people here could afford to buy, at least not in
the amounts necessary to provide the sort of living we wanted.
Zie that as it may, I hope that the Environmental Protection Agency
will reject Pittston’s application since this is a unique region
because of its many bays and inlets, its great tidal range, its
present and future potentialities for producing many varieties of
marine related products, not only fish but marine worms, sea moss,
etc., even tidal power, if need be.
Just at the time when scientists are becoming conscious of the pos-
sibilities involved in aquaculture and when money may become avail-
able to do something about it, just when the U.S. is about to ex-
tenU its fishing rights to 200 miles and consequently wil]. be more
likely than before to aid the fishermen as does the Canadian govern-
ment, just when foreign oil is more likely than ever to be restricted
to us by OPEC and just when we are told it is about to run out any-
way in a few years, this is not the time to take a chance on destroy-
ing forever or at least for a very long time the enormous potential-
ity of this unusual area.
110w about recommending that steps be taken to advance the cause of
aquaculture (I’d personally like to see something done about raising
haddock as is done with salmon or trout), and to improve the situa-
tion of the fishermen by subsidizing docks, boats and gear, and then ,
if that hasn’t done any good in 25 or 30 years and if there is still
oil to refine, then give permission to Pittston or others to bring
in tankers if they want.
208—i
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-2—
ME0022420 12/10/76
If you are still reading, my chief purpose in writing is to call.
to your attention the enclosed copies of editorials from THE ELLS-
WORTH AMERICAN, an excellent weekly edited by J. Russell Wiggins,
former editor of the WASHINGTON POST and former ambassador to the
United Nations.
In spite of our need for more jobs, Hangin9 Refineries expresses
my feelings and that of many others, that just when there is a
chance to develop the natural characteristics of the area is a poor
time to try out something the area is definitely not suited for -
i.e. bringing VLCCS through the treacherous waters of Head Harbour
Passage.
Hopefully,
4
7et Z onaghy c 1 4”
MJD
End.
208—2
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...—,- E;” ’ •- --
,. ..•
*SI IlM ________________________
— 4 ,, W:s :. ’ ;m ,
Q.,m ,. ,a.. V *1
A.’ gui” — rn. Pm. V I
Reviewer Finds EPA May Have
Laid An Egg In Pittston EIS
Tb ’ U i Environmental Protec-
. Agency has Ian—d a ±aft
5.vL onnt*1 Impact Statement
(O . 13) on Pittston’s plum to
a Won oil refinery at East-
put Tb ’ c i’ i Is applying to
EPA for permjta to discharge
s and to lb. U.S. Corps at
E Issurs to dee . and to cc
e ict
EPA will hold a p-” ’ hserb on
— In Sbd l$im’ Is1
$rb”•& on
flk--3at1 PubI l c
will be Leo_is Oct.
$to c. 13.
‘flu lengthy statamait Is In ss
an “eucutivs
d pupss; the statement thai of
Ilpuges; 3ndat.ctmIsaI’j —l1Li
uidt was not Included to th . copy
remind.
EPA dencrihos Its raspuaib’Mty
is: ‘lb. Pittston Co. proposes Lu
lulldsnuiaury in Eestport , Maine,
with uW procem I0N berrele
per neleudor day at crude oil lot.
_ prothicts._ft has been
deuumL ,.d that th i ifln. 17 ’s coos.
k ll . and cpMndon will buy, a
“ g I Impact on the L-
alt, and EPA with assIstance
the Corps and 5*,w1 other
haul agencies has puepaisd a
Beidroemenud Impact SIa$
mites the proj.ct”
Ths annuuncwment further
delis: “The EPA RiØonat Athuin.
ha l ts. for Raglan I has tentatively
to lieu. $ permit for the
. The p d pensdt re
— compliancy with the new
aw n performance standards end
Iimltauons st forth in the
EPA guidelines for the petroleum
‘ •1
• Thes. icoftheE1SIsbrosd,
alibsagh ir.sny people Intorseted to
project may find ft contaUw
lime startling statements and
a ’ depth.
The f pfl ats M diacusiss tout
re ng Lemma
— ci the cor4ro .rilaI project
a dsecr*ption at the
L.jnunt, energy neede, ceno
otr Lactcr and . nvI ass tel
h The Introduction treces the
i oIth.bsar i ngiheWbyth .
• hoed of Environmental Protection.
“Because of the extensive adc)i-
thinal formation required for the
£IS ’ it states, “tt was agreed that
the Pittston Company would dive)-
Ip an .-“om#nt
Report (EAR) baled on an outline
approved by the EPA and FRC.
DarIng the priponlics o(the EAR,
Individual agencies wore p.rlodice )-
ly consulted. Various field werosys
and moeltoring .flcrto were aia
condiact.d by Pittston. The EAR
was rec e lvsd by EPA In April c i
1*71. FollowIng an lndopth review
by EPA and the FRC work pse .
the Pittston Co. wan rsç -i to
curtly louses and preside
a tiona1 data ub... required...
Whore opliiL ius a’ the PW Co.
ore b hitled in the LIE In davelip-
leg an hate, are on fetid.”
A good at the
aiarnsuit net “us actid” reed an
the company loud wrMlu them too.
In . va’nath the i’ and
likelihood at epilis 11. . t .st
uses Pittston’s projactkntd epWi at
Milfcu’d Ravea England. ft s ’
that the tidal rar s, the ci rnd. ,
the citsomel depth and width, and
a ipronchus, . ‘p of water
— the J and adjac
terra in o naUlndkrhetg lv isao
aipportiuig dale at this . xcs f Cr
the shape at the dumneL The £13
conctudssthetthsr.wlflb.nomou,
thno 1 0beivu l ec lspm..ge
dwthg off and on hading activities
at Eutpcrt. No otha io .coa than
Pittston’s projection are used.
According to the Pittltu .i figures
the number at ddps entering yearly
or. $7 of the lM,OliDWTslze; 0at
*015 to 70,005 DWT; 1100(10,010 to
30,010; and 100 nallar•
The statement experiences more
troubl. on the occurrence of major
spiDs and tints can happily avoid
aiggesting their likelihood, but
is no .-.isthtg data base
except the knowledge that secasles.
ally uur Lmphasts a lure. .hlp has
iafs)y trana dEastport nates...
“At the 8PP hearing. Pitt iIon ’s
upset witnesses taltifled that, in
relation t o Milford Iluvi n and other
parts, the peg . to Eutport was
less hawdoua, pirticuinri) if U
proposed, the transit Is mode it
times of low velocIty currents...”
Wits’ P ippetwd to the te iiitnnny
of all the expert witnecon, wIi .
susceptible to certain petroleum
1 • _
It cornea to the odd co&hA :
“Assuming that the loblt ra wlfl
probably imvlve If not directly
costed by the oil. the eventual
damage r,p’ ”g from a spill
be math Is.. then th. total
value .1 the resoterce Itself.”
By and large, , , ..s , the stats.
mont does adnit that cOnsiderable
damage would be dons to marine
I t t case c i a major spill
cosdhnes the evakiaties to nearby
wits’s. Nomentioaat*fi Is made s(
lbs c: _ __ -dothwlia c ia 1 car-I
ri t could cencelvably pua
$ major spin along Thai
ceast as P,s- ’ot Ray.
‘I’s_s I , _ h _ . $ dsscriliu at some
length lb. elabosal. oselgatimmi
aid ath provialom Pittston has
so _ ggut.d as making the project
but” us moth, at
— will esstorvs them nor y
oimal agreenusda the c ” ayj
ghu made to use then. Nor doss thsl
;statu.nus take any not. of lb.
— cotnpen s poor re
oil el. ,.Ii.r , the hdfalo ( usk
er hang the most widely
p.hl i d .
The sta t cornea to the can-
clinton: ‘lb. operatlost of the re
finery ii, i wta the co. ,..Jt . _ .t
a’ the ty, region and’ te
toacco_pttheris&, howi.irweull.
t an accident could affect aft a
portions a’ the fisheries Itt th, aria.
Titus, the riflaury may ie , .M a
ccrnnUtmsnt to an Is ia1 activi-
ty which could remit In 11w
Mon or even elimination ate
abis resource - fk1V , In ad tien,
i lbs ftah.,rutan were to ai ’r ” t on
Uwir life style and turn to
the potentially rems lucrativ, ser-
vice indu ..the ng’ . -’ ,
could also be .4tn d.”
Same of the rsuouou for EPA.
readiness to ronaider this for Mth
are a rsnt under lb. oL . ,..,....k
end energy sections ci the stats.
me
Ptttstost emergos wri, , ,, d In red,
white and blue for Its
Federal estlmats project the need
(or the construction at elgbt or nine
niek reftnsrles In the U.S. over the
next ithie yeast.
Most of the material on the
(the stauMn4’s owit qusta.
tl,w, msr t fiw a refinery In New
208—3
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iniaie’appind t UI0#SUSr.II
madeeinlaaM 1S (or’ ,,
# r
0. burinj.W 4I-
ths js ___
of lbs C i lbS REP
, ....Jtin U cwdsis to I .NS
rh r,ui.p ,4& ad
to the EPA r 1 i*i L i , g ttuiitl
S tOrn vRV 5 theea h Hon
Barbsar Paasag., wblcb is Cans-
- An early IsCtOO M III lila l$ b
din that par c*Mad to writing lb.
a mcl”I.g the Pittston
a.
earner u . s r rere& )ia,*rli
. ‘. :
mason a, tWUW&O is tam a’-,
though the stats record must hoe.
,bosn available bad the EPA wisbadt
Ito alibis It.
in vabiatuuM the rr*&tta 4
¶ the e* m.nt lnmbPe no M.runr’
islbaii ,nulotive. Ie.i u( .nt -J
‘eas unail lN’ a;’ t son -or(
granted that * 1 w us. 1 b m• o4!
contsin them. a1th ,*? eoo id.’
ble evtdsn e to as ‘ inb’y
a!a1Iable. or d’sa tJ sta rm - t
CO M1 the steed ;t ;tS -4
inhale ’ y. bunwa n b vey
..
thi 1edr I F.fl.n er*y’a fts ’J-
•tim ji.% ,4 wt.u.li Peon. kgtgs
energy ‘póHrt.s” have grvwa.
Seine nt it, h.w..on . Indicibu why
Pittston has been as persisted in
peilutni the Eutp t tlng for
lb. rmuin toiec’wenmhe s — )
favor the PMIpvct locedun over the
CI U Coast and the ?i dd1e AIIMIIe
salon. In Ilmi order...Eas ait has
.r per bbl cat advantage over the
( ‘a I’r’liern ai ti per
.&vantage a a bflddie Atlan c
Ihess dlfterei*laIs or.
based s. delIvered prodect costa
and eflsetpskon,.revin
sbOI offset an tk.a , far ceos
mar — pederonones w be
det ind by eu ,i tarn ’
to (Che ad. )
Purther along the statum i
dde: “ d lido the delised
predict cod Is a 1$ , j.. .wt I. .
on Invontrnar4 .”
Pandig raiusnc Is made to the
c z —
ty for a co sane IT I1g5
as is
wht pinam.y be. Thu can’t be
id m J on EPA since no
one mine muw to know either. No
rei .aci at all in made to the
findings Cith. liT2Goverioes Tach
Torte on h’dimry nod the cost
lids — - dsemslbsd as “blue
ribbon” Iiv i p of the .tdzlesee of
the pa’Øe on It, , . s . .miaidid lid
lie Washaugtoa Coondy coed be
considered for a major b’ .ii (rI. l
— . #.
Padag reforsuci in made Is the
____ C i a P ” ueddj
p 4aeL says that the MIs
for the p. aed rofinury ad the
— for the puwur peoj.ct have
been coer itsd by Pittat.. ad
lie Corpssl Ei ers and adde the
aypdc that ‘the toyed ml
the two projects appaurt L
No d nce Is made to the need
(or CensdI ’i approval, soul Ito
— . ppostflo ” for lbs p e .gs
C i tai*ers tluvegh lined Ba’t
Passage. Why this to made
is not clear, perhaps a rigid and left
hand dIvision between EPA and the
ant. —
Tb. ExecntIv. $wnmary ’
winch in sit that may be read by
sone — th mm power than
percuptice, c a couçte of
M P&t sn (send that f lpWI ml.
fared a g , i’ c adv .
laes as well as a very Mw r
or”slfara & ‘ Ml
Amung the adi: ra P
wan u i.. I&v . lad
Rinebsan thin EPA
has really told an egg -an ostrich
egg.
20 5—4
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(1 .. i ’
Tb. Environmental Protection Agsncy
ha. reached the conclusion that Eaatport is
an Ideal place for an oil refinery, with only
one drawback, the danger of a tanker
&saiter in the channel leading to the site. It
is like saying that hanging Is a relatively
harmless .ff.it. enc.pt for what it doe, to
your nick.
It is not true. either. that the damigs of
a wrecked 2S0.(E0 ton tanker would have
only a local effect. Due to the counter-
clockwise movemint of current. In the Gulf
of Maine. any considerable spill would have
fatal effects on marini life over a long
section of the coastline. It wouki take years
for the area to recover b such a
calamity. Th. fishing hulus y of Down But
Maine would be terribly The blew
to clam,. bloodworma and would be
fatal.
The refinery lt .elf, having destroyed a
going Industry In Main.. in 30 to 50 years.
would become a monumint to another dead
Industry, with the exhaustion of fossil fuel.
Eastport does not need another Industry In
its terminal stages. a. badly U it nssds a
live industry with a bright future.
Hangrng And Refineries
208—5
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$ a
1971 e..,be ’ i”,
Dei.v l5,v s:
ft
No tø t *P I”$• eppi;c ##c ! f!
S
• S.
*5 ‘ me 9 u c)dy 7d?dJ Dom,
4€,i*,1 E. Bs’.wai,
209—1
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11 D .c. 1976
?(r. John )icGlennon
Regional Adainistrator, District I
Environnental Protection Agency
John F. Kennedy Federal luilding
loston, lass.
Dear Mr. McGtenn.n:
lb sooner bad I sent off to you op letter of 10 D.c. with it. .nclosure,
a copy of the artici. by 1. asthsll end D. McAtser fran Washington Monthly,
May 1972, “The Pittston Pbntalityi Kanslaught.r on Suffalo Creek”, than I
ran across this satond article, her. .nelossd. It is by Mary Walton, and
appears in Harper’s of Mrch 1973. It is titled “After the Vlop4 1 a contin-
uing lesson in corporate insensitivity.” If anything, it -1u’IhWs’.ph.sius
the lack of concern for hanan life and for .nvironaental values in th. cor-
porate structure of the Pittston C any. The p.opl. of Eastport have every
reason to be alat d and angry over the pos.ibUity that this co .ny would
be building any kind of business uthatsosvsr on their island, especially on.
that involves explosive substances such as petrolowo. This is a coepany
without exp.risnc. in refinery op.ration, but with plenty of experience in
Jeopardizing huean life. I further e basis. that tb. corporate record,
th. character, in other words, of this applicant for a license is very
relevant indeed to your revise. I urge you to consider both of this. art-
icles and others on Lbs sean topic as in integral part of your review of
the application.
oha S. Chappsll, Jr.
do Dept. of Earth Sciences
lborthsastern 1h iv., loston, Ha sp. 02115
-------
r 74
lWa cA
“73
Mary Walton
AC’1C 2 iC4]1 L L©©
A costtinuing iesson in corporate inaensh ivity
Ai L £.N . . Fei uy
U. l 11. a Lan cal.
t UJ . Aned.
, ii 34d. Creek
te La... Cas .sy. V.u
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gas. l na.. any .
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•f
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a rtp•rS#P I.’ •&e
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-. wiu.r .,
She b&IaE.tphta I .
The rum Jails so/dy at r* its sound aaspii.
fled 1,y the trailers’ metal roe/s. A child begins
to cry. A miner dressed for the second shift
steps frees the door and trudges towed the creek
The rain continue, through the night and he
reulsiul th.r.. ug work for a conipulsioo
vigil at th. creek bank. Car after car filled with
J.milies and blsw igiap golfs from the trailer
park us sowck of higher ground. Those who do
not 1e listen te she ruin mid rameasb.r. Their
tears are the sorrow 01 R. 9slo Creek
A SULLER ORA? CIILIRC piessas down woes
9%Ddalo Creek hollow, from hilltop to hilltop
and — far op and down the winding valley as
you Con sue, clamped on like a lid. F.xc .pt forth.
pies p and trees—thuus faudly singed with
owl, au’sani— s is a black and white movie.
The sky, the houses, th. people are all mono-
. .biema : pals white children lrnng in a shadowy
valsy whir . they’ve nerer mien a benson, ails
I wn p.opl . whine peat.grandfathers canse to
lay is rails and stayed to mime coal beside whites
black as they. There is a brisk, cool
wlad atinring. wnuiual here. cloansia but eerie.
Ikee al ien the valley is still. c with dust
kl.k,j up by can and pickup trucks traveling
the crumbling road, and with black grit from
she tipple. where coal is loaded into boxcars.
And, under skies LIJCh as theme. a fine dulling
mist. At this particular hour in suidafternoon.
the long lines of C £0 cars are full but not
end of the seventrea-usile-tong
valley is a retty place. Hones are tethered in
thick pastures on choice bottom land. The trees
are full, riHIsd by the wind, and the creek is clear.
But something is wrong. It is too quiet, cunieissly
empty , too clean. In the coal-mining hollows of
West Virginia. tlaud hustles with small coal.
ca.p ! and carefully nurtured gardens,
ce’ t ”y Mores, trailers squaued onto tiny lob,
drive-In ruslaurant shacks, cars anti more cars.
Ills that cluttered leaving the town of Man,
at she mouth of the hollow, where the single
movi, theater is for sale and you are “cordially
i.vi..r tos revival. But at I(iitler, three miles
op is valley, the l - seem oddly dilapidated
and the yard. are muddy. Farther up you see
the high-water marks, the houses askew on fous.
dations. And then it is empty.
Where are they, the people? The people: the
old couples sitting on front potohes, men tinker.
ing with gaping cars, children scattered among
the houses , the young girl, walking in pairs, long
hair stringing down their backs and hips sway.
ing in tight jeans, the boys in worked-over
Chevys and Forth, hooking as they roar by,
a .dting to a stop to yell, “Where y all gain’?”
The jirk smile too sweetly. “We’re just takin’
awalk.”
A stats road sip, pee, with white letters,
stands beside a large field. It says “LOrSdO Us.
incerjonstut” It could may “LOIIdO Uninheb
lied. There is nothing here. Lorado is one of
several cononoalties that vanished February 2(i
when the darn eoilepa.t
p4 ’AT . .. ATRLR* .. • WAUGI is at home.
Vt Home now l.a two-bedroom trailer, sleek.
ly paneled in plywood, with a new color TV, in
a place called Latrobe No. IV—her., Lay.trobe.
Odd, these Roman numera l ., an outsider’a, a
— to
She is a tall slender woman of forty-three. is
dark-blue flared slacks and a blue and white
patterned shirt. Her hair is light brown, very
short, soft and fluffy. Her voe, fragile and
quavering. carnes the jarring *‘est Virginia
twang; her laugh is nervous. She grasps her
hand. when she ims’t drawing on a menthol cig-
arette. now three packs a day, she tells you. She
is a beautiful woman and tragic even before she
smiles. But the smile, with disconcerting
between her teeth, is heartbreaking. It is
and not there, more a wish than a smile.
“And what did . . . what was your husband’s
mama?”
“Roble.”
“Roe lsr
TM R.ble, yob.”
“How do you spell their
“R -o. ” She coughe. “I get aerusu . just
talking about that.” Sb. iisi4 again, apolo.
gstlrafly. “I ’ve sort .4 bad a aiM the last few
day. is..”
210—2
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7.C,dr Michael Wrnsgh, Lw,dnle, VIM, aga 18
29. Rohie Waugli, Lundale, VIM. age 45
63. James Waugli, Lundale. VIM. age ii
116. Larry Kevin Waujzh, t.undale, V/U, age 5
117. Donna Waug/r, Lw.dale. V/F, age 20
Cathy W’augk, age I (missing)
_-/rom the deceased lisg, March 28, 1972
Kit Waugh thdn’t want to talk to you very
ouch when you called from the Lundale store.
A high clapboard structure that escaped major
boil damage, the store has been freshly painted
nd restocked for customers who never come. “1
iwfly don’t know anything.” she had said. “I
see very much.”
When it happened.. . when the dam broke,
Ia water exploding through the burning slag
pat, surging down the valley in a twenty-foot
vase nearly always described as a “wall of
water,” KM was visiting a neighbor two houses
away. “We just looked out and here come the
waler. That’s all we saw. I tried to go home, but
I eeeldn’t make it back home. So I just stayed
thee? Stayed there, until the water went down.
nailer of minutes. When it was over, her bus-
hail, four of her six children, and her grand.
lighter were gone.
ae doesn’t tell you, but others have, that she
ksileepaes.. imagining five-year-old Larry, her
Ichy, running ahead of the dreadful wave, arms
i .aJied . crying “Mommy, Mommy.”
Were all the bodies found, of your family?”
“AU of my family was found but just one. My
pa.ddaughter, she wasn’t found.”
(They speculate, on the creek, about the lost
sdhes, whether they reached the Ohio River
ety-Ihree miles away. It is too horrible to ____
Ia&aboui Cathy Lynn, little bit of a thing, all
• (
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____ - 210-3
‘I • 4 .
proud smiles as she stood, for the lint thus. “‘We just looked
Decaying now somewhere.) out and here come
Janet Waugh, seventeen, is alive because she
spent that night with a girlfriend. She is. the water. That’s
girl, with a swollen face, and you wonder if ahe all we saw. I tried
has been crying. It is her last year of high schooL to go home, hut
She will no doubt be married soon, Like Kate I couldn’t make it
remaining son, and the mother will be alone.
“I think it was about four or five altogether back home.”
they didn’t find,” Kat says.
“Seven,” says Janet. “Seven,” you repeat.
“Six kids and an adult,” Janet add..
Kat: “Was that Mr. Clay’s father that was
never found? And I don’t know who those chil-
dren was they never did find.”
Janet: “Donald Clay’s children and Cathy.. .“
“I thought they found those children.”
“They found one of them .. . and the three
unidentified kids too.”
You ask, “Janet, your mother say. she isn’t
angry. Are you angry?”
“Well, I kind of agree with her, but, I don’t
know, uh, I just think it’s pure-all murder.”
Kat: “Other than that, I’m gettin’ along
pretty well.” The phone, a party line, belche . a
harsh treble ring, not the Waugh’s. “We just
learn to live with it.”
Other than that?
UREa MOUNTAIN ST ZAMS come together to
I form Buffalo Creek, and the small town
farthest up the hollow was called Three Forks,
or sometimes Saunders, as ii is on maps outdated
by the flood. The houses, former r owned by a
coal company, had been pure by ml!lors iii
the late ‘50. for several thousand dollar.. Over
-------
A
THE FLOOD
the ysain people—most of them earning decent
wages in the mines—had added siding, reome,
porches, and garages, installed new heating aye.
tems and appliances. It was a clean, well-kept
ciemunity.
In 1953, the state of West Virginia brought
under its water pollution control program what
peopl. call “black water”—ihe discharge from
preparation plants where coal is washed before
shipping. Seeking the least expensive way to
treat the waste waler and sludge that until then
had gone directly into the nearest stream, coal
companies hit on the idea of using mine wastes
—slag, “gob,” or slate—to build dams, then
pumping the “black water” behind them. There
the sludge could settle and the water would be
clarified as ft seeped through.
On one side of Middle Fork was an ugly burt,-
ing gob pile like the hundreds that have sput-
tered for decades on West Virginia hillsides, the
still highly combustible material emitting sulfur-
ous fumes that wither surrounding trees. It was
a s ”p 1 e matter for Lorado Mining Company,
which had begun dumping gob there in the tat.
‘40.,t. extend the pile acres. the hollow to form
a dme. By 1966, the structure was 500 feet thick
d twenty feet high, a stinking, smoking hill
h,eked between the mountains. Because the im-
poimdme”t was filled with sludge, the new owner,
Buffalo Mining Company, started a second darn
Luther up Middle Fork.
In October 1966 a large hillside coal-refuse
hank in Wales buried the Aberfam schoolhouse,
frfl g 144 children and adults. That Decem-
ber the US. Geological Survey dispatched gee 1 .
eght William Davies to e•”ve thirty-eight
banks in West Virginia. One was the first darn
on Middle Fork, which Davies noted “could be
overtopped and breached.” In March 1967 Sec.
• rotary of the Interior Stewart UdaII wrote the
governor , the state’s Congressional delegation,
and county officials, calling attention to hazards
in thirty ban’.s. Only the four considered most
dangerous, however, were mentioned by name.
The dam on Middle Fork was among the remain-
ing twenty-six. Wall pledged continuing ohser.
votion of mine dumps “for possible critical
conditions.” Only a few months later, Davies’
forecast proved accurate. Water from melting
snow overtopped both dams on Middle Fork,
flooding yards and causing minor property dam.
ago in Saunders. Residents recall a similar break
the year before in a slag pile in Proctor Hollow,
another offshoot of Buffalo Creek.
Ia 1968, Governor }luleu Smith’s o ce ye-
caLved a second letter, this one attacking the
dam In no uncertain terms. An elderly Saunders
woman named Pearl Woodriun wrote: “Dear
Sir, I liv . 3 miles above Lorado. I’m writing you
about a big dam of water above us. The coal co.
basdmoped a big pile of slate abo ut4o r5 hun-
deed fast high. The water hrkLld it is about 400
feet deep and it is like a river. It is endangering
our homes and lives. There are over 20 families
here and they own their homes. Please send
someone hero to see the water and see how
dangerous it Is. Everytime It rains it scares every
one to death. We are all afraid we will be washed
away and drowned. They just keep dumping
slate and slush in the water and making it more
dangerous every day. Please let me hear from
you at once and please for God’s sake have the
dump and water destroyed. Our lives are in
danger.”
The letter was routinely forwarded to the
state’s water pollution control agency and also to
the West Virginia Public Service Commission,,
which is required to license danzs for construc-
tion after a thorough review of their design. Rep.
regentatives of each agency looked over the dam
with Buffalo Mining Co. vice-president Steve
Dasovich. Later, they acknowledged in inter-
agency letters and memoranda that the drm
might slip and that th. company had never
sought the required license. However, the agency
officials interpreted th. law to mean that no
license could be required retroactively.
“They told me they’d been up there and looked
*tthe dam and it was dangerous and they’d see
what they could do about it,” Mrs. Woodrum
recall.. “And that was all that come of it. I never
did hear of it anymore, and then I had planned to
write Governor (Arch] Moore (who succeeded
Smith] but I neglected, just kept putting it
off until it was too his.” Widowed before the
Hood, she lives now with bet daughter and a small
nasty dog in one of 600 emergency trailers pro-
vided by the government Over the yeses, the
Woodrums had left their borne a half-dozen
time, during heavy rains, the last the night be.
fore the flood that destroyed it.
By 1968, the poo 1 behind the second dam was
full, and work began on a third, again without a
state license. (In testimony Dasovich said he did
not know that a license was required.The sludge
in the second pool served as the new dam’s foun-
dation. Like the first and second dams, it was a
loose mixture of shale and low-grade coal, irregu-
larly compacted by a bulldozer. In June 1970,
when the dam was about half its eventual sire,
Buffalo Mining was sold to the Pittston Co., the
fourth largest coal producer in the United States.
A conglomerate concentrated in coal mining and
oil distribution, Pittston also owns 80 percent of
Brinks, Inc., the armored car company, and all
of United States Trucking Corporation, and
claim, to own more warehouse space than any
other company in the world. Among the more
notable members of its eleven.msn board of di-
rectors are ex-keavyweight boxing champion
Gene Tunney and former Kentucky Senator
Thruston B. Morton. In 1971 the company was
operating seventy-six mines—the majority tn
southwestern Virginia, easamw Kentucky, and
210-4
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AFTER
THE FLOOD
West VirginIa—through Its Clinchiteld cost d l .
vision and ten wholly owned subaidisriss, among
them Buffalo Mining Co.
In February 1971,a front portion of the third
dam sloughed off. Nevertheless, the company
continued to dump refuse, widening and height.
ening the structure. During that year, a water in-
spector habitually noted in written reports to
the company that the dam lacked an emergency
spillway. His warnings had as much effect as the
previous letters, reports, and cave-ins.
In May 1971, nine months before the disaster,
the U.S. Bureau of Mines promulgated regula-
tions effective July 1 under the 1969 Federal
Coal Mine Health and Safety Act. “Refuse piles:
shall not be constructed so as to impede drainage
or impound water,” the regulations stated. “If
failure of a water or silt retaining dam will create
a haaard, it shall be of substantial construction
sad shall be inspected at least once a week.”
Inspection, however, was left up to the company,
not entrusted to federal personnel, and, in fact,
there were no adequate engineering inspections.
On Buffalo Creek the dam appeared so massive—
an 80,000-ton dump, 550 feet wide and 480 feet
thick—that no one dreamed it could go: it might
overflow, but not crumble like a sand castle ,
which is what happened to it that Saturday
morning.
I T NAD Izan RAINING off and on since Thursday,
but the precipitation wasn’t that unusual: 3.7
iarl in three days, which might be expected on
mu average of every two or three years. February
had been a warm month, and there was little
mow.
Had the flood come earlier, even more people
would have died. But most were awake, and many
s the huge wave laboring toward them in time
to run for the hills. Others, particularly around
Saunders and Lundale, had been warned by men
who had been up on the dam the night before,
watching the water creep to within a foot of the
top. They had gone door to door, pleading with
friends and neighbors to leave. But there had
been other warnings, in other years; and some
people heard only what seemed to be another cry
of wolf.
Two deputy sheriffs. Max Doty and Otto Mut-
ters, were among those who urged people to get
out. They halted their warnings after they met
Buffalo Mining’s Steve Dasovich on the road
about 6:30 A.M.
According to Deputy Doty’s testimony before
Governor Arch Moore’s investigative committee,
Dasovicli, who had just returned from the dam,
stated, “Well, Sheriff, you can quit worrying
now. We have channeled around this thing and
riutrv.ed some of the prensure off of it, and I think
It L i going Lobe all right.”
Deasrich maintained afterward that he bad
merely announced piwia to ditch around the dani.
That may have been the case, according to Mist.
tern’ testimony before a Senate labor subcommit-
tee. Whatever was said, Mutters was left with the
impression that the dam was all right, as were a
group of other people on the road who heard Das.
ovich at about the same time. Had they not been
reassured, Mutters told the subcommittee, “1
think myself and the other deputy and people
there could have got everybody out.” When the
dam went, Dasovich himself narrowly escaped.
Subsequent engineering studies have shown
that during the night the dam became saturated
and the particLes of gob buoyant as the water
climbed up its slope. The dam quite literally
turned to slush and began to ooze forward, allow-
ing 132 million gallons of water to surge over
the top, mingling with the sludge. The liquid
mass swept through the two lower dams, causing
explosions in the smoldering bottom one, and
crashed down on Saunders, destroying every
dwelling. It picked up cars, trees, people, and
even homes with whole families clinging to them.
calling for help as they were propelled past those
who had scrambled up hillsides to safety. Careen-
ing from side to side through the zigzag valley.
the black maps skirted whole communities and
leveled others. In the three hours it took the
wave to travel the seventeen miles to Man, 125
, women, and children died; 1,000 others
were injured, 551 homes were demolished and
another 936 extensively damaged, leaving 4,000
people homeless. Property damage w estimated
at more than $50 million. Only two homeowners,
it turned on carried flood insurance.
(I was then a reporter for the Cl iar1asgorm
in the state capital. While my colleagues
were having no luck finding company officials ma
the scene, I called the New York headquarters
where an executive vice-president remarked that
the flood was, “of course, an act of God.” How. I
wondered? He explained: The impoundment
“was incapable of holding the water God poured
into it.”)
The homeless survivors were housed’ tempo-
rarily in the Man high school, with the gra&
school nearby serving as a morgue. Along the
creek, National Guardsmen sifted through de-
bris looking for bodies. The weather was un-
seasonably wirm, and the stench of death hung
in the sir The U.S. Army Corps of Engineers
moved in construction crews to rare houses dam-
aged beyond saving, bulldozing the remains
into huge piles for burning. Thirteen sites were
leveled and equipped with water and sewage
facilities and electricity to accommodate the
cm igvi cy trailers ordered by the U.S. Depart-
ment of Housing and Urban Development.
Interior Secretary Rogers Morton, brother of
Pittston director Thruston, issued a press re-
lease saying that his department, which includes
the D.uwu of MInes, lacked the authority “to
210—5
-------
der.the e miaatioe of dangers to public health
and safety” posed by coal-refuse piles. The state
investigative committee, however, would later
conclude: “The U.S. Bureau of Mines indirectly
hal authotity to prevent dams to be coestrocted
from refuse piles.”
AlOtiT A MONTH AlTEC THE FLOOD, Pittston,
M carefully denying liability for flood dam-
ages, nonetheless opened up two claims offices
and announced plans to settle with survivors.
The company assured stockholders that “the
sect of the claims should not be material in
telatios to the company’s consolidated financial
yet another ordeal for the flood vic.
. For weeks they had queued up at various
offices to get emergency loans, houaing, unern-
pioymeat benefits, medical help, welfare assist.
ce, legal advice, and charity. Now they began
lng from store to store, seeking the receipts
t Pittston insisted must accompany each
dales. (One man presented a laboriously ac
re list of a dozen lost items. He was sent
inch for proof of the dates of the purchases.)
For Pittston, immediate settlement had obvi.
s.s .sdvantages. Dazed by their losses and eager
for compensation, many filed claims without a
thorough accounting of all that was gone. Un-
rhooled in the law, many didn’t place claims for
a of their lomve’ , including physical and mental
ajuries. Totally without resources, most couldn’t
afford the two or three years it would take to sue,
&da’t trust local lawyu rs, many of whom work
hroosL companies, and didn’t want to give a coo-
,-fee lawyer a third of their settlement .
Filing claims was frequently arduous. It wasn’t ‘ 4 There had been
unusual for people to make three cv four trips to
the claims office to argue the worth ol a house, a
living-room luite, a son’s life.
On May 2, as Pittston executives and directors
journeyed to Richmond, Virginia, for the annual
shareholders’ meeting, forty-five bitter Buffalo
Creek survivors boarded a chartered bus to take
their grievances about claims handling before
the meeting personally. They arrived the next
morning, weary and disheveled from the long
ride over the mountains, only to confront several
off.duty policemen charged with keeping order.
Pittston broke precedent to admit newsmen to
the meeting, but the band of West Virginians wu
barred. (Only the day before, Continental Oil
Company, faced with a similar if lesser challenge,
had opened its stockholders’ meeting to a delega-
tion of miners and widows concerned with the
policies of its subsidiary, Consolidation Coal
Company.)
Still. Pittston couldn’t insulate the meeting
from the events at Buffalo Creek. In April, the
New York-based Field Foundation, which grants
about $3 miUion annually to a wide range of
social projects, among them the Voter Education
project in Atlanta and the National Indian Youth
Council in Albuquerque and several in Appala-
chia, had discovered among its holdings some
shares of Pittston stock. As the group from Buf-
falo Creek waited outside the carpeted board-
room, three Foundation representatives were
inside, urging Pittston to deal with specific prob-
lems raised by the disaster. Field president Mor-
ris Abram explained: “As a participant in the
total society, (the Foundationdoes not want] to
receive i 11 c ma from its iav uL ts csily to
other warnings,
inotheryears;
and some people
heard only what
seemed to be
another cry of
wolf.”
— V..
•1. ./
..—..
-- ;_.
- ‘ -:: -— -i
t..J
I .—.
p.
V
S
r
— . .
210—6
U
-------
spend the same income in allocating grants to
redress the social distress attributable to that
business investment. Moreover, the Field Foun-
dation firmly believes that, in the long run, the
safety of its investment in Pittston or any other
company depends on the compatibility of that
company’s operation with the welfare of its work.
era and the conservation of the environment.”
Abram proposed resolutions requiring Pitts-
ton to report to stockholders in six weeks on the
kinds and amounts of claims and compensation
arising out of the Buffalo Creek disaster, to ap-
point a committee to develop information on the
potential for similar disasters arising from com-
pany operations, and to explore alternative min-
ing methods, complete with cost analyses, for
disposal of coal wastes. The resolutions were de-
feated by a vote of 12,000,000 shares to 1.171.
With a half-dozen reporters present, clearly
the waiting West Virginians couldn’t be ignored.
After the meeting, Pittston president Nicholas T.
Csmicia met with a delegation of seven. This
time the press was not admitted. Camicia, the
eon of a coal miner, is a short, agreeable man
who was raised in McDowell County, one county
below Buffalo Creek. During the session with the
seven men, Camicia apparently soothed their
doubts. One leader murmured, “I’m satisfied
Nick is going to do what he said. We have faith
in the company.” To reporters Camicia re-
marked, “I was born and raised in this very area.
- . These are my people. I assured them that
our policy is to make restitution and to expedite
the claims as rapidly as possible.”
By early June, however, many victims hadn’t
received settlements or were dissatisfied with
Pittston offers. Miners also resented the loss of
six to twelve weeks’ pay while the mines along the
creek were closed by flood damage. Employing
the only weapon they knew short of violence,
3,000 men staged a week-long strike for back
wages, vowing to shut down all of the company’s
mining subsidiaries. Failing, they returned to
work poorer for the protest.
INCE FEBRUARY 26, 1972, Pittston executives
have maintained a distinctly low profile—
except for a flurry of appearances before state
and Congressional investigating committees
where, for the most part, they were treated
courteously, even gingerly. But at a hearing last
May, while Camicia was on the stand, New
Jersey’s Harrison Williams, Jr., chairman of a
Senate labor subcommittee, pointedly observed
that Pittston had been cited 5.000 times for
alleged violations (carrying possible penalties
of *1.1 million) of the Federal Coal Mine Health
and Safety Act—snore than any other company.
“I was not aware of that, sir,” Camicia replied
On reflection, he added, he believed certain of
the citations were either not justified or cx-
cest ive, and thus were being appealed. In a
subsequent letter Camicia explained additionally
that the appeals were being Med in order to test
the constitutionality of the Safety Act.
At the hearing before the statc investigative
committee. Camicia essentially argued the posi-
tion that Pittston adopted shortly after the flood,
that the disaster “was not foreseen and was not
reasonably foreseeable.” But, identifying Fran-
cis J. Palarnara as the source of the “act of God”
quote, he observed, “I would never call it an act
of God. -‘ . Certainly I’m not blaming God for
it.” With the deity absolved, Camicia further
maintained that the impoundment wasn’t a dam.
“It was a slag heap used for filtration of water
from a cleaning plant.” Finally, he begged for
“some help and not a lot of rules and regulations
that won’t do us any good, as we now have.”
• The governor’s committee, surprising those
who expected a whitewash, concluded: “The
Pittston Company, through its officials, has
shown flagrant disregard for the safety of ml-
dents of Buffalo Creek and other persona who
live near coal-refuse impoundments. This atti
tude appears to be prevalent throughout rnpch of
the coal industry.”
Camicia now turns aside interview requests.
He explains that his lawyers have advised him
to keep silent about a $52 million lawsuit brought
by nearly 500 families and individuals. He calls
the suit “a nuisance” that will “take a lot of my
time.” (In response to my own request for an
interview, Camicia suggested that a written list
of questions be submitted through Pittston’s
public relations firm, Albert Frank-Guenther
Law of New York. This was done, and the im-
mediate response was a telephone call from a
man named Gilbert Busch, who described him-
seLf as a “special public relations consultant.”
Busch asked for a copy of a draft of this article
to provide “a frame of reference.” Turned down,
he declined to answer questions that involved,
among other things, the amount the disaster has
cost Pittston in lost production. claims settle-
ments, flood damage, and lawyers’ fees, as well
as what action Pittston has taken to eliminate
its other slag dams.)
The Pittston board of directors seems pre-
occupied with the company’s economic pro ’-
pects. Quite apart from the flood, 1972 was a
bad year: by October, net income was only S 13.2
miLlion, compared with $34.9 million for the
same period in 1971. Camicia and board chair-
man Joseph Routh blame surface (strip) mining
restrictions and costly health and safety regu
lationa, not the Buffalo Creek claims against
which the company is insured.
StiU, some of the directors display a startling
viewpoint toward the Buffalo Creek disaster.
Samuel Pryor of Greenwich, Connecticut, a for
mer Pan Am vice-president, observed that PiUs -
ton was no more responsible for the Buffalo Creek
! _ ary Walton
AFItR
THE FLOOD
_ p., ‘ ‘b
Is
210—7
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fl..d than the one last summer in Scranton, Penn-
sylvania. “It was an act of nature... . The rains
came and the dam wouldn’t take it.” Vigorous
despite his seventy-two years —.t least over thc
koac Pryor insisted that the dam “was built
by the government and inspected and inspected
and inspected.” To the incredulous response, “By
the government? Buffalo Mining Co. built the
dam,” Pryor replied, “JuM read the reports.
Don’t be satisfied with what the minority say.”
Thruston Morton, the affable ex-Senator and
Inner GOP national chairman, sighs: “It was a
tembis tragedy, of course. No question about it.
WeU,it happ ned o usin 1937 in Louisville . .
NA dam broke?”
“No, forty days and forty nights of rain.”
“But it only rained three days on Buffalo
C,edc.”
“No, no. Check your weather.”
There is a grain of truth in Morton’s state-
-Ut.
1* January and February, rainfall aver-
. d 2.5 inches above normal, leaviflg the
grusud saturated. But, in the words of West Vir-
ginia Mate climatologist Robert Weedfahl, “If
there’d been no darn, there’d have been no flood.
It wan not a naturally occurring flood.” And of
J the dozens of slag dams in southern West
Virginia, including others as Buffalo Creek, the
one to fail during the rainstorm belonged
teP ttstosCo.
A kiv through the valley, today under
sunny skies. There ’. a chill in the air and
theism. eerie wind persian. At the head of the
neek the remains of the lust gob pile are sliced
by a V-shaped gash where Lbs water surged
through. One hundred thirty-two million gallons
of liquid failed to extinguish the internal fires,
and flames still lick at its slope. Several
handied yards away, a clamshell is scooping the
cleaning-plant sludge from the new, shallow
settling pond. Trucks haul it away to a t!ibtant
hollow. The system is a substitute for the dams—
so less unsightly, but one that at least poses no
hreat to human life.
For a brief time, there was anger on Buffalo
CreeI. Now y u find only depression and uncer-
Lainty. N’ t -‘rprisinjly, Dr. Albert Redo, a
psychiatrist t h th county mental health
age -. ia d “an extremely, almost
piranc ddusbn of fear every time it begins
t r*i, especialLy in the children.” There are
‘ ‘ ult ferli sgs i mong those who lived while
sammy died. Cases of extreme headaches, body
aches, and hypocho idria are common. A dozen
elderly people, in whom the symptoms consti-
tatUd acute ne4rnajs, have been sent to. state
nuatal hospital. Redo, a Cuban refugee not un
nsiated with dishucstic , is nonetheless ussr-
— that “aswingiy enough, they all want to
go back to the same place.” To their
their land, their neighbors. The doctor
ii would be the best thing for them now.
