ATTACHMENT C
Metcalf and Eddy Report, “Review of MDPW Central Artery/Tunnel
Supplemental Environmental Impact Report” July 30, 1990.
The July 30, 1990 report by Metcalf and Eddy, Inc. (78 pages) cited
as Attachment C to EPA’s July 31, 1990 letter to Lt. Colonel
Stanley J. Murphy of the U.S. Army Corps of Engineer is available
for review at EPA’s Regional Library. EPA’s Regional Library is
located on the eleventh floor of One Congress Street in Boston.
A limited supply of copies will be made available for Federal,
State and local agencies upon request.
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REVIEW OF XDPW CENTRAL ARTERY/TUNNEL
SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT
30 July 1990
Metcalf & Eddy, Inc.
30 Harvard Mill Square
Wakefield, MA 01880
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TABLE OP CONTENTS
PAGE
1 • 0 IntroductiOn. . . . . . . . • . . . . . • . . . see. • • • • • . • • • • • • 1
1 . 1 . Scope of Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1 • 2. Project Constraints.. • . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2.0 Proposed Materials Disposal Program................ 2
2.1. MDPW Proposed Plan (Spectacle Island).............• 2
2.2. Spectacle Island Aquatic ResoUrCeS...........—• •. 2
2.2.1. Benthic MacroinvertebrateS.. . ..... .......... 4
2.2.2. Shellfish. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
2.3. M&E Minimum Fill Alternative Proposal....... 7
2.3 .1.MethodolOgyaT ’dASSUmPt10flS. 7
2.3.2. Results....... . .. . . .. . .. ... . . ... . . 9
2.4. Comparison of Aquatic Resource Impacts 9
3.0 Evaluation of Alternative Disposal Sites...... 11
3.1. Summary of MDPW Site Selection Process. 11
3.2. M&E Alternative Site Evaluation Process... 11
3.2.1. Evaluation of MDPW SEIS/R Finalist Sites.... 12
3.2.2. Evaluation of MDPW/MWRA Sites...... 12
3.2.3. Evaluation of New Sites............. 13
3.2.4. Results...... ... . . ... . .•.•...• . 13
3.3. Feasible Alternative Disposal Sites......... 13
15
3.3.2. Bates Quarry (Weyinouth)..................... 17
3.3,3. Saugus/Meirose Quarry. . . . -. . .....•. ... ... .. . 22
3 . 3 . 4 . Weston Quarry . . . . . . . . . . . . . • . . . . . . . . . . . . . • . . • 2 4
3 . 3 . 5 . Logan Airport . . . . . . . . . . . . . • . . . . . . . . . . • • . . . • . 28
3.3.6. Fratningham—13. . . . . .....••• . . . . . . . . . . . . • . •... 30
3.3.7.SpectaclelSlafldCappiflg..... . ........ 34
3.3.8. Supplemental Site Investigations..... 35
3.4. Disposal SiteTraffiCPrOjectiOflS.................. 35
3.4.1. Introduction and Assumptions.... . .. 35
3.4.2.MethodOlOgYandResUltS.................” 36
4.0. Evaluation of OtherAlternatlVes............... .... 41
4.1. Ocean Disposal.................... .....•.. . 41
4.2. Backfill forProjeCtArea....................... ..• 42
4.2.1.CharaCterOfMateria15................ ’ 42
4.2.2. suitability forReuse...................... 44
4.2.3. Handling of Excavated Materials............. 47
References
Appendix A: Alternative Site Screening Process
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LIST OF TABLES
PAGE
2—1 Summary of Spectacle Island Sediment Contamination...... 5
2-2 Summary of Soft-Shell Clam and Mussel Densities at
Spectacle IslandandReference Sites.................... 6
3-1 Summary of M&E-Proposed Alternative Materials
Disposal Sites. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
4-1 Potential Disposal Options for CA/T Excavated
Materials...... •••• .. . ........... .......... ... ...... .. 43
4-2 Suitability of CA/T Excavated Materials for
. ... .. 45
A-i MDPW Interagency Working Group Site List................ A-2
A-2 M&E Materials Disposal Site Screening Process. . .. ....... A—13
A-3 Application of DEP Solid Waste Landfill Siting
Criteria to Potential New Site Alternatives... . .. .. . ... . .A—16
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LIST OF FIGURES
2—1 Spectaclelsland(MDPWProposal)................ .3
2—2 Spectacle Island (M&E Alternative)..................... 8
2-3 Spectacle Island (X&E Alternative and MDPW Proposal)... 10
3—1 RoweQuarryandSaugus/MelroseQuarry.................. 16
3—2 Bates Quarry................................. ...... ... . 19
3—3 Weston Quarr r. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
3—4 Logan Airport RunwayAreas................. ..... 29
3—5 Fraininghain—13 . . . . . . . . . . . . . . . . . . . . . . . 31
3—6 Truck Loads Per Day for Land Disposal ..... 38
3—7 Projected Disposal SiteTraffic............ .40
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1.0. Introduction
The Massachusetts Department of Public Works (MDPW) has proposed
the disposal of 9.3 million cubic yards (mcy) of excavated and
dredged material on Spectacle Island in Boston Harbor, as part of
the materials disposal program for the Central Artery/Tunnel (I-
93/1-90) project. They have recommended the use of Spectacle
Island for disposal of all excavated material (and some dredged
material) in their Draft supplemental Environmental Impact
Statement/Report (SEIS/R). Metcalf & Eddy (M&E) has been
contracted by the Environmental protection Agency (EPA) Region 1
to review the project’s materials disposal program.
1.1. Scop. of Report
This report presents our findings on the review of the MDPW’s
proposed materials disposal program presented in the SEIS/R. Our
review to date has focused upon; (1) the impacts associated with
the MDPW’s proposed landfill on Spectacle Island; (2) the MDPW’s
alternatives analysis for the materials disposal program; and (3)
development of an alternative disposal scenario. Section 2.0
reviews the MDPW proposed use of Spectacle Island, and provides an
alternative approach to minimize impacts to the island’s aquatic
resources. Sections 3.0 and 4.0 review the alternatives analysis
used by MDPW to select Spectacle Island: in addition, in Section
3.0 an alternative approach to materials disposal which utilizes
several upland disposal sites, is presented.
1.2. Project Constraints
Data has been gathered from several sources for this analysis.
These sources include (1) MDPW files; (2) NWRA databases; (3)
Bechtel/ParsOfls-BrthckerhOff (B/PB) reports; (4) state and federal
data sources: (5) field visits; and (6) personal communications.
In some cases, data files were not complete or were unavailable for
analysis. Due to time constraints, certain sources (such as
wetland inventory maps and aerial photographs) were not available
for use in the analysis. Quantity estimates for the materials
disposal program presented in the SEIS/R are assumed to be
generally correct (although various sections of the SEIS/R present
different figures); no independent review of the MDPW calculations
of material generated has been conducted. Also, calculation of
disposal quantities for M&E alternative sites were based solely
upon USGS 1:25,000 topographic mapping which may not accurately
reflect current site conditions; as a result, all capacity
estimates are necessarily conservative. Finally, field visits have
been restricted to publicly—accessible areas; rights—of-entry to
privately-controlled sites were not obtained. As a result.
information and observations of these sites are liiniteth For
example, the extent and quality of wetlands and other significant
resource areas at the disposal sites could not be field—verified.
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2.0. Proposed Materials Disposal Program
2.1. MDPW Proposed Plan (Spectacle Island)
The proposed plan for materials disposal includes the disposal of
the 13.5 million cubic yards (mcy) of dredged and excavated
material from the Central Artery/ Third Harbor Tunnel construction
project as follows:
9,283,000 mcy to Spectacle Island
• 1,205,000 acy to Massachusetts Bay Disposal Site(MBDS)
2,666,000 mcy for landfill capping
• 379,000 mcy for disposal at landfills
This plan results in an increase in the size of Spectacle Island
from 83 to 186 acres and requires the filling of 85 acres of
subtidal coastal habitats and 18 acres of intertidal shoreline
areas.
The proposed plan would change the topography of all but the
southern tip of the island (see Figure 2—1). The new fill would
rise to an elevation not to exceed 140 feet above mean sea level,
which represents an increase of 50 vertical feet in the peak
elevation. All existing structures on the island would be
demolished and approximately 80 percent of the island covered with
fill. Material would be contained by the construction of a rock
containment dike around most of the island. A construction haul
road could be placed on the top of the dike and encircle most of
the island.
Following completion of the disposal phase, the island would be
regraded and revegetated for park use. Some portions would be
restored for use as wildlife habitat.
2.2 Spectacle Island Aquatic Resources
A number of studies have been undertaken by the project to document
the potential for impacts to the island’s aquatic resources.
Biological sampling was conducted by MDPW consultants in the marine
waters surrounding Spectacle Island in November, 1988 by Jason M.
Cortell and Associates. Benthic macroinvertebrates were collected
at 11 stations using a 0.05 square meter Ponar grab. Three samples
were collected at each site and combined. Sediment chemistry was
also measured at each of these stations. A standing crop survey
of the abundance and distribution of soft—shell clams (Mya
arenaria) and blue mussels (Mytilus edulis) around the island using
protocol developed cooperatively by Massachusetts Department of
Public Works and Federal and State environmental agencies (Cortell,
1990). A lobster survey was also conducted by the MDPW, but the
results have not yet been released.
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MDPW PROPOSAL
SPECTACLE ISLAND
I. ’.
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2.2.1. Benthic Macroinv.rtebratss
Fifty-f ive benthic species were identified around Spectacle Island.
Fifty percent of these species were polychaetes, 22 percent were
arthropods, and the remainder were molluscs. As is typical of all
of Massachusetts Bay (EPA, 1988) spionid polychaetes were the
dominant family of polychaetes. Species densities ranged from 167
organisms per square meter to 3107 organisms per square meter.
These densities are relatively low for Massachusetts Bay where
densities are generally in the tens of thousands per square meter.
The benthic community within the area of fill is very similar to
the stations sampled by Cortell outside the fill area. The species
composition is typical of Massachusetts Bay hard bottom communities
interspersed with sandy patches. The densities of organisms in
this area are relatively low ranging from 167 organisms per square
meter to 2820 organisms per square meter.
The chemical composition of the sediments in the area of proposed
fill are similar to those in other areas of Boston Harbor (see
Table 2—1). Cadmium, chromium, copper and lead concentrations are
up to twice the concentrations found in Quincy Bay. Since
Spectacle Island is located in close proximity to the existing
Boston Harbor wastewater and sludge outfalls and because the
sediment contaminants are similar to those found in other areas of
Boston Harbor, it is likely that the source of the contaminants in
the vicinity of Spectacle Island is sediment deposition from the
discharges. The SEIS/R notes in Appendix 1, Chapter 9, that tests
are presently being performed on boring samples taken offshore of
Spectacle Island to determine the presence of hazardous materials.
Additional sampling of water and sediments around the island are
also underway to determine the presence of contaminants and extent
of the original landfill (SEIS/R, Appendix 1, pp. 9-19 to 9-20).
We consider this information to be critical to any decision on the
final size and type of containment facility for the island.
The structure of the biological community in the vicinity of
Spectacle Island does not appear to be affected by the contaminants
in the sediments, as evidenced by the diverse community composition
and presence of sensitive species. The low densities of organisms
in the area may be the result of a combination of sediment type,
sampling methodology, and sediment contaminants.
2.2.2. Shellfish Resources
Table 2-2 provides a summary of clam and mussel densities at
Spectacle Island and two reference sites. Soft-shell clams were
found in low densities around Spectacle Island (averaging 0.4 clams
per cubic foot), as compared to Thompson Island (1.6 to 7.8 clams
per cubic foot); they were comparable to those densities observed
on Long Island (0.25 to 0.4 clams per cubic foot). This is due to
the minimal amount of soft bottom substrate preferred by the clam.
Even in areas of soft bottom substrate, densities of clams are
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TABLE 2-1 SIJISARY OF SPECTACLE ISLAND SEDIMENT CONTAMINATION (pps)
Spectacle IsLand Station
Range observed Range Causing Range Range at Knous
at 1-1 at 1-2 at 1-10 to Cause Non-mortality Causing Contaminated Site
Parameter 0 - 0.5’ 0 - 2’ 0 - 0.5’ No Sf fect Adverse Effects* Nortallty (Quincy Bay)
Arsenic 39.1 12.3 15.7 54 to (72 70 ND
Cathius 4.7 5.7 2.2 ‘1 to 5800 ‘1 to ‘5800 6.9 to 5000 0.1 to 1.62
Chromiun 282 45.8 84 c86 to 1430 (95 ND 5.6 to 215
Copper 181 271 81.4 20 to 4000 ‘53 to ‘17.8 ND 6.8 to 141
Lead 187 310 110 (21 to 380 33 to ‘120 130 to 300 6.6 to 164
Mercury 1.31 1.6 0.48 ‘0.18 to 1.7 ‘0.28 to ‘1.1 ND 0.02 to 21.5
Nickel 43 57.4 22.1 13.9 to 96 55 ND ND
Zinc 308 1210 140 99 to ‘51,000 51 to ‘200 ND ND
PAN (total) ND 18.75 3.3 2 to d29 2 to 3900 c122 to 200,000 1.27 to 113
PCB8 (totaL) 1.14 0.76 0.25 0.1 to 1.22 0.16 to 36.8 ‘0.13 to )O.16 0.1 to 1.22
• Based on review of more than 35 scientIfic studies.
Source: EPA, 1988
ND = no data
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TABLE 2-2 SUMMARY OF SOFT SHELL CL M AND MUSSEL DENSITIES
AT SPECTACLE ISLAND AND REFERENCE SITES
sediment type
mean clam densities
foot(lowtjda].)
Spectacle Thompson Long
Island Island Island
cobble
pebble
sand
shell
silt
wave exposure
0.75 7.8 0.25
0.5 0
0.13 6.3 0.4
2
0.31 1.6
high protected high
mean mussel densities
per square foot
cobble
pebble
sand
shell
silt
wave exposure
36.3 12.5 4.6
24.8
42.1 1 78.4
62
15.8 1.7 0.6
high protected high
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relatively low-due to continued disturbance by high wave exposure
during storms.
Mussel densities around Spectacle Island are relatively high (15.8
to 62 mussels per cubic foot), as compared to Long Island (0.6 to
78.4 mussels per cubic foot) and Thompson Island (1 to 12.5 mussels
per cubic foot. This is due to the prevalence of physical
conditions preferred by blue mussels. MuBsels readily colonize
substrate dominated by secured cobbles and boulders which is common
around Spectacle Island. Mussels also prefer areas of high wave
energy since they are filter feeders.
Available data is insufficient to determine the extent of impacts
from the island’s historic landfill activities on the area’s
biological resources. This is due to (1) the lack of comparable
sampling transects (with similar physical substrates) within and
outside the inferred landfill boundary; and (2) the presence of
other sources of contamination (e.g. wastewater outfalls) in the
vicinity of the island.
2.3 )1&3 Minimum Pill Alternative Proposal
An alternative proposal for Spectacle Island has been prepared
which limits the disposal of material on the island to the minimum
amount required to adequately cap the historic landfill in
accordance with current state landfill closure regulations (see
Figure 2-2). This proposal would utilize a combination of upland
containment areas for the disposal of the majority of the excavated
and dredged material from the CA/THT construction project. This
alternative is intended to minimize the filling of coastal waters
of the United States subject to regulation under Section 404 of the
Clean Water Act and Section 10 of the Rivers and Harbors Act. It
is recognized that this alternative proposal would be relatively
expensive, based upon cost per volume of material disposed.
2.3.1. Methodology and Assumptions
A grading plan for the capping of the historic landfill at
Spectacle Island was prepared in accordance with all existing DEP
regulations. The grading plan is intended to cap those portions
of the historic landfill above mean high water (MHW). The
intertidal and subtidal boundaries of the landfill have not yet
been confirmed by the MDPW; they are currently conducting
additional investigations to determine the extent of the historical
landfill. For purposes of this analysis. the landfill boundary
does not extend into the intertidal area. and this area remains
unchanged by the proposed landfill cao .
It was assumed that the landfill would be capped with a two foot
layer of the Boston Blue Clay that will be excavated during the
CA/THT construction project. In order to minimize the filling and
consequent impacts to the adjacent coastal waters, the grading plan
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SPECTACLE ISLAND
M&E ALTERNATIVE
‘I .
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utilized the maximum allowable side slope of 33 percent and limited
capping to areas above elevation 105 (mean high water). Ten foot
wide benches were placed for slope stabilization every 20 vertical
feet in areas with the maximal side slope. A maximum top slope of
3.4 percent was used along the north-south axis of the island in
accordance with DEP regulations. An erosion control dike would be
required in order to minimize the undermining of the fill material.
At a maximum, the dike would extend from mean low water (elev. 95)
to mean high water (e]ev. 105).
2.3.2. Results
A final grading plan was prepared that would allow for the capping
of the historic landfill on Spectacle Island. The total volume of
fill required to cap the existing landfill is approximately 550,000
cubic yards. This grading plan would result in the filling of some
acreage of intertidal zone (between elevation 95 and 105) on the
eastern and western side of the island. No subtidal area is
permanently filled with this plan, although temporary disturbance
during construction of the rock dike is likely in both the
intertidal and subtidal areas.
This alternative will allow for the beneficial re-use of the island
as a park or conservation area. It is anticipated that walkways
and trails would traverse the island, utilizing where possible the
landfill benches, to provide suitable viewing and walking
conditions. The island could be revegetated following landfill
activities with a variety of meadow grass species, and low native
trees/shrubs to match the vegetation of other Boston Harbor
Islands. A comparison sea level view from Boston Inner Harbor of
both the MDPW and M&E approaches is shown in Figure 2-3. (This view
is intended to show differences in island heights between the two
alternative approaches and does not show the lateral extent of the
new fill areas.)
2.4. Comparison of Aquatic Resource Impacts
The MDPW proposal would result in the permanent loss of 18 acres
of intertidal aquatic habitat, and over 85 acres of subtidal
aquatic habitat. The impacted substrates range from rocky
intertidal shoreline to sand/silt and clay/silt benthic substrates
which are prevalent in the subtidal areas to the north, east, and
west of the island (Cortell, 1990). These fill areas will replace
suitable benthic invertebrate, clam, mussel and lobster habitats
of low to moderate quality. Surrounding areas outside the
containment dike are also likely to be temporarily impacted (i.e.
increased turbidity and contaminant redistribution) due to dredging
and rock placement activities.
The M&E—propoSed alternative configuration greatly reduces the
severity of spectacle Island aquatic habitat impacts from the
levels presented in the MDPW SEIS/R. Permanent impacts to the
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SPECTACLE ISLAND
-____ ____ ___ ____ ________
M&E ALTERNATIVE
MDPW PROPOSAL
‘II
I .I.
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intertidal zone will be limited to the installation of a granite
or similar riprap structures on the east and vest sides of the
island to preserve the integrity of the new landfill. No permanent
subtidal impacts are anticipated, although some tempOrarY
disturbance (i.e. physical displacement, increased turbidity, and
contaminant resuspension) is possible during construction of the
riprap structure (from barge unloading and stone placement
activities). However, the reduced length of necessary riprap and
dike placement shoreward of the low water mark result in
significantly lower impacts due to dike construction. This riprap
viii also provide suitable intertidal habitat for a variety of
invertebrate and shellfish species.
3.0. EvaluatiOn of Alternative Disposal Bites
3.3. Summary of MDPW Alternative Bite Selection Process
The MDPW materials disposal site selection process commenced
following publication of the initial project EIS/R in 1985. That
document deferred identification and selection of candidate
disposal sites to the supplemental EIS/R. In May, 1989, the MDPW
released a Disposal Site Screening Report (Bechtel, 1989) which
identified approximately 30 sites (primarily municipal landfills
and confined marine disposal areas) as candidate sites. The report
recommended the exclusive use of Spectacle Island for materials
disposal (with the exception of acceptable dredged material
disposal at the Massachusetts Bay Disposal Site (MBDS).
Following release of this report, the MDPW undertook a screening
analysis of approximately 824 sites (primarily the 296 MWRA
residuals landfill site alternatives and over 500 municipal
landfills). With the assistance of an interagency working group,
all but approximately 97 sites appear to have been eliminated from
further consideration due to cost, logistics, availability or
technology criteria established by MDPW.
The recently-released SEIS/R documents the elimination of
approximately 15 additional sites from this list, but only
evaluates nine sites in detail (4 upland and 5 marine sites);
Spectacle Island has again been recommended for exclusive use for
disposal of all excavated material and a portion of dredged
material. No documentation is currently available for elimination
of the other 73 sites from this screening analysis. The SEIS/R
indicates that additional sites are being evaluated during the
document’s review period (MDPW, 1990).
3.2. M&E Alternative site Evaluation Process
Because several alternative materials disposal sites had either (1)
dropped from consideration within SEIS/R as preferred disposal
sites; or (2) not screened from final consideration (by the
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interagency working group) as candidate sites, M&E initiated an
independent screening process to identify potentially feasible site
locations. This screening process consisted of several steps, as
discussed below.
3.2.1. Evaluation of MDPW SEIB/R “Finalist” 8itea
As mentioned above, 4 upland sites were retained for analysis as
disposal sites within the Draft SEIS/R. These sites included (1)
East Brookfield; (2) Bedford; (3) Maiden (Rowe Quarry); and (4)
Weymouth (Bates Quarry). Upon review of these 4 sites, M&E
initially concurred that E. Brookfieid and Bedford should be
dropped from consideration, due to excessive potential impacts to
wetlands, aquatic and terrestrial wildlife, and existing traffic
conditions. However, 2 of the 4 finalist sites, Rowe and Bates
Quarry, were retained as viable candidates, and existing
information on wetlands, public water supplies, land use, and
traffic were reviewed (where available). Field visits and
literature review confirmed the potential viability of these sites.
They also appeared desirable as they provided potential disposal
sites to both the north and south of the project site.
3.2.2. Evaluation of MDPW/MWRA Site Database
The 73 sites which were apparently not eliminated by the MDPW were
evaluated to select those which appeared to be most promising, in
terms of location, size, and amount of surface water on site. This
information was retrieved from the MDPW summary data file prepared
for the April 1990 interagency site working group. Most of these
73 sites evaluated, but not eliminated by MDPW, were obtained
directly from the Massachusetts Water Resources Authority (MWRA)
Residuals Site database, which included 296 candidate locations
within the MWRA service area. This list is provided as Table A-i
in Appendix A of this report.
From this list, 17 sites were selected for more detailed analysis
based upon the initial criteria discussed above. During this
phase, M&E staff reviewed the project consultant’s data files for
the sites and prepared a summary matrix of key attributes for the
sites and a recommendation on the need for further investigation.
This analysis is presented in Table A—2, in Appendix A of this
report. Of the 17 selected sites, 7 were selected for more
rigorous analysis. These 7 sites were visited and evaluated using
a variety of information sources, including USGS quad sheets, land
use maps, and discussions with town officials. Of the seven sites
evaluated, only one, Framinghaml3, was retained as a candidate
site following the site visits. Other sites were rejected due
primarily to access concerns (through residential areas), present
land uses (new commercial or residential development), or
regulatory status (designation as state hazardous waste sites).
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3.2.3. Evaluation of New Bites
In addition to review of MDPW sites, many of which were taken
directly from the MWRA residuals landfill screening database of 296
sites, other candidate sites were identified from discussions with
EPA and the Army Corps of Engineers Regulatory Branch personnel.
This site identification process was largely subjective, and
focused upon area quarries which might be available for use as
landfills. Quarries are generally considered to be favorable
locations for landfills, as they are (1) heavily disturbed; and (2)
often connected directly to major rail and road networks. Some of
these sites were not considered eligible for use by MWRA as
landfill sites, as they were located outside the MWRA service area.
As a result of these initial investigations, two quarries
(Saugus/MelroSe and Weston) were identified for further
investigation. They were selected as potentially feasible due to
their proximity to the project, existing adjacent land use, and
access from major road and rail networks.
3.2.4. Results
A total of 7 upland sites were evaluated in detail as a result of
this screening process. Two SEIS/R finalist sites (Weyinouth and
Maiden); one MWRA residuals site (Framingham-13); and two new
quarry sites (Saugus/Meirose and Weston) were retained for
consideration. Those new sites not previously analyzed by MDPW
were reviewed in relation to state solid waste landfill siting
criteria; this analysis is summarized in Table A-3, in Appendix A
of this report.
The Spectacle Island (minimum capping alternative) and the filling
of depressed areas between Logan Airport runways have also been
retained as potentially feasible disposal alternatives. All sites
(except Logan and Spectacle Island) were visited and all were
evaluated in detail. They are discussed individually below, in
section 3.3.
3.3. Feasible Alternative Disposal Bites
The 7 candidate sites were evaluated in terms of significant
resources (e.g. groundwater/Wetlands, floodplains, cultural
properties); on-site and adjacent land use, including zoning,
traffic and existing development; and size/capacity. Each of these
site characteristics is summarized below for specific sites. Table
3—1 summarizes the capacities and potential constraints on use of
these sites.
It is important to note that the potential institutional
constraints (e.g. the time required to obtain a DEP Solid Waste
Landfill Assignment) are considered to be roughly equivalent for
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SUMMARY OF PROPOSED ALTERNATIVE
MATERIALS DISPOSAL SiTES
SOURCE CAPACITY ( MCY) POTENTIAL CONCERNS
Rowe Quarry DPW/MWRA 3.0 Minimal
(Maiden)
Bates Quarry DPW/MWRA 2.5 Minor Residential impacts
(Weymouth) Quarry Pond Losses
Logan Airport DPW 0.7 FAA Restrictions
Framingham-13 DPW/MWRA 1.0 Access &
Site Constraints
Weston Quarry EPA/COE 2.0 Site Constraints
Quarry Pond Losses
Saugus EPA/COE 1.6 Minimal
Spectacle Island DPW 0.6 Cost/Unit Storage
Total 11.4
Table 3—1
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each alternative upland site and thus not used in the evaluation
of individual sites. Costs of landfill site acquisition and
development, and materials transport costs have also been excluded
from this analysis.
3.3.1. Rove Quarry (Maiden)
The Rowe Quarry (Maiden) site, an MWRA residuals finalist site, is
located directly off Route 1 North with access from Lynn street
(see Figure 3-1). The site is approximately 3.6 miles from
downtown Boston and is surrounded on the north, south, and vest by
residences. Residences on the south side of the site are owned by
the quarry. Forest, open space and Route 1 serve to buffer adjacent
residences from the quarrying activities. The site is
approximately 60 acres and is expected to provide approximately 3.0
million cubic yards of storage volume.
Wetlands . The SEIS indicates that up to 4 acres of wetland are
present on the site and that all of these wetlands would be
impacted by the landfill operations. However, the MWRA’s Residuals
Management Study and EPA’s Residuals SEIS, which also evaluated the
impacts associated with similar use of the Rowe Quarry site, did
not indicate the presence of any wetlands on the site. Any
wetlands which may be present on the site are most likely man-made
and highly disturbed by the quarrying activities. Therefore, low
impacts to wetland would be anticipated from use of the site.
Water quality . The site drains to a portion of the Rumney Marshes,
which was recently designated as an Area of Critical Environmental
Concern (ACEC) by the state Coastal Zone Management Program. A
leachate collection system would be required to minimize impacts
to this area. Low impacts would be anticipated with a properly
designed leachate collection and treatment system.
Transportation Route . The proposed transportation route to Rowe
Quarry is Route 1 North to the Lynn Street (Saugus) exit (the Salem
St. interchange) to the quarry on the left. Route 1 is a busy
double-lane highway lined with numerous businesses.
Traffic . Access to the site would be from Route 1 and Salem
Streets. Traffic on Route 1 and Salem Street is heavy at times and
includes a high percentage of truck traffic. Average daily traffic
(ADT) counts for Route 1 near the quarry are 87,700 vehicles/day
(CTPS, 1990). As a result, low to moderate impacts would be
anticipated from truck traffic along this route (see section 3.4).
The SEIS evaluated the traffic impacts from accessing the site
using Route 1A. The impacts from the use of this alternate route
are high and therefore access should be provided from Route 1.
Land Use . Although the site is surrounded by single family and
multiple family residences, low impacts would be anticipated from
15
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the landfill operations due to buffering to the north, south and
west by wooded areas, open space and Route 1.
Sensitive Recemtors . Sensitive receptors identified in the
vicinity of the quarry are indicated (by number) on Figure 3-1.
They include:
1. Annemark Nursing Home, east on Lynn Street
2. Williamsburg Square Condominiums, east on Lynn Street
3. Northshore Assembly of God — on vest side of Route 2.
South
4. Trailer Park, Route 1, Maiden
Relocation . A relocation plan would be required for the quarry
business. It may be difficult to relocate the business in close
proximity to the Boston area.
Air quality . The SEIS indicates that 7 tons of non-methane
hydrocarbons and 24 tons of oxides of nitrogen will be emitted by
the truck traffic. These emissions will increase the levels of
pollutants in the air along the route. However, this is not
expected to have a significant impact above the existing conditions
due to the presence of heavy truck traffic along the route.
Transportation Noise . The selected route is along commercial
roadways with relatively few sensitive receptors which are exposed
to high noise levels from truck traffic. As a result, low impacts
would be anticipated along the route.
Operations Noise . There are seven residences within 100 feet and
30 residences within 400 feet of the site boundary. The impact to
these residences would be high at times. However, these residences
are exposed to high noise levels from the traffic and the quarrying
operations in the area. In addition, the houses on the southern
edge of the quarry are owned by the quarry, and could thus be
temporarily closed during site landfilling operations. As a
result, the landfill operations are not expected to result in high
impacts above already existing conditions.
Historic Resources . The MWRA Residual Management Study indicated
that potentially significant impacts could occur from the landfill
operations at the site. However, it is expected these impacts can
be mitigated through consultation and data recovery under Section
106 of the National Historic Preservation Act. The SEIS did not
address the impacts to historic resources.
3.3.2 Bates Quarry (Weymouth)
The Bates Quarry (Weymouth) site is located north of Route 3 just
17
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west of the Hingham town line, approximatelY 38.6 miles from
downtown Boston (see Figure 3—2). The site, as delimited by MDPW,
is approximately 130 acres and currently supports an operating
quarry as well as forested and undeveloped area.
Some dumping has been reported along the periphery of the site.
The quarry area is reported to cover only 62 acres. Other gravel
pits are located northwest, north, northeast and south of the site.
The disposal plan for the site, which was evaluated in the SEIS/R,
included placement of approximately 3.9 million cubic yards of
material on 81 acres of landfill area. The M&E —recommeflded use of
the site would focus on disposal of material within the 60 acre
disturbed quarry area, allowing a disposal volume of approximately
2.5 million cubic yards.
Wetlands . The total wetland and open water area is reported to be
12.2 acres of the 130 acre site. The SEIS states that approximately
9 acres of the 62 acre quarry area consists of open water and
wetlands. The quality and size of these wetlands and aquatic
habitats has not been fully field—verified by the MDPW. The MDPW-
selected landfill footprint, which covers 81 acres of the site, is
reported to impact 12.2 acres of wetlands as well as 5.4 acres of
open water (greater than the total area reported to be occupied by
the open water and wetlands on the site). Impacts to wetlands at
the site could be reduced by utilizing only the active quarry area
for disposal. Impacts to wetlands would then be limited to those
which are either manmade or heavily disturbed from the active
quarrying work in the area.
Water pua1itY Runoff collection and sedimentation would minimize
impacts to receiving waters. Some elevation of turbidity and
suspended particulates would be expected. A liner and leachate
collection system would also be required to protect local
groundwater supplies due to the presence of fissured rock in the
quarry area. Public water supply wells are reported to be located
northwest and southeast of the site. Zone ii delineation has been
requested for these supplies. The SEIS does not specify the actual
distance to theses supply wells. However, our discussions with the
town of Weymouth Department of Public Works have confirmed that the
nearest public water supply is located approximately 0.9 miles
north of the site.
Transportation Route . There are several alternative transportation
routes to the Bates Quarry. One route involves constructiOn of a
direct access road to the quarry from Route 3 North. The SEIS/R
route utilizes Route 3 South to Exit 15 to Derby Street (Route 228)
to Whiting Street (Route 53). Several options exist from Route 53.
From Derby Street, the route could turn left into the Weymouth
Industrial Park on Woodrock Road and then either turn left onto
Morse Road (west) and proceed along an access route to the quarry,
or turn right on Morse Street (east) to Pleasant Street (south) to
the quarry. A fourth alternative involves traveling directly from
18
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Whiting Street to Pleasant Street (south) to the quarry.
Derby Street is a two-lane road with commercial buildings and
industrial parks. The intersection of Derby Street and Route 53
is very heavily travelled, but requires a sharp turn. The southern
portion of Whiting Street is heavily wooded and the speed limit is
30 m.p.h. After the intersection with Cushing Street, the speed
limit increases to 45 m.p.h. Land use along Route 53 is
predominantly commercial with light residential. The industrial
park roads appear to be quiet and not heavily travelled. Pleasant
Street is a busy road. The Libby Industrial Park access road is
located across from the current quarry entrance.
Our review of the site location indicates that traffic impacts
could be significantly reduced if access to the site were improved.
This could be accomplished by construction of a temporary direct
access route from Rt. 3 into the quarry area. Loaded trucks could
then exit Rt. 3 at Rt. 228, cross over the highway, turn north onto
Rt. 3 northbound, and access directly into the disposal site. The
use of this alternative direct access route would eliminate the
traffic impacts projected for Rte. 53 and the potential need for
at least some of these bridge repairs.
Traffic . Recent traffic counts for the site vicinity range from
17,770 vehicles/day (at the Rt. 3/Rt. 228 interchange) to 26,023
vehicles/day (at the Derby St./Old Derby Street interchange),
indicating a moderately heavy level of commercial and residential
usage. Route 53 counts (22,180 vehicles/day) also indicate
relatively high traffic volumes of both commercial and residential
vehicles (Vanasse, Hangen and Brustlin, mc, 1989). According to
the SEIS/R, use of the site would have a low impact on Rt. 1-93,
with an increase of 9 percent in daily truck traffic. The impact
on Rt. 3 would also be low with an increase of 20 percent in daily
truck traffic. However, the SEIS/R predicts that a very high
impact would occur on Rt. 53, with a maximum increase of 259
percent. Although unknown, we assumed that this represents peak,
not average traffic for a larger site than the active quarry on
which the M&E alternative scenario is based. Thus, impacts could
be reduced from these levels. Pavement life would be reduced by
0.3 years, 0.7 years, and 9.5 years for Routes 1—93, 3, and 53,
respectively. This was considered by MDPW to be a moderate to high
impact for Routes 1-93 and 3 and a very high impact for Route 53.
