PRELIMINARY COMPARISON OF CONSOLIDATED WASTEWATER AND CSO TREATMENT OPTIONS FOR THE BOSTON HARBOR SDEIS Prepared for U.S. Environmental Protection Agency, Region I Environmental Evaluation Section JFK Building, Room 2103 Boston, Massachusetts 02203 DRAFT April 30, 1984 CE MAGUIRE, INC. Architects • Engineers • Planners 60 First Avenue. Waltham. Massachusetts 02254 ------- INTRODUCTION As requested by the Environmental Protection Agency (EPA), a preliminary investigation has been made into the feasibility of a scheme developed by the Massachusetts Division of Environmental Quality Engineering (DEQE) which would develop conveyance and treatment facilities for Combined Sewer Overflows (CSO) at Deer Island. These CSO facilities would be combined with the option for use of Long Island as a consolidated treatment plant site. The feasibility of this new proposal from the State may be compared with the existing option of no treatment at Deer Island and consolidated treatment facilities at Long Island. To this existing option have been added existing plans of the MDC for CSO abatement facilities in Boston Harbor. DEER ISLAND CSO TREATMENT FACILITY SCHEME In summary, the major new facilities required under this new CSO option, as shown on Figures No. 1 and No. 2, consist of the following: 1. Construction of a new 111611 diameter 21,500 foot long deep rock tunnel to convey sewage from the Columbus Park Headworks to Long Island. In essence this scheme would convert the existing Deer Island Treatment Facility into a CSO treatment facility. The existing Boston Main Drainage Tunnel (BMDT) which currently conveys sewage from the Columbus Park Headworks to Deer Island for treatment would be converted to transport newly consolidated CSO’s to Deer Island. Sewage flows from the Columbus Park Headworks would be rerouted via a new tunnel to a wastewater treatment facility on Long Island. Sewage flows from the separate Ward Street and Chelsea Creek Headworks would be conveyed from Deer Island via a new tunnel to Long Island for treatment. ------- 2. Construction of a new 12’ diameter 11,000 foot long deep rock tunnel to convey sewage from Deer Island to Long Island. 3. Construction of a new 438 mgd influent pumping station at Long Island. 4. Rehabilitation of Deer Island pumping station to provide for North Metropolitan System and CSO flows. 5. Construction of a new headworks facility next to the existing Columbus Park Headworks for CSO discharges into the existing ll’6” diameter Boston Main Drainage Tunnel to Deer I si and. 6. Construction to convert the existing Deer Island Treatment Facility into a CSO treatment facility. 7. Construction of approximately 9,000 feet of CSO consolidation sewer in the South Boston Old Harbor area. 8. The complete facility requirements for wastewater treatment under this scheme, relating to consolidated treatment facilities at Long Island and headworks at Nut Island are not factored into the discussion nor are their costs reflected in the tables. These costs would be the same under either of the schemes analyzed. Therefore, this discusion focuses only on the comparable differences between the two schemes. Under this new CSO scheme, the various flow consolidation, headworks, conveyance, pumping and treatment facilities are based on components derived from plans of the South Boston Area Old Harbor CSO mitigation program in the Metropolitan District Commission’s (MDC) Report on Combined Sewer Overflows in Dorchester Bay Area (October 1981). Flows from the proposed 9,040 foot long consolidation conduit recommended in the above report would discharge through a new CSO headworks into the existing Boston Main Drainage Tunnel (BMDT). The existing Columbus L ------- Park Headworks would remain and be connected to the new 11 ‘6” diameter deep rock tunnel to Long Island. The proposed 3.0 million gallon capacity storage/containment facility included as part of that report would not be required. Other proposed CSO mitigation plans, such as for the Inner Harbor area and other parts of Dorchester Bay area (see References attached) as addressed in MDC’S recent planning reports do not appear feasible for consolidation into the CSO Treatment Facility being proposed at Deer Island. Design Considerations In order to determine the approximate magnitude of CSO that could be readily diverted into the Boston Main Drainage Tunnel (BMDT) various CSO reports on Boston Harbor were utilized as