But no one can begin rebuilding until wst
and sewage facilities are installed, and work has
barely begun. It was held up for months by con-
troversy over plans for a highway through the
hollow and into the next county, plans formu-
lated ten years ago and dusted off when the flood
made possible 100 percent federal disaster fund-
ing. Social strategists have further complicated
the future with a master plan for three “nodes”
or aubdevekpments of diversified housing in the
$12,000-to .$20,000 range, which is more than
many people say they can afford. (Mention
“node” on Buffalo Creek and they think you
mean “know’d,” but never mind.) Such concen-
trated housing, with no aid for private efforts,
would leave their property valuelein. So, now,
months afte, the flood on Buffalo Creek, there is
only grass.
ersrsy osnonna, thirty-six, sits uncoinfort.
ably in the easy chair that came with his
three-bedroom mobile horns in “Green Valley,”
a trailer site on Huff Creek a mile from Man. He
has spent the day in bed, his back laced with
pain from an injury in the mines last year. Peri-
odically he draws workmen’s compensation, then
returns to the mines when the pain eases, reins.
usgto do the light work ordered by the doctor
because “I ain’t going to ask no boss to let me
go outside and work. I figure I’m no better than
thereatofthem.” /
Kenny, his cheerful wife Anne, and their (is.
children lived in Saunders. They escaped the
flood but lost their five-room house and every-
thing in it—and, he calculates, twenty-seven
relatives. You ask Anne what they’re going to do
and she says, “That’s upto Kenny.” The weight
of that burden seems added to his physical pain,
and in his eyes is the same wounded expression
you saw earlier in Kathleen Waugh.
For the house, furniture, clothing, a car, and a
jeep, and nineteen stands of bees, he received
from Pittston—and he tells you to the penny—
$13,588.16. He now calculates $ true loss of
$27,000, but in the haste to file he forgot much
of what he lost. “I just asked for $16,000.” Un-
some, “I tried to be honest about it.” And of
the $13,588.16, some 33,000 was withheld to
repay a federal emergency loan used to buy
clothing,, additional trailer furnishings, and a
car, leaving him now with $10,000. What will he
do? “I don’t know. I’ll have to get an. a double
mobile borne, I guess. I can’t put up a $14,000
hons e and put furniture in it. ” Why didn’t Isa
sue 1 “That’s a good question. I’ . asked that
10,000 times.”
He repeats this, and you he., bins L& g aod
1 L i 1 11 , with no aasw r . 0 uacn ia n
‘rotnlly without
resounees, most
couldn’t afford
the two or three
years it would
take to sue.”
MACA7INI
210—8
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211—3
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13 DEC 1976
Ia .tp.rt, *d.ns .. U, 1976
? missis fo r ‘ i’* that *w is pot the ? ias for tI. Pitt. tee Oil •
.r a ether sonsern to build en bose at ie of &astport,
{n,• ether or not the development of that idea would iver be f .a*ibl . ii highly
dsbateb l..
Th. history of the Ia 1 sM of Pass aisaquot r i y has alw a leon aerked by turlul.nss.
The stage was set for thatby th.ir th.ir natural g.ogrm ie sit, in a harsh i—it .
sUish.d .vith fog bai*s and traversed by high winds this h tnd to lapse into th.
fury of a gale, pabtisularly when they are spin ted frnm ths northeast, or be_use of
.th.r unfereseen provocation. Ligend has it that a fastory lop th. AIusfasture of fsg
ii.. off ‘isd lead. th.n the factory bottles all it no . 4. for auarrent s.as tioa
the overflow is let lees, to ibid the benson until ths “ 4’ .hang.s or the sun
.srwifuUy burns it sff.
The Bq of Pbnly, of profound depth and aighty tides govern. Passa.aquo .
It. waters surge in aud around the the risky iulanli with scent rospost for inter..
nattona]. boundaries or h an aitions for ths assujm].ation of wealth. ( 1$ the denteons
of the deep of all sp.sies s- whales, sharks and squidi sod ask.ral ad pollo .k; herring,
.hrlsp ad fleunder. jlobet.r., dads ad ssu]pins aaz species that iwia or ereel
along the osesa’s £lasrbavs fisurished he re and given sustiasnes to the bax4 fishermen
wh briss the elements. A story is even teld sbout a s.-measter rivaling the Leek .ss
nenatr was eap red ad sometias in th. last e.ntury and pot os di.pley by an eat.rpristn
sbeime.a. (This talc has been most diffieult to verify although the grb ’aghter of the
entr.p7 a r Li still trying).
)Is sodern pr.gnostisator. are seytag that the only future that ve ca be sure of
rk t- b c..
is that of shasge. It lies ce_setias. that events happen so rapid1 1 tb re wJ get a
aim idea digested it i i already obosl.tI and inedible. cannot help sosparing the
‘spe of l s’s dq with that of the modern spase age, The Ian e , tgiad of thses
oldee times hid notorious bter prison., rat.riMee ships in barber frs all quarter ,
212—1
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.f the globe and po.rl.y educated s f.lk. try rssowrec to i reve
their condittont and give their children a better shanec in life than they th.ly.s
had, In those 4 a78 the ‘New World” opeidng ip in *ecxiea ereated situations and
jnteruational rivalri.s espeeiall y awong the sountriec of Western tr epe. m that ti
jnternational history was shaped by what went on in riea.
Captain John Smith, the same who invoked (provoked?) th. ssttl.rs of Jst ,
Virginia with the soon sense d.strins that “Thos, who will not work shall net eat’
sailed up and down the North Atlantis sri.an coast on voyages sp.ll4ng out the
aurveloes features of the “Nov We d”for prospectiv, settlers. He vu .xsit.4 about the
fjchsri.c in Worth Atlantis waters and wrote ham. abe t it in glowing t.i’. At that
from the 31 4 th to the 1 6th6 parallel of North
ties the British :ire was claiming the region a —LrrrbM i.e IL $LL ....... I1 I t1
latitude a rid extending ar4 to the Pacific Omean. O ith’e aaps 4 it was all
Virginia. zt the ?r.nch were also in the running. A litti. band of won under the
leadership of .fl. I Monte and (h lain as navigator me s..kirg peace omap fram tk. jp
,.itti..i .aii. LbtslIL native land.4 4 They att tsd t. p lant a settlomsnt en our awa.
St. ‘oix River and spent the first Qu’istaaa of chit. n in imerien uerth of the 3p tsh
pus.ssiona. That was in l6Oh- . ut their hardehip. Vsr so great that they lasted only
winter. In th. spring the survivere moved to the Aneapolie Valley in what i the
Previn.. if Nova Smetin, Canala .
Pros then on for over a hundred y.ers the g1isb sad Prenik had it .u.t with the
fisheries, lumbering and the fur trade to attract v.yageurs and the Uk.. The *itisb
re won •tit and became th pir. “upon which the sun never a.t.’ t vu ine’vitaILe
that upon th. heels of those war ., a new nation, th. ”Unit.d States of Aesrisa” was born
bringing in a now era in whi a!sVdeati ” played upon the imagination.
In madog pease nsgtiationa during the ‘lrnlnticnary period the determination of the
international boundary presented probl.aa, s. of which have not been yet.
The St. Croix River was an i .rt .nt tutor. The month of the river was decided to be
several wiles from Mseec Island epp.aite the Perry shor. at St. Andrewa en the I &tan
side and the srry shore en the Ariea . All of the islanda of Pasmaqmod4 Bay __ u
212—2
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not eo sj&.r.d to be of importance except ror itinerant fishermen. That vu tiiie at first
3at after loyalties were established they proved to have prime ii ortancs in the
hectic historic events which follovedi— the American X .evolution, the War of 1812, th.
Civil TM ar of the United States. I uing all this time the Dominion of Canada was growing
dp, profiting by the mistakes of the United States and bee ng a world power in its
own right aside from its allegiance to England. n fact, the. CL*1sii iaDa have ef ten s.d
to be more impertaistie than ‘ 1 reat britain itself.
I believe I am right in thinking that the Pittston Oil Go, latched onto aatprt
or its refinery project be.a aae no ether plae. along the lame eaet wou]4.have tbum..
They tried to sell themselves at several places from Mt. Desert down M were’ i1 ’ns4
down at each. It aist have been about ten year. ago when an az’tie appeared in a
eagasine (Ithink it was the atur4 R.vi.v but I am a ot sure) putting ‘Down Zut’ in
M.1 , in the ‘Appalachian’ pover - category. It would appear that some bright anal7st
in Wachington, D.C. studied some gover iut .t report pertaining to labor thremgbe zt
the nation and becaus, of similar wage scales noted that Washington County in ka1 .a was
in the same quartile as a negro sestion o th. south. M e n . e the “AppalashMa’. The
furor caused by that showed up ignorance of history and e ..nomies on the part at AP
and similar news releases.
Because Eastport was as far east as they could get, we were NItH for a rsfin.r site.
After its initial suce.es in winning over the City Council, QiaM.r of Coere. and business
interests which had watched Eastport go behind financial y year after year, the Pittston
pec le made mistakes, acme of their modern business methods did not fit hers. A few
tLldependent t minded individuals refused to sell their homes or holdings for litti.
‘ r uothing. hat gave the ‘omrary some undesirable publicity. ant enough to upset their
apple cart but enough to keep them in the lime light. Ear’y this year it was publisiset
in the papers that “ viro Servieea Ins. ‘was .mployed by Pittston to saks a favorable
report for them. That report preyed to be too provincial, (mau i provincial, in ike asses
of narrowness of interest.) to be wo$tk - of a firs such as Pittston set itself up to be.
k....s sp ,’I’
Sir.. then, Pitt.t.a, money nd en propaganda and has tried to ss .y th. idea
212—3
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of its worthine aa a good citisen.
‘I
So, we em only seneluds that what is to be vii]. Jan resolve to make th. beat of
it for our COflat1Ufli 7. There is an old saying that oil and water do not mix. The
Pittston peosis maintain that th y wil]J mix. tat emulsifer th.y’ plan to make to make
that come about remains to be seen. They haven’t hur l.d Head Harbour off CampObeUO
let.
There is an old saying 4bM to the .ff.et that where thers is no vision the p.opl.
perish. 4e oa know that there is beauty a].]. around us. ihsre imist be acme means of
turning that into rofit. And we are advised that “change to th. order of the E y3t,
£t is d ifficult to compare attitudes of th. old days then pree stivm emigrants
to ‘merica wsrs proaiud “streets paved with gold with the present Eq rivalries
tjs auter- apa.e”prior’ities. Ws already have an “International Co ” ity of the St. ‘rsix
*y mot sake the most of it 4 ai carry on there JsI nt. and his f.Uevsrs left off?
, j1 ttP 4
, jr
LNES ifl
L9 W*!f*
c
L 1
212—4
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14 DEC 76
213-].
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44
A
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214—1
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December 13, 1976
U. S. Environmental Protection Agency
Region I
Enforcement Division, Permits Branch
John F. Kennedy Building
Boston, Mass. 02203
Re: No. 1W 0022420 (The Pittston Company)
Dear Sir:
The Pittston application shouLd be denied for the following reasons:
1. Canada opposes it.
2. The proposal relies on imported oil over which the United
States has no control.
3. The “need” statements that the F.E.A. uses to justify the
proposal are highly questionable.
(P.E.A. justifies need on the basis of a) demand;
b) economic benefits; and c) national security, yet:
a. The best way to ensure conservation, reduce de,and
and encourage alternatives to our insatiable
appetite for oil is not to continue to satiety the
demand with forei SIT.
b. A three year injection of laborers in Eaatport will
create economic boom and then bust. The Alaska pipe-
line experience shows that a local economy can be
inflated by out-of-state workers and then be left
floundering. One oil spill will adver8ely affect the
Eastport fishery and the jobs it supports for many
more than 3 short boom years. Worse still, an embargo
of any length will jeopardize jobs and be a disaster
for Eastport residents. FinnIly, what will Eastportera
do when the oil wells run dry, as is predicted in a
short 20 years? “Eastport - ghost town to the oil
age?”
The F.E.A. justifies the proposal because it is close
to markets, but Eastport couldn’t be further from the
market place in terms of U.S. based refineries. The
source of the crude oil should be off the East Coast,
the refinery should be close to the off-shore source
and the on-shore market. Obviously that is way south
14 of Eaatport.
s_.
215—1
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December 13, 1976
U.S.E.P.A. (2)
c. The national security argument cited by the F.E.A.
in the draft summary is ridiculous. No matter where
the refinery is, if it relies on imported oil, as
Pittston proposes, and an embargo or worse occurs,
Pittston will be refining thin air.)
4. The Pittston Company has a poor record. Its past actions
lead us to suspect its words and doubt it will keep its
promises, despite Federal regulation. For example:
a. The Buffalo Creek disaster shows that Pittston is
not overly concerned about the environment.
b. The history of this proposal shows Pittston is inept.
Their application procedure to the Depar1 ent of
Environmental Protection in Maine was very m—
professional.
c. The company has chosen to flaunt the conditionS
imposed by the DEP.
d. The company has ignored Canada.
5, The approach to the port facility is narrow, dangerous and
fog bound.
6. Any oil spill will dams ge marine life and both United States
and Canadian fisheries for years to come. (See “Drilling,
T jcers and Oil Spifls...”Science Vol. 194, No. 4267, Nov. 19,
1976)
7. Air pollution - the refinery will make things worse than they
are now.
8. The entire Environmental Impact Statement is biased toward
Pittston and takes a very short—sighted view. The E.I.S.
should take a long term view, should recognize oil is non-
renewable, that oil reserves are limited, that foreign
sources of oil are unreliable, that the nation has (had?)
a policy of becoming energy independent and that the
Pittston proposal Is a stop gap measure.
The E.P.A. can make a bold, far-sighted step by saying !i2.
Sincerely,
d/1; e;Ir. FD I
U 4 i J. A4. a ss”
(&t,
. .,; Ii. 0 ‘136’?
RVD I N’ (YlCV brtO Ct .
215—2
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215—3
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JOllA.. DONAGRY
P.O. I 3
Lubec, ‘
TsLi 13$-4
December 11, 1976
U.S. Environmental Protection Agency
Region I, Permits Branch
Room 2109, John F. Kennedy Federal Building
Boston, Massachusetts 02203
Re: The Pittston Project
ME0022420
Gentlemen:
I am submitting this letter and enclosures after I have forwarded
my letter of protest against the Pittston proposal along with a
reference map and hibits as of December 8, 1976. The enclosed
letter dated January 31, 1975 is addressed to A. L. Irving, President
of the Irving Oil Co. of St. John, N.B. and the transmittal letter
is from Dr. D. J. Scarratt of the Biological Station at St. Andrews,N.B.
I am submitting this because the proponents made such a point of the
fabrication that the Canadians were using Head Harbour Passage them-
selves for the passage of large tankers but didn’t want Pittston to
have the same privilege.
The only tanker of any size at all that the Canadians have brought in
has been the Irving Glen which was brought in to be off loaded onto
barges bound for St.Stephen, N.B.. I recall that it caused such a
furor that it was attempted only once • It should be well noted that
the Irving Glen is only of the 20,000 ton class and can hardly be
considered in the same context as a VLCC of the 250,000 ton class
which Pittston wants to use, nor even of.the 150,000 ton class with
double bottoms and other restrictions approved by the Maine B.E.P..
Once again, please reject the Pittston proposal.
JAD : md
Enc]..
REAl. 1ATE UROI
Rei
A. Donaghy
216—1
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January 31, 1975
A. L. Irving ‘)i’/ic
President
Irving Oil Company
Saint John, s.a.
Dear Mr. Irving:
I am writing to draw to your attention some implications or
management of oil tanker traffic in Canadian coastal waters.
$y concern is with the hazard to the quality of the marine
environment and the living resources that it supports that
may be caused by certain shipping practices. I am sure
you will agree that it is a matter of broad and considerable
significance.
I have learned that on Sunday. January 12, 1975, your tank•x
IRVING GLEN (20,000 ton dwt) traversed Head Harbour Passage
and anchored in Passamaquoddy Bay preparatory to lightering
Bunker fuel to the Irving terminal at St. Stephen, N.B.
I understand further that lightering op.ratioi. continued
throughout the following week and that som. five or six trips
were made up the St. Croix River befor. the IRVING GLEN finally
left the bay. I am told that serious consideration was given
to leaving a loaded barge moored alongside one of the wharves
in that vicinity over the we.k-snd because the tug involved
in the operation was required at Saint John to attend other
shipping. In view of the strong winter storm which took place
)fl Saturday, it is fortunate indeed that the tug and barge
returned to Saint John instead.
I am deeply concerned that these operations created a serious
risk of contaminating the ecologically sensitive waters of
Head Harbour Passage and adjacent areas. Contamination of those
216—2
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-2-
waters by oil would have caused severe damage to wintering
wild fowl and to recreational areas along the shoreline in both
Canada and ths Un ted States I am concerned as well because
of the vulnerability of the area’s fisheries, their high
value (both in absolute terms and in their importance to the
local economy) and the fact that your lightering operations
took place in confined waters where any accidental spill would
not be dispersed by the open sea. I am also informed that
• • ¶ ‘
apparatus on board and that th.r. was no such apparatus
closer than Saint John, some 50 •iles distant by sea and 70
miles by road.
Should you suggest that fishing operations in the Passamaquoddy
area are largely inactive at this time of year I would accept
your point as technically correct but I would point out that
your transfer point was only three miles from the Deer Island
lobster pound which, at the tim. of your operation, could be
valued at approximately $3. million. As you know, if a spill
occurred in Passamaquoddy Bay prevailing windi, particularly
t thL t a. of year, would caus. 031 i.o dratt d recLJ.y tow ras
the Deer Island pound.
I am sure you are aware that there are costly consequences
of even minor oil spills such as th. one that took place at
Mispec last June that contaminated herring weirs and beaches
in the Passamaquoddy area. The reaction of the general public
to such incidents is distinctly unfavourable to both government
and industry. Beyond that the resulting loss of confidence
216—3
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i Jaa/i
-3,.
La the quality of affected fish products can af ect the earket
that it supplie, by a auch greater area.
I can, of course, understand the econonic advantages that
you and your custoaers would gain by an operation such as you
have carried out, particularly when related to the iaai .nt
changes in U.S. oil tax policyand the •ucalating costs of
shipping. $.v.rthsless I cannot accept that savings of this
nature should be sought by placina other sectors of tb .
econocy at risk.
Viewed in the broader context I a. sure you will appreciate
that the longer ter environeental effects of an oil spill
aust be asasured in ters of years and net seasons, and that
contain.ent and clean-up of spilled oil could at best be
only partially successful in such confined and treacherous
waters as those in and adjacent to Passasaquoddy Bay.
My Departeent is prepared to recognise existing traffic as
an elaaertt to be considered in the drafting of any regulations
that eight be deeced necessary by the governeent. However,
ne u ezatiun that .s tne sub)ect ot thi.s Letter constitutes a
new and euch enlarged diension of risk and cannot be considered
a part of the traditional traffic pattern. I hope that it will
not be repeated. I eight add that I consider the eatter of
such significance that I have asked for a review of legislative
action that would be necessary to safeguard this particularly
vulnerable sector of the aarine environeent.
Yours sincerely,
(Original signed by Madace Jeanne sauve)
216—4
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fl_s
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PSths
l QQ .%(’)p
Ir. John Donaghy
Ion 52
Lahac. N.. 0U52
Deal Mr. D.sapky,
December , l 7$
Y*xtk.r to year tel*pkoss call of
December •, I am edvi.M by oar Ottawa IQ that oar
Minister’s letter to the ftvia Oil Ca say Ltd.,
f• llowiag the transit of lead larbesr Paesaqs by the
IRVING CLII, is not considered coat ideatial, and that,
La fact, a copy of this letter has already bses forwarded
to officials La the U.S. I an farther advised that I
say forward a copy of th. tent of this letter to yon.
You will see that Znvttonasat Canada
is prepared to acknowledge and accept existing threats
to th. area from present-day traffic levels, hat is act
prepared to tolerate say escalation •f that tbr•at. I’m
• ire you will agree this makes oar aos14.toa vis—a-vis
th. lastport proposal quit. consist
Mac i.
FW d
St As N
Oftl
aw Is , & L i Cwmb
N o .
M*ma (P&.a)
D.
Scarratt
r t?I h 7 * 1
216—5
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1$ D C
nvtron..nta3. Prot.otion Agency
Region I, Pireits Branch
3Ff Federal Buildii*
Boston, Wassachos itts
Dear Oirs
The DIX3 for Eutport, Main.’. proposed. Pittston refinery pr
3.ct is a study in £nadaqueoi•s. To ooent on Just one aspect
of it would be fruitlsss. To eoemnt on thee .11 would fill
three ear. voluass.
D.spit. Kr. KoGlennon . tiMing that ‘bias ii.. in the ey. of th.
beho].d•r,’ I charge the DITS with blatant bias In fa,or of the
Pittston proposal.
Publishing a poorly written, sloppily researched., obviously bta..d.,
Draft Inv2rorasntal I aot Stat.aent for the Haatpoz’t situation
is not only nsgl.oting your duty to the p blie b zt 1. else Insult-
ing to the intelligence of us all.
If the Federal agencies invol?ed do grant Pittston the required
pereits, I vIU not only suspect those agencies of bias and eallu.
sian, I will know that utport has bean betrayed in the subver-
c lv. tradition of Vatergate,
Sincerely,
Holly G, Lehigh
7 Cuatoa House Street
Lea tport, Wain• Oie6fl
217—1
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0
V # ## F
HHS •‘
/
4
December 13, 1976
TO: U.S. Environmental Protection Agency
J.F.K. Building / Floor 22 / Region 1
Boston, Massachusetts 02202
REGARDING THE PROPOSED PITTSTON REFINERY IN EASTPORT
On behalf of my friends, family and associates,
I wish to express our collective dismay at the
possibility of this area becoming another copy
of a place like New Jersey.
Many of us have come here over the past few years
to get into a new life style and away from the
crass co rcialism, noise and industry of other
areas. What a shame to ruin the Maine Coast with
a heavy oil industry, air and water pollution.
More to the point, the State of Maine is so
concerned about air pollution that we Eastport
area residents must now drive a forty mile round
trip just to dump our garbage. Open burning has
been banned and our local dumps closed.
If it is true that the refinery will emit more
hazardous materials into the atmosphere than the
Eastport dump, we intend to sue to stop construction.
Thank you for your consideration and attention to
this position. In the meantime we intend to continue
the struggle to “Keep Maine Beautiful.
Very cordially yours,
award i4aiit S th,
)Lotion Picture ucar
HIIS ENTERPRISES INC. • PEMBROKE, MAINE 04666 • (207) 726.4249
218—1
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I
December 14, 76
United States Arm)’
Corps of Sngin..r.
Federal Building
RosIn, M IS s*Cl is$ttS
Centl.—w:
I appreciate sour having bald the h.sring on Dec
her 3rd in Eaatport which I was n’shls to attend de. to lbs
weather. I had to remein in Keen.bs. to kemp my boat from
btng destroyed by th. gal..
O Following_is what I wauld have said had I been there,
U speaking as a former pier supervisor at the port of Nay York
City, d as pilot at Aigsmtta, Nemfoundlands
$v.ral years s , the President of th. United States oz
dared the Ar r Corps of Engineers to study the AUasittc
coast and r.coenend to him the best Locations for oil r
fineries. One hearing on the aubj act was bald in Portland,
D i’iiigse and I appeared before It. I iugg.st.d there aheuld
be refineries near the greatest demand for the pre act with
perhaps twa or thre, discharge and isading centers along
th. coast. In their final report the Ingineers did reco.-
mend twa place., on. just south .1 Ner York City, the other
about halfway to Florida. tastport yes emnstdsr.d them and
did not nest the criteria and sheuld not, now. The coedi.
lions Pave not chmnged sine, the Portland bearing.
For over forty years I hew, operated various craft in these
waters. The entranc. to lb. Bay of Fund, is lbs foggiest
plac. in the iaorld, having held the record whem logs were
kept by lighthaus. prsonoal. In lbs r r thsr. vi ii
oft.n be heavy fog for a week or war. at a tin., Lasting
nor. than a nonth. (Between let. Jun. and August 1, 1976
it was that way 38 out of 40 days.) This is the seaaon o
the beat sac conditions. The winters to th.s. waters are
plagued with frssstasg spray *mused by high winds, and vapor
or sea senke. I Operate boat Earing these period., but
marine traffic is amen d non .adst.nt. It Li distressing
to cont lat. a vigoroul ott traffic such as wauld be ge .
wzated by the refine y at Eastport.
219—1
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Tb. tides an, just th. as stated at the Portland
hearing. .s place. it run. to liv. wiles p .r hour
in one direction while. short distance ‘ .y it run. the
opposite or on other sour., and upsed. Pm-
quoddy lay is nct.d for this as well. a. so. . of the
stzvngest tides in the world. This ames the handling of
Larg• ships diffiault and dangerous, • .ptsaUy as these
conditions prevail in very nar Head Harb.r Passage.
The .tis ships Pittston is proposing sri unttdiEabls.
(I bass this on s ertsec. with wartiws warms traf.
ftc in N , York harbor.)
I hays read the n .pse accouots of th. Lsatport
hearing and it es _ s that the foregoing was net included. If
the .n r to A.srica ’ s xgy probl is r.alLy ancthsr r
finery for iapsrtad oil, Bar Harbor of f.n. the best seessi
and port on the East coast. It is difficult to
understand why Pittston should choose iastport with all it.
Itabtilttea whco th e n. are asny other places, second only to
Q Bar Harbor, far core suitable.
Biaear.ly,
Harboxuastar
Jonesport, Main.
cc, U. S. £ivvi.1u _11Ital Protection Agcosy
BBi4 La
219—2
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Mff iRRLL& TAVN P T CO.
1031 FOREST AVENUE. PORTLAND, MAINE 04104
AREA CODE to? 75? 7th
ce er 13, 1976
‘C
nager
N Yost (Xs Office
8w,u of Lsid a a-snt
Six World Trade Cantor, Suits 6000
Nsi Y ?t, N. Y. 10048
At the Pittston finu’y hurinq in £astport en Dscsiti.r 3rd
I enclosed nas of support, end fowid en ‘ , .tu,’Il to Portlau d
that theA usis these addItional nes to bs added to our
support .
Very truly you ,
,-,I11 Trrsport Co.
P i £. FP111
Osor Sir:
PEM/bt
Enc.
SERVING NORTHERN NEW ENGLAND
220—1
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;, ,jti. ;; u • F ERY
1 Dt 197
the ‘mds’s1qi d. w o ri wo’lt%nq *ODIe and 1f intu’siUd in I utw’e
of M 1r with wui, •i 4 i ib equs t the £. *. to epi vo s th. bui dinq
t th4 raf’e - b ’ PEtt to Co iny t $ M JRGENflY S .PPORT
t4V
NIt”(
Pg
I VI4
• L
i4A w aii, 4t’(
o;c( J ll J 2 W
x h
#t/
7r¼c
£
Q 1
ADORI ‘S
/7
4i 1 c ; •-“i.--L
“- ‘, )%i .s
4a £
‘ j, t i4qd4 24M_ ’
I ( a’ , 4 ::a- ‘ ‘-
4 •
..•,
Q A /
220—2
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PIT1STOR, E TPORT FINERY
th. duni isd, dis eve ws ’ 1eg .i*1s and a ve lntsvestsd in th. futeve
of 1ns wit), ve and bsttsr jths, r t the ( P A. to appve the bui dlna
of the rsfi ry by Pit ton Cc ny at E.stanrt sins. E URCEK1LY SUPPORT
THIS PRD 1 ECT.
1lLt _ --cRd 4 L
J L
PeA4 a -
7
RVb
(
7’dL L.
7IJe .
QfB cd4ue/ 2 f. $A4
J AL 4 Wft t rw
p.
/12 -
220—3
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Ii •I III LtIU %: ‘L%LIt. , tI%ILI1
th tinhcr t f L utmme, SIuc.
W/tSIl!NCrOI! COUNTY clMiJjsi:R O CO?tIIkRCZ IKONY FOR EPA
fli;Fi : i u Y ii : U.! HG AT , #M I::E — in c niuu 3 , 1976
Fly NAME IS KEiTH RUFF.
I Alt A NATIVE OF TillS STATE AWl) HAVE WORKED AND LIVED HERE
ALL MY LiFE.
I I IAVC BEEN EMPLOYED BY THE WOODLAND U1V1 1ON O1 GEORGIA--PACIFIC
CORPO} ATIQU 1’O JUST OVER FOUR YEARS A [ ) HAVE RESIB!D IN CALAIS
SINCE JOINING GP.
II? B1 tEr TE5TZHONY TOI3AY IS ON BEHALF OF THE WASHINGTON COUIVCY
CHA1 BER or COHMEtZCE. I PRESENTLY SERVE AS PRESIDENT OF TUE
CHAI4ECR, WHICH RL1’RESENTS A WIDE VARIETY OP BUSINESS, COMMERCIAL,
IHUL’STRIAL, iU lTCIPAL AND INDIVIDUAL }IE U ERS TUROUOUOUT TUE
COUUTY. I /tIt AWARE OF ONLY TWO OF OUR NEARLY EIGHTY MEMBERS
WHO ARE NOT IN FAVOR OF UE PITTSTON KEFIGEItY PROJECT.
TIlE WASUINCTO COU31TY ChAMBER OF COMMERCE URGES THAT THE
F.NVIRONMENTAL PROTECTION AGENCY, TIlE CORPS OF ARMY EHGINEEaS.,
AND ALL OTUE t AGEUCIES INVOLVED HOVE AS QUICKLY AS POSSIBLE
TO GRANT THE NECESSARY APPROVALS SO THAT THE PITTSTON COMPANY
CAN GO FOKWA1 D WITH THIS PROJECT.
IT IS PLAIN TI AT A TREMENDOUS AHOUHT OF RESEARCU, STUDY AND
ANALYSIS HAS GONE INTO THE IMPACT STATEHEI4TS. WE SUBMIT THAT
CONSTRUCTION SHOULD NOW BE ALLOWED TO START.
‘,i i (‘/15’
WE WOULD CALL ATTENTION TO ii -T4d4 . STATEMERTS APPEARING IN
TUE CPA ENVIRONMENTAL IMPACT STATEMENT:
223.—i
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(I) TILE i?IA El, M()UIJT OF OI)OI(— r Ol)U4: I. H( EU 1:; ; tON ; ou
I; - ,)
TEL; I EF1 NEflY WOULD ILK UNDE’IiCTAflL.E 1 U COHL’AR [ SON TO
ODORS FL OII EXISTING FISh PRQCr.SSLNG I ’LAUTS IN THE
AREA. (VOL. 1 P.29), and
(2) “THE OPERATION OF TILE REFINERY REPRESENTS THE COHUITMENT
OF THE GO}LHUNITY, REGION AND STATE TO ACCEPT TIlE RISK,
IIOWEVLR_SHALL, THAT AN ACCiDENT COUI 4 L) AFFECT ALL OR
PORTIONS OF HE FISHERIES IN TUE AREA.” (VOL.1, P.40).
AS FOi TUE SOCIO—ECONOHIC IMPACT, THE DISHAL IHFORNATION
CONTAINED IN PAGES 29 TLI ItOUGQ 38 IN VOLUHE II TELLS PART
OF THE STORY.
A WASILIk ’E%OUHIY POPULATiON OF 45,000 AT THE TURN OF ThIS
CENTURY REDUCED TO ABOUT 31,000 TODAY . . .
FEWER JOBS TODAY TItAN THERE WF.NE TWENTY YEARS AGO
19Z OF WASHINGTON COUNTY FALIILIES WITH INCOIIE BELOW TUE
POVERTY LEVEL .
MEDIAN ILOUSEROLD LNCOzIE 30% BELOW THAT W THE REST OF HAINE,
AND 3fl BELOW THE NATIONAL LEVEL . .
AND MORE THAN 22 OUT OF EVERY 100 UASHIIIGTOM COUNTY RESIDENTS
ON FOOD STAMPS. .
WE ARE hEAVILY TAXED, AND THE L1O ’S SILARF. GOES TO EDUCATE
OUR CHILDREN. ONCE EDUCATED, ONLY A TINY PERCENTAGE OF OUR
YOUNG PEOPLE CAN FIND CAINPUL EMPLOYILENT IN WASHiNGTON COUNTY.
PLEASE DO NOT BE SWAYED BY THE SHALL BUT VOCAL MINORITY WHICH
WOUL J KL 1 WAsttI& CTOH COUNTY UUDERUF.VELOVED AND III A STATE OP
POV arY FOREVER. OPPONENTS OF titi: REFINERY — MANY OF WHOM
221—2
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ARE ALSO oii’u ;i:ii TO IARVE!;TIHC RI:ES U ININC PEAT, AND
COUSTZWCT I HG UT GU WAYS , DM15 , 511019’ itu; CENTELt MB) KL
TRAILS , AI’PF: \I 1’E t ECTIIY COIIFORTAIILE WITh A SELFISU
“NO—GROWTh” Pill LOSO1’HY
TillS IS HOT TILE PHILOSOPHY THAT ?IADE THIS COUNTRY GROW
AND PROSPER
TILE VASIjINCTON CC Ui TY BUS IN ESS COIHIUN ITY KNOWS TILE
BEi4EFlCIi L IUPACT THAT WORE THAN 1,000 NEW JOBS WILL
HAVE
OUR STATE, COUNT? AND LOCAL GOVERNIIENTS KNOW WHAT TREHENDOUS
ECONOHIC ilIPLOVELIENT WILL BE GENEItATED BY SEVERAL HILLIONS
OF PITISTOU TAi DOLLARS EACH YEAR . . .
HOST WASHINGTO J couar PEOPLE DESIRE — AND OUR CHILDREN
DESERVE — EVERY VIABLE OPPORTUNITY FOR ESCAPING THE QUICKSAND
OF POVERTY THAT TliRl: TEW5 TO BURY US.
AGAIh WE URGE YOUi APPROVAL OF TILE PITTSTON COHPANY PEk IlT
APPLiCaTiONS SO WASHINGTON COUNTY CAN STOP SLIJ)ING BACKWARD
AND BECIN LIOVIHC AHEAD THANK YOU.
221—3
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299.
4••.f / I( • ‘‘
township of Edmunds, Washington County. I am a sixth
generation on the farm of which i now live. My boys
who are helping me are actually of the seventh generation.
My sixth great grandmother was the first public
schoolteacher in the city or the Town of Eastport, or
whatever they called it in those days, and I suppose
Mr. Robert Bell was lucky enough to pick her off, take
her up the river, with the aid of an Indian, and there
set up what was known as the tide mill — and was shown
where to build a mill, and there lived, which we have
resided since about 1770.
As you have heard for the past few hours, th. values
in eastern Maine have become lower and lower and lower.
And I assume that this means jobs. I assume that it means
buildings. I assume that it means lands. And by assuming
this, I would assume that it should mean also the people
are feeling the same way. And when I have heard some of them
and seen some of the reactions. I cannot help but feel
that that is how they feel. But as I recall, a short
time ago I opened the Bangor Daily News, and there I saw
the re—evaluation of all the towns in Washington County.
And because Edmunds and Trescott were wi].dland townships,
222—1
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300.
our valuation of those two areas was left out. But
last week the professional assessors of the State of
Maine caught up to us, and only the day before yester-
day did they come down upon us and show us our new
evaluations, and I would like to say that those who
thi.nk that this land is going to pot, that the values
aren’t here and it is not worth a damn, are crazy as
hell or the assessors are crazy, because the values
in the wildiand townships of Prescott and Edmunds
went from $1,400,000 in the case of Trescott to $3,500,000,
and in Edmunds it was the same. And in some cases the
land changed in value from three to as high as twenty-
five times in value, and every time that it went to the
twenty—five times in value it was along the shore, along
the coast. That which would be affected by an oil spill,
that which would be affected by Quoddy. by the low tide,
the low poole that which would be affected by any part
of the environment which you see fit to change what
nature put here and the moon controls.
Now, as I have listened to the bankers, the ship-
builders, the truckers, the businessmen, the State
Chamber of Con terce, and the people that do not come
222—2
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( 9
301.
from outside of Washington County only when they can
be viewed by such an astute panel as we have here in
front of me, appear before you to speak, I begun to
wonder if we weren’t being ripped off by our own
citizenry, about as much by them as we are by Pittston
who wants to build such an atrocity-- (Applause) —-on
a place that has the God-given beauty that Moose Island
has.
Now, you heard the man from Canada say at this same
podium that out there in that channel you have things
that are nowhere else on the whole east coast or any-
where else in the world, as far as plankton, currents
and tides. I say to you, a1k up on that hill, walk
up whe:e that geodetic t’r nt is, and lcQk around you,
in
that damn ncnuxnent up
r .
these United States, I will, eat
there for you. (Applause)
Now, what you are going to do, if you approve this,
you are going to change the entire countenance of those
tides from the view of the country, the view of the
people, the love of people who like nature, the love
of people who like the sky, the love of the people who
like the water. You are going to change that not uat
222—3
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302.
for four years, for fifty years, for twenty years
you are going to change that practically forever.
Forever it has been possible to go up there and look
around over and see. I believe it was a Mr. Mitchell
from Pleasant Point who said they were against it. I
am sure that they stood there, or his ancestors stood
there, a hell of a lot longer before my sixth great-
grandmother courted my grandfather out there on those
hills and persuaded him to take her up to the pine
trees up there where I live now. And I don’t think
that that is any place for Pittston to come down here
and court Eastport and say let’s have a marriage and
build an oil mill over here and put up what you call
those oil tanks and stuff and destroy the beauty of
the only place in the whole world, the most eastern
point of land in the whole United States, the one place
that you can never replace.
You can build an oil well or an oil mill, or an oil
refinery, anywhere you want to up the coast of Maine,
but the people up there don’t want it and that is why
you can’t build it. I think you could build it by an
offshore single mooring and pipe it in without the great
222—4
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303.
dangers of this tide. Why fight all these unheard of
chances that we take? Hell, if we had fought World
War II - the only great chance we took in World War II
was when Ike sent us over there in parachutes, and I
was one of the leaders. He dropped us in, and then
we had one hell of a job to get the boys ashore in the.
boats. We took one great chance and we won.
MR. McGLENNON: Mr. Bell, are you about to conclude
your remarks?
MR. BELL: And I don’t think that we can afford to
take chances like that day in and day out just to please
the people to make money, and the economy of this area
or any other area in this country, when we know that
the time is running out n that kind of a conmiodity
like oil and we have got go lc king for another. I
am one who is convinced that if we have managed to
squander and refine all the oil there has been in the
world up until this time with what we have, and we only
have 25 years left, by God we can do the rest o f it
with what we got. (Applause)
MR. McGLENNON: Thank you, Mr. Bell.
MR. BELL: Thank you.
222—5
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7979
Crows *.ck
Lubec, Maine
0 +6 2
Dec enber 1976
vnnign t /rc t ec t c A g
ore emen
JJ.I. Building
Boston, )ias .. 02203
He N.?.D.L5 . Permit # MEO022 42O
Greetings:
The following is the text of my testimony late Friday ev ing
Deceeber 3, 1976 at the public hearing in sstport 1 n reviewing
th. draft of the Environmental pact Statent. £ submit this
letter to register my protest age.inst th. proposed pla ns by the
Pittston Company of New York for an oil ref inry to be established
In the deep water port of Eastport, Maine.
My name is Ruth Merrill. I em an ‘1 entary school teec her,
living in !rescott across the water from this proposed well—screened
refinery. 1 have recently moved froTnidaho where this summer several
govt ent agencies were involvd in a tragic miscalculation regarding
a much contested earth 4i 11ed dam wbich collasped shortly after being
filled to capacity in less than twenty-tour hours with a consequence
of severe loss of life and valuable farmland and livestock. 1 bring
up this tragic event not in m 1 1r • but to eaphasize the absurd bi Inn
trust the people in the Eastport business community appear to have
In a corporation such as Pittston to i.*i ritain and protect the quality
of life now existing in the Eastport area.. What needs to be ccnsid—
erel are the two sides of a scale — on one side is the protection of
the existing quality of life which is inmeasurable and on the ctb.er
side are some few hu rM ‘permanent’ jobs for carpenters, laborers,
etc., a few odd jobs for en as secretaries and the iumiediate yet
teaporary ld mine tc i effect on Eaatport. P erhaps to get a cláarer
perspective, included in the impact statenent should be th. estimated
tak, home monthly pay of Pittston corporate members.-
hy main concern revolves around the effect and impact of this
proposed refinery on this particulan ’ area around Eastpcrt. 1 am act
here toi ig t to argue against the need for an oil refinery, being
such a te!nporary stall, for energy demands or for an economic boost
to the New EnglRnd area. ow.ver, while reading the & A’ s imtact
draft I tried to reaflstic..3.]y weigh concerns of my consci ees
with the need for emplqymeit and a tax base increase in the depressed
ecomomy or Washington county. 1 have tried to ba1 ce the tren oUs
poaure to the biological .co systns such as the daA y ba fui.
223— ].
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(2)
concentrations of petroleum by—products Introduced into the marine
wwircn ent, the inevitable tragic eflect of an oil spill, and con-
sequent disastrous effect on the fishing industries and sattalite
businesses, the stated impact on the noise and air quality of this
realitively untouched area, the dangers introduced by the unusual
conditions of fog and current In these waters, and the social 1mph—
cations of a large outside temporary, and I want to emphasize temporary
population influx on &stport in such areas as schools, health car. “
and the economic gap after the larg. percentage of the crew involved
in construction of the refinery pulls out and goes home. Although
sympathizing and feeling the pressures myself of the depressed econ-.
omy of Eastport, all the surrounding co unit1es are depressed
economica* and we can find other saf.r, more dp.ndabl. and less
environment&lly hazardous solutions. I firmly convinced that
we cannot gamble our inherited girt, the luxury of purity in this
unique ar’ cn th dangers of the pittston oil refinery. 7 Aa 1 j k you
for th. opportunity to express my concerns — individuals often feel
hcpel•ss against the powers and monies of big business.
I ith )IzrjlL
223—2
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. . LuuK: Gentlemen, my name is Robert Peacock.
I am a lifelong resident of Lubec and a seaman. t
the present time I am on vacation from the Sun Oil
Company where I sail as chief mate aboard their tankers.
I hold a Master’s License from the Coast Guard, &: d
I hold pilotage for Eastport Harbor, Head Harbo: Passage
and Friar Roads from the Coast Guard. This is all on
limited tonnage. I piloted vessels from 30.000 to 80,000
DWT on the Delaware River and the Great Lakes. I also
hold pilotage for the Neches River in Texas and Puerto
de Abicoa in Puerto Rico, and the Sabean River in Texas.
I am Vice President of R. J. Peacock Canning Company
in Lubec and I assist my father in the sardine canning
224—1
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308.
business wh*n I em home on vacation.
I have a vital interest in the economy of this area
and in the environment of this area. Anywhere my tanker
is operating I try my best to make sure that we have
no oil. epills, and in the past years I have handled
close to a billion gallons of oil, a billion gallons,
and I hav, had no spill, not one drop, and nobody on
my ship has had a spill while I have been chief mate
on that ship. I car, about th. quality of the water
and th. quality of th. work that our company does, and
I do my best to make sure that it is as safe as possible.
I have watched with interest the proposal. and
hearings pertaining to Pittston’s application. I have
studied the Environmental Impact Statement, and I have
studied the findings of Dr. Eda àf Stevens Institute
as to the handling of the tankers in the Head Harbor
Passage. From these studies, and from my personal
experience at w.l1. over 100 refineries and terminals
throughout th. world, I conclude that the marine terminal
and the tanker operations can be safely and efficiently
run in Eastport.