The route would require repair of three bridges to handle increased
truck traffic. As mentioned above, a direct access from Rte. 3
into the quarry could significantly reduce these potential impacts.
LAnt..2.a . Residential and commercial development along access
streets and the Pratt School (now a condominium development) which
is near to the site could be impacted by truck traffic and landfill
operations if the MDPW access route were used. Impacts could be
significantly reduced with the use of a direct access route and
application of DEP minimum site buffer criteria.
20
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Sensitive ReceDtors . No sensitive receptors were identified along
the direct access road from Route 3 North to the quarry. Several
sensitive receptors including numerous single family residences
along the route, were identified along the transportation routes
involving Derby, Whiting, and Pleasant Streets. Other receptors
are indicated (by number) on Figure 3-2. They include:
1. Old Colony Montessori School, Derby Street, Hingham
2. Queen Anne’s Gate, apartments and townhouses, Route 53,
Weymouth
3. Kindercare school, located on the east side of Pleasant
Street, Weymouth, after the intersection with Morse Road
4. Woodridge condominium development, under construction at
the site of the former Pratt School, Pleasant Street,
Weymouth
Another sensitive receptor was identified near the MDPW-proposed
access route:
5. Church, Rte 53, Weymouth, just north of intersection with
Pleasant Street
Relocation . A relocation plan would be required for the quarry
business. It may be difficult to relocate this business in close
proximity to the Boston area.
Air quality . Although the level of impact was not addressed, the
SEIS states that 9 tons of non-methane hydrocarbons and 50 tons of
oxides of nitrogen would be emitted during peak year operation of
the site. Direct access into the site would reduce air quality
impacts to surrounding areas, and would confine peak truck
emissions to the Route 3 area.
TransDortation Noise . The level of impact was not addressed. The
SEIS states that noise increases of up to 5 dBA over the existing
ambient would be expected in the area of the Pratt School. In
other areas noise level increase would be less than 1 dBA. Although
the SEIS/R states that twenty-four hour operation would not be
possible because of the proximity to sensitive noise receptors,
direct access to the site from Rt. 3 would reduce transportation
noise and allow extended periods of operation.
Operation Noise The SEIS indicates that insignificant noise
impacts would occur during landfill operations. There is no
discussion of the noise level increases. This level of impacts is
probably valid as no residences are located within 500 feet of the
landfill.
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liiJ.tQzi2. No historic resources were identified on the site.
3.3.3 aaugus/M.lrOS. Quarry
This site is located just north of Rowe Quarry, off Rt. 99 and Rt.
1 on the Saugus/Meirose border (approximatelY 4 miles from Boston;
see Figure 3-1). it currently supports an active quarrying
operation; most of the equipment and facilities are concentrated
in the southern portion of the site. A conservative estimate of
site capacity is 1.6 million cubic yards; this figure could
possibly be revised upward, as the site appears to be similar in
size to Rowe Quarry, but detailed topographic information is needed
to confirm site capacity.
Limited access to the site prevented complete evaluation
of the wetland area. However, the site is mostly disturbed and it
is likely that if there are wetlands on the site, they are man-
made, such as quarry ponds. Therefore, impacts are expected to be
minor in nature. There is some upland forest on the site. No
threatened or endangered species habitats have been reported on or
directly adjacent to the site.
Water Resources . There are no surface water resources on the site.
A liner may be required to comply with DEP requirements for a
minimum depth to groundwater of 4 feet. The site is not in the 100
year floodplain, Zone II or Interim Welihead Protection Areas.
Transportation Route . The transportation route to the
Meirose/Saugus quarry is along Route 1 North to Essex Street
(Meirose) to Route 99 South to the quarry on the right. The
portion of the route along Route 1 North passes numerous businesses
including motels, gas stations and restaurants. The route
continues to the Essex Street overpass toward Melrose, then south
on Route 99, a heavily-travelled state highway (traffic count
information not available). Route 99 development near the quarry
is predominantly commercial, with businesses such as office parks,
motels, car dealers, restaurants/nightclubs, and stores. There are
some residences along Route 99, including a trailer park on the
east side.
Traffic . Traffic on Route 1, a major regional arterial, is heavy,
with ADT counts ranging from 98,000 to iio,ooo vehicles/day (MDPW,
1990, and CTPS, 1990). The truck traffic associated with the
Central Artery disposal is not expected to result in significant
impacts to Route i traffic. Impacts to Route 99 are expected to
be higher, but only for a very short segment of the road which is
dominated by commercial and industrial uses. It appears that one
or more bridges crossing over Route 1 would require improvements
to handle project truck traffic. This could be accomplished as a
mitigation measure associated with the project. The area
immediately adjacent to the site is mostly commercial although
22
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there are some residential properties near the intersection that
could be affected by the truck traffic.
Land use . The Mount Hood Park is located to the north_northwest
of the site. Noise from the operation of the landfill would have
some impact upon the users of the park, but is buffered by wooded
areas. The closest park land uses (parking and golf) would not be
significantly affected by andfilliflg. In addition, any impacts
would be similar to what is experienced flow as a result of the
active quarrying operation. Therefore, it is not expected that the
landfill activity would present a significant impact to the park
use. The land uses to the south and southwest of the quarry are
primarily commercial and residential. Penny Lane, located to the
south of the site, is primarily a residential street. If access to
the landfill is prohibited in this area, impacts will be minimized.
The land uses to the east are primarily highway commercial. The
conversion of the quarry to a landfill should not result in a
significant impact to these uses.
Sensitive Receptors . There are a number of single family
residences along the proposed access route, near the Essex Street
overpass and on Route 99. These residences are presently subject
to relatively high noise and visual impacts due to Route 1
development. Other sensitive receptors on the route to the
MeiroSe/SaUqus quarry are indicated (by number) on Figure 3-1.
They include:
la. NorthshOre Assembly of God - on west side of Route 1 South
2a. Trailer Park, Route i, Maiden
3a. First Baptist Church - opposite quarry off Osprey Road
4a. Mount Hood Golf Course, Meirose
Relecatiofl . Relocation of the current quarry operation would be
required. This would present a significant impact if an
appropriate location could not be found, or if an equitable
monetary settlement could not be arranged. A secondary impact
related to the relocation of the quarry activity is the loss of tax
revenue for the towns of SaugUs and MelrOSe. Depending upon the
amount of tax revenue contributed by the quarry this could
represent a significant impact.
Air qualitY . As this site is similar in size and located very near
Rowe Quarry, the impacts on air quality discussed earlier for Rowe
would also apply to this site. Due to the heavy volumes of truck
traffic and assumed levels of particulates associated with the
quarrying operatiOflS significant additional impacts to ambient air
quality due to landfilling are not expected. However, additional
site-specific data are needed to confirm this.
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TransDOrtatiOn Noise . As noted above, transportation noise impacts
are possible, but can be reduced by keeping truck traffic routed
on Route 1 to Route 99, maintaining traffic volumes to the same
levels as are recommended for Rowe Quarry. There are some
residences near the intersection of Route 1 and 99, and there are
also some residences on the Route 1 overpass which would be used
to allow truck traffic to change direction on Route 1. As
mentioned above, these residential properties are already
experiencing negative impacts associated with heavy traffic
(including trucks) associated with Route 1 commercial activities
(and the existing quarry). Depending upon the final access route,
the project truck traffic could have a moderate negative impact
upon these residences.
ODeration Noise . As noted above, the operation of the landfill
could negatively impact users of the Mount Hood recreational area,
and residential properties located to the south of the site.
Acoustic and visual buffers (such as the vegetated area on the west
edge of the quarry) would reduce impacts to the Mt. Hood golf
course users. The noise levels would be expected to be similar to
those generated by an active quarry, and therefore the impact is
not expected to be significant as long as the hours of operation
are similar to the quarry’s current operation. Use of the landfill
during night—time hours or during weekends would result in more
significant impacts.
Historic Resources . There are no historic resources recorded on the
site.
3.3.4 Weston Quarry
This site is an active quarry (currently owned by Massachusetts
Broken Stone Co.) located at the junction of Route 128 and Route
20 in Weston (see Figure 3-3). The site contains large areas of
historic excavation activity; several deep pits (60-80 foot depth)
are apparently on site, and at least some of them appear to contain
water (depth and extent unknown). The site is bounded on the
northwest by the Town of Weston’s municipal landfill and to the
north and east by the MBTA commuter rail tracks, a fuel tank farm
and the Route 128/Route 20 interchange. A small stream, Stony
Brook is located just to the north of the commuter rail tracks, and
a large pond is located just to the south of the site. Total site
capacity is estimated at 2.0 million cubic yards, after applying
necessary DEP siting buffers. The bulk of this capacity is
expected to be within large open excavated pits on the north and
west side of the site.
Wetlands . The site is highly disturbed due to the quarry activity.
In the southernmost portion of the site there is a fairly large
pond associated with the quarry. It is approximately 5—10 acres
in size, and may be the detention pond for the quarry. Because of
difficulties to accessing the entire site, it was not possible to
24
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. el ‘.
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WESTON QUARRY
Sinsitive Receptor
SENSITIVE RECEPTORB
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Figure 3—3
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confirm the size or values of these ponds and wetlands on site.
It is likely that the landfill would have to occupy at least a
portion of the quarry pond area in order to provide sufficient
storage volume.
Water Quality . According to the DEP Water Sources overlay, an
unverified well exists just north of the Weston quarry site. It is
not expected that landfill activity, with proper design, would
impact the well, however, additional investigation should occur to
insure that DEP site assignment criteria can be met. As portions
of the site are located within 0.5 miles of the Stony Brook
Reservoir and within 250 feet of Stony Brook, site buffers will be
necessary to meet DEP site assignment criteria. The site is not
located within a Zone II, or Interim Wellhead Protection Area.
Although there is 100 year floodplain located on site (associated
with the pond on the southern portion of the site), disposal would
already be avoided in this area to meet other criteria regarding
minimum distance to surface water bodies. More investigation is
needed regarding the precise location of the surface water features
shown on the USGS map before a more definitive determination of
impact can be made.
Transportation Route . The proposed access route for the Weston
site is Route 128 North to Route 20 West (for .1 miles) to the
quarry entrance on the north side of Route 20. There is limited
development along the transportation route. Several businesses
which generate truck traffic are located on Sibley Road, to the
east of the site on Route 20.
I. 1.th. As Route 128 is already a heavily-used truck route at
present, it is not expected that there would be any significant
additional impacts related to traffic access for that highway.
Route 20 volumes, while lower, are still substantial (26,800
vehicles/day west of the Rte. 128 interchange) (MDPW, 1990). In
addition, there is an active railroad line that runs along the
eastern boundary of the site, and an abandoned railroad line
bordering the north and vest site boundaries. The active line, at
a minimum, could be used to reduce truck traffic to the site.
Land Use . Part of the site is an active quarry. The other part
of the quarry appears to be abandoned. A railway runs adjacent to
the site along the northern and eastern borders. There is some
residential development on Route 20 just of f Route 128 (at the end
of the quarry access road) as well as to the north of the railway.
There is some commercial and industrial development to the
north/northeast of the site. The town of Weston’s landfill is also
located to the north of the site and railway. Significant impacts
to surrounding land uses related to truck traffic or landfill
operation are not expected if the hours of operation are the same
as for the current quarry activity. If extended hours are
necessary, there could be minor to moderate impacts upon adjacent
residences due to increased traffic and elevated noise levels.
26
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Sensitive Receptors . No sensitive receptors were identified along
the proposed route to the quarry in Weston. Nearby sensitive
receptors include some single—family residences on or near Route
20, although none are located directly adjacent to the quarry area.
Two additional sensitive receptors are indicated (by number) in
Figure 3-3. They are described below:
1. Weston Veterinary Clinic: located about 700 feet west of
the quarry entrance on the south side of Route 20
2. The Gif ford School: school located about 1000 feet vest
of the quarry entrance on the north side of the road
Relocation. There would be a need to relocate the existing quarry
company, Massachusetts Broken Stone. There is the potential for
a significant impact if an appropriate location can not be found
or if an equitable monetary settlement can not be found. There is
also a potential for a negative impact to the community as a result
of lost tax revenue generated by the private quarry activity.
Depending upon the amount of tax revenue generated by Mass Broken
Stone, this could represent a significant impact.
Air quality . Although no estimates of existing air quality
conditions for the site are currently available, it is reasonable
to assume that, if the site is operated at comparable levels to
Rowe or Weymouth, incremental air quality impacts would not
significantly change from existing conditions (due to the presence
of active quarrying and the proximity to Route 128. However,
additional site-specific data is needed to confirm this preliminary
finding.
Transportation . The site has excellent direct access from Route
128 or from adjacent rail lines. If the same hours of operation
are maintained for the landfill as for the quarry it is not
expected that there would be any significant impacts to surrounding
land uses. If hours of operation are extended it is possible that
the additional truck traffic would result in some negative impacts
to the nearest residences located (1) on Route 20 at the end of the
access driveway; and (2) in the Kendall Green area north of the
site.
operations noise . Significant negative impacts related to
operation noise would not be expected if the hours of the landfill
are maintained the same as for the current quarry operation. If
nighttime hours are added, the noise from the landfill might carry
to the residences which are located at the end of the quarry
(landfill) access road from Route 20 and in the Kendall Green area.
Other land uses would probably not be affected. The site boundary
has been reduced to account for minimum DEP siting criteria from
residences (500 feet).
- 27
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ifistoric Resources . There are no known historic resources recorded
on site.
3.3.5 Logan Airport
This site refers to the areas between runways at the airport which
are currently below the runway surface grade (see Figure 3—4).
They are presently used only for drainage and navigational flight
aids; both of these functions can be accommodated during and after
the landfilling operation. Assuzing a level deposition of project
material in these areas to a height of approximatelY 2 feet above
existing grade (but still below runway elevation), total site
capacity is estimated to be approximatelY 0.7 million cubic yards.
The site is briefly discussed in the SEIS/R, and is apparently
being investigated further.
Wetlands . Although some (unknown) areas of the site may
potentially meet the federal jurisdictional criteria as wetlands,
they are all essentially non-native disturbed areas which would not
provide significant wetland values and functions. Further site-
specific information is needed to confirm this finding.
Water quality . The site would drain directly into Boston Harbor,
allowing for disposal of sodium-contaminated materials without
treatment or lining. No impacts to groundwater or public water
supplies would be expected.
This site offers significant traffic advantages to other
upland sites, as material could be brought directly from the
project alignment by truck or barge to the runway areas without
direct impacts to residences. This would allow use of the site on
a 24-hour basis; proper site scheduling would allow maximum use
when airport traffic is lowest. Federal Aviation Administration
(FAA) and Massport coordination would be necessary to ensure that
impacts are minimized.
Land Use . As the surrounding land use is primarily commercial and
industrial, and the airport activities presently affect surrounding
communities to a larger extent than the proposed landfilling, no
significant impacts would be expected.
Relocation . No permanent relocation of airport functions would be
necessary, although some temporary displacement of certain airport
lighting and navigational aids would likely be required.
Air quality . Although exact data is not currently available, it
is expected that existing ambient air quality at the airport would
not be significantly affected by the addition of project-related
traffic.
TranspOrtation Noise . The access route and disposal locations are
28
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Sr
Ezèstvig bi gs
Ez stb g shorellil
LOGAN AIRPORT
Figure 3-4
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within heavily—travelled areas with high levels of existing ambient
noise levels. No significant impacts are thus expected.
oDerations Noise . As stated above, the airport is a current source
of relatively high ambient noise levels, and project related
activities are not expected to contribute a significant new source
of noise to the environment.
Ristoric Resources . As the runway areas are all on filled land,
and thus previously disturbed, the potential for impacts to
historic resources due to disposal activities is considered
minimal.
3.3.6 Framingham Bit. (YRA—13)
This site, located approximately 20 miles from the project area,
is approximately 1.5 miles north of the Massachusetts Turnpike, in
an active gravel pit and quarry (see Figure 3-5). It is bounded
on the north and west by the Sudbury River, and to the south and
east by open land and commercial/residential development. The MWRA
Sudbury Aqueduct runs through the center of the site. As a result
of these site constraints, and the application of minimum DEP
landfill siting criteria, the site capacity has been revised
downward from the original MWRA estimate to 1.0 million cubic
yards.
Wetlands . The USFWS wetlands map does not indicate the presence
of any wetlands on the site. However, regulated wetlands are
likely to occur on the site in the area adjacent to the Sudbury
River. The DEP siting criteria require a 250 foot buffer from non-
drinking water bodies such as the Sudbury River. This buffer would
probably also provide the required 100 ft buffer from any wetlands
which are present along the river. As a result, impacts to
wetlands are expected to be minimal.
Water quality . Runoff collection and sedimentation would be
required to minimize impacts to the Sudbury River. Some elevation
of turbidity and suspended solids would be expected. A liner and
leachate collection system would be required to protect the local
groundwater supplies due to the likely presence of fissured rock
within the quarry area. Four wells, one of which is a public water
supply well, are located to the northeast, within 3300 feet (1000
meters) of the site. The closest well is 1250 feet north of the
site. The site is adjacent to, but not within, a Zone II recharge
area associated with the nearby Pod Meadow/Sudbury River system.
Transportation Route . Access to the Framingham site is possible
from either the Massachusetts Turnpike (Route 90) West, to Route
30 North, to speen Street and Old Connecticut Path (north). Another
alternative route runs from the Massachusetts Turnpike (Route 90)
West to Route 30 south, to Burr Street, onto the Legatt-McCall
Office Park connector road, to Speen Street and Old Connecticut
30
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FRAMINGHAM’-13
BENBITIVE RECEPTORS
!X0 3 1000 : o
— 1_ —
LET
Figur. 3•-5
- - --<.
SCALE
ensitiV R.c.ptor
-------
Path.
The Legatt—McCall connector road is newly paved, wide single lane
road with office buildings. Land use along this portion of Speen
Street is exclusively commercial and industrial. The southern
portion of the route on Old Connecticut Path is commercial, while
the northern portion passes through a residential area.
fjj . Truck traffic would most likely have a low impact on Rt.
1-90 and a moderate impact to Rt. 30, Speen St. and Old Connecticut
Path, which are 2-lane striped roadways with substantial
commercial, industrial and residential development. Traffic counts
for Route 30 (33,350—35,200 vehicles/day at the turnpike
interchange area, according to CTPS, 1990) indicate moderate to
heavy usage. Old Connecticut Path traffic is somewhat lower, at
approximately 18,000 vehicles/day north of Route 30 (CTPS, 1990).
Although the northern portion of Old Connecticut Path is
residential, the area appears to currently receive some truck
traffic from at least three heavy industrial operations (the
Ellirigwood Construction Company gravel pits, American Precast
Concrete, and the New England Sand and Gravel Co.) all of which are
located at the end of Meadow Street, on or adjacent to the site.
Land Use . Land use on the site consists of 50 percent industrial
development, 45 percent forest and 5 percent open space. There are
occupied residences within 500 feet of the site and a few single
family homes adjacent to the quarry. A residential neighborhood
lies south and east of the site. As mentioned, earlier, a MWRA
Aqueduct runs from west to east through the site. A powerline also
runs north to south, along the eastern border of the site. However,
this easternmost portion of the site would be used for disposal,
as it lies within the Zone II recharge area.
Sensitive ReceBtors . Numerous single family residences are located
along Old Connecticut Path and one of the access roads to New
England Sand and Gravel Company. Other sensitive receptors are
indicated (by number) on Figure 3—5. Those sensitive receptors
located along the proposed transportation route include:
1. Office Building, 160 Speen Street, located about 10 feet
from road
2. Saxony Apartments, Old Connecticut Path (west side)
3. Children crossing sign at the corner of Old Connecticut
Path and Hamilton, (assumed to be for a bus stop)
4. Wheelchair handicapped sign north of the intersection of
Old Connecticut Path and Fenton Street
Sensitive receptors identified in the area surrounding the gravel
pits include:
32
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5. Danforth Street/Meadow Street single—family residences
6. Church of Saint George — Catholic church at the
intersection of School Street and Hamilton
7. Saxonville Village Condominiums — east side of Concord
Street, between Hamilton Street and Stapleton School
8. Mary E. Stapleton School — elementary school on east side
of Elm Street
9. Edwards Church, United Church of Christ and .7onathon
House Childrens Center — church, parsonage and nursery
school on 45 Edwards Road, off of Maplewood Street
10. Boston Taivanese Church — next door to (south of)
Stapleton School, on Elm Street
11. Cameron Middle School — located on the east side of Elm
Street
Relocation. A relocation plan would be required for the affected
industries. Due to their need to locate at commercially-viable
sources of rock/quarrying material, it may be difficult to relocate
these businesses in close proximity to Boston.
Air quality . As discussed under land use, several occupied
residences are located within 500 feet of the site. Air quality
impacts to these residences could be mitigated by (1) reducing
traffic volumes and hours of operation for the site; and (2)
constructing the landfill with an adequate buffer distance from
residences. The truck traffic along residential sections of Old
Connecticut Path could have a moderate impact to the area’s air
quality. Additional data on existing traffic and air quality
conditions for the site vicinity are needed to confirm this
finding.
Transportation Noise . The residential neighborhood south and east
of the site would have a moderate to high impact from the truck
traffic to the site. Yet, the neighborhood is already exposed to
a moderate noise level from the gravel truck traffic. Noise
impacts to the neighborhood could be mitigated by restricting hours
of operation for the site and by carefully scheduling truck traffic
during the day to a maximum rate of 100 truck loads per day.
0 eration Noise . The landfill operations would have a moderate to
high impact, as some residences are located within 500 feet of the
present site. Impacts could be mitigated by constructing the
project landfill with an adequate visual and acoustical buffers
and maximum distance from these residences.
33
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xistoric . According to Massachusetts Historical conunission records,
one archaeological dig is located on the site. They have been
contacted to obtain additional information on the status and nature
of the site.
3.3.7 Spectacle Island capping
As mentioned previously, The M&E-recommended alternative would
limit the disposal of material at Spectacle Island to the minimum
amount required to adequately cap the historic landfill in
accordance with current state landfill closure regulations (see
Figure 2—2). This alternative would significantly decrease the
levels of impacts for all site categories, as the material to be
disposed of on the island would be reduced to approximately 6
percent of the MDPW proposal. In addition, no permanent subtidal
impacts would occur, and intertidal impacts would be limited to
rock dike construction. Accordingly, the level of impacts is
presumed to be acceptable.
Wetlands . Approximately 0.2 acres of coastal salt marsh may be
lost, and some permanent intertidal and temporary subtidal impacts
are likely with the M&E alternative.
Water quality . The construction activities could, as discussed
earlier, result in some short term increases in turbidity and
contaminant resuspension. However, the new landfill cap will
stabilize the existing landfill and reduce contaminant flows into
the harbor, resulting in a permanent positive benefits to the
area’s water quality.
Traffic . A small fraction of the MDPW barge traffic would be
expected to the site (approximately 450—500 total barge trips over
3-4 years). This is not expected to significantly affect current
Boston Harbor navigation conditions; much of the barge traffic
would be expected at night, when harbor commercial and recreational
use is lowest.
Land Use . As the island is presently not available for widespread
use as a park, the landfill cap will create a positive net benefit
in site land use activities; landfilling activities will not
significantly affect use of the island.
Relocation . As no industries or residences are presently on site,
no impacts are expected.
Air quality . Minor impacts due to truck and tow boat traffic are
possible, but are not expected to be significant increments to the
current existing conditions in the harbor.
TraneDortation NoiM . Barge loading and unloading operations will
generate some noise, and care will be required to mitigate noise
34
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at shore—side loading facilities. However, as mentioned earlier,
levels are significantly reduced from MDPW alternative. No
significant impacts to sensitive receptors are expected during
barge transport to Spectacle Island.
ODerations Noise . Island landfilling activities are not expected
to result in significant noise impacts, due to the distance to
sensitive receptors.
Historic Resources . According to MDPW, one potentially significant
cultural resource site exists on the south drumlin of the island.
It is likely that this site could be avoided, if not within the
area of historic landfill (as is expected). If it cannot be
avoided, data recovery efforts in accordance with Section 106 of
the National Historic Preservation Act would be undertaken to fully
mitigate the site.
3.3.8. supplemental Site xnvestigatiofls
Our most recent site investigations and review of available data
indicates that significant site constraints exist for the
Framingham—13 site. First, the relatively low traffic counts for
Old Connecticut Path and the number of sensitive receptors (schools
and residences) along portions of the access route could require
significant reductions in truck traffic volumes. In addition,
further consultation with the MWRA Water Division indicates that
landfill activities directly on the Sudbury Aqueduct would not be
permissible, and adjacent landfill work would have to be done under
stringent controls to ensure that landfill contaminants could not
infiltrate the aqueduct structure. Finally, although the site is
not within a Zone II recharge area, its proximity to the Zone II
area and existing, presently-unused water wells would also require
very stringent design and operational controls in order to protect
these resource areas. Thus, the MWRA staff contacted did not
encourage use of this site.
In view of this, we have conservatively assumed that the site may
not be available for use, due to these potential impacts and
limited storage capacity (1.0 mcy). Thus, the site has been
excluded from the following disposal site traffic analysis (Section
3.4).
3.4. Disposal site Traffic Projections
3.4.3. IntroductiOn and Assumptions
A component in the analysis of alternative sites for disposal of
excavated material is the determination of the total daily truck
traffic which would be directed to each site from the various
Central Artery project areas. The alternative disposal sites vary
in capacity and surrounding land-use character, and therefore,
there are differences as to the maximum daily truck traffic which
35
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could be allocated among the various alternative sites. In
addition, consideration is given to meeting the disposal needs of
the MDPW in terms of coordinating the geographic location of
disposal to the Central Artery project area of generations and also
assuring adequate disposal capacity during peak periods of
excavation. As noted above in section 3.3.8, the Framingham site
is not included in this analysis, as we have assumed for purposes
of this analysis that it may not be available for use.
The analysis consisted of five steps, which are described in more
detail below. In order to estimate the total daily truck traffic
to each site for each year of )1DPW excavation, the following
assumptions were made:
• In residential areas, an average of 100 trucks per day
would be allowed to access the site over a period of 8-
12 hours.
• At sites where direct access was available, thus
minimizing contact with residential areas, an average of
180 trucks would be allowed to access these sites for
periods of 8-16 hours per day.
• Total traffic volumes were based upon the use of 12 cubiC
yard (cy) trucks.
• Total material disposal volumes were calculated on 260
day per year operation.
3.4.2. MethodolOgy and Results
As noted above, the analysis consisted of the following five steps.
These are described below, along with summary results of the
analysis.
i. Determination of maximum excavated material quantities for the
alternative landfill sites
Data from the SEIS/R report were used to determine the amount of
excavated material which was intended for disposal at Spectacle
Island, and, therefore, would need to be deposited at the
alternative sites. However, it should be noted that there was a
discrepancy in the numbers reported for the total volumes of
excavate to be deposited at Spectacle Island. One reported volume
leaving the barge unloading facilities was 11.5 mcy, while the
other reported volume was 9.28 mcy of material going to Spectacle
Island. It is believed that the higher volume includes “new
material” which would have to be transported to the island, in
addition to the material actually excavated from the Central Artery
project. This new material may include rock riprap material, liner
material and topsoil for the landfill and containment structure to
36
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be constructed on the island. Therefore, the smaller number,
believed to represent the actual volume of material to be disposed,
was used for this analysis.
2. Determination of the maximum quantity of fill that could go to
each of the alternative sites.
As noted above in Section 1.2, the capacity of each of the
alternative sites was calculated utilizing USGS topographic mapping
and the results of field visits. The following disposal site
capacities are anticipated:
Rowe Quarry: 3.0 acy
Bates Quarry: 2.5 mcy
Logan Airport: 0.7 mcy
Weston Quarry: 2.0 mcy
Saugus/Meirose Quarry: 1.6 mcy
Spectacle Island: 0.6 mcy
3. Determination of the annual material volumes which would be
generated from each of the project sites.
These volumes were calculated based upon MDPW estimates of barge
loading facilities traffic data provided in Appendix 1, Chapter 9
of the SEIS/R (see Figure 3—6). The volumes used represent the
lower of the two volumes to be deposited at Spectacle Island cited
by MDPW (9.28 mcy versus 11.5 mcy). As the volumes to be moved from
individual barge loading facilities roughly correspond to specific
project excavation areas, the facilities totals can be generally
grouped into material destined for disposal north, south/west, and
east (to Spectacle Island or Logan Airport) of the project area.
4. Determination of the maximum daily truck volumes permitted for
each alternative site, and subsequent determination of the
maximum annual volumes of excavated material which could be
deposited at each site.
The maximum number of truck volumes permitted at each site was
based upon the character of the area in which the site was located.
If access to the site required travel through residential areas,
a maximum of 100 trucks (200 trips) per day was allowed. Therefore,
a maximum of 100 trucks per day was considered for the Weston site.
At the Rowe, Bates, and Saugus/Meirose Quarries, where access to
the sites from major roadways is relatively direct, and residential
areas are less impacted, an average of 180 trucks per day were
considered. The total for Bates Quarry assumes direct access from
Route 3. Logan Airport and Spectacle Island were considered
separately since the movement of materials to those locations would
primarily involve barging.
Total maximum annual volumes of materials which could be deposited
(using these rates) at each of the alternative sites were then
37
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TRUCK LOADS PER DAY FOR LAND DISPOSAL
TRUCK LOADS OF MATERIAL PER DAY
YEAR
Charles
Fort Dock #3 Bird Total
River
Point
island
1200
800
400
90
91 92 93 94 95 96 97 98 99
‘T i
p.
‘1
-------
a
calculated. The maximum annual volumes ranged from 300 acy at the
Weston site, to 562 mcy per year at the Rowe, Bates, and Saugus
sites.
5. Determination of anticipated daily truck trips based upon
disposal need for each of the planning period years, including
peak periods.
The SEIS/R and Figure 3—6 indicate that peak years for disposal
are expected to be 1992, 1993, and 1994. During that time period
it was assumed that several of the alternative sites would have to
be utilized at maximum rates to handle the peak excavation volumes.
A bar graph (see Figure 3-7) were prepared indicating the projected
need for disposal at each of the alternative sites over the
planning period. The disposal scenario is focused upon the need
to provide MDPW disposal sites to both the north and south/west,
and to utilize Spectacle Island and Logan Airport during peak
excavation periods when 3 shifts are underway.
In 1991, when the project excavation is beginning, two sites would
be designated to receive material. These two sites, Rowe and Bates
Quarries, would permit convenient disposal to both the north and
south of the project excavation areas. In 1992, the NDPW requires
greater disposal capacity. Thus, total volume deposited at Rowe
Quarry increases slightly. However, one additional northern site
(Saugus/Meirose Quarry) and one western site (Weston Quarry) are
also added. In 1993, the peak year for excavation activity, the
sites at Logan and Spectacle Island are added, thus providing
maximum disposal capacity for the peak excavation volumes. All
sites are again utilized in 1994. In 1995 and 1996, disposal of
excavate material may continue at the northern sites if the need
arises, however, as the bar chart shows, the disposal volumes can
be met by trucking the excavate to the southern and western sites.
It is important to note in 1993, when peak excavation volumes are
projected, excess material will have to go to a combination of
sites in order to accomodate these peak volumes. Material disposal
at spectacle Island and Logan Airport (chiefly by barge) is
maximized (assuming total combined capacity of 1.3 incy), and the
remaining volume (approximately .5 to .7 mcy) of material could
then be sent by rail to either the Weston or Rowe sites. If (1)
storage capacity at Spectacle or Logan is increased (by slight
increases in the height of these landfill areas); or (2) additional
material, beyond the 100,000 cubic yards proposed, can be used for
backfill (see Section 4.2), the rail scenario is unnecessary.
In summary, this disposal scenario can provide for peak excavation
volumes at traffic levels which can be accommodated at specific
sites. Additional traffic projections and documentation of
existing conditions at each disposal site (which could not be done
under our review time frame) would be necessary in order to refine
39
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PROJECTED DISPOSAL SITE TRAFFIC
TRUCKLOADS OF FILL PER DAY
YEAR
ROWE L2 J SAUGUS
I 1 WESTON
I ] SPEC/LOGAN
RAIL
400
300
200
100
0
91 92 93 94 95 96
BATES
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this analysis. Confirmation of final materials disposal volumes
(exclusive of project backfill and Spectacle Island capping) are
also needed to more accurately define the optimum disposal
scenario.
4.0. EvaluatiOn of Other Alternatives
4.1. Ocean Disposal
In order to determine the feasiblity of disposing of a portion
of the excavated material from the project, a study was conducted
by Bechtel/Parsons BrinckerhOff in February, 1990. This study,
summarized in their report on the potential for Fill Material to
Float, concludes that “...potentially floatable material exists
throughout the fill and that dumping this material would result in
unacceptable wood rafts and scum floating on the ocean, potentially
resulting in a hazard to navigation, significant fouling of the
beaches and an adverse impact on aquatic life and the fishing
industry” (Bechtel/Parsons BrinckerhOff, 1990b).
Review of this study indicates that the testing conducted on the
material was somewhat conservative, thereby overestimating the
floatability. One of the greatest limitations of the study was
the amount of material sampled and the testing methodology.
Samples were obtained from the borings or by excavating test pits
with a backhoe at selected locations along the alignment and the
floatability analyzed in small 16 oz. jars. In order to simulate
the handling of the material prior to disposal, (excavation,
loading onto trucks and barges, and transporting to the disposal
site), the samples were excessively separated, and dried. In
reality, many large clumps of material would be likely to remain
in contact and these clumps would sink more easily than the
separated grains. Very few clumps were present in the study
samples due in part to the small size selected for the samples.