noted above. In addition, the hydraulic capacity of the interceptor sewers including the new Boston Main Interceptor, tributary to the Columbus Park Headworks were reviewed from plans of the Boston Water and Sewer Commission. Based on the information contained in these plans and reports, the following approximate flows during storm conditions would be transported to the Columbus Park Headworks: 1. Dorchester Interceptor 60 mgd 2. New Boston Main Interceptor 166 ingd 3. Old Boston Main Interceptor 20 mgd Total 246 mgd Since the design capacity of th Columbus Park Headworks is 182 mgd, a CSO of approximately 64 rngd may be expected. This amount of CSO could readily be conveyed to a new facility at Deer Island. ------- In addition to the above flows, the proposed South Boston Old Harbor CSO, estimated at 149 mgd in the Metropolitan District Commission October 1981 Report on Combined Sewer Overflows in the Dorchester Bay Area , could also be diverted into the BMDT. Therefor, a total CSO flow of about 213 mgd (l49mgd+64mgd) could be available for transport to treatment facilities at Deer Island. Based on the preceding, it can be readily seen that the 438 mgd capacity of the BMDT would not be fully utilized for projected CSO flows under this scheme. It should be realized that under this scheme the BMDT will be subjected to intermittent flow conditions which must be considered. Between storm flows when there is virtually no flows in the BMDT, and during CSO conditions when the BMDT would be operating at half its capacity, sedimentation of suspended solids and possible septic conditions may develop similar to that being experienced in the present Calf Pasture — Moon Island Tunnel. The problems of odors and systems operation plus any furtehr consideration of possible added CSO flows to the BMDT under these conditions would require additional consideration and would result in significantly higher construction and O&M costs to develop the CSO portion of this scheme. Although beyond the scope of this study to evaluate in detail, possible solutions to these problems could be developed. They include: 1. Periodic flushing of the BMDT with ocean water; however, this would introduce salt water into the pumping and treatment facilities at Deer Island. 2. Dewatering the BMDT between storms at a considerable added cost. 3. Additional CSO consolidation to increase flows into the BMDT. Possible options include rehabilitation of the Old Boston Main Interceptor (BMI) slated for abandonment as well as further consolidation of CSO’s not readily conveyed to ------- Deer Island. However, the required interceptor/sewer construction throughout the City of Boston under such an approach would significantly increase both the costs and environmental impacts of CSO mitigation under this scheme. Construction and Equipment The following briefly outlines the construction and equipment required for wastewater treatment and CSO elements under this scheme. New CSO Headworks and Consolidation Conduit As shown on Figure No. 2, a new CSO headworks is required in the vicinity of the existing Columbus Park Headworks. This new facility will provide screening and degriting of overflows from the Dorchester Intercepter, New Boston Main Interceptor, Old Boston Main Interceptor and from the previously mentioned South Boston Old Harbor Consolidation Conduit. The facility should be designed for up to the maximum future CSO anticipated, but not in excess of the 438 mgd capacity of the BMDT. Flows from the headworks will be discharged via a new shaft into the BMDT. At the location of a new shaft the BMDT must be plugged to prevent flows from the Columbus Park Headworks. The significant and major environmetnal consequences of such work are discussed in a later section of this memo. Deep Rock Tunnels Two deep rock tunnels are required under this scheme as shown on Figure No. 1. First, a 21,500 foot ll 6” diameter tunnel (New BMDT) is needed to convey sewage from the c ------- Columbus Park Headworks to treatment at Long Island. Second, a 11,000 foot 12’ diameter tunnel is needed to convey sewage from Deer Island to treatment at Long Island. The new 21 ,500 BMDT from the Columbus Park Headworks would have the same 438 mgd capacity as the existing BMDT. New shafts approximately 9’ diameter at Columbus Park and 11’ diameter at Long Island would be required. Flows would discharge into a new influent pumping station at Long Island. The new