I wish to add that my company v*sssls have b.en
224—2
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c9
309.
chartered out to Pittston subsidiaries on several
occasions. I have dealt with Pittston Marine and with
Metropolitan Oil on day-to—day oil transfer operations,
and I have been impressed by their concern for pollution
and cargo quality. Any company can set company pollution
standards in a board room, but it is the barge man, the
tanker man, the dock watchman, or the mate on watch on
the tankers who turn the valves and who are ultimately
responsible for moat oil spills. Pittston’s operating
personnel on the low level, right down on the barge
level and the dock level, seem to be more aware of their
responsibilities concerning pollution than most companies.
I have made 37 voyages in the last five years to
Puerto de Abicoa of Puerto Rico where a situation which
has certain similarities to Eastport exists. de Abicoa
was depressed economically, with high unemployment, and
had a fishing and agricultural economy in a rural setting
with similar population levels to Eastport. The town
haS beautiful beaches and a new resort called Palmas del
Mar is being developed less than five miles away. The
Sun Company built a 65,000 barrel per day refinery in
1970, and spent over 150 million dollars investment in
224—3
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310.
just pollution equipment at that refinery. As of last
August, all but 12 of the nearly 200 employees were
Puerto Rican. with most being from the local area of
de Abicoa. The refinery is immaculate with no visible
air or water pollution. We swim 50 feet from the
docked tanker. We fish off the tanker, we eat those
fish, and generally enjoy running to de Abicoa more
than most other ports. Clean air, clean water, good
fishing, farming on the refinery property, local employ-
ment, and little effect on the local area other than
a higher standard of living for most; this is a good
example of what a refinery can be. But I know also,
from running to Marcus Hook, New York, New Jersey. and
Philadelphia. what a poor neighbor refineries can be,
and also tankers.
I sincerely hope that if you do see fit to grant
Pittston their permit based on the merits of the situ-
ation, you will make those permits at least as specific
and as tough as Puerto Rico did for Sun Oil. Company in
de Abicoa. If you do issue strict permits and insure
that Pittston adheres to those requir ents. I do not
think that the government, its agencies you gentllMn
224—4
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311.
personally, and especially the local people, will
regret having a refinery and its supporting marine
operations as a neighbor.
I agree wholeheartedly with Captain Kennedy’s
recommendations. He is an acknowledged expert and a
fine seaman with an excellent reputation in the United
States Merchant Marine. He is far more knowledgeable
than I in VLCC operations.
There is one other point I wish to make. The State
DEP has given conditionalapproval to the refinery.
You gentlemen represent federal approval or disapproval
of the refinery. If you grant the permits, then I
strongly believe that the local population should be
allowed to av a direct say as to having their way of
life cha’m ’ed. I suppcrt the refinery, but I believe
that both Washington County and the local area of
Charlotte County in Canada should be allowed to vote
on the merits of the proposal. There is enough infor-
mation available to make an intelligent decision.
Thank you.
! MeG TENNONL: Thank you, Mr. Peacock.
The next speaker is Mr. Richard-Eaton.. Aft e him,
224—5
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U 6 RAMSO(LL
.0.t .? p p(p 0Cr P 0(H JOHN 0 T0FT WSCL ØtOtN? LPO’V WAR N. T ASU IP
— ----
( çççLc tsLç
2C 1 ,
FACTORIES .T
LUBEC
TjI.EPI4OP* tu C
A A COOP 207 713-15S4
04 552
November 23, 1976
Mr. William Stickney
United States Environmental Protection Agency
Region I
John F. Kennedy Building
Boston, Mass. 02203
Dear Mr. Stickney:
Due to previous engagements I will be unable to attend the bearings
of the Pittston Company in Bastport the first part of December.
As you know our Company is a pack.r of Maine sardines so we a e
very, very interested in the impact that any new industry might
have on the area .nvi ropmen tally and otherwise.
When I first heard of this I started traveling all over the country
just looking at refineries and finding out what some of th.ir problems
were • For instance I have been on the Delaware River and through the
New York area, along the Sabean River in Texas, all through the
Gulf of Mexico, to every refinery in Purth Rico, and two refineries
on St. Croix Island in the Caribbean. I have also had the opportunity
to make a trip on one of the small supertankers (83,000 tons) and
watched them maneuver in extremely close quart.rs -— not over 150 feet
cn i her side in a channel and I have corns up with the following
conclusions.
If a refinery is built in the Baatport area and it adheres to the
environmental requirements when it is built the impact on the area
should be good for Washington County. After traveling on the tankers
and talking with several eupertanker Captains I have come to the
or !lusion that the channel up by Campobello Island will be no problem
whatsoever. An far as our own industry is concerned the sardine industry
should show no effect whatsoever except possibly there m ght be a labor
shortage during the construction period.
op
LJ
CANNCRS SJID DCAL.ERS IN
225—1
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y. William Stickney
U it•d States Environmental Protection Agency
Region I
John F. Xenn.dy Building
Boston, Mass. 02203
Looking at the worst asp.ct which might be a spill I would lik, to
aay that, after th. tanker AR sank, the next winter we r.ceiv.d
many of our fish from within 1/2 au. of the ship after it had sunk
and th. fish were perfectly normal.
gain, after all of th.se factors hav, been iook.d into, we feel
that the economic impact on Washington County and surrounding areas
yin offset any risk that may be incurred.
If we can furnish any further information please do not hesitate
to call U..
Yours very truly,
k. J • PI W P 1 G
RSP:ni
225—2
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315.
MS. OTIS: Good evening. My name is Meg Otis, and
I am a weaver and live in Perry.
One of the first things I would like to address is
the availability of the draft Environmental Impact
Statement. There were precious few available. They
were scarce as hen’s teeth really, and I think when
the final one comes out, if there was some way of
distributing them so more people could have access to
them, I think that would be wise.
Living in Perry. I have two concerns: one is the
water source, fresh water source being Boyden Lake.
I have talked to George Peters, who is the Manager of
the Eastport Water Company, and have assurances that
there is an adequate water supply, but I feel there
has not been enough recorded as far as actual infor-
mation such as flowage and what might happen, like a
contingency plan, in case we have a particularly open
winter where there is not much snow, and therefore not
much runoff, and then followed by a dry sunnner. I
would like to see some figures on that, possibly having
a meter to find out how much water actually flows from
the lake, if this could be included possibly in the
226—1
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316.
final impact statement.
The other is the effect on Perry of the influx of
extra people,, students, and on the other resources of
the town, and the effect after the basic work force
has left, because this will mean the townspeople will
be left to pay off the bonds. So this is something I
would like a fuller explanation of.
And then something I would just like to mention:
there is a very distinct possibility of the boat school
moving from Lubec to Eastport , and I see that as a
very positive thing, bringing with it not only the boat
school but quite an enlarged program to include a whole
line of fishery subjects. I can see this being an
impetus for a whole new rejuvenation of Ea tp rt and
a spirit and an initiative that it once had at the turn
of the century to become a small port again. And this,
to me, utilizes the people in the area to its fullest.
Something else I would like information on is how
Pittston is financing the refinery. I have heard
rumors that it is foreign money, possibly even coming
from the Middle East, which makes it very diff cult
for me to believe the statement in the draft EIS that
226—2
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317.
states that having this refinery will make us independent
and increase our national security in case of another
oil embargo. I see a contradiction if the oil refinery
is being paid for possibly by one of these countries
and if the oil is coming from these countries. To me
that is irrational, it doesn’t quite fit.
The other thing is the apparent corporate arrogance
of Pittston to have these hearings over the objection
of the Canadian Government. To me, thia hearing is a
farce, and everything before it. because of the stated
opinion of the Canadian Government that they are opposed.
I think if the oil refinery does come in. we will have
earned the enmity of a large proportion of Canadians.
and I see the advent or the coming in of the boat school
as being something tha cQuld draw people in this area
together and once again make it into a lively and viable
area.
226—3
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b1. 1ji . beafjaa. pse fiii • .t3 .a as 1 doer , s . Jot liv .. in
th. aiddla of las Task City or *is tos, D 1 C. The.. pssp2. M uasi t a dos’t
1jIj in l ttos. % at skoot yos? *at absot tks root of ths resident. of .t.i.
aai *tcs C..AtYt • abat or. ,.ttisg In vetoan far . sa l .. St say health and p.... ?
yo $sttia 500 sss.tveatios s or. fir you (for ‘ 4i. . thor. t. nd.isat. ho.ain
sq. the r.pmrt). lb a ,. gsi t. 2 ... the lit@e so . left .f ftibias indutry
. 1k. poenikilitis. St t rsvasost 1k ilk. M1WsaI S. Jo .. f . . that
so —. to3d o portia ‘.spçsrttv. wlas’ i.ik • 1 l.sv. It to jas to leagim. t
1hs..J.b.vl31b . Mf , Istat.tslho.steks.. t.art.f3*Xsssd .
espilsi to invest 1* a bosh.. that soald be and I as _ that th. bs
—. sat 11k517 to to $ n. nith $ ills szps staa of yssas.
sWeet .1 stpsrt iU.b. $ )at of bir, bs * . - a gs p s.
.ssvly so . to 1.. . $ it lit, that is s w . and pree&asa. lb laIn St
liE of ity of 1k. ash bet ti st t\lfl 1’1.eeS to t p1.... Ia
so ia r.1ativl fl’se of t it biws t. lb still M . i- ‘
a rslatiniEip . to look t 14.01. * — a v.it i .,siat oe.r abot
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1k. rs. Jos i fss 21i dl.uasr abe hw that if *0 to
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227—2
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PW1 ’ Th o?th rv *t of tb . Pitt srton fir,r , t that
“ bOT,o? ’.iC fry. Lo t is rw e.-ssary if’ ‘tnrton ‘.‘urt’ is te sur’” - .“
tartir. th rsrtrntr..’ o t!ust .-rtsne’- ot c’ic rr -. , tI ; frJ’! 7
‘ jot, kO. . ) € 4 I o *t C + L C I4 CObii. fr.i•C i -t4 4i t
-iiy ‘L it .. —J. a ! .1ar5t ‘ r’ a ‘ i ‘-u. _ t&a ’w ’ rs
that arr irr ‘ci ? : hay. c a1ts ’r tho a’n zkLUs thr ‘ii— ‘ir!g
ignoy’d as apot. ntial aouee of .eonorie r v-.Lpn . ’ . nt . ‘h - 1—- .
it. .‘r F 1 - ra a— it. ‘- *z ” t4 i” +% qS •D t - . ...‘ •h
eraftr n r . in fact sr.aj L ranutactur rs. siJ. r —
r’rativr 1 ’-vst rr tb - ‘T orr’ rt 1 rs’l i:. tii.iv ’tle’r c -s jj Ii j. !—
‘xt i’” -.t ’rAa.L s v k.( £ I ;].i:. of ‘artt I t . r -t j’-. -. r
but Labor tht,r.tv...
If as b-or o .r ow e .r that thu , s, Wisoi’ a . e pt +hia r to for cob,—
p -o$ idil b- le to wr t I a 1 natam oty— tlwro sr a rrat i bitt.-r
ys to spar . a bait btlllon .‘sUarö. bxs that wool.’ •-;.i c ’ ru-at ‘ ‘r p ’ cole
then tb. flf) rytM.&L jobs this proj.t po, -ij.’ s.
In Tactl Z. “ot talkini ab.*t •&,i!r-tur COIU’17 at 1I , - *r. tii ’irr about
‘bq,’,el’sa. If the an’er 4 vwss i r rt a r . -f’Ir ry t ” .‘-.‘Jv- b&w . t -‘i4J.t tr
are-or,tb’ . irr’ .L•so ’ tu - ,r ‘‘ ‘ -‘, -r -- ’ r ’r
t1 i .i tha :‘iP” -n 4 ,cr qj’ . ‘i- P - t ‘ ‘ sr” -‘ “‘ ‘ ‘ ‘4
cf .aatr’ ton (t ’ rt,-..r. ti --v thr ci . s t r’!r.- e to ‘ ‘ 1—? c, t ‘ er -ct. ..
They i er’t iart it. Th.y’e uoit. too er’ rr . too t’ o’ist tr. ae the- ‘1 p ’
pharpiter vith a bo” t *t . ..lcr . roar ’ .-is. as si --’ -t’- a
a.-!pMiIr rv L— - o ’ - . i. ’ r• • tb -‘.r. tI . -r rj.—t.; th . .‘ - cJ jv
•.Ii- uhet roar- ‘-in w . ‘ - •• •- + j t - e” o-y -“r
t oboold at l a.at hay .- the cb.io.. Ipt ‘‘-eL” via e Ios r f -r’ , “— , vhet 1
riaht .r a ror or us.
Is for aurytial, the survival of i uhipwton County. Thi * r ’r.ry viii kill us. t”troy
us eorp . -t 17 , j ‘-‘It ” -- oci .ty, norrunity. the lit. sty.fr : • t wiLl he,
. estroyc . ’ for ”w’r. Lii of ‘.y . iepii toariso. r’tiy’-, rt eor ’triti’- a, fidtip,w,
aquacultur. • “•stroyu- by 0 jj eug bartc acid s& rr.rd. ¶hr. is no pi. in the sky an—
PS for us,, v%atrv.r w tao )p. u- vill take hay .4 k a n ’ 4 p.rststaw’e but *t 4e—
5. PP-ire OUF OUfl “ire et ion an’ iboujit be the oars to r.rofit, not pittston.
227—3
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4.—’
‘.1 4
‘ ‘ - —
:.._.
IIol 1 mEs Pnc1 In6 Coiiponn’rion
itic*aI. MANAGIN TEL 853 2932 AREA 207
P. 0. BOX K
ERSTP0RT,mRInE n’ic:it
December 3, 1976
13. S. ENVIRONMENTAL PROTECTION AGENCY AND THE U. S.
ARMY CORPS OF ENGINEERS PUBLIC HEARING AT EASTPORT,
MAUTE, DECEMBER 3, 1976, 1:00 P. M. ON Prr’rsToN COMPANY’S
PROPOSAL FOR AN OIL REFINERY AT EASTPORT, MAINE
My name is Mrs. Barbara Galen. Mr. Moses B. Pike, who is the
Treasurer arid the General Manager of Holmes Packing Corporation,
was unable to be here because of other business commitments. I have
been asked to read his statement.
My name is Moses B. Pike. I am Treasurer and General
Manager of Holmes Packing Corporation which operates two
sardine factories, one in Eastport and one in Rockland, Maine.
I have had no experience with oil refineries, but there
has been a yreat deal of talk about the devastating effect of an
oil spill upon the supply of sardines. There is one tanker disaster
with which I have had some experience. The 11,379 ton tanker,
Arrow, was lost in February 1970 in Chedabucto Bay, Nova Scotia.
The “Arrow’ t had a cargo of 3. 8 million gallons of Bunker C
Oil when it was wrecked. One point three (1. 3) million gallons
were salvaged. The balance of 2. b millIon gallons were spiUeU in
Uie Bay. A year later it was difficult to see that the beaches had
ever been contaminated with the oil.
V 4
Foods
228—1
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—2— Docontbcr 3, 1970
however, my interest In this spill, as a fish packer, lies
in the vast difference between the widely advertised, imminent
damage to the fisheries and the actuality.
The Canadian Magazine, Sea Harvest , for April/May 1970,
written shortly after the wreck, stated:
(Quote) “It has threatened to ruin some of the Nova Scotia
fishing grounds, beaches, harbors, and wildlife.
Consequences are such that It will most likely take
years to recover. If this fishery Is ruined, It may
take a litetimel”
(Unquote)
The foregoing was the projected damage. Now as to the
actual fishing situation. A year after the wreck, from January 1
through April 12, 1971, Holmes Packing Corporation obtained
from Chedabucto Bay some 1,771 tons of sardines. We were
only one of a dozen American and Canadian factories drawing
from this area at this time. Instead of the fishery being destroyed,
It was the most fish ever caught in that bay In one season.
We have had more recent oil spills, and nearer to Eastport,
since the one at Chedabucto. There was one at St. John, New
Brunswick, in 1974, and also one at the same port In June of this
ye .r. The quantity of oil lost thIs year was not accurately given,
hut the incident received great publicity. The rogross of the
spill was followed, as the Fundy Currents brought the oil from
St. John to Quoddy. The oil duly arrived and messed up some
228—2
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December 3, 1976
beaches and fishing gear. However, moans of coping with
this sort of thimj have been greatly improved and the debris
was cleaned up.
The interest of Holmes Packing Corporation in this spill
was the effect upon the fisheries. In the summers of 1975 and
of 1976, we had two of the largest and the best catches of sardines
that we have ever had in this area.
We have cited these two incidents to indicate why this
company is not unduly concerned about the effect upon our fish
supply of the coming of an oil refinery to Eastport.
We employ in Eastport a maximum of 150 people and we
believe we will be able to get an adequate supply of help even
during the construction period.
In a broader sense, however, we welcome an oil refinery
here in Eastport, as it should enable more of our young people to
find work and to make their homes In this community.
228—3
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‘1i LAYLWARD: entlemen, my name is Aylward. I am
-
a real estate broker from Lincoln, Maine. and have been
since 1956. I also am a property owner in Eastport.
Maine. I have seen the fishing industry and sardine
canneries gradually go down hill due to the lack of
fish, the textile mill go up and down due to market
conditions, until you can truthfully say Eastport has
nothing but a minute percentage of overall employment
that is dependable. This creates the problems of low
229—1
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c 9
330.
wages. high unemployment, and very little incentive
for the young to remain in their current surroundings.
My educated guess is that the largest employer in
Eastport consistently is the Unemployment Commission
of the State of Maine.
I have also been involved in a non-profit development
group in Lincoln, Maine for the past twelve years who
have put a paper mill in business, a shoe factory in
business, and a worsted mill in business. We as a group
have sent over these years literally thousands of
brochures to prospective manufacturers and made hundreds
of contacts and telephone calls to prospects. I am
here to tell you that to get a heavy capital investment
industry to even consider the State of Maine is a feat
in itself. We are far from the a ketp1 :e , we offer
few incentives, taxwise we have high sales taxes, state
income taxes, and a small population to support our ever
increasing state budget. The industries who seek out
Maine primarily are those looking for inexpensive labor,
cheap leases on vacant buildings. of which we have many,
or a large unemployed labor force.
A project such as an oil refinery represents a
229—2
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331.
tremendous investment in dollars and cents per job.
The refinery being considered represents an investment
of upwards to 700 million dollars, with a projected
cost in labor of 20 to 30 million dollars over the
building span, with an estimated employment of 300
direct jobs and some 200 more in contractual services,
and the additional factor of for every job you create
you create part of a job for the oil. man, th. gas man,
the water company, the garage, the plumber, and so on.
Let us now consider a part of the project that no
one knows. How much sales tax does a multi-million
dollar manufacturer spend per year just to purchase
the necessities to manufacture their product? How many
industries may be interested in locating close by. or
even in New England, because of oil supplies that may
not be any cheaper but at least are there? Remember
it was only a few months ago that two of Maine’s largest
firms, Great Northern Paper and Georgia-Pacific. were
within days of shutting down due to lack of oil. Their
supplier - Canadian.
I would remark that, to the beet of my knowledge. this
is either the largest or one of the largest single
229—3
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332.
opportunities for an investor in the Stat• of Maine.
To the best of my knowledge, I don ‘t think anybody
has made this kind of an investment or offered to
with private enterprise.
I would remark in closing that there remains the
fear of oil spills. In my youth I was a merchant
marine officer. Going to New York through Hell’s Gate
was always an experience you didn’ t particularly care
for, the river in Antwerp was another very bad paslage,
and there are numerous others, however, expert pilots
have been putting ships through both passages with
very few problems for centuries, as they will in Eaatport.
If the weather remains unfavorable, the pilot may elect
to stay in the Hook for a day or more until the weather
is favorable. He has that authority.
We also have a refinery in this same bay, Canadian,
that we have no control over and none of the, pluses that
come from big industry.
I would also like to mention Quoddy. The Quoddy Tidal
Project has been studied for some 40 years. Nothing has
ever come of it and I doubt if anything ever will.
I thank you for your time.
229—4
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i_:.2 iiy ci t cL.L LL iu.’Lv.; . I C ti. t4.
ov Au j; I. iL 4 11 k; 1IU11,U4
4:. , ct; :. .;A Ic . u;.1.&. A L—:1 J, . 1976,
1L4, .t àLA JJ 1 . a & . i. J . AUiCZ UI. !. s ILsi . .
I .ould Uko to i.iakc juet a tots cor nto ‘h.tch i1U bo win
bnlaf and to the point. A .a a orkLn n Ond n opokow. .an for
ortinj r. n, 1 an concernol c bout thrco thin ;c. dioso ru $
dcoant Job,, a dc :cnt ctund rd of livin ; and a pod onYir rnient.
..&th the b aina and $ .onoy available in thifl cotu.try .1 u i couv inecd
o can havn cit thr’c3 of th.
PU re Lppre Qh.tn a very cniticci tino in ..ow .3* lan . o
need Job3. ..o nccd oiL l 1 or our homcc. tor trzisu -iortatton, tow
present nd fti urc f: ctQ$ .eu and lcctzLc prser. . 0XaO pvoplc uivs
r 4s public a ttt:.;3n that i l AntLnox’io d;n’ t M’On & any jabe.
in a totr.3.ly fctr’c a ,e livin.. proof Jo er iaa
tiat bw bui. .t Ut i.u Jnorà.ou are ivit , procpcrUj
a d jobs.
let’s f..ac it. Our t,oU*ro, our otandard of livir dspond
on 3obn ar d Jab: ara reis .t;d to .ner y and ita 0*. It 1. tIy
Co fl r’ n :. tar äU ucod in .ew lcnd to be refined in es
‘.0 ehould not depcnd on 0 there h* r.de of Lloo at to. rs oil
for our In thia u_u at space the tcchn3l c.rtoLsil oziat.
ror cie i c iio rodtmtton end rottn1n of oil I s lit’s e1
on wit . thc job.
230 .-i
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] ry, t1fle
De c ib :f
gr. John I4cG].ennan
Roi jOflal A(Lt::ifli t1’a(Or
U. 3. •;nviroiuicnta)• rrotcction AL cncy
Rc(,iofl 1
Boston, Iascachusetts 02203
Dear I•:r. I cGlcnnan:
I have livc in the i ast iort area all ny life. I have s cnt.
all my life Iishinj; fror.’i I astport, iith t1 e exception of five years
with the UniLccl States Coast Guard. 1 y Lather and his family also
made their living by fishing for herring from this area. I am
about the only fisherins in z stport who earns his living b ’
fishing on a full-time basis.
For the .ast several years, there has been talk of The Pittston
•Com ariy locating a rciincry in ? astport and the ert i of all fishing
in the area as a result. It seems to me that the oil refinery and
the fishing in this area, such as it is, an live together.
I have read some of the report concerning the impact of the
refinery on the area. It seeinato me that i givea the impression
that fishing is a major source of income. To me this is false. The
report is &reatly exaggerated in all the estimates in regard to the
fisheries. As I have already stateci, I believe I an the only full—
tirw fisheriian. in the Eastport—Perry area.
The fishing that I do and that is done in.this area is not
only In Paesthnaquoddy Bay, Cobscook Bay, Head Harbour Passage or
around iaatport itseLf. There are a limited number of weira in the
area, but the major fishing grounds run the whole length of Fundy
Bay and along the coast of Maine. I have fished as far south as
Massachusetts.
232—1
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—2—
Your report indicatoo that oil can ho bad for ‘Urn- £irthi uj. My
vcr onal experience dooc not boar this out. Following the opiU
Chcdabucto Bay a few years ago fichorman experienced some of the.
boat hcrrin.- fi hing ever right in the Bay where the spill took
place. In 1974, oil from the St. John, New Brunswick spill drifted
into the area of our five fish weirs. The two weire which had the most
oil caught the most fish that year, so oil hac never bothered the
woir fishing. This sum, er, one of the tankers at St. John spilled some
oil that reached Deer Island and Perry- ast ort area and again fishing
has been exceLtionai good. It should be noted that oil will not hurt
the nets on fish wcirs as we treat our nets in a solution of tar and
savosol, which are by products of oil.
I would like also to point out to you that there are no
lobster or crab fishermen in -the i astport arca who are catching
lobstora or crabs on a full—time basis. The fact is there are no
lobsters around astport. There is some clamming done in Cobscook
Bay, but tife beds around Eastport are alrea y closed because of raw
sewerage ollution. Again, no one that I am aware of clams for a
living. The clam factory that used to be located in Perry burned
down this year and was not rebuilt.
Also, it may be of interest -to you that the sardines which I
catch are very rarely brought to EastporVs one factory for ;roccssing.
‘I often sell them farther down the coast in places like Prospect
Harbor and Rockland. You should also know that, diapite what the re-
port indicate3, all fish packing is done with fresh water, and the
only calt water uaod i to pump the fish from the boats to the factory.
I am unable to see, if there is oil on the water, bow this will affect
the fish. The intakes that are u od to got the oea water for pumping
232—2
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—3-.
into th. frv tory ari aiwayn ncveral feet bn).ow tho ).nvol of the
water and oil always float.ø on surface.
As to the treacherous currents and large whirlpools in
this nrea, Iicj have been played up in the newspaper3 and
tourists’ attraction pazii hlets to attract tourists to the area
and these have been greatly exaggerated. I have, un my fishing
vessel loac ed ;ith fisI end scalc through these no called
treacherous currents and whirlpools for years, at ‘times, my
decks awash, but nsver have I lost a fish or scale off the deck.
On the average of twice a week the Irving Oil Company of
St. John, Hew Brunswicl: sends a tug and barge loaded with oil
through these so ca1ie treacherous currents and whirlpools. The
tug tows the barge at least 1,000 feet behind it and they have
never had any trouble navigating the area.
Another t1 ing is the fog. If I fished only in Head Harbour
Passage, ast,ort— erry area, I would never have installed a
radar. The fog never sets in as fast as it is reported. When
you see the fog bani: in Grand Nanan Channel you have plenty of
time to navigate fron Head Harbour to Eactport or Eastport to
the Perry Shore before the fog can catch up to you.
Thank ynu.
,._•.. • •
I’iayhard C • Morrison
232—3
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MR. CHAIRMAN, MEMBERS OP THE BOARDI 1
NY NAME 13° CHARLES DAVIS, A NATiVE OP EASTPORT WHO HAS WORKED AT THE LOCAL
POST OFFICE FOR THE PAST 2t YEARS. IN THAT TIME THE POPULATION HERE HAS
DECREASED BY OVER 1000 PEOPLE. LIKEWISE, IN THAT SPAN WE HAVE SEEN THE
DEMISE OF SEVERAL BUSINESSES, LARGE AND SMALL, INCLUDING INDUSTRIES, RETAIL
STORES, HOTELS, RECREATIONAL FACILITIES, AND SO FORTH. THIS, OF COU .SE,
HAS HAD A NEGATIVE EFFECT AT OUR POST OFFICE. NATURALLY, THE AMOUNT OF
MAIL HANDLED TODAY IS FAR LESS THAN IT. WAS TWO DECADES AGO, AND THE WORK
FORCE HAS DECLINED ACCORDINGLY,
HOW MANY OF US FONDLY REMEMBER THE SO-CALLED GOOD OLD QUODDY DAYS OF THE
MID-3D’S? WHAT A BUSTLINO COMMUNITY THIS WAS...PLENTY OF WORK...THE PEOPLE
EXUDING CONFIDENCE THAT A BRIGHT FUTURE WAS SURELY ON THE HORIZON...HOW
HAPPY WE ALL COULD BE IF A SIMILAR BOOM RE -OCCURED.
SEVERAL TIMES MONTHLY A TUG CAN BE VIEWED ENTERING READ HARBOR CHANNEL TOW-
ING BERING IT - AT APPROXIMATELY ¼ OF A NILE - AU OIL BARGE ON ITS WAY UP
THE ST. CROIX RIVER TO ITS TERMINAL AT ST. STEPHEN, N.B.
EXCEPT FOR THE PRESENT CONTROVERSY, THIS WOULD BE OF LITTLE CONSEQUENCE...
BECAUSE SINCE SAMUEL DR CHAMPLAIN EXPLORED TiLE PASSAMAQUODDY BAY REOION Is
THE EARLY 1600’s - AND PERHAPS EVEN CENTURIES BEFORE - SHIPS OP ALL SIZES,
SHAPES AND DESCRIPTIONS - EVEN THE LARGEST WARSHIPS - TRAVERSED IN AND OUT
OF HEAD HARBOR CHANNEL.. . .ThIS, MIND YOU, IN THE FOULEST OP WEATHER CONDIT-
IOUS, THROUGHOUT ALL SEASON3 OP THE YEAR. • .AND, CERTAINLY BEFORE THE ADVENT
OF RADAR AND ALL THE OTHER MODERN TECHNOLOGICAL NAVIGATIONAL AIDS.
DURING MOST OP THE 19th CENTURY, AND RIGHT UP TO THE GREAT DEPRESSION,
EASTPORT WAS 05 (0 ? THE BUSIEST SEAPORTS ON THE ATLANTIC COAST, RIVALING
CITiES FAR GREATER IN POPULATION. THIS HARBOR ACCOMMODATED VESSELS WHOSE
PORTS OF CALL TOUCHED ALL CORNERS OP THE GLOBE. AS WELL AS PASSENGER AND
CARGO SHIPS WHiCH STOPPED HERE REGULARLY ON A DAILY OR SEVERAL TIMES—A—
WEEK SCHEDULE.
233—].
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2
WiTH ALL THIS TaAWIC, ALONG WITH HUNDREDS OF SMALL BOATS, INCLUDING
FREIGHTERS, PASSENGER AND FISHING CRAFT, ONE IS HARD PRESSED TO RECALL A
COLLISION OR THE GROUNDING OP A LARGE SHIP IN ANY OP THE NEARBY WATERS...
GREAT CREDIT MUST BE PAID TO THESE SHIP’S MASTERS OF YESTERYEAR...
HOWEVER, THE EDUCATION, KNOWLEDGE AND EXPERIENCE REQUIRED TO OBTAIN A
CAPTAiN’S LICENSE TODAY IS PARTICULARLY RIGID AND DIFFICULT - NECESSARILY
SO. WITH ALL THIS ABILITY, PLUS THE ADDED ELECTRONIC GUIDANCE SYSTEMS,
SHOULD ALLOW THE LARGEST OF MODERN DAY TANKERS AND OTHER SHIPS TO SAFELY
ENTER AND EXIT PASSAMAQUODDY BAY TO THEIR PROPOSED BERTHS.
THERE IS NOW A VITAL AWARENESS OF THE DANGERS TO OUR ENVIRONMENT. BUT
BECAUSE OF PRESENT - AND CONTINUING CONTROLS, RESTRICTIONS AND REGULATIONS
BY FEDERAL, STATE AND LOCAL GOVERNMENTS - A NEW INDUSTRY WOULD BE REQUIRED
TO INSTALL AND MAINTAIN THE LATEST AND MOST EFFICIENT ANTI-POLUTION DEVISES
AND EQUIPMENT.
MANY OPPONENTS OF AN OIL REFINERY ARE OF THE OPINION THAT IF ONE IS FOR OIL,
THAT PERSON IS ALSO PRO POL.LUTION...NOTHING COULD BE FURTHER PROM THE TRUTH.
NOT A SINGLE INHABITANT WISHES THE ECOLOGY OR THE ENVIRONMENT DAMAGED...WE
DO NOT WANT ANY INFRINGEMENT ON MARINE LIFE OR THOSE WHO DERIVE THEIR LIVE-
LIHOOD FROM THE SEA. BUT WE DO WANT JOBS PAYING DECENT WAGES, AND A STAND-
ARD OF LIVING COMPARABLE TO MOST OTHER AREAS OF OUR COUNTRY.
AMONG MANY OTHER CONTRiBUTING FACTORS IS THE iNESTIMABLE HELP SUCH A COMPLEX
OF THIS MAGNITUDE WOULD MEAN TO OUR TAX STRUCTURE, ALONG WITH MANY ALLIED
INDUSTRIES AND ENTERPRISES ACCRUING THIS PROPOSAL.
AS YOU CAN WELL IMAGINE - YES, I AM AN AVOWED PROPONENT FOR THE ESTABLISH-
MENT OF AN OIL REFINERY IN THE EASTPORT AREA...I HONESTLY BELIEVE THAT THE
BENEFITS, BOTH SHORT AND LONG TERM, ARE FAR TOO ADVANTAGEOUE TO ALL OF
WASHINGTON COUNTY, OUR NATION — AND EVEN EASTERN CANADA - FOR US O BE
DENIED THIS OPPORTUNITY FOR ECONOMIC SURVIVAL.
THANK YOU.
23 3—2
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MR. CooK : I would uk. to go on record as being
opposed to the refinery, and I would also li3çe to go
on record as being opposed to a town of the size of
Eastport being l owed to decide what is going to happen
to an area as large as the area that could conceivably
be affected by a refinery.
Also, I am construction worker. That is how I make
my living. I am a carpenter ar c I nake E. ut $4.50 an
hour - it varies - and I have worked en the Calais High
School for about seven months now. And I would like to
point out, not to you, because I am sure that you know
this anyway. but to the people that live in Eastport,
the people that ar• int.re.t.d in a better standard of
living, wages and what have you, I am going to tsll you
right now for c.rtain as far as wages are conc.rned,
unless you ar, highly skilled, probably union. what.v.r,
234—1
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367.
moneywise the cream of the cream sin’ t going to come
near you. In other words, you are going to get the
jobs, probably about 15% of the jobs involved with any
construction operation - this isn’t even talking about
a refinery; I am talking about a high school, all right
you have subcontractors, they are all out of the area.
Eastport doesn’t have anybody in this area that knows
anything about building a refinery. If you are lucky,
you are going to get laborers, maybe carpenters, but
the people that are going to make the real gold are
the people that are coming from out-of-state. You can
go up to Woodland and you can’ see all those nifty looking
rigs from Arkansas, Illinois, with the Hobart welders
on the back, they all cost about 14 grand, and they are
going to be gone in about two months because that pipe-
line up there is going to be done. So this is my
complaint. People talk about the standard of living.
Also, another thing you might want to look into: go
into town and try and get a hotel room — I am talking
about Calais-Woodland now - try to get a hotel room,
try to get an apartment. You are not going to find one.
Make sure that you get yourself a good reservation in
234—2
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368.
advance. To me, it is a good indication that rather
than the standard of living going up the cost of living
is going up. You have got to take this into consideration
when you think about okaying something like that.
That is pretty much what I have got to say. Thank you.
• McGLENNON: Thank you, Mr. Cooke.
234—3
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Is Mr. Fc rni ’tn h c? 1 fLc’r Ii. Erainian, Mr. Mahan 6
MR. ERf M.IAN: Thank you. Got ting back to my earlier
point, this here is a big question just to be considered
in one night, and if you people want to get everybody ’s
views on the subject that has views on them, it is going
to take a lot longer than one night. And I can appreciate
your view, you know, it is your time too, but this is a
big question and it means a lot -to people around here.
MR. McGLEN1 JON: I appreciate that.
MR. ERAMIAN: I will just try and make it quick, but
naturally I am opposed to the refinery. I am opposed
to the refinery, and everybody agrees it is going to have
a negative impact on the envirorunent around here, and
the sulfur dioxide, or whatever, the air and the water.
I don’t know, but this is more important to me than these
so-called short—term economic benefits.
235—1
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369.
The EPA, I would think, should take the lead in
protecting the environment. I mean, you people. I
think you should almost be advocating the protection
of the environment. I don’t know if that is in your
charter or not, but as a citizen and taxpayer I would
like to see somebody advocating the protection of the
environment.
one more thing, as far as the economic benefit is
coflcerned, everybody agrees that there is only so much
oil left in the world, so shouldn’t we try to be con-
serving oil? By building a ref iri.ry, we are just going
to b using up th. oil that ws hays quicker. and this
doesn’t seem to me that it is in line with prot.cting
the environment or conserving natural resources and
the whole thing of what has been coming about in the
last ten years about a finite planet with finit. resources.
We have got to start protecting what w have got. So
I will make one plug for the tidal project, which seems.
ju3t philosophically, you get energy out of it, yet it
is not opposing the natural forces, and it is a non—
polluting sourc, of .n.rgy and it sounds to me uk. it
is a good id.a.
235—2
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370.
Thank you.
MR. NcGLENNON: Thank you, Mr. Eraznian.
Richard Mahan. After Mr. Mahan, Sherri Riggs.
235—3
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Ca&d Ckamtfez 0/ Conu eewe, line.
Cat’aie, T 1aine
2
eceither 3, 1976
Good evening my nane is Richard C. Mahan. I represent
and am president of the Calais area Chamber of Coumierce.
Our membership now totals 72. We are comprise of people
from Perry, Robbinston, Princeton, Woodland and of course
Calais.
At our October meeting we took our last and final vote
up on our position on the Pittston Oil Refinery. That vote
with the mes ership that was present was unanimous to
support this project in its entirety. To my knowledg. there
is only on. member of our chi er who doed not support this
project.
I will nct bore you with a lot of facts & figures that
I. sur, a lot of th. previous speakers have gone over. I
will only say that if this project is approved it should provide
in excess of a thousand n.y job. in our area.
Wages from direct and indirect source. that will total
in the millions.
As a businessman myself here in Washington county, I
know bow sorely these jobs ar. needed.
I can only urge you to approve this project and let Pittston
get on with its building.
Thank you and
Good evening
WL:....I I Ck jni , f j inI , — Ilichod Iiglpt tn t nPnt2I United States
á36—l
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MS. LEHIGH: Gentlemen, I am HolLy Lehigh, and I
would like to say one thing, and that is that if federal
and state government agencies are as receptive and as
truthful to the public as you fellows seems to be this
evening, then I can well understand why the Pittston
Company has managed to slip through the BEP and will
probably manage to have all, the conditions removed from
its conditional permit.
I am very upset, and I do intend to ask Mr. Stickney
personally why he informed me that there were going to
be two days of this hearing, if it was necessary, to hear
the public. And I would also like to know the number of
people whose names have been called who have not been
heard.
MR. McGLENNON: Thank you, Miss Lehigh.
MR. STICKNEY: I believe in our conversation we said
237—1
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372.
that if there were a significant number of people
remaining to be heard at a late hour we would consider
iRoving into Saturday; we had made tentative arrangements
for the Gym and for the recorder to come back. There
ar, not a significant number of people remaining to
testify. People have left. Had they been her.--
MS. LEHIGH: Yes, but it is a 5ignificantly late hour
and there is a significant number of people that ‘have
not been heard, because I have been here all evening
and I have heard you call off a number of names of
p.opt. who have had to leave. And I think that if this
hearing ran into another day. many of them would be back
to testify tomorrow. I think that as a responsible
government agency it is your responsibility to hear
the testimony of everyone wno wants to speak on this
issue, because it is a very, very in ortant issue to
this area. I realiz, that you people probably don’t
live her., therefore • it probably ian • t quite so isçortant
to you.
MR. STICICNEY: Well, I am sorry that misunderstanding.
exists.
MS. LEHIGH: Welt, I hope you will consider reconvening
237—2
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MR. REI VEY: Gontt mcfl , I im Reae ireh Diroetor of
the Passainaquoddy Tidal Power Advocates, and I am a).
speaking as a private citizen. I will try and make my
statement very brief.
The EIS statement has dismissed the Passamaquoddy
Tidal Power Project. more or less, with a one sentence
paragraph. Now, most people, as Mr. Jones stated earlier
this evening, confuse the value of Passaxnaquoddy. There
is an American plan available that was made i j 5 by
the IJC. Unfcrtunatcly. it : fused. e save treaty
after treaty with Canada that we will not pollute their
waters. Not only do we have them with the contingent
state or county or province, we have them clear across
the United States, including, which this particular
Pittston proposal may put in danger, we have the upper
Mississippi River Basin, we have Montana, we have the
State of Washington, we have the Columbia River Basin.
238—1
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374.
and each one of these projects can be shut off by
Canada at any time they care to do so.
Now, I understand that earlier this afternoon, at
2:00 P.M., we had word from Canada that possibly they
will approve Pittston coming through Head Harbor
Passage; this is their business. However, the people
here have not had a chance to vote on the issue. Every
effort by the citizenry of the county to have thi, issue
brought to vote has been scuttled. There is a procedure
to go through. 10% of the voting population at the time
of the last election for Governor is required to sign
any petition in the state. I understand from a statement
tonight from a gentleman that this here would have to
be in before January 1st, a referendum by the people.
It can be done countywide, it can be done statewide, any
way you like, but it has to be done, and it should be
done. This is important to all people. It is not just
a question of Passamaquoddy coming in here or Pittston
oil; it is the d sire of the people thi, is the only
way it can be put forth, and that’s it. I have to ibid•
by the judgment. I am against the Pittston Company. th.y
know it, and I have made no secret of it, I am morally
238—2
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375.
against them, and I am practically physically against
them, and that is all I have to say. There is nothing
I can threaten them with. I build boats for a living,
arid that’s it.
Thank you, sir. (Applause)
238—3
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MR. • McGLENNON: Thank you.
Is Mr. Robert Treworgy hers? Mr. Joseph Unobek. j
Mr • Ernest Gusy? kiter Mr. Guay, Joan Xlyver.
MR. GUAY: Mr. Chairman. gentl en. had I known this
was going to be this late I would never have put my àard
in.
I don’t have no long list of credentials to present
you with. While they was gathering up credentials, I
was steaming on them old grea3y tankers for twenty years
in the Navy, and I for o . I an in favor of this refinery.
One thing that hasn’t been mentioned here today is
that I think more consideration should be given to these
.up.rtank.rs. As you all know, my experience with tankers
is that most of your accidents occur whansver you are
connecting or disconnecting your lines, and the isa.
trips you mak. through thi, harbor the less chanc. of
having any collisions or any disasters. If you can bring
239—1
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S
376.
in supertankers in here, for every two supertai kers.
that you bring in you would have to bring in four and
five of the other type. And when you start going into
the smaller tanker you are going into the trash. When
you are going into supertankers 4 you can just about
bet they are fairly new and they have got the latest
equipment on them.
Another thing - I don’t want to dwell on this for
too long - nobody has mentioned here today about take
a good look at this aesthetic values that they have
been mentioning in here all day long. Take a walk
around these beaches tomorrow morning before you leave
this place. There is not one of them that is fit to
walk on. An oil spill in this area would be a God-
ri : thcy would have th clean some o the dcbris. I
have cleaned beaches before through my naval career
where we did spill oil, and they looked a hell of a lot
better than they did before we spilled it. Believe me,
take a look at them. And if you were to clean the debris
off this beach, I wouldn’t be. surprised if the remains
of Noah’s Ark is down there right now, because I don’t
believe it has ever been cleaned.
239—2
-------
377.
MR. McGLENNON: Thank you Mr. Guay.
MR. GUAY: And count me as one of the greedy ones,
a transplant. When I pulled into this town, I headed
my trailer going out. I am saying this to th. rest of
them. I got transplanted in thió town, and if traffic
gets too heavy. I can tow right back out again.
239—3
-------
MR. McGLENNON: Thank you.
Joan Klyvcr. nftor Joan Klyvor. Kevin Callahan.