In order to simulate the dumping of the material into 300 feet of
water, the samples were mixed with twice their volume of water in
jars. This test does not appear to accurately reproduce the
downward pull on the material that would result from the dumping
of material from a 1200 cubic yard capacity barge. It is likely
that many of the smaller constituents would be entrained in the
bulk of the dump. This effect would only partially apply to wood
pieces which could be cleaned of the attached soil during the 300
foot descent and would return to the water surface due to their
high buoyancy.
In addition, the determination of the floating volume fraction was
conducted by visual estimation of 5 judges. The accuracy of the
results is somewhat questionable since the results are generally
less than one percent. A more quantitative approach, used in
conjunction with larger sample volumes and larger dump depths,
41
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would have provided more accurate results.
However, despite the conservative nature of the tests, soil boring
data indicate that the fill material appears to contain significant
fractions of material that would be likely to float. This would
severely limit the volumes available for open ocean disposal. A
more realistic testing study would probably not significantly
change this general conclusion. It should also be noted that there
is presently no local approved ocean disposal site for excavated
materials; a complex and lengthy site designation process would be
necessary to allow use of such a site.
4.2. Suit&bility of Excavated Material for Project Backfill
We have conducted a qualitative evaluation of the character of the
materials and issues raised by the MDPW related to the handling and
re-use of these materials. In general, the MDPW analysis for re-
use of excavated materials concludes that the potential logistical
difficulties associated with re-use severely limits their options.
They have also made several simplifying assumptions to assess the
feasibility of re-use of excavated materials. In addition, there
is some inconsistency between statements made about the potential
for sorting materials for reuse, and the proposed action to dispose
100% of the excavated materials at Spectacle Island. These items
are discussed in greater detail below.
4.2.1. Character of Materials
The materials to be excavated within the project alignment have
been categorized by the MDPW into three general groups for
discussion. These are:
o Fill placed in former tidal or subtidal lands for land
reclamation
o Native soils lying at or below the ground surface prior
to reclamation
o Bedrock
The MDPW has further subdivided the native soils to distinguish
between the upper portions (characterized as very soft and
unworkable or mixed with elements of the fill), and lower portions
which are stiffer and free of contamination. They have
conservatively estimated that the quantity of native-mixed soils
is approximately 25% of the total native soil quantity to be
excavated.
Table 4—1 summariZes potential re-use options for each material
group expected to be found within the project alignment. Table 4-
2 presents the estimated quantity of each material group (as
42
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TABLE 41
POTENTIAL DISPOSAL OPTIONS FOR CA/T EXCAVATED MATERIALS
MATERIAL DISPOSAL/REUSE OPTION
Wood Compost, burn, wood chips
Brick Re—use (donate); crush and
use in backfill
Concrete Crush for aggregate or
backfill, roadway base, or
subbase
Asphalt Recycle, crush and use as
base course or improved
subbase
Leather Incinerate or landfill
Glass/Ceramic Crush and use in backfill,
recycle
Coal/Cinders/Ash Incinerate separable
quantities of coal,
landfill remainder
Organic Native Soils Compost, or landfill
Metals Scrap and recycle
NOTE: Available disposal options may be limited by potential
soil contamination within the project alignment
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TABLE 6-2
SIJITABILITY OF CAST EXCAVATED MATERIALS FOR BACKFILL
OUANTITY *
•.......ua.I
41% Sand & Gravel: 2.1 MC !
7% Wood: 0.46 NC!
8% Coal: 0.5 MCY
19% CinderAsh: 1.2 MC!
81. BrIck: 0.5 NC!
31. Ceric: 0.2 MC!
31. Glass: 0.2 MC !
51. Concrete: 0.3 MC!
3% Asphalt: 0.2 MC!
3% Leather: 0.2 MC!
1.15 MC!
Equals 25% of total
native soils expected
to be encoixitered
Equals 751. of the total
Native soils to be
encountered
1.6 MC !-
B. Boston
84000 C!-
Char lestoili
1.06 MC !-
CA/Nor.
0.8 NC!-
CAISou.
2.1 MC !-
Interchange
1.65 MC!-
S. Boot.
.6 MC! E.Bos
.45 MC ! CA-N
.95 MC! CA-S
.22 MC! 1-90
1.2 MC! S.Bos
from
T el
LANDF ILL
large piece.
of wood should
be incinerated.
Docie ientl state
that 901. of wood
removable. Would
rec ice excess
fill quantity 7%
Recoverable
concrete and
brick from
foundations, and
pavements should
be crushed and
reprocessed as
raw mater:als or
general filL.
UNSW TABLE
Difficult to
handle
SUITABILITY AS
ROAD EMBANKMENT
OR BASE
UNSUITABLE
Fill in B. Boot.
likely to be
suitable as
fill below frost
depth.
Must avoid use
of conpressible
and frost
susceptible soils
Sorted sand and
gravel may be
suitable as road
ei*ankment;
Quantity is
Indeterminant
from available
data.
UNSUITABLE
UNSUI TABLE
Frost susceptible
possibly
expensive
Will consolidate
after placement.
SUITABILITY AS
GENERAL BACKFILL
POOR TO FAIR
Represents current use
Fair if wood canbistibles
degradables & elasto-plastic
elements removed. RemainIng
brittle elements/glass
coeposites. cerunics are
crushed fine. Elements
mist be blended to uniform
consistency. May require
mixing virgin soil materials
to establish acceptable
gradation. Will require
an area for stockpiling.
sorting, and batching.
May be used above tirmel
structures If air rights
surface areas are restricted
to passive uses.
UNSUITABLE TO POOR
May be very difficult to
sort mixed Landfill elements
Difficult tO process.
POOR TO FAIR
DifficuLt to place
Thick deposit would be
siáject to considerable
settlement (likely
differential)
WHERE *
LOCATED
6.5 MC!
OPT IIIJS
DISPOSAL/REUSE
EXPECTED
DISPOSAL
SUITABILITY AS
FOUNDATION SOIL
(STRUCTURAL FILL)
LANDFILL
EXCAVATED
MATERIAL
TYPE
FILL- including
sand and gravel;
demolition materials;
abandoned tiaber
piers; refuse; coat &
cinder-ash
NATIVE-MIXED
NaturaLly occurring
soils (organic silt,
peat, outwash,
alluvitiii clay &
glacial till) which
are either fouled
by fill solids or
will be virtually
inseparable from fill
due to proposed
excavation methods
NATIVE-CLEAN
Remaining native
soils expected to be
encountered
UNSUI TABLE
Some zones, part
in E. Bost. may
be fairly clean
send & gravel.
This may be used
but probably won’t
be evident until
excavation
proceedes.
Quantity which may
suit a structural
filL would be very
limited- not more
than 11. of the
total excavation.
LANDFILL LANDFILL UNSUITABLE
3.45 MC!
ROCK 0.34 MC! Mostly
Harbor
LANDF ILL
CAPPING OR LINER
Reuse as trap
rock
LANDFILL
CAPPING
OR
LINER
Reuse In
rock
dike
- - GOd if processed
and unweathered
Good if processed
Wasteful
* As reported in MDPW SEIS/R
-------
reported by the MDPW) and their suitability for various re-use or
disposal options.
Most of the information related to the character of the soils to
be excavated has been obtained from the Soils Characterization
Report . prepared for the MDPW by Jason M. cortell Associates.
Cortell made approximately 130 borings within the project
alignment. The borings extended through the fill and into the
native soils. Samples removed from each boring were batched to
create a bulk sample representative of the soil column for each
material at each boring location. Testing was performed on the
bulk samples to evaluate the physical and chemical qualities of
these materials.
The fill consists primarily of fine to coarse sand with little
gravel and a trace of silt. Also detected within the fill was
wood, concrete, brick, asphalt, glass, coal and cinder, leather and
other refuse and demolition debris. The soil portion of the fill
is estimated to represent 41% of the total volume. The percentages
and quantities of the other fill constituents as estimated by the
MDPW are presented in Table 4—2.
It should be noted that the boring locations were not selected at
random. Borings were taken at sites that were currently or
formerly developed, especially by industry. Project-wide quantity
estimates made based upon the findings at these selected locations
are rough approximations. Additional soils testing would be needed
to confirm these estimated percentages.
Sieve analyses were performed on bulk samples of the fill from each
of 43 different borings. The report does not state whether the
bulk samples for testing contained appreciable quantities of non-
soil elements. The sieve analyses show that the fill materials
sampled had relatively low quantities of fines, with a maximum size
of between ½-inch and 1½ inches (typically 3/4-inch). On average,
the percent finer than the number 200 sieve (fines) was 3.5% by
weight. Of these 43 sieve tests, only two samples possessed fines
in excess of 10%, the maximum being 15.6%.
4.2.2. Suitability for Re—US C
Assuming these materials were relatively clear of degradable or
combustible elements, the sieve data suggests that the material
could qualify as “Ordinary Borrow” per Section Ml.0l.0 of the
Massachusetts Department of Public Works Standard Specifications
for Highways and Bridges. 1988 . As ordinary borrow, it would be
suitable for use in road embankments below frost depth. If the
soils contain minimal amounts of organic soil, they should be
suitable as general fill or backfill.
Chapter 4 of the SEIS/R states that “Most of the material.., cannot
be used for backfill because it lacks the necessary engineering
44
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characteristics required to stabilize the backfilled structures.”
In fact, backfill above buried structures would have little if any
impact upon the stability of the structures. Thus, use of the area
above the tunnels as an urban park would not impose very stringent
physical requirements or restrictions on fill usage. Based upon
the grain-size distributions presented in the soils report, the
fill material should not be subject to significant long-term
consolidation which prevent passive uses. In fact, the area would
require a roughly similar level of compaction and consolidation as
that which is presently proposed to prepare Spectacle Island as a
park. However, roadways or utility beds constructed in these
materials would require clean granular material within the frost
and bedding zones.
Structural fill placed below or along side of buried structures
will have a substantial impact upon the stability of the structure.
We concur that the excavated materials, by themselves, would not
be suitable for reuse as structural backfill in these areas. We
also concur with the MDPW that these materials would not be
suitable, by themselves, for support of “air rights” structures
above buried structures. Additional structural support (e.g.
beams, piles, or columns) would be necessary to provide suitable
foundations for buildings directly above the tunnels; these
supports could be tied directly into the support structures for the
tunnels. Because the decision for ultimate re—use of above—ground
areas within the project alignment has not been made, final
structural requirements are unknown.
The SEIS/R indicates that some of the fill constituents are
actually the remains of building foundations or marine wharves
which were abandoned or demolished and buried in place. The
document indicates that most of the wood which will be encountered
is either piles or intact logs, and that approximately 90% of the
wood is rather easily separable from the fill. The SEIS/R also
states that the MDPW plans to “process and reuse” excavated raw
materials including brick, concrete, asphalt and “high quality
granular materials.” However, none of these quantities are
reflected in the Proposed Action for landfilling at Spectacle
Island.
Of the 7.27 mcy of excavated materials destined for Spectacle
Island under the Proposed Action, approximately 1.2 mcy may be
separable wood, brick, concrete, asphalt, and “high quality”
granular materials. This figure is based on the stated MDPW 90%
recoverability of wood and 100,000 cubic yards of clean granular
fill located at Bird Island Flats, plus an estimated 75% of the
brick, concrete and asphalt quantities. The quantity of
recoverable granular soils could exceed the 100,000 cubic yards
included above, as this quantity estimate appears to have been
based upon the results of limited sampling.
The results of the borings indicate that the excavated material
46
-------
from certain zones within the project alignment may be too
contaminated with degradable or combustible materials to be sorted.
This is particularly true along the proposed Seaport Access Road
at the South Boston toll plaza and tunnel portal, and at the 1
90/1-93 interchange. These zones have particularly high
concentration of coal, cinders and ash which would be very
difficult to separate.
The MDPW’s assertion that the quantity of unsuitable, mixed-native
soils will equal 25% (or 1.2 mcy) of the total native soil
excavation cannot be evaluated, given present information. While
mixing has undoubtedly occurred within the soft organic soils and
harbor sediments, quantification is difficult. It is likely,
however, that the only fill elements which would have penetrated
deeply into the native soils (more than 3 feet) would be the more
massive and easily—recovered items such as wood piles, concrete or
brick. Therefore, the quantity of native soils which may be
suitable for uses such as for capping of landfills could be
increased slightly above current estimates. The very wet, soft
organic soils and peat, whether or not they are mixed with fill
elements, would clearly not be suitable backfill or capping
materials. Thus, the MDPW’s estimate, though conservative, may be
reasonable (from the standpoint of construction planning) for
assessing potential project impacts.
The remaining portion of the 9.3 mcy of material destined for
Spectacle Island under the Proposed Action includes approximately
1 million cy of dredged material which cannot be dumped at the
Massachusetts Bay Disposal site, aoo,ooo cubic yards of suitable
capping materials and 200,000 cubic yards of rock to be
incorporated into a shore protection dike. If additional material
can be sorted and separated for re-use as shown in Table 4—2, the
quantities for disposal, capping and dike construction at the
island can also be reduced somewhat.
4.2.3. Eandliug of Excavated Materials
Assuming that approximately 1.2 mcy (16%) of the excavated
materials may potentially be separated and reused, and an
undetermined quantity may be used as general fill or be disposed
away from Spectacle Island, there remain several issues which must
be considered. These include excavation methods, transport,
sorting, and stockpiling.
On page 4—24 of Chapter 4 of the SEIS/R, the MDPW indicates that
the materials cannot be easily separated:
“During the excavation process, substantial mixing of material
from the different geological strata is unavoidable because
of the construction methods. The excavation support systems
will consist primarily of struts that extend across the
excavation to support the exterior walls. The use of these
47
-------
struts will dictate methods of excavation that will cause more
mixing of the soil strata than would occur if a tieback system
were used to support the sidewalls. Unfortunately, a tieback
system will not be possible for most excavations because of
the character of soil strata and/or the close proximity of
adjacent properties.”
This statement is an example of where a conservative, though
common, scenario is used to make a projectwide generalization. In
fact, it seems likely that tieback systems could and will be used
on some portions of the project including East Boston and at the
1-90/1-93 Interchange.
The MDPW further states that the upper 10 to 15 feet of the
excavated materials will be removed by backhoe and dumped directly
into trucks. The backhoe is expected to cause substantial mixing
of the soils. While there is no doubt that portions of the work
will be excavated in this manner, backhoes may not be effective in
excavating areas which are characterized by bulky debris. It is
more than likely that large bucket front end loaders would be used
to the maximum practical extent, and that crane—mounted clamshells
will be used where bulky items must be picked from above the
excavation.
An alternative method of excavation could also be used. The
contractor would begin the excavation by “stripping,” using
bulldozers, loaders, or scrapers. The excavation would proceed as
deeply as possible with this type of equipment before the first
level of struts are constructed. For a relatively narrow
excavation of 30 feet or less, stripping might continue to a depth
of four or five feet. This which would permit relatively clean
removal of pavements and base materials. For wider excavations,
deeper stripping may be possible after subsurface utilities are
relocated. As proposed by the MDPW, trapezoidal trenches at the
bottom of relatively deep and wide excavations may allow access to
the lower depths by track-mounted equipment. If stripping methods
are utilized to the greatest practical extent, mixing of the
general fill soils and the native soils caused by excavation
methods should only result at the interface between these strata
or where piles and concrete foundations must be removed from native
soils.
Perhaps the most significant concern for re—use of project
materials involves the logistics of transporting, sorting and
stockpiling excavated soils, due to the lack of available land area
and increased labor requirements. If rough sorting of reusable
elements from excavated materials at the project sites is required,
several trucks will need to stand by the excavation site to receive
the separated materials. These trucks must be available to go
directly to processing or stockpiling sites with the sorted
materials. Additional laborers and equipment would be needed at
these sites.
48
-------
Rail transport is one possible option for removal of excavated
material. The MDPW has stated that some portion of the borrow
materials which they expect to use for backfill will be transported
to the project area by rail. Although excavated materials could
also be transported by rail away from the project site, this may
slow the rate of construction progress and add a significant cost.
There will clearly be some lag time between peak excavation and
backfillirlg activities, requiring either (1) interim storage and
cleaning of railcars; or (2) excess railcar storage capacity. It
may also be difficult to locate project borrow locations that have
the capacity (at least 25-30 acres) to accept, stockpile and
process excavated materials over possibly 2-3 years.
Transport of excess excavated materials by rail to other project
designated disposal locations (e.g. Rowe Quarry or Weston Quarry)
is also potentially feasible, but would also require additional
railcars, handling equipment and personnel at disposal site.
Portions of the site which are lined, but not yet filled would
likely be needed for storage and processing of materials. This
option could, however, reduce truck traffic impacts for disposal
sites.
For processing, areas would be required for dumping incoming
materials, separating rough sorted materials into like piles for
processing, and for storing processed materials. It may also be
necessary to perform some very fine storing of like materials such
as creosoted and uncreosoted wood, or different brick composites.
While some initial processing is possible within the project
alignment (to remove large elements such as timber and
pavement/Concrete rubble), any additional screening and processing
facilities would be more feasible at off—site areas.
In conclusion, logistical and handling difficulties may be a
greater obstacle to re-use of the excavated material than the
physical suitability of the materials for backfill or other uses.
49
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REPERENCES
Bechtel Civil, Inc. 1989. HydrodynamiC Circulation and Contaminant
Transport Study for Alternative Spectacle Island
Configurations. Boston, MA
Bechtel/Parsons Brinckerhoff, 1990a. Central Artery (1-93)1 Third
Harbor Tunnel (1—90) Aquatic Resources Functions and Values
Volume I: Roadway, Tunnel and Bridge ALternatives Assessment.
Boston, MA
Bechtel/Parsons Brinckerhoff, l990b. Central Artery (1—93)1 Third
Harbor Tunnel (1—90) Potential for Material to Float. Boston,
MA.
Bechtel/Parsons Brinckerhoff, 1990c. Central Artery (1—93)1 Third
Harbor Tunnel (1—90) spectacle Island Numerical Modelling
Studies of Water Quality Impacts in Boston Harbor. Boston,
MA.
Bechtel/Parsons Brinckerhoff, 1990d. Central Artery (1—93)1 Third
Harbor Tunnel (1-90) The Aquatic Resources of spectacle
Island. Boston, MA
Bechtel/Parsons BrinckerhOff, 1990e. Defining the Quality of
Excavated and Dredged Material form the Central Artery (1-93)1
Third Harbor Tunnel (1-90) Project. Boston, MA
Bechtel! Parsons Brinckerhoff, 1989. Central Artery (1—93)1 Third
Harbor Tunnel (1-90) Material Disposal Site Screening Report.
Boston, MA.
Central Transportation Planning Staff (CTPS), 1990. Personal
Communication, telephone conversation between I. HarringtOn, CTPS
and B. Shreve, Metcalf & Eddy, 24 July, 1990.
Cortell, Jason M. and Associates, 1988. Central Artery (I-
93)/Third Harbor Tunnel (1-90) Disposal Site Screening Dredged
and Excavated Material. Waltham, MA
I 4 Associates, 1989. Geophysical and Soil Gas Survey of Spectacle
Island. Report prepared for Massachusetts Department of
Public Works central Artery (1-93)/Third Harbor Tunnel (1—90)
Project. concord, MA.
Massachusetts Department of Public Works and Federal Highway
AdministratiOn, 1990. Draft Supplement Environmental Impact
Statement. central Artery(I—93) \Third Harbor Tunnel (1-90)
Project. Boston, MA
Massachusetts Department of Public Works (MDPW), 1990. Personal
Communication, between Ken Scott, XDPW Traffic Division and
Betsy Shreve, Metcalf & Eddy, mc, 23 July, 1990.
-------
United States Army Corps of Engineers, 1986. Mitigation Plan for
Development of Wilmington Harbor South Dredged Material
Disposal Area. Philadelphia, PA
United States Army Corps of Engineers, 1985. Final Environmental
Impact Statement; Wilmington Harbor Federal Navigation Project
Dredged Material Disposal Area. Philadelphia, PA
United States Department of Transportation, Federal Highway
Administration and Maryland Department of Transportation State
Highway Administration, Interstate Division for Baltimore
City, 1978. Environmental Impact Statement Supplement:
Preliminary Section 4(f) Statements Report No. FIMA-MD-EIS-
74—02-03—04—D—S. Interstate Route 83 in Baltimore City from
Gay Street to 1-95. Baltimore, MD
United States Department of Transportation Federal Highway
Administration and Maryland Department of Transportation State
Highway Administration, Interstate Division for Baltimore
City, 1978. Environmental Impact Statement Supplement Report
No. FIThFA-MD-EIS -79-03 -D. Interstate Route 95 in Baltimore
City Fort McHenry Tunnel Dredge-Disposal Program. Baltimore,
MD.
United States Department of Transportation Federal Highway
Administration and Maryland Department of Transportation State
Highway Administration, Interstate Division for Baltimore
City, 1978. Environmental Impact Statement Supplement Report
No. FHWA-MD-EIS-79-03-F. Interstate Route 95 in Baltimore
City Fort McHenry Tunnel Dredge-Disposal Program. Baltimore,
MD.
U.S. Environmental Protection Agency, 1988. Analysis of Risks from
Consumption of Quincy Bay Fish and Shellfish. Task IV Report
prepared for EPA Region 1 by Metcalf & Eddy, Inc. under
contract #68-02—4357, Boston, MA.
Vanasse, Hangen, Brustlin, Inc. 1989. Environmental Impact Report
for the Southwood Pointe Development, Hingham, Massachusetts.
EOEA File #5673. Boston, MA.
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APPENDIX A
ALTERNATIVE 8ITE SCREENING MThLYSIS
-------
APPENDIX A
ALTER2(ATIVE SITE SCREENING PROCESS
As discussed in Section 3.2, a systematic screening analysis was
conducted in several phases to identify potential materials
disposal sites. The first phase involved review of SEIS/R
finalist sites. Of the 4 upland sites considered, two sites, (Rowe
Quarry and Bates Quarry) were considered potentially feasible,
based upon review of available information and results of field
visits.
The second phase involved a summary level review of the !4DPW/MWRA
database files to identify other suitable sites which had not been
screened out of the SEIS/R. The attached Table A—i, which was
provided by MDPW to the interagency working group in Spring, 1990,
was reviewed to identify potentially feasible sites. The criteria
which we used to select the most promising sites (which could be
analyzed in the time available) were size, proximity to the project
site, and amount of upland acreage (as documented by MDPW). This
process identified 17 sites which appeared to warrant further
detailed investigation.
The third phase involved a detailed evaluation and review of the
MDPW/MWRA site data files in order to gather specific background
information on the 17 selected sites. Following this review, 7
sites were subjectively selected for more rigorous analysis, based
upon a number of factors, including capacity, present land use,
wetland type and acreage on site, access, and surrounding
development. These 7 sites were visited by a team of M&E planners
and biologists. One site, Framingham—l3, was retained for
consideration as a result of this more detailed analysis. The
results of this initial screening, and reasons for our initial and
final recommendations on all 17 sites are summarized in Table A-2
(attached).
The final phase involved (1) detailed review and field visits of
some additional sites (outside the MWRA service area) identified
by the Army Corps of Engineers; and (2) evaluation of these new
sites (not considered by MDPW) in accordance with the Massachusetts
Department of Environmental protection (DEP) Solid Waste Landfill
siting criteria (as stated in 310 C1’ Part 16). A summary of the
results of this review is provided in Table A-3 (attached).
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TABLE A-i
INTERAGENCY WORXING GROUP SITE LIST
-------
lot Wator Cj,iarily
I &S Uiaii total lbr,u,i rn tint (ml I 1!. .) Av.i ii
0
ito ohm
Silo icr Cor is
lliilaliiii mcijt Ii g ltiin ii ks
Sito Iocatia
—— Aa 1EA(L Mixiniie lltACllCA8lt I IY 1281 I1IIIA
Fill
CosIsI Av.ili
I i jl 1 k. hi Ii.
t,’i . ..., , - i$_
— I —‘. cc
Jii’ ’ I J
( .Stil e
•S (r\
1 ’4
$1 4 (.”%k •.l(.
&D-08
Biller ica
98
18
78
2 lU
X
o
VA lk p. sowago disposal plant, Sprgs Brk Plc.
&D-09
Blllerica
124
26
98
32(10
B I 1H-04
6 1 1 8-05
Blue Hills
Blue lulls
20
28
18
0
2
26
0 000
0 339
X
0
Orlvo-ln thoatro; tuildlr s
6118-09
Blue HIlls
V
10
12
0.028
X
0
9010 1 site ocx iedby resI kwelcq ioit
6118-12
61119 Hills
206
10
196
8 9130
.
6118-14
Blue lulls
196
$51
39
0.768
CAN-(fl
Blue hIlls
24
11
13
0 010
CAN 04
Blue hIlls
1?
0
12
0028
X
0
Ibm ollla tiJlldlntjs ow y site
CAN-08
BlueHills
36
35
1
0000
CAI I-09
Blue Hills
53
18
35 0620
CAI I-12
Blue lulls
124
0
124
4.7(N)
CAN- 13
Blue hIlls
88
60
128
4 900
CAi4-14
Bluehlllis
79
21
58
1.149
N
CAN-lB
Blue Hills
188
1
185
8.1110
N
o
state IE pltal sthaol
CAN-i?
Blue 111115
445
381
64
I. $10
N
1 CAN-20
IIB-Ol
Blue 11111$
Blue Hills
213
6
15
0
198
6
8.9110
0.000
N
N
0
PcsIcapog Golf corse
Site dlIuGla are helm the ulni a reqilred.
111-02
Blue Hills
14
0
14
0.060
N
Site dlmonsIcr are belcis the ilnl .a rerp lred.
11B-lfl
Blue Hills
11
0
11
0.018
N
fl
0ixi Ied by ri coimierclal/lrdastrlal blc s.
116-04
Blue HIlls
34
5
29
0.427
N
0
SIte oci. led by res’l development
116-05
Blue HIlls
I l
6
11
0018
N
Site dlmmsia are bek i the minima ropilred.
116-07
BlueHills
23
13
10
0009
x
116-08
Blue HIlls
26
0
26
0.339
N
C ,
Oruplod by hog, rec. facilities of 1K SctUoI
116-09
Blue HIlls
50
ii
39
0.758
N
116-10
Blue Hills
106
1
98
3 159
N
M IL-0i
Blue hIlls
449
42
401
210110
N
o
kwin ai otvaIlen aroa;rosl abjts;iisod for fec.
UlL ..02
Blue lulls
3)9
$9
287
14.000
N
MIL-03
Blue HIlls
4200
64$
3559
205 ( X l)
N
o
Blue lulls Reservatlen; 13 historIc sites
NAT-02
Blue Hills
31
31
0191)
N
jj:)
(l jT:U8—
Blue lulls
Bltio hills
148
523
5
143
523
6 (I II
27 lI
X
I
N
hiazaukus wasto sIte; actIve parlclarKi . : I’
filename HEM. 1Sf 11(1 (04-Apr-91) ) Page I
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A1i 1FA( M.ixi.iia lUACIICABIIIIY (ItlitHiA
Fill Situ cli i i
loI.Wa ter Capacity Costs/ Avail. Site per Corps
Site Location L S Oiad Total Rosftlross Net (mu CYs) Avail. Logistics Teth. Rutalnud mcutuiwj Remarks
NAN-Ui Biiio lulls lti U 6 U 310 X
RAN-02 Blue Hills 66 IS 5% 1. 100 X
RAN- U I Blue Hills 62 46 16 0.080 X
STD-03 Blue hIlls 48 14 34 0 585 x
S10 -04 Blue 111115 114 II 103 3.200
STO-OS Blue Hills 382 33 349 17.800
Sb-OS Blue Hills 187 38 149 6.200 x
BUS-Cl Boston North 6 0 6 0.01)0 X o (ko ied by inthstrlal use
8 0 5-09 BostonNcwth 8 0 S (0005 X 0 0ix iedby Inctistriai use
805-10 Boston North IS 0 ii o. in x o Ocavled by co rclai and lrüistrial uses
DIA-Ol Boston North 9 0 9 4.005 X Site dImer ior are belmi sin req’d; Site NA •L.tAi’ “i’
alA-el Boston North 4 0 4 0.000 X Site dImsr icos and small size
a lt-UI Boston North 18 0 18 0. 172 * o Ooaiiled by conmercial and lrdistr lal uses
DIA- 05 Boston North 8 0 5 4005 ... ..t ’
alt-O S Boston North 15 0 18 0. In X Site dhm loem and small sizi . . .
Dlt-07 Boston North I? 0 12 0.028 X o &opled by irdistrisi uses
a lt-CS Boston North 10 0 10 0.009 X o Site Is o 10ued by Ryans Piay an1
alt-OS Boston North 53 0 51 1.128 i D arlesteml Navy Yd, hist sites. com.’rosl uses
alt-la Boston North 5 0 5 0.000 I o (kxivied by inWstrlai use . , I .. .tt
Boston North 4 0 4 0.000 I Site dlmer i al 1 mali size i JKc 1 - ( • .
DE-OS Boston North 4 0 4 0.000 I a (copied by IMistrial use
DE- 06 Boston North 8 0 8 0.000 I a Oco.pled by oil t rks
QE- 08 Boston North 18 0 18 0.172 1 Site dumormions and small size
(1E-09 Boston North 5 0 5 0.000 I Site dImer ia and small size
DE-lO Boston North S 0 8 c.005 I Site diaor ior and small size
Boston North 11 0 11 0.018 1 o 0cu. lod by resi uses
DE-13 Boston North II 0 II 0.053 I Site dIwisla and small size
(iE-14 Boston North 91 0 91 2.286 I o US Naval Ibepital
IVR-01 Boston North 10 0 10 0.009 1 o Con ieteiy conpied by Irdistrial uses
EVR-O4 Boston North 23 0 20 0.165 I 0 PartIally ocopied by liii. usos,rest is wetlands
EVR -05 Boston North 20 0 29 0.421 1 ilazarckus waste site (. L 1 i’ tJ co - _ jL ..t,j K
EvR-O6 Boston North 19 0 19 0 113 X o Boston Edison guser plant; piaygrcirid
Fiio’iame:NENLiSJ.*l (04-Apr-90 ) Pa 2
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ACREA ( Ilaxinuu PRACTICABILITY (flhlEfliA
liii — - ———- Site clue
lol.Nator Capacity Costsf Avail. Silo per Corps
Site Location t SOiad Total Resciurces Not (eli CYs) Avail. Logistics Tech. Rotalned meeting Remarks
FVR-01 Boston North, 28 0 28 0 i’ll 1 o Oai*jled by irthstrlal uses
1 1*1-01 Boston North 41 41 I fl! d) x
1 (0-Oh Boston North 21 0 21 0.191 1 Small size
lEO-rn Boston North 31 3) I 0.0(X) I o coon, resi, irdistrial Uses; 75Z metia,ils
1(0-0? Boston North 3158 902 2257 129.000 X 0 Nldsex Fells Reservation; nc/eater muily; 3 hlst
1(1-04 Boston North 169 12 IS? 6.500 I o Mt. Ikod Memorial Park: goI isrse
1 ( 1-05 Boston North 65 12 53 I. 128 I o Pine Barks Park
1(1-06 Boston North 98 9 89 2.790 1 o golf oalrso/hxultry chit wil rosl devokpmnt
1 (L-O7 BostonNorth 48 3 45 0900 I o Parkandpm d
RIV-01 Boston North 10 4 6 0.000
REV-02 Boston North IS 3 12 0.020 1 o Comorcial dovelqiient
PLY-UI Boston North 10 0 10 9.000 I o Cemnercial doveiqinont
RE V-OS Boston North 145 145 0’ 0.0(1)
J4-0t Boston North 8 0 8 c.0( I o Counercial dovelqiient
J1-O 2 oston North lO g 0 109 3.800 I 0 MystIc 8. Reservation; rac USeS; ftrmol StadiLa
Sf1 .0 1 Boston North 82 0 82 2.480 I 0 golf ur’se/resldontlaI developmmt
STN-02 Boston North 35 0 35 0.620 I o Boar Hill Golf Cc .rse
IAX-W Boston North 598 78 520 21.700 I o Breakheart Res;rec and wervaticn iand;piier lines
80 5-04 Boston Saith 8 0 8 0AI 1 o 0r. ied by lndistrlal uses
605-08 Boston Smith 5 0 5 0.0(10 I o Site is a pier.
Boston Saith 8 0 8 0AI I o Ocnpled by inctistrial use/Boston Edison
BUS -il Boston Smith 10 0 10 0.090 1 0 VA Ibspltai en site
BOS-17 Boston Scuth 12 0 12 0.028 I 0 SIte oonjiled by inthstriai uses
605-13 Boston Smith 22 0 22 0.230 I
60 5-15 Boston Scuth 16 0 18 0.084 1 Site dImer ici are 1 )oion the ainluigu reijIlred.
BUS-lB Boston Smith 19 0 19 0.143 I 0 laterfront site; piers
BUS-i? Boston &uth 24 0 24 0.289 1 o 0ca lod:E0lC, md. and coin. U ; eaten rent site
805-18 Boston Scuth 17 0 Il 0.1(1) 1 o Waterfront site; Pan Pier
805—19 Boston Saith 19 0 19 0. 143 I
805-20 Boston So th 68 28 40 0.780 1 o Back Bay Fons Park
( ) Boston Smith 150 10 140 5.911) 1
- Boston Smith 268 II 254 12 000 I o Frar*iin lic;atuts Shattuck State lbsp ,goiI , rso area
Fliename:N [ M.lST.N(i (04-Apr-90 ) Page 3
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Uaxiniu IRACIICABILIIY 001 lERlA
HIP - ——— Site cl i.
lot.Watcr Capacity Costs/ Avail Silo per Coips
Site tocatien LEGS Wad Total Reswrcos Net (mit Crs) Avail LogIstIcs ledi fletai,w d nw etiiq Remarks
Boston Saith 50 0 50 I 160 x
805-28 Boston Scilth 143 61 82 2.218 X o Actively used (or othcation ar* recreation
805-29 Boston Swth 10 0 10 0 009 X Site dlmoi la wil small size
B OS-3 1) Boston SOJLh 13 0 13 0.040 X Site dimensions ajil small sIze
80 5-31 Boston Saith lOS 0 105 3. 1(1) X Not available; Cuiley ler.lnai ri .’s/ L&i .aL jiv iu. t 11 i’A
805-32 Boston Scaith 32 0 32 0.520
QJi-03 Boston Swth 44 21 23 0.250
RB-U Brodctm 139 79 60 1.550 I
S10-07 Orodcton 204 37 161 7.0(I) I 0 Tom cuiservatlon area; resl ab.its; usod for rec.