pumping station was assumed in this analysis to be similar to that existing at Deer Island with a capacity of 438 mgd. The 12’ diameter tunnel from Deer Island to Long Island, as shown on Figure No. 1, is required to transport wastewater flows from the existing North Metropolitan Relief Tunnel and Winthrop Terminal Facilities at Deer Island to the proposed Long Island Treatment Facility. Capacity of the new tunnel is 475 mgd based on 350 mgd from the North Metropolitan Relief Tunnel and 125 mgd from the Winthrop Terminal Facility. Rehabilitation of Deer Island Pumping Stations The main influent pumping station at Deer Island will require new pumping equipment to handle both the existing sewage flows from the North Metropolitan Relief Tunnel (NMRT) and proposed CSO flows from the existing BMDT. The 10 existing pumps would be replaced with 8 new pumps. Four pumps would lift the 350 mgd flow from the NMRT and discharge into the new 12’ diameter tunnel to Long Island; an additional pump would be stand-by. Two pumps would lift the estimated 213 mgd CSO flows from the BMDT into the proposed Deer Island CSO Treatment Facility; an additional ------- pump would be stand-by. Use of the existing pumping station for both sewage flows and CSO flows is made possible through the utilization of any combination of the 8 pumps. In other words, no single pump would be dedicated to a single system. Each of the new pumps should have a rated capacity of 88 mgd against a Total Dynamic Head of about 120 feet. It is assumed herein that 2,200 horse power variable speed electric motors will be used to drive the pumps. tinder normal operation, the two pumping systems, sewage and CSO, would be separated. However, should the necessity arise, the CSO portion of the pumping station could also be used to pump sewage flows to Long Island. Some reconstruction of the discharge piping would be required as part of the rehabilitation process. The Winthrop Terminal Facility would be upgraded from 60 mgd capacity to 125 rngd capacity as proposed by the MDC. This pumping station would also discharge into the 12’ diameter tunnel to Long Island. A total of four pumps including one stand-by pump is suggested. Each pump would have a rated capacity of 42 mgd against a Total Dynamic Head of about 54 feet. It is assumed that 500 horse power variable speed electric motors will be used. It is important to note that the new pumps will provide sufficient hydraulic head on the new 12’ diameter tunnel to Long Island to preclude the need for influent pumping of Deer Island flows at the proposed Long Island Treatment Plant. 1- ------- Long Island Influent Pumping Station A new 438 mgd pumping station will be required at Long Island to lift flows from the new BMDT into the treatment facilities. The new station would be similar to the existing Deer Island Pumping Station in depth but smaller in overall size. A total of six pumps including one stand-by pump is suggested. Each pump would have a rated capacity of 88 mgd against a Total Dynamic Head (TDH) of 105 ft. The TDH is the same as now required at Deer Island. Variable speed 2,000 horse power electric motors are assumed herein to drive the pumps. It may prove feasible to consolidate the flows of both the New BMDT and Long Island Headworks into a single influent pumping station. In such case, the equipment requirements and costs would not change; however, some savings in construction costs would be realized. These potential cost savings have been factored into the cost comparison to reflect additional potential benefits under this scheme. Conversion of Deer Island into CSO Treatment Facility The present Deer Island Sewage Treatment Plant, (STP) can be readily converted into a CSO facility. The only modifications necessary relate to the intermittent use of the facility when operating as a CSO facility. In the CSO mode the primary settling tanks would be drained back to the sewer after each storm event. The sludge and scum would also be returned to the sewer for treatment at the plant. ------- The essential work necessary to effect conversion to a CSO facility would include: 1. Provide effective tank drain and wash down system. 2. Divert present sludge and scum pump discharge to the sewer (either Winthrop facilities or Chelsea - Long Island System). 3. Revis present chlorine facilities (tank truck delivery not cost effective for intermittent use). 