MS. KLYVER: I don’t really know whether God wants
oil in Eastport or not, but I do know this: you can
make money your God, or else you can believe in God
and that he will bring some answer. I know the people
in this town and most of them are Christians. I know
that other people that are trying to move in have made
money their idol. It can’t be right. What Pittston is
doing I feel is wrong.
They are trying to give us a map of ou,r country and
it is already all planned out with their money. I can’t
hardly believe it. They don’t even know us. We are
just figures, we are numbers. At the vocational achool
there is already a cafeteria training course set up.
The people in Eastport don’t know about that. There
240—1
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6 )
378.
are people regi.t.red in that. I suppose they come
from welfare and they are required to take the course
in order to get a job, and I suppose Pittston will
provide the job. But I know the women who work in
fish factories and I know the reason why there have
been fish, even though there have been oil, spill.. It
is because God wants them to make enough money so that
they can get their unemployment check. And acme of
them are $14 abort so they hive to make wreaths for
$200 more worth of wreath., and that is the way it works
around here. Rut we don • t need money from people who
aren’t conc.rned about lives but only figures. We need
it from something else, and it has to be positive.
The tidal project is a positive thing. I don’t want
to fight against something. I want to fight for some-
thing that is good. And that is all I hav• to say.
(Applaussi
240-2
-------
/ fQi
- 379.
I thought I could sneak half an hour, but I missed it
though. I will tell you who I am and where I am from.
My name is Kevin Callahan, and I attend the Shead
Memorial High School, right over here across the way.
Unfortunately, I seem to be the only person repre-
senting the high school here. That is rather sad.
I know you are all tired, but I think I have some-
thing important to say. As a co-editor of the school
newspaper, I have noticed that there are a lot of people,
of those I have spoken to, there are a lot of people
against the refinery but who can’t put their finger on
why. Now you have presented here volumes of information.
A lot of these people who feel the way they do in the
high school feel this way from intuition. Nc ’z, u may
laugh at intuition, but there is a lot to be a .ci or
it. A human mind can certainly calibrate more information
than you can present at this meeting if yo .i held it for
a hundred years, and I think that you should take into
account the fact that intuition and the feeling that
the people of the area have is really very important.
I really think that if a refinery moved in here you
would have a bit of a cultural shock, because these people
241—1
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380.
ar. not ready for an industry. They have lived rural
lives, and this is a rural coninunity, and if you are
going to do something like this, I think it should be
a more gradual thing. Pittston is coming in hers very
fast, and I feel that their presence on the island
would restrict the growth of the coninunity, if not
control it. That is the way companies are, and I have
no objection against them, but I don’t believe that
there should be one here.
I am sorry that there is not a delegation and that
there has not been a poll taken in the high school.
Perhaps there is something I will be able to do about
that within the next ten days. I think it is important
that you should know how the high school students feel.
I just gave you my personal opinion; I don’t know how
reich that counts. Ithink what is important is that
you should know what the high school students feel about
this, because they are going to graduate and they are
going to come back hre. I have heard many people say
that if Pittston comes in they won’t come back because
there won’t be anything for them to do here, they won’t
want to live here, they won’t want to rais• children here.
241—2
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381.
Now, that is the personal opinion of the people I have
spoken to, but I think definitely that you should know
how they feel. I think you should take it into account.
because they are going to inherit the town and I would
like you to know how they feel.
MR. McGLENNON: Thank you, Kevin. I think you have
represented your school well and -I. appreciate your
testifying, and it does make a difference.
MR. CALLAHAN: I sin sorry there weren’t more people
from the high school here to represent the high school.
I am afraid that - I heard a couple of names mentioned,
but it was getting rather late and there is a basketball
game tomorrow and there are a lot of personal concerns.
A lot of them don’t really have time.
Thank you. (Applause)
241—3
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The CURRE T
£1 WC Shead Memorial Hig ci
T’cKinley Street
Eastport, tt’iaine O’ -631
NZ0O221 .20
U.S.E.P.A.
e ion i, Enforcement Division, P rinits Branch
J.F. Kennedy Building
Boston, Ma8s. 02203
Dear 5jrq
At th ‘4esrini’s on D cc. 3, an associate editor o1 the high school news—
raper st ted t”at the paper would conduct a pa11 to determine the opiriion
of the students at Shead High School on the topic of the Pittston Oil Re-
finery. The past week, a poll was taken and the results are contained in
this letter.
We divided the results into four catagoriesz Eastport students, P1e sart
Point stiident , stulents from all other areas that attend Shead, and the
entire sturient body.
are the resuit9:
1. O you think the rroposed Pi t tston Oil Refinery should be built in
Ea stport’
EA’TPORT PLEA. PT. OTHCRS TOTAL
Y 1W lnva i’l Yes No Invali YeR 1W Invali’l Yea No Inv, ijd
5 4.(4 1% 32% 5 6R 32$ O 57$ 1%
?.Thic question determine 1 the hometowns of the students.
3. This question was ror non—Eastport residents only.
Would you change yo ’ r newer in Question I if the refinery w s to be
built in your home town”
5 itS 16% 76% 8/ 1 ,9 78%
!. • Would you pr.’fer another industry to the Pittston Cii Refinery?
- li .O% ii.2 l3:
5. If the Quoddy Tidal Project or another alternative was built in East-
ort, would you want an ofl. refinery? 28% 52% 20%
r . o “o intend to live a d work in the Eastport Area after your grad-
uation If there isn’t an oil refinery? 21% 280 21%
‘. Would your answer in u stion 6 be charig d if the Pittston Oil Refin—
b ilt here? 24 56% 20%
U y’- ’ -id the opportunity, would you work for P tston If the Oil
F i ery war. built? 4.2% 4i, 17%
Tbe r son the invalid column is so high Is because some Eastport student.-;
:i ict answer questIons 4—R aecount of the heading non—resident only on
uest on 3. All the results are in the copy of the Current provided. Also
in eluded is a copy of the poll. We hppe the results of the poll will be
of so’ use to you. Please send any questions or comments to us at the
‘dress above.
i c, y
Associate ditors of’
242-1 the CURRE 4T
-------
//• ,‘
r its of tt.ia poll will be entered as t.ati
i, c “e traztscripts of the £..P.A. 1 sarin s bsld
rria y. This poll will aid the in its
‘ion. be L’eeulte wifl also be print.d in this
q’ £S iC or the CR L?T.
, you th :k the propose I ittiton Oil efinsr7
ie be in iastport?. . . . . . . . . . . . . . . • • • . • •• •• • •
itese check your b etown:...........................
OR B LDER S C LT—
ould y:i ch ng . your answer in .u.stion I if the
.usry wiu to be built in your baustown?
ald you prefer another iMuatx7 to the Pit toc
It the .uod y ida1 Project or another alt.rnotiv.
iilt in Laat ,rt, would you want an oil refinery?...
o jot. thteid tr li v. and work in the tpsmt Area
r yotr graduation if there isn’t an oil rsfins ?....
odd your &nswer to ueetion 6 be changed if the
s’;on Oil Refineryims built here?...................
f yoi had the oppo’tunity, would you work for
ston if tht oil refinery was built?.................
1tl T fl D LL’TERC TO 1 E EDI TO O THIS TOPIC ARi. ‘11CON J.
— Y _I. )
kS O .T
( dL ii L i
• 1 fl L T. Q
T1 NO
—
•__,Y & JO
! ‘
a a
r s _ro
_ ,Yt : —
242—2
-------
,Jg tç Q J
i O.EL’
The Current, In it
effort to he useful,
promised t e F;. P. .
at t . Pittston h.er’
ing that it would con-
duct a poll of the
tii h school studont
in order to see what
their feelings were on
the ref iner .
- The ioil hopeful].y
was unbi ed and real-
istic. b believe
that deepite Its er-
rors it ropresents a
good projection of the
fcelings tier. in the
scuoo).
These wore tZ . ques-
tions. 1) Do you think
the proposed r. tc .ry
should be built in
sstport? 2) on reeo*
dents oolj-t ould ‘ou
chanCe ;our arawor to
Question 1 it the ro—
inr j W?t ’, built in
tour tw 3) ;fould
ou prot r othsr in-
dustry t3 the refth.ry?
L) If t’ Quodcj pro-
ject or t r a1t.ru -
tive were uiit it ast—
por’,. wo want
the ref izwry? 5) T)o IOU
intend to liv. and work
in lsitpor; if there
ir t an oIl ‘.ftr .ry?
‘ufl y ,u ct ang.
)Ok 7 U&i’ if the T0
r rj wa butit in
stport? 7) If you
t o opportun.ty
we .U ou for
P t ?j, ,n ii t h& r,fiit—
ol-:, wa hni ?
Gt inuoc t. 2
ti O
fj. j j. .
.1 c) UJCiJi)i)
The 1atIons.1 ronor
Society induetion will
be held Thursday, Do-
ce or 16, the acti—
it period in tbc e r
at a school-wide a.—
sertbly. tligiblo
Juniors and Senior.
witn an scadsnio
£rad. point of 8S or
higher and who rsoet
tie r.quiren.nta for
leadership, service
and ohsxaoter will be
inducted. Interested
parents and the sen-
.ral public sad in-
vited to attend.
CHEf S TMAS
CONCE! T
On Doa. bsr 21 at
7:00 tbe.Eastport
Music D.psr .nt will
perfoz its aflnual
C wtstmas cousert in
the auCLtori . The
begtnisxs’, gren sr
and ht b school bands
will be pert O ’nin&.
l driiaoton is tree.
The ‘ii. .d Uigb Paud
is ezpet,ttrw to re—
eetwe its n i net-
tor a btore the con-
oort. If they do not
arrive bsfor. it, the
band wiLt not he pro-
forvtin on the date.
£ f , band calm’
dare are loft sad
thej’ will be sold at
the concert. ALso a
por.onowill be rnffled
ott for the £ 5 band.
PLAY REVIEW
The c ady, “ zn,
Robber, Run”, was
staged by the 6. S.
two weeks ado. The
play was attended by
a fair siscd audience
slthou h a1i htly
lass than desired.
The play ran quick .
lj with much slap.
stick and sation. The
tYO robbsrs Kevin
Callehan ao& Ronny
L. tevensori, portrayed
the two biabling ama —
teursobb.rs very
•ffectivaly.
The highlj hta of
the play were a. 1 *4 ..
de e ’ seen. where tb
cast hM to dive to
th. floor to keep tr
being clobbered aM a
pie in the face of
Risky Rsd.l1 (who
was playi the bead
disciplinarian lie’. Al-
den).
The Sudience en—
aoyed the slapstick
tho most and didn’t
scea to a tio. the mi-
nor mistakes made
the cast.
This fiz,st play o
the S. 8. 8 this
was a very success
production. The has
generated much enthy..
The 8. 8. 6.
should b quite an-
ti,. is tbe,prinl.
Voi 2 11 &hoad iOr1LU ! 1j Ii SCflOOJ. UQce ber W, 1f * Profltatle 20
242—3
-------
ps o 2
- ,
Frj
C Ur RENi
“,‘ r r’
\ . .. I ‘
JJI-’
Poée? Spinnoy
Kevin Callahan
I. d Prorich
r 1 . Lohir,h
1 aron Anderson
Jo rine fIver7
Rornie T’ ianoh
Su. an Davis
Aut t EJ ) ‘O f
tao l’orsyth
Katb . Vr’enoh
Pob.r Gardner
Carroll I oward
Kim Lehigh
fl, Gary Lewis.
E.ath ,’ 1 artin
Peter MCDonald
‘Send7 Morrison
Doceober Let was ar
exciting day for Shead
o start with,
the cr eer1 ader 5 had to
wear their uniforms to
school (whioh was ob.’.
jucted to r ore by the
c 1eerora than the play.
era). The pp rally
durinc activity pertid
harbored an intorest .
in aoll.otion of
school—spin ted. aott’
vi 1 tte . Th.te tno].taded
skits, chears, copt.it$,
music frc a the band,
and hto introduction of
the ‘?6-”77 pla7ere
and oneenieadeDs. The
tires oo ’ztest 5 had Iota
of participation.. The
Sophoftorea won th. note.-
5Aking contest. ; the -
niors took first for
thein sin in of the
50n001 song, and t ie
poster contest Wt n .r5
were as follows: •tnst,
Viaki Farl.7; a.oo d,
: e1.ri. Seiwood; third,
Karen pinney. It!.
worth it to oh.ok srotu d
o the g7m p.lls for
their creativity.
Also *t the ra117,
wtiob lasted *3.1 afts ”
noon, )fr. LLnco3.rz save
an oxeitir spo b as.’-
oonp*nisd by psppl
sic which the track
team 3ag od ‘ouM th.
to (much to ever7
one’s .it e snt).
Susan ewnan
Stave att1.
Suaaz Pottle
Any Ray
Kev ri 1 ay
l3ecky Robinson
Kizt eritworth
Roger ung
.rditana:
sr. I itor:
kd,tscr’
PIT 15 TO i
POLL
Prom pace 1
Sov e :astpor ; real-
4ax ts did not c:n’tploto
the rest of the poll
because of the teading
can residents o ly On
q estton 3’
The cunu3 .ati’io re’.
suits were as f.2llowa:
J . 5r yac. L 2 ao,]4’
2 13 7s ., 18% no,
9% td 3) 1 0 i,s, 140
, 1$ a itis 1 .) 2 7e 5,
$g so, 2O’, in. ? 2l,
‘as, 5b; no, 2l . in.
6) * .; yea, . no,
a in. 7) 1 2 yea,
Li1 no, l7, in.
utport
No
1) 53 1j6
I) 43% 2
, ,.‘
S)2Q%
6)22 145%
7135% 39 ;
Pleasant
No
i3 63.
2 51 BLI
j gi,i U 1 a
t 16 79;
5 16 6
b i; 90,;
7) 37 63..
Other Pisces
Jo In.
;32 O
76 6%
56 6,
1i .9 10%
6L.% ?
63 6
391 ’ 7%
PEP KALLY KESUJS
4r. Puss•I1’s speech
wan s.3.so irtpresiiivs,
and showed much en- 1.
.thuaiaas tor’ the up—
conini • 5Øfl, 0 AU. f
the participation arid /1
e cttement was very
enooUra4tDg.
&t 14:30 tl torch
lit• parad. started
trota the \‘, P. W. Hall
and piosc.d•d around
town, with the march-
era ieartng aU. the
1 57. The nsin parti- f
pants in the parade.
were the ohe.a’1.adera (
sad voisriteer torch.
carriers; no on. e3ae
was craz; enoUgh to
be out n the freezi
coldi .1:
The warmth of the
bonfire was appr.otat
w en they r•aohod the
b*tt.r field. All III
LathSrSd around cd ifl
ono.red wheu a paper
macne nornet (Lubee ‘a
mascot) was burned.
After cheering around
the well biult bouti
th. tans and sneer-
leader, excitedly dc-
parted ton the gjm.
(
In.
30
. C)’
27%
Pot tt
t 3.
I
),0
%
I ..
ai 16%
5) $;
242—4
-------
f)
1iTT . Th( I Aif IT
At the E.P.A. baring
the Portland press
Herald reported that an
Editor fron Shead high
School stated that he
represented the school
body in saying that the
school was opposed to
the refinery. That
person vie nys.If and
I would like to apol—
ogis for anything I
night haTs said which
was trus. I belt,. .*
that the Herald lmui
fairly turned a mistake
of in. into the na or
point of r speech I.
tried to av3i6 aay
ing soosthing like that
but I or aged to give
that impression anyway.
I apoligias and hop
tt .at the poll I promised
the EPA has bei imbia..d
and realistic. I 4
lik, to teal this s
atoned for a mistake
on part.
I would 113cc to say
on. mon thing bownrs
I heard many excuses
froz people as to why
they did not speak but
I thiitk that anyone who
ia $ co: c.rnd would have
spoken if they wanted
to.
If you wish to be
heard c .n riot be
atyai ! t As in
y ease 3U n y ak. a
aistake yet that is
preferable to not speak-
a a_ i. ou night
let sonsor e take advan.
tags of you anc attach
his opinicr o yours
thply becaujo you let
hiz get swa, with it.
I heaiC that sane
people st t u angry
.tter to . .ral4
about q £ jnt
t o!t t a this
u d like to
the C’:jr at get r ail.
I TO tIZ ITr.
I en a st snt of
S, .H.8. in good standing.
I have an ob3.ction to
raise to your attention
concering your recent
poll. I feel the wording
of the poU’s questions
could lead the person
filling out the poll to
imply other than what he
actually f.lt. I feel
you did an .xreasl.y
poor Job on this poll and
past polls.
ED. : or
A]]. polls that tb
Current conducts are
written by the editors
and an .tts. pt is mad. to
ceep th. poll as simple,
clear, and unbiased as
possible. s v u ].d like
the p.naon who wrot, this
latter to ks specific
argu.asnta not genera lisa.
tions. We would ike to
improve our polls and with
your help we will be able
to. Thank you for your
letter.
To tbs £ditori
In rs rd to the itt-
atom Permit 1!oariáge of
Dec. 3, 1974:. e feel
that it was unfair for a
ShaM High Sobocl student
to represent the sigh
cboo1 without beinE. c-
lectd to do so. e also
feel these opinions were
strick3! his own. we
feel this student had r o
right o o this and his
stat.ut should bc re-
tracted from the L}.i.
itecords.
I . Yew Conc.rtod
btud.nts
(Plus. as. statement
in pxvvioa oolumn.-4.)
TR Cft I 1 C( S ALL -
L T?!R&TO Tfl kDITOR,
PL ASZ PUT T}1 Th TH.E
BOX II TH. ?-iAIN ROV!1.
242 -5
To the $ditor
The Sophomore
Class hasn’t beert dti..
ing too much, noted
by the cancelation
of the Sadie Mawkine’
Dance, Is it becagee
of poor leaderanip?
No. The reason the
class hasn’t gotten
off the ground is du
to the lack of intret$
and partipipation in
class affairs. £he
attendance at class
meetings has been
rioedlessly low. If
this keeps up, we
won’t get anything
done this sur.
The peop2.e who are
not interested and
refuse to cO-operate
are usually the same
ones who do all the
complaining about
the lack of funds.
At the present
rate, when we are
seniors, we will not
even have enough
money to have a year-
book. Wouldn’t that
b a grat distinctict
Th. first class tO
graduate fro SILI(S
that didn’t iave a
‘jearbookt
o come o * “ )laea
of!7 V’ don’’ e so
lazy! Let’ ; et go-
ing on some projects
that will ri. ise come
money and a p blam
ing everythir. g on the
president of the
class.
A kii( ORA
To the dito t
We chafle.- e the
rest of the c e rooai
in the school to a
Chrietmug de orations
conte at.
ROO?4 7
(ED. NOL ; Tie oph-
onores a ’e h’vir one.
& 5?-&R
P . s. 7
-------
It3
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L’ ...
4&i - ‘C -4 /4
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4k a14,t 5d C .‘ 7 tt. 7 ” t
b. _/ . L/ -. Yi , -
f FJ - , ‘ t —4 t flJ
.—‘ & - / ‘-a. -
£ flZdLAJ -‘&, t. 2) a2’/ ‘ t t ’ i.
OX-EL 4 ug (.1 a d”om _(A. r
J \ 41 .t’L L i -
2i cu -ta. . c-, a - t(C/ gij p d
w -n L v,S ‘L 4J ?O “C’O —c- i • - <- L•
/
t_ - -’ CO .24 L _4
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c!- 4 d / L7i 7t J •
Y_ .&
21O 7
V - . - - — c. _/
f .,z 4 d Acwc. ‘7t4 A’L &-,c_’ - 4 - e i t ” ‘ -
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tt1 ( MU. Z#& e2,’ ’
y-4 I c ‘ ./- j
, __,&‘
P •/ () — ,4: c
-t4 c(aJr1 2’ c2. ‘
243—1
-------
l . Proaton Xinney
Co ty Rood £
Eestport, rain.
1 r. ohn Fccaonnan
Rogion3l *drtiniater
U.S. fl ,torr ontcl Protection Agonay
gicnI
baton, ! aeo.
er I i. cGLennanz
I wa born in Yaatport and have lived here all ny life. I have tried
fishing for a 1ivin s. r l then. I have nvvar seen two yearn in a row
in this aree then a doont yearly vs e could be r ade fiehing. !) experi.no.
a. been that following one tair.ye.rly wge would o two or three sara of
w 3ng for below a r e wages. Tb. net result being, a person could work
the three to fot ’ ysers end it he v .a lucky,he could get beak hi. invs.t ent.
this thz s his * uip ient v.a v out, so in sl!toat IVS27 aese a person
ceald work three or four year. for i othing. Thin baa happened to ne end to
others in !aatport. V aybe ea of then. peopl. are here today.
There i n a esying in Znetport that 1! you are going to flab for a living
be sure you have a good pen oion or your wife has steady * plojment.
} virLg lived and wor1 ed on the atere eurrounding Eaetport I would lIke
to i a a row remarks on the recent report baeed upon “ knowledge and
.xperianoea.
3.. po s thirty-four it is stated that seventeen crab and lobster
licenses were issued in l97 and only timlvs in 1974. This show a
drop of nearly on. third. Lobster fishersaeu slang the coast t Eot
244—1
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2
fish an nvcro o of one hunc’rcti thirty trops. To1cin this avorur e 1,560
traps should o in u e in Ecr tport Dlone. !!o nention is node os to the
ni ibcr of licen oc issued in Lu1 ec or other to ms sLlrroufldjrir Cobscook Boy.
C n o e one hundred si : it stetos that out of the forty boats in
Wanh1n ton County fifteen uscd Cobscoo! , !!oro or oin, fifteen tinee
one hundred thirty tre s should r ive us 1,950 tr rz in Cobscook Boy.
Several ti :es durin the o k fishing period of these yesre I hnve keen in ønd
all over the boy. I hove never seen note than fr fifty to seventy—five
trap buoys. It loo!:s to me ce if the report has boon overat ted by some twenty
tfres.
2. Cn r a e one hundred seven the orea of the scallop beds are shown
nuch lor or tht’n they ore,about t ronty —five per cent.
3. pace one ‘ nndred Thrty—seven there is a c cph sho4ng the
annusi occurrence of fog at Eastport.Tho rrap}i shota the rorcentages
of t1 e the density 1i its visibility fror 0 to •5m lee, fror
.5 to 2 ios, end over 2 r.iles. This graph could be true of
west uoddy flead. where the water is from two hundred to three hundred
feet deep, therefore, lower in temperature —a necessary ingredient
for the dove1or ent of fog. The graph eppeers to me to be upside
do rn for the ores fror Head Harbor to Eastport. The ,ercentages
seem about rir?ht hut .5 to 2 miles should be interchanged 4th
Oto .5 ‘dies. Then this report would make a more accurate picture
of the Heed Harbor to Testport fog density.
244—2
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3 ( )
, The last paragraph on ioge one hundred torty-th!ee and continues on
page one hundred forty—four at s it up quite well as on a ro thnotion.
The next paragraph is not even good cuess work. Here it suggests that
the eouthweot winds would fill the paeee e with dens. fog without
werniog.
This io not the vny it uor!:s. The fog does not roll in Lnetently without
warning. Thc,rs are tires it ee s to roll in thick and feat but it could
have been seen for h’uxe or even daya before condition. get just right for
this to ha ’pen. S e of these conditions ore when the sun has gone down or
when the lend is cooling off. There is warning for those that take the tin.
to follow end observe the conditions. Anyone fenilior with the area and the
wetere could, it as :ed, almost predict to the hour when this will hapt,en. This
being else true of the tir.e it will leave or clear. The renort on the fog
in this area seers to have bean e gerated the rtostl
5. Another area of the renort that could etend a little fins
tuning is the wind end wind shift suggestion.
We do have winds that spring up very rapidly and blow a gale in twenty ninutes.
Pirt, never fran the east, south, south-east and eouth - .at directions. These
winds breeze up gredi*lly over. period of hours and the .. winds are th. fog
carriers. The herder they blow the greater the visibility • At least two
or nore, with the most denee fog being at flat calm. The wind blowing fror
weet to north can spring ( ron flat calm sod dena• fog to gal, force in ten to
twenty minutes. When the winds oone (ron this direction you can be sure the
fog ia abort lived, in minutes it is gone. Conpistely gone, not b.nk.d up
outsid, of the cuter ialonds but gonel
244—3
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4
Aside from the report, I hove hoard a lot lately, or since Pittston Company
ht3 5 been interested in Eostport, oboat Head Harbor orrowe or Heed Harbor Channel.
}!ard].y ever do I hear it by its correct name Head Harbor Passage. A boat or ship
is inside of Tteod Harbor Lir ht before the water shoals to two hundred feet,
pr-on there to within shoutinr distance of the Eastport r.unioipal pier, at no niece
is the depth of the woter level less than one hundred feet. T eoritv oil that is snid
one would thin2: it is n narrow, hord—to—negotiate place. The narrowest place is
much more thon o half rile wide. Looking at a chart of the light at Head Harbor
Passage tho nearest point to the ma inland ie about eight to ten rilleg. res, there
are islands nearer but, still eight to ton riile to the neare-’t mainland.
Cne final point would b; if Canada wants to atop all large earners in all
Canadien waters that is up to them. Thit, if they want to select certain areas
that have teen used for hundreds of years by large and & all sailing vessels of all
flags, four, five, six r aatschoonoro with only a compass and a sounding line to get
then in the harbor it would e sort of a double standard affnir to n y way of
thinking.
Thank you for giving me your kind attention.
Sincerely,
- E2 ‘ Z-f
Preston Kinney
244—4
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TVl4phune M t KEJt
III e c cutiIIe( notInIut-r .Aqcnc
(:I:Nl.;RAI, INS URAN(:b:
lkttrnn * El.,Nou lh.*mii
Route 100
c )
1WJPURT. JMNE (HO3L
December 3, 1976
TI. S. Enviromenta ]. Protection Agency
Region 1
Boston, Mass.
Gent lezen:
My husband and I
of Eastport and Lubec
operated an insurance
per8Oflal and business
County.
have been lifetime residents
and for the past 12 years have
business in Eastport, handling
accounts throughout Washington
We have seen our once thriving communities
regress to their present state of high unemployment
and poverty anJ feel that the Pittston refinery will
stimulate the economy of the whole area.
Yours very truly,
(2 1-7z 1. . ?/ 7 €ar,,c2
Elinor H. Blanch
i45-1
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4 ; h44 I.’. v’rti isIy J4t I ] di i,
emtnn, M;ui .
Ctntl .nu n:
) y ‘ ime ji } than Co n. I : m ‘rp ’pnt ’ a.rvin ; n Member of the Governor’s
Ejrecutlve Councfl of thø SLr te of M tinn. W hin tor, And Aroi stno) Cnirnt Ian mnke
up the 7th. Diatrtet, of !h4ne, which r’’esent.
Por the pa O years I have h.e a reni-tent of 1w tport. ?fl of thece years
w an spent oper t.ing a elothin atore, on rmr main street., from which I retired
P years ago. I am interested in rivic and pn1itie; 1 nf1 lm having s erv ed n ” t? e
?x tpnvt City Council, presided over t! e W hin t.on County Ch he of Cntnrner e
and the Wanhin ton Go’nty Dev ioj’iient. Cnr oratior . T h4ve .i-yed as a Member of
the Sm tl1 usth’ as Administr tinn ivianry Council and the Maine Health Pac’i)ities
Anthority alon with many other State and loc’al or nnieations.
Thiring the past y rn I have watched with disr a.y and dlanppolntment, the
steady de 1ine in the economy of our area. No one known riny bett,er t.)’ it I the
strong efforts that have been made to reverse thin unVortun te slti wtton. lu nary
cases tax reductions and other attractions were offe’ ’vi 4 brine new indi7 try into
this area. I recall or two industries who located )-,rp for p short time. p
for their closing was a simrle one to ex lain. ! ii to n’ r eo iral ‘tion we
a just to far away fron the market. ‘rsirsnnr+etion -os s o 4 hrj 1’ the r si
eateri le into t ’e ares, end spi’i out ti’. rf is-eti r rhat, er . jus 4 ‘co pr t.
Industr ’ carrot compete with t? ,.e arideil costs. If nr’y we rnni’ solve this oMem
by piekin, mtpcrt p and transpla tin the a’e resr oeto’ , Ne Yr”k, T ’ ’i)adei ’hia,
orsøme other le.r e areas This we know in an n..sihS1ity.
• When this Universe was created ie+j:ort was bir a crl with. a C oat T ttvr T e oa1rse
v! ieh is practical1 t.o’u-hed, I am rererrf C to o ’r wall i ter’ 1 ’rd d e
Pltt.str’n has rpo ipe the ra+Pnt.i8 0 r P’d h’ ’ dP% 1r r l 1 ’r
to hni]d a oil refinery here.
We eho’ild he deerl:’ conc,rn d to e:rn that Qfl o ’ afl jr T 1nc, i e
heated by oil and that 4 o ph ert.rini ’ e ’ trr , i” i .’., is
t . upe of fuel oil whe’ t’e Ta+irmal avc ;. 4 “ 1 - “. r—. r ——t
e1inery n’eratin in t” ix New Stn’ . sa 1— o” 4 ’ is r c -r, ir
t a t a combined tate of ‘a’yl9r 1 r d lrwrrr, - r’r rs he
the ideal location for thin irery.
Fn’m r ? -er (Th%- 1 , !il1 am 3irrr, 1- s;-o o I- r” too i.- °7/ r ’ i
}e’v 1a’itl to do ever: +!’in ji jrj +o )o +i -t ci ‘- in c
“L e in r w 1i-1, wh ” c 4jo ’ e r pdc “c ‘cilHor. ?zy, ‘ere
isn’t a rp!ir ’r’ o e ti°” j +lnp y ••r’flr .e11 ‘s
for the nt r’, this re or rust do 1l it. c: ’ ° r ’ ; rc. ‘; ‘“ k .
C’ .aeity ke -ed to l’ ’a prr ’ ct r ’ 1 of t ’ô o’ ci ‘ . C c i h’fl+ j ’
re oririhip w ” wi +“ r (;rF1 4 P t P r v ’1 ““‘ ( Cr t •1’
R° r C. 1nrfrn, I—t ’iir + tar 1 - c i° r ‘C r.o - ‘ ‘r
iT ‘nrniu .’i e . n E t rt “‘“ “ 1 - —” ‘ r r; c’
Cflfl5 n’C+i on of rsri : ° ea •‘pr r ” ’ 1 n ‘ “ r ’ 1 r c’ •“ “c 1 +,4 +.c
i huic h i mt ° ‘ d to Cj d on b • n1 e ’r ‘o, crr “r v’r’ -c
reo’ le ir. New En l .otl, or o * te ‘ ; ‘c’ -o
a i attroctj.,e . - od rn v-.fi*’.’ry ‘r hq?” T’o.. ’ “ j j 4 4 ’r oo fl .+
In cr d 1e, sin- cn. ‘T’hv Z vvr,’ 1ra ” in irrii C’, c 4 . o’ 4’ V’ ile jr
.TOUI I llinois? T e ‘en ”J j.n o to rl-’c c ” 4 of •c’ c..-’ 1 c r-
Senbor,l, is son thin t. ’’t stirk , s ’ ok”o, foils up t ’ • +r ’ r ’j t ‘1nw
and 18 a Canerel nutsartc ’e.”
24 6—1
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i’,,. tar tas 1 as ‘ti ! . . f asia
V. ha * .wui 1 . r .f asp s u44 r.4, as v) f iv, Ws4i ?‘ vi r’is.Ip.r ‘m d
oth.r ? ** .iP tas4st ’ m?w!s. P .rd n t v ’ t r! r4 ;. i’.y w .ni
t) ! ‘ifl .n’mr. t!’t nf ‘ . .r.’t liv n, T Ir , r,t t’i’4 thul • .ji i j4 4
r k! Th. hit’ nm. fnr ‘tt’ tn b’!cnr.. pnrt nf . ‘1’%C A,ui r1es’. C’ nti-vtii’,n
Th. T*ttMi n Oil R.’tin.’!7, m v ) t!w m ’tell (0 1n4 ”st’I.. wht th imu3d a4 rntr hv’to,
wou1 I .r.iite tb ... ne”, ..*‘ie i rw.i1o4j ba. This v4 o WMlld CTaatø fl tP? )tA 5 5
rrn’ satp ’t as Wanhj, te*i C’r intj, Th.i . a * but £ v nf tb. aan htn.fl tim that
vfl( b, tvas tha ennntruetien of thi a etiniry.
C.’ntl . ths* ynsi tri i vin im. tb. .ppm’tsity tø aipra.. y vf ns n
p mpoasd vi4ttom 0(1 a.fIns ’, in .tpnrt.
246—2
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247—1
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tdtppC.e.iIJ’m 4 y .4lp. TtoN// %.t ‘.t . 4 . t , ’L.
pClITION TO AV! TIIF. INTERIJATIONAL. PA MtAQUODDY TWA !. POWCR
SITE AND FACILITIES AT MOOSL ISLAND (EASTPORT), MAINE, AND TO
rRt CRvL -IT Ut R PED RAL4’RU TEESIIIP 4J1 ?IL SUCH’ T(M ’A IT
CAN- BE DIVEL.OPEI) FOR POWER ç ENERJ TI ON.. Tq .EAS 3, OyIr DEPENDJ ThiCE
ON ’rOSSIt FUCG SOURCES, NUCLEAR PowrR, ANb OThER ‘ORMS OF’ LESS
I Ej,IA1ILFRYDROPOWFR- . .
laff ix my signaturc to t is’ Setition, which I understand is to be
us th any .foru in..which Lt)wAll. he lp to.f.o estal1 an ..prevent any
actions taken; by t ie U.S. En ironm n.ta.1 Vrotection . g cy, T e my
Corps of Engineers, or any other federal gcn ies. a jned at pproving
the construction of an oil refjncr on Moose I nd ,, Maine (such
approval is implied ipt e rocQ t draft Environ enta1 Impact Statement,
designated under the Environmental I’olicy Act of 1969 as Appli ition
Number NE0022420, referred to 4n public Notice No. ME—Ol 77, iss ied
1
and signed October 13, 1976 by Regioni, EP Director John MçGlennon;
Corps P r ’mi€ App1icat ion No. 25-16—367. N>’ objectipn. is ase4 on
4 -
the fóllówing considératións:
A The propos d ef1ner) is to ‘be built on fedEral a .r ort lands
and also in a m nnet as 2 to neg te further construction of the p oposed
Intcrn tional PasPamaquod y Tida1 Power Project, as óutlinedin the
updatedAi ny Corps ofE qi eer t1studies from 1959 to 1965. This is
by far the best and in fact the only- viable tidal power site in the
Eastern U.S., and represents clean, reliable, fyel—fr?e e 1 ergy for
centuries to come. Despite claims of these twbprb ee Jco ing compatible
by part-a çipating,age gies and the oil firm, thi com tibi1ity is
highly doubtful, since a gigantic, unprecede tqd lock must be bu lt
to operate the oil refinery with
ation is to be built later; and since the problems oC t% Jcjo &these
supe’tankers in the low pooi of the tidal power i 4 l t j will be
grca;er t ian in existing tides. I note the totally inappropriate down—
p1ay rg o.C this conflict in the draft E.I.S. referred to above, and
C311 upon the public and officials to realize that if the refinery is
built, the chance of ever harnessing the tidal power of the area will
be placcd in serious jeopardy. (All these considerations are in addi-
tion to the usual complaints against oil refineries everywhere: the oil
spill d ngcr, etc., which arc actually greater than average at this
Site clue to a long, narrow approach through swift currents)
1. Tne federal government has already spent millions of dollars in
prcT vn ry wcrR to b ’th develop ana c’bnstruct this tidal power s&te,
‘ “&nj i ltt?Ti phi. uuuh Lng1 . ’ - - - --‘‘‘-—-
2 Q . l
-------
construction workers, supervisory housing and further update studios.
r tall on the federal government to make public an account:ing of these
fundn tiot only no that it is reoUzod what oxinting investments will be
seriounly jc op rdizod or alt ethor lost - f this refinery is built, b’ t
to oscort in what a ludicrous price tag the federal bucarucracy might hove
arbitrarily placed on thin mohetarily priceless free-fuel energy source
from the eternal tides.
C 1 further ask tho Codezal jovornmunt to mayo nwiftly
to finish its re-evaluation of the economic (vanibility of this
tidal power installation in the light of recent oil pricc increases,
and to offer the public quickly a federally-funded tidal power
project which in the final analysis appears to be the only way
to alleviate the pressure of exorbitantly high electric power
rates in the private—power dominated New England area. We hereby
join in setting forth our claim to prior equity and option
as federal taxpayers and power consumers in this federally
funded TVA-type low-cost source of energy on our doorstep.
b. I further petition to set aside the entire area around
Passamaquoddy and Cobscook Bays, near Eastport (much of which
lands are now questionably claimed by the Pittston Corporation).
as a Tidal Power National Park, to be fully developed when the
power of the tides are ultimately harnessed, perhaps by so ite
future generation in the face of depleted organic energy sources.
Name ddress City State Zth
Ab i.& &v %k L th 5 OiL .
1JA ’ ° ____
L 5- L oi ’ EQ2Ctd J üM$rnA . b c . . ___
L iL
Q L £L
249—2
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249—4
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. Iwi, II4fthII ’* 4.
swo.. Ms i U*U
PETITION
Petition to Save the International Passamaquoddy
Tidal Power Site at Moose Island, Maine (Eastport)
and to Preserve it under Federal Tru t. 3ship U ti1
Suca Time as this Unique, Claan, Infinitely Renew-
able Source of Energy can be Developed for Future
G.enerations which will Face the Dilemma of the
Depletion of all Organic and Mineral Fuels
I affix my signature to this petition which I understand is
to be used in any forum in which it will help in any way to
effe’ct the forestalling and the ultimate preventing of any
actions taken by Region 1 U.s. environmental PDrtection Agency
(EPA), and the U.S. Army Corps of Engineers and other Federal.
Agencies, Bureau officials, elected off ice holders named in the
EPA’s current Environmental Impact Statement (EIS) designated
under the National Environmental Policy Act of 1969 as being
Application Number NE0022420, referred to in Public Notice No.
ME-Ol-77, issued and signed October 13, 1976 by Region 1, EPA
Director John McGlennon (Corps permit application no. 25—76-367).
My objections to the transferring of this heavily federal tax
ollar laden project being set forth all or in part as follows:
(A) At the site designated at:Moose Island as the proposed
International Passamaquoddy Tidal Power Project in the Army Cor s
of Engineers 1959 study and updated to August 1964, both submitted
to the President of the United States and the Secretary of Interior
is the one and only environmentally and technically feasible
site upon which the United States can participate with or without
anada in the harnessing of this massive, geographically unique,
free, clean, self-renewing energy potential provided by the over
wenty foot tides at Moose Island. This petition seeks to establiii
ndsave the federal taxpayers’ equity in this federally built
acuity, this one unique tidal site within continental United
tates where such an engineering feat is physically possible and
conomically feasible and needed.
249—5
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U) I further object to the giveaway of this federally funded
facility to the private sector, based on the fact that the tides
s an infinite or eternal source of cj.ean, low—environmental--impact
tydro ower will outlive all organic and mineral energy fuels known
on this planet at this time, and that therefore this unique
idal. power site is a literal monetarily priceless resource not
at this point in t.tm but far into and perhaps far beyond
21st Century for the life sustaining use by generations yet
nborn.
c) I also join here with my fellow citizens and federal taxpaying
) titioncrs in challenging cho GovernmOnt Account Office (GAO), to I
onder, either through members of the New England Congrcs i.or.al
)elcgation, or directly to this tidal power site preservation
rganizati0rt an exact penny by nonny accountin j of the dj pon l o
going back to the first federal. tax dollars Spent Ofl the site
acquisition in the early 1930’s and including $7 to $10 million
dollars spent on actual construction of two dams, a barracks
compound with dining hail and work shops and including supervisory
residential housing on Moose Island. I petition the GP%O further
that an exact accounting be given of the additional three million
federal tax dollars spent for additional “updating” studies of
the project in the ensuing years. the last of which studies beirfg
rendered as recently as 1975. I further request that the same
criteria of ccountihg be rendered with reference to the two
federal airport facilities which at this time also rest within
the site designated by the Pittston Corporation’s compound describe
in their application number NE .0022420. I further join with my
fellow petitioners in requesting that the GAO also submit documents
and signatures, chronologically tracing the history of the
decisions and authorities to dispose of this priceless federal tax-
payers’ asset in an unpublicized or certainly underpubliCized
manner in order that all persons involved in the decisions to pass
this priceless facility into the hands of the private sector on
the actual basis of prices less than one mill on a million
dollars (value based on the fact that this free energy facility
is priceless in the present ar.d future energy picture in the
Northeast), can justify to the federal taxpayers and the electric
power consumers of ew England the logic and motives behind such
249—6
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questionable acts at those consumer taxpayers’ expense. We
adamantly pursue these answers in spite of all pressures brought
to bear by the private power interests not only at the time of the
uiet disposal of this priceless facility in the past and in spite
f the current pressure by that same faction in effecting the
licensing of the Pittston Corporation to be allowed to build an
environmentally questionable oil refinery for the production of a
short term finite type fuel on the exact site designated the
r ny Cors of Er:gineers as bei the only feasible site in coritin—
ntal U.S . u whicft the tides can be ccoñr mically harnessed .
(D) Finally 1 I join in petitioning that this entire priceless.
ingularly unique federal tidal energy site, together with adjacent
lands and ii cluding two fr derally built airport facilities to which
titles have been recently transferred in challengable manner, be
set a iide and thc entire area designated as a tidal power n.ttional
(federal) park under the. trusteesilip type of protection of the
appropriatc federal agency and under the specific terms of intent
nd purpose of the site and facility, the terms being specifically
that this ;IricC].css free, rcncwablc energy facility be closely
uarded until such time as this or some future generation deems
it feasible to harness these unique tides at this one critical
geographical site in order to harvest the clean, ever beckoning
yield of free energy for all time to come while serving as an
energy—cost—yardstick federal power authority as has the Tennessee
Valley Authority in its region —. a region which still has after
four decades one of the lowest, if not the lowCst electric power
rate, in the nation.
Na:ne - Mdress City State
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249—8
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ri’riOs Loi’ ‘rii UUflL)UY 3 rI.I’ AT tONAL IIINI;Y v UAI 1 IOWI t(
PROJL CT AZ’ P’WOSJ V : 1.AflP (t:A$TPORT. HAl NI ) —
WIIIR}:A , the United t ito anti p.i rticul.i r 1.y r.hc, Northhu;Lcrn Suabo I . 1
‘ s suffered by reason of fuel costs and av ii1ability and thc fact of un—
conscion ibic hardship duo to plant closings; and
WHEREAS, the Northeastern Seaboard is and has been the hardest hit
area by such fuel shortages and excessive encrtjy costs;
Now. THEREFORE. we the undersigned residents and/or citizens of the
Northeastern Seaboard states and all states, as indicated opposite our
signatures, hereby petition our Congressional delegation as well as the
entire United States Congress, to immediately propose, enact, and fund
legislation designed to authorize engineering and architectural studies in
order to take advantage of more recent technological improvements since the
rendering of the 1965 Army Corps of Engineers’ study, in order to participate
jointly with Canada in harnessing Cobscook Bay, Passamaquoddy Bay and the
entire Bay of Fundy to their maximum yield potential of hydro-power. We
fuLLli r urye that the United States Department of SLate imLuedicltely ei Le
into the necessary negotiations with Canada for their cooperation in this
vital, mutually beneficial and environmentally clean, self-renewing source
of hydra-electric power.