8 (0-06 Cuurd 53 21 26 0.339 I
— 8(0-10 Cciuxd 183 35 148 6. TOO
8 (0-Il Couwd 609 40 569 30.540 1 o AIrFor Base
IU.-01 Cauwd 212 10 202 9.0(X) 1
LEX-Ol Caurd 27 8 19 0.140
LEX-02 Co d 76 42 34 0.511
1 ( 1 -01 Cau rd 98 8 90 2.800 I o Pine Ueadoiis Camtry Ckt aM golf crurse
1(1-08 Cuu rd 50 9 42 0.840 I Conmmrclai uses on site (1 4 .LLI f O
1(1-06 C rd 32 0 32 0 520 I o ( xa ied by park, historic area
LEX-TO Caicud 64 64 1.7(X) I o largo bi . In ainter of site usod as a retreat
STO-08 Coiooud 34 34 0.585 I
AS 1$-01 Fra.lrç$ia. 8 0 8 0.000 I o (kzs,lod by active recreation usos
A9$-02 rruiri paa 22 21 0 0.000 I 0 (bipiod by 9 thny River
A (-O4 Fraainçpa. 23 0 23 0.200 I Somo residential dNeiq mont on site; small size
Fra.i iam 35 I 34 0581 I
A l-06 rra.in(jia. 30 20 II 0(11 ) I Site diuu’ ions are boise tie uini rerpjired.
ASH-lI) Fraei a. 80 0 80 2.390 I o BOX is r irvoir; rest 9Jrrozds A iiard Ros. Plo. 2
ASH-b Fraain a. 65 I 65 1.7(X)
A9 1-13 Fruirirjias 22 19 3 0 000
ASH-lB Framlr iai 130 10 120 4 (1)0 1 o NYAN7A irir(iud silo
Sit- Framir ’iau 181 8 119 8 000 I
& Framii tias 108 2 109 3.200 I o Belmont Ccn try Ci i i, aM golf ures
FP.A-01 Framin aa 941 894 47 1.( 0 I o Cothituato State Pk;Lake,tiE reservoir;? hist sites
Fiionamo:N(M.iSf.M(I (04-Apr-90 ) Pago 4
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AIJEA& Maxin a PHACIICA8IL 1IY D li IERIA
Fill •———-——————---——--—— Silo eUrn
lot Viater Capacity Costs/ Avail. Silo r Corps
Silo ti atl LEGS (kiad lotai Resaurces Not (iii CYs) Avail, logistics lech Retained meeting Ile ilarks
FRA-W FraJuIriç iarn 14 0 14 0A 3 X o ithJry River; (kx led by park and piay ’ci.nl
FRA-66 Fraaln iaa 21 I 26 0.339 X o Conwucla l use; p er Ilr s tlrw( site
IRA-07 Frarnin iarn 11 0 11 0.018 X o 0ea ied by park uses
FRA-08 Framir4iaa 34 29 5 0.001) X
FraaIn aa 29 7 22 0.230 X o Irdistrial uses;Deaver Darn &Odc;9J(tlry aaieijct
IRA-li FramIru aa 12 1 11 0.020 X Site dimonsiom are belay tt mlnhui reqjired.
I -12 FraaIr ai 82 24 58 1.148 X
RA—1 1raaI, aa flU 1 102 3.000 X
- 4 Fra in $ ai 28 0 28 0.391 X o Frarnin iarn State Qil logo
F - 5 FraiirU aa 111 0 iii 3.800 X o Framin parn State Ib! .;BarierI (les. School
RA-IBj Frarnin aa lii 5 166 7.000 X
Ibiliston 24 0 24 0.280 X o Fully dovekvod wiht rosl ard rx nrnmrcIaI uses
*9 1-08 ibilIslon 51 3 48 1.085 1
A9$-12 Ib lliston 50 4 48 1.180 1
A9i-16 Ibiliston 114 4 110- 3.800
* 5 1 1 —11 lbiiistai 425 236 189 8.500 I 0 A lar!I State Park; reservoir in cmter of site
*91-21 IbilIston 186 74 112 3.900 1
A 5 11-fl ibiliston 125 125 4.800 I excluding pipeilrma6Se mt
605—24 lUll 184 3 181 8.000 I o Om.vled by Loog lsiar 1 IbepItaI park uses
B OS-25 iL ill Ti 0 71 2.220 I
605-26 liii I 179 2 Ill 1.500 I o &u iod by sewage treatmt plant
805-27 11.111 35 8 21 0.368 I o Boston harbor lslari State Park; historic site
H IN-02 Itili 14 0 14 0.053 I .- np Site dim lom bela, the ulnI.uu ret)jlr J. ‘ • ‘ ‘
(JJ 1-01 lUll 6 0 6 0000 I o Octwlodby Intlistrial uses
O Il -02 11,1 I 15 I 14 0 (fio I Sito dIun slaG bolai tbo mInlumn reciulrod.’ a,.’.’ ( L I’ “• ‘t
UJi-OS 1 1 111 87 15 71 2.050 I
Wl-00 lUll 50 0 50 1.180 I 0 Ocailodby sewage treatmont facilities
00 1-10 liii I 13 0 13 0 040 I 0 0cii xJ by sewage disposal plant
PitY-OS hill 24 0 24 0 280 I o rnt1 lkutu’Ial State Paik
ItT- 06 1111 I 26 0 26 0 338 I a Fully aPilNI mliii resldrntlal usoc
P IIP-14 lUll 616 4!€ , 120 4.800 I
AJ(-01 Lexington 21 5 22 0.230 I Site dlmnislom belew •lnluiuu ruxplred. i..., J • .111
Fli&iamo:HEWuiSl IKI (04-Apr-90 ) Page 5
-------
A(’JU All Ilixl iua IRACI ICAIIII I If (‘Ill llI
Fill -———- — Silo oil.
lot.Water Capacity Costs! Avail Silo per Corps
Site Locatuti ( GS Giad total Resaircos Net (eli CYs) AvdIl. logistics leeii iletained mectiiij Remaiks
&004 LoxiogUn 9 I 2 0 (11) I o Cost puI ibltive (110 to small size
B [ L-02 1exlrijta 16 9 7 ‘ 0 (115 I o Cost prohibitive die to small size
D l i 03 loxis jtai 19 6 Ii 0 040 1 o Iloavur Wcdc Rosorvatirn
NI 04 I oxiiçjiri, (19 7 81 2 ku I 0 Hii lduit lal u os; Bolluit 11111 uiitry ckdi
&L-O5 texIi jku 8? .13 4 ) I 121) 1
B [ L-06 Lexlr!Jtm 205 8 197 8. XX) I o iUoanibsoltal; water tcwier at cmter of site
8F )-O2 Lexirçtcn 1W 3 115 4.500 I Brodcllm Coil w rse afli Ca, try Club ‘ ‘
8111-02 Lexlr tai 65 24 II 0.825 I
0111-rn Lexlr jUii 259 13 246 11.900 I
CAM-Ol Lexirçtm 41 41 0 0.825 I
FPA-I0 Lexirçtm 31 37 0.689 I I
111-03 Lexlngtm 39 9 39 0 452 1 IIjtrgxlitan State ikispital t+’ ’ t
tU-04 Lexlr jtm 225 1.15 90 2.800 I
111-05 Lexlr ta 108 21 81 2.800 I
LU -06 texliçton 91 11) 87 2.NX) 1 o kim ai orvatlm area - t) t
NIT-02 Lexlrçtcn 151 2 143 6.160 I Sdiriol m site. .. ,, I ,(...I . (
WL1-04 Lexlrgtcn 34 0 34 0.588 x
N. -05 Lexirigtm 29 0 29 0.425 1 o Ikiss Coi logo of A lu iture
T Lexlogton 227 52 115 1.&U I . ‘t
Lexlrçttn 132 9 123 4.800 I o Storer Cooservatiai; historic sites:aWts Raitha. US
*1-10 Loxirçtm 169 I l 152 8 211) I o flCA caip arxJ biiidi ; resld tiai dovolroiiont
ti-il LexIngton 74 0 74 2.100 I
LexIngton 140 9 131 5 000 1 o IDnohoster CQmtry ClL1
LexIngton 234 33 196 8.800 I
a P t- I l ) LexIngton 58 3 53 1.250 1
LexIngton 10 I 9 cOOS I Site dlmi1 ki10 bekim tha emma rewired.
LexIngton 29 0 29 0.425 I
Lexington 37 II 26 0.338 I
100-01 Lexington 9 1 2 0.1 11) I o Ikist of site oixwled t cuiimrcial use
Lexington 60 fl 38 0.720 I
U-ID Lexington 169 23 146 5.900 1
1 (8-12 Lexington 411) 213 241 11.911) I o ikE ani ca orvatlm aroa; iximor linos
Flionamo.tlEWl.iSI *1 (04-Apr-90 ) Pago 6
-------
AflU A(iI liii iuuin 111*1 I l(.AllIi liv iiii iiu
Fill - — -_ Situ cliii
lot Watos Capacity Costs/ Avail. Situ pcr Corps
Site Locatim USGS Qiad lotal I%escxirces Not (liii CYs) Avail logistics Tech lictalnud meeting Remarks
(TN (ii (vi i i (UI (1 101 .1 l iii X o Q maiii(acturiiij plant; rail yards
[ TN 0? [ yin 81 10 II 2/40 X t i’ Iti iclpal lai iJllIl; waslemater treatuwiil
REV 06 lyini 76 8 68 I 810 X !)uIfnIk l1ain Rai track
REV 07 (yin 3? I 31 1)411 X u Wiatrlaiij dog track arii parkliij . ,— —
WINO? lyi n 24 a 2 0 (U) X C) 11P ltrdcipal larilfili (M?(4 h —
WIN-(13 Lyrn 41 45 2 0 (1110 11 o kim park with lintirop GolI Coirso
WLP-00 Mar lloid 84 6 18 2.300 11
A I-1l Marlboiwcp 86 1 85 2600 11
A I-23 lIar IbIbolfl 646 210 316 19 (0) 11 o Ikikintosi State Park; reservoIr; 3 historic sites
MP-l0 lIodlield 124 84 40 0 190 11
MP- 13 l lodf told 291 62 229 10 800 X o lIP lar fllll siting cr11.
MP-15 Modlield 589 64 525 28(1110 X o lip laiuilill siting alt.
NAT-Ol Nat ldc 10 0 10 0 0(11) 11 Uhiubia-is tiolcm •in r 9 qd; duvoI nd osi site ZJ.%
NAT-a) Na(Idc 25 0 25 0.310 11 Natiosial Qiard ai site1 (f4 )- , ..J 4_ •. /c. • 1
NAI-04 HatIck 45 2 43 0.000 11 C) Army Base m site .°. -4 — ..( ciI i
NA1-1 Hatldc 75 2 13. 2. 111)
NAI-06 Natidc 65 I 64 I 1 (1) X
( j ) Nat ldc 224 2 223 10.500 X
NAT-( Natidc 1)3 0 113 4.000 11
t(1)-02 Natldc Ill I (16 4.100 11
1E ) Natlclc 212 115 157 6. 110 11
t(D-06 Natick 19 (4 65 1.150 X
Hat ick 160 29 131 !i 000 x
(I-a) Natidc 22 0 22 0 2(0 11 () Silo dIuu siu’is bolos, ttw •Inhuu. ioipilrod 1 j i(U
WEL-ol Nat idc 99 0 99 3.2111) 11 v•. /L. lj I .lfr.A
Nat idc 125 22 104 3.3)0 11 IoiiosieyCantryCkl) .
Hatlcic 163 (30 33 0540 11 0 Stony Brodc Rusorvolr ,
80001 Hosutai 65 0 65 1115 11 (%,../)cf4I’.k /
800-00 Hositosi 134 1 121 4800 11 BrMcIi00 l’(xirso au Coritry CItd ic. ’ / ‘J ‘ .
80004 Hositm 19 0 19 0 143 11 Silo dhunshcms bolos, llu minima roipilrod
Nosilosi 149 5 144 5.000 11
P L O 01 Hmtai 4!fl 2.19 254 121 (11) 11 o Qitlor Park. boidurs aias. R.; hI p yield aajii(er
Filonaee:N(M.ISI.Vl(1 (04-Apr-90 ) Page 7
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M,ixluun IItACIICAiIII I IT all uiii
Fill -—————-- Site cli i i
IotJater Capacity Costs/ Avali. Silo per Corps
Site Locatlcn LEGS Wad total Reswrcos Not (eli CYs) Avail. logistics lech lietaliwNi meotlig Ilrinatks
r) r” 14• • ’•• 1’ •‘, 1 ” ,U v 91 ‘i
NED ) Ncwtai Ill I ? lO S 3200 X — •\ i/.
P 1 (004 Nciitm 44 1 43 0910 X
NEW-UI Neiitm 189 23 166 7 (U) X o gull colrse/curnt,y citd
Ncwtm 20 0 20 0. 165 X Arsaiai Park/Army iabslroslthitlai/sdml
WA I-O2 Neiitm 84 I 83 2.500 X Oakley lull Camtry Ciii ); Mt. Trinity Academy
CAll-OS Norwood 49 18 31 0.485 X
CAH- 0 5 Norviood 14 0 14 0.053 X
CAll-li Norrnxxl 119 80 39 0.758 X
CAN-lB Ntx i,ocxl 216 $98 78 2. 290 X
-ii ’ tlorwood 330 158 172 1.400 X
-UI Norwood 15 8 9 .005 X Site diuu luis boii , minhlu, rei7jired.
Nonwood IS 2 13 0010 X () raiki,ig Lot Ion ttaatre . “ I -
l U l l-UI Nonwood 144 95 49 1.170 X
lUll-U ? Noriiood 128 I? 116 4. Rn X
Norr,ood 50 4 46 1.0 10 X
NcI l-04 l Ior wood 75 3 72. 2 050 X
P4(1 1 -OS Nor wood 159 119 40 0 1 iJ X
(1 ) N(WlOOd 83 0 83 2500 X
P 4(1 1-07 Nonwood 108 1 107 3.7 ( I) 1 o gull cairsoflnmtry ci i i )
ST O-01 Nonwood 21 6 21 0.190 1
SW-U? Norwood 44 7 31 0 680 1
WtS-0I Noiwood 88 0 88 2.700 I
VIES 02 Nor iiood 131 7 124 4 800 I
lionwood 126 35 91 2820 I
VIES-UI Nonivood 3fl 91 231 11.000 1 / i (I
VItP-m Nonwood 28 10 II 0 390 I 1 0 Hail of site is sliulnig aintor
*P-04 Nonwood 12 0 12 0.028 1 1 Small size; e o residential
MP-I Notwood 9 0 9 .(Th I I Small Silo; sano residential
M i-Ui Nonwood 46 046 1.010 I
M i-li Nonivood 10 93 2.9(10
Mi-I? Nonviood 212 Ii 200 9.000 _ ()•
RED-U? Reading 60 IS 45 0.980
Filmamo:NEWLISI.WI (04-Apr-90 ) Page 8
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ACRE A1 Iitxliiu. IIIACI ICAIIIL I IY (ill ILR
Fill ——•————— Site ohm
tot later Capacity Costs/ Avail. Site per Cerps
Site L(x atlm LEGS Oiad Total Resairces Net (eli CY’s) Avail. Logistics Tedi Retalnod meoting Remarks
REt) 03 Reading 112 38 Iii i .1111
WAJC-07 . ReadIng 193 134 59 I fl)
CAX-04 Reading P78 55 73 7 0 1l
8RN-06 Woylnaith 40 0 40 0 7!l)
6RN 07 Woynuith 31 5 26 0 3iii
BRH-08 Weymwth 34 4 3) 0 445
BRN-10 Woymwth 46 19 27 0 380
BRH-11 Woylelith 12) 81 34 0 571
6 RN-13 Woymwth 145 58 81 2 681)
118-06 IoymwUn ii 6 6 0(11)
P16-li Ueyinwth 108 3 105 3.31)
118-13 loyinwth 336 48 288 4 311)
(111-01 Wey I ith 82 4 18 2 2H Z)
UJI-01 Weyunaith I SO 0 ISO 6 2 (1) 1 o Mjssadnisotts 2 1E site
Woymwth 9 3 6 0(11)
V IEY-04 Woymwth 28 21 7 0111)
W Y-07 Woyinwth 32 12 20 0. 115
WIY-08 loylinith 35 21 4 0.051
Woyiiwth 56 9 41 1.020
WEY-ID Woylinith 47 16 31 0.485
l U-il Ioymwth 41 I? 29 0.420
WEY-12 Woymwth 89 18 ii DOn
WET- 13 Reylloith 13) 26 104 3 300
WEY-14 Poymwth 120 21 93 2.900
WET- 15 Woylloith 1410 404 1006 56.000
NET- 16 Weylnwth 8? lB 68 1.750
L - 07 rnyinaith 152 68 84 2.580
& lIlulngtczi 21 1 20 0.170
HIN O4 WIl.lngtcm 41 24 23 0.260
R(D-04 ulleinqtm 274 101 173 7.51)0 X
WlL IIi.Ingtm 13 0 13 0040 I () iritistrial doveltpnant em site Q’I t Ci1t’
111-04 Wilmlngtem 43 34 9 cOol
Fllemame:NEWLIST.*1 (04-Apr-00 ) Page 9
-------
lot Jater
Site Locatim LEGS Oiad Total Resijrces
Mixhium IItAC 1 1CMIIL1 1Y Ufi II I
Fill
Capacity
Hot (mll CVs) Avail.
Wit OS
IIIL 00
Wit-fiB
111-00
111-10
tilL-Il
ROB-U
R IP-l i?
RIP-08
Uxlsca Crtx
C nrall
Fraud In lrxLustr lal 1k
itivlf J Brdc ftis. F1.
Icrig islard
t1epa” ot dr. I lve In
tlcvitvrypo( t
North [ iii Park
Pi twc a
Porn StrlCxalrm
Providence Hartu
Qilncy Diarrlos East
Ojirty Ujarry last
Rayr aa Roods
Scutitay Area
Sqiantui Point
Th m islarvi
531 tIP sIlos
wutinlr!Jtm
R I lmlrlljtrn
RI imir tai
II i.ir gtrn
Ii Imiiigtm
Ii Imington
Ii lmington
R liuingtcn
tirontham
Irentha l
Irenthati
x
x
x
x
x
x
x
6 local cl-edge
(J prevlwsly filled
(JQl
Site ollm
Costs/ Avail. Silo per Corgi
LogistIcs teth. Retained meeting
Rxnar ks
IS 3 I ? 01 1 /8
63 II ! ) iir i
79 19 21’I)
118 118 44111
$10 6 104 3.300
119 56 63 1.650
132 59132.050
89 7 82 2500
lB 8 10 0. IPJ
11 0 17 0.100
9 96 3.050
x
x
x
I
I
I
I
I
I
o Ouvolcipud inthstrlal ZC1
Maiicipal lauwif ill; hvhstrial iise ,J .‘ . it ’ i’,I
Sanitary larwiflil
Site dimrxGiens boks the minlewa rewired. 1b
Site dimonsiaG boks the mmm i. . rewired. 1 (&r.
o IMRA tariff ill site
restrict navigation
excessive cestimat ratio •Y
C LI then. disease ti sp.
- -
• Truck e ss tIwu park r
sIlo filled
I 41 I
I
I
I
I
I
I
I
I
x
x
() prqjosoddSofaclllty
park-Doer islarwi Projoct (t 4’t (L
() flu lwridBinlod area
Filename NERIIST.*I (04-Apr-90 ) Page 10
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Yes
No
-------
854 sites
I
J-.
-
-------
TABLE A-2
STJ1 4ARY OF M&E ALTERNATIVE SITE SCREENING PROCESS
-------
TABLE A•2 SIJIMARY OF I S lE/EPA CENTRAL ARTERY/TUNNEL MATERIALS DISPOSAL SITE SCREENING PROCESS
Preliminary
Size
Reconiiiended
Field
Visst
Site (acres)
Status (1) Reason for Recoiiunended Status Status
(2) Comeents
0 0 1-06 148 investigate Further
Zoned i, istrsal; site — 80 X
disturbed (Ouarry); no apparent
ecological or wetlands concerns.
Site dropped
(Development
on-site)
Parts of the may be in residentiatFcomiiercial
development. Some sensitive receptors in bordering
areas. Roth of these need to be quantified.
FRA-13 103 Investigate Further
Zoned lnckistrial; site disturbed
(gravel pits); no apparent ecolog-
ical or wetlands concerns.
Site retained
Potential problese to be investigated and one
potential historic site and potential groimth ater
concerns (high I medi.a yield aquifers). Conflict-
ing info on whether or not ptitic wells on site.
DED-03 149 Investigate further
Low niuthers of wetlands acres (2
streaum on site however; apparently
no sensitive receptors within 1 km.
Site dropped
(access; rca.
i spacts)
Site mostly forested; s new construction needs to
be investigated - site is zoned residential. 2 poss-
ible historic sites. Some potential terrestrial
habitat impacts.
BOS-21
150 Investigate Further
Few t tands; apparently room for
development. No apparent water,
cultural, or ecological concerns.
Site dropped
(access; rem.
impacts)
Zoned residential - Dorchester Mental Health Center
may occtpy part of site. Bordering sensitive
receptors include schools and 2 cemetaries. Portion
of site may be reasonable. Probable ccmiu nity
concerns.
MAY-07 224 Investigate Further
Very low wetland acres; no welts,
aquifer low yield. Few sensitive
receptors and all 1 km.
Site dropped
(sccess; res.
impacts)
One possible historic site. Zoned residential and
used primarily for agriculture (45Z) • orchards.
Potential terrestrial habitat upsets (SOs forests).
Classified prime faratand7fl Poor access.
NOR -06
83 Investigate Further
No wetlands. No wells or water
concerns. Few sensitive receptors
and .11 2 km. No apparent ecolog-
ical concerns.
Site dropped
(Development
on-site)
2 possible historic/arch, sites. Zoned fl inó.istrial
and 95 residential. Need to investigate extent of
new housing being built and possible power line
corridor. Nay be su site as WLP-09. Small size.
WES-03 126 InvestIgate Further
Apparently 28 forested wetlands
and brook through site. Potential
land use problem. Appears marginal.
Site dropped
(Development;
access)
New housing construct ion - extent ,.rknosa . Zoned 95
residential; 5 intkistrial. Nearby receptors and
historical (14) sites.
No Further Investi’
WLT O8 227 gation
Site 25X wetland and zoned as
conservation/recreational land.
Metropolitan State Hospital on
portion of site. Mui,erous sensitive
receptors nearby.
HURA Data Sheet Compiler rec 1 end that site be
investigated further.
-------
TABLE A-2 SIJIIARY OF NIE/EPA CENTRAL ARIERY/TUIINEL MATERIALS DISPOSAL SITE SCREENING PROCESS
Pret binary
Size
Reco.ended
Field
Visit
Site (acres)
Status (1) Reason for Recomended Status Status
(2) C nts
Land use and potential ecological _______
No Further Investi- iq*cts. Fish A Game/Tosei forest Low wetland scresges. Worksheet cc il.r reci ded
ASN-20 167 gation lands, further Investigation.
Apparently eiitensive new residential
construct Ion. Nunerous receptors in
nearby areas including 2 hospitals,
churches, I pork & nunerous schools; About 122 wetlands and 5% standing water area. Good
No Further Investi- nearby historical (11) sItes. Off- terrestrial habitat in forested areas. Poor access.
WNC-02 234 gation site TU flora. Coapiler recomended further investigation.
Site nearby 502 wetlands (quality?
doe to sine). On medlu. to high
yield aquifer, but no pillic wells
No Further Investi- noted. 402 of off-site wells 752 of site inthistrlal zoned. Active mine on site.
WIL-OT 152 gatlon contmeinated. PossibLe power line across site.
Site are one-third wetlands according
to NIH saps; 602 swaiip with brook
through site center according to
site visit notes. 502 to m land.
Receptors off-site include a conser
vation area. Poor access. Fairly
No Further Investi- pristine area - good terrestrial
IIES- i )4 322 gation habitat. Database cciipiler recom iwIed further investigation.
2 surface ispounthnents hazardous
waste sites on-site. One possible
No Further Investi- historical site. State prison on 252 of site i, astriaL zoned. Hazardous waste sites
FRA-16 171 gation port of site; nunerous other sites, classified 21E.
1 possible historic site. Site —202
wetlands (Nul), but 952 of the site
say have hydric soils. Site
No Further Investi- spparently mostly forested ,nd with
NED-OF 160 gation terrestrial habitat value. TIE flora and fauna off-site.
-------
TABLE A-? SIJIIARY OF MU/EPA CENTRAL ARTERY/TUNNEL MAIERIALS DISPOSAL SITE SCREENING PROCESS
Pie I luiinary
Size
Recosmended
Field
Visit
Site (acres)
Status (1) Reason for Recainnended Status Status
(2) Coents
On site hazardous waste site. Two
possible historic sites. Smell size.
Conflicting wetland info: SIWI - no
wetlands; field notes - 60 sw&ip; Hazardous site clansif led as 21E sod apparently
No Further Investi- note. on land use map - 90X salt closed site with 55 gallon druim (contents not
50 5-23 50 gatlon wetlands, specified).
1 hIstoric site. Site 40’SOZ wet-
lands (SIWI) end potential aquatic
No Further Investi- habitat. Potential terrestrial
NED•0S 272 gatlon habitat (60Z forested). Poor access. Zoned residential. One TIE spp on-site.
Site 50% wetlands (NW); 70-90%
swp according to note. and borders
Neponset River. 3 possible on-site
historical resources. 90% of site
No Further Investi- In 100 year floodplain. 60% of site Area zoned indostrial. Within Foul Nesdowiw - this
CAN-19 330 gatton over high or medius yield aquifer. may be a name for a wildlife area.
(1) 8aaed on initial review of ItIPWIMWRA database files at project offices.
(2) Rec e.id.tion for alt, following site visits and detailed Investigations.
-------
TABLE A-3
APPLICATION OF DEP SOLID WASTE LANDFILL SITING CRITERIA
TO POTENTIAL NEW SITE ALTERNATIVES
-------
TABLE A-3 Application of DEP Solid Waste Landfill Siting
Criteria to Potential New Site Alternatives
Affected Buffer Zone FRA-13 Weston Saugus/MeiroSe
Resource or Restriction Quar Quarry
Sole Source Aquifer Conditional OK OK OK
Recharge Area Restrictions
Private Wells 500 feet OK LOW(1) OK
Height Above 4 feet LOW(2) LOW(2) LOW(2)
Groundwater
Occupied Resid- 500 feet MOD(3) LOW(3) L OW(3)
ential Buildings
Nondrinking Water 250 feet MOD(4) OK OK
Bodies
Wetlands 100 feet MOD(5) LOW(5) LOW(5)
F loodplains Banned LOW(6) LOW(6) OK
Zone II Banned OK(7) OK OK
Interim Wellhead Banned OK OK OK
Protection Area (IWPA)
Upgradient of a 15,000 feet LOW(8) OK OK
Wellhead (If pending
Zone II Determ.)
Potential Water Banned OK OK OK
Supplies
tJpgradient of a 0.5 mile OK MOD(9) 01<
Surf ace Drinking
Water Supply
Downgradient 500 feet OK OK OK
Streams Feeding a 250 feet OK MOD(9) OK
Water Supply within
1 Mile
Agricultural Lands 100 feet OK OK OK
Buffer Zone
Area of Critical Banned OK OK OK
Environmental Concern
Traffic Access Unacceptable danger MOD LOW LOW
to Pu].ic Health
and Saftey
Wildlife/Habitat No Adverse LOW OK OK
Implications to
Species/Communities
-------
NOTES ON DEP SITING CRITERIA RATINGS
Ratina System
“OK” — In full compliance with criteria.
“LOW” — Minor impact; can be mitigated.
“MOD” — Moderate impact; can be mitigated.
“HIGH” - Significant impact; cannot be mitigated.
pecif Ic Notes :
i. According to the Concord quad DEQE Water Source overlay, an
unverified well exists just north of the Weston quarry site.
2. Some excavation has occurred at each of these sites.
Excavations may have penetrated down to the water table or
below. In such a case, a landfill would have to be
constructed so that the liner/containment system were at least
four feet above the groundwater.
3. There are occupied residences within 500 feet of each site.
A few single family homes are adjacent to the two quarry
sites, and a residential neighborhood lies south and east of
the FR.A-13 site. At each site, potential noise/air quality
impacts could be mitigated by constructing the landfill an
adequate distance from the residences.
4. The FRA-13 site borders the Sudbury River. Proper mitigation
would require that a landfill be constructed at least 250 feet
from this river.
5. Regulated wetlands (bordering vegetated wetlands and riverbank
wetlands regulated by Mass. DEP, and palustrifle forested,
palustrine shrub—Scrub, and riverine wetlands regulated by
USACE/EPA) likely occur on the FRA—13 site adjacent to the
Sudbury River. The 250 foot buffer zone required for (4)
above would satisfy the buffer zone requirement for wetlands.
Wetlands may exist on the two quarry sites; limited access
prevented a complete view of those sites. Nonetheless,
wetlands on those sites are probably man-made and/or man—
altered.
6. The FRA-13 site is bordered to the north and west by the
floodplain of the Sudbury River. The Weston quarry site is
bordered to the west by a pond. Both sites are therefore
somewhat restricted by floodplaifls.
7. The FRA-13 site is adjacent to, but not in, a Zone II recharge
area.
8. The FRA-l3 site is upgradient of four wells. Because these
wells are within a Zone II area, and are apparently abandoned,
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according to DEP Water Sources Overlay Maps, the site appears
to currently be in compliance with the regulation. However,
MWRA has expressed serious reservations about the use of the
site, due to concerns for potential impacts to the wells and
the Zone II recharge area.
9. The Weston quarry site is within 0.5 miles of the Stony Brook
Reservoir and within 250 feet of stony Brook. Proper
mitigation would require that buffers be used to ensure that
the landfill is greater than these minimum distances from
water sources.
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ATTACHMENT C
Metcalf and Eddy Report, “Review of XDPW Central Artery/Tunnel
Supplemental Environmental Impact Report” July 30, 1990.
The July 30, 1990 report by Metcalf and Eddy, Inc. (78 pages) cited
as Attachment C to EPA’s July 31, 1990 letter to Lt. Colonel
Stanley J. Murphy of the U.S. Army Corps of Engineer is available
for review at EPA’s Regional Library. EPA ’s Regional Library is
located on the eleventh floor of One Congress Street in Boston.
A limited supply of copies will be made available for Federal,
State and local agencies upon request.
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September 10, 1990
Ms. Julie Belaga
Administrator, Region I
Environmental Protection Agency
One Congress Street
Boston, MA 02108
Dear Ms. Belaga:
As you know, since the joint public hearing held on June 21 and
22 on the draft SFEIS and the Section 404 Permit application for
the Central Artery/Tunnel (CA/T) Project, the Massachusetts
Department of Public Works (MDPW) has continued to pursue design
refinements to further reduce the environmental impacts of the
Project. Extensive dialogue among permitting agencies and the
MDPW has also continued, particularly on issues concerning the
capping of Spectacle Island, and disposal of fill from the CA/T
Project at locations other than Spectacle. On July 31, 1990, you
wrote to the Army Corps of Engineers (“the Corps”) regarding
EPA’s concerns about the CA/T 404 Permit application. In
addition, considerable public testimony has been received on the
Project, and Environmental Affairs Secretary John DeVillars has
certified the adequacy of the Draft SEIS/R and included a series
of requirements and recommendations which are to be incorporated
into the Final SEIS/R. In reference to your comments on both the
404 Permit application and your anticipated EIS comments, we
thought it would be useful to summarize the results of these
processes to date, particularly on issues concerning the capping
of Spectacle Island, creation of a park and alternative fill
disposal sites, issues of air quality, issues concerning the
crossing of the Charles River, and issues concerning air—rights
developments.
SPECTACLE ISLAND
As you are aware, we have been working cooperatively with staff
from several environmental agencies to achieve agreement on an
acceptable material disposal program, and have made some
significant progress.
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The SDEIS indicated that the landfill at Spectacle has
historically extended at least 200 feet north of the current
water edge. (Wave action has eroded the visible part of the
island, leaving the dramatic 85 foot high cliff of rubbish at the
water edge, but there continues to exist in the intertidal area
and below the low tide line a considerable area of historic
landfill.) The SEIS proposes that to properly cap the landfill
will require significant construction of dikes, capping of areas
now under water, and installation of a drainage system to curtail
the seepage of leachates which now contributes to the pollution
of Boston Harbor.
After additional in depth field work we have established the
lateral extent and depth of the existing landfill at Spectacle
Island. We have confirmed and expanded upon the information
contained in the DSEIS and produced a brief report containing
those findings. Additionally the above report also contains new
information on the chemical composition of the landfill. We have
forwarded to you the report detailing the findings of our
consultant on this issue. This information will be incorporated
into the Final Supplement.
Second, we are working cooperatively to identify the most
appropriate means to cap this landfill in a manner that will
ensure proper closure and long term stability consistent with
your comments on the 404 Permit. The Massachusetts Department of
Environmental Protection has indicated that this closure cannot
be adequately accomplished with “minimum DEP landfill closure
standards and guidelines”. We are working with both State and
Federal staff to delineate just what will provide adequate
closure of this landfill, particularly in view of its end state
of active park and recreational use, as agreed to in our recent
meetings, and as outlined in the August 20th letter to a number
of environmental organizations by the CA/T Project, which commits
us to a cooperative process to design the Harbor Island Park.
ALTERNATIVE SITES
Uiland Sites
Your comments have encouraged the Department to continue looking
for new upland disposal sites; but there are several cautions we
must be aware of while conducting this analysis. One is that the
State DEP has recently “adopted tough regulations for both
existing and new landfills”.