We further urge that a reasonable portion of the $20 billion allocated
to the Energy Research and Development Administration (E.R.D.A.) be immediatel
set aside for this specific project.
.—.-— — — —
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ADDRESS
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CITY
A.
STATE
249-9
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T uER1;AS , Lh’ Uni. i 31a Lc and pa rt iculurly LIw Ntirlhea !;turn Seaboard
ha su fer U by reason 01 Cud co ;t . and .!vai l biliLy and the fact, of en—
conscioiiuble hardship due to plant closings; and
WHEREAS, the Northeastern Scabo ird is and has been the hardest hit-
area by such fuel shortages and excessive energy costs;
NOW, T!E1 ErORE, we the undersiyncd residents and/or citizcçts of the
Northeastern Seaboard states and all states, as indicated oppc’sito our
signatures. hereby petition our Congressional delegation as well as the
entire United State ; Congress, to immediately propose, enact, and fund
legislation designed to authorize engineering and architectural studies in
order to cake advantage oC more recent tdchnolocjical improvements since the
tendering of the 1965 Army Corps of Engineers’ study, in order to participate
jointly with Canada in harnessing Cobscook Bay, Pasuamaquoddy Bay and the
entire L y of ; undy to their maximum yield potential of hydro—power. We
further urqe that the United States Department of State immediately enter
into th ’ necessary negotiations with Canada for their cooperation in this
vital, mut ialiy beneficial and environmentally clean, self-renewing source
of hydro--electric power.
We further urge that a reasonable portion of the $20 billion allocated
to the Energy I esearch and Development Administration (E.R.D.A.) be imznceiatel
set aside for this specific project.
i r 1’I ow LOI ‘iii!; QUODDY I N’I’L:I 4A’I I NA L ruM)? Ti UA I. powi:it
__________ __________ i o i i:e’r AT Mno$n: i •;t.A 1I) ( 1 ;A ;’t’PORT , 1AI r-Z )
NANE ADDRESS CITY — STATE
249—10
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CALMS. MAINE
Gentlemen of the A,
I represent. the third eneratiori of Uno skeys that has
lived in the E .port, C;l is area. e are engaged in
retai1iri and rnal estate develtprnent and I n 1gement. My
family h s always been involved in trying to pron ot.e industry
for this area. They struggled h ri md ior to promcite
1nduatri l deve1 pmer.t, bu the results of their effflrts
were r*acre. The problems of distance to markets and
high power rates were hard to overcome. The lackof jobs
hda brought about n outmigration of our youth. Th tax
bases of th. towns ar.d cities in ‘ -ishington County have
not been able to keep up the inflationary costs of
providing municipal services. •Fhe economy of Wshington County
and all of 1 astern I’ aine is in a condition of etagnation.
The huge capital investment and the job opportunities th at
wouci be afforded by the building of an oil refinery would
be the great;est economic stimulus that hi ever been proposed
for ;mShington County, )e know that modern refineries can be
good neighbors as well as good employeL’6. The EPA and the BEP
are the jeople’s guardians and I hive faith that they will
make sure that Pittston carries through on all the safeguards
proposed in their plans. We want ev ployment and we want a
beautiful undespoiled Eastern Ilaine. There i 7 no reason w y
— A —— — — -.
251-1
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ISTIUCT
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DISTRICT 41-0
MAiNE irnd NEW I3RUNSWICK
UONS iNTERNATIONAL
ULLOt4 C PO W
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C*ws. MA*NS Sl I
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RICHARD V. DREWIA
I cIiasp Pa D*,bi* G,v,n,nr
4 i P. 0. lot S)
Environmental Protection Agency Hearing
The Calals Lions Club is .Dst appreciative of this opportunity
to express our position on the proposed construction of an oil
refinery here In Eastport. Our club would like to go on record
as supporting the construction of this refinery.
The primary reason for our support Is the e loyment opportunities
and the resulting economic i act whtch this project will have
on our area. Most of our club’s annua! projects are designed
to help needy people both inside and outside Of our comeunity who
arethe victims of very law annual family incomes. We feel that
the direct eu loyment opportunities associated with the construction
and operation of the refinery and the resulting expansion of
retail and service Industry job opportunities wifl help increase
the family incomes of our region. As a result of higher family
incomes our people will be able to afford a better quality of life
which will mean such things as better medical and dental care,
better educational opportunities, etc.
While we are much iware of the positive aspects of the refinery,
we are also aware of some of th. problems which might result from
the refin.ry.
252—I
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E I$TiUCT
41
PRINCE
NEW
IRU*WU
REGION ONE
INIAD VIOLEITE
lay Dütiitt Go’vrnoe
Si. Mao*w ts *
lINE 3. BERIJBE
chai.aa - Zone One
Si. Vai lu,r..
IHUP L. WILLEY
chaia.a. - Zone Two
Dua l
REGION Th0
‘cIRCE V. DUBOIS
lay Dimite Gone,aue
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IC) !. NIcICE*SO 4
chal... - Zone One
.716 W t TOC
IIAISES BO(JTOT
hal .- Zone Two
MATTAWAIIKOAG
REGION ThREE
AID V. UPTON. JR.
way Dimict Gomoot
t I.. F.aay OILAKO
‘ M l 0. HIG( INS
• . Zone One
- iS i. PLL1 OSTN
IIHN F. PARMER
uinuu. - Zone Two
cHARD !IALSCIA
lONER LvlII.ANC
RrNcE LYN3UR 4ER
tRLltN SAVAGE
c i Adviaaey Committee
•*LRT CRAWFORD
p Cha ,rmia
4 An CA.tou
J($W! OOMBS
.: lebtium Chairmin
hi ,. Si. BM.GOS
lET PORTER. P.0G.
‘i*tmi ’,. thait*an
SEPH SLEEPER. JR.
LEO Chai,m.an
iT. CA.tlIOtt
C1 LYIE1IURNER. PD.G.
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I. .e the at (.hjiaman
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CALMS
PAIl!. DONOVA 4
ii , iwh,nte Chi,rmin
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PIUN S1MP iON
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Att. It , ‘wt.ui , ,
74 A. TIMPEIN. . I’ll)
“ Mai,e Chairman
iT. Pir ou, JSLI
DV. IIRISCIA. I.P.D.(..
A! ( at . (Litman
(Aptpou
H.%IIAZ4 SMAI.L
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UT NiRTER. P.0G.
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RIBSIL a),.TAIT
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IiI1LLA hEWN! i cEY
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DISIRICI i.i.t U —
MAJNI ’ :uul NE% ’ B1UJL’ S V1CK
LIONS INTERNATIONAL
0. T. “$ilr AVERII.L. JR.
Di tii.t t..oweritot
P. 0. liox 9
M*cut. s. Mu N i 046 4
REIJ.OM C. POWERS RICHARD V. ERESCR
Cahiiwt Svrrctary.Treamrec Inmwdiate Put District Governor
12 FSANKLIN STUEI!T P. 0. Bcax ico) CA IIS0U
CALMS. MAINI 04619
-2—
As a result of the construction phase and post construction
phase of the refinery there will be various pressures on the
social economic structure of the region. It Is our belief
that the citizens of our area have the ability to cope with
these pressures and to minimize any negative Impact which they
might have.
In conclusion It is our opinion that the economic benefits of
this project far outweigh any problems which might result from
the construction of the refinery. We therefore, respectfully
support Pittston Oil Company’s proposal to build a 250,000 barrel
a day’refinery here in Eastport, Maine.
252—2
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U. S. nvirnnoental Prot.’ctton *g.ncy
Joltu P. J.nn.dy Ruilding
lo.tnn. P!as..
sntl.m.n:
Ny name ii Harold Kisser, •rid (or tPose of you ho do not know
!e, I ci’ in tie Tnusras ce busirtene to *fl *II t, : ‘i.U r mri.I er Lir the
•en4er ’n Agency Ira. or Calata, an amq,e t e Ea.itport : c .
I am 49 Tears old, have lived in ‘autport, c’rse to scnoo ., worked,
.1 nsd up for unemployment, and gone through the trustriitiona of
living in tht area since my birth, these qualifications I reel
•h•uld carry more weight than those who haven’t lived here long
enough to -st the .aell of the big city out of their heir.
It semo that I have stood on tbt. floor more times to fight
f’— emithing for Ka tport, and got less satisfaction, more discoura ed,
hit m e !eter,’ 1n.d than ever, that this refinery be builti
I bore yet, people noticed, en you drove here the scarcity of
•atirr rl.ce • lace, to lodge, end the type of hiChwa, you used to
-.t Pee. These are but a fe.. 01 th. things to think about in your
eva] ’.tior of tP. impact Pittston, or any other 1ar s conpany would
‘eve, wio oull locate in astr ’ort. As lIttle tine mi’ 17 years have
for. l’v h.’r. e ha ’ all these. thi? ge. s had two reitaurant open
all year rotir ——we had a theater——a bowling alley——a shoe repair shop——
so—s do -tor • and dentists—6 sardine packing plants——3 fish processing
plante and over 500 more people than today.
Pow all we have 1 ths apathy that goes with a comnunity
•tru çlin to survive, and the type of peep1. who are very eloquent
in their conversations, and writings, but fax short of the swers for
233—1
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(2)
er m ena other than Pittston, to get this coamunity off
its b.ek, • ei on its feet again. During this hearing yot; will be
‘etering to these people, end as present citizens of astport they
ave a right to be heard, but I would ask that you please consider
t-e f ’IJrce.
‘trrt: The retired, most who live nicely off past income earned in
a r ore lucrative area, thin group ranges from those with no
interest in the economy, and problems of the comrnunity, to
en intense interest in keeping everythint out ic ould
provide eriployment to those who need it.
.cond: The environmentalists, who are fine people, but seem to lack
the common sense required between ecology and eco cmy. This
group includee many voicea—from the retired who craw fixed
incomes, snd still work, to those fortunate enough to have
soneorte somewhere ttr.anctally well—off supporttn them.
Third: The younl, who mean well, but have yet to realize, noting is
for nothing, end haven’t ha t e veaponsiLlittea of earning
t e1r o n way.
r I . 1 ‘P Is comnuntiy survive with thin a a they are ‘today r Can
‘ -“rr’ r ty i urvive with the type of peo ile who woul(i eny us the
o tu 1 tt’ tc catch u ’ with the rent of th Unitea t te ’? Most of
‘i oul’ nettle just to catch up with the rest of t e t te of Maine!
Ce t ’ is conr.unity survive much lon er on the ::inii.”n this for
7 ! nr1 of the yeir? with the remaining 5 months on unemployment?
I w ’.ill doubt that it could for very much lon er. For 5 months of the
ye y R5 of .he work force In this area draws or trys to craw some
t unsm’loyment, “hether it be federal or state aid, surely
•rit ’nr is sn improvement over this type of situation. Pinally, can
253—2
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(3)
tkls ee emunity survive, when the young, who are wrbitioue, graduate
tra hiph school, and college óave V’. er , bø au e there are not
•reu ’h sobs available for thea.
Thi alternatives are few, either we take the Oil Refinery,
,t.r. ginr by ready to go, or continue on the wa we are now, depending
core and more on state and Federal money to survive, or we could look
.“.‘id! ‘think what the tax dollar8 from this company could do for
‘,toort, and the surrounding cOmmunities! In Eaetport the projected
t.z tP’ t would be available in addition to the k million ‘e receive
ma , would be 4 million dollars, what a good city governnent could
4 ” tth that!
You .ol. can help us, we need favorebi. re.ort, and we need
V’s ennnrtunity to bring this community back to life. I have an
horept love !or Zsstport, I ’ve lived for 49 years, I’ve seen this
s ha’oy er.d roduetivs place, all i see now, in decay,
r. ination, I’d like to see a tj;ort be a proud
litt)e cit. .gath, with your help we car.
253—3
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—- -. . - -
- / ‘ 76
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254—1
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254—2
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ACTION AGENCY
P :
1
HE ACTION AGENCY, REALTORS = P. 0. BOX 302 = MACHIAS, MAINE 04654
De cemba
Mr. Wallace B. Stickney
Director, Environmental Policy Coordination Office
U. S. Environmental Protection Agency
John F, Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. Stickney:
like to) j!etter entered in recçrd
o the testimony received on 3sd, *4 E stport, Maine
and concerning the application of the Pittston Company for con-
struction of an oil refinery at that location.
I would have much preferred to testify in person, but after spending
ten or more hours waiting, my patience ran out at l0 45 P. M. I also
must say that considering the abuse given, (especially from a Mr.
Dorchester and several others) the patience shown by the committees
was certainly remarkable.
How to get down to the business at hand:
First, I am a native and lifelong resident of Washington County
(43 years) and my profession is a Real Estate Broker and farmer in
Machias and I wish to make the following comments:
1. Contrary to what you were told, December 3rd . 1976 wan
definitely an unusual day for that time of year, the wind being much
stronger than usual and also the sudden drop in temperature. We may
experience an occasional day such as this during January and February
but it is an exception rather than the rule.
2. There appeared to be a great many people in favor of a refer—
undum vote of the people. I do not oppose this, but would ask that it
include the entire County since the impact of an industry such as this
will be felt throughout the County and certainly not contained within
the City itself,
3. 1 have read the DEIS and find it satisfactory. However, you
must understand that many of us do not understand the technological
explanations or particularly what they mean. Certainly you must also
realize that many of the people testifying are ranily not qualified
• to make some of the statements that were made and that there was a
great deal of emotionalism involved.
..r.
255—1
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—2-
Kr, Wallace E. Stickneys
4, Relating to the allegation that crime will run rampant in
the streets, I strongly doubt this. During 1959—62 there was an
additional 1200—1500 construction workers (with their families)
lodged in the Machias area during construction of the Cutler VLF
station and the fact is that therw we. much 1.sa crime in the area
then than there is now. s to prostitution, X have a feeling that
the laws of economics apply to that profession also, thus it would
*ppear to as that thi, type of busines, would not do wel] in the
area.
5. As to compatibility of th. project with the oft proposed
uoddy dam, it certainly seems obvious to me that if we (this county)
have the know—how and technology to put peopl, on the moon, then
we can surely operate Quoddy and the Pittston refinery jointly and
with no hardship placed on either one. In fact it has been said
the Pittston refinery could be a real asset to Quoddy because of the
tremendous amounts of petroleum products needed during its (Queddy)
construction.
6, I do not see a danger (if that is what it is) of Washington
County becoming involved with an industrialized society (so—Called).
As you are probably aware the Georgia Pacific paper mill and stud sill
complex is within 25 miles of astport, employs sore than 1500 persons,
and if you drive over there, you would probably have to look to find
it.
7. Xt is great to consider Canada, our neighbor to the North,
but say-be it is time we looked out for our own int.rests. Presently
Canada is bringing in wood products, blucberries, fish and nany
other items, duty free. However, when we here in the United States
wish to do business in Canada it is a different story. I think it
is time that our dealinas with the Canadians became a two—way street.
You ma also be interested to know that there is a successful fishing
industry within a stones throw of the Irving Oil Refinery at St.John.
In light of the above, and based on other testimony and input that
you have had, I wish to go on record as being in favor of the Pittston
Company constructing and operating an oil refinery at Ea.tport, Maine.
Resg ctfully s bsitted,
XM l/ed
.G. R. I.
255—2
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NEW ENGLAND
COUNCIL
STATLER OFFICE BUILDING
BOSTON, MASSACHUSETTS 02116
617/542-2580
EDWARD). KING, President
November 1, 1976
Mr. Wallace B. Stickney, P.E.
D1.reetor
Environmental Policy Coordination Office
U.S. Environmental Protection Agency
Region I
JFK Federal Building
Boston, M 02203
Dear Mr. Stickney:
The New England Council wishes to introduce the following statement
into the official record concerning the Environmental Impact Statement relative
to the Pittston Company’s proposal to construct an oil refinery in Eastport,
Maine.
This organization is composed of business and consnunity representatives
from the six states comprising New England, and has as its prime charter responsi-
bility the economic development of the region. It is a non-profit organization
funded by the private sector, and at present, represents some 2000 member firms,
executives and community organizations. It maintains its central offices in
Boston, and has representatives itt Washington through its l ev England Council
Economic Research Office which directly interfaces with the New England
Congressional Caucus. In addition, the membership is divided into state member-
ship caucuses called state councils, and several involved couznittees which bring
together the area’s business and. community representatives to focus on specific
issues with the best talent and extended experience available.
It is within this organizational framework that the Council has viewed
the region’s ener r and fuel needs in general, and more specifically, the
Pittston’s Eastport refinery and deepvater port facility. The weakness in the
region’s fuel infrastructure is well documented and need not be repeated here.
The factors and statistical documentation is readily available. What is not
readily available is a comprehensive appreciation of the need for an in—region
refinery capacity. We presume to suggest that we can accurately articulate the
views of the region’s economicinterests in arguing for such capacity. The
New England Council is fully supportive of the Pittston proposal and wishes to
be recorded as such.
ADVANCING ALL FACETS OF NEW ENGLAND’S ECONOMY
THE
256—i
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!fr. Wallace!. Stickney, P.!.
Page -Tvo-
November 1, 1976
The New igland area is literally a totally import region for oil
and oil products. This dependence places it at the mercy of price, availability
and international vagaries well beyond its means to influence, let alone control.
A locally based refinery vould respond in pert to these concerns. It would,
at a minimum, provide a measure of guaranteed availability for the product
whatever the national and international considerations are in place over the
next decade or more. This is a moat important concern, as the availability of
product, in necessary terms, will allow for sound business investment decisions
in terms of capital formation, capital investment and job creation across the
six—state region. In addition, such a refinery can be expected to provide
some a1 1 fue]. transportation savings 80 essential in an area with high
transportation and transfer costs.
In addition to providing the above, a refinery of the dimension
proposed in this proceeding, would also allow for additional east coast
refinery capacity should the oil exploration of the east coast find substantial
reserves in excess of the current refinery capacity along the Atlantic coast.
This would provide a capacity potential over the long term, perhaps into the
mid-1960’ s.
Oil and ener are the essential and perhap. moat critical ingredient
in the shaping of a viable New gl*nd econaic mix. This region is truly
ener dependent upon influences outside its geographical or politics], sphere
of influence. It needs to develop a local structure and capacity to meet its
ener - needs. Pittston is prepared to work within this cent ext.
The New igland Council wishes to be fully recorded in support
of the Pittston application, and is prepared to present additional support
if necessary. The Council urges your favorable consideration of the necessary
environmental impact statement.
Thank you.
EJK/jw
cc: Zeb D. Alford, Chairman - Fuel and er Ccittee
William 3. Kirkpatrick, Chairman — Maine Council
John D. )bore , Vice-Chairman - Vermont Council
256—2
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THE
NEW ENGLAND
COUNCIL
STATLER OFFICE 6UILDING
8OSTON, MASSACHUSETTS 02116
617/S42-2560
EDWARD J. KING, President
1,
December 3, 1976
U.S. Environmenta]. Protection Agency
Region I, Enforcement Division
Permits Branch
John F. Kennedy Federal Building
Boston, MA 02203
RE: NPDES Permit Application #ME0022)420
CORPS Permit Application #25—76—367
The attached statement represents the official position
of The New England Council for Economic Development conoeruing the
Pittston Company’s application for the construction of a refinery
in Eastport, Maine.
May we request that the attached be made an official
part of the record of the December 3, 1976 hearing.
EJK/jw
Attachment
Thank you.
a.,
ADVANCING ALL FACETS OF NEW ENGLANDS ECONOMY
President
2 56—3
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STATE? NT OF
EDWARD .J. KING
PRESIDENT
THE NEW ENGLAND COUNCIL
December 3. 1976
256—4
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The New England Council would like to present the following
viewpoint for the Environmental Impact Statement on the Pittston
Company’s proposal to construct an oil refinery in Eastport, Maine.
This organization is composed of business and co unity
representatives from the six New England states, and has as its
primary charter responsibility the economic development of the
region. It is a non-profit organization, funded by the private
sector, and currently represents some 2000 member firms, executives,
and conmiunity organizations. The Council’s central office is in
Boston, and it also maintains a New England Council Economic Research
Office in Washington, which works directly with the New England
Congressional Caucus. The Council proper is composed of several
conmaittees designed to research and formulate policies on specific
economic issues; while the Council’s membership is subdivided into
separate state councils.
It is within this framework that the Council has viewed the
region’s energy and fuel needs, in general, and the need for Pittston’s
Eastport refinery and deepwater port facility, in particular. The
weaknesses in the region’s fuel infrastructure are well documented
and need not be repeated here. What does need repeating, however,
Is the fact that the establishment of an in-region refinery would be
a crucial step towards eradicating those weaknesses. We presume to
suggest that we can accurately represent New England s economic interests
regarding such a facility; and we would, therefore, like it recorded
that the New England Council ié in full support of the Pittston
proposal.
256—5
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-2-
New England is primarily dependent upon imported oil and oil
products, and is therefore at the mercy of international vagaries
in costs and availability - factors which are well beyond its
influence and control. A locally based refinery would help relieve
this situation. At the very least, it would provide a measure of
guaranteed availability for the product throughout the next decade
or longer, irrespective of national and international considerations 1
This is a monumental concern, since foreknowledge of the availability
of oil will permit sound business decisions in terms of capital
formation, capital investment, and job creation, In addition, the
refinery would provide some small fuel transportation savings which
are essential to an area with high transportation costs,
In the event that oil exploration in the Atlantic rea’ lts in an
increase in petroleum reserves which exceeds the current eastcoast
refinery capacity, the refinery under consideration would also serve as a
supplementary storage facility. This additional reserve potential
might well sustain our storage needs until as late as the mid488O e
Oil and energy are preeminent in the shaping of a viable New
England economy. The region’s energy supply has been far too vulnerable
to outside influences, and the time has come to begin a new era of
self-sufficiency. Pittston offers us the first step towards energy
independence.
The New England Council wishes to be fully recorded in support
of the Pittston application and is prepared to present additional
support if necessary. The Council urges your favorable consideration
of the necessary Environmental Impact Statement.
256—6
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DEC8 76 ( /V
THE MERRIU. TRUST COMPANY 181 MAIN STREET I LINCOLN, MAINE 044571 207-794.8529
JEREL ARMSTRONG December 3, 1976
United States Environmental Protection Agency
John F. Kenmiy Federal Building
Boston, Mass, 02203
RE, Pitteton Oil Refinery Application
Gentleaeru
Until my recent promotion I was for almost eight years the Branch ?iin’ .ger
of the Eastport Branch of the Merrill Txu t Company and thxu my roil as a
co rical banker saw a steady decline in the economy of Eaatport. I be-
lieve the statistics speak for themeelfi.
Maine State Government Annual report for 1975 stated that during that year
15 new w tifacturers announced locations in N’i [ nA with 16 existing finns
expanding for a total estimated new jobe numbering 1,518. None of these
were in Washington County. For the same period Washington County showed
a net loss of 100 jobs
Looking at the unemployment on a 5 year basis (1/70 to 1/75) the State
Planning Office and Division of Economic Opportunity found that Washington
County had a mean unemployment rate of 9.3’ which was the highest rate in
the State, significantly above the State level of 6.(% a id the National
level of 5.3’. Eaatport unemployment rate alone was 17.3%. The situation
is best described this way “ Por several years Washington County has ex-
perienced very lIttle irduatrail development, a high level of unemployment,
limited job opportunities, out migration of its young people, aid many other
serious problems. In reviewing present economic inlicatore, it appears that
Washington County will continue to have abnormally high unemployment. Ex-
pansion programs in existing industries accompanied by increased job op-
pQrtunities would undoubtedly improve the area’s ocomy, it economic level-
opment on a large scale will have to be undertaken if the present economic
picture is to change. In assessing the outlook for the future the most
important issue in eastern Washington County will be the possibility of an
oil refinery locating in Eastport. An economic development project of this
magnitude could have a far ranging effect on Eaatport, Washington County, aid
adjoining counties, Unless a development of this scope aid size does take
place, it is very unlikely that the unemployment in Eaatport aid surrounding
communities will decline in the future.
A ILL BANKSHARES CO ’ANY AFFiLIATE
257—i
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Page 2
Th. 1970 Census figures show that moose, of Washington County residents were
the lowest in the stat, Ze8.8% of the flailies had moose less than $6,000.00 a
year, way above the State figure of 30.7%. Washington County had the highest
percentage in the State of po u1ation below the Federal poverty level • Their
rate i s a 22. while the Federal rate was 13.6%. stport’s rate isa 39.6%
and it has not isproved since.
La of October 31, 1976 21% of the population of Washington County and 23% of
the stport population were receiving sose fore of State or Federal welfare.
Again thss percentages are well above State and Fede .l levels. Diring the
first six souths of 1976 our -‘ . - t one distrit*zt.d in Washington County
Federal Thod Staaps with coupon islu. of over $1 150,000.00 of this figure
the D.stport area share i sa well over $200,000.00.
It h&a been said eany tine. the Pittston’s application for an oil refinery
in stport is NOT that oo nii ties last rthance for econcaic developeent
and that the citisess of stport have not taken an active role to pro.ote
other types of develoisent • This state.ent is wrong because stport HAS
been vezy active for years thru it’s Chasber of Coerce, PlkIIT i ng
C .m1ty Bettereent Coittee, etc. Just as an exasple of stport ‘s rejection
the Industrialised World, several years ago I was Co-Chai n of the
C -m4ty 3stt.i .it Coesittee and thnz the help of the State ] paxtaent of
Ccerce and Industry we isiled letters and oo”ity profiles of Dstport
to o r 15) o spsnies in the Electronic field that were reported to be
interested liPlocation and/or expansion • Of these 150 plus only 10 or 1...
replied, only to say that they received our profiles and letters, were ispressed
with the profiles bit th* to atport’s Geographic location they were not
interested.
FOr the interest of Washington County and Ilatport I urge your a zoitl
of this sest vital project.
Thank You.
Sincerely.
L. A trong
P zsger
257—2
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23 Stony I-il I I o.d
Port Jefferson New York
November 3, I9 6
r.’ew England ‘)ivIsIon,ij.S.Army Corpsof Engineers
424 Trapelo Road
‘Maltharn, tassachusetts 02154
To all It may concern;
W v public comments regarding an oil refinery in Eastport, t. aine———
Reasons why Pittston Co. of New York does not belong on the coast of Waine
FINDINGS & FACT & 0 DE
, . P.
L epr. o EnvI,nrnental protecf ic’n
I. Cip3CSItiCfl tromCanadi.n ‘jov’t tc resolve issue of ‘ssa ftrcu—I
Canea.
2. Solid waste— DesuIphurIz — rr nswer, “ unlikely to live up to ex—
pecf t1 ns
3. Cffenslve ... dcrs— ac u tz e ssin c nfrti— r.y aswcr, flunlikeiyW
4. C!.ar cter ef • plice’nt— ”P cr reput ticn to live up ic H —h stanf rc ’s”
5. Traffic!.cverent—z rc f fi: zs, fcj, w ett.zr/ rrcky s} orc r kcs
!e t - rt one cf I c ;.cr •.irficult c•rts in fl.c icrlc. ” Excelleft
rcas n :t s Pittston shcuid nr.f .e .,ilrw v Infr H Is r .. The tlce
weat1 zr cU! :l ti ’ ns v:1 II lirit t!’ flu: “er cf 1r1’s . th t’ eir v SS’ Is
an they, fh r:fcr , r y f ir st thc l’e set s1rz f r then n
create desasfcu ’ y tekir their c uct s f by exlstIn C p’r!y.
Lu ec esIpcrt m, y ex erIence fire h zords the re net cc i. le to
han I .)
6. CII S.—i Ii!— alv: ys ossI’ le sn-’ llJcty tc occur many times cver, why
submit the undcrlyin sea to ay Its toll in gradual death and decay
Evidence ap,ears to have more reascrts against than for an oil refinery
on the untouched, uncontaminated coast of 1 .alne.
I do not feel that thc Pittston Co. wi lI live up fr their part in keer—
$n :alne safe for envlrnmentat purposes and protection, but will only
succeed In doing what Pittston wants for Pittston. Like the NursIn Home
scandals of New york City , the profits are for the Company and when if
hurts their pocketbook they will not keep up with the j high standards
you may impose upon them and will enevltably fall back on lowering the
standards to the east possible amount neccessary which likely will
elevateOffensiveOdors, etc. etc. etc.......
To reconsider a &j ’ at this time is of utmost importance. )Ihy should
Pittston do whats best for Pittston, why not taint do whats best of tame.
Overpopulation being what It is it is the necessary time to reconsider
th. impoTtancc of an electrical OWCT plant, and will certainly bring
In nccccssary jobs an keep the coast of P 1ne clean md Pure.
Ltlbl.Jl.*
258-1 ,
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STATE OF MAINE
Department of Environmental Protection
$
pI : MY !UNS . NSIYAL PMST.*SSNIA
. - _ - _ : ‘
____ October 18. 1976
‘-I
P’ks. Russell Stagg
___ 23 Stony Hill Road
Port Jefferson. New York 11717
N flT UW SI
s_I ft
a • . .99.
This agency appro’ ed, with conditions, the Pittston Co any
proposal to build areflnery at Eastport in decisions rendered
in 1975. I have enclosed a copy of those decisions for background
information. To date the cc any has de no effort to fulfill
the conditions pnding r.ceipt.of required federal permits.
____ Wearings on those permits will beheld in Eastport on Dec iber 3.
In addition further state permits for water and air discharges
L P I 3
_______ are required So we are not in a position at this point to say
ien, or if, a refinery will be built. A major renaming
st* ling t ock Is the stated opposition of the Canadian
govern.ant to allowing tanker passag. through their waters to
get to Eastport.
I hope this Information will be of help to you.
Sincerely,
9 Ja w
Nanry E. Warren, Director
Bureau of Land Quality Control
.s4oy
HE ;1dp
Enclosure.
258—2
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Wovember 3, 97o
December 3, (976
REAS NS HY P1TTSTC OIL REF INE Y DOESN’T BEL 4 l i EASTPO T, t!AINE
The b st way for me to describe how I feel about the ccasf of
i.aine is to take writings from books of popular authors exactly In
this re 2 ar J.
I. Louise Dickenson Rich— “State of t aIne,” “The peninsula,” and last
but not least , “ The Coast of lame.”
W dern life is increasingly corrupt with motive and profit and
contempt, but the coast sf1 II has kindly habits, a strong heavy sea
sme I I,
Summer folk came and bul If cottages — the people who nede Bar t arbour
Into a resort had no interest in t:aine life or tradition and were sim-
ply buyin9 a bcautlfui site and climate for their )i own worldly
pleasures. They succeeded in distroying it. -
The State oficaine has persaudcditself to print “vacation “on It’s
license plates recreation business ) its selling its own birthright.”
. Gerald garner Brace— “The Island,” “Between ‘Jind and Water”
N The r ost dramatic play of coastal weather Is the northwesf rncr,
the “cold front” that sweeps downout of Canada with a rush of artlc
air. The big ones go on for two days 4 nd two nites In the winterthe
intense cold comes with them. perhaps of quality of clear dry air with
itisome}randeur.
-3 ,t ncthing In the world’s Ian or s a Is more beautiful than
we+ef—* the mornings after a grent northwcsterner. The air seemsfresh—
er, the water an intense blue with pale infinity of the sky. The
l.aine cc st in the winter can se..m oppressive with a week long north—
westerners ani with zero diys and nites or with northeasierlies blizzards.
3. Clinton Trombridge— “The crow gsland jcurnat”
“ An is l n is it’s coast— it is th tide r-ore that anything else
I iVS t ’c nlc cca ir f 7 ur,h,3raIiV 1 - S 5 t’r t jf o szsses.
Rocks and ledges provide a solidity to which olants and animals
aii è m y ctingwhiie ¶ w if fc7TWc foild ti e”f give them TIfe again.
To toii spe 1 Thr ure,tc b nccnsC1OuS of its gIcryT TC”
be miserLy with its opulence Is to distroy our hold on the planet nd
losc th -: sense of wonder an 4 respect for life that ire the basis for
r I - - - s a • F ‘ ‘ r : I I II “i n I n r c i h ‘ l s s
; ;a; . i•h c J; rr’v •‘z -r o jr i r; er;.
ir , thz r rnote future we may Inhabit a v3 5% isneyland m d take our pleas-
ure in c servIng pneumatic wildlife and plastic mcuntoins an:! artificial
sno . a lien s merely a dream. So is the coast of lame.
any will cling to I t’ in sent imeo and longing In order to escaPe!\Ihe
anxi tics and compulsions for a ico crowded world.
Typed by Louise Stagc of Port Jefferson
Long Island, New York
258—3
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Testimony of Btlaa Bttsssn. - Zastpert, Maine Dec .31 976
Governor, y.ur LordJhips , and neighbors:
I’ve acme b.ez’e to say a word for old Ltgktutn’ and his buddies. Public
meetings put a lot of pressure on us, we sort of like to vote on these things,
quiet like. We voted old Lightnin’ out last time but he didn’t seem to notice.
Most of us are scared shirtisi. that we’ll get our neoke out for no reason.
Jothinç we say ever makes no difference, anyway. You people get our names
and we re sunk. Jo stamps, unemployment benefits, no town jobs, no credit,
no nothing. I just can’t set myself againBt all these money b078 and get
myself boted. I’ve get three kids to feed and I have to live with these
people and they hold the power —— so you see, what I’m eeyin’ is I’m scared —-
but I’m going to have my say this time. This here oil refinery is no good.
I’m no educated man like you grand government officers —— I just figure you’ve
made a mistake because you don’t live here. You see, Lightnin’ and Beans
and these guys make their living bullelinging. Ain’t no hare in that -- I
do it ‘i’v ’.if on occasion. They buy and sell. They’re trying to sell Bastport.
Ain’t no harm in that,-eithör. Juat’*. didn*t think anyone would take them
seriously. You know thsa Chamber of Commerce types! Always big dealin’.
Well, it ha. occurred nov that you fellas are all the way down here, that
something desperate could happen. Mainly, we bad relied on your good sense to
humor ‘em and sort of lit them f.sl ilk, big shots and then lit th. m down easy
so there wouldn’t be any trouble. Jot your fault, undsretsnd-’we Vt 3 j
sittin’ beck haptng.tt would all blow over sorts like the fuses frog the
refinery stacks. Mostly we farm, work in the woods or fish. Can tire a man
out, you know. These town boys hardly sv.r get tuckered out taikin’. Take
old Beans -- he osn talk .11 night! My bead hits the table right after
dinner. Anyway —— why don’t r.u just let thee. old boys go? They didn’t
u .n no bars. They just dtdn t nails. the p.isens in them gases. Th.y
wouldn’t want to kil us. They’re just country boys that got had by- that
old ulko.s. He outplayed ‘em fair enough. We’ll give’es their money
baek. J• questions. We just don’t want a big mistake to come down on us
and the kids. You see, we , here. Ain’t lik, the city whire it don’t
make no difference what air conditioned buildin’ you’ro in. Tan laugh-—
but vs got sort of a way of life down here. Ain’t easy — - but we seem to get
along. Beats workin’ in an oil refinery. No offense-- but if you work fishin’
farsin’ ar loggin’ you sort of don’t go so good in a factory. Sort of takes
a man’s tndsp.nd.no. away, somehow, lever could hack It up there in
Connecticut — - couldn’t watt to get back down here. !athsr elan than mak
guns in on. if this damned factories, any day. Well, why dQn’t you C.Z1as just
go away and we ‘11 give the money back best we can and no hard feelins’ • An
oil refinery! Lord, we have enough trouble breathing that junk that roil.
in here from the W..tard now!
259—1
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Robert B. Jackson
Csmjed PM Wit Atc.ai u nt D
Pleasant Stteet
Monmouth, Maine 04259
(207) 377.2794
December 3, 1976
Permits Branch 1 Enforcement Division
Envirorunenta]. Protection Agency
Kennedy Federal Building
Boston, Mt 02203
Ret Proposed Pittston Refinery
at Eaatport, Maine
Dear Sires
Based upon pure economics, this proposed refinery is
in the wrong part of Maine. The area has no transportation
network and if all transportation is to be by ship, actually
presents environmental dangers not related directly to the
refinery operation. The local harbor pilots claim navigation
is dangerous, normal tankers too large, and combined with
local, weather, it is reasonable to expect groundinge and
spills far above necessary or acceptable standards. The
additional coat of this inefficient project will be borne
by all consumers and the real environmental dangers plus the
cost of attempting to avoid these dangers is just not worth
the project.
Thank you for your attention.
Sincere ,
Rbart 3. Jackson
260—1
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TOWN OF ST. ANDREWS
• POVPKE OF N( SIUNS’WICK
ST. AND VS, Pt$.
December 3, 1976
?4r. John t4cGlennon, Director
EPA Re ton I
.?olin F. Kennedy Pui1clin
J3oeton, ?‘.ase. O?2(fl
flear tir. McG1ennon
T writi,r’ tr ‘ xor, s thc con’ ’ri c’f thr rp5triqv,ts
of the To’.m oC St. %niire rn to th’ Pitt’t,nn r n vyr nrono .,i
to huild ,n oil rr’.fth r ” intl ri rin t iiin l it t.oort,
Puma. like W.Aetnort, St. Andr m h q ‘r nn ita fortu te1
eo n md ‘o i:lth the nrosnerjty of th” inh’ rt s ntl
vo ntsit t.r din , ut u rnm 1n ccrnviiv ’ r’ th t thn futur
nroen rity of the rc ’t( n d’ ” nQt lie rith iiir tri 1i tion
of th tync th.’ Pittston Cornn ni. ‘ rono’t -’. urth”-’ior , th’-
draft. trt ’ntn1 ]‘ioRct 53t:itr ’r,t do”q n thjn- t rv’— i,-p
rn thnt thn t o’in nv c n oo” rit’ ‘ ‘ ch a r o in 1 I t i”t
serious rLak to the envirnnrnent o ‘hich todo’”’
prvsp rit’t depend .
Our princionl re’-ional ir duetr1.re re Wjqh rj
Pornitrv.,nd Touri which dnnind aheolut€ lv on clv’in
and clean * tr,r, nnd a et’-nific,nt. fret t.1v n o t. t”e’io
pr( r) y j, with th virious hir’o—ic,) rn ’ rr.h -r i tu hi1
intJtitut Mns which • re 1o ,t’d hr re hr,c ius of thr unsnojlcd
and rorIuctivn watnrs which iurrnund u .
ve fi nlv convinced that ‘ ,hr rt t!” likr ’1.v jrinir ts
(f th flrOr)O5’ I v -n nrnnr’rl” 11I3 lt(’ , t- i’i)l h ’ ‘r th t
1.hr’ tncv t ’,l” i ’r1.or tton In i mr’ ‘ ‘r r
a re’ton il nc tl .n rind thn rc!onn,ltr eOn ‘i r ’-r r prnt b’
IunttfIc d cjmntv ‘ ‘ thri r t rin 1 hrq r fj ccrut”— t’
r r tflort rrnd the Pjttsto , Cnmn n’r. “ ‘ ‘ uld f”r r th r
i r,ti ’v ’1 joint. civv”lnrwv nt of oip ,,t,r 1 rrnr’y’bl’
1r r , rn, th’t i . n -— - ‘ —
nut nil l v ‘ r f r t.hr t.tr’t q’nt. nr the’ re’ i i
flhIj’f ).vlr”r’l,,
(Ii — ’
? .k
Tl . ‘ ) ifl
TI A V 0
Co!’ri o to: Cfrtmhnr cf
Hon. ‘toniclo T.n’flanc
Hon. 1km J irtienon
- C flr, - T j%I,l T’
2*1 —i
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è
i4hitthg Box 20
Maine ( 69l
.te ion 1 ?ermits i’anch L)eoember’ Li., 1976
U. S.Environr erita1 ?rotection 4ig€ncy
Boston, Xassach setts
)Iar Sirs:
All of us her. in the Northeast coastal region
or Maine share three Goa-given blessings which the people of
the rest of this country may never have ha a, or have
sacritioea to tne greed ana industrial blinuness of
“Corporative Big Business”.
áe itill have 1) the BIG 3 , 2) CRYSTAL CLEAN AIR,
3) SUPP0 TIVE WATEiS TEEMflfl wiru FISH.
Do we really want to sacrifice this on the altar
of a possibility of 100 temporary jobs which bring with them
the more real possibility (however rer,ote) of oil spills,
mechanical failures, explosions an1 fires?
AS a positive alternative to the bu.ilaing of
Pittston’s oil refinery, why art we not reconsidering the
Passaaaquoday natural tidal power project? This would
also bring jobs to people and without the accompanying pollution.
It would boost the fishing industries rather than destroy
them.
If you are tabulating citizen res oiise - this
letter says “NO” to Pittston’s api 1iCation
“YES” to Pa3samaq 1oUuy Darn Project
Very sincerely yours,
262—1
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p OO2242O • DEC 191k
u.S. ENVIRONMENTAL PROTECTION AGENCY DEC 5, 1976
REGIOI’ 1, ENFORCEMENT DIVISION
PERMITS BRANCH
JOHN F. ENP4EDY FEDERAL BLDG
BOSTON, MASS. 02203
SIR:
1 WISH TO REGESTER MY FiRM SUPPORT FOR THE PROPOSED PITTSTON OIL
REFINERY IN EASTPORT, MAINE.
ECONDP4OC CONDITIONS ARE SO DESPERATE IN THIS AREA THAT PITTSTON
APPEARS TO BE THE ONLY VISIBLE SOLUTION. I WOULD LIKE TO BE ABLE TO GET
A JOB IN THIS AREA AID SO WOULD MY CHILDREN.
CURRENT TECHNOLOGY ENABLES THE CONSTRUCTION OF A CLEAN
FEFIRERY. THERE WILL RE FEW PEOPLE LEFT EXCEPT THE PRILED6ED FEW TO
ENJOY THE ENVIRONMENT UNLESS WASHINGTOI COUNTY IS FINALLY ALLOWED
OUT OF THE ECQIOMIC DAaK AGES.
SINCFRELY,
MALCOLM W. IRYOON
ST. CROIX MOTEL
CALMS, MAINE 04619
263—1
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!, Addrtnof Writer .O. 0Z.I7.
City f $t° ,••Mp•the• O .21
.t M.tal Woà.n’ Int.rnaticnal Aisoclatlon
LOCAL UPflOId No. 545, LzwIsroN, MAiNE
U.S. viroinenta]. Protection Agency
Permits Branch
Room 2109
John F. Kenne y BuiL 1ng
Boston, Mass. 02203
Ret: MEO022 0
e$r Sir;
I atten e.q part of t e public hearing in Eastport, Maine on December 3rd.
I not request to apeak then because I wante to hear anq judge ‘what
was bapDening.
As Bosiness Manager of a builAing traqe, I am in favor of constructing
the refinery in Eastport. I have several reasons:
I. Jobs for the construction tra4ea.
2. Job• for a epreseeA area.
3. Economic gains, not only for E stport but also Washington County
BT1A to some extent the ent!.re State of Maine.
1 . The benefits out—weigh the risks.
The only matter that bothers me is the Canadan ( overnment. They Aon’t
want the reflnerl built in E stnort but wil]. plr.ily buil. it in Cana a,
I might aa.a that they have 2 in St. John, New Brunswick. Cons1 . erth
that, we must bulLs It ariA forget what the Cana.sian Gorven nent says.
Chard Grsn aa.lson, M
264—1
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U • S • EPA
Esgion #1
forc.. .at Iflvision
P.raits Division
J.F.K Federal B’lding
Boston, au 02203
To Whoa it My Conc.r*,
The proposed oil refinery at Eastport wifl prey, to be an ecological
disaster. P.asaqsoddy Bsy is a bea*tiful satnrsl area — one of the
few left. There a,. bald eagles and ospreys roosting in the rno.s
along the coast. 8eala and whales br,.d in the bays. Thoisand of
Canada gsess land each Spriag and fish the watsrs. Reroaa follow the
*ZSline. low can you possibly approve tbe proposed .il refinery
which can oily sean a destruction to this delicate coastal Sea-life
balanos.
LP.DI 1 1 Box 179
Tr.soott Mains 04652
10 DEC 7Ô
265—1
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SPVVICeMASTER of MAINE, INC.
II - - - -p .. 0. 00* • s
— PORtLAND, NAINt 04104
- k - 1 i / lm...s.owe 7ai.ssoo
leather 1f , 1q76
Permits Branch, Fzmforcaient Divis ion
Thvinunent Ptutectiøn Ag ry
Ketiedy Federal Building
Boston, aachusetts 02203
lb wiun it tiny con rn:
I i1d like to go on re rd in support of the proposed
Pittston Refinery in Eastport, 1rE. It is my judganent
that as we look to the future a rgy needs of the Northeast,
such a project uld be a n jor asset for ! ine, Naw & 1and,
and the Northeast.
F wiromentally, I share the c rn of the opponents w
opx,se the camstniction on that basis. & wever, I an
c onfl.dent that with proper plari ixig and tec txlogj, the
can receive the optinun protection and assured
safet.
E wLcaI ly, Washing Co rtty and Eaatport, as well as the
entire state of Nair , are In desperate need of such ecxtunlc
stii ilun and str th that the refinery wuld generate.
In my jt 1&I1i nt. as we lock to the future, we nust resolve
a viable y in mkiith we can develop the exmnic and energy
resow.-ces of area throt h an acceptable resolution of all
cciterne, but i t with the dcmdnar of environnental facts
only. A harnonious solution can be developed that will best
serve all cxxxerned tile still alictring the deelu 1 ut of
the refinery. I ild heartily support such a goal.
Very t Ly yqurs,
I.ca
‘ii. èu Co
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PEREGRINE ASSOCIATES
Fine Metal Scu pture
12/16 176
XI O22424
Dear members of the RPA,
Znclosed is a copy of a ca npaign ad I wrote while run-
ning for office in the Eaatport City Council eleption of
12/13/76. Ny fr’ilure to be elected should in no way be taken
as an oil referendum as Mr. Norman Young, who openly ii oppos-
ed to the refinery, was electe by a substantial margin o er
all the other candidates. Please include this ad along with
the following comments in your record,
The 7U was created under the Nixon administration to im-
plement his 1985 energy self-sufficiency program for Merics.
(notice ho, IlL projections in the XIS a1vsy refer to 1965).
It represent. a highly parti.n vie, of energy problem.; on.
that has more concern for the energy industries then for th.
.evironaent (which includes eoDle ) or, for that matter, aNl
se*iou long term solutiom to bs. ic eaergy problems. Tn
their ITS presentation the flA’e positton that a refinery in.
Iastpor’t is somehow related to national security is absurd.
The Nest, the last Coast, the Northeast United States, lain.,
Washington County, anc3 Ra itpor” are not’interchan€ eable geo-
graphical entit e !eir p’eeent&ion would lead one to be-
lieve. The state of Maine has about one million poeople and
Eaatport, as far North as one can go on the on the eastern
seaboard, is hardly located near the Northeast’s market for
oil. If the latter fs a consideration then new refineries
should b. constructed in 1ev York, New Jersey, or lss .achu .tts,
where most petroleum products are actually consumed. One
3 Clark Street Eeetport, Maine 04631 (ZOfl 553-4810
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PEREGRINE ASSOCIATES
Fine Metal Sculpture
I O22424
gets the inpreesion that llama should suffer agonizing guilt
becaude it consumes oil without refining it. Let’s hope that
this tfle of guilt is felt by all the other states who con—
snee the lion’s share of l lainS’s tiaber products without, in—
wredible as it sesa., growing their onu trees. The argunent
soout steaaiug eupertankere at sea insuring • O-6O d
supply of oil in case of another sabargo also mints up the
Pit’s lack of vision. The problea showld be salved by Duild-
lug exteusive stockpiling fsoili . as for crude oil and thes
ShOUl d again be located sear the actual aarketplaoe for re-
fined products. It is a qneitio* of values & priorities.
If wo continue sacrificing our natural heritage d rsu•-
able resources to ‘gr.sd eoo*osioe ef the eaer r industries
there will be littis left of 1.ric* the Beautiful’ or
‘Morton the Bountiful’ that will be worth safeguarding.
I sa apall.d *at Pittston recruited so aany .g Boainsss
and j Labor representatives to speak on their behalf at the
A hearing of 12/13/76. They conteaptibly dosinsted the
first hours of public aoeat and only asde it that such
acre &tff c nit for 100*1 puopis who oppose this refinery to
publicly speak out. I hope you all noted the august business-
can who displayed such wishful thinking by referring to the
EPA as the Board of Econoaic Protection.
In conclusion, seriously consider all the points underlined
In tha accoapanyiflZ eanpaigo ad. £11 percits to Pittston
should have an expiration date and none should be issued
3 Clark StrsSt Eastposl, Malo. 04131 1207) 8554810
269—2
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PEREGRINE ASSOCIATES
Pin. Mtal Scuiptuit
I O22424
until the people of Zawtport approve the project In an official
ref erend.
Sincerly Toura,
&ll.a larria
3 (2 k 8tr t Eastpoct . M.t s 04031 (207) 0534019
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I I4 TII0 000 00YT1 OJU
VIEWS OF AN EASTPORT CITY COUNCIL CANDIDATE
Ia NIw , Hwr i hate f.i.d in Etupoit fe. ft., yfrt Did ant hilly weilipo cad .nthe 1)1000. yes, the Iwol IW O. dope 1w inW bo t 1)33
all ‘ . ,d . to .dicy fat esty cautal a baotd .tea. . my da.o Daleef mat a weak ot 112$ a, hemp. Neithe, Itewly attelda Ilk, a union wapa to use.
1w thai.., to adetha The P.IWo.. Coumuny be Itaw.d to bmpld a seftnaty Atul do you .apsce 1w .wan msni 1w profemianel . . ..,..l to be .awaal
in I .t leemild and ultatsataly must be decided by aus city ma. an official met’ The. .me *1w any people ,adtIanWy apeewd to union.. b id it lie Would be
we . P,MIs .inlsn pals aid ML$. ,. . . .aaphaipe., wo I A Ieia kiel km weld W a bee . .. P )ttelati is ..nlamt In N.Y.c do. net mai that It ad
by Me p apl.. be matlan ii. EatIpeit. I.. fact. otto of th. muon. be letaliMp In EaaipOtt 1 1 , 1 0 .1
I ___ . a. a .d to We Pittston mefmntoy peapasi To hold thI, pal- be to wed peyvip motion (Me dlffutona . in payvall between peyi..p
Wa ha — a. Me pa. to be Ithelladan “suede..” “bidoetWer. ” “ea.es awn $300 at hoe aid $100 an hemp weomad to an anieto I a iflP of oeor
pawe, ‘tetha. ippi., ” to wew. I mewnl thate tWIst a thay hots bean $100000.).
w,fIpf p toed by .,lMm, .y litooltoll to i , es heneat oposotun. inwlhpanl do- I litton that ,tow ao.tw’ he load EaWoa. lf l dtolvioa Ito ,, bean be to bel.eee
.1,1. aid apan.debate A. a taUt this unotmumat pmemeel Ills bean weptid.. , ., ...... . ,.,o.. be foacad to pay unto,- atmyt tWin Pirnion comes rt
.muv peth blind faith aid that. ft Is my belief that any abe,cMtm if thy tolls tø ,etien IwIp. P $ae note, howe, .., that at the E.wlioomeneli
.wemat I .. .11w ,,f.ne .y prøpesl metels hidden nWs. mat danp.ms, 1w. Ptc4action Apancy heath. of -I2 3(7$ 11w p..,ademet of Gulfeid lnd.atfles hid a
f a i ’S 0,1.1 . ae _ d q..i*mova. mtaea.wn, .1w In .1 t.dt li. fially endoned the Putttton .efiw.y piocOal. Would
I well Ilk, you to _ fua 1w a. at The toaolatan , he 1 seae doap an If ha bellied that the mfrw.y weld neotaa.taee the paynwot
• w.— becese to n.wty fact. han, bean oil iltil .,. wtota.IWIa. About Of union to his evaploy..s?
p 11w MatiapeLtan Oil Company ainaiwed plate to bull a tad The otto wear of the (.1 impact lanluedon Met I find tweet dmthla ,a aid
Is.. Mt Eatps .t to ito, hal be.. by Ganepa P,llic Ia. lIPS 410$ the city 1 , fandbe i 5 the p.äöectad wco .day benefit, of the refkme.y. Meet of the prop.-
domyt aid wee adjiomme peeparty we IWU eadotud to 1w,ocohta ,. In 1111 told. Wool el .taFII$i , fitotI ipsalne. bowbns ‘Ileti. smyo howe., etc. o
Ito . ...uip.. aw.matomd that the lath tap., wee we to be am oil t.fa..-y. lust plame ‘iffy. And the wconday .ndstonat aetnitias we .e.bdhy eepand.I, to
Palsy, an Aped I I , $573, at an .tsfuneatiend .toeliiip Wout the , ...d contt,cled by . .ommyw WOI0.um .cco.thap to how esto the o ,eill Pittiton
.,lse.y. 1w pmabeis we lint lifonwed Weal Me ‘i .e of 1w e,yeaet. We las-and we appess at 1w mansent The 100 an io . PIttelen, impotis wIlt not bee
Wa We,... .,..llta. Oil we ataatlly not by The Pitwe. Company. a mull- at Eatpon and Woet of the 200 man Idea . lana wIll leo be conemitmnl ii . hunt
ballan deWe Mew Y.te bated 1w. pt-wy .ntovaet we at . 1 nitoftbenap w’ aanit.al, Ineidentatty. the toew hap of a aapsnaime . is paw..
iduiip. I II , tetomaty becaae a caimulae, takias pa newly ens laid .11w Ila’md. ally lions 25 to 40 nest and Woy saudhy Ia not Ia.. Me lila alman it pulls tate
tell. aide ad dolesy blimp mile by h,qe ..pe.tadaw. St..inld by thaw dl- pal to load at wdoal touda oil.
.11w ., ad below Met II, a .la imeatlon hal ant bean isedif V . .adWI. babe.. Cnet,i.tdb. . Wa Thise and otto hell veer, Pitticot , bidfcated that if t
a er ad met to disoaw II mallet. Meal bothatud us eteat tow anal not bepin casatruttilee en *1. ,,llne .y by mid $ 571 the plofect, l.a to
Met Me nape .11w psamace hal not been weaNed to Eastpott’s cWp.* ,mt.l mauntmn$ InRut.on. weld h ..e to be Jl.o 5 Itit dalhiiw ha
Pimpee., ’, toptyatha is M,al’ . $0.11 of Enw.o.wseni$ Psontoam toad emil now p 11w tray we awe, dsle .n,I .ed ems. seat. AtMe EPA lies-imp sat D .c
Lt_. . to be mad pall- Dma to I I I . emeemusa .iepect Wa p.viect weld ‘ado. 3 Caned. tewead its Ions held ofIbel policy of fo.blddinp Pittston.
an £a1wai , e,1w .t Metal pa d, .sctty is Its paaple and that . petite ,.. tim of $4.1 H.baw Pawepe be ..pemdo*ut trif ha. km ipIto Of this PItmilen mad-
Is- a . .fl. _ & - 1wudd be a.uilatad. $54 . .,......d eale.s ecisthns mu city ulilled ‘I we ye I np back to Wokie’, load of Ees4. .....tl Ppotactto. to ape. ..
- Me .s4 ,f .n . petit...., tote.. lee pettesat we ....n1w to ad (O t 4 0 .1w Ia we 210,000 a. tethers, fIn 1w Ito UP decision Pi(tsjo..
Me Ney a*ils far ed-man. ml tow defeated 37. The ‘a. ,,, mu be thee deli- had bean tolohead to $10,000 tan. ). They doe staid Wa they ewe no can-
al we Ito Me le womi to. lpeeia .t of a ,. laces to ut*. to mnotIhpenl toatbq an alternate (e.onebuoyl eyeiae . 1 tale oil ddh ,aty. Why ad be
leddas ad that Ia tap we Weedy le wet’atted to Pit-a ferarifuvaidoam I. tape usapattodiwi alien thmsy anesol be tated? It eppast that Pittata. it
to . I WessI Wa Me people ants , tota oil do fees, bacaus *1w 11w wteds tiwes . .. I ,. wait’s Head SIP .__ . l . t- titan it Is I totally
we mMe fluia. I tether wibeot that 1w c .ey had bow. lddty we.- bmillthup Ito peo)ect we. At the spew 17* heallp (tV 7S ) is. Ito, P I tt , t o . .
to do pepito aliheut lee peedo bes.p .11w. .mfwesd to wetoilaw. we Ileesdy tWN flay would 1w toll. bulldlnp the timnary m l they me..
Wasi Me - 1w spae.d the , afuts th.se a .ww jtsdead ip PIes, . eawbeid to wIt, $10,000 ion laden Is- Is , . ). They ‘wee. lee sum’
we Is to las ee -decha . at Wit anunel mu. The Mel h told a ,. ad $ Sl°et. I. Ptmton liapi’s that l ’ s Camille’s Ttid.sa4Iet I lild $.. ..—nU ttilpie? Ms
p w Ido do mm. th at 5th wepauwe to a vafaweWen we a pm eodd act of of (Is at Wit teat few yaw’ ad ilsat I I . .iplteonwnt m .Il be tao .,
ad We ho ties l aw . - - - - Wiut I.e Wewbibly of 1w - ,vmpadwtal to Me u.s of eupeltatkas? Is Pittston pull . ., to pat all It, peemit .
n.Way p.s. hon. I. lads-I EPA t0w. nil beta.el ,t a anwama to balki esist.uct.on. but
Me haweat Ito ta,k laws has w• eehary, I ., talk.’ bec tt hIll.. It inipiit be mud. .siar lope Waus now that tWin a pans..’
app hap b a asfbw.y ad ..entaWet pail. Os you i.ue The Pittisea bad p nw.o Itsatla Cat., .dntln.at.atlan ales we. I .. Wid.impten. It Would be
.ps’my to wee Mets? The feds-I £m0.etowitol Pretectean Agate,’s ‘s cott rweuta.mId *1 511 WWlapn Simon. pa. head of It. Psderel Ens-pr Athuln.etrj
we we —h.p psedieteon,, It s . we Wa by 1101 lady P yaws awayl ho.. and Rapen Utoten, tsoint Saciolap el C...,........ . bo l l tnld to tiN
Wa ad be .th w Na.. upland Is. a. .tWnes.a, at tapeeMe pmpaO.d atPsmneo to I ustha. PIttston’. (wlpert tefinery propel. The pe.m.ta aid my
Piwe saWeep 1210000 bond, par day) Thia dewed ad hate to be ewe by s-oils ‘ die bali .1 E,. .,l. _ ., ,,,, ..Ld Pyowatten and lime Ensinawentel
, bmillliq sew ..1w .’.s to eeaadasi sawtma ’ s oms E..stmp .af.na .ss, Piolactat Ape., may thus do woe .tpew Ptts,t.n would any sell be toaw-
of a, Iotaal let Me Ne Yoth - NeWiddplea ate, hats Leuns on mefiaie.p AWado oFflsa..t if ad alien aids .w.es a. found. t
to Mele Ian.ste and a, peasant, wept let Is Ptttsman piepeel, nasal totally be a lot iwo,, p. 0 1 meWs, to miMe, .1 hon. off die Atlas,, wet
Mew we we CatWa peed..4 be Wa weawuttesi of mu u,fasa,i. at flew than to Smu I i d.t.. ,d of die way from Me Fatal Gulf. They sell, at do law
, Meat If Putwea daede. to .emyid its Iowa... at.on to nest Me data, do not ha. e los.. be Persian oil net witticisM finaleS bailS to we . ’
till Wae .dT Ill. Koalakia ha blIp lesinhed aa.%V4$EP I’we., tt...ce Ito .54 iwty.
Wa Is o that Pitiaton has plate to weld to a 500,000 ks-il pa. day Mud, of tim Woe, I ipecidatise. bitt ‘ pi— ” , Is of diet Is loft to is ot
. , to, , ., . Mlplit 1w., net lie tsn as-a aWatlo. . plate lolsadm* . ,,, .&,, . PIttston pal, is Ito, l iens p,on.at aiti. us a to Is, anlasat plate, mehoss. aid
km Piwe’s Now y fly of mae? tkmit totithilas, Its posebidity that Films... plato a, .1.0 hipidy ipanIWa
Is do bean any litWat fat Psywsom to pal th ,. . , . ad pemouw ad that they wet net iwntodsal ’ Iy bq.n ta.tewuction anm of na t -wy permit.
fa, this pee ect. It ted be mud. .111.. to pat l.a _ s,als ad panara aid 10.0 -I . we .mcwed Would be frlpimlaeios, to we the .ofIewys Iv onbs it.
to we we hwy how tiwl. at.til ..fate .y o..ien,cisd. toe., ad! Way Se- auppaflef I. The heWer lii. ew.e .,nilsa .an.’s.efead one nay a. snothee Ills
pad to? Ye., a at peed as .fte. Dual I hats no 15,111 that, It enoit Iwo ’. it 1w to and hum o u t city. I bafsis that the SEP and the EPA should b
____ a. be Wa . . _ ... .J.. . 1. not apdy a poeelb4ity but a aitanty. The ( I the Cat iT O can taQad tInt. conditioel- e /
PIWey I f Ito estatlily var. , paep... , hot panilapendy bean sew of .piwne wnpl *,aay .PtttMoc paItsyeon c Tho . .s,h ld’$1Ul$t •
aid .—. (ThsPittotqnC 57 .ps- . pin .Wita.tlal carmett’uctlon on the ref.r Ti sW i’\
Meat psoestlon I . we hme .pewet seos-Son? Pltttfan. peal horn eel so,, (yea of rpejylpa tseceiaij .ppeli W11’*mltvwy’IIS Wdilso ’ a,ie )
tat Me mm? 0.. aotmu.p laws? People on both lids, of tIlls lee.e wee
dial owe Pit-as.’. eadw.y aDult, Ifs, utnipats ad be Me daa..nant be.. at is Mtha,*th, nsk flM%*lsy’i00Goi a. telsilsely stall thaw riles
ow ad . ..s*.....t . In alias .o.ds Mere all is, , . , ,.l.,,tl.... . Ill a, i.,edla. Mtackj$ely seal. Ta.*att ap I tank bayes Ne es.lode. Paflnt”v
to bdha l .a emit l.a. I, of 9w rebaw.y a pra.ndy wepased weld Itotwe maths do cads hI... AM said.. aired.. Sassy westhe. cendltlate palaaie’
auto 0 41w etpswiOsy. “ ) eat w,lfmw.c add mist atO (ante at its Eietpaei aIr we b ,atoa. *Jthoq4s Pittaloft
on II leash w elI . with p.sl.neatap .palato.y ) ha .daattad lie, .t thaI nmksimmi. aid. tWa. .1 sf 50. 14 be cornpellad So totally
.t Pittston Ca. be uma iPiecWop baiaimd wet ij3$ 1w \ shininess 111,11 ,. $uclt instill be Wi, a.. 1(1w sefineay p .c$est ware lobe built
wftt p.apa.i”fT at S.. Hate . to Mae 14*. Suds weld ds.b. lee well lies., tote billlt Ins
to’ ’ ’ihee,’ toi.nc till ,iat.ate etttai lIff ) iwe wl.a. p.pul,tmom. co.wlited of Pittasen , pallild... .
pWi A l We eowtn.ct.on the .shuie.y ad opapa and. e .5.11 of I ton one pap ailnor tanks. ,yeladon Ito. Ito .sfb ieqy he wesald, it lily
airmail. Ow I l i tWad of time. ad be bmilst in by Ptitlmen apaWa, lest to Me pails filltlnp .1 (we St ptopa l l y. U . ita,tmanelily. fat Ito
I.. -L -L . J . liMed, aid wepawe lab.) ad 300 peal, add be had ham we wean peals wemli is. ap.alasw ho ad, smas all is. We peNIs ateisift
Me bead web Iwe Ium.-WiIad ad aithatil weleaps Iso,, Eaati ,fl w I a- is buy feneept peadly Pletemanl. Aid I Watt cape how Ia$s lii lily. tan Wa
we). The.. aianl w . ,ow will weets a . ,...,I.,,.4 pepedlif is. If nasal web to pow kawe I I be’. welds very nialim.
Woo adha Idlas, Of fba .1 The Piseesap, Con.masy ham weaen ,Iv held ‘ 1 5w wee few e lI ’ s apatene an w illIs n.y oppeaitlon to
is Wa ee ad If t we thee’ ene ectoan plemdIy poilteid to that Me l ’ s . ..., . _ l milnety Ia based. I tessld ad yaw 10 ers my sp .nlOf to on lila
ads-p be $10,000 1.1 I make $10,100 a sar aid pa. oils. laws wilds dais .11w adiet cadadee nauslnp for city .unc.I. I would add
$1,510. yaw eels Wa an wepa eday of $250001. tat to ea ee Mets thee a e sst,, .,..l...ai I wesild be as . . - . . . 4 whIm Ia a i d. .4 y day to day pa’
. TI. men l0.sbd ad be s- I p ’-”- : pail far- .swet .41w Itty * I would be witIs da-IlyImp 1w .eeal* ’ s steel tasteeL
— _ . -.. _ . __, . ‘spares. kadoel p 1a e t, lee. Eailnaamel . 1. na a TM, _ . _ , _ l WilMa., 51 ref steep at Me Wa faIn, (iatpO.t. II I ouawme
hal ball., dais- IWay, Isp sat be .iae.l a -al kiplily li.ll.l. Fermi to ad deal., las belle. or es.w. ala, ad bacaws at *1. ally ad s 5t people
1 1 1 w. Mel, balsa to 1w latost s-es Isy amid, wish Isle qidofisatlara, 0.c pe.sliiy of life, aid a It-. of ilt- l eL..mlnatlan we mdv a few o the
e fad . , .,l’ 0.10-51w .I. _ ? _ II Me law. bela we toe ha. ,Mees at ,&*.. lbs people sleet, at las’s last, be passhettad Iss ,e,ciI , l’hirun
it NiNe is we We Mey ad mIs. a elmlmu. .1 11w 555,000- $20,000 qua.s.enthle rpi W . t Uliecaia.ty ha do.wn.j”r
. yes-. At $30000 . yea- thea arWo..d aiim p.ysal s ’S toll 7 pielkan o 1 ’q4relefsdam. Pa. lilt set aesy ‘obe biaill w .ttmlvt lie ,aplic,t ct-inc .1”
daiw’, Ibis b . .ea meewe daft. paynal be Me 3001.1 _ : ihosa mu toil P t a, to hoe ads It .551. unl.im*abIs and annesay to of ha
lea beeS, Wa to 11000* paw. 1*00 a weds. $3.10 anba. U the PInto’s basic eta dea.ooi . cy. — Ala, Male
1 ll, ,wlprlimea,swe.#a,3 stm
- N I5w Ala. Ito,,
269—4
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BROWN & T BBETTS
ATTORN Y5 AT LAW
MCRRILL TRUST 8UILO NG
CALMS. MAINE 04610
FAAPdCIS 4 OWM, I. 0.
ROBCRT ( i..rrrs. j.o ZO .4$4?$43
JOMN A. CNIJ CHILL. .1- 0.
December 13, 1976
U.S. Environmental Protection Agency
John F. Kennedy Building
Boston, Massachusetts 02203
Greetings:
I am writing with reference to the draft Environmental. Impact
Statement on which a public hearing was held in Eastport, Maine on
December 3, 1976.
As a resident of this area since birth (except for my education and
U.S. Army service) I feel I have a real interest in the matter and some
knowledge of the area and its peopLe.
First, there can be no substantial argument with the need for
increased nployement generally in the Washington County area and parti-
cularly in Eaatport. This condition baa existed for many years —
several decades, in fact.
Secondly, other plans and efforts to supply an economic and job
base to the Eastport area have met with failure or only very limited
success. The Quoddy Tidal Power Project has been a political football
for fifty years and is still controversial from an economic standpoint.
The two — pool project has little chance of success because of lack of
Canadian interest here and strong political pressure to develop tidal
power sites at the head of the Bay of Fundy. Anything less than the two
pool project will not pass economic muster in my judgment.
The refinery project offers a solid achievable economic boost to
the area and would probably bring with It in time some other petro-
chemical indus tries.
The only major counter—consideration Is that of potentially adverse
environmental Impact associated with it.
After considerable thought I believe that present and future
environmental controls enforced by our state and federal agencies will
provide reasonable protection to the area. & few years ago I would not
have had that confidence but when I view what Maine has done already to
clean up its waters and , I believe we need not fear a project like
this.
270—1
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-2—
I behave further that me have an obligation to provide apace for
such a pro3sct bse u.e of our own high án.rgy d. n l which is not going
to lessen substantially in the short run nor is it going to be met by
alternative sources in th. near future.
While I can identify with th, concerns of the so—called environ—
aentahista I have to be realistic in terms of present needs. Man, too, is
a part of the .nviror ant — a .Dat important part - and while it is
great to preserve nature in its primeval state, it hal been affected to
an incr.aaiiig degr.. by man’s existence since be appeared on earth. We
will modify our behavior and energy d *ids s]ovly, if at all so long
as it is still optional. We need increasing effort in our search for
alternate energy sources but me ca t do without oil and oil energy
refineries now.
The H-.d Harbour Passage probien is solvable, in my opinion, with
proper navigational aids, adequate tugs, some obstruction renovala, and
strict rules as to u-ag . . The probl with Canad ian permission is solvable
by dipl tic approach, I am sure.
It is therefore my position that the Pittston Project will not affect
the euvir omaait in an unacceptably adverse w r or degree.
Very truly yours,
FRANCIS A. 1R JN, Atty.
PAZ/arc
270—2
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THV000uti C. NAUSNT’ON
40 £AfT SSTh TRUT
NIW YOftit. HutW YOutK IOOSI
r)ece, er U:k,
1cr76
‘Ne nvironrnentd t rot, ctior
Jo!in F. “ennedy eder 1 “ i1ding
3oston, ‘ass. 022C7
‘c ency
Th: ‘ittston °ef ’inAr\r at st, ort,
‘ o ‘o’u mean to tell, me that. tiis i11. not
han.en in th goad ‘far’ or ‘ ssa e”
27 1—1
THE NEW ‘GRK a ’JM S, SATURDAY. DECEMBER 18, 1976
Au W Pvu
AGROU OFF NAN’IUCKrr: Argo Merchant, a Liberian auaounced Jut night that 100,001 gallons of the oil bad
tanker carrying 7.6 mIllion gallOns eI oil, foànderlng in leaked from the ship, but was being blown south away
heavy seas off Nantucket Island. The Cosst Guard from the Island. The crew was evacuated on Thmi y.
(Zy Z
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-------
is Cli t 1 .... i htre? Is Anne Maiia hastings
here? Is I4 Najka hcr n Bradshaw?. Next, Dean
Dradshaw.
ItS. BRADSHAW: You gentlemen have been very good.
I am really impressed.
I just want everyone else to know that I love it here.
And I have heard many people speak tonight about the
economic gains that a refinery will, provide for the area
residents, and I would like to say that n ney cannot buy
good air clean water, health and well-being, and this
Z13—*
-------
bothers me very much.
Some of my corrm ents regarding the draft of the
environmental statement - the statement says that this
is a receptive corr nunity, and I disagree. There are
many, many of us who do not feel receptive, and I think
many of them have spoken tonight, and I hope many more
will speak.
I would like to go on record as being opposed to this
ref inery. It will incrnase air pollution, you know it,
you say it. It will increase water pollution due to
daily discharges of 400 to 500 pounds or tons, whatever,
of oil. Whatever amount, it is too much for me. You
will destroy the clamming industry if there is an oil
spill. There will be increased noise pollution, increased
traffic, and endangerment to the wildlife, including two
threatened species. I think they were slightly iientioned
in the report but not extensively, the eagle and some
species of whale. And this refinery would seriously
alter the unique lifestyle of this area.
I ask that a referendum be placed before the people
of Eastport. I think the people should decide this issue.
Your draft states that a refinery will help national
275—5
-------
security. I think we will still be subject to the
whim of foreign oil suppliers because this refinery,
as stated, will, handle imported oil, I believe. Also,
we have no control over what happens with Canada and
Head Harbor Passage.
I felt that the draft that I read - and I read
Volume land II and the sumnary; I did not receive
or get a copy of the third part — was slightly impartial,
and I quote: NI felt that the material was based too
much on the report which I read by the Enviro-eciencea
Company of Rockaway, New Jersey, which was hired and
paid for by Pittston, and I felt that this was not an
entirely biased rsport.
I am asking you gentlemen what guarantees will the
people of the impact area be given that the conditions
of the construction and operation of this refinery will
be met? So far, Pittston has not met all of your
requirements to this date. I believe they had a dead-
line of to rrow to complete some things. which I have
not seen any evidence that they have completed. If I
am wrong I would liii. to be corrected.
I think in sveral decades oil may not be our primary
275—6
-------
fuel. This refinery will be outdated and useless due
to depleted oil supplies, and what will Eastport be
left with? I want clean, safe industry in this area,
and the concern should be for renewable alternate
energy, not potentially obsolete energy.
In conclusion, I demand an unbiased environmental
impact statement, a re-evaluation -of the place. of a
company and a refinery in Eaatport , and a referendum
to let the people decide and choose their own way of
life.
Thank you. (Applause)
MR. McGLENNON: Thank you, Mrs. Bradshaw. birs.
Bradahaw, just one thing on your remarks, where you
suggested that a report from the Pittston Company was
due tomorrow. That was the report that was given to
us today concerning tanker simulation, modeling of
tanker traffic. -
- 275-7
-------
YL) /D . 4
Robbineton, Maine 0ii671 fr’
December, 23, 1976
U. S • Enfl otaental Protection Agency
Permits Branch, Enforc iient Division
Jo)m F. Kennecjy Federal Building
Boston, Nassachusetta 02203
i ’s ; case t ME 0O22 i20
Dear Sjr ,
I have not voiced opinion about oil refineries
before because I use oil and felt it would be dishonest
of to criticise scasthing which I subsidize - even
though it is by necessity, not choice.
Rovever, the spill off Nantucket has made it impossible
for a. to remain silent any longer. Whzt good are the
ooutorte *‘ovided by oil, in a world unfit for habition?
Not asough! But we do hay, enough....
Oj]. for b*aic needs
P U tj on this E*i’th
Int.lligsnae to find cleaner, safer sources of energy.
Do we have enough sense to preserve this p lanet for
future generations? Ny children and I hope so.
cere ,
3 OOEC , 6
276—i
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&reaic N Shth.’eil V
312 Maine Street, I(ennebunkport, Maine 04046 .(207) 967-4400
Mr. Lilace Stickney
U.S.Environ.sntal Protection Ag•ncy
Persit. Branch, Enforcecent Division
John V. .nnedy Pederal Bsilding
Boston, Us a.. 02203
Dear Mr. Stickney: ØLE00420
Tb. threat to tb.. eavirossent froc
oil Spills on the coast of Main. have bsen
highlighted recently by the breakup of $h.
Llbrian tanker on the Atlantic coast of
the United States, and the •tattstics on the
hers possibl, to the sir frocs.alph•r gases, ste.
force a. to register sy protest against the
bui1din of an oil r.fin.ry at Mstport,
Uain•.
I as in fever of activating the Quoddy
Tidal Po’c.r proj.ot, so long shelved by the
U.S. goverlnt. This ‘could supply such of
the nedded energy f or N.. Ingland and yet not
pollute the •nviroasent or endanger health.
Sincerely,
&b> L
Deoesber 23, 1976
217—1
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Sylvia . .fftiillm
312 ikai* St.
D.c..bor 23, 1911
Mr. Wallace Stickasy
U • S. Zavirosstal Protosti•s Agasoy
P•mits Irsask, Mf.ras.s*t Div.
J.ka?. J.S*.Sdy ?d.ral 111g.
1.st ., Mass. 0*203
D.ar Mr. Itiakasy:
I yell liko to register protest
sgaiast the beildiug of tbe oil rot Leery
d.p.t at *astport.
WhO daeg.r to ho .aviro at f roe
oil spills aloeg the coast sad fr.. gas
p.l tset s kayo base veil d;::tad—7oa
keow how grave thoss us.
I — bigly is favor of iap la.satitg
ike Qasddy 14.1 Powor prsjet, whiek
yell boest it all Mow Isgisad, sad do so
ps3bttag t. the oevir .st or to sailal
sad k health.
$isssrely,
278—1
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The Graduate School and University Center
of the City University of New York
Graduate Center: 33 West 42 Street, New York, N.Y. 10036
Mini nigtratjon
SUBJECT: #ME0022420 (oil refinery at Eastport, Maine)
I am prompted. to eomsun.icate with the Environmental Protection Ad-
ministration about the Environmental Impact Statement (application #MEOO22l 2O,
I believe) au itted in relation to the proposed. location of an oil refinery
at Zastport, Maine.
As an Eastport home owner and suzer resident ‘who looks foreyard
to settling in Eastport sometime in the future, I strongly object to the
proposed location of an oil refinery in our city- because of the clear neg-
ative environmental impact to be expected.
There is no question that the economic problems of Eaatport are
grave. But I have seen nothing about the proposed oil refinery ‘which would
indicate that its location at Eaetport would, in fact, aid. the area in any
substantial way. On the contrary, the disruption of the physical, biological
and human environin..nt attendant upon the location of an oil refinery at East—
port would work, it seems fairly clear, a negative impact on the local economy,
particularly during construction, as well as a long-term negative impact on
the natural environin nt of the area.
Although I have not had the opportunity to go over’ in detail the
impact statement su itted by the company seeking to locate a refinery at
Eaatport, I am given reason to believe that it is both incomplete and inac-
curate in significant and important respects. The reputation and past practices
alone of the company which seeks to locate a refinery at Eastport brings into
serious question the voracity and competence of any work or statement they
sponsor. In particular, I understand that the Environmental Impact Statement
fails to address itself to the region as a whole by limiting itself to the
United States area only. Clearly, the nearly unique natural beauty of the
area, the problems of fog and tides for shipping, the range of animal and
plant life——to mention but a few elements—cannot be viewed and evaluated
in terms of mere geographic political boundaries • The discrepancy in the
count of the numbers of forms of natural life between the impact statement
and a .briet. b c an outside expert ought, by itself, serve to demonstrate the
carelessness, it not dishonesty, of the attitude and work of the company seek-
ing to locate an oil refinery at Eaatport.
Under the circumstances and given the consequences locally, national-
ly and internationally, I do not see how the United States Environmental
Protection Administration can fail to reject outright the pplication for the
location of an oil refinery at Eaatport, Maine.
December 26, 1976
TO: U.S.
2 79—1
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OFF THE RECORD 1)E C 2’ 1 *
Mike Cohen, Tr.scott
A little known error vs. made in the White House after President
Nixon resiqned. One of Mr. Nixon’s tape recorders was left operating
and it still isi A chambernaid friend of mine has discovered it and
left it intact. She’s been sending es recent tapes she theught might
be of interest. Th. following is an alleged conversation betwain the
president and his secretary which should be of interest to citizen.
of $.ihe.
President. What’. new in the mail today Mr • Secretary? Did my Sears
Roebuck cataLogue arrive? The coentasary tell. me we’r, running low
us toilet paper. Order some from Sears? No. we’ll use the cataloguel
Just as good, you know, and you can read it tøø. It’. either that or
tel.. tss...
Secretary. Pit • President, there’ an incredible letter here from a
. ber of the kastport City Council.
P. Ssstport? Where’s that? Maine? Where’s that? Oh, I ren
her i Ea.tport. Maine, the tidal puv.r city that the Indians
. stat’s the councilman have to say for himself?
S. .. Sir, this is absolutely unbelievable. It’s a long letter in
vhich he says gut ready for this now - he say. he has arranged
with $rssimv and the Russian navy to make Iastport into a Russian
naval base . . . for missile laden .ubearinPs, troop carriers, and
warship..
P., W14&( ’&)*** ’&/ . . . . . by golly Charlie he can’t do thatit
y Godi Iaposaiblel It’ S downright dangerousi
S. t The letter says he thought you sight react that way at first ut
he says you .houldo’t worry one little bit, it’. not dangerous at
all • The water is plenty deep for th. ships, he .ys, and the Russians
at. going to help out a bit and dredge some in thâ shallow areas just
to show their good intention.. Don’t sorry sbeut anything going wrung,
esy., they’ve oven been careful .nough to put old tire. alosg the
dock eO it won’t scratch then Russian ships at .11. He premises it
viii all he wicJCod safe, and so do the Rusaismé.
P.. se ’t taut idiot lumw the Russians ar potantial . i.s of
this c:ry? ?het they’ is not going to do us any good$ My *mtê .
212—1
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—2—
where’s the man been all these years?
5$ His letter, sir, says exactly the opposite. It says h.r that in
lit his dealings with the Russians to date they have been friendly and
even cooperative. They promise they won’t do anything to hurt anybody.
1f they break their promise and invade or shoot rockets they say we
can fine them and even make a speech to spoil their: world image at the
United Nations if we want to be m.ein. They’ve even offered to let the
Eastpott people have their Quoddy Tidal h-over Darn as long as they put
in locks under Russian control. That way the troop ihips can get into
Cobscook Bay and the soldiers can go flounder fishing near the ferti-
lizer factory dock. Soae good fishing there, he says.
P.* The man is insane The Russians will use the base to invade the
United States when they please. We’ll be within missile range. Bus-
ihessea will be destroyed, what will happen to our balance of trade?
Our bargaining power at the arms race table? Cur national security?
Our 200 mile fishing limit? Our mighty fishing fleet? Our . .
S.s Hr. President, isn’t it even possible that people might be in-
jured or killed?
P,* Oh yes . . . People. . . American citizens might be injured or
killed.
b.$ And Canadians.
P . , That’s correct, and even Canadians, whatever. The whele idea
is Insane - it’s madness. Why the hell are they doina_ this enyhe ?
S.i Sir, the councilman says the area is ECONOMICALLY D PR SED.
Says the naval base would really perk things up a bitl pier construc-
tion, hammer and sickle sharpeninq, borscht made from Maine auger beets
and Maine potatoes, caftnon cleaning, machine gun lube jobs, battleship
tune-ups, uniform pressing and alteration, button ahd medal shining
concessions, undsrwater parking meters for submarines, pay toilets in
them; and souveni ts, why he says here it might even bring in the
tourist trade. People f rein far and wide will wsnt tO Come and gaPe
at just how far a city will go to make money. They ’ll put a toll
booth in just before the Indian reservation For stirs they’ll never
ha economically depressed vith a full fledged Rtia ian sval base in
town.
P. $ Medneesi Don’t those Maineiacs know that “economically dpr.ased
is an advertising term vhich simply means that some people caft’t afford
282—2 .-
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to buy everything that big business would like to sell thea Vh.v$
they’ve falln for the big business “economically depressed” brain-
washing in a big way up there, haven’t they?
S.. You mean down there, Down East, correct, sir?
P.. Up, down, anyXvhere around - they’re still LI. S. Citisensi Don’t
they realize they’re far better off than anybody else in the world?
S., The letter says, sir that they’re sick and tired of being them.
selves. They want to be real Americans - like itskx,ws on the T.V.
or in the ad. of the Boston paper. They want big money job. like
American. are supposed to have and to hell with gardening, carpentry,
logging, fishing, handerafte end tt4iite. Thy want more than to just
be able to live peacefully in a beautiful place like Washington County.
They want it’ugly, polluted, developed, and tense like it is from Bangor
to Norfolk, Virginial They haven’t had a spectacular robbery, suicide,
rape, or murder down there in yearsi so naturally their newspaper has
hothing exciting to say. All it talks about is who visited whom, which
boats came and vent, when the tide will be high or low, and which local
club mt where, when. That’s front pagf news down there. Even the
kids are using low quality drugs, uninspected by the U.Sb.k. People
have lost their sense of pride in being American . . . they figure,
they’r. a minority group . . . when they go to Bangor thsy thina they
must rid, in the back of the bus. He says the naval bsze will change
all that.
P.’ Don’t they know what uncontrolled, uncaring foreign personnel
can do to a town when they’re just visiting? Don’t they care about
bow their neighbor. in the Quoddy area might feel about such a
develo ment, about having a prime military target being moved ihto
their locality?
S.. Evidently sir, they’re not thinking about later on. They a.. . to
be ill hot to trot and make money now, no matter t effects. Tb.
Russians have evidently even agreed to pay rent forAthe land so it ‘a
a new source of city revenue. The town council Is loo)Ung forward
excitedly to being bigahot politicians.
P.. The foolsi They can’t do itt I’ll call the Pentagon arid
General Nuisance will take care of the situation with a bangi The
federal government will protect its citizens Eros this kind of crasi’
n .e.. That’s what we’re here for, and by golly the army will, see to
282—3 ’
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-4-
it that this happy horaeah play with the Russians will atop immedi. .
atelyl Now
S,s Mr. President, bold on; ôet thiwl The councilman says in his
lett.r that if the federal government makes them atop, they’ U put
n an oil refinery instead, Most people, he says, would much ratheg
have the Russians because they won’t screw up the environma t as much
In the long run • . • and: at least you can ask the Russians to Leave
if it doesn’t ‘wor)lout. There’s no getting rid of oil efjnerjea.
s long as they mak e money, they stay. They’re a big stationary in-.
vestment. Matter of fact the letter says they are known to multiply
and spread out along the coast, and get bigger once established,
But, it says right here that if Russian naval base it isn’t, then
an oil refinery It isi
P.. An oil refinery? They’ll pollute and develop the last natural
area north of the Carolinas? Doe that make sense? Don’t they c re
about thesselvea? Don’t thos. misled few know a refinery esne many
more tankers, many more chances of oil spills and Ziuti , A
polluted, destroyed environment pollutes and destroys the pmopl* i
it, Don’t they read or believ, in histary or the Uib j? God told,
Noh for his own welfare to take and keep g j the animals g th. ark,
The City Coa ctl sounds like £t is pl.nntn to kick off some of thnm
with poisonous oily water and sulphuric acid fog from a ref theryl It
states right in the Bible, “That which befalleth the songs of.,men
befalleth beasts. . . as one dieth so dieth the others yea, they
have all one breath.w (Ecciesiastes 3, 18). Is Eastport full of
heathens?
S.. Why doesn’t the federal or state government stop it just like you
can stop the Russian naval base? Protection is needed in this situ-
ation, right?
Pt It’s not in our make-up or nature. It’s an internal matter.
S.. Excuse me, Mr. President, sir, but what about the Environmental
Protection Agency, E.P.A.?