Taking these comments into consideration the Department will
further explore the idea of larger volumes of project material
being disposed of in already sited and/or permitted commercial
landfills. This may be a more achievable way of disposing some
of these materials in an upland environment.
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Coastal Sites
Logan Airport continues to show significant potential for receipt
of excavated materials from East Boston and will very likely be
the site for disposal of all such excavated materials, a quantity
we expect to exceed two million yards.
Design Refinements
Through design refinements in the South Boston and South Bay
portions of the Project, we have been able to reduce our total of
excavated material we need to dispose of by approximately one
million cubic yards.
Backfill
You and the DEP and the COE have all expressed interest in the
more extensive use of project excavated material as backfill
material to meet the approximately 4 million cubic yards demand
for backfill. Our DSEIS did address this issue and identFfy some
opportunities for use of excavate as backfill. In order to fully
respond to these comments we are further analyzing ways of
obtaining all project backfill from our own excavation as a way
o minimize the amount of material needed for disposal.
In summary, we are addressing the comments of your staff in a
comprehensive way that will allow us to respond to all of these
issues in our final document.
Our current plans for display of this information in the final
SEIS is to produce a combination of potential material disposal
options that would be consistent with the Project for use in the
permitting process.
As we have discussed, this approach would contain options of
placing various amounts of material on Spectacle Island, in
combination with other alternatives for disposal of material,
such as: upland sites; commercial landfills; coastal sites, and
increased use of backfill. Each appropriate material disposal
program would then be analyzed for environmental impacts, and
would therefore be available for use, dependent upon the
permitting process. This approach will clearly document in the
final a range of options for material disposal as requested in
your comments.
DESIGN REFINEMENTS NORTH OF CAUSEWAY STREET
Over the past month, we have been working to refine the Project
design in the area of the Charles River. Based on our extensive
review process with DEP, MDC and other agencies, and based on a
public mediation process encouraged by the private group “1000
Friends of Massachusetts”, and the requirements of Secretary
DeVillars’ Certificate, we have adopted the following course of
action:
—3—
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1) The MDPW will modify the basic bridge structure across
the Charles to an appropriate longer span structural
system which will decrease the number of piers in the
water from approximately 17 to under 9. These design
modifications will be undertaken in cooperation with DEP
Division of Waterways, the United States Coast Guard and
the Army Corps of Engineers.
2) The MDPW will modify the design of ramp “CS” so that to
the extent possible, the new ramp will be placed over
the CANA ramp and extend no closer to the northern bank
of the Charles River than the CANA ramps authorized in
waterways licence # 1742.
3) The MDPW will modify the design of the bridge in such a
manner as to maximize effective usable space under the
bridge at critical crossings for pedestrians and’
bicycles.
4) The MDPW will create a gap between major structural
elements of the bridge to increase the amount of light
and natural ventilation experienced by those crossing
under the bridges, whether by vessel or by land.
I believe you will find these design refinements will result in a
considerable improvement to the Project.
In short, we have taken the Charles River area comments of the
respondents very seriously. Based on a review of engineering
design refinements available to the Project, we now believe that
the outer-most highway ramp affecting the north bank of the river
can be pulled back to directly over the presently approved CANA
ramp along the north bank. We believe that this will make a
major improvement in our ability to achieve the mutually held
goals of optimizing the quality of the environment along the
north bank. We further believe that use of longer span
engineering technology for the major bridges can considerably
decrease the need for supporting piers in the water and on the
riverbanks.
AIR QUALITY ISSUES
Sensitivity Analyses
We concur in the desirability of undertaking a sensitivity
analysis to help us understand the potential for mitigating
measures to play a part in a total policy towards transportation
implementation in the region. To recap the basic information
presented in the SEIS, the Project is expected to reduce total
vehicle hours of travel by 29%. Perhaps this is the most
important statistic in the entire DSEIS. But we do not perceive
the Artery/Tunnel Project to be carried out in a vacuum, nor ever
have we. Many questions about associated policy issues merit
—4—
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further attention and will be addressed in the sensitivity
analysis. We will examine the implications of greater and lesser
job growth than initially forecast; the implications of parking
policies being more or less restrictive than assumed in the
models; and the implications of a greater and smaller transit
networks than assumed in the models.
The sensitivity analysis will allow each of the input assumptions
to be tested separately in order to understand the relative
importance of possible mitigation and support programs in each of
these areas.
In conclusion, we are confident that the traffic assumptions
included in the forecasting process were indeed correct to make
cautious conclusions about the possible air quality benefits of
the project, and most importantly to compare the design year with
the project to the design year without the project. We Look
forward to undertaking the sensitivity analysis to help us
understand the relative importance of each of the component parts
of the transportation network, and to help us to guide policies
to achieve even greater benefits.
Air Quality During Construction
Both your agency and our State DEP have asked us to develop a
“protocol” for assessing, defining and permitting air quality
impacts from our construction activities and traffic hours during
construction.
We are agreeable to such a process and will be meeting with
appropriate agencies to agree on a protocol for inclusion in our
final document.
Dewey Sauare
Based on recent discussions, we note your concerns about the
operations within the Dewey Square Tunnel. At present the
Project does not intend to reconstruct the Dewey Square Tunnel,
or to make major changes in the nature of the ventilation
system. The traffic studies undertaken show a significant
improvement in the flows through this tunnel segment. Based on
our conversations, we have undertaken further analysis of this
issue, which we will share with you as the information is
developed. Through this process we will determine an optimal
policy in this area. The results of this examination will be
incorporated into the Final EIS.
Level of Transit Commitment
We are committed to construct as integral elements of the
Artery/Tunnel Project, major transit improvements at South
Station, at Blue Line Airport Station, and the provision of a new
transit right-of—way for the South Boston Piers access
—5—
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transitway. In addition, the Project includes a major HOV
roadway system for both 1-90 and 1-93 as an integral part of the
Project. Based on the EOEA MEPA Certificate we have committed
that none of these elements will be deleted from the Project.
AIR RIGHTS DEVELOPMENT
Massachusetts Secretary of Environmental Affairs John DeVillars
in his August 29, 1990 Certificate on our DSEIR (copy enclosed)
wrote at some length on the issue of air rights development. The
conclusion of the Secretary’s analysis of this issue was’ a strong
suggestion that approximately 75% of the land created by the
Artery depression should be maintained as publicly accessible
open space and that the surface streets should be limitea to
three lanes in each direction, (in several locations it is
presently six lanes per direction). The BRA is proposing such a
plan, which is now being reviewed in a series of community
meetings. This plan, now undergoing public review, will b ë
included in the FSEIS.
I hope this update on our work in these areas will be of value to
you and your staff. As always, if we can further clarify any of
these issues, please call either of us directly.
-. Very truly yours,
cL -
Frederick P. Salvucci
Secretary. /
T)aw c 7
ai ie Garvey
Commissioner
I
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For more Lntormation call Rudy Brown (€17) 565-3412
8/1/90
EPA OPPOSES FILLING BOSTON HARBOR TO DISPOSE OF FILL FROM
ARTERY/THIRD HARBOR TUNNEL PROJECT
BOSTON —- The U.S. Environmental Protection Agency (EPA) today
formally recommended to the U.S. Army Corps of Engineers (COE) that
it deny the Massachusetts Department of Public Works’ (DPW) request
for a permit to dump 9.3 million cubic yards of material in harbor
waters around spectacle Island. The material would come from
excavation and dredging activities during construction of the
Central Artery and Third Harbor Tunnel (CA/THT) project.
Said Julie D. Belaga, EPA’S Regional Administrator,”DesPite today’s
temporary setback for the DPW, I see no reason why this project
cannot be designed to achieve the multiple goals of landfill
capping and park creation on Spectacle Island and materials
disposal while minimizing the risk to the environment.
“We are more than eager to work with the DPW and Army Corps to
ensure that the project is developed in an environmentally sound
manner. This is not the final step in the process. We look forward
to continuing the dialogue as the DPW addresses our concerns,” she
added.
EPA expressed several objections to DPW’s proposal which, if
permitted, would be the largest filling of harbor waters since the
Section 404 regulations of the Clean Water Act were issued in 1980.
The agency explained that as currently proposed, DPW’s disposal
plans do not comply with several Section 404 regulations governing
issuance of a permit under the Clean Water Act. In addition, it
determined that the fill would cause significant adverse impacts
to the surrounding environment.
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Filling would destroy a large acreage of biologically productive
intertidal and shallow tidal habitat. These areas currently support
over 55 invertebrate species, including soft-shell clams, blue
mussels, and lobsters; provide food sources for water birds such
as black ducks, .iders, gulls and mergansers; and provide habitat
for numerous species of fish.
EPA also determined that DPW failed to demonstrate that no
environmentally preferable alternatives existed. It did not
adequately explore other disposal options, including upland sites.
Preliminary research done for EPA indicates that environmentally
acceptable upland disposal sites likely exist.
Explained Belaga, “We do not oppose using some of the material from
this project to cap the abandoned landfill on Spectacle Island and
to create a park at this site.
“But, federal regulations do not allow filling in the harbor if it
can be avoided or if it would cause a significant adverse impact.
This project fails the test on both counts,” she concluded.
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4 ID
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
+, J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211
September 24, 1990
Anthony Fusco
Division Administrator
Federal Highway Administrator
55 Broadway, 10th Floor
Cambridge, MA 02142
Dear Mr. Fusco:
The Environmental Protection Agency, in accordance with its
responsibilities under the National Environmental Policy Act (NEPA)
and Section 309 of the Clean Air Act, has reviewed the Final
Supplemental Environmental Impact Statement (FSEIS) for the
proposed South Boston Haul Road, South Boston, Massachusetts.
The proposed project is a two-lane 1.1—mile limited access road to
be built substantially within an existing, below-grade railroad
right—of-way from Dorchester Avenue and Congress Street. According
to the FSEIS, its use would be restricted to trucks associated with
the construction of the Central Artery/Third Harbor Tunnel Project,
other commercial trucks, and empty buses travelling from the
Massachusetts Bay Transportation Authority (MBTA) Cabot Yard bus
facility and service routes. The purpose of the project is
essentially to provide an alternate route for construction and
commercial trucks that would otherwise have to use local streets
in South Boston.
We appreciate the considerable efforts made by the Massachusetts
Department of Public Works (MDPW) and the Federal Highway
Administration (FHWA) to address the concerns raised in our July
26, 1989 comments on the DSEIS. As a result of these efforts, we
believe our concerns have essentially been resolved and the project
has the potential for substantial environmental benefits.
The FSEIS demonstrates to our satisfaction that the project, though
linked to the Artery/Tunnel Project through its function as a
construction mitigation measure, has independent transportation
and environmental merit. At its peak year, 4720 vehicles are
expected to use the Haul Road daily. 1700 of these will be
construction trucks, and of these 900 are expected to be from the
Artery/Tunnel Project. By relieving local streets of this truck
traffic, the project has the potential for substantia] improvements
to traffic flow and thus to air quality independent of the
Artery/Tunnel Project. The project also has the potential for
other environmental benefits, such as remediation of contaminated
soils, while at the same time causing few significant adverse
impacts. For all of these reasons, we believe that the project can
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and should proceed without awaiting resolution of EPA’s concerns
about the Artery/Tunnel Project.
Additional comments and recommendations are as follows:
1) Contaminated Boils :
The FSEIS is responsive to the concerns we expressed in our DSEIS
comments about contaminated soils. We support the MDPW’s
commitment in the FSEIS, in response to EPA’s comments on the
DSEIS, to remediate soils contaminated with polychlorinated
biphenyls (PCBs), including removal of soils contaminated at 50
parts per million (ppm) or greater, at the Boston Junk Company
property in advance of construction of the Haul Road in this area.
We also support the commitment for further sampling and analysis
of the PCB runoff area to determine the extent of contamination,
confirmatory sampling during and after removal, development of a
remediation plan for EPA and Massachusetts Department of
Environmental Protection approval, and ultimate disposal at an EPA-
approved site in accordance with the Toxic Substances Control Act.
We request that these commitments be incorporated as enforceable
conditions in the Record of Decision.
In addition, as we have discussed regarding the applicability of
the Resource Conservation and Recovery Act (RCRA), EPA has
promulgated several new RCRA hazardous waste regulations that may
have an impact on the project. The MDPW is aware of these from
discussions with MADEP and EPA staff. Among the most significant
of these new regulations are the Toxicity Characteristic (TC) rule,
and the regulations to implement prohibitions on land disposal of
hazardous waste (LDR). The TC rule adds 25 organic constituents
to the Toxicity Characteristic list which is used to identify
hazardous waste. The rule also replaces the Extraction Procedure
(EP) Toxicity Test with the Toxicity Characteristic Leaching
Procedure (TCLP). This rule was published in the Federal Register
on March 29, 1990 (55FR11798) and becomes effective September 25,
1990. The LDR rule has consisted of a series of regulations in
which certain hazardous wastes are prohibited from land disposal
unless specific conditions and treatment standards are met. The
most recent LDR rule was published in the Federal Register on June
1, 1990 (55FR22520) and became effective on May 8, 1990. It will
be important for the MDPW to keep abreast of the changes to the
federal and state hazardous waste programs as they occur to ensure
that the project is kept in compliance.
2) Water quality :
The FSEIS adequately responds to our request for additional
information on storinwater/groundwater flows and water quality
impacts to Fort Point Channel. We understand from the FSEIS that
no direct wastewater discharge to surface waters, either from
drainage or construction dewatering, is proposed for this project;
hence, no NPDES permit under Section 402 of the Clean Water Act
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will be required. Further, we would not object to the proposed
drainage design described in the FSEIS which would connect
stormwater flows to the Roxbury Conduit, provided the connection
enter the system downstream of the structures that regulate
overflows from the combined sewer overflow (CSO) system. We are
pleased that the FSEIS recognizes the planning studies being
undertaken by the Massachusetts Water Resources Authority (MWR.A)
concerning the need for treatment of the CSOs, including the
Roxbury Conduit. When this planning effort is completed, treatment
or separation of the Haul Road flow could be required. We
therefore request that the FHWA and MDPW commit in the Record of
Decision to participate in the funding and implementation of any
new drainage requirements or treatment of drainage from the Haul
Road that may result from the MWRA studies.
Finally, we request that the Record of Decision contain a
commitment to development of a formal Best Management Practices
plan for purposes of controlling sediment and construction activity
runoff. The FSEIS alludes to such a plan on page 13-1.
In conclusion, we support the construction of the South Boston Haul
Road because we believe it could benefit public health and
environmental quality. We further believe the FSEIS adequately
assesses the project’s impacts and demonstrates that it is
justified both as an Artery/Tunnel truck traffic mitigation measure
and as an alternate route for overall truck traffic in South
Boston.
My staff and I would be pleased to respond to any questions you may
have. We would appreciate receiving a copy of your Record of
Decision when it becomes available.
Si sc rely
cc: Frederick Salvucci, Secretary
Executive Office of Transportation and Construction
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j(D SP .,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F KENNEDY FEDERAL BUILDING, BOSTON MASSACHUSETTS 02203-2211
July 31, 1990
Stanley J. Murphy, Lt. Colonel
District Engineer
U.S. Army Corps of Engineers
New England Division
424 Trapelo Road
Waltham, MA 02254—9149
Dear Colonel Murphy:
This letter responds to your May 18, 1990 public notice seeking
continent about the Central Artery/Third Harbor Tunnel (CA/THT)
project. The Massachusetts Department of Public Works (MDPW)
proposes to build approximately 7 miles of new and reconstructed
roadways in Boston. Key features of this $5 billion project
include placing most of the rebuilt Central Artery underground and
constructing a new Seaport Access Road and Third Harbor Tunnel to
Logan Airport. Because the proposal involves considerable
dredging, filling and placement of structures in marine waters, as
well as ocean disposal of dredged material, it requires federal
permits under Section 404 of the Clean Water Act, Section 10 of the
Rivers and Harbors Act and Section 103 of the Marine Protection,
Research and Sanctuaries Act (MPRSA). Our comments center
primarily on the request for a §404 permit; we also briefly address
the request for § l03 and 10 permits. 1
The case raises several environmental concerns, the most
significant of which stems from the disposal of more than 13
million cubic yards of material dredged or unearthed during the
course of the project. MDPW and the City of Boston seek approval
to place 9.3 million cubic yards of this material in over 100 acres
of Boston Harbor around Spectacle Island. While the primary reason
for filling the harbor waters is disposal, the permit applicants
have indicated that the fill would also serve to cap the historic
landfill at the Island and accommodate creation of a park. The
Island would be expanded to more than double its size by
sacrificing 103 acres of marine habitat. Both intertidal and
1 The Federal Highway Administration (FHWA) on May 10, 1990
issued a Draft Supplemental Environmental Impact Statement. EPA
has responsibility to comment to FHWA on the project and the
adequacy of the DSEIS under the National Environmental Policy Act
(NEPA) and will do so by September 22, 1990; we anticipate raising
substantial concerns in the NEPA comment letter. Those comments,
which shall incorporate the conclusions set forth herein, will also
address the full range of environmental issues within EPA’S
jurisdiction and expertise. We understand that the NEPA comment
letter will be made part of your administrative record for purposes
of the Corps’ NEPA and § 404, 103 and 10 permit decisions.
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2
subtjdal areas which provide habitat for fish, shellfish and
various waterbirds would be destroyed.
EPA Opposes this extensive filling of Boston Harbor because, as
explained below, it would cause severe and unnecessary
environmental impacts. At the same time, however, we emphasize
that we do not object to capping the old Spectacle Island landfill
and creating a park. We recognize the need to devise a final
materials disposal plan for the CA/THT project which minimizes
overall environmental consequences. We are confident that these
objectives can be realized without major impacts to the aquatic
environment at Spectacle Island and in a manner which complies with
the requirements of the Clean Water Act.
We conclude that the project as currently proposed cannot receive
a Clean Water Act permit because it violates the EPA §404(b) (1)
guidelines on several counts. First, EPA believes the record does
not support the conclusion in the DSEIS that the proposed action
is the least environmentally damaging practicable alternative. The
record developed to date contains convincing evidence that other
disposal options, including several land based alternatives, likely
exist. The applicant has therefore not demonstrated compliance with
§230.10(a) of the guidelines. Second, we believe the proposed
filling of 103 acres of marine habitat would cause or contribute
to significant degradation of the aquatic environment in violation
of §230.10(c) of the guidelines. We base this conclusion on the
unmitigated permanent destruction of aquatic functions and values
of the intertidal and subtidal habitat. If permitted, this fill of
harbor waters would be the single largest allowed in New England
since the publication of the §404(b) (1) guidelines (December 24,
1980). Sheer size aside, the fill would destroy productive marine
habitat and cause severe impacts to the species that utilize the
area. Third, the significant adverse impacts to the marine habitat
would cause a loss of existing uses thereby violating
Massachusetts’ federally approved anti-degradation regulation.
Hence, the current proposal also fails §230.10(b) of the guidelines
which prohibits violations of any state water quality standard.
EPA’s concerns are long a matter of record. As early as 1982 we
alerted MDPW that since the project would be subject to regulation
under §404, avoidable or significant losses of aquatic habitat
would be prohibited. We commented on the draft and final EIS for
this project in 1983 and 1985, respectively. Since 1987 we have
participated in numerous meetings and subcommittees to help MDPW
design a project that would comply with the requirements of federal
environmental laws. Our involvement has substantially increased
in the last two years with reviews of draft portions of the current
DSEIS. By October 1988 we had alerted MDPW that Spectacle Island
“Scheme 1,” which would have filled 62 acres of coastal and aquatic
resources, appeared to be unacceptable under §404. We are
dismayed that concerns repeatedly raised by us and others remain
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3
unresolved. 2 The delay and difficulty the project faces in
obtaining a §404 permit could have been avoided if environmental
issues identified years ago had been dealt with squarely. We
nevertheless continue to believe that the basic project——depression
and widening of the Central Artery and construction of the Third
Harbor Tunnel -— can satisfy the guidelines if these longstanding
issues can be resolved. Our §404 concerns, while serious, can be
remedied if the materials disposal plan is modified. We remain
committed to working cooperatively with MDPW and other involved
parties to ensure that the CA/THT project is developed in an
environmentally acceptable manner. To that end, we recently have
been participating in a series of meetings with the Corps, MDPW,
the Department of Environmental Protection (DEP), the Department
of Environmental Management (DEM) and the City focusing on issues
related to material disposal alternatives.
This letter presents our evaluation of the impacts of this proposal
to the aquatic environment, our assessment of the existence of
practicable alternatives to filling the waters of Boston Harbor,
and our conclusions with respect to the requirements of the
§404(b)(l) guidelines. 3 Attachment A contains our comments
pertaining to the permit applications under §3.0 of the Rivers and
Harbors Act and §103 of MPRSA as well as several §404 issues
unrelated to the Spectacle Island fill proposal. In conducting
this review and formulating our position, we have relied upon the
Corps public notice and the DSEIS, information received during our
extensive involvement in the project, and recent work done by
Metcalf and Eddy (M & E), a consultant retained by EPA to assist
in the review of the DSEIS and the federal permit applications.
We requested M & E to examine the impacts to the marine environment
associated with the MDPW’s proposed filling of waters at Spectacle
Island; evaluate MDPW’s alternatives analysis for the materials
disposal program; and assess the feasibility of alternative
disposal scenarios which would have less environmental impact. In
so doing, M & E devised one potential capping/park creation
alternative for Spectacle Island and identified several potential
upland disposal sites. The scenarios identified by M & E do not
2 Through impressive in size, the DSEIS analyzes certain key
§404 issues inadequately, incompletely or not at all. Attachment
B lists the additional information we feel should be provided so
that we can completely assess the project’s impacts. Despite
deficiencies in the DSEIS, enough information exists for us to
conclude that the present proposal does not comply with the
guidelines.
3 Whjle we have reviewed the proposal primarily in light of the
requirements of the guidelines (40 CFR 230), we believe many of our
comments are also germane to your public interest review.
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represent the only choices available; they demonstrate, however,
that even a relatively quick (i.e., less than two month) analysis
reveals several apparently practicable and less environmentally
damaging options. The M & E report is appended hereto as
Attachment C.
Section 404 Permit for Filling Waters at Spectacle Island
1. The Massachusetts DPW Has Not Demonstrated the Unavailability
of Feasible Less Environmentally Damaging Alternatives .
The alternatives analysis performed to date is not adequate for the
purposes of compliance with §404(b)(1) guidelines. These
regulations prohibit discharges if there exists a practicable
alternative which would have less adverse impact on the aquatic
ecosystem, so long as the alternative does not have other
significant environmental consequences. It is the applicant’s
obligation to demonstrate that no such alternatives exist. 4 The
regulations consider practicable alternatives to include, but not
be limited to, activities which do not involve a discharge of
dredged or fill material into the waters of the United States or
ocean waters, or which involve discharges of dredged or fill
material at other locations in waters of the United States or ocean
waters. “Practicable” alternatives are available and, either
singularly or in combination, capable of satisfying the basic
project purpose taking into account cost, logistics and existing
technology. ( 230.l0(a)(l) and (2)). Any alternative which would
appear to satisfy the basic project purpose and cause less
environmental damage should be considered in the §404 analysis.
This could include examining alternatives to the basic
highway/tunnel project itself, as discussed in the U.S. Fish and
Wildlife Service comment letter of July 17, 1990. However, since
our primary concern centers on the adverse impacts of filling the
waters around Spectacle Island rather than the actual construction
of the artery and tunnel, and since we believe there are
alternative disposal options, we do not here address alternatives
to the overall project.
4 Nonwater dependent projects which fill wetlands, mudf late or
other special aquatic sites as defined by the guidelines must rebut
a presumption that practicable alternatives which do not involve
a special aquatic site are available and have less impacts on the
aquatic ecosystem ( 23O.lO(a)(3)). Courts have held that the
guidelines impose a substantial evidentiary burden on the applicant
to demonstrate the unavailability or infeasibility of alternatives
(e.g., Hou h v. Marsh) . The CA/THT proposal (including the
landfill capping and park creation aspects) is not water dependent
and the area MDPW proposed to fill includes some saltrnarsh and
mudf late. Since MDPW has failed the general requirement to comply
with §230.10(a), it clearly has not overcome the rebuttable
presumption insofar as it applies to this case.
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The evaluation of disposal alternatives by MDPW is wholly
inadequate. Indeed, it does not appear that a coherent analysis
of alternatives was performed at all, let alone the searching look
required by the guidelines. Instead, MDPW employed a set of
“siting criteria,” not all of which EPA agrees with for purposes
of the §404 analysis, to reject alternatives other than Spectacle
Island. Even accepting MDPW criteria, the record does not support
the conclusion reached in the DSEIS that the proposed project is
the least environmentally damaging practicable alternative. On the
contrary, there is ample evidence that less environmentally
damaging, practicable alternatives likely exist to filling the
marine habitat around Spectacle Island. We treat each of these
issues in turn.
a. Inadequacy of Current Alternatives Analysis
The §404(b)(l) guidelines mandate a serious evaluation of
alternative sites for disposal of materials other than in the
waters around Spectacle Island. The materials disposal
alternatives analysis provided in the DSEIS was flawed for several
reasons. First, the evaluation of land—based disposal options was
cursory and apparently involved little or no on—site investigation
of potential alternate sites. Second, MDPW applied overly narrow
site screening criteria, effectively eliminating potential
alternatives. Third, even accepting the site screening criteria,
the MDPW eliminated sites inappropriately or without justification.
Working with the MDPW and the Corps as recently as April 5, 1990,
we reviewed the Massachusetts Water Resources Authority (MWRA) list
of 296 sites to determine if these sites should be eliminated or
assessed further based on information contained in the MDPW files.
This process resulted in approximately 200 sites that warranted
further investigation to determine feasibility for use as a
materials disposal site. MDPW planned to eliminate most of these
sites based on a criterion which required sites to be at least 80
acres in size. EPA and the Corps stated that the minimum size
criterion should be reexamined and supporting documentation
provided. In response to this request, consultants to MDPW
provided information suggesting that 20 acre sites could be
economically feasible for disposal. Nevertheless, MDPW adhered
to the 80 acre criterion in the DSEIS and rejected most potential
disposal sites on that basis. Similarly, it appears that MDPW
eliminated a number of sites by presuming endangered species
concerns. While we agree that effects on endangered species ought
to be considered in evaluating alternatives, the potential adverse
impacts should be documented before sites are eliminated on that
basis, It also appears that MDPW inappropriately excluded sites
on the basis of “program implementation issues”
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(DSEIS,VOL.II.B. ,PP.4-35) such as the dela rs that might result from
acquiring necessary regulatory approvals.
Even accepting the applicant’s screening criteria uncritically,
the MDPW retained sites that should have been eliminated and
dropped sites that should have been further analyzed. For
instance, the Bedford site should have been eliminated based on
wetland and water supply impacts. In our October 4, 1989 letter
to MDPW, we recommended that the Governors Island Flats and Hull
Bay sites be eliminated based on concerns about the aquatic
environment, yet MDPW retained the sites in the DSEIS. Of greater
concern, we believe a number of sites have been eliminated
prematurely. Of the roughly 200 sites identified by the agencies
in April, 1990, approximately 70 of the sites evaporated from the
list of alternatives with no explanation. Furthermore, the MDPW
eliminated from further consideration the use of the 524 existing
landfills in the State, based on DEP’s objections to using the very
limited capacity available in the remaining landfills for disposal
of materials other than sanitary waste (Appendix Vol. 3 of 5, page
7-4). EPA agrees with DEP that the limited capacity of the State’s
existing operating landfills needs to be reserved for municipal
refuse disposal. However, MDPW could have considered existing
closed sites for possible vertical or horizontal expansion, as well
as the possible beneficial re-contouring of landfills that have not
been properly capped.
In summary, the MDPW alternatives analysis is seriously flawed and
the record does not support the conclusions in the DSEIS. That the
DSEIS eliminated sites which appear to meet MDPW’s own screening
MDPW has also stated to EPA and the Corps that it believes
upland sites are generally impracticable because of perceived
difficulties in overcoming community objections. In considering
community concerns in the §404 alternatives analysis, several
factors should be kept in mind. The regulations define a
“practicable” alternative as being available and feasible taking
into account cost, logistics, and existing technology. EPA and the
Corps have consistently held that generalized and undocumented
difficulties encountered in making siting decisions do not serve
as a basis for rejecting otherwise feasible alternatives. In
unusual cases, community objections may render an alternative
unavailable if it becomes impossible to obtain, manage, or utilize.
However, we do not believe MDPW would have difficulties obtaining
sites because it has the power of eminent domain. In any case,
a general expectation of community opposition, without
documentation of diligent but unsuccessful efforts to utilize an
alternative, falls far short of the showing required by the
guidelines. Moreover, we believe MDPW could ameliorate community
concerns by showing that the material is not hazardous, traffic
impacts are not severe or permanent, and the filled areas can be
put to productive private or public use.
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criteria and for which we sought further study, and meanwhile
retained sites that appear to fail the same criteria or which we
recommended be dismissed, is baffling and casts doubt on both the
quality and fairmindedness of the analysis. Based on current
information, the MDPW has failed to show that there are no less
environmentally damaging practicable alternatives to filling 103
acres of harbor waters, and the proposed discharge does not comply
with the requirements of §230.10(a).
b. Practicable Disposal Alternatives Likely Exist
Not only has MDPW failed to show there are no alternatives, but
the current record and the work by our consultant demonstrate the
probable availability of feasible, less environmentally damaging
alternatives. These alternatives include options identified in
the DSEIS and others not included in the document. The following
discussion underscores our conclusion above about the inadequacies
of the MDPW analysis and, further, illustrates the likelihood that
feasible alternatives do in fact exist. The sites examined by
M & E do not necessarily reflect a conclusion by EPA that these are
the only potentially less environmentally damaging practicable
alternatives or that these should be selected over other less
environmentally damaging alternatives that may be identified in the
future.
Based on the DSEIS and other sources M & E examined several
potential land-based disposal options that look promising from the
standpoint of §404 requirements. 6 They conducted a preliminary
evaluation of how each of the options would affect wetlands,
traffic, water quality, land use, relocation, air quality, noise
and historic resources (see Attachment C; Section 3.0). Based on
this preliminary analysis, it appears that these sites would be
less environmentally damaging practicable alternatives to the
Spectacle Island proposal. Of these, two have already been
identified in the DSEIS: the Rowe Quarry in Revere and Maiden and
the Bates Quarry in Weymouth. 7
°Based on discussions with your office, we understand that the
New England Division staff reviewing this project have identified
other alternatives which merit further study.
we recognize that the MWRA has selected the Rowe Quarry
site as a back—up alternate site for disposal of residuals from the
Deer Island wastewater treatment plant. If (and only if) the state
legislature prevents the MWRA from using its preferred site at
Walpoie, thereby resulting in the use of Rowe Quarry, EPA would
agree that, from a public health standpoint, it is a more urgent
priority to use the quarry for residuals disposal rather than
excavated materials disposal.
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The Rowe Quarry site, for instance, drains to salt water, has
direct access off Route 1, and is only 6 miles from the project
sites. The Weyinouth Quarry site could be developed in a manner to
avoid impacts to any significant wetlands, affecting only some
quarry ponds that have been used for rock washing operations.
Residential traffic impacts associated with the use of the Weymouth
Quarry site could be eliminated by provision of a new direct access
and egress from the adjacent Route 3. Concerns about protection
of water supplies could be mitigated by construction of properly
lined landfills at these sites. These sites need additional study
to determine the extent of federally regulated wetlands and waters
of the United States within the sites, measures to avoid or
minimize the loss of any valuable aquatic habitat within the
Weyinouth site, the extent of other potential environmental impacts,
and means to maximize site volume capacity for the materials
disposal program.
Other quarries 8 may also be suitable for disposal of excavated and!
or dredged material from the project. For example, N & E
identified three additional sites, two of which are quarries, which
conbined iay be able to contain 4.6 million cubic yards of
material. The estimates of capacity are conservative, based on
achieving full compliance with DEP solid waste siting criteria.
N & E’s preliminary evaluation suggests that these other sites
would be far less environmentally damaging than filling 103 acres
of harbor waters around Spectacle Island.
In addition, the DSEIS briefly evaluated the potential use of Logan
Airport infield areas as a disposal site for some of the material
from the project. This alternative may be able to accommodate at
least 0.5 million cubic yards of material in the infield areas to
a height of approximately one to two feet within FAA restrictions.
This alternative involves little or no wetland impacts and minimal
traffic worries. It appears to be practicable and less
environmentally damaging, and clearly warrants further study.
We believe that MDPW should also reassess its proposal to use only
a small fraction (100,000 cubic yards) of excavated material as
backfill. The project will require roughly 4 million cubic yards
of backfill, and we have not seen a compelling explanation of why
excavated material could not be used for this purpose. EPA
8 Quarries generally offer a number of advantages because they
are heavily disturbed sites, often connect to major rail and road
networks, and can contain substantial volumes of material.
Moreover, quarries typically blight the landscape and are sometimes
a safety hazard. Once filled and capped, quarries could be put to
productive public (e.g., park, open space) or private (development)
use. Apparently several quarry owners have recently expressed
interest to the Corps and MDPW in accepting excavated material from
the CA/THT project.
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recognizes that suitable grade material may be necessary in certain
areas (e.g., utility corridors, roadbeds) to prevent differential
settling. However, after taking measures to protect utilities and
any other especially sensitive zones, it would appear that perhaps
as much as several million cubic yards of material could be
utilized as backfill. Insofar as excavated material can be used
in this fashion, it has the twin advantages of reducing the volume
of material for offsite disposal and the need to truck in backfill
material. This alternative re—use of the excavated material should
be explored in further detail.
Your staff has also identified a marine disposal alternative of
nearshore confined aquatic disposal. Under this approach, shallow
areas would be isolated, dredged and backfilled with material
generated by the CA/THT project. At first blush, this option
appears to have certain advantages: the material dredged from the
cells could be used as cap at the Massachusetts Bay disposal site;
environmental impacts to the Harbor, while long—term, would not be
permanent: with careful site selection, it is unlikely to violate
the prohibition against significant degradation, in contrast with
the proposed project; and it appears to be cost-effective. We
recommend studying this option further to determine whether
environmentally suitable nearshore areas exist which could
accommodate a contained dredge and backfill alternative.
In summary, the record developed to date indicates that less
environmentally damaging practicable alternatives likely exist to
the current disposal scheme. These include recycling more material
as backfill, land-based alternatives, and, possibly, nearshore
confined aquatic disposal. EPA need not prove the existence of
practicable alternatives, let alone devise an actual disposal plan.
However, the evidence in the record that other feasible options
exist reinforces our conclusion that the current proposal fails the
guidelines and underscores the need to redirect the materials
disposal evaluation towards a plan that will comply with the Clean
Water Act requirements.
c. Less Environmentally Damaaina Landfill Capping and Park
Creation Alternatives Exist
The MDPW has joined with a co-applicant, the City of Boston, in
seeking the §404 permit to fill waters at Spectacle Island. The
City hopes to use MDPW’s dredged and excavated material to cap the
historic landfill at the Island in a manner which can accommodate
future use of the site as a park. This multi—purpose proposal
complicates the alternatives analysis under §404.
A proper §404 analysis in this case can be handled two different
ways. First, the Corps could consider the capping of the landfill
and creation of a park to be secondary benefits of the basic
transportation project proposed by MDPW. If the alternatives
analysis for the materials disposal demonstrates that some fill in
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Harbor waters around Spectacle Island is unavoidable and would not
cause significant degradation of aquatic resources, we would
support designing the disposal operation with these secondary
benefits in mind.
Alternatively, and more consistent with the Corps public notice,
the Corps could determine that there are three distinct project
purposes: materials disposal from the transportation project,
landfill capping or remediatjon, and park creation. Under this
approach, there must be a separate inquiry to determine the least
environmentally damaging practicable alternative for each project
purpose. There is no requirement that all of the purposes be
accomplished at the same site. So, for example, if the
alternatives analysis for materials disposal shows that filling
waters at Spectacle Island is avoidable, then the inquiry would
turn to the minimum amounts of fill needed to remediate the
landfill and to enable a park to be built.
As discussed above, MDPW has failed to show that filling 103 acres
of harbor waters is the least environmentally damaging practicable
alternative for disposing of excavated and dredged materials.
Similarly, MDPW and the City have failed to show that such filling
is unavoidable in order to cap the historic landfill or to create
a park. Indeed, the current record supports the opposite
conclusion.
The MDPW agrees that the 103 acre fill for which it seeks a permit
exceeds the amount necessary to cap the landfill. It has stated
that a minimum of 800,000 cubic yards of clay arid fill material is
needed to cap the landfill and that this would require filling 23
acres of the waters surrounding the Island. EPA is unconvinced
that 23 acres of filling in harbor waters is necessary to cap the
landfill and remediate the environmental problems at the Island.
Numerous questions must be answered before we can determine the
minimum amount of fill needed to accomplish this purpose. For
example, the dimensions of the landfill are unknown. MDPW has
assumed, but has riot yet documented, that the landfill extends
seaward from the eastern shore of the island approximately 200 feet
beyond mean high water. Until the areal extent and depth of the
landfill are determined, it is impossible to know the scope of the
problem. Also, we have questions regarding the nature of the
environmental hazards posed by the landfill. Even if the landfill
extends below mean high water, it is not clear that it is causing
harm to the aquatic ecosystem. If so, it may be possible to remove
the material rather than filling intertidal and subtidal habitat
to cap it. Similarly, while some data have been gathered
concerning the leachate, more information is needed to determine
the potential environmental harm. Also, we would need information
about the leachate contribution which would be expected from the
additional solid waste MDPW intends to place on the island.
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Finally, alternative ways to control the remaining leachate should
be studied.
Based on current information, M&E prepared a preliminary plan
(Attachment C, Section 2.0) to cap the existing landfill while
minimizing encroachment into the intertidal and subtidal areas
(i.e., a design which would comply with the §404 guidelines). It
is apparent that with appropriate re-grading of portions of the
existing steep landfill slope, and with the use of new steep slopes
and possibly some vertical sea walls, the encroachment into waters
of the United States could either be eliminated entirely or at
least significantly reduced below the MDPW’s stated 23 acre minimum
fill proposal. The M & E initial design, which may need to be
adjusted and refined as additional information becomes available,
would affect 37 acres of the historic landfill and less than 1 acre
of intertidal habitat below mean high water, which would be
converted to riprap slope. 9 This capping plan would accommodate
approximately 0.6 million cubic yards of material and would have
iniinal impact to the aquatic environment.
Finally, the applicants have failed to show that filling 103 acres
of waters around Spectacle Island is necessary in order to create
a park. There have been several state plans which discuss the use
of Spectacle Island as a park; none of them envisions substantial
filling of the waters. The 1967 Metropolitan Area Planning Council
(MAPC) plan does not call for any fill, bank stabilization or
capping to prepare for Spectacle Island’s projected use as an
“open, natural area for picnicking and other day-long recreational
uses.”° The 1972 MAPC-DNR plan, an outgrowth of the 1970 Islands
Park statute, called for compaction and a gradual vegetative
restoration program. A seawall was proposed at the toe of the
eastern dump slope. Future uses included nature trails and
boardwalks on the northern portion; boat facilities and playfields
in the middle; and potential small swimming areas on the southwest
beaches. No other fill or capping is suggested. 1 ’
The 1986 Boston Harbor Islands State Park Master Plan recommends
capping to remediate effects of the historic landfill, using clay
This does not involve capping the area underwater where it
is alleged that historic landfill materials have eroded. As noted
above, there is inadequate information to conclude that the
landfill extends under water or, even if it does, that it is
causing environmental problems which require remediation by capping
and the consequential loss of intertidal and subtidal habitat.
10 MAPC Open Space and Recreational Program for Metropolitan
Boston, Vol. 2, “Boston Harbor,” p. 36.
h1 MAPC-Department of Natural Resources “Boston Harbor Islands
Comprehensive Plan,” October 1972, p. 69.
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soil material from a public works project such as the CA/THT
project. In addition to capping, the conceptual plans suggest
filling against the eroding slopes, installing riprap, and creating
a salt marsh behind the riprap to add environmental habitat value
as well as a wetland water quality treatment system for leachate
coining from the landfill. Future uses would include a docking and
“arrival” area, nature trails and boardwalks, meadows, and a small
swimming beach on the southwest side. These plans do not appear
to contemplate substantial filling in waters around the Island in
order to achieve these goals. 12 Indeed, it appears that the
M & E plan referred to above would successfully accommodate a park
with features similar to those identified in the 1986 Master Plan.
As discussed above, it appears that landfill remediation and park
creation could be accomplished with far less fill than any of the
Spectacle Island alternatives presented in the DSEIS. However,
MDPW has suggested that disposing of a small volume of material at
Spectacle Island may not be cost effective on a per cubic yard
basis. In our view, it would be improper under the guidelines to
authorize filling harbor waters for landfill capping and park
creation beyond what is necessary to achieve those purposes,
because of the economics of the CA/THT project. We acknowledge
that in determining the practicability of alternatives, cost is a
consideration. However, cost is to be viewed from an objective
standpoint, not from the standpoint of the financial circumstances
of particular applicant. It is improper to reject a less
environmentally damaging alternative based on the applicant’s
assertion that it cannot afford the alternative, as long as the
alternative has a reasonable cost. It would be particularly
bizarre if such an analysis resulted in approving more fill than
necessary for the project purpose, and at a greater overall cost!
Even if this were a proper approach under the guidelines, we remain
unconvinced by MDPW’s unsupported assertions. It has not provided
any documentation to support the claim that small disposal options
would be too costly. MDPW would incur costs to send the materials
elsewhere if it abandons Spectacle Island; it is unlikely that the
incremental increase in the cost of going to the island would be
great, compared to the overall cost of the entire CA/TIlT project.
In addition, even if a small disposal scenario is not “cost
effective” for a transportation project, it may well be cost
effective for the landfill capping and park creation purposes. If
these are important priorities for the City and the State, these
goals might be achieved through the CA/THT project even if there
are poor economies of scale from the materials disposal standpoint.
The applicants have also failed to demonstrate that there are no
alternative ways to fund a small disposal option. For example, it
12 Department of Environmental Management Boston Harbor
Islands State Park, 1986 Master Plan, pp. 20—23.
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may be possible to devote for this purpose some funds from the sale
of air rights over the depressed artery. At worst, it may be
necessary for the City of Boston and the Massachusetts DEM to
contribute financial assistance.’ 3 (Indeed, the City already may
obligated under existing state solid waste laws to spend whatever
is necessary to cap the existing uncontrolled landfill.)
Finally, we think the question is more complex than just economies
of scale. There may be other reasons why it would be advantageous
for MDPW to spend the start up costs to establish barging
facilities at the Island, such as to facilitate handling peak
loads.
In conclusion, regardless of whether the landfill capping and park
creation are viewed as secondary benefits or distinct project
purposes, the filling of harbor waters cannot exceed the amount
demonstrated to be the least environmentally damaging practicable
alternative. MDPW has failed to demonstrate that filling 103 acres
of Boston Harbor is unavoidable for any of the project purposes.
2. The Proposed Filling of 103 acres of Boston Harbor Would
Cause or Contribute to Significant Degradation of Waters
of the United States .
a. Site Characteristics
Located on the western edge of the outer Boston Harbor, Spectacle
Island originally consisted of two drumlins connected by a tombolo.
The City of Boston gradually covered the tombolo with waste from
roughly 1920 to 1960. The shoreline consists of rocky intertidal
areas, coastal banks and beaches and a small area of high
saltmnarsh. Biologically productive intertidal and shallow subtidal
habitat populated by benthic macroinvertebrates and shellfish
surround Spectacle Island. Over 55 invertebrate species, including
soft—shell clams, extensive blue mussel beds, and lobsters 14 live
13 We note that the expected cost of landfill stabilization
is less than a third of the expected cost of park development ($3
million vs. $10 million), according to the 1986 Master Plan.
Presumably the City and/or DEN will need to obtain funding for the
park development: we see no reason why their funding request could
not be increased to encompass some or all of the costs of
stabilization if MDPW will not agree to carry out a small disposal
alternative.
14 MDPW has comninenced but not completed a lobster survey. The
presence of numerous lobster trap buoys within the vicinity of
Spectacle Island offers evidence of their presence in harvestable
numbers. For example, according to the NWRA, a 1-day count of
lobster pots located within 500 yards of the perimeter of Spectacle
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within the areas proposed for filling. A number of birds-—black
ducks, mergansers, and eiders to name a few——undoubtedly frequent
the intertidal and shallow waters around the island. Nearly four
dozen species of fin fish have been observed in Boston Harbor
waters. The DSEIS concludes that the same fish that inhabit other
parts of the Harbor should also be common around Spectacle Island,
including the winter flounder. Marine mammals such as harbor
porpoises and seals probably visit the proposed fill area
occasionally. The M & E report (Attachment C) discusses the
aquatic resources of Spectacle Island in greater detail.
Both soft shell clams ( Mva arenaria ) and blue mussels ( Mvtilus
edulis ) inhabit the intertidal areas. Mva occurs in low densities
because of the limited availability of soft bottom substrate which
the clam prefers. Nevertheless, the soft shell clam remains a
viable part of the benthic community of the Island and contributes
to its overall diversity. The organism contributes to the
secondary productivity of the benthos by providing food for diving
ducks, demersal fish, true crabs, horseshoe crabs, and moon snails.
Smaller predators such as the muinmichog prey on the young clams.
The blue mussel favors the cobble substrate surrounding the mid to
low tide level and exists in relatively high densities at the
Island. Mussel beds occur along the entire northern and eastern
shores of the island; a particularly large bed occurs to the
southeast near the southern drumlin. Mussels inhabit nearly 15
acres of the intertidal zone and extend well into the subtidal
area. Densities average 62 individuals/square foot with a high of
267/square foot. Because of their high density and wide
distribution, the mussels contribute more than any other species
to the secondary productivity of the lower intertidal areas around
the island. They provide food for diving ducks such as the common
eider, gulls, and fish such as tautog and cunner. Lobsters eat
them as do the lobsters preferred prey, Cancer crabs. The
extensive shellfish mats also create a multitude of microhabitats
for numerous organisms and burrowing opportunities for crabs and
lobsters. The results of the lobster survey of the waters
surrounding Spectacle Island may shed additional light on the value
of the subtidal areas.
Several bird species have historically bred at Spectacle Island
including glossy ibis, black crowned night heron, green backed
heron, snowy and great egrets. When present, these species would
likely use the marine habitat around the island as feeding grounds.
A 1984 survey revealed nesting pairs for one great egret, 40 snowy
egret, 60 night heron, and 10 glossy ibis (DSEIS, IIB 4-87). The
heron rookery was not occupied during the 1988 and 1989 breeding
seasons.
Island showed a total of 149 buoys (August 1989 Draft Materials
Disposal Program, Chapter 8, p. 8.4—27).
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The biological communities at Spectacle Island are normal for
Massachusetts Bay and do not appear adversely affected by past
disposal activities at the Island. The chemical composition of the
sediments in the area of proposed fill correspond to those in other
areas of Boston Harbor. Because of its close proximity to the
existing Boston Harbor wastewater and sludge outfalls and because
the sediments resemble those found in the rest of the harbor, the
project area reflects the prevailing condition of the harbor more
than pollution emanating from the landfill.
The benthic community at the Island is typical of New England urban
estuaries and indicative of a functioning, but moderately stressed,
benthic community. Although organisms such as Polvdora connuta,
Nepthvs spp. and tubificid worms commonly occur in stressed
environments, none of these species significantly dominates any of
the sampling stations. Nearly half the stations reported
codoiniriant populations of amphipods which characterize healthy
communities. Am elisca abdita , an organism sensitive to sediment
contaminants and often used as a barometer of sediment toxicity,
exists at the Island.
b. Significant Adverse Effects of Fill
The proposed filling of 103 acres of marine habitat in Boston
Harbor would cause or contribute to significant degradation of
waters of the U.S. in violation of the §404(b) (1) guidelines.
Section 230.10(c) states, in part, that “no discharge of dredged
or fill material shall be permitted which will cause or contribute
to significant degradation of waters of the U.S. Findings of
significant degradation shall be based on appropriate factual
determinations...with special emphasis on the persistence and
permanence of the effects....” The regulation then states that
effects contributing to significant degradation include, among
other things, “significant adverse effects” to fish, shellfish,
wildlife as well as aquatic ecosystem diversity and productivity.
We believe the impacts of filling 103 acres of aquatic habitat
would cause significant degradation within the meaning of the
guidelines. This is true from either an individual or cumulative
perspective. Even assuming for the sake of argument that the
project would not directly cause significant impacts, it
contributes to them, an outcome the regulations also prohibit. We
reach this conclusion after examining the quality and quantity of
the affected aquatic habitat, the direct and cumulative effects of
the fill, the persistence of the impacts, and the difficulty of
effectively mitigating the habitat loss that would result. MDPW
itself at one time appeared to recognize the potential seriousness
of the impacts at Spectacle Island. In the June 1988 Draft
Disposal Site Screening Report (p. 5—11), MDPW concluded that the
advantages of filling 62 acres of water around Spectacle Island,
“may be outweighed, however, by potential environmental impacts
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such as the loss of aquatic habitat, and by the high disposal Costs
associated with construction of the dikes.”
As noted earlier, MDPW’s revised proposal to destroy 103 acres of
marine habitat would be the largest permitted fill in New England
in the decade since issuance of the §404(b) (1) guidelines. The
sheer magnitude of the loss is itself a significant factor. In
addition, the record shows that the habitat at risk is not
depauperate, highly stressed or otherwise incapable of functioning
typically. The natural resource values of the area have been
independently verified by our own biologists, MDPW’s consultants
(see Aauatic Resources of Spectacle Is1and , Corte].l and
Associates), the Fish and Wildlife Service (July 17, 1990 letter),
and the National Marine Fisheries Service (C. Mantzaris, pers.
comm.).
The most severe impacts caused by the proposed fill would be among
those proscribed by §230.10(c) of the guidelines. Specifically,
the benthjc macroinverterbrates and shellfish that now live in the
103 acre fill area would be smothered and killed. Because the area
would be converted to fastland, there would be no opportunity for
these organisms to recolonize and so the impact would be
permanent.’ 5 Although fish and birds that now utilize the area may
escape direct mortality, the fill would destroy the existing
habitat for those species. In addition to the immediate impacts,
the value of the site for food web support, nutrient cycling, spat
export, and other functions of the estuary at large would be lost.
Although all the habitat that would be filled has value, the loss
of intertidal habitat particularly troubles us. Intertidal
habitat—-that area between mean low and mean high water-—is
relatively scarce to begin with and has historically suffered a
disproportionate share of adverse impacts. Past encroachments into
the harbor typically affect the intertidal zone first by replacing
the natural gently sloped habitat with vertical bulkheads or steep
riprap slopes.
Viewing the issue from a broader cumulative context reinforces our
concern about the significance of this impact. According to a
report entitled “Cumulative Impacts of Fill in Boston Harbor”
‘ 5 MDPW has stated that the riprap slope of the dike would
provide suitable habitant for marine species (even suggesting that
the acreage of new habitat will be greater than what is lost if
the interstitial pore space in the dike is counted). While the
dike would be colonized by some species, such as Fucus , periwinkles
and clumps of blue mussels, it would not even begin to replace
either the quantity or quality of the lost habitat.
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17
(Breiteneicher, 1988) ,16 approximately 3,200 acres of Boston Harbor
mud flats, saltntarshes and shallow waters have been filled since
the late 1700’s. While that finding is hardly surprising, it
illustrates how we have already squandered the majority of Boston
Harbor’s most valuable natural resources and the need to protect
the remainder from avoidable or significant losses. In addition
to habitat loss, the cumulative impact of past filling has resulted
in a loss of tidal prism adversely affecting the water quality
because of reduced flushing of the harbor waters.
An analysis of cumulative impacts should also take a prospective
view and we are mindful of the implications of this project for
future proposals to fill harbor waters for development or disposal
purposes. EPA and the Corps have consistently sought to minimize
impacts to harbor waters. EPA went to considerable lengths in the
MWR.A wastewater treatment siting EIS to avoid impacts to the
aquatic environment. EPA rejected options that would have involved
three acres of fill in Hinghain Bay at Nut Island or 20 acres at
Deer Island. The Corps, in its Saugus Pines River estuary
hurricane barrier project, eliminated three acres of in-harbor fill
because of environmental concerns.’ 7
In evaluating whether the adverse impacts of §404 discharges would
be significant, EPA considers whether compensatory mitigation could
reduce the impacts sufficiently to comply with the guidelines. In
this case, we believe it would be difficult to replace the lost
functions and values at Spectacle Island with confidence for
several reasons, including the scientific uncertainty associated
with successful recreation of shellfish habitat. A more fruitful
approach to achieving compliance with all aspects of the guidelines
16 Breiteneicher, Denise. Cumulative Impacts of Fill In Boston
Harbor. Prepared for Save Our Shores in Conjunction with Boston
Environment Department, Boston Shipping Department, Massachusetts
Coastal Zone Management Office and Massachusetts Port Authority.
April, 1988.
‘ 7 Several recent §404 cases also illustrate the successful
efforts to protect valuable marine habitat even when the initial
fill proposals had less significant impacts. The original proposal
by the Flatley Company to fill 3.3 acres of intertidal habitat in
the Mystic River was reduced to 1.8 acres. A more dramatic
reduction was achieved by the MDPW in the Salem—Beverly Bridge
project. The original project would have filled over 7 acres of
intertidal mud flat; the final plan calls for 0.75 acres of
permanent loss.
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18
would be to eliminate (or drastically reduce to the minimum
practicable) fill in the marine habitat around Spectacle Island. ’ 8
3. The Pro osa1 to Fill 103 Acres of Boston Harbor Violates
230.10(b of the Guidelines .
The Massachusetts anti-degradation policy expressed in 314 CMR
§4.04(1) states in part “the quality of the waters of the
Commonwealth shall be maintained and protected to sustain existing
beneficial uses.” This absolute protection guaranteed to existing
water uses by Massachusetts is taken directly from EPA’S water
quality standard regulation 40 CFR 131.12(a)(1). The existing
beneficial uses found in the proposed fill area include benthic
organisms, shellfish, lobsters and other fisheries. The
significant impacts associated with the proposed fill in 103 acres
of intertidal and subtidaj. areas would eliminate these existing
beneficial uses in contravention of the Massachusetts anti-
degradation policy. This would therefore violate §230.10(b) of the
Guidelines.
4. Public Interest Review Considerations
In addition to determining compliance with the EPA §404(b) (1)
guidelines, the Corps also conducts a public interest review
pursuant to its own regulations (33 CFR 320.4). No permit can
issue which the Corps determines would be contrary to the public
interest. As noted earlier, the issues discussed above should be
relevant to determinations under both the §404 guidelines
evaluation and the public interest review. In addition, the
overall project affects nearly all the factors considered in the
public interest review. One issue we believe you should evaluate
is the effect of the proposal to fill waters at Spectacle Island
in light of the broader concerns for the well being of Boston
Harbor.
MDPW’s proposed fill area at Spectacle Island lies within the
boundaries of the Boston Harbor Islands State Park. The enabling
legislation adopted the goals of conservation and recreation
(including the policy to prevent the destruction, exploitation or
neglect of the natural resources of the harbor islands) . The 1970
report of the Special Legislative Commission which proposed the
18 1f unavoidable adverse impacts to the aquatic environment
remained after thus revising the project, MDPW would need to
develop a compensatory mitigation plan in order to comply with
§230.10(d) of the guidelines. The nature and extent of the
mitigation plan would ascertained after completion of the
alternatives analysis.
19 Boston Harbor Islands Comprehensive Plan (Oct. 1972) under
C. 742 of the Acts of 1970, p. 18—20; 31; and 69.
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19
creation of the island park reveals that the legislature was
mindful of the threat of harbor fill:
Landfill could obstruct the tidal flushing action necessary
to remove pollutants, do permanent injury to marine life, or
interfere with shipping. Before additional areas of the
Harbor are filled, it is essential that the consequences of
such action be known. 20
Apart from the state’s action in setting aside an area for
recreation and conservation, Boston Harbor is an area of regional
and national significance and its resources merit special
protection. The MWRA’s substantial cleanup expenditures and EPA’s
major enforcement action testify to the high level of interest in
remedying past insults to the harbor. Although much of the effort
to date has focused on the major inflows of pollutants into the
system, incremental destruction of habitat could just as easily
frustrate reconstituting the harbor.
Conclusion
We object to issuance of a §404 permit for the CA/THT project as
currently proposed. By causing an avoidable and significant loss
of aquatic habitat, the project would violate the EPA §404(b) (1)
guidelines. We recommend that the MDPW modify its materials
disposal plan to eliminate or greatly reduce fill in the waters
around Spectacle Island as discussed above. We believe it is
entirely possible to redesign the proposal so that it both complies
with the requirements of the federal Clean Water Act and achieves
the project objectives of environmentally sound materials disposal
and remediation of Spectacle Island.
Our NEPA review letter providing additional comments on the project
and evaluating the adequacy of the DSEIS will be available by
September 22, 1990. In the meantime, feel free to call me or have
your staff contact Ed Reiner or Doug Thompson at 565-4421 if you
have any questions about this letter.
ie Belaga
Regional Administrator
Attachment
20 Second Interim Report of the Special Commission on the
Boston Harbor Islands, February 1970.
rel
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20
cc: Fred Salvuccj, Conun., MDPW
Wi1U.am Lawless, Chief, RB, USCOE
Joan Drake, USCOE
Daniel Greenbauxn, DEP
Thomas Bigford, NNFS
Gordon Beckett, USFWS
Janet McCabe, MEPA Unit
Jeffrey Benoit, MCZM
Richard Kendall, MDEM
William Twoxney, DPW
Ed Hammond, B/P/B
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ATTACHMENT A
Comments on CA/TNT Prolect Aspects Other Than Spectacle Island
1. Section 404 and Section 10 Issues
With exception of the material disposal issue, EPA has no objection
from a §404 standpoint to a tunnel being constructed across Boston
Harbor, including the placement of screeded gravel foundation
material and protection with rock and borrow backfill material.
This also includes the reconstruction of the existing seawalls at
Bird Island Flats in East Boston and the Boston Marine Industrial
Park in South Boston. Item No. 10 of the Corps Public Notice
describes a small (0.07 acre) corner of the General Ship Slip which
will be permanently filled to protect the Third Harbor Tunnel. EPA
has no objection to this small amount of permanent fill as shown
on sheets 22 and 23 of 38 of the public notice.
a. Fort Point Channel
Work in the Fort Point Channel consists of placement of 5.25 acres
of permanent underwater fill (conversion of bottom sediments to
concrete tunnel box) associated with the construction of the 1-90
Tunnel across the Fort Point Channel, and 3.1 acres of channel
bottom fill (conversion to upland) for the ramps and depressed
roadway portions of the 1-93/1—90 Interchange that lead to the
1-90 Tunnel. A portion of Vent Building No. 1 will be constructed
on the proposed permanent fill in Fort Point Channel.
Approximately 2,500 linear feet of existing granite block seawall,
will be replaced by a combination of granite block surfacing,
concrete and rip rap in the area of the proposed temporary casting
basin and the proposed 3.1 acre permanent fill.
In addition to the permanent fills, temporary fill is associated
with the construction of cofferdaxns along the Dorchester Avenue and
Gillette sides of the Channel. Other work in the Fort Point
Channel consists of the relocation of the existing Gillette water
intake north of the proposed 1-90 tunnel crossing, construction of
a temporary barge loading terminal and the temporary and permanent
modifications to numerous existing Fort Point Channel bridges.
The current plan appears to represent the least damaging
alternative of all previously studied alternatives with respect to
permanent alterations of Fort Point Channel. Nevertheless, EPA has
concerns that the impacts of the proposed telnp3rary and permanent
fills in the Channel may not be adequately mitigated.
According to the public notice and DSEIS, the top of the proposed
tunnel box across the Fort Point Channel will protrude seven to
nine feet above the level of the existing mudline, maintaining an
eleven foot depth of water below mean low water to the top of the
tunnel box structure (including armoring). Because the tunnel box
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will extend above the existing channel bottom, acting like a
submerged concrete weir, it will adversely affect water flushing
within the channel. Sediments will accumulate on the south side
of the tunnel box, Potentially leading to undesirable substrate
conditions which will require periodic dredging to maintain the
efficiency of the Gillette thermal discharge.
Because of changes in the hydrographjcs of the Fort Point Channel,
i.e., increased flow velocities due to areas of the channel being
constricted by fill, the DSEIS (Part 1. — Vol. 2 of 2 page 13—28)
states “additional studies and design of Channel protection
features such as riprap slopes or gabion will be performed during
the preliminary and final design phases.” The DSEIS also describes
the possible need for additional HEC-2 computer modeling run based
on the use of more recent depth soundings. Furthermore, studies
of the effect of the submerged tunnel box on the existing thermal
regime in the Channel are continuing (page 23—30). The DSEIS also
states on pages 13—28 and 13-29:
To partially mitigate these hydrographic and flushing
impacts, abandoned I iies ana piers in the work areas near
Dorchester Avenue will be removed, which will eliminate
certain obstructions to flow and will therefore enhance
flow and flushing, Riprap armor will mitigate for the
increase in flow velocities.
Mitigation measures described in the DSEIS in section 13.3 include
the relocation of the Gillette cooling water intake, and removal
of approximately 800 derelict piers, piles, and other structures
in 4.5 acres of Fort Point Channel to promote improved flushing.
EPA needs further information about the specifics of these
mitigation measures and the results of the studies mentioned above.
The nature of impacts on the Fort Point Channel will be better
understood once the thermal studies concerning the Gillette cooling
water discharge and other studies concerning the hydrographic
changes in Fort Point Channel are complete.
EPA is also concerned with the proposed temporary filling in the
Fort Point Channel along the Dorchester Avenue and Gillette sides
of the Channel. These structures, described in the public notice
as generally cofferdains, will be removed at the completion of
construction. As shown on sheet 13 of 38, the cofferdain would
narrow the channel to a minimum of only 30 feet. Increased
velocities in the constricted channel may be highly erosive to the
bottom substrate and the shoreline. The channel construction may
affect flushing and mixing characteristics with respect to upstream
discharges. EPA questions whether there may be ways to mitigate
for the lost channel cross-sectional area caused by both the
temporary and permanent fills.
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The Public Notice item No. 2 states that fill may be placed for the
construction in Fort Point Channel of the railroad bridges. EPA
would like further information on this aspect of the project.
Even with the inclusion of the mitigation measures mentioned in the
DSEIS designed to enhance flow and flushing, a net loss of aquatic
resources in the Fort Point Channel would result from the project.
The proposed plan would permanently convert 3.1 acres of Fort Point
Channel to new roads and a ventilation building. This 3.1 acres
of fill in the Channel includes the loss of 0.83 acre of intertidal
inudflat, and 0.06 acre of wetlands. The potential to widen the
Fort Point Channel by upland excavation to create additional
aquatic resources, for instance on the southern side of the
Channel, should be examined. If upland excavation is not feasible
within the Fort Point Channel, off-site, in—kind, or out—of-kind
mitigation can be considered.
b. Charles and Millers Rivers
Item No. 2 of the Public Notice describes that backfill material
and concrete wi’’ be placed for various bridge pier footings in the
Millers River, Charles River as well as the Fort Point Channel. 1
As the placement of the piers will be performed within the confines
of cofferdams, the direct adverse impacts to water quality will be
minimized if appropriate best management practices are used for the
work, including filtering sediments from cofferdam dewatering prior
to discharge back into the Charles or Millers Rivers. The bridge,
bridge piers and other associated work are the subject of a
separate U.S. Coast Guard permit application. It is unclear what
fill is under the jurisdiction of the Corps of Engineers. In any
event, EPA believes either the Corps or Coast Guard permit should
contain the appropriate best management practices.
From information contained in the DSEIS, we understand that new
bridge piers will be placed in the Charles River and Millers River
temporarily affecting 0.66 acre of existing river bottom in the
Charles River and 0.29 acre of river bottom in the Millers River.
The existing 0.44 acre wetland in the Millers River would be
removed during construction, and replaced with shade tolerant
species after construction.
‘The DSEIS contains conceptual plans for relocating the
Millers River as mitigation for the impacts associated with the
construction of the ramp system. This is not discussed in the
public notice and needs to be addressed as part of the Corps review
since a relocated river implies that the existing Millers River
would be filled.
111
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The impact of the project on the Millers and Charles River is not
limited to the temporary construction of cofferdains for bridge pier
construction, or the permanent displacement of river bottom by the
bridge piers themselves. The proposed three bridges over the
Charles River and the maze of roads and ramps above the Millers
River will cause shading impacts to 1.23 acres of the Millers River
and 4.38 acres of the Charles River. These indirect impacts will
adversely affect the proposed MDC park along the north side of the
Charles River and the aquatic biology of the rivers themselves.
The large highway viaduct structures in this area % iill create
traffic noise and shadows, thereby reducing the potential
attractiveness of the park under them.
In addition, the proposed configuration of bridge piers in the
Charles River will likely create an impediment to safe navigation
at this important gateway to the Charles River. EPA questions
whether there is any environmentally preferable alternative to the
proposed construction of viaducts and ramps at this location.
While the temporary construction impacts to the Charles River of
“Option T Modified” would be greater than the proposed action, the
permanent impacts of the overhead structures associated with
“Option T Modified” on park and river use are of lesser magnitude.
2. Ocean Disposal Issues
EPA has concerns relative to the proposed ocean dumping of dredged
material from the project. Additionally, we have addressed the
acceptability of excavated material for ocean disposal based on the
floatability tests.
a. Dredged Material
i. Fort Point Channel
If the sediments from the Fort Point Channel are proposed for ocean
disposal, we believe that they should be retested according to the
revised dredged material testing protocol. First, the chemical
data from these sediments show high levels of contamination and
appear to demonstrate the potential to cause an adverse biological
effect. In particular, we recommend a flow—through bioassay using
the ainphipod, Ampelisca abdita , which is very sensitive to the
presence of pollutants in dredged material; Nacoma sp., a deposit-
feeding bivalve, which will represent maximum bioaccuinulation
potential for the sediment contaminants, including PANs; and Nereis
. ., a ileposit—feedinc, worm. As indicated in the regic... l dredged
material testing protocol, bioaccuinulatiofl testing would not be
required for Ampelisca .
Second, the most recent data we have is from the 1982 DSEIS. This
outdated data may not accurately reflect current degrees of
contamination. The nature of the sediments may have changed
because the incidence of spills and effluents discharging into the
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area. Additionally, substantial advancements in testing
methodologies have been made in the past eight years.
Page IIB 4-21 incorrectly states that 140,000 yd 3 of dredged
material from the Fort Point Channel may be suitable for ocean
disposal. This statement cannot be supported until bioassays have
been conducted.
Additionally, although the amounts were not quantified, the Soil
Characterization Report (May 1989) indicated the presence of
cinders which appear to be floatable in these sediments composed
largely of historic fill. If this material is classified as
dredged material, ocean disposal may present a floatability
problem. Since we do not have sufficient information regarding the
quantities of floatable materials present in the fill, we cannot
determine compliance with the ocean dumping regulations.
According to the public notice, one million cubic yards of dredged
material would be removed from existing lands adjacent to the Fort
Point Channel for construction of the graving basin. As this
material is currently not below Mean High Water, but rather
isolated from the Fort Point Channel by a sea wall, EPA considers
this to be excavated material rather than dredged material. We
will need further clarification regarding the relative quantities
above and below the high water mark. An additional one million
cubic yards of material is also not dredged material in the
ordinary sense. This material is coming from the excavation of
present upland primarily at Bird Island Flats on Logan Airport in
East Boston and the Boston Marine Industrial Park area in South
Boston where the Third Harbor Tunnel will meet land. At least at
the East Boston Bird Island Flats area on Logan Airport and in
South Boston at the Boston Marine Industrial Park, according to the
DSEIS (Appendix Vol 4 of 5, page 9) normal methods of land
excavation would be utilized to bring the level of the land to the
tide level, where the remainder of excavation is proposed to be
performed by a large clamshell dredge.
ii. Third Harbor Tunnel
Since the alignment has changed, MDPW must demonstrate that
material along the new alignment is also suitable for ocean
disposal.