P. $ Are you kidding? The E .F A. just makes big business gobble up
the environ 1 more slowly. I’m sure E.P.A. would never directly
say NNO to a refinery like the government and the Pentagon would
say “NOv to a Russian base. The E.P.A. listens to BIG OIL money,
BIG OIL public relations, BIG OIL lobbying, BIG OIL profiteering,
BIG OIL spills, and BIG oIL excuses in just the same way that the
282 4
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-5-
public doss. Just read their Environmental Impact St tesents. At
best E.P.A. fines aig Oil a piddling sum of money If they disobey
. oee pollution law, but that’s not protection. Now when I call out
the .m.d forces and sy “NOr, that’s what one might call protectioni
$.. Mr. President, sir, how then does the federal or state government
protect the environment and the people In it?
P.s Whoever told you that we did? You’re so bewildered I can’t
beli.ve its You b4liev. the Environmental Protection Agency is
n sgs, y for protapin the environment. I know, it’s exactly
the sass words, but just because it sounds like it protects the
evwiroonsnt doesn’t mean that it does. E.P.A., 8E.P., D.E,P,,
C.R.AP., they’re all the same. Just look at the state of the American
anvirouM nt today and you’ll Jaiov exactly who in this country protects
it. NO )DY, that’s vhol The way it works is if peopl. can’t die .-
tingutsh between the powerful brainwashing of the mighty businesses
in their and their own everyday veil being - if the people
d ’t a to their senses and protect their own environment - than
mobody viii.
S., What should I t.ll the councilman. six?
P., Tell hi* that if he wants to represent oil coepanya he should get
a job with th. If he wants to represent the people’s welfar, like
he’s elected to do, then he should encourage thes to take care of
tl ..lf.s by writing letters to E.P.A.. taking E.P.A. to court,
elmct concerned councilmen, and pass resolutions over and above the
council which will protect the environment in a permanent manner. If
people tell him they are helpless when it comes to environmental pro.-
t.ctien whit they are really saying is that they are lazyor scared.
There’. plenty they can do, especially if they get together. knd tell.
the uncii.an to forget about investing in Russian—to-English diction-
arise. When it comes to protecting the American people from foreigners,
the federal government will. do it pronto, you bet, because big busi-
ness vL.l let uss it profits when we fight. But big business has
become too powerful. It won’t let us really protect the American
.nviiuaaent, or the people in it from their own overwhelming desire
for gold and what it can buy.
S.s I’d sur ilk, to tell th. councilman what you’ve said. Mr.
President, but I’m afraid I’d hay, to learn to cluck. Evidently,
they bays poultry serving on the council in Eastport.
282—i
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P.s Poultry?
S. Y , sir, th. councilman who wrote the letter is a -
he di ’t s i sign his naa, nd the rest duck the issue, Isn’t
that fowl? An oil refinery? They cant pulløt off without .ing
a bunch of turkeys.
P. tggnactly
282 —6
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TRA1LS1DE’ SCHOOL
i,1 4 11 11 .se VtIPO,T
1976
D. r *, Prench,
a ooe.d is the *8,50 for the Quod4y Tide ubeortpflon that we
SPOke sbaut ca the phen, We decided to have the paper foflow us in
our travel. srows* the aauntl7 because there ar 1mpo t4nga
hepp.ninj in th zo4dy ares that we want to b. aware r
r th. soener the b.tteg we hop. to b. full tia rssld*nta, I 5uS$’
say thoia t that I send in the subscription money h.eLtantly
J b taus. of ,hat 414 o ecur in relation to the artio2.. that b(i*. Just
ennt ye i, It we. not that yov rejected It bc*u that’e happened
b.faç., it is the reasons for which you did so, You liked the
attia , I eaeu that you agre. at least somewhat w4th fte aefltjmen e
but ‘t print it becauc. it’s too lnflaatory -• the,;o $y.couneflaen
w ul ’t uk. it, I juat can’t understand it is th -: QuoddY fldu
a free prsee ar is It too confrolled by oil int.reataind’aU
power? I dt i’.t think. it was but the artlol. is not something you
have written, it was written by a read.? end you won.’ t iven take
a paid sdvertiseaent, t just daaan’t sake aenIó, -/Ya know,
I read the artiols about the meeting )w14 In etpOrt $ .othe ’ week
aboi $ the vj ’D.cta3 j at tatoment and only fou 4. ai $ Later
hat zs.U.y happened at the a..ting, Why did my infors.atia hav. to
acme from fri.nda and neighbors who were at the meeting t ath.r than.
from the articl, in the Tides. All the Tides told me m why the
óity councilmen wanted the refinery; why didn’t it tall me that Marten
lkdgins. ,i pt.4 .th. *s.tlai and asked the people whO ware
oU to stand up and a ority rode;why dt4n’t it ta1 1• e that al*
of people gi*i’t get to speak who were against, the reftn.ryj 414 -
I have to’ read Batbar lehigh’s letter to get the’ other point of view?
S.ane like some pretty selective reporting to mel
Looking forward to more realietto ‘reporting
not editing;
stlI( t’
284 ,1
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0 c’ !g’ Jq ( s)
U • S. EnvironmentaJ Prètction Agency,
Region I Enforcement Division D C 2
Bostofl, Mass. 02203
Dear Sirs,
I have just returned home ] to Treacott Maine for Chriatnas and
made an informal survey. You migh$ interested in e results of it.
I have spoken to seven neighbors about their thoughts and feelings
with regard to the proposed Pittston refinery. Al]. of them, with one
exception, are opposed to it. What is most important is that none
of them have wZitten you. Two never found out they could write to
let you know the reason why they oppo e it. The other four have just
had it up to their ears with the stupid attitude of big business and
government; mainly that economics is the only value which has any power
in this country and if you don’t have much buying power you’re pretty
much a nobody when it comes to determining what kind of an environment
makes most sense for your community. They ‘ye written and fought in the
past and the outcome was business as usual, so they just don’t trust
their government or country any more. They feel that to be effective
one must get a job at the refinery and then secretly undermine it so it
loses money. That’s the only thing which talks, which is heard, or
wi].l make it stop/
Th seventh neighbor thinks the refinery is a bad idea environmentally
but since the Canadians have on. in St. Johns we ‘d a. hurt by an oil spill
from it there so we might as well have one he* and make some money
from it. But basically, he is also opposed to it.
The significance of my findings is that for each person who does
write there are probably 5-7 persons who don’t write. There are an
overwhelming majority of pop .. in Quoddy who won’t writ* or act because
they have learned from the environment of the past that it’s a waste
of time. To me that is foolish. But I think it is important to know
that the letters you z eceive against Pittston would and should safely
be multiplied by five, or even seven to determine how many
feel distrought about a refinery being built.
You might want to very seriously consider the following questions
Why does only one 01* of seven people with strong opinions against
the refinery write. What has happened to the .other six who run from
25-77 years of age? What has happened to the newspaper the QUODDY TIRES
which has turned down articles of mine against the refinery because
they are afraid of the reactions of the City Councilmen. ., and admit
it whon you speak to them on th. phone. In each case the individuals
have learned from their ENVIRONMENT that there is no room for what
they know and feel. They’ve given up. Economic power is in complete
control and they know it. Th. fact that EPA can even consider
d.spoj ing the last 100 miles of coastline makes it quite plain that
you know it too.
The actjons of such people are a direct outcome of the environment
in which they live and have been brought up. It is the environment of
big business and a lobbied government. It Ia nothing short of disgraceful
that at this late date an EPA can still find the ways and means to
condone the construction of an oil refinery thereby reinforcing an
environment which has already made people feel helpless,: suspicious,
and resentful of their government and economy.
285—1
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We all know that a refinery in no way belongs on the last small remaining
indisturbed coast of America. Megalopolis would never notice the effects
of it. There it is already too late%-too late. To continue to despoil
relatively wild coast when 1000 miles of megalopolis could be utilized
instead is nothing short of a despicable action for a federal agency. It
makes me ask,myself questions I don’t want to hear” who is watching the
federal govt EPA . Has Pittston bought off a secretary so that tkis
and other letters are being lost, stolen, burnt? What will Pittston do
to me when they learn of my reactions to their efforts? Will my house
be burnt down? U Oh, it • s not funny to have to live, in an environment
under the thwnb of so powerful a lobby as Big Oil. When you call the
local press and find that they have been put into a state of fear so they
won’t print what they express to be a worthwhile article one cant help
but wonder what kind of a trap letter writing invitations may be. That’s
the environment we at Q aoddy a e living in today. So is the rest of the
country. The refinery is but one mo re coffin nail in what was once the
magnificent dream and blood of the founding fathers of this country, Gold
was also important to them but so were the rights of men equality,
life, liberty, the pursuit of happiness. By lending creedence to the
request of an oil company to further extend the environment of big
business makes a mockery of what this country was upposed to be. What
happened to my rights and those of my neighbors? All we ask is a rural
environment worth living in, one which will support life. Most of us
came up here from megalopolis to get away from it. That’s our way to
pursue happiness. Look at the map EPA: there’s no more coast, there’s
no where else to go and remain American. Eastport is the Canadian line.
Ain’t you proud? 1 You’ve helped and are still helping establish a new
America one where, 1 those with financial power enjoy those original cherished
rights which are supposed to belong to all of us. How can that possibly
be fair in your eyes? Why don’t you protect a pristine environment and
tell Pittston to go to hell or Boston. In our eyes there is little
difference.
For your amusement I am including a copy7of the article which the
local paper was afraid to print. Perhaps it will help you see the kind
of environment which now prevails in Eastport and which a refinery will
promote. It’s even reached the freedom of Ithe press,.is this the kind
of environment EPA is protecting? W H)’?
yours,
&
COhen,
Lubec, Maine 024.652
285—2
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286—1
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CARLETON \V. AYLWARD
LINCOLN, MALNI 04437
December 30,76
EPA Itegion I
2203 J.F. Kennedy Federal Building
Boston, Massachusetts 022203
A’ T: John McGienon
RE: Eastport( Pittston Oil Refinery
My name is Carleton Aylward. I am a Real Estate Broker from
Lincoln, Maine and have been since 1956. I also am a property
owner in Eastport, Maine. I have seen the fishing industry and
sardine canneries gradually go down hill due to lack of fish,the
textile mill go up and down due to market conditions until you
can truthfully say Eastport has nothing but a minute percentage
of overall employment that is dependable. This creates the
problems of low wages high unemployment and very little incentitive
for the young to remain in their current surroundings. My educated
guess is that the largest employer in Eastport consistantly is the
unemp].oyment commission of the State of Maine.
I have also been involved in a nonprofit development group
in Lincoln, Maine for the past 12 years, who have put a paper
mill in business, a shoe factory in business and a worsted
mill in business. We as a group have sent over these years literally
thousands of brochures to prospective manufaôtures and made
hundreds of contacts and telephone calls to prospects. I am
here to tell you that to get a heavy capital investment Industry
to even consider the state of Maine is a feat in itself. We are
far from the market place,we offer few incenitaves,tax wise we
have high sales taxes ,state income taxes and a small population
to support our ever increasing state budget. The industries
who seek out Maine primarily are those looking for inexpensive
labor,cheap leases on vacant buildings of which we have many or
a large unemployed labor force.
A project such as an oil refinery represents a tremendous in-
vestment in dollars and cents çer job. The refinery being con-
sidered represents an investment of approximately 700 million
dollars with a nroj c’t i nost in labor of 20 to 30 million dollars
over the building span with an estimated employment of three hundred
direct jobs,200 more in contractual services and the additional
factor of for every job you create you create part of a job for
the oil man, the gas man, the water comapny, the garage, the
plumber and so on. Let us now consider a part of the project that
no one knows. How much sales tax does a multi million dollar
manu.fact irer spend per year just to purchase the necessaties
to manufacture their product? How many industrics maybe interested
287—1
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(2)
in Iocattng close by or even in Ni. w England because of oil SUpplieS
which may aol be ny cheaper but at least nrc there, remonber it
was only a few months ago two of Main&’s largest firms Great
Northern Paper and Georgia Pavific wore within days of shutting
down due to J.ack of oll(their supplier Canadian).
I would Lemark in closing there remains the fear of oil
spifls,iu niv youth I was a Merchar.t. Marine Officer going into
New York through hell Gale w s alw.tys ‘n ‘xperiencc you didn’t
particularly care I cr. The river in Antwcrp another very bad
passage and numberous others.
However expert pilots have been putting ships through
boat passages with very few problems for centuries as they will
be in Ea5tport. If the weather remains unfavorable the pilot
may elect to stay on the hook for a day or more until the
weather is favorable. He has that authority.
Ve also have a refinery in the same bay(Canadian) that we
have no control over and none of the pluses that come from big
industry.
I thank you for your time.
Yours trulya
Carleton W. Ayi ar
Lake Street Real Estate
5 Lake Street
Lincoln, Maine 04457
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288.. 1
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289—1
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I ,etter, tu the &iitur
The A, o Merchant
Should Help Us Think
Deer Sir:
The.. pc4nls in regerd to the ARGO
MKRCHAWF oil dlsutsr gould be noisth
1) The us of the —jr-.y for wbtan the
oil was ds .Used.
2) The contract for II pInlt of oil In the
Argo Merchant. by when mad..
3) Tb. “Act of God” semis. Tb. rusty
tanker has had 18 minhaps to her demerit Tb.
tanfrat was off course. Why?
4) A full ssdgàtIbn of tIde aIdr tragic
spill. with no whitewash end mention of en Act
of Gad but with hI pIssed usectiy . .hus It
b*.iig , en the L bs of a ir kederu. who for
reesoen best bonn to thswlrus . I Sis ? .
dangsroes conditiosa which should be watched
5) A rsnilndir to our pOlItiCians end
heresucrsts Just the bit that ha. been divu1d
gIvse further rasson for the to bee. titus
faith or trust In our hsdsrs..
Turning to Pit s.$ly affairs. there te
dia mte about having to asospi c.rtsln rub so
lug a. we era dsywlut en far all. Yet do
we hay, to cheess a bean. dangerous Ieon m
tobringia oil fare ri bs pls isd so t 1 ttht’
psny can op.rste. at • prot. to the
detriment of sli of-
their tiving and pr* f or
ersItog a pia,....._ii far t...Fs . ,shbi
Let lb. ARGO U A 4T tsr b. p es
to think.
Yours truly.
tAi..iiiat 14. lath. .
Mora Letters as Pap a
289—2
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augor aiI ew
10 IAN001. MA3NI. F 5$DAY. DEC MIEI 31, 1916
IN OUR OPINiON
The ‘controlled experiment’
Prior to the operdog of the US. Department
ofthelnt.rkwshe.rtogsInBeatenonl hlgoL
e fracto off the Atlantic Seaboard for oil
deWing, we had a vInit front a represeidative of
the Ameiican Petroleum Inetlizate sad some
L 5fl
carrying r ’ ’ 1 authorItative
bon about the fecI ’ logy of offshore
de Nataaslly. too, they were st* sIng the
retative .svir ntaI Integrity of offshore oil
Ii ou t of thetr assiwsnc., that all
“ &(JLI LL i iidbei ” will be taken before
ac ntl eti to tahoe from beneath the ocean floor,
on ’ of vWtors fl d a flow chart of the
. .,tILd lapl e,a required by g n-
L
reassured by it, placed it In the file under “0”.
Then the Argo Merchant broke up off Nan.
hIi !ket , spewing her oily Innarde Into the sea.
And almost from the moment that 7.8 million
llooa of crud. oil spilled, it was ago iizingJy
obvlcsa that man was net In confrol and that
tineoll w bomdlor wherever the w1 tide.
and arrests wanted to take It.
We repeat . A major, potentially catastrophic
oil spill, and we stuoditoiplesaly by. Where was
the clean-up techeology we had heard ro much
about and placed so much confidence in’
The flow charts and the gentle words of
ressswance from ‘the oil indietry public
relattoi*.pseple were if ftle value. The US.
Comet Gtardfs “controlled experiment” Is town
off theoll never got InItial base.
We out the longtby flow chart from the
“o” file. In none of tim Is.pba lwocedimre boise
could we find “D oafratIm of teelmaloglcal
capacity tocleaaupmajerollspllL” ifit Is in
there, we c akb1’t f1 nd It.
If it is in thero, we would hops that the En-
vlronmeimtal Protection Agency requires a
practical demncostration of effective clean-up
techeology before prodection commences and
the drills if the majors inàk t&...gh the ocean
floor.
Clearly, tarp M *11 teeh demo i
as yet . !mst .
Cued a “wecs al ) ‘ing flow chart for
O.C.$. aid p. prodeetion,” ft literafly strot-
chsd bom om s if the office to the other.
Thom mIa o Ung , its sheer a im made it
l.lpi u1.1vv and c Ung. From the latial
ftlüigofages4ogkalpermittothecommenc lng
if commercial prodection, the chart indicated
dorms and doses if separate proce ea . each
if winch read as If itconetituted the Map. Car’
to drafting Itself.
The oil left. We rued neer the flow chirt
a little closer , and still feelkg som.Lt
289—3
-------
TH A 1CAN, ELLSWORTIL MAINE GteO5 .
- a . FWE
ByL.rneS
life seems to have a tendenry to
gainsay diaclaizners, sometimes to
a palM of fine irony.
In 1970 when Sen. F.d r. M MuMae
was hearing proponenta clan oil
port at Maci saport disclaim my
great ritha in the iraz ort of oil by
isrge tanker the tanker ARROW
was going ageound m far away In
Nova Scotlan waters.
Now, lees Uwn , wi h after the
last gkslous wlthn 5 ci risha In
frasuporthig ad tteou Read Nor-
beer P lg . to the gropoad Pun.
ton refInery at Eastpert , the tanker
ARGO MEIU WIT, care ng 7.6
n t ipi — of oil, ha iU.d
her cargo afte ine.k*ng spent caa.
shOal o
At the hearing A.F. Kaulaki, said
the major decla loIV for navigating
tankers through the Passage was
the re onaibllltie. of the captahu
and pilots, not his. Whether ittaton
Is rP’ponhih . or not, it may find
itself dealing with the kind ci
captain who can get tea miles off
course In the open sea. Head Har-
bour Passage is only 3* feet wide
at Its t*’oadest and othwim frk y.
The ARGO MERCHANT was only a
little more than half the La ci the
carriers PuUMou M W
talks about putting tircugh the
Paenage.
TheARGOcaptalnaM: “Iwas In
the wrong position?’
l3e e arewa s . Heshonidhave been
selling oboes.
A recent d .i4 â , w by the lidiec
selectmen she iswno to have bean
overturned by life. The ARGO had
been I g her oil for eeme day.
when Liibec’s tsom p - ne
J MIC d Ms bused’s — ..,4t for the
PiUwon devekçmai at — t .
According to a r ort in the BAN-
GOR DAILY NEWS, he aid that 1*,
bøsrd bellevas 11w
hiW.ct ci the r j “waiM be
stringently regulated by Mate and
federal agencies.”
According to one ri the ARGO
has had ii accidents since lilt and
has been using US. ports In that
thaw. e was husking when the
do&sd In Boston Harbor 1aM year,
Two of the accl ’te wew ground-
m g i before this, her flea! “acci-
No power on eagth, even If a
regulating plen Misiad could coi.
the oil stiullng from . Now.
we maM face the oomupmaces.
Much Irdcrmati1m has been d i-
veloped conceIiiliW the probable
effects of oil on marine his. Cone-
taut review seems , w,c ry stoics.
lot ci laths either forget or Ignore
It.
The tadmony of Dr. Max Slim-
mer, isnior scientist at Uw Wooth
Hale OceanographIc Inst itution, it
the hearing before Sen. MuMae Is
still pertinent:
‘11w toxicity ci cnmde oil and oil
prodicti to marine life and the
danger ci oil pollution to the mailed
ecokC has been e 1 ’ In
several thde ’it ways.
“ ‘11w studies ci erode oil compost-
tim haveA that M I contahe
boiling arOU — and Id*..
hyfrocarbofla,
whech act more alowly but are
equally severe In their e’ect; some
ci t are known to cane. caneir.
“Laboratory Maths. on many
marine anhnal . live d.nu.u.fr,ind
the toxicity ci oil and c l i predicts.
Field studi, have shown the thaM
rena ect of oil spills a marine
org nlnl in their normal
From each inveatlgatims we know
that all end. oIIa and Ill oft
products, with the ercspllrn ci
highly —
are pUes icr all maine cr
“We nead to ,.. ...tn..l ea
inoblan ci pafreleom ad mow .
S years ago, a high hucji . ci
this cancer In some refinery pu’
aamal was o*u ‘ ad . The cause was
friend to prolonged skin ceetact by
thtp. with patrolman sad with
r 7 pIOdtCtA BsUar plaid di-
sign seat education, aimed at pee.
vdisg the base Maca
riedaca 1 or a ,i t,4 IMs baaarL
0...... . ,tbess have e.
o stsd t ill and oil predicts
can cause wor he man, ad thai
finiflvp wern spv tad by the
I-.’ 4i- ’ from p*uhem of
caleUwt see lawun to cassceaor-
and that were ictually shown to
induce cancer In tai animal .
‘ Ithgoaed . In plaM
— the public from this hasard;
whem oil I. spilled Into the
etivircoment we lou froi over It
and should again be concerned
about the piui . public health
beard ftvm oi chem
eels In the oIL We have shown that
maine crg - In gaM and rMaln
hyike..4 ai to which they are
19 A 5 II Etans sew transferred to
and rolahed by predators. In this
way evea aa maJ that were not
directly uIp _ d to a spill car
piuZh by eating coutaini.
sated ‘• ‘13d. and the peas.
cane cicsmar .caaig cheMicals is
oil pmih Wu hij 3I that the t .
kathig and eating of oU metaininat .
ad flu and cseutl*umtas a
— k b be.. ”
A Communwation
Oil Disclaimers Can’t Pa 4 ss The Test of Time
-------
OilOrFish
Maine 1. ge to hav, to choose
b.twemi an oil refinery at. Eastport and.
fishing industry al its whole seaboard.
The disastrous spill of the ARGO M-
CHANT ii only. dr. tic reminder that
this I a the State’. choice. The traditional
maritime food produdni h rh friis and the
oil industry are incompatible and mutually
exclusive at any seaboard site. In some
sites, the effects are essentially local. At
Eastport. we are rI aHtig with a site that.
because of the cur nIs in the Gulf of
Maine. will mect the entire coast and the
whole ff g iathmtry of Maine.
Itis asPv i. htng to see Maine citizens.
at levels up to the office of the Governor.
calmly contemplating the destruction of an
bi dustry which yi.kI d in 1974 an annual
Income of $41 .410.167 and In 1975 a total of
$46,406 ,343. Waskn County flàhermsn
alone brought In a catch worth $7,006,949
in 1975 ; Hancock Coiaty fishermen gained
$11,000172. P.opl . li about the destruo..
ties of dO fWii”y as 1h it were a minor
matter. The selectmen of L.bec opted for
the Eastport Pittassi r .f1es , s though they
had no stke in the fishery . The’ resemble
thed gin the fable that dr .4 pad its bon. 14
tbebreukinan ortinc*pture it. image In
the water. The wildest optimists do not
aspect • refla.ry to match the tncom
Ms4,i peepi. dolt, , from ft.hIng
o’ . . r. being t tht they can
have both their ‘ ih 1 g ta try and a new
coastal oil r nery at Eastport . This Is
simply untrue. Nothjag is mor. contemptibly
false than the assei’tkm of. Pittston offlimi
that major spills are so rare as to be
immaterial. There a mars than tea
thousand coastal ws psA.ides spills a
year-mar, than thr,s4osrths of tb des
to oil. To be ears. an APCO M CHANT
doesn’t go aground every da but the ,, are
.$getflcan& pollution . pilb somewhere .very
day. And there are spills In oil
ports that have ideal natural conditions.
- favorable tea safe operation.
Mllford Haves. Pag1 nd one of tb
most modern and best run oil ports in the
world, in 1967 bad 55 geifii ant spills. 7 •t
jetties. 46 from fanL.i ’ at jetties, 2 frvra
--- - in passage Ther. were 32 spill, of
lees than 60 gellom. 1S of W In 160 gafl a
ed 7 “ c ‘t hEW’ The.. m II
spill. during dlschargp of cargo. 9 darIng
loading. 4 loading bwjkars. 4 bsllsathig. S
pimping bilges. 10 die to d.f cta. 2 to other
causes. Since 1960. M.iltord Haves has bad
three major .plllu the 3O POWTSMOUI’H
got afire and dnp d an estImated 300 tons
the C iRY$Sl P. G( JLANDR1S. In January
1967 spilled 250 tans the JJAMP4
(X)ATS ran aground on mld .chanawl rocks.
captain G. DaIsy. herb ‘ .. . discs.-
s 52 spi . esys ‘enfo,mtusaluly
dOs .. .. tube anuive sbli aspect of
tm*s ’u op tiom.” And so It Is. Mali . he.
had esough tanker spills In the ares to
they are not “Infrequent’ as Pittston ’s
Kaulakis ha. argued-The TA MANO caused
much damage In Portland harbor. The
barge ARROW sank off Prince Edwards
Island.
Tanker accidents ire frequent on the
high seas and in navigable waters: they can
be expected to be more frequent in
passages like the Head Harbour channel.
entering Eastport.
Roger P. Duncam. ho writes of his trip
through this passage In EASTWARD de-
scribes this waterway In his account of a
DownEasttrip
“Hers. a nil, wide, Is a region of the
most violent tidal activity around. The main
fooce of dis flood tide runs up the eastern
shore of Ca obello . around East Quoddy
Heed and southeast through Head Harbour
Passage. Off the southern end of Deer
Island. It ma ss a hairpin tUrn and meets
another branch of the current coming north
through Quoddy Roads and Lubec Narrows..
The situation Is further confused by the
current c lng down the St. Croix River,
the current flooding ci water in Cob.cook
Bay. The rssultlssturbulucice on both flood
and ebb that poem ordinary credlbility.L.
A good skipper, sided by tugs, could
p.rbsps bring a supertenker through Head
Harbour Passes.. Bat to brine In several of
them each week In fog or storm through a
channel with jagged rocky aides only a few
hundred yards wide would sooner or later
lead to a TORREY CANYON disaster that
could pat a “bathtub ring” around the
whole Bay of Pundy and ruin the herring
and labeler fisheries for years.”
about to sell Its lnhri-
tance for a mass of potleg.. If Pittston
c s to Etport Mains will be pitting in
jeopardy the asrins food Industry that
ought to be Its m lii.t*y. The normal
of an oil port will drive the fishing
Industry from that vicinity. The Inevitable
major spill (even one as big as the ARGO.
MERCHANT). dee to the counter clockwise
gyrs in tb. Golf of Maine and the Corlo&u,
effect will carry the oil insh . and push It
a_s the co.sthns where the deadly tovic
material will settle into th. rich marginal
dss ‘ r -bet .lIvftig Cr.atbP9s
as the ‘ ‘ :.. mussels sod
bleed wot. A ganerathm from now. w
oil has ceased to be available or so far
declined as to be priced beyond reach for
fuel and propulsion. the abandoned towers
of the vacant Pittston refinery will rise like
an ugly monument to the dead fishing
Indistry which Pittston destroyed. The
invseto - . who own Pittston will be far away.
exploiting some new and different resource;
but the rs ’ 4 ents at Down Ei t Maine will
still be living as their once fertile, but now
shills shares, from which all marin, life
will hey and at which no tourists will
289—5
-------
j ) d I
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71
2 90—1
-------
QUODDY BAY CO -OP, INC.
Fresh end Process J Fish Products
RFD1 80*154
Lubec. Maine 04652
Tel. (AC 201) 73 4445 Henry N. Merrill. Jr. Manager
Jaeuary 13, 1977
Johi A.. S. MoGlerrioa, Regi:r al Ld iitetr.tor
U.S. evir ita1 Proteotlo. Ageaoy, Region 1
.7..’. !ernedy Puildir2g
Boeto., *e.., 02203
e& Tr ,poeed Fitt. ’tc’v Con ”eny’s project at Ea tport , !&iae
!)ear r. L cG1e o ,
Quodiy Bay Co—op Iiic. i. fi terire.v owned and operated orga izattoa of
tifty—four aemlers. Our em1’er ’ e,er most or all of there livelihood
by ha-vestia var oue ari . crn I rron the Wetlands, Pa ,., River., and
Sea wriioh e oompsea tne ‘ :‘ ern tal of Waal 1rg ’l n County.
We erie the tit), rte3 or this area not as $ neer siear of eurv1.val ut a. a
rswardia g venture laden with future potential.
W. strongly protest the eaorifioe r f this region to an i dustry whieh so
l o1i1y dajroietrates 1t. total laok of ooaoer* for rot only cur, but the
orLd’a urine re :’ir es.
in a ary e are o roeed to ar Oil Refinery .antil such t tue a the oil
iriiustry in prspared tc duot itself In a re ipoi’ tb1e manrer
i oet si.c.r.1y
‘4 •
lienry I L rrill, Jr., ö.aa er
‘ /44 ’
291—1
-------
13 DEc
December 10, 1976
U.S. Environmental Protection Agency
Region I
Permits Branch
Room 2109
John F. Kennedy Federal Building
Boa tun, MA 02203
Subject: The Pittston Company
NPDES Permit
Application No. ME 0022420
I writing to express my concern on the Pitteton Oil Company’s request
to build an oil refinery in Eastport and the subsequent Environmental
Impact Statement that was prepared by your office.
I am a life—long resident of Perry, Mains; born, educated, raised a
family, and owned end opsrated a retail sales store for 33 year. along
with 53 years of come.rcial fishing.
I have seen this c -” 1ty degrade from th. lack of work du. to changing
of time. and conditions.
Alter spending hours at the recent EPA and Corps of Engineers hearing
in Eastport on December 3, 1976, I am concerned that a minority and very
vocal group that was present at this hearing would give the impression
that this type of ecosonic development was not wanted by citizens of the
area. This is not the case. People who have spent their lives in this
area, who have worked long and hard to make a living wage would welcome
any industry that would better the living conditions, and bring the
peace of mind that comes when one ha sufficient income so that he does
not hav, to worry where his next meal will come from.
Fishing alone has not been enough to raise and provide for a family. I
have bad to fern, cut wood, cut Christmas trees and run a store to meet
these need.. In recent years the trend has been for most of the young
and industrious to leav, to find reliable work in other areas of the
State and Country. We need the capability and capacity of industry to
keep our youth in the area to maintain a healthy end growing comeunity
that would not be dependent on the welfare programs.
292—1
-------
U.S. Environmental Protection Agency
Page 2
December 10, 1976
My experience and knowledge of the fishing Industry, waters, and
harbors dates back to where 53 years ago there were two fish processing
factoriesp*JRobinston, 1 in Perry, 1 in Pembroke, 15—18 in Eastport,
10—12 in Lubec. There were 5—7 sardine carrier boats for each factory
and a sardine can manufacturing plant in Eastport and one in Lubec.
In contrast, today we have 2 fish processing factories in Lubec and 1
in Eastport with a total of 4 sardine carrier boats for these.
I have personal knowledge that in the past that these boats, powered
by gasoline and. diesel engines, discharged their oily budge water and
their engine oil when changed direct1 ’ to the waters that the Impact
Statement indicates will be discharging 60 gallons per day of various
types of oils.
I also know that the fish processing factories and the canning factories
discharge all their wastewater, process water, lubricate wastes directly
into the waters. This has been done for a number of years and has had
no affect on the fishing in the area.
In recent times several oil spills occurred, originating in Canada, one
in 1974 with severe accumulation of the oil at the Perry shores and La
fish weirs that I own as well as in those owned by others. This oil
spillage did not effect the catches that particular year since the weirs
that caught the most oil also caught the moat fish that year.
Another spillage occurred in July of 1976, after which herring were also
caught. It is my opinion that limited oil spillage or control of limited
discharges does not effect herring fishing with veirs O k atop seining.
An oil refinery in .astport would not effect my future ability to catch
fish in anyway.
The report also considered the ability of large crude oil carriers making
the head harbor passage. I have traversed this passage with my fishing
boats through all types of weather, and any captain or pilot worth his
salt could bring a large vessel through this passage without harm nor
danger.
It is my opinion that there is sufficient environmental laws on the books
which, if properly enforced, would allow a refinery to be operated in
Eaatport, Maine.
292—2
-------
U.S. Environmental Protection Agency
Page 3
December 10, 1976
If we can put a man on the moon, we ought to have enough technology
and ability to build a refinery to meet the existing and future
environ nt requir nt..
Very truly yours,
Colon S. Morrison.
Perry, Maine
292—3
-------
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OFFICE OF HE GOVERNOR
* €ead4 ce øc e
PERRY, MAINE 04667
TO: Mr. John A.S. McGlennon
Regional Director
U.S. Environmental Protection Agency
Regional I
John F. Kennedy Federal Building
Boston, Massachusetts 02203
RE: NPDES ME0022420
FROM: Francis J.
Governor
OATE: December 10, 1976
I have enclosed (2) copies of our statement relating to the evaluation,
and assessment of the Draft Environmental Statement concerning the Pittston
Company of New York and their proposed Oil Refinery. The Passamaquoddy
Tribe requests your agency to reject this permit or permits requested by
this company and any other company or corporation, proposing an oil refinery
in the Passamaquoddy or Cobscook Bay area.
We have, also, forwarded a similar request to the U.S. CORPS of Engineers,
Department of the Army.
GW
296—1
-------
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298—1
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(t..t J&44.I t
2 8 DE 19?s
MARINE MAMMAL COMMISSION
1 2S EYE STREET. N. W.
WASHINGTON. DC OOO1
8 December 1976
Dr. Steven X. Katona
College of the Atlantic
Bar Harbor, Maine 04609
Dear Steve:
I am forwarding a copy of the Commission’s letter to
the Bureau of Land Management concernirq the Draft Environ-
mental Statement for OCS Sale No 42. Your extensive cri-
tique of the DES was invaluable to the composition of this
letter. Thank you again for providing your comments.
I also have enclosed a form for your use in providing
whatever consent you feel is necessary and desirable to
facilitate consideration of your proposal (MMC-136). Be-
cause the Commission would like to provide a careful and
complete review of your proposal, we may want to disclose
it to outside reviewers and other agencies. Provisions of
the Privacy Act of 1974; 5 U.S.C. 552a, prevent us from dis-
closing personal information (e.g., personal vitae and. budget
items such as sa1arie ) to persons outside the Commission,
its staff, and its Committee of Scientific Advisors, without
the written consent of the individuals of whom that informa-
tion pertains. Please return the completed form in the
attached envelope as soon as possible.
Sincerely,
Jane W. Anderson
Assistant to the Scientific
Program Director
Enclosures
299-1
-------
lOL3tTt SbCLtI N.W.
WA$ItINGTO4 DC 2OO 5
17 Z4arch 1976
Dr. Robert Beaucha ip
Bureau of Land •Ianagernent
U.S Department of the Interior
Washington, dC. 20240
Dear Dr. eauchamp:
s we discussed in our telephone conversation of
26 rebruary, relatively little is known about marine mar r a1s
in coastal, waters of the Northeast United States. Several
of the xore than two dozen species that have been observed
in these waters have been heavily impacted by human activities.
Populations of harbør seals and gray seals, for exa uple, have
been displaced by human activities that compete for coastal
sites that historically were haul—out and breeding sites. Large
cetaceans were the target of the t ew England whaling industry
that flourished in the late 1700s and early 1800s. Six species,
marked with an asterisk on the following list, are classified
as endangered under the Endangered Species Act.
Pinriipeds
Phoca vitulina Pupping occurs along the
(harbor seal) Gulf of Maine; feeds
opportunistically on fishes,
cephalopods, and crUstaCeans;
autumn molt.
Balichoerus grypus Small group around Mus.keget
(gray seal) and Tuckernuck Islands,
Nantucket; Jan-Feb purnping;
feeds on fishes, squid, and
crustaceans.
Cystophora cristata Stragglers; feeds on fishes
(hooded seal) cephalopods, mussels, starfish,
and crustaceans.
Cetaceans
Eubalaena qiacialis* Migrant and winter resident;
Iblack right wi a1e) feeds on copepods; calves in
winter.
299—2
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t
Balaet Optera acutozostrata
( r inke whale)
Balaertoptera b realis*
(sei vitals)
Balae optera
nusculus*
(blue wnale)
•
Balasnoptera
physalus*
(fin vitals)
Physeter catodon*
isperm whale)
Thrs Lops truncatus
(bottlenose porpoise)
Gra pus griseus
(Risso’s dolphin)
Lagenorhynchus albirostris
(white-beaked dolphin)
Lagenorhynchus acutua
(Atlantic white i
dol hin)
Stenella coeruleoalba
(striped dolphin)
Sua mer resident (JUflQ.e.e’.);
feeds on cuphausiids and
stnall fishes.
Su er resident; feeds on
small fishes, copepods, and
euphausiids; winter calving.
) igrant; feeds on euphausiids;
winter calving.
Year-round; winter calving;
feeds mostly on euphausiidz
but also fish, e.g.., capetirt.
Su er resident; feedemostly
on eupbausiids but also on
small fish when available;
winter calving.
I4igrant; feeds on cephalopod t
as well, as dernersal and
mesopelagic fish; Swcxner—fafl
diving.
Stragglers; feeds on fishes,
squid and crustaceans, breed
year—round.
Little known; feeds on
cephalopods.
Coastal; feeds on fishes,
-crustaceans, and -molluscs;
mostly midsiimi er calving. -
Common; feeds on pelagic and
• benthopelagic fish as wel].
as soma crustaceans and
molluscs; mostly midsununer
calving . -
Year—round; feeds on fishes,
squids, and crustaceans. -
Listed as endangered under Endangered Species Act
t
Negaptera novaeanqtiae*
(hu npback whale) -
299—3
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DelohiflUS d lphis Nay be y ar-roU- d; fceds
s ddLc o ick dolphin) Ofl fishes; dives to x o
.fatho s; o fsh3:e sp cjes.
Globicephala r laena Year—round; fee s mosUy on
(common pilot whale) squids but also s ll fish;
mainly July-Augast calving.
Orcinus orca Feeds on fish, squid, octo us,
(killer whale) dolphins, whales, and seals;
calving mostly in autumn.
Phocoena phocoena Year—round; nearshore Species;
(harbor porpoise) feeds on bottom fish and on
some scuids, cle s, and
crustaceans.
Kogia breviceps May be co on; feeds r tost1y
(pyg ty sperm whale) on squids bat also pelagic.
crustaceans such as shri nps
and giant inysids.
Mesoplodon bidens Probably rare;- late winter
(North Sea iaked whale) and spring calving.
Mesoplodon mirus - Little known.
(True’s beaked whale)
Z.iesoplodort densirostris Little known.
(dense—beaked whale)
Mesoplodon europaeus Probably rare; little known.
(Antillean beaked whale)
Ziphius cavirostris Feeds an sqi.iids and deep—
(goose-beaked whale) water fishes.
Hyperoodon ampullatus Probably rare; nay winter in
(North Atlantic bottlenose area; feeds zEtainly on squid,
whale) spring—su.zztaar calving.
The most important task, with regards to the conservation
of r rine x mmals in the Georges Bank area, is to identify
critical habitat and action necessary to protect this habitat.
Areas on Nuskeget and Tuckernuck Island, for e :ar?le, are
the only sites in U.S. waters where gray seals me still pug,
therefore, it is important that these areas be to:aily protected.
299—4
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In general, kno rledge of the abundance, movements, and life
h s tories of rtarino manu al in the Georges Bank area is
insufficient to reliably predict the potential mpact of OCS.
oil a d gas davelop5?flts. t1iqratory routes, feeding areas, and
calving areas could be directly impacted by exploration,
drillir.g or transport activities; disturbance, including
harassment and changes in the acoustic environment, could cause
some soecies to abandon certain areas. Identification of haul—
out sites, migratory routes, feeding areas and calving areas
should be included in the study plan for the Georges Bank area.
A general field study to provide reliable estimates of
abundance, along with information on movements and distribution
patterns, would require a substantial, long—term financial
co iitmant and probably is not justified at this time. SeveraL
s lle .r studies would be more cost—effective in terms of
providing a. data base for immediate decision—making and long—
term raortitoring. 1 recor mend that you support
1) a marine wnnal . sighting network,. using ships
of opportunity and ships assigned to other
BLM activities;
2) a stranding-recovery program to• collect life
history data and provide baseline standards for
evaluating the effects of petroleum pollutants;
3) a survey to determine the status and location of
gray seals in U.S. wakers; and
4) a systematic monitoring program to assess trends
in the distribution and abundance of both harbor
and gray seals.
A marine maxmnal sighting network, such as the Gulf of
Maine Whale Sighting Network (GMWSN) coordinated by Dr. Steve
ICatona at. the College of the Atlantic, would provide important
information on relative abundance and distribution patterns.
The GMWSN is dependent upon opportunistIc sighting data front
vohnteer observers — trained observers aboard ships carrying
out geological, oceanographic, or biological cruises in the
area could increase significantly the amount and quality of
data that are collected. Marine mammal data can and should
be c ared to oceanographic features and distributional
ir.for’-tation on fish, cephalopods arid crustacea to elucidate
possible cause-effect relationships. Th. optimal program in
ter .s of the cost-benefit ratio would probably include a
full tirr.e coordinator and secretarial help to organize voluritèer&
catalogue ar.d analyze data, etc. Cost, including salaries,
c0pu tar tine, travel and co unications probably would be
about flS,000 per year.
299—5
-------
Ziarine mammals in the New England area are not harv st
co ercially, and it is unrealistic to consider deliberately
taking animals for scientific purposes. Studies of strat d c
animals, therefore, provide the only method for collecting
inforrtat.ion on population reproductive parameters and causes.
of mortality. Oil spills may be anticipated therefore it is i
tant to have baseline standards with which to assess the affect
of a spill. External oil may have little effect on cetaceans
and hair seals, but ingested oil could contribute to significan
rnortalities. Mr. John Prescott and Dr. Joseph Geraci at the
Ne; England Aquarium have initiated studies of stranded animals
and it would be desirable if these studies were continued and
expanded. - Dr. Geraci also is conducting investigations to
dete zztine the effects of ingested au on harp seals. A con re-
hensive study of stranded animals, including subcoz tracts to
specialists; could. be supported for less than $50,000 per year.
The present status of gray seals in waters off the North-
eastern coast of the U.S. is uncertain. Gray seal remai $ are
kno: n from late prehistoric coastal sites fror Mt. Desert
Island, Maine, to New Haven, Connecticut, and it bred south at
least to Norfolk, Virginia in the late Pleistocene. There-can
be no doubt that the species should be a self-sustaining,
viable member of the U.S. fauna. Because of the uncertainjtv
associated with the gray seal in U.S. waters, high priority
should be given to a preliminary survey to determine current
status, and the location of possible haul-out and breeding
sites. Likely haul-out and breeding sites should be protected
from human disturbance, including potential OCS developments, tc
encourage the reestablishment of gray seals in U.S. waters. A
regional aerial survey and interviews with local inhabitants
could be carried out fora modest sum.
Harbor. seals, like gray seals, have been impacted by
activities therefore it is important that these populations
are monitored to determine trends in abundance and unusual
changes in distribution. Mr. David T. Richardson of the Fishers
Research Station, West Booth Bay. Harbor, Maine, has been active
in the assessment of harbor and gray seal populations in Maine
and probably would be the best person to contact for further
information concerning these species. P routine m’nitoring
program to determine trends in abundance and distribution
patterns probably could be accor plished for about $20,000 per
year.