Based on historical test data compiled in our Boston Harbor data
management system, the presence of outfa]]s, ound ate”
discharges, runoff, and other contaminant sources, we believe that
the sediments along the proposed alignment should be retested
because they could be more contaminated than previous test data
indicates. We suggest that Tier II chemical testing be performed
on sediments along the proposed alignment. We believe this should
be done without compositing because of the spatial variability
evidenced in historical data. Based on this analysis we will
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jointly review this data and determine the need to proceed with
biological testing.
iii. Charles and Miller’s Rivers
The preferred disposal options for these sediments were not clearly
presented in the DEIS. If they are proposed for ocean disposal,
we recommend that biological testing be conducted as the bulk
sediment analysis demonstrates the potential to cause unacceptable
biological effects.
b. Floatables in Historic Fill
The regulations at 40 CFR §227.5(d) prohibit the ocean dumping of
anything that will materially interfere with legitimate uses of the
ocean. Section 4.8.3(a) appears to eliminate the ocean disposal
alternative from further consideration based on this prohibition.
As discussed at previous meetings with MDPW, EPA does not
necessarily endorse the floatability tests performed on the
excavated fill. We believe that the analyses may be overly
conservative and therefore may overpredict the potential for
material to float. However, considering these test results, the
soil boring logs, historical records of filling in the areas, and
the amount of material to be generated, we are convinced that there
may be enough of a floatability problem to cause an adverse effect
to the marine environment. In particular, we are concerned that
floatables would adversely affect the foraging of the severely
endangered right whale and impair recreational uses of the area
such as whale watching. Consequently, we accept MDPW’s
recommendation not to consider further the ocean disposal option
for the historic fill material.
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ATTACKMENT B
LIST OF INFORMATION AND DOCUMENTS YET TO BE RECEIVED
1. New bulk sediment chemistry analysis and grain size
distribution for the THT alignment using the current regional
testing protocol (see Attachment A).
2. Bioassay/Bioaccuinulation testing results for all of the
proposed dredging within the Fort Point Channel.
3. A clear representation of which areas will be dredged from the
Fort Point Channel and proposed for disposal at the
Massachusetts Bay Disposal Site. Additionally, a diagram
depicting where the dredged material which was considered by
MDPW to be unacceptable for ocean disposal is located
accompanied by MDPW’s plans for its disposal.
4. The DEIS in Part II, Section 4.2.4(b), on page IIB 4—21 stated
the results of which additional sampling and analysis would
be performed for the 925,000 cubic yards of dredged material
to be removed from East and South Boston for the Third Harbor
Tunnel and in the Fort Point Channel.
5. The results of the Lobster survey surrounding Spectacle
Island. This information was not included in the Draft
version of the report received June 25, 1990 entitled “The
Aquatic Resources of Spectacle Island” A note on the cover
of the report stated: “A section of lobster surveys will be
added to this report before it is finalized.
6. Bioassay/bioaCcUTflUlatiOfl tests for the material to be dredged
around Spectacle Island in relation to the installation of the
proposed dikes if ocean disposal is being proposed rather than
upland disposal.
7. A report cited in an Appendix as “Slope Stability and Related
Design and Construction Considerations” by Bechtel/Parsons
Brinkerhoff dated March 1989.
8. Thorough evaluation of alternative sites to Spectacle Island
for disposal of materials in accordance with the 404(b) (3.)
guidelines. An evaluation regarding the practicability size
limit and accompanying cost analysis should be included for
each of the alternatives.
9. Detailed justification regarding the basis for rejection of
the use of rail transport for dredged or excavated material
to upland disposal sites other than the hypothetical Conrail
and Pennsylvania coal mine alternative should be included.
10. Report concerning the studies of the effect of the submerged
tunnel box on the existing thermal regime in the Fort Point
Channel related to the Gillette cooling water intake and
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discharge. Any additional reports or studies concerning the
hydrographic changes in the Fort Point Channel and the
proposed mitigation measures including details concerning the
removal of approximately 800 derelict piers, piles and other
structures in the Fort Point Channel.
11. Details Concerning any proposed compensatory mitigation
including but not limited to the following:
a) The proposed two acre salt marsh creation on Spectacle
Island;
b) The restoration of the existing Millers River wetlands
with shade tolerant species, or the complete relocation
of the Millers River;
c) Mitigation for losses of intertidal and subtidal aquatic
habitat of f Spectacle Island; and
d) Mitigation for permanent losses of aquatic habitat in
Fort Point Channel including the degradation in sediment
quality expected to result as a result of the submerged
tunnel box wejr.
12. Additional information on options being considered for
disposal of 31,000 tons of Category 5 debris (“unsalvageable
metal”, p. 20-7, DSEIS), especially the feasibility of
constructing an artificial reef and potential environmental
impacts from the lead-based paint on the reef, and the
feasibility of stripping and salvaging the metal for reuse.
13. The report entitled “Numerical Modeling Studies of the Water
Quality Impact in Boston Harbor” dated May 1990.
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( tP4p
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
,, J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211
September 24, 1990
Anthony Fusco
Division Administrator
Federal Highway Administration
55 Broadway, 10th Floor
Cambridge, MA 02142
Dear Mr. Fusco:
The Environmental Protection Agency, in accordance with its
responsibilities under the National Environmental Policy Act (NEPA)
and Section 309 of the Clean Air Act, has reviewed the Draft
Supplemental Environmental Impact Statement (DSEIS) for the
proposed Central Artery (1-93)/Third Harbor Tunnel (1-90) project.
These statutes require that EPA, from the standpoint of its areas
of jurisdiction and expertise, formally comment on the
environmental impacts of the project and the adequacy of the
environmental analysis as presented n the DSEIS that was filed in
May of 1990. The results of our review are detailed below and in
the attachments to this letter. However, since the filing of the
DSEIS, there have been a number of positive discussions between the
EPA, the Federal Highway Administration (FHWA), the Massachusetts
Department of Public Works (MDPW), and other agencies. Additional
information has been developed, and on the basis of this, we are
hopeful that the concerns we are required to formally present in
this letter will be resolved. I have attached a copy of a
September 10, 1990, letter to me from Secretary Fred Salvucci and
MDPW Commissioner Jane Garvey that contains specific expectations
for project improvements in several areas bf concern to EPA. We
believe this indicates progress towards resolution of EPA’S
concerns.
The May 1990 DSEIS describes the MDPW’s $5 billion proposal to
construct approximately 7 miles of roadways in Boston, the key
elements of which are a widened, mostly underground Central Artery
(1-93); an extension of 1-90 via a Seaport Access ‘Road and Third
Harbor Tunnel to Logan Airport in East Boston; and extended
frontage roads along the Central Artery and Southeast Expressway.
(The proposal also includes a new South Boston Haul Road for which
a separate EIS was prepared. EPA’S conunents on the Final EIS for
the Haul Road are being submitted today in a separate letter). The
DSEIS, the fifth in a series of EISS that began in 1982, is
PRINTED ON RECYCLED PAPER
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2
intended to address issues that were left unresolved at the time
the Final EIS was issued in 1985 (see Appendix 1).
The project has multiple public goals which are, in essence, to
improve traffic flow in the Boston metropolitan region and to do
so in a manner which pet its a more livable city, reconnected to
its waterfront and without the barrier that the elevated Central
Artery now poses. The project also has the potential to bring
other environmental benefits: to improve air quality; to remediate
any harm that may be occurring as a result of the historic landfill
on Spectacle Island; and to create a park on the island.
EPA supports these objectives and recognizes the importance of
their fulfillment. As the SDEIS recognizes, this project, by
virtue of its enormity and its location, raises substantial
environmental concerns, which EPA has addressed in numerous
meetings and letters throughout the project’s history.
In summary, EPA does not object to the proposed project as a whole.
We do, however, believe that certain key elements of the project
as proposed in the DSEIS would cause adverse environmental impacts.
These impacts are of sufficient magnitude that the project should
not proceed until they are resolved in the FSEIS in accordance with
the substantive requirements of the Clean Water Act, NEPA, and,
potentially, the Clean Air Act. We further believe that the DSEIS,
while comprehensive in some areas, does not fulfill NEPA’s
requirements for disclosure of significant environmental impacts
and evaluation of less damaging alternatives. We are pleased,
however, as mentioned above, that MDPW and others are already
working to fill these information gaps in the FSEIS.
EPA’S principal concerns are as follows:
1) The materials disposal program, described as the preferred
alternative in the DSEIS and in current applications for federal
permits, would place significant amounts of dredged and excavated
material in 103 acres of Boston Harbor surrounding Spectacle
Island. In its review of the Corps of Engineers’ public notice,
EPA concluded that this fill would violate Section 404 of the Clean
Water Act, particularly the regulatory requirements concerning
alternatives and significant impacts. Similarly, we conclude that
the fill proposal in the DSEIS would violate parallel requirements
under NEPA that agencies fully assess all reasonable alternatives
and use all practicable means to avoid or minimize any possible
adverse effects (Council on Environmental Quality ‘Regulations at
40 CFR 1500.2(e) and (f)). (A copy of EPA’s July 31, 1990 comments
under Section 404 is included at the end of Appendix 3).
We note, however, that during the months since the DSEIS and the
public notice were issued, the MDPW has been making a serious
effort to respond to our objections to the proposed 103-acre fill
in the Harbor. For example, the MDPW has identified portions of
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3
the project where excavated material can be minimized or re-used.
Further, the MDPW is re-evaluating upland disposal sites and is
examining the size and impacts of the island landfill. We are
optimistic that there will emerge from this effort a number of
sites that alone or in combination would be less environmentally
damaging, reasonable alternatives to the 103-acre fill at Spectacle
Island. We are therefore hopeful that the MDPW will ultimately
submit a revised materials disposal plan which satisfies the
requirements of the Clean Water Act and NEPA.
2) The DSEIS does not discuss the potential for adverse effects
to public health due to high levels of carbon monoxide from the
currently proposed ground-level ventilation exhaust from the Dewey
Square tunnel portal in the vicinity of Chinatown. To ensure
compliance with the Clean Air Act and NEPA, the FSEIS must quantify
this impact and evaluate the effectiveness of options for ensuring
that no violations of applicable air quality standards will occur.
3) The DSEIS does not evaluate the potential for adverse air
quality impacts from exposure to high levels of truck and
automobile exhausts throughout downtown Boston during the 8-10
years of project construction. The DSEIS mentions the potential
for major construction—related impacts to cause elevated levels of
carbon monoxide at 34 locations in Boston, but defers the
evaluation of air quality impacts and mitigation planning to a time
after completion of the EIS process. Because of the potential
seriousness of this impact and the large numbers of people who
would be exposed to it, the FSEIS must identify the key locations
that will be impacted by construction activities and quantify
predicted air quality impacts.
We are also concerned that the DSEIS does not adequately identify
construction-phase mitigation measures that the MDPW had promised
to include. A further evaluation of such measures must be included
in the Final SEIS. Moreover, since some mitigation measures from
the Maintenance of Traffic Plan and the Construction Mitigation
Program will not be finalized until after the EIS process is
completed, the FSEIS must also define future air quality
commitments and commit to the inclusion of EPA in a process that
will insure that these commitments satisfy air quality criteria
and are implemented in a timely manner.
4) One of the most serious long—term environmental policy issues
involved in the Central Artery decision is how to increase the
likelihood that the construction of the Cent ral Artery is
accompanied by an array of mass transit improvements and regulatory
actions sufficient to permit the project to succeed in its
purposes: to avoid traffic strangulation and to permit a more
liveable city. Dramatic changes in intra—city and inter—city
transportation are required, along with farsighted control over
such growth and traffic generators as new infrastructure and land
use.
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4
The FSEIS must commit to treat mass transit improvement as an
integral part of the project. There must be a commitment to a
reasonable group of mass transit projects and transportation
control measures and to a process (that viii include EPA) to
determine that the projects viii be done and the promised
improvements viii be achieved.
The Executive Office of Transportation and Construction has a long
record of commitment to mass transit. The upgrading and expansion
of mass transit, however, viii be as difficult as implementing the
Central Artery project itself. We fear that, in an era of fiscal
and government retrenchment, the steps viii not be taken to change
the transit mix from a reliance on the private automobile to a mix
relying on mass transit. Many public comments reflect this sense
of urgency and a sense of unease that these “other” projects will
fail by the wayside and the Central Artery viii dominate the
transportation agenda.
Therefore, we expect that the FSEIS viii contain commitments,
linked to the policies of other state cabinet offices through the
Massachusetts Environmental Policy Act process, to schedules of
mass transit improvement and associated transportation control
measures. The first category would be to assure the completion of
those projects the success of which is assumed in the air quality
modeling that predicts pollution improvements as a result of this
project. The second would be an aggressive program of
construction-period transit—enhancing measures, with the commitment
to continue successful measures on a long term basis. The third
category would be the design of features, such as NOV and carpool
lanes, and fringe parking, which could be built into or with this
project to provide long-term benefits. The fourth program should
be one of farsighted regulatory and environmental review actions
to prevent unplanned growth from cancelling the traffic capacity
benefits of the project and thus frustrating its purpose.
EPA is committed to use its regulatory authority, through the
Massachusetts State Impiementation Plan (SIP) for air pollution
control, to assist in meeting these objectives.
Furthermore, we encourage FHWA to take a creative approach to
evaluating the myriad mitigation and environmental enhancement
measures which would be appropriate for a project of this
magnitude. FNWA’s new Environmental Policy Statement (April 1990)
places emphasis on “avoidance, minimization, and mitigation of
environmental impacts,” and places special emphasis on “the need
to consider environmental enhancement measures.” In addition to
the mitigation measures identified above, we see an opportunity,
consistent with the new policy, for FHWA to ensure that any
environmental harm posed by the historic fill on Spectacle Island
will be remediated and that the island will be transformed into a
public park.
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5
The attachments to this letter detail these concerns as Well as
others, such as the need for additional analysis of the impacts of
and alternatives to the proposed Scheme Z design for the crossing
of the Charles River Reservation and of secondary effects from the
future development of the 27 acres on top of the depressed Central
Artery.
In accordance with EPA’s national rating system, an explanation of
which is attached in Appendix 2, we are required at the Draft EIS
stage to assign a rating to the environmental impacts of the
proposed action described in the EIS, and to the adequacy of the
EIS. We have rated this DSEIS “EU--Environmentally Unsatisfactory”
and “2--Insufficient Information.” it should be noted that we are
required to rate the project based on the information in the DSEIS
provided by the FHWA and MDPW in May, 1990. Since that time,
however, a series of meetings has been held that should result in
important improvements to the project and should address the
concerns that we have raised. As we receive this information, we
will review it promptly and expect that it should be incorporated
in the final SEIS. This “EU-2” rating is appropriate in cases
where the proposed action has the potential to cause a substantive,
long term violation of a federal environmental standard, as would
occur under Section 404 if the MDPW were to pursue the 103-acre
Harbor fill, and where the DSEIS does not contain sufficient
information to fully assess environmental impacts that should be
avoided, such as the air quality concerns above.
We are pleased at the positive steps and the cooperative effort
that have taken place over the past few months. The issues we have
raised are being discussed but do require resolution in the FSEIS.
We believe that they can be resolved and an environmentally sound
project achieved. My staff and I are committed to working with the
FHWA and the MDPW to that end.
e Belaga
egional Administrator
cc: Frederick Salvucci, Secretary
Executive Office of Transportation and Construction
erely,
Enclosures
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APPENDIX I
SIGNIFICANT ISSUES THAT WERE UNRESOLVED IN ThE 1985 FEIS .
Source: Third Harbor, Interstate 90/Cerrtral Artery, Interstate 93 FInal
Environmental Impact Statement and Final Section 4(1) Evaluation; Volume I
FHWA/MA DPW August, 1985, pages kvl and xvii.
Sections where the issues appear in the FEIS are identified in parentheses .
(1) The extent of federal-aid construction funding for sp cffic project Components of
the Preferred Afternative (6.1, 6.2).
(2) Selection of the materials for sunkeh tube tunnel construction: concrete or steel
(4.1).
(3) Selection of tunnel fabrication site, including additional analysis as needed (4.1).
(4) Selection of site(s) for replacement parking (4.2, 4.4).
(5) Identification of disposal sites for excavated and dredged materials (4.13).
(6) Design of the new bridges and ramps across the Charles River, and analysis of
their effects on Charles River Reservation, including existing and proposed MDC park
facilities, navigation, traffic on Storrow Drive, BRA North Station plans, etc. (1.4, 4.2,
4.9, 4.10, 4.11, 4.14, 4.16, 5.1, 5.2).
(7) Approvals of all required Federal, State, and local permits necessary for project to
proceed (no specific section).
(8) Identification of appropriate staging areas for construction (4.1).
(9) The establishment of process to assure environmentally-sensitive future joint
development activity with full citizen and agency participation (4.4).
(10) Construction impacts on traffic, air quality and noise levels in the project area
(4.2, 4.7, 4.8).
(11) Location and height of ventilation buildings (4.4, 4.5, 4.7, 4.14, 4.16).
(12) The extent of work for the Phase I, Step 2/Phase II Archaeological Survey and
final mitigation details for impacts on archaeological resources, consistent with the
Section 106 Memorandum of Agreement (4.14, 5.3).
(13) Construction staging and sequencing of the project (4.1).
(14) Further study of business relocation impacts, including a case by case analysis of
whether specific privat facilities will be taken or modifIed (4.3).
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APPENDIX 2
SUMMARY OF RATING DEFINITIONS AND FOLLOW-UP ACTION
Environmental ImDpct of the Action
LO--Lack of Objections
The EPA review has not identified any potential impacts requiring substantive changes to the proposal
The review may have disclosed opportunities for application of mitigation measures that could be
accomplished with no more than minor changes to the proposal.
EC—Environmental Concerns
The EPA review has identified environmental impacts that should be avoided in order to fully protect
the environment. Corrective measures may require changes to the preferred alternative or application
of mitigation measures that can reduce the environmental impact. EPA would like to work with the lead
agency to reduce these impacts.
EO—Envlronmentat Objections
The EPA review has identified significant environmental impacts that must be avoided in order to
provide adequate protection for the environment. Corrective measures may require substantial
changes to the preferred alternative or consideration of some other project alternative (including the
no action alternative or a new alternative). EPA intends to work with the lead agency to reduce these
impacts.
EU--Environmentally Unsatisfactory
The EPA review has identified adverse environmental impacts that are of sufficient magnitude that they
are unsatisfactory from the standpoint of public health or welfare or environmental quality. EPA intends
to work with the lead agency to reduce these impacts. If the potential unsatisfactory impacts are not
corrected at the final EIS stage, this proposal will be recommended for referral to the CEO.
Adeouacy of the Imoact Statement
Category 1--Adequate
EPA believes that draft EIS adequately sets forth the environmental impact(s) of the preferred
alternative and those of the alternatives reasonably available to the project or action. No further
analysis or data collection is necessary, but the reviewer may suggest the addition of clarifying
Janguage or information.
Category 2 -- Insuflicient Information
The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that
should be avoided in order to fully protect the environment, or the EPA reviewer has identified new
reasonably available alternatives that are within the spectrum of alternatives analyzed in the draft EIS,
which could reduce the environmental impacts of the action. The identified additional information, data,
analyses, or discussion should be included in the final EIS.
Category 3--Inadequate
EPA does not believe that the draft EIS adequately assesses potentially ‘significant environmental
impacts of the action, or the EPA reviewer has identified new, reasonably available alternatives that are
outside of the spectrum of alternatives analysed in the draft EIS, which should be analyzed in order
to reduce the potentially significant environmental impacts. EPA believes that the identified additional
information, data, analyses, or discussions are of such a magnitude that they should have full public
review at a draft stage. EPA does not believe that the draft EIS is adequate for the purposes of the
NEPA and/or Section 309 review, and thus should be formally revised and made available for public
comment in a supplemental or revised draft EIS. On the basis of the potential significant impacts
involved, this proposal could be a candidate for referral to the CEO.
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Appendix 3, Page 1
Table of Contents
A. NEPA and Clean Air Act Comments on Air Quality Issues.
i. Ground Level Emissions from the South Portal.
ii. Construction Impacts.
iii. Emissions from Vent Shafts.
iv. Promoting Mass Transit.
v. Post—Construction Impacts.
vi. Operational Commitments: CarbonMonoXide in Tunnels.
vii. Technical Comments.
B. Other Issues Pertinent to the National Environmental
Policy Act.
i. General NEPA requirements, including mitigation.
ii. Disposal of excavated and other materials.
iii. Cunulative impacts of harbor fill.
iv. The proposed recreation area at Spectacle Island.
v. The secondary impact of the future development of
land occurring as a result of this project.
vi. Tunnel fabrication site(s).
vii. Cross Town Boulevard.
viii. The Charles River Crossing.
C. NPDES Permitting Issues.
D. Section 404 Issues.
i. Summary of EPA’S July 31, 1990 Findings under
Section 404.
ii. Description of Interagency Discussions Subsequent
to Corps’ Section 404 Public Notice.
Attachment: Text of EPA’S Letter of July 31, 1990
concerning Section 404.
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Arpendix 3, Page _ i
A. NEPA AND CLEAN AIR ACT COMMENTS ON AIR qUALITY .
i. Ground Level Emissions from the South Portal.
ii. Construction Impacts.
iii. Emissions from Vent Shafts.
iv. Promoting Mass Transit.
v. Post—Construction Impacts.
vi. Operational Commitments: Carbon Monoxide in Tunnels.
vii. Technical Comments.
This DSEIS was intended to fulfill a commitment made by FHWA and
the MDPW in the 1985 FEIS to address in a draft supplemental EIS
fourteen issues left unresolved at the time the FEIS was approved
(including those related to construction impacts, vent locations
and impacts, and long term air quality) as well as any other issues
that have surfaced in the intervening years.
i. Ground Level Emissions from the South Portal of the
Central Artery.
The MDPW intends to connect the new Central Artery tunnel at its
southern end to the existing tunnel section at South Station (Dewey
Square). The DSEIS, however, does not evaluate the air quality
impacts from this tunnel section and portal emissions either on the
south portal or on the adjacent vent system to the north.
Emissions from this ventilation system are of particular concern
because they are released at ground level and may cause air quality
violations.
The FSEIS must include an evaluation of the air quality impacts
from this tunnel section. This analysis must be submitted to EPA
for review and comment as soon as possible and prior to the
submission of the FSEIS.
ii. construction Impacts on Traffic and Air Quality.
One of the significant unresolved issues from the 1985 FEIS was
the need to identify construction impacts on traffic, air quality
and noise. Despite the MDPW’s commitment in the FEIS, however,
the DSEIS fails to show that impacts due to construction will not
cause air quality problems. Indeed, the DSEIS states that
approximately 34 intersections (including the Leverett Circle
underpass; the Sumner-Callahan Tunnel approaches; the Leverett
Circle/CA ramps) are expected to be impacted by construction
activities. The DSEIS also identified 60 major detours and
road/bridge crossings (Chapter 20, page 27). Construction
activities are expected to occur over a ten-year period and will
impact high volume roadways as well as congested intersections.
The FSEIS must identify the key locations that will be impacted by
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Appendix 3. Paae 3
construction activities and quantify predicted air quality impacts.
Moreover, the air quality analysis contained in the DSEIS is
dependent upon traffic mitigation nieasures being implemented
before, during and after the construction phase. Many of these
mitigation measures have yet to be fully developed. While the
DSEIS describes and commits to implement several traffic mitigation
measures, it relies primarily on its commitments to establish a
process (the Maintenance of Traffic Plan), which is intended to
encourage transit ridership, improve traffic management and provide
public information. This Plan is to be part of the Construction
Mitigation Program, which will oversee the development and
implementation of all construction—related traffic mitigation
measures. The DSEIS commits to use the Construction Mitigation
Program to re—evaluate traffic and construction impacts as the
details of construction are developed or changed.
The construction mitigation measures must be evaluated in the FSEIS
itself so that a determination as to the acceptability of
construction impacts can be made. NEPA requires that EISs disclose
impacts so that alternative mitigation measures can be evaluated
for their potential effectiveness and the likelihood that they will
be implemented. To the extent that agencies (e.g., the City of
Boston) other than the project proponent will be responsible for
their implementation, it is important for the FSEIS to discuss the
ways in which the public will be assured of their implementation.
Many additional mitigation measures from the Maintenance of Traffic
Plan and the Construction Mitigation Program will not be developed
or finalized until after the EIS process is completed. Therefore,
EPA requests that a formal document be executed with EPA that
defines the commitments made to satisfy air quality criteria,
provides for their implementation in a timely manner and includes
EPA involvement.
Issues to be addressed in the document could include the following:
- Traffic Detour Management
- Maintenance of Traffic Planning
- Traffic Surveillance and Control Systems
— Construction Management Planning
— Construction Mitigation
- Ambient Tunnel Monitoring
- Vent Stack Monitoring
The FSEIS should also respond to the following issues related to
construction impacts:
Section 20.2.1(b) on page 20 to 22 of Chapter 20 states that
“workers will be required to park in facilities away from the
work area, use public transportation, or park in the
contractor remote parking area and be bused to and from the
work site.” The location of the contractor remote parking
areas, as well as any additional remote parking areas to be
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At pendix 3. Page 4
used by workers or cornii uters, needs to be described in the
FSEIS.
Section 2.7 on page 17 (Appendix 4 of 5) lists several
mitigation measures as temporary solutions to the loss of
parking spaces. Procedures to select measures to be
implemented must be described in the FSEIS. After the
appropriate measures have been implemented, there should be
an evaluation to determine whether any measures would continue
to be effective in reducing vehicle-miles-travelled (VMTs)
(such as remote parking lots) if they were made permanent.
Section 2.2.2 on page 3 (Appendix 4 of 5) states that “close
coordination will be maintained with MBTA, Amtrak, and Conrail
during construction of the South Boston Bypass Road viaduct
over existing active transit and railroad tracks”. Procedures
to implement this should be described in the FSEIS.
Coordination among these agencies should include increases in
service on lines that serve areas whose roadways will be
impacted by construction.
Section 2.4.4 on page 6 (Appendix 4 of 5) discusses expansion
of alternative modes of transportation. The FSEIS should
describe the process that will be used to evaluate and
implement these activities.
Section 2.6.3 on page 9 (Appendix 4 of 5) discusses emission
abatement measures for construction activities. Control of
fugitive dust emissions during• construction is important
because of the close proximity of the general public to the
proposed project. Procedures should be created to identify
and reduce excessive fugitive dust emissions during
construction.
Section 4.3 “Pollutants for Analysis” on page 4—6 of Chapter
4 fails to note that the project may generate greater P1110
(small particulate) emissions from construction activities
and entrainment by vehicular traffic than could result from
tailpipe emissions. PM1O emission inventories often neglect
such activities; but when they do not, PM1O from entrained
road dust often dominates emissions from other sources. The
FSEIS must include an air quality analysis of P1110 emissions
from temporary construction activities and planned changes in
the highway system. EPA’S Control of ODen Fugitive Dust
Sources (EPA—450/3-88-008) should be used to estimate P1110
emissions from open sources and identify applicable control
measures.
iii. Emissions from Ventilation Buildings.
Section 8.5.3 on page 8-16 states that seven buildings are required
to house the equipment necessary to ventilate the project’s
tunnels. According to page 9-15, the stack heights as described
,in the DSEIS (see table below) are “maximums”, which could be
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Page 5
reduced as a result of more detailed analysis during the design
process.
Vent 2. Dorchester Ave. 320’w x 80’d x 9o’h 130’ stack height
Vent 2 Frontage Rd. 160’ x 135’ x 80’ 220’ stack height
Vent 3 Atlantic Ave. Below grade 240’ stack height
Vent 4 Parcel 7 Entire parcel x 80’h 125’ stack height
Vent 5 Summer St. (exh.) 120’ stack height
(2 bldg.) (mt.) 210’ x 150’ ___ 120’ stack height
Vent 6 Subaru Terminal 200’ x 130’ x 75’ 115’ stack height
Vent 7 Bird Island Flats 310’ x 100’ x 65’ 95’ stack height
Dewey Square Vent(s) stack height(s)
While extensive air quality modeling has already been conducted
for the ventilation stacks, changes in the design of stack heights
would require new air quality analyses. The air quality analysis
in the DSEIS states that future design changes in the vent
buildings will be evaluated at that time. If and when such changes
are made, EPA must be able to review, comment and concur on the
acceptability of design changes. EPA must concur in any new
ventilation stack — air quality analysis associated with changes
in the ventilation systems.
In addition, we request that the FSEIS include the following: an
analysis of PM1O and NOx impacts inside the tunnel and at the
sensitive receptor locations.
iv. Encouraging the Use of Mass Transit through Commitments
to Infrastructure Improvements and Regulatory Support.
The FSEIS must include specific commitments to develop and
implement those mass transit projects that were included in future
traffic projections upon which the air quality analysis was based.
Section 1.4 of Chapter 1 (Part I) states that one of the major
policy issues (policy theme 5) affecting project development is
the need to integrate the project elements into larger regional
public transportation and high occupancy vehicle (HOV) strategies.
The traffic analysis forecasts a 45% increase in transit ridership
by the year 2010 without indicating how these trips will be
accommodated. The FSEIS must commit to the implementation of
transit projects which will achieve the increased ridership.
Integration of project elements should include such activities as
the mass transit connection between North and South Stations, Old
Colony restoration, fringe parking lots for commuters and extending
HOV lanes. The proposed project describes numerous mass transit
improvement projects, but does not discuss a connection between
North and South Station. Providing a network of fringe parking
lots could offer an alternative to vehicle users in corridors not
served by mass transit. Finally, while the proposed project
includes HOV lanes, these lanes exist for relatively short
distances. The proposed project must accommodate the development
and implementation of expanded HOV lanes such as the proposed HOV
lane on the expressway from Braintree to Boston. The FSEIS must
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Appendix 3. Page 6
also evaluate the potential to integrate and extend the existing
HOV lane on 1-93 into the proposed project.
The FSEIS should evaluate procedures that would help isolate the
high speed lanes (both north and southbound) of the depressed
central artery to facilitate through traffic.
Page 3-67 describes the surface artery corridor as providing a
virtually continuous frontage road. The FSEIS should describe the
function of the surface artery.
v. Post—construction Impacts.
An air quality analysis task for the DSEIS identified air quality
impacts from the operation of the proposed Central Artery/Third
Harbor Tunnel project. Mobile source pollutants of concern include
carbon monoxide, ozone, nitrogen oxides, hydrocarbons and PM1O
(particulate). The results of the air quality analysis must comply
with the Clean Air Act (CAA) (Sections 110 and 176) and the 1982
Massachusetts State Implementation Plan (SIP) (40 CFR Section
52.1120(c) (53) (i)) project level criteria (Table V—8). In order
to comply with the CAA and the Massachusetts State Implementation
Plan (SIP) for air pollution control, the DSEIS must satisfy two
air quality criteria:
1) The hydrocarbon emissions must be less under the build
alternative than the no-build alternative for similar years,
and
2) The build alternative must not result in new CO violations
or exacerbate existing Co violations.
The DSEIS used modeling procedures that were reviewed and agreed
to by EPA. These procedures are defined in a document titled
“Protocol for Air Quality Analysis for the Central Artery/Third
Harbor Tunnel Project,” dated January 1989. EPA did not approve
the revision of the Air Quality Analysis Protocol, referred to on
page 20-105 of the DSEIS, that delays assessment of air quality
impacts of the construction impacts.
The results of the DSEIS indicate that, based on the assumptions
contained therein, the operation of the proposed project satisfies
the review criteria and will have a positive impact on air quality.
The areawide pollutant levels are presented in Tables 4.3.5 and 4.20
of the DSEIS. This table indicates that hydrocarbon (HC) emissions
will be less under the build alternative (17% less in 1998 and 19%
less in 2010) than under the no—build alternative. Similarly,
reductions are predicted for Carbon monoxide (CO) (22% less in 1998
and 2010) and for NOx (7% less in 1998 and 8% less in 2010).
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Appendix 3. Page 7
The Co concentrations are presented in Tables 4.8, 4.12, 4.13, 4.17
and 4.18 of the DSEIS. These tables indicate that there are no
violations of either the one or eight-hour Co standards under the
build alternative for 1998 or 2010. However, one analysis site
(number 17) has an eight-hour CO value within 10% of the standard.
The FSEIS must include a discussion and commitment to implement all
reasonable and feasible mitigation measures to reduce CO emissions
for this site.
vi. Operational Commitments to Control Carbon Monoxide (CO)
in the Tunnels.
Based on an average time exposure in the CA/THT, the ventilation
system must be operated in such a manner so as to insure that the
Co level does not exceed the concentration allowed for that time
exposure. We understand that, upon completion of the depressed
artery and harbor crossing, a vehicle travel run (to determine
maximum duration in the tunnel) will be calculated, and re-
calculated at pre-deterinined intervals thereafter.
Section 8.5.2 commits to base the selection of fresh air supply
and exhaust rates on traffic flow - evaluated by the Traffic
Surveillance and Control System. EPA expects that evaluation of
traffic flow will identify the maximum amount of time an individual
can spend in the tunnel system during a peak hour and that this
time period will be used to determine which air quality criteria
(from Section 8.5.1) that the fresh air supply and exhaust rates
must be set at to meet.
Section 4.8.1, on page 4-41, discusses the ventilation criteria
for exposure to carbon monoxide. However, it only discusses the
15 minute exposure criteria and must discuss the other criteria,
which apply to exposure durations of more than 15 minutes. Section
8.5.1 on page 8-15, also describes EPA’S in—tunnel air quality
criteria and commits to install continuous CO monitors. The FSEIS
must commit to maintain these monitors and to submit the monitoring
data to Massachusetts Department of Environmental Protection (DEP).
This can probably be best accomplished by incorporating the tunnel
monitors into DEP’s monitoring network.
S
vii. Technical Comments Ofl Air Quality Modeling Parameters.
The FSEIS must include a discussion of the monitoring data used to
develop the CO background values for the microscale analysis.
The FSEIS must evaluate data from the nearest monitoring station
and determine a project-specific eight to one hour persistence
factor. (The DSEIS used a 0.7 persistence factor to convert eight
hour CO results to one hour results.)
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Appendix 3. Pages
Table 4.1 on page 4-3 of Chapter 4 states that the 24 hour PM1O
National Ambient Air Quality Standard (NAAQS) is “...not to be
exceeded more than once per year per site.” This is technicallY
incorrect: the standard is met when the expected number of days
per calendar year, with 24 hour concentrations over 150 ug/M3, is
less than or equal to one. The statements of the one hour ozone
and annual PM1O NAAQS are also technically incorrect.
Section 4.4.2(a) on page 4-10 includes a description of “neutral”
versus “unstable” conditions which is incorrect: neutral conditions
occur when air temperature decreases 1 deg.C/100 N., unstable
conditions when the decrease is less, and stable conditions when
it’s higher. Other factors can also play a role. The FSEIS should
correct this language.
Section 4.4.2(a) also asserts that neutral conditions and low
mixing heights generally result in reduced pollutant dispersion.
For ground level sources, like intersections, this is not true;
lowest dispersion rates and highest impacts generally occur under
stable conditions.
Section 4.4.3(c) on page 4—19 states that 70°F was used as an
average summertime temperature in estimating daily pollutant
emissions. EPA guidance during the development of the modeling
inputs recommended 70°F. However, new data indicates that this
value must be revised. All future runs of EPA’S MOBILE emission
model for estimating summertime daily pollutant emissions must use
64°F as the minimum daily temperature and 96°F as the maximum daily
temperature.
The DSEIS used EPA’s guidance to develop idle emission factors for
the CO microscale analysis. Recently, EPA has developed a
procedure to more accurately estimate idle emission factors. This
adjustment must be used in the FSEIS. The vehicle speed of 2.5 MPH
used to adjust the NOBILE4 idle emission factor must be developed
in the following manner: 1) Run MOBILE4 for calendar year (C I)
1990 at the desired conditions; 2) Determine the projection year
Co emission factor (EF) by reducing the CV 1990 EF, obtained in
step 1, by the percentage given below for the projection year.
CV % Reduction CV % Reduction
1990 0.0 2001 5l. 1
1991 9.4 2002 52.2
1992 16.8 2003 52.4
1993 23.3 2004 52.7
1994 30.6 2005 52.8
1995 35.2 2006 52.8
1996 39.3 2007 52.9
1997 42.8 2008 53.0
1998 45.7 2009 53.0
1999 50.2 202.0 53.0
2000 50.2 2011—2020 53.1
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Appendix 3. Pace 9
Section 4.10.2(a) on page 4-48 does not, but should, note that ISC
more commonly evaluates impacts on elevated receptors by plane
displacement. It should also explain why flagpole receptors are
more suitable for the DSEIS’s analysis.
Section 4.10.2(a). Although the CO point source modeling
considered impacts from, and interactions with, “microscale” Co
(i.e., roadways and intersections), the N02 point source modeling
did not consider mobile source NO2 impacts. Also, no major N02
point sources were modeled for interactions with the tunnel vents.
Unless the D$EIS can establish that N02 background reflects worst
case annual N02 levels from the unmodeled sources, it should
justify the exclusion of mobile and background point sources from
its N02 dispersion modeling.
Section 4.10.7 on page 4-69 should reference Table 4.31 instead of
Table 4.21. (Note, the table does not show the 1.1 ppm CO impact
the text claims). Also, Section 4.10.7 should cite Tables 4.12 and
4.13 instead of 4.13 and 4.14.
Comments Concerning the MDPW Central Artery/Tunnel Traffic Analysis
1) The DSEIS did not include a traffic report that evaluates the
traffic impacts of the proposed project at locations outside the
project study area; it states that this study is being prepared
(Section 3.2.4, Part 1, p. 3—57). This analysis must be submitted
to EPA when it is completed to allow review and comment prior to
the submission of the FSEIS.
2) The DSEIS used “worst case,”i.e. maximum land use development
and employment projections, as a basis for future trip generation.
There should be an explanation why the future numbers are higher
than the Metropolitan Area Planning Commission’s estimates? (Page
2.2—13)
3) The FSEIS must include a discussion of the calibration method,
data, and values used for trip distribution and mode choice models.
4) The FSEIS must discuss why the trip distribution model for
future trip interchanges does not include consideration of travel
times throughout the proposed highway network ‘for the final
estimates of traffic volumes.
5) A forecasted 45% increase in transit ridership by the year 2010
is indicated. There is no indication of how these trips will be
accommodated or how key elements of the modal choice models
incorporate the possible changes in travel time. The FSEIS must
include more information about future public transportation
volumes, capacity, travel times, and other measures of
effectiveness.
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Page 10
6) The FSEIS must adjust the final traffic volumes to relate trip
distribution estimates to initially assumed speeds for the trip
distribution.
7) The DSEIS predicts an increase in average travel times for the
region in 2010 over 1987. The FSEIS rust include a crosscheck of
travel times throughout the project study area.
8) The FSEIS should include additional information on commercial
vehicle volumes at key locations on the network.
9) The FSEIS must include, to the extent reasonably foreseeable,
traffic information describing the traffic impacts of the proposed
North-South station transit connection.
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Appendix 3, Page 11
B. OTHER ISSUES PERTINENT TO THE NATIONAL ENVIRONMENTAL POLICY ACT
i. General NEPA Requirements, including mitigation.
In addition to meeting the requirements imposed by the Clean Air
Act and Section 404 of the Clean Water Act, the proposed project
must comply both substantively and procedurally with NEPA and CEQ’S
Regulations (42 U.S.C. sec. 4332 (c)(1) and 40 CFR Parts 1500
1508). In general terms, these require federal agencies to take
actions that protect and avoid harm to the environment; and to
provide “full and fair” discussion of direct, indirect and
cumulative impacts, of alternatives which would avoid or minimize
adverse impacts, and of any adverse effects which cannot be
avoided. Ultimately, federal agencies must implement mitigation
measures it has committed to carrying out (40 CFR 1505(3)). In our
opinion several aspects of the proposed project arid DSEIS fall
short of these requirements.
The DSEIS discusses various possible mitigation measure to lessen
traffic, air and water quality impacts. It is not always clear,
however, which measures have been assumed as necessary
preconditions in the impact analyses,, which measures are being
definitively adopted to reduce identified impacts and which are
merely being considered as possibilities, and who will be
responsible for implementing the various measures. These points
must be cleared up in the FSEIS to ensure that environmental
impacts and mitigation meas t s are adequate.ly analyzed and
discussed.
This DSEIS was intended to fall ill a commitment made by FHWA and
the MDPW in the 1985 FEIS to -address fourteen issues left
unresolved at that time and any other issues that have surfaced in
the intervening years. This section discusses EPA’S NEPA concerns
about the DSEIS’ treatment of several of these issues: the
materials disposal program; the Charles River crossing; the future
development of land as a result of the project; the tunnel
fabrication/Outfitting sites; and the Cross Town Boulevard. The
previous section discusses EPA’S air quality concerns under NEPA.
ii. Disposal of Excavated and Other Materials.
As the cover letter indicates, EPA has concluded that the placement
of dredged arid excavated materials in 103 acres of Boston Harbor
around Spectacle Island, as proposed in the DSEIS and current
applications for permits under the Clean Water Act and other
federal statutes, would cause environmentally unsatisfactory
impacts. The basis for this conclusion is that we believe the
proposal would violate the substantive and procedural requirements
of both Section 404 of the Clean Water Act and NEPA.
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p endiX 3. Page 12
EPA’S July 31, 1990 comments under Section 404 describe the basis
for EPA’s findings that the proposed fill would violate EPA’S
Section 404(b)(1) Guidelines. They are both summarized and
incorporated in full as part of this NEPA comment (see Part D of
this Appendix) because they detail EPA’S concerns about the direct
impacts of the proposed fill and about the inadequacies of the
DSEIS’ analysis of alternatives for materials disposal.
NEPA and CEQ regulations require that, in this DSEIS, FHWA and MDPW
“rigorously explore and objectively evaluate all reasonable
alternatives” to the proposed 103-acre fill and “devote substantial
treatment to each alternative” (40 CFR 1502.14). As discussed in
part in the 404 comment, the analysis in the DSEIS was flawed in
that it gave only cursory attention to land-based options, involved
little or no on-site investigation of potential alternative sites,
applied overly narrow site screening criteria, and eliminated sites
inappropriately. Further, the DSEIS eliminated from detailed
consideration such options as use of some of the material for
backfill and use of rail as opposed to trucks for transporting the
material. As noted in the cover letter, since issuance of the
DSEIS, the MDPW has been developing information fl response to some
of these concerns. We trust that in addition to providing the
project changes and information required under Section 404, the
FSEIS will, for purposes of complying with NEPA, correct the
deficiencies in the DSEIS that have been identified here and in
EPA’S July 31, 1990 letter (attached to Part D of this Appendix).
Additional NEPA issues regarding the materials disposal plan are
discussed below.
iii. Cumulative Impacts of Harbor Fill.
The filling of 103 acres of Boston Harbor adjacent to spectacle
Island would have a significant cumulative impact when viewed in
the context of both past and reasonably foreseeable future fills.
CEQ Regulations require (40 CFR 1508.7, 1508.25) that an EIS
examine cumulative impact and consider the degree to which the
proposed filling would set a precedent for future actions with
significant impacts or would represent a decision in principle
about a future consideration (40 CFR 1508.27(6)). The DSEIS does
not fulfill these requirements in its treatment of the impacts of
materials disposal in Boston Harbor.
The area in which the proposed filling is to oc’cur is within the
Section 4(f) boundaries of the Boston Harbor Islands State Park.’
The 1967 MAPC report, which first formally proposed the creation
of the state park, had noted “There are only a few areas of the
Harbor that are officially designated and reserved for conservation
St. 1970, ch. 742, sec. 9 (Mass.). See, Section 4(f) of
the Department of Transportation ACt, 49 U.S.C. Sec. 303;
Section 18 of the Federal Aid Highway Act, 23 U.S.C.Sec. 128.
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Aprendix 3. Page 13
purposes or for public recreation:” 2 consequently, the Island Plan,
called for in the Act, adopted the twin legislative goals of
conservation and recreation. 3
In its 1967 Report, the MAPC noted the vast historic filling of
the tidal flats of the harbor. The report pointed out that
significant fill had continued in the twentieth century, such as
the Commonwealth Pier area, the connection of Castle Island to the
mainland, and the filling of 2,200 acres for Logan Airport. 4
Elsewhere in the harbor, the MAPC noted the following:
In recent years there have been only limited filling
activities in areas such as Columbia Point or at the mouth of
the Neponset River.... An exception may be in the area of
Squantum and Thompson Island —- the proposed site for the 1975
World’s Fair. Present plans for the Fair suggest new fill
projects around Thompson Island and Columbia Point, and the
reforming of the mouth of the Neponset River into protected
water basin.” 5
Since 1967, fill has continued: hundreds of acres have been filled
at Logan Airport (Bird Island Flats, etc. and at the end of the
easterly runway) and in the South Boston shipping channel area.
The Outer Harbor and its islands continued to be candidates for
harbor fill: more than three quarters of the harbor has a mean low-
water depth of ten feet or less.’
The 1970 Special Legislative Commission which proposed the islands
park legislation was aware of the threat of harbor fill: its report
stated: “Landfill could obstruct the tidal flushing action
necessary to remove pollutants, do permanent injury to marine life
or interfere with shipping.”
2 Open Space and Recreation Program for Metropolitan Boston,
Volume 2, “Boston Harbor,” (Metropolitan (Boston) Area Planning
Council, 1967), p. 16.
3 Boston Harbor Islands Comprehensive Plan (Department of
Natural Resources-MAPC, under C. 742 of the Acts of 1970), (Oct.,
1972) p. 18—20, 31, 69.
1967 MAPC Open Space Report, p.14.
1967 MAPC, p.14.
‘ Second Interim Report of the Special Legislative Commission
on the Boston Harbor Islands, February, 1970, p.17.
Second Interim Report, February, 1970.
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AppendiX 3. Page 14
A recent report states that the cumulative loss of intertidal
habitat, flats, and saltmarsh in Boston Harbor to date is 3200
acres. The US Fish and Wildlife Service calls this loss one of
the largest on the east coast.e Thus, the current proposal to fill
103 acres would cause an additional cumulative loss. The existence
of this proposal is already creating other proposals for additional
fill: for example, during this comment period a public agency has
suggested the further expansion of the MDPW’s proposed fill at
Spectacle Island to accommodate contaminated dredge spoils from
maintenance dredging projects over the next 10-20 years.
Furthermore, the Corps and EPA are faced each year with many
proposals to fill the harbor for a variety of public and private
purposes, and must apply consistent standards to their evaluation
under NEPA and regulatory statutes. EPA, in its 1985 NEPA
selection process for the Waste Water Treatment Plant for the
Boston Harbor cleanup, avoided creating a precedent by rejecting
the many suggestions that filling the harbor would facilitate the
siting of the treatment plant.’° EPA went to great lengths to avoid
the fill of Boston Harbor, seeking both state-of-the-art
engineering alternatives that would reduce the size of the
treatment plant (e.g., considering double-decking the tanks at
Deer) and requiring study of many alternative locations and
configurations. For example, EPA decided that a treatment plant
alternative site that required three acres of harbor fill (adjacent
to Nut Island) was environmentallY unacceptable for reasons that
included the “serious impacts of filling tidal areas.” 1 ’
8 “Cumulative Impacts of Fill in Boston Harbor,” Denise
BreiteneiCher (Save Our Shores with Boston Environmental
Department, Boston Shipping Association, MA Coastal Zone Management
and MassPort, April, 1988), p.13.
e Letter, U.S. Fish & Wildlife Service, Vernon Lang, Acting
Supervisor, New England Field Office, July 17, 1990, p.3.
Siting options suggested to EPA included a 154 acre man-
made island; a 19 acre fill or a 3 acre fill at Nut Island; and a
20 acre fill at Deer Island.
“ EPA’S FEIS “Siting of Wastewater Treatment Facilities for
Boston Harbor,” Vol. 1, p. 56. Referring to the decision criteria,
EPA’s Boston Harbor FEIS concluded: “EPA found Split Deer-Nut to
be environmentally unacceptable because of its severe impact on its
“Neighbors” at Nut Island and on “Natural Resources,” and strong
barriers to “Implementation.” EPA’S FEIS, Vol. 1, p.63.
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Appendix 3. page 15
Pollution abatement in and the protection of Boston Harbor has
become an issue of national significance.’ 2 As u.s. District Judge
A. David Mazzone observed in his Sept. 5, 1985 decision finding the
Commonwealth to be in violation of federal law:
“Boston Harbor is a powerful ecological system which is
capable of reconstituting itself as long as the system is not
overloaded... .“
Though Judge Mazzone was referring to the massive inflow of
pollutants as a cause of the overload, the continued loss of
natural habitat could frustrate the reconstituting of the harbor’s
“powerful ecological system,” the restoration of which is the
purpose of the Clean Water Act.
iv. The proposed recreation area at Spectacle Island.
EPA does not dispute that certain curative measures on Spectacle
Island may be beneficial, provided they are done in compliance with
the Clean Water Act, or that island recreation plans can be
modified to fit changing circumstances. None of the official park
plans, however, called for major harborS filling at Spectacle Island
either to remedy existing conditions or to create new park land:
A. The 1967 MAPC plan did not call for any fill, bank
stabilization or capping to prepare for Spectacle Island’s
projected use as an “open, natural area for picnicking and
other day—long recreational uses.” 3
2 For example, the Congress has passed specially designated,
Boston Harbor pollution control appropriations of up to $100
million. EPA has commenced its major enforcement action to remedy
what has been cited many times as one of the nation’s worst
pollution violations. U.S. District Judge A. David Mazzone, in
granting the motion of the United States for summary judgemnent,
noted on Sept. 5, 1985, that the harbor “is of unique historical,
natural, and recreational significance”; and on June 29, 1987, EPA
Administrator Thomas noted that “The importance -gf (the Boston
Harbor-Massachusetts Bay) estuary to the nation and the need for
additional pollution abatement and control programs are well
documented.” Furthermore, special interest and concern has been
asserted by the Commonwealth through the creation of the Boston
Harbor Island State Park; the designation of two bays within the
Harbor as Areas of Critical Environmental Concern; and the
Governor’s nomination of Boston Harbor—Mass Bay-Cape Cod Bay as an
“estuary of national significance.”
‘ 1967 M.APC, ‘ t Boston Harbor,” p.36.
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Appendix 3. Page 16
B. The 1972 MAPC-Department of Natural Resources (DNR) plan
called for compaction after extinguishing the fires, which
had then burned for twelve years, followed by a gradual
vegetative restoration program. A seawall was proposed at
the toe of the eastern dump slope. Future uses included
natural trails and boardwa].ks on the northern portion; boat
facilities and playfields in the idd1e; picnic areas on the
south hill; and potential small swimming areas on the
southwest beaches. No other fill or capping was suggested. 1 ’
C. The 1986 Department of Environmental Management (DEM) plan,
the last major park plan revision, for the first time suggests
capping the island and filling against the eroding slopes. It
also suggests installing rip—rap (behind which there would be
an artificial saltmarsh). The acreage of proposed fill
(including the newly created saltxnarsh) appears to be small.
Central Artery or other public project spoil materials are
suggested as the source. The cost of stabilization is
estimated to be only $3 million, with an additional $10
million estimated for development. Future uses, except for
the area close to the docks, are proposed to be such medium
intensity uses as nature paths, lookouts, and meadows.’ 5
Nevertheless, if one purpose of MDPW’s request to fill the harbor
at is to “create a park” at Spectacle Island, it is important to
assure that in fact a park would be created if fill is authorized
and the FSEIS should provide these assurances. It should be noted
that in 1984-5 EPA was asked by the Commonwealth and the City not
to consider Long Island, another island in the Harbor, as a site
for the Massachusetts Water Resources Authority’s wastewater
treatment plant, because of the plans that Massachusetts and Boston
had to create a park on Long Island, which the 1986 DEM plan shows
to be the premier park opportunity remaining in the Harbor. For
example, at that time the DEN Commissioner cited the “great
importance and consequence to the Commonwealth” of Long Island as
a potential park and noted that in DEN’S view three million five
hundred thousand people annually would be deprived of what he
describes as a sorely needed recreational experience if Long Island
were to become the site for Boston’s treatment plant. He stated
that the loss of Long Island for park use would be”severe” and
added that “no other island offered equivalent opportunities.”
Representations such as these from state and city- pfficials were
definitely a factor in EPA’S decision to approve the use of Deer
Island for the new treatment plant. These Long Island promises,
1972 DNR-MAPC Comprehensive Plan, p. 69.
‘5 Department of Environmental Management Boston Harbor Islands
State Park, 1986 Master Plan, p.20—23.
“ EPA’s FEIS on Siting, Vol. 1, p. 42 (1985).
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p endiX 3, Paae 17
however, have never been fulfilled: Long Island remains closed to
the public for general recreation.’ 7
In the case of Spectacle Island, the DSEIS indicates that the NDPW
is not committed to complete the park at Spectacle Island. It is,
rather, planning to leave the Island, after materials disposal, in
such a form that some other agency can create a park there. The
FSEIS should contain commitments by the FHWA/MDPW and others as to
which agency is to construct a usable park on spectacle Island,
using whose funds, and by what date.
v. The secondary impact of the future development of land
occurring as a result of the project.
As we have stated in previous letters (e.g., November 1, 1989
letter to William V. Twomey), under NEPA and the CEQ regulations,
FHWA has an obligation to evaluate reasonably foreseeable
consequences, or “secondary impacts”, including induced changes to
the pattern of land use and related effects on the human
environment, that flow from this project (40 CFR 1508.8). One of
these, as FHWA has stated in this and previous EISs, is the
environmental impact associated with development of the 27 acres
of land through downtown Boston which the project will make
available because of the depression of the Central Artery. Indeed,
one of the significant, unresolved issues which FHWA, in its 1985
FEIS, committed this DSEIS to address is how to ensure an
environmentally sound combination of uses for this land.
Unfortunately, the DSEIS describes a process for “joint
development” which, as currently proposed, does not provide a role
for NEPA. As we understand the CEQ regulations, FHWA’s obligation
to address these secondary impacts could be fulfilled in one of two
ways: either evaluate in this SEIS the reasonably foreseeable
impacts from an assumed maximum development scenario, or commit in
this SEIS to undertake the analysis later as part of a tiered EIS
process.
EPA’s concern is that the proposed federal action (which includes
funding for construction of the supporting foundations for future
development) not result in violations of the National Ambient Air
Quality Standards or exacerbate existing violations, and that the
build condition be no worse than the no-build condition with
respect to air quality. Ultimately, the future air rights
development should also be compatible with the Na sachusettS State
Implementation Plan (SIP) which currently includes a parking freeze
component.
A planning process undertaken by the island’s owner, the
City of Boston, has been delayed.
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appendix 3. Pace 18
Further, for the reasons discussed above, we believe FHWA has an
obligation to evaluate “secondary” impacts and jnduced changes to
land use that could result from the creation of large areas of
developable land at upland disposal sites for excavated material.
As discussed elsewhere in these comments, the DSEIS gives scant
attention to both the direct and secondary effects associated with
land-based materials disposal sites. As suggested above, a tiered
EIS approach might be an appropriate means for providing the
requisite analysis of any significant secondary impacts at
materials disposal sites.
vi. Tunnel Fabrication site(s).
One of the fourteen unresolved issues that FHWA and the NDPW, in
the 1985 FEIS, committed to addressing in the DSEIS is the
selection of the tunnel fabrication site and evaluation of
associated impacts. The DSEIS does not fulfill this commitment.
In lieu of the analysis, it states (p. 1—2) that existing shipyards
will be used and tunnel sections will be towed to the site from
long distances, leaving to the contractors the choice of which
shipyards to use. The DSEIS further states that nine potential
outfitting sites for finishing the sections have been identified
in the Boston area.
While we agree with the inference that use of existing facilities
is likely to be environmentally preferable to the development of
new sites, we do not believe this absolves FHWA and NDPW of its
obligation to fulfill either its 1985 FEIS coinmnitinent or NEPA’S
requirement for disclosure of impacts associated with this aspect
of the project. We request, therefore, that the FSEIS identify
the locations of the sites most likely to be used, their current
baseline use and environmental condition, changes from the current
conditions necessary to permit their use as 0 tfittiT1g/finiSh g
sites (i.e., whether dredging will be needed to accommodate moving
the 40-foot draft tunnel sections), any impacts during construction
or operation of these sites, and appropriate mitigation.
vii. Cross TOWn Boulevard
As we have discussed in previous correspondence (see Nay 2, 1989
EPA letter to William V. Twofl ey) and meetings, we believe that
FHWA and the NDPW have an obligation under NERA to describe in the
DSEIS the “Cross Town Boulevard,” a proposed divided road from the
new Leverett Circle to Congress Street at Government Center. As
this project would be built parallel to and concurrently with the
CA/TIlT, and would function interdependently with the CA/THT, the
CEQ regulations require that it be addressed in this EIS (40 CFR
1508.25). As the DSEIS does not refer to the existence of this
project proposal and evaluate its impacts in combination with the
construction and operation of the CA/THT. this obligation remains
unfulfilled. We therefore request that the information be provided
in the FSEIS.
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Page l
viii. The Charles River Crossing
This issue known as “Scheme Z” is shorthand for the complex of
issues better called “Charles River crossing” issues. We note that
efforts have been made to address some of the open space concerns
that have been raised: the proposed design avoids the Paul Revere
Landing Park and historic area and the DPW, in its september 13,
1990 letter, has agreed to modify a major ramp. We continue to be
distressed, however, by the massive size of the bridges. The
DSEIS’s proposed crossing of the Charles River Reservation by the
Central Artery and its Storrow Drive Connector (now, Scheme Z) is
much more intrusive than the solution proposed in the 1985 FEIS.
In the FEIS, the bridges carrying the main body of the road were
narrower and less massive; also, the then—proposed Storrow Drive
connector (Alternative 5A Modified) required a less elaborate web
of ramps and did not require a separate, double-decked bridge.
EPA has long-standing policies to safeguard and encourage the
public uses of the waters and shorelines that have been improved
with federal funding under the Clean Water Act. Enthusiastic
public enjoyment of clean water is the best guarantee of continued
public support for both clean-up and continued protection. Thus,
EPA agreed that there was a benefit to the Central Artery project’s
effort to reconnect the city with its waterfront by removing the
barrier of the elevated artery. We have expressed our concern,
however, that the massive highway structure, 17 lanes wide, passing
low over the river bank then ascending to a 90’ high spiral of
ramps, would blight the potential of this portion of the water
park.
We hope that the FSEIS will more fully examine alternatives to the
Scheme Z Storrow Drive Connector and to the Charles River Crossing.
As part of this re—examination, please state whether the state’s
decision to proceed with the MBTA parking garage at North Station
foreclosed in any way the selection of Alternative T Modified
because of conflict either with the garage or associated structures
or prospective uses.
An alternative that should be more fully discussed in the FSEIS is
that of diverting all or part of the through traffic off Storrow
Drive, thus permitting its use as a lower-volume road, principally
serving Boston but without the necessity for elaborate ramp
connections (such as Scheme Z) to connect to the Central Artery.
For example, diverting suburban traffic bound for Logan to the Mass
Pike at Western Avenue would reduce Storrow Drive volume, and noise
and air quality impacts on the adjacent water park. It is possible
that this and other traffic diversions could permit smaller-scale
solutions or a surface connection to the Central Artery using the
Cross Town Boulevard. Such solutions would respect the public
importance and potential of the Charles River Reservation.
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p endiX 3.. Pane 20
The FSEIS should also contain commitments as to how the impacts of
any chosen alternative are to be mitigated. These should include
design modifications and significant parkiand improvements that
reduce or offset the impacts of the Charles River Crossing and
facilitate, to the maximum extent possible, public open space to
connect the historic water park of the Charles River Reservation
with Boston Harbor.
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pendiX 3. Page 21
C. NPDES PERMITTING ISSUES
According to Page 3, “The National Pollution jscharge Elimination
Systems permits may be required”(elflPhaSiS added) for the project.
We are concerned that such a tentative statement would be included
in the DSEIS after our many discussions and letters on this issue.
While groundwater injection or tie-in to existing storThWater and/or
combined sewer systems may potentially be alternatives to direct
discharges to surface waters, we believe that direct discharges
will be the most likely method of disposal and must be more
completely discussed in the FSEIS. NPIDES permits will be required
for any direct discharges of effluent to surface waters, including
construction site dewatering, storinwater, and tunnel wastewater.
Such discharges will be required to satisfy technology and water
quality requirements, and the permits may contain stringent
effluent limits and best management practices.
Considering that major construction is projected to begin within
the year and extensive preliminarY design work has been undertaken,
information regarding whether surface runoff from dewatering basins
will discharge to surface waters should be available. Hence, we
believe that information Ofl NPDES permit requirements, including
data to support permit issuance, should be presented in the FSEIS.
Specific information for NPDES permit applications should consist
of approximate discharge points/areas, receiving waters, and
estimated discharge volumes taking into consideration appropriate
storm events and dewatering practices. NDPW as the permit applicant
should correlate the soil and groundwater quality associated with
specific discharge points/areas. Also, any construction or related
practices which may affect the quality or quantity of the discharge
should be addressed. We recommend that MDPW include specific
practices which are mentioned in the DSEIS such as water table
level maintenance, spill minimization and prevention, fuel storage
and sedimentation control in their NPDES permit applications.
These and other issues which could potentially affect the quality
of the discharge should be addressed because the eventual NPDES
permits will most likely include such best management practices
(BMPS) as conditionS. Existing soil and groundwater samples taken
for material disposal (which yields estimated pollutant loadings
associated with discharge areas) should provide sufficient data to
initiate the permit issuance process.
For the proposed dewatering activities, we recommend that the areas
where groundwater will be withdrawn should be characterized as best
as possible for NPDES permit application purposes. NDPW’s
application should include well detailed maps showing primary
construction areas and discharge points. Sufficient groundwater
sampling should be performed SO as to obtain as best an estimate
as possible of effluent quality. Since the time frame from NPDES
application completion to permit issuance is at least six months
to a year, it would be in the project’s best interest to file
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pendiX 3. Paae _ 21
in order to avoid possible
StorinWater discharge permits will be required in either 1991 or
1992, pursuant to Section 402(p) of the clean Water Act (1987),
depending on how the jschargeS are charaCteriZe EPA plans to
issue regulations in October, 1990 for stormwater jschargeS
associated with industrial activities. If I 6uStria1 activities”
is defined to include large scale construction projects then
stormwater from the CA/THT project will be required to comply with
the new regulations and will be required to obtain an individual
permit or coverage under a general permit. The FSEIS should
contain information explaining the applicabilitY of the new
regulations and jsCUsSiflg measures )IDPW will take to comply with
such regulations. If the new regulations do not define “industrial
activities” to include construction activities, then stormWater
permits will be required in 1992, or sooner if EPA determines that
the jschargeS will be significant contributors of pollution. The
FSEIS should contain information sufficient to allow EPA to make
such a determination, including information concerning jscharge
locations, projected jscharge volumes for various storm events,
projected pollutant oadiflgS, and best management practices to
reduce the quantity of pollutants reaching surface waters.
The tunnel wasteWater, which includes tunnel washdOWfl and
storinWater, may not be accepted by MWRA and Boston Water and Sewer
Commission (BWSC) into their sewer systems. The DSEIS does not
address alternative methods of wastewater disposal. Alternative
jscharge schemes for this wastewater need to be explored,
especiallY discharge to surface waters, which would require NPDES
permits. The FSEIS should describe MWRA and BWSC policies related
to allowing additional tie-in of stormwater/tu1 wash down into
an already overloaded Combined Sewer Overflow (CSO) system. If
tunnel wastewater is jscharged to surface water, sedimentation and
oil/water separation may be required, depending on wasteWater
composition.
Leachate collection systems associated with the material disposal
areas — including the historic landfill at Spectacle Island, and
upland disposal sites — may result in discharges requiring NPDES
permits. According to Volume 3 page 11—2, “The dike will be used
to contain and treat water trapped behind the dike during the fill
operation prior to jscharging into the harbor.” it would seem
that this operation would require an NPDES permit, and the permit
application shoUld include information on the discharge location
and excavated material quality.
applications expeditioUSlY
construction/operation delays.
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Pace 23
D. SECTION 404 ISSUES
i. Bu mary OF EPA’S July 31, 1990 FindingS under Bection 404.
EPA has objected to MDPW’s proposal for the 103-acre fill in the
Harbor for the reasons explained in the Agency’s July 31, 1990
letter to the Corps of Engineers pertaining to the MDPW’s
application for a permit under Section 404 of the Clean Water Act.
(The July 31, 1990 letter is attached to this section.) EPA
concluded that the proposed fill would violate EPA’S Section
404(b) (1) guidelines in several ways. First, NDPW failed to show
that the proposed action is the least environmentallY damaging,
practicable alternative and therefore has not demonstrated
compliance with Section 230.10(a) of the guidelines. Second, EPA
believes that the proposed filling of 103 acres of harbor waters
would cause or contribute to significant degradation of the aquatic
environment, in violation of Section 230.10(c) of the guidelines.
Third, the significant adverse impacts on the marine environment
would cause a loss of existing uses, thereby violating
Massachusetts’s federally approved water quality anti—degradation
regulation and, in turn, Section 230.10(b) of the guidelines. EPA
has recommended that MDPW modify its materials disposal plan to
eliminate or greatly reduce fill in •the waters around Spectacle
Island, in a way that both complies with the requirements of the
Clean Water Act and achieves the project objectives of
environmentally sound materials disposal and reinediatiOn of
Spectacle Island.
ii. Description of Interagency DiSCUSSiOnS Subsequent to
Corps’ Section 404 Public Notice.
During the months since the May 1990 issuance of the DSEIS and the
Corps’ public notice, we believe that MDPW has been making a
serious effort to respond to our 404 objections. We have been
meeting on a weekly basis with the MDPW, the Corps, and other
federal, state, and local agencies. The interagency dialogue
fostered by these regular meetings has been constructive, and we
hope ultimately that they will result in MDPW’s submission of a
revised materials disposal plan which satisfies the requirements
of the Clean Water Act.
While it is premature to predict the elements of a revised disposal
plan, it is useful to describe some of the work MDPW has undertaken
to avoid or minimize the need to fill waters of the U.S. First,
as a result of value engineering, !4DPW has identified areas along
the Central Artery where less material would have to be excavated
than originally believed. Design changes for these areas may
result in a 0.8 million cubic yard (mcy) reduction in the amount
of material excavated (thereby reducing disposal needs).
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Appendix 3. Paae 24
Second, MDPW is exploring the feasibility of reusing approximately
0.7 nicy of excavate in the East Boston portion of the alignment for
structural backfill, and disposing of the remaining 1.6 incy of
excavate from that portion at the Governors Island area of Logan
Airport.
Third, MDPW has developed a revised methodology for evaluating
upland alternatives for materials disposal and is currently
screening a large number of potential sites. We are optimistic
that there will emerge from this effort a number of sites which,
alone or in combination, would be less environmentally damaging
practicable alternatives to filling waters at Spectacle Island.
Finally, MDPW has been gathering additional information about the
biological resources at Spectacle Island and the nature and extent
of landfill material at the Island. MDPW’s consultants have been
conducting lobster surveys arbund the island and we expect the
results to be available later this fall. On September 5, 1990,
MDPW submitted to EPA and the Corps a report entitled “Results of
Field Program to Locate Landfill Material Offshore of Spectacle
Island.” The report, which is still under review by EPA, presents
soil characterization data to delineate the limits of landfill
material along and offshore of the eastern and western shorelines
of the island. This information will be important to our
evaluation of MDPW’s materials disposal purpose related to landfill
capping and park creation. Equally important will be the
information still to be developed by MDPW, related to the nature
of the environmental harm being posed by the landfill material and
alternatives to remediate whatever harm exists.
In summary, MDPW has entered into a cooperative process to address
the concerns EPA identified in its July 31, 1990 letter commenting
on the § 404 permit application, and we anticipate that MDPW will
continue its efforts to find alternatives to filling Boston Harbor
waters.
Attachment: Text of EPA’ S Letter of July 32, 1990 concerning
Bection 404.
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