I think that it is clear that the primary task is to
identify c iticai marine mammal I.abitats so that p: posed Ocs
activities can be evaluated to assess their pQtent al impact
2 9—6.
-------
on narine mar nal populations in the area. Causes of
mortality should be determined as far as practicable to provide
bss lina standards with which to evaluate the impact of oil
spills that may be anticipatcd. We do not have a good under-
standing of the functional relationships between marine mamztals
and other species of the ecosystem, therefore, it is important.
that we act conservatively to insure a full range of options
for future generations.
You may find it useful to consult with one or more persons
on the attached list. Please keep me informed as you progress.
I will be happy to assist in any way possible.
Best regards,
RObert J. Hofman, Ph.D.
Scientific Program Director
Enclosure
CC: Co missioner5
Coini ittee of Scientific Advisors
29 —7
-------
The following arc sor e indivIduals, who amo others,
Ttight :e1l be consultcd for further infornatior co cernir.g
marine ia ’j a1s in coastal waters of the Northeast t!.S.
Mr. Clinton Andrews (gray seals)
Nantucket Research Station
University of Massachusetts, Box 1182
Quaise Point,Massachusetts 02554
Dr. Richard H. Backus (cetaceans)
Senior Scientist
Woods Hole Oceanographic Institution
Woods Hole, Massachusetts 02543.
Dr. Robert L. Brownell, Jr. (cetaceans)
Division of Mammals - NHB-398
Smithsonian Institution
Washington, D.C. 20560
Dr. William H. Drury, Jr. (gray seals)
Hatheway School of Conservation Education
Massachusetts Audubon Society
South Lincoln, Massachusetts 01773
Dr. James Gilbert (biornetrician-pinnipeds)
School of Forest Resources
University of Maine
Orono, Maine 04473
Dr. Joseph Geraci (pinnipeds cetaceans)
New England Aquarium
Central Wharf
Boston, Massachusetts 02110
Dr. Steve Katona (cetaceans)
College of the Atlantic
105 Eden Street
Bar Harbor, Maine 04609
Dr. Arthur W. Mansfield (gray seals)
Arctic Biological Station
Fisheries Research Board of Canada
P.O. Box 400, St. Mary’s Road
St. Anne de Bellevue
Quebec, Canada
Dr. Edward D. Mitchell (cetaceans)
Fisherics Research Board of Canada
P.O. Box 400
St. Anne de Bellevue, P.O., H9X 31.5, Canada
299—8
-------
Dr Roger S. Payne (cetaceans)
Research Zoologist
New York Zoological Society
kockcfcller U .ivcrsity
New York, N.Y. 10021
Mr. John H. Prescott (pinniped c taceans)
New England Aquarium
Central ltharf
Boston, Massachusetts 02110
Dr. David T. Richardson (gray harbor seals)
Maine Department of Marine Resources
Fisheries Research Station
West Boothbay Harbor, Maine 04575.
Mr.William E. Schevili. (cetaceans)
Museum of Comparative Zoology
Harvard University
Cambridge, Massachusetts 02138
Ms. Susan C. fi1son (gray harbor seals)
National Zoological Park
Smithsonian Institution
Washington, D.C. 20009
99-9
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MARINE MAMMAL COMMISSION
1623 EYE STREET. N. W.
WASHINGTON. DC 20006
6 December 1976
Mr. Curt Berkiund
Director
Bureau of Land Management
Department of the Interior
18th & C Streets, N.W.
Room 5660
Washington, D.C. 20240
Re: OCS Sale No. 42
Dear Mr. Berkiund:
The Marine Mammal Commission, in consultation with its
Committee of Scientific Advisors on Marine Mammals, has
reviewed the Draft Environmental Statement (DES) for the
Proposed Outer Continental Shelf Oil and Gas Lease Sale
offshore the North Atlantic States (OCS Sale No. 42). As a-
result of this review, and pursuant to our responsibilities
under Section 202 (a) of the Marine Mammal Protection Act,
we make the following comments and recommendations.
P. 358, paragraph 1: The citation “(Katona, 1974) is
incorrect. It should be listed here and in all later
references as:
Richardson, D. T., S. K. Katona and K. Darling.
1974. Marine Mammals. Vol. I, Book 4:.
pages 14-1 through 14—102 in The Research
Institute of the Gulf of MiIne (TRIGOM).
A Socio—Economic and Environmental Inventory
of the Gulf of Maine. TRIGOM, South Portland,
Maine.
p. 359-361: Table 11—46. This table has been changed and
amended since its original preparation. A copy of the new
version (see enclosed draft) will appear in:
Katona, S., D. Richardson and R. Hazard. 1976.
A Field Guide to the Whales and Seals of the
Gulf of Maine, 2nd ed. College of the Atlantic,
Bar Harbor, Maine. In press .
299—10
-------
This book will be available in iaid—December, i976,
from: The College of the Pitlantic, Bar Harbor, Maine 04609.
The Cctz ission recommends that the revised table from this
second edition be used in the final impact statement for O s
Sale No. 42.
The most important differences between the oriqjna l and
revised tables areas follows:
Column Headirt g Original Table Revised Table
Dominance in Relative Dominance
Gulf of Maine iu Gulf of Maine
Species
Phocoena phocoena
Estimated Abundance 4,000—10,000 Not known
in Western North
Atlantic
Globicephala inelsena
Estimated Abundance No estimates: No estimates
in Western North most common whale
Atlantic seen in Cape Cod
Bay: schools of
up to 300 on
Georges Bank
Relative Dominance Frequently seen Frequently seen.
in Gulf of Maine May have been
reduced by hunting
in past centuries
Deiphinis deiphis
Relative Dominance Not known; Not known
in Gulf of Maine possibly
Phocoena is a
competitor
Tursiops truncatus
Re1ati e Dominance Rare; perhaps Rare
in Gu of Maine Phocoena is a
competitor
299—11
-------
Table 11-46 con’t.
Species Original Table Revised Table
Lagenorhynchus albirostris
Estimated Abundance Rare stray in No estimate
in Western North Gulf of Maine;
Atlantic No estimates
Relative Dominance Apparently minImal Usually not im-
in Gu1 of Maine portant by nwnber
but large schools
may appear occasion
ally
Lagenorhynchus acutus
Relative Dominance Apparently not Usually not im-
in Gulf of Maine important by portant by numbers
numbers but large schools
- may appear occasion
ally
Grampus griseus
Relative Dominance Much less common Poorly known
in Gulf of Maine than Phocoena Apparently, of
minimal imoortance
Balaenoptera musculus
Western Atlantic Gulf of St. Law— From about 350
Range and Distribution rence to Davis toward pole
Strait; routinely
sighted on banks
fringing outer
Gulf of Maine;
population much
reduced from
original number
of about 1,100 in
western N. Atlantic
Estimated Abundance Generally not Severaihundred.
in Western North common; some Pre—whaling popu—
Atlantic sightings ‘expect— lation estimated
ed in offshore - at 1,100
regions; no esti-
mates.
299—12
-------
P. 3bJ: TabLe 11—41. Large numbers of white-sided
dolpitins ( Lagctorhynchus acutus ) were present in the Gulf
of Maine during 1916 and this species appears to be the
most corinon délphinid in the area. To indicate that it
might be a key species in some situations, an asterix
should be placed by L. acutus in the table.
P. 364, paragraph 2: Although the passing of the use of
weirs may have reduced mortality of marine mammals caused
by fishing operations, such mortality may still be significant.:’
For example, in 1976 a mother and calf right whale ( Eubalaena.
glacialis ) were caught in a weir at Grand Manan Island (early
August). All, were released unharmed. However, a minke whale
( Balaenoptera acutorostrata ) caught in aweir at St. Andrews,
New Brunswick, was shot on 14 July 1976.
It also should be pointed out that any decreases in mortality
resulting from a decrease in the number of weirs, may be
of fset by an increase in mortality from gill nets. It is’
known, for example, that a humpback whale was entangled in
a gill net on 20 July 1976 at Jeffreys Ledge. The whale
freed itself after several hours, but an L. acutus died on
the same day in the same area.
P. 808, paragraph 1: The introductory statement that “The
most significant impact to marine rnammals...would be as a
result of an oil spill” should be substantiated to show how
this conclusion was reached.
(pp. 808—814)
The discussion of pinnipeds is adequate except for the
following statement: “Fortunately, Nantucket shields the
island from the proposed leasing area and therefore a spill
originating from a platform or drill rig probably would not
affect Muskeget’ (p. 8)3, paragraph 1). There is no evidence
that gray seals ( Halichoerus grypus ) confine their feeding
activities to Muskeget Island.
Cetaceans (pp. 815—820)
P. 815, paragraph 1: Although it generally is thought that
cetaceans in the Gulf of Name are migrants, there may be
proportions of the populations which are residents through-
out the year. Both humpback whales (Megaptera novaean ’liae )
and fin ha1es ( Balaenoptera physalus ) have been ssen in
the Jeffreys Ledge area i mid-Nove er, suggesting that
299—13
-------
thesa animals have not migrated south for the winter.
They may migrate inshore-offshore, rather than north-south,
making them subject to oil hazards in both inshore and off-
shore areas. Because no data is availabic on these rnigra—
tions, there is a definite need for field studies.
Minke whales (B. acutorostrata ) were much more common-in-
shore in Maine waters during 1976, and at least two specimens
found dead along the coast apparently had been struck by
ships. Because minke whales come inshore during the summer,
the possible effects of oil on this species should not
be limited to offshore spills, as the DES now states. It
also should be noted that many minke whales come to the
Georges Bank area with calves whi h may be feeding for the
first time. ..
p. 816, paragraph 1: The statementthat “there is no
record of any cetacean having died from the direct effects.
of oil pollution” is misleading. Because of likely inter-
ference with normal lung function, one must suspect that
any inhalation of oil or oil vapors would cause fatal injury.
Since the terminal state of the injury probably would be
complicated by pneumonia or other conditions, it is unlikely
that the causitive agent (oil) would be identified. There-
fore, there clearly is a need for controlled laboratory
experiments to elucidate the possible effects of oil on
cetaceans and other marine mammals.
p. 817, paragraph 2: Although it is true that “cetaceans
are very mobile and forage over a large area”, in general
they follow traditional routes which allow them to efficiently.
exploit their environment. It is unrealistic to assume that
cetaceans can move to other feeding areas if primary feeding
areas are perturbed. Secondary feeding areas, if they exist,
may have been impacted by man already.
The Georges Bank area is one of the major feeding grounds /
for many cetacean species. Certain fishing banks, such as
Jeffreys Ledge and Steliwagen Bank in Massachusetts Bay,
appear to be exceptionally important habitats for whales.
During spring, right whales are fauna on both banks and one
must suspect, from the limited data available, that much -—
if not r ost of all -- of the remaining North t1antic popu-
lation is at times concentrated there. Furtherrore, Jeffreys
Ledge appears to be an .irnportant habitat for humpback and
finback whales, both of which feed there . in large numbers
during autumn, and possibly in winter and sprin;. as well.
O.xe shtp which frequently traverses Jeffreys Ledge
299—14
-------
regularly reports whale sightings to the Gu1 0! Maine
t: ale Sighting tet iork station. On 17 September 1976,
for example, 43 humpback whales, along with several fin—
back whalos and harbor porpoise (P. phocoena) , were sighted
in a 4 hour period. — ________
One of the two possible pipeline corridors shown in Figure
1 1—1 (p. 618) runs through Steliwagen Bank and to the
southern end of Jeffreys Ledge. Use of that corridor would
pose an extraordinary threat to right whales as well as an.
important fraction of the humpback whale population and
other cetacean populations. Therefore, the Commission strortc ly
recommends that an alternative route be chosen for the pjpa—
line corridor.
Other potential adverse imoacts which should be included
under Cetaceans (pp. 815—820)
The danger of direct collision between tankers and
large whales should be emphasized in the DES. At least some
of he large cetaceans which have been found dead on the -
New England coast are suspected to have been killed by
collisions with ships. Data from the Marine Mammal Salvage
Program, directed by Dr. James Need, Smithsonian Institution,
and from the New England I quarium should be consulted for
further information on this potential danger.
As detailed on pages 303 and 747 of the DES; zooplankton
species likely to be impacted under certain conditions in-
clude Calanus fininarchicus, Thysanoessa , and MeganyctiDhanes .
It should be noted that these and other species are consun edT
by right whales, finbac]cwhales, and blue whales (B. musculus) .
Pages 12-6 9 through 12—73 of the DES discuss the input
of heavy metals into the marine environment due to offshore
recovery operations. It should be noted that because
marine m ” a1s are at the top of the food chain, they could
be greatly affected by the accumulation of heavy metals in
the marine food web.
Endangered
P. 818-819: Although the DES includes an adequate
discussion of finback :ha1es, it is seriously deficient with
regards to hu. ’ pback whales and right whales. Both historical
and recent data si. ggcst t t the Gulf of Maine is an tm
port rtt habitat for some ; rtion of the hu pbac c population.
299—15
-------
During the past five years, humpbacks have been seen in
the Gulf from April to May (in the southern portion),
through surnmer (along the Maine coast), and into September .:
and October (Maine and Bay of Fundy coast), and even in
November (Massachusetts Bay area). As mentioned previously,
43 hurnpb ck whales were observed on Jeffreys Ledge in mid—
September 1976. The exact migration routes of the species
are not yet known. However, the whales do pass Bermuda on
their way north for the summer. Animals corning to New England,
and possibly Nova Scotia, would probably come over the
leasing area, right across Steliwagen Bank and onto Jeffreys
Ledge. This would afford the species maximal exposure to
al]. oil-associated activities.
In regards to right whales, the DES should state that man ,
if not all, of the individuals remaining in the western
North Atlantic congregate on Steliwagen Bank, Jeffreys Ledge,
and probably Georges Bank during the early spring. It is
probable that many of the animals migrate along the east
coast of the U.S. from more southerly wintering grounds be-
fore arriving in Massachusetts Bay. Deterioration of ‘the
environment by oil—associated activities would certainly
be to the detriment of any recovery of this species. Further-
more, it is possible that this species may be particularly
vulnerable to oil spills because it commonly feeds by skim-
ming plankton from the surface as it swims forward open—
mouthed. Although it also feeds at various depths beneath
the surface, surface feeding on caIrn days, when small plankton
animals are available, is an important part of its feeding
repertoire. This animal has a tendency to feed along windrows
where wind and current have concentrated plankton into a
slick which is visible to human observers. Surface oil
would also be concentrated in’such windrow slicks. Finally,
since this species may be more closely associated with the
water surface than are the other large whales, and since
it apparently is a slower swimmer than the other species, it
might be more vulnerable to ship collisions.
P. 819, paragraph 5: The statement that “the blue’
‘whale is a pelagic animal which is routinely sighted on the
banks fringing the outer Gulf of Maine” is based on data from
the DES Table 11-46 (page 360). The blue whale data in this
table have been revised (see page 3 of this letter) and the
above phrase concerning routine sightings has been omitted.
The ne vers!on states that the blue -hale is seen “occasion-
ally near land in deep—water areas such as the St. Lawrence
River.”
299—16
-------
p. 820, paragraph 2: Contrary to the statement in
the DES, the sei whale CR. borealis ) probably ranges as
south as Ziexico and the Caribbean. Furthermore, some set
whales were caught from shore-based whaling stations,
suggesting that sei whales are not exclusively pelagic.
Thus, no conjectures can be made about the impact of the
lease plan on this species.
In summary, it is clear that “ [ i]f the proposed sale
should take place, both geological hazards and any unique
biological communities will [ not) have been identified and,
delineated” (DES, p. 1252). The Commission therefore
recoz ends that the proposed sale be delayed until ere
are sutflciartt datato realistically evaluate the potential
impact on marine t, rnz .ajs . .
The Bureau of Land Management apparently has initiated
no marine nai l studies to supply the benchmark, descriptive
and predictive data which the BLM environmental studies
program is designed to develop (DES p.. 27). The Commission
recommends that the research program identified in Dr.
kotman’s 12 I!arch 1976 letter to Dr. Robert Beaucha.i o (coov
enclosed) be iraple.’ iented as à ii as possfb1 7 and tnat the
Bureau of Land Management underta
-------
REFERE: CES
1. Dr. Steven K. Katona, College of the 7 tlantic,
Bar Harbor, Maine. Personal communication.
2. Dr. James C. Mead, Smithsonian Institution,
Washington, D.C. Personal communication.
3. Dr. Howard E. Winn, University of Rhode Island,
Kingston, Rhode Island. PersonaL communication.
299.48
-------
Environment Environn nt
Can .d Canada
Fisheries and Pêches et sciences q 1q7
Marine de Ia mer rn 2.
June 22, 1976.
AIRMAIL
Mr. J. A. S. McGlennon,
Regional Administrator,
United States Environmental
Protection Agency,
Region I,
J—Y. Kennedy Federal Building,
Boston, Massachusetts. 02203.
U.S.A.
Dear Mr. McGlennon:
In response to your letter of June 8, 1976 I have
to advise that chart 4373 is a reproduction of the for-
mer British Admiralty chart 2020 which resulted from a
survey carried Out in 1847 with corrections from the
U.S. Coast Survey chart of 1893.
Small corrections were made to this chart by the
British Admiralty up to and including 1952. The first
Canadian edition was printed in 1956 and minor cor-
rections were included in reprints in 1972 and 1975.
Chart 4343 is based on the Canadia 4fydti H )
Servipryc y pf 1948 . Echo sounders were used àur —
ing this survey. This survey was done to meet the
requirements of that day and, as y u have assumed, it
was not anticipatcd that ships requiring 65 f ef of
water plus a clearance rac ar w .,uj.c ever be utilizing
trrr (or any outer cnannei. Minor corrections were
made to cflart 4343 unen it was reprinted in 1972 and
1975. Because of the need to deploy resources in
areas of higher priority than charts 4343 and 4373,
we have not done any recent hydrographic surveys in
the area and because it is anticipated that 15Q fl00
I T s 1i?s, proposed by the Pitteon Comoanv. will not
be permitted to transmit Head Harbour Palsage
- have no imediate plans to re-survey the area
./2
Ottawa X l A 0H3
300—1
-------
—2—
When the area is re—surveyed, the specifications
will be much more stringent than those which satisfied
the 1847 and 1948 requirements and the use of modern
surveying, photogrammetric and cartographic techniques
will permit a greater degree of accuracy.
I trust that the above will be of some use in
preparing a draft environmental impact statement.
Youra truly.
Canadian
.c Service.
300—2
-------
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WRIGHT PIERCE BARNES AND WYMAN
ENGINEERS AND PLANNERS V
NINETY NINE MAIN STREET
• TOPSHAM MAINE 04086
I TELEPHONE 207 725 8721
___ J MEMBERS OF ACEC & ASCE
November 10, 1976
Mr. John A. S. McGlennon
Regional Administrator
Environmental Protection Agency
Region I
J. F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
Previous commitments preclude my attending the forthcoming hear-
ing on the Pittston Refinery at Eastport, Maine. I do, however,
wish to express our strong support for this project.
Even if we ignore the relief that will be generated for the North-
east energy shortage, the long term benefits to be derived for
Washington County and the State of Maine dictate support.
Washington County, which has experienced a seriously depressed
economy for years and Eastport in particular, cannot help but
benefit from the project. The construction period must provide
a beneficial impact, hopefully one that will offer sufficient
recovery, to guarantee continued improvement from resultant
long-term employment at the Refinery and support employment in
other areas.
In addition, the tax benefits that will result both for Washington
County and the entire State of Maine, cannot be ignored as a
tremendously beneficial effect of the project.
Respectfully submitted:
WRIGHT, PIERCE, S & WYMAN
e4 ø’j
Geor ’ W. Barnes
President
GWB: ssh
NEW HAMPSHIRE OFFICE 25 VAUGHAN MALL PORTSMOUTh 603 436 0174
303—1
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Boston Shoe Store
99 Main Stzeet
( ‘d.i . Maine 04619
Tel. 207-454.2844
Ioie sr 10, 1976
tr ta1 Protesttcm Agescy
Jab.?. .ussdy t1dia.
1est , ua.tts
A. t.b. o srs of a o store ii Cslais, 2 ails.
frc balport, viM to r... o pozt for the pro..
— oil refinery in Iutport.
Tb. tr aus o’ v.iic advtagea to the area durieg
the ocestrustios period mad U i. pores mat pqrcU area
beast tb.t this oo atjy o t afford to loss.
V. trust that pressat difficulties sq be ovr—
oce d that ocaatr tica a begin soas .
ioiu’s truly,
1 ry C. Cssq, Tress.
L. krwdiai Co., Iac.
304—:L
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€ November 15, T 7F
Mr. John A. S. Mc(lennon
Region I Administrator
Environment Protection Aqency
John F. Kennedy Buildina
Bo ton, Massachusetts 2203
Dear sir;
As a business man and ro rietor of the Bayview C-aracTe in
Eastport I want to express my oosition on the Pittstor Co. oro—
ject. Besides myself I employ two helpers. Sometime it is very
difficult to keep these two men workina. I fjnR it very exoens-
iv ’: 4, ,.
ive to keep’ and buy modern equipment. This I have not been able
to do. We,in the Bayview Garaqe ut our full su ort hehini the
Pittstons proposal. I hope this makes our oosition clear.
Yours Truly
3 mae Lowe proprietor.
305—1
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I ,’
I -
9 d’
306—1
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32 shi ton 3tre’e.t
.ast ort, .ine 04631
i ovember 16, 1976
nviron aer.ta1 ?rotect 3n . ent
F ;ion I per iit #25—76—367
oi n P. ::ennedy 31d .
oct• n, L ss. 02203
De r Sirs:
AS Teside:Lt of st ort for any ye rs, I have vzatched
the ever—increasing decltïie in the D’osperity of the area and
have coie to the conolusiOn t only a vibrant new industry
will s.ve the area from b co in vir ua.l ghost town. To me,
it secms th ..t tb is new industry will 1 ve to be Pittston Oil.
he vay I see it, the nez.ds of the oo:.raunit or economic
rev.v l far outweiGh any ris . of dancer to the environ ent.
Yours truly,
ly e 1
3O7—
-------
iL. :ii ;
A(
LA4J/
I$/ ±k1 4 ?1.
.:
.
.
I____________
L.
JL ?LLd4
6
p
308—1
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3 . ’ ,
• WATI poomso
HASCALL I HALL, INC.
• COPIC rIt EroNAruoN
• STONE N Olp4yIp4G
• CAULICIN
P.O. SOX i.a* TL4 Q. MAINE 04104 • STEAM CLEANING
TELEPHONE (*07) 775.14I • SAND UtASTING
November 18, 19Th
Permits branch, ‘ nforcement Division
EnvironI entb1 Frotection Agency
i(ennedy iederal b’uiiding
oston, . assacLusetts 02203
Dear Sirs,
I shall be una.le to attend the hearings being i eld on
December 3rd at ‘.astport, -aine, concerning the proposed Fitt5tcn
refinery. I em therefore writin , to record that I am very much
in favor of this refinery becomin a r ality In our state. Tne
econor.iic benefits this would give £r .aine and the Downeast area
i an overpowering fact, a d a much needed boost. 1 am convinced
that adequate safeguards can be provided to give reasonable
r rotection of our envirorment.
Sinc. rely,
kascall & Hall, inc.
ph .4
ioJst# e ,
President
RLV/et s
309—1
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KOY t5 1976
C)V ; ‘
4
310—1
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Ni ” - 1976
William G. PreBton
25 W I Pond Road
Kennebunk, Maine 04043
U. S. Evironment Protection A(ency I ovember 1 3, 1976
Re Jon 1 , Permit 25 — 76 — .367
John F. Kennedy Blvd.
Boston, Mpss. 02203
Deer Sirs:
Re: Pr”posed Oil Refinery
Eastport, Maine
I visit Eastrort, Y ine frequently and find there no hotel
or motel ccoripdt1ons available arid no resturtent or dinning
acco:..nocation of any type.
In addition the buildinLs are dilapodated and the wharfs
are rotttn av:ay.
TJner loyme it is extremely 1 i-h.
Eorever nunber one—-—we need this source of energy in
the state of Maine and I wish to express my approval of the
Installation of a oil refinery in Ecstport, Maine. Both to
boost tue economy in this area mc? a a ditIone1 source of
enercy.
Toure truly,
)4 _
311—1
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RALPH A. DYER. III
COUNSELOR AT LAW
477 CONGRESS STREET
PORTLAND. MAINE 04 11
(2O7 773-6489/6480
Novexi ber 18, 1976
Permits Branch, Enforc nent Division
Envirorssental Protection Agency
Kennedy Federal Building
Boston, MA 02203
Gentlemen:
I have received notice of your forthcoming hearing relating
to the proposed Pittston refinery at Eastport from the Eco-
nomic )êeaources Council of Maine. Please note that I am
in support of the proposed refinery.
Very truly your..
S
A. ,III
312—1
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CIANBRO
C Q F Q F T I Q NJ
NOV 22 N76
REPLY TO Pittsfield, Maine
NWIULW(LL ARt.. P 0. I II S PITTUSIJ. m. S 4I1J Oft.. 2 1 1 1 4 * 1- 5121
1004 CONGBtSS SI P 0 BOX 1219 PORILAND Mt 04104 I tt 207/172 I%6
SIAIX RI P 009 1208- PRLSQUE ISLI M I 04769 -lIt 20717644139
November 18, 1976
Permits Branch, Enforcement Division
Environmental Protection Agency
Kennedy Federal Building
Boston, Massachusetts 02203
Gentlemen:
I urge you to approve the application to build a refinery at Pittston,
Maine.
The refinery will provide temporary and permanent jobs, which Maine
needs. It may also perhaps provide work for our cempany.
As a personal user of electricity to heat my apartment, I would also
hope that it would lower the cost of oil to Central Maine Power, and the
consequent cost of electric production.
Vary truly yours,
CIANBRO CORPORATION
—74
William J. Weck, c (
Vice President-Finance
W 3W/br
313—1
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• Ljt ,
CALAIS FEDERAL SAVINGS
mU L ASSOQAT
•I & $ V’GB .O O*. $ *CJ C fZDU . 0t SA .r(
L)S P. A N %T EY • CALAI*. MASNE • AfttA COOt 20? 454-2123
November 19, 1976
Federal Envirooment al Protection Agency
John F. Kennedy Building
Boston, Mass.
Re: Pittston Refinery Project
at Eaatport Maine
Greetings:
I me writing with respect to the proposed hearing on the Pittston Refinery
Project to be held in Eaatport, Maine, the early part of December.
I, and my associates, support this project because of the following reasons:
The State of Maine is fortunate in having two natural resources;
wood products sod deep water ports.
The economy of Washington County, and especially the Eastport
area, has ben declining rapidly over t te pest thirty years or so.
This decline in the ecom can be accounted for to a great extent by the
fishing industry declining, more or less, annually. I can recall when we
had an American Can plant in Eaatport, also an American Can plant in Lubec
which did nothing but manufacture cans for sardines. The nusber of sardine
factories now operating in Washington County is probably only one —tenth
of those that were in operation twenty-five years ago. So the argi nt
that building the refinery may result in the environ nt producing less
business for the fish processing companies, in my opinion, is without merit
because if it had merit, why would the fishing industry have declined so
rapidly over the last quarter century.
EnvIronmentalists, of course, are using the argusent that because of super
tankers going through Head Harbor there is a great possibility of an oil spill
which would hurt the fishing industry. In my opinion this I. unfounded to
the extent that it should be a reason for not allowing the refinery to be
built. It is true in any industry there is soms pollution and it seeme
that your agency, in all fairness should weigh the possibility of son.
pollution against the economic factors involved in any project. It certainly
would be nice to live in Utopia where th, air would be fre. of pollution,
314—1
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FEP Agency
—2—
11/19/76
and the waters completely free of pollution but I don’t believe we are going
to find this on this earth. Consequently, it appears to me that the balance,
if there is such a balance, between the environment and the economy that the
economy should have preference.
Is it not true that tankers are going by the Eastport area routinely to
enter St. John Harbor where there is a large refinery? To the best of my
knowledge they have had no major problems because of oil spills. Is it not
true that the modern refineries constructed under strict federal supervision
have done away with practically all the air pollution? It seems reasonable
to believe after many marine engineers have testified that there is no extreme
hazard by going through Head Harbor, that the risk of any oil spills should
be offset by the effect that the refinery will have on the economy of the area.
It is unfortunate that so long as I can remember, and I am sixty—four years old,
that from every graduating class of students in Washington County a large
percent have had to leave the area to seek employment when, in fact, this is
where they were born and brought up and, by preference, would like to live
but due to economic factors have had to leave.
As I have followed the opposition for the refinery, it seeme to come primarily
from people who have moved into the area to get away from suburban locations,
who are now retired and have no interest i.* what happens to future generations.
To me, this reason is of a very selfish nature. The other type of opposition
comes from the so—called hippy type people who have moved into the area, who
either come from wealthy families who are supporting them or who are not
interested in working at all and are living on federal handouts. So far as
I am concerned that type of individual is not needed in the area because they
are not productive and only are critical of everything that is attempted to
increase the economic condition of those willing to work and provide better
education, better medical facilities, etc. for the children.
Lastly, I might just mention one item. We all drive automobiles. A lot of
people have private boats and yachts which need refined fuel to operate them.
However, it appears that the people who are opposing this project are willing
for these fuels to be refined in some other area . They are not concerned
about possible pollution of that area, where this fuel is refined, so they can
enjoy the so—called wonderful environment that they are talking about which
we should retain in Maine.
In closing, I stand not to gain anything whether or not the refinery is built;
however, I have always been an individual who is civic minded and progressive,
having built our own banking institution from One Hundred Thousand Dollars to
slightly under Twenty Million Dollars at this time.
I, and my colleagues, would appreciate your consideration of the arguments as
set forth in this letter as to why you should approve the project as it has
been presented to you now in its entirety by PitLeton Cospany.
PWF/m
314—2
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2
iss AMITTA c ur EMTI N DIVISION
.J 4Z
November 19, 1976
Mr. Richard Z.ppler
Region 1
Reviroia tal Protection Agency
JFK Build lag
Boston, )¼ssachus.tts 02203
D.ar Mr. E.ppl.r:
Vs here at the Thomsaton Plant of Martin Marietta Cement
enthusiastically support the Pittston Company’s application to
build a refinery within onr State.
U. .11 know that the State of Maine neds new industry as
well as a reliable source of low sulfur fuel oil. The construction
of the Pittston refinery would go a long way toward improving the
economic situation within our State.
U. trust you will react favorably toward the Pittston
application.
Very truly yours
J ee Wilson, Jr.
JVJR:ul
sasos VI eff
W ENSL S
315—1
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STARBIRD LUMBER CO. INC.
STRONG, MAINE 04983 lafly 22 1976
LUMBER - BOX SHOOK • BUILDING MATERtAI.
RED-E-BILT CASING
P 1 10 115 UI lusi
November 19, 1976
Permits Eranch, Enforcement Division
Environmental Protection Agency
Kennedy Federal Bui1din
boston, Mass. 022C3
Gentlemen:
AlthouRh I cannot attend the Pittston hearing in
Eastport on December 3rd., I a n 1 eenly interested.
Every person in t aine and all of New England should
get behind this project and bring a refinery to Maine.
\ oe need the products of the refinery in the North-
east.
Our economy needs the additional dollars that will
be generated in construction and operation.
Very truly yours,
4 4 W
CVS/bea C. V. S erbird, treaa.
316—1
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$mJND MFGCO,IIC.1
4T4 M I,E o4/ J ô85 3385
Nov ber 19, 1976
Permits Branch, EnforC Ient Div.
Enviroiaental protection Agency
Xennedy Fd.ra l Building
Boston. Mass. 02203
Gnt1 en:
We would like to take a stand in support of the
Pittston refinery in Bastport. This would be of
tr ndoua benefit to Maine, not only from an employ-
aent staadpoint, but from the fact that it would
supply additional taxes to the State as well as the
t n of Eastport.
Sincerely,
Vice Prss.
JAIivsb
McI1L*1c f d Oiaiiess Fans H ji s
317—I
NOV 22 WS
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S. C. NOYES Co.
S C NO ts Co BL,ILOING • RAMGELEY, MAINE 04970 • 207-864-5512
November 19, 1976
Permits Branch, Enforcement Division
Environmental Protection Agency
Kennedy Federal Building
Boston, MA 02203
Gentlemen:
NOV 22
We cannot be
at Eastport,
favoring the
at your meeting on December 3,
but we want to go on record as
Pittston refinery at Eastport.
1976,
strongly
This refinery will benefit the entire State
and the Northeast.
Very tr i y yours,
SCNC0
of Maine
C. Nayes
SCN:cb
REAL ESTATE DEVEL0PEI? II ?b REAL ESTATE BROKERS
-------
aa.—Jo.ch1a & Edith LMhu€fer c/o
I
r u* vi
- —
vlrn’v’nertt Prot.ction . tey
Re io I Per. it Jo/25-7(-X.7
J’bn T.X vi’. ’
3u”ton, ‘* .. O??03 Nov. 2 , l97
3.ntle.. n,
.a. iould ii e to let u that m•
ore vera such in t.v. r of h- vi t th Pitt..ton Oil
. c :itt tc’ Ee t rt. ‘e .re surs todis . trict
•nvirona.rLt: J. r*,ui t1o.i ill i ..ke th. *r Loa
of iS Cii fi’ er is bsf• a.
tth a.st 1 .orts ftah Indu stry ote U srs is * r at
isel to et ltft n rin thid deprse*.d £.r.a
to life
77 4
319—1
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ST. ANDREWS CIVIC TRUST
BOX 484, ST. AND REWS, N.B. Nov.l3th, 1976
EOG 2X0
lion. Don Jssieaon,
Minister for Ext.rnal Affairs,
Ottawa, Ontario.
D.ar Mr.Miniat.r:
Attachid are recent newspaper reports of th. Pittetsu
Company’ a propoa.d oil refinery at Eaatport, ‘ain., and tb.
forthcoaing public hearing by th. U.S.Envixona.ntal Prot.atig
Agency and the U.8.Ar y Corp. of Enginasre on the proposed
refinery and relat.d faoiliti.s.
Our organization is oppo..d to the adv-.r.. environm.ntal
impact of th. Pittston plane. A* oil spill, which expert. say
is an inevitability, would have disastrous .ff. t . on St.kn r.ws,
b•oause of the prsvailing inda and tb sztr.a.ly high Pundy
tides.
iLdbt i v.u1a eU k4ibtM to promot. Area Conssrvat-
ion in St.Andrws, in conjunction with our national trust,
HERITAGE CAI ADA; we are now in sight of that goal, whiøh would
greatly enhance ths natural, historical and arahitsotural ‘attrao$- .
ions of this 1784 Loyalist settlement. Tb. potentia) invsstn.nt
of about one million dollars by Heritage Canada, foundation.,
government and private sources is an important •conomic and
environmental factor here. We would uk . to be assured that our
Government will oontinu to oppose passage of 1.rg. volunsa of
pollutants through Head Harbour Passage.
Yours sincerely,
copy to Ira. Allan lag..
President
U.S .Znvironmental
Protection Ag•noy
320—1
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On a cold late October day (October
2Sth) at 800 AM Dkkcrtnans Dining
((all on (he Husson campus was filled
to capacity with Bangor businessmen.
lucy had hiaved the early morning cold.
not only to eat a fIne breakfast of baked
beans. mend potatoes. scrambled eggs.
donuts, pie and cofkc but to hear what
the Vi .r President of Energy for the
Pittston Co.. A. F. Kaulakis had to tell
them.
A few years ago they might not have
turocd out us such numbcrs, since the
name “Pluaton” was not weU known in
Northeastern Name. However, since the
Pittston Co. filed an application with
the Maine Department of Emironmental
Protection in April 1973 to build a 250,
000 barrel a day oil refinery in Eastport.
the name “Pittston” is well known in
the Bangor area--an area which Is the
trade and service area forNortheastern
Maine...
In talking to the group, Mr. Kaulakis
stated that the end of all of their environ’
mental applications and studies was now
in site and they should know in early
i 77 whether or not they would be
building the refinery. The $5( ) ,0OO.00O
O g.3S
which they would put into the cnnstntc
tion of the refinesy and marine temsinal
would creak a vIgorous impact In a
sparsely populated ares with a strong
ripple effect. “They were not buildings
rickety factory which would pull out at
any time, they wore not asking for a ta*
break and they wets not asking for a
credit goametse from the State”. The
rsfl.viy was a Ø of bard bricks treat-
ed with loving care. They would employ
300 people to operate the refasety after
it was constructed and 200 people for
maintenance, workM In the cafeteria,
ek. There would be tanker crews needed ,
inateriek coming in and out, supphes
and repairs needed. There would be
people needed to service skips. iranapot’.
*1101% people, motels and many odser
setvices. The local taxot would be Increas-
ed (similar to Wiecanet) and Ernatport
citizens would here money to spend foe
schools, sidewalks, the libraty and roads.
Jo shod, the P Ittston Co. would be puB.
hag dasleowa anightotad th.ywould
need s.ppwt fiom people south ned uset
of Emepoti .
12 November, (976
There would be an opportunity for
young peopie who had been leaving the
ares because of lack of opportunities.
They were coming into the ‘home
stretch” and he asked the busineumen
to go on record supporting the oil refin-
ery if, in their judgement, It was a good
thing foe the public Interest sod for the
stat’.
Mr. Kiulakis. In sof.senc* to the long
environmental hearings which the rafin-
cry proposal had been through. mention-
.4 the refineries In Europe where he had
done a great deal ol work. lie spoke of
th. fact that the people there were
concerned about the envlronmsnt—tM
waler and air around them - but that
titers were govcnunent regulations to
make things acceptable. There were
tough requirements which were met
quickly. Technical problems were solved
with the people working out the prob.
lame. lie thought that problems in the -
United States would be handled the mend
way, but that was not the and that
was why in October 1976, he w In
Rmpor, M’.. imissd of Etpott, Ms
L.J U
Pittston Seeks Support
From Bangor Businessmen
1 0Y T S
PITTSTON (Continued)
320-2
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The U.S. Environmental Protection
Agency and the U.S. Army Corps of
Engineers will Hold a public hearing con-
cerning the Pittston Company’s proposal
to build a 250,000 barrel-per-day oil
refinery. storage facility and marine ter-
minal in Easiport.
The hearing will be held on December
3, 1976 at 1:00 p.m. at the Shead Memor-
ial High School in East port.
The purpose of the hearing will be to
receive comments on (1) EPA’s draft
environmental impact statement on the
project. (2) EPA’s proposed wastewater
discharge permit. and (3) the Corps’ pro-
posed permit for construction of piers
and dre4gzng activities.
The proposed facility will receive
crude oil from tankers of the VLCC (Very
Large Crude Carriers) class, refine the
crude oil into fuel products. and offload
the products into medium-sized tankers
and barges for transport to product di i-
Coat. on pug, 2$
E.P.A. HEARING (Continued)
tribution terminals on the northeast
coast.
John A. S. McGlennon. EPA Regional
Administrator said, “The draft EIS is an
in-depth analysis of the project’s poten-
tial environmental, economic and social
effects on the community. The principal
beneficial impacts include (I ) provision
o fuel oil and gasoline, which have been
in particularly short supply in the north-
east:(2’l increased employment, tax
revenues, commercial activity, and per-
manent employment for about 300 people,
200 of whom would be Washington
County residents; and (3) more assurance
of a continued petroleum supply. reduc-
ing the vulnerability of the nation to
another embargo.”
•fl principal adverse effects of the
proposed project which cannot he avoid-
ed include (1) the conversion of an es-
sentially rural site to heavy industrial
usage. (2) an incremental decrease in air
quality, (3) discharge of treated sanitary
and industrial wastewater to marine
waters, (4) increased noise and. (5) poten-
tial oil spills. In addition, there will be
some temporary construction-related
impacts.
ilic Pittston Company has applied to
EPA for a National Pollutant Discharge
Elimination System Permit as requtred
by the Federal Water Pollution Control
Act.
EPA has tentatively determined to
issue a permit authorizing the discharge
of treated process wastewater, treated
ballast water and treated contaminated
stormwater run-off into Deep Cove. The
proposed permit requires compliance
with the new source performance stand-
ards and effluent limitations set forth
in the EPA guidelines for the petroleum
refining industry. All treatment facilit-
ies needed to meet these standards must
be operatiotial by start-up of refinery
facilities. The final permrt wili incorpor-
ate comments received through the EJS
process and will insure compliance with
state and federal water quality stand-
ards.
In addition, the Pittston Company
has applied to the Corps of Engineers
for a permit for the construction of two
piers and dredging activities under Sec-
tion 10 of the Rivera and harbors Act.
Co$onel.John Chafldler, New England
Division Engineer of the Corps of Engin-
eers said that the application pertains to
the construction of a pile-supported pier
in Broad Cove. The pier would extend ap-
proximately 2,000 feet from shore with
a 40 foot wide concrete deck for receiv-
ing crude oil. A second 40 foot wide pile-
suppor ted pIer. 1,875 feet long, would be
constructed in Deep Cove for shipping
refined products.
The applic.atiofl requests authorization
to dredge about 358.000 cubic yards of
sand and clay and 808,000 cubic yards
of rock to provide the required depths of
75 feet and 50 feet in Broad and Deep
Coves respectIvely.
All interested parties are invited to ex-
press their vIews at the public hearing-
Written comments on the draft EIS
are invited any time before December
13. 1976, and may be sent to: US.
Environmental Protection Agency, En-
forccment Division. Permits Branch,
John F. Kennedy Federal Building, Bos-
ton, Massachusetts 02203.
Fact sheets may be obtained at no
coat by writing or calling EPA The com-
plete application. proposed permit and
copies of the draft ELS including an exe-
cutive summary are available upon re-
quest, and are on file and may be inspeCt-
ed at the EPA Boston Offices. In addi-
tion, copies will be available at the
Peavey Memorial Ubrary. the Quoddy
Tides Foundation Marine Ubrery and
the Eaatport City Rooms.
‘4)
N
4
E.P.A. public hearing
Pittston’s proposed refinery
Eastport — December 3rd
320-3
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C 3
Dece ’ber , 1976
astoort, P tne l 631
A • 3emiou
Reytonsl stntetr tor
uvtr .msnts1. Proteetton &i”encv
.J&w P. etw ady bl .
boston, *. O 2fl3
Dssr Pb. Oleimon:
Two thtrwe. Pirat I would 1tk . to stats my onooettton to
litttnp ansdtans etarwi us end sneak it the Dtttnt h art,w iso. 3rd
at !aatnort. I Iou’t hsltvs they have any rt t to nsa the tsxnaysrs
*oniy in tsJ1tn us mi to ron our .9a ire. U. were not caked to
tastily at the Point Ia ieau L.Pl nt site twelve sues from !etnort or
at th. St. John oil ref tnery exn.nston, we tn, tt the larçst tn Carada.
Sseo d, as a L i fe loep resident of !astnort and b.th a b ieinsssisn in
Emstnort T attended the Ptttston hsartnss. I noticed that a very lily.
,erconta.s of the opooettton was from out Of the City. iø en local City
off toil. and business etend no and sneak, these wan have the interest of
the City at heart.
*tJ.L waVR NMEM1 PIMTINS O?VCi t*7 7SS41tt7
Sincerely,
) rrtll Conti.
321—i
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