4. Revise pump discharge piping so that any pump can be utilized for either CSO system or Chelsea - Long Island system use. 5. Demolition of facilities no longer needed such as digesters, sludge thickners, etc. The present main pumping equipment or an equivalent replacement could serve the CSO needs. rn fact, with a peak requirement of less than the present 438 mgd, the pump head requirement would be less. However, with the utilization of the existing pumping station for both the CSO flows and the Chelsea—long Island flows, it would seem prudent to have all pumping units suitable for either service. The attached pump curve illustrates (Figure No. 4) how this can be effected. LONG ISLAND CONSOLIDATEO TREATMENT OPTION AND SEPARATE CSO MITIGATION Under this option, no wastewater or CSO treatment would be provided at Deer Island. All present inflows to the Deer Island Wastewater Treatment Facility would be conveyed via a new 16’ diameter deep rock tunnel to a consolidated wasterwater treatment facility on Long Island. This option incorporates, for comparison purposes only, existing CSO mitigation plans consistent with those developed under the new CSO option described in a previous section. ‘I ------- As shown on Figure No. 3 the major new facilities required under this option consist of the following: 1. Construction of a new 16’ diameter 11,000 foot long deep rock tunnel from Deer Island to Long Island. 2. Rehabilitation of the existing Deer Island pumping stations to pump the flows to Long Island. 3. As noted in the previous section, facility costs of the complete treatment plans which would be the same for both pptions are not factored into this analysis. Design Considerations The sewage flows to be conveyed from Deer Island to Long Island consist of 438 mgd from the Boston Main Drainage Tunnel (BMDT), 350 mgd from the North Metropolitan Relief Tunnel (NMRT) and 125 mgd from the Winthrop Terminal Facilities for a total flow of 930 mgd. All of these flows currently are conveyed to Deer Island and would, under the MDC’S upgrade plans, continued to be conveyed there. As part of the Deer Island pumping station rehabilitation design criteria the new pumping equipment will provide sufficient hydraulic head on the new 16’ diameter tunnel to preclude the need for influent pumping at the Long Island Treatment Facility. Construction and Equipment The following outlines the construction and equipment requirements under this option. Deep Rock Tunnel The new 11,000 foot 16’ diameter deep rock tunnel shown on Figure No. 3 from Deer Island to Long Island will have a ------- total capacity of 930 mgd. Two new shafts will be required, one at Deer Island and the second at Long Island. Rehabilitation of Deer Island Pumping Stations The main influent pumping station at Deer Island will require new pumping equipment to provide the additional hydraulic head to meet the influent hydraulic gradient at the new Long Island Treatment Facility. The existing 10 pumps would be replaced. Normal operation at the design flow of 805 mgd (930 mgd minus 125 mgd for the Winthrop Terminal Facility) would consist of 9 pumps with one pump as stand-by. Each of the new pumps should have a rated capacity of 89 mgd against a Total Dynamic Head of about 120 feet. For this analysis 2,200 horsepower variable speed electric motors were assumed to drive the pumps. The Winthrop Terminal Facility would be upgraded from 60 mgd capacity to 125 mgd capacity as proposed by the MDC plans. This pumping station would also discharge into the new 16’ diameter tunnel to Long Island. A total of four pumps including one stand—by pump was used for this analysis. Each pump would have a rated capacity of 42 mgd against a Total Dynamic Head of about 54 feet. It is assumed that 500 ‘horsepower variable speed electric motors will be used. Some reconstruction of the discharge piping would be required as part of the rehabilitation process. COST COMPARISON The comparative costs estimated for the two schemes examined show a differential of about $82 million. Table No. 1 outlines the separate construction cost elements developed for each scheme. It is important i t ------- to note that these costs are not the total construction costs for each option. They reflect only those costs which would be alternates under each scheme’s different approach to developing wastewater and CSO treatment facilities. The costs for common elements under both schemes such as facilities at Nut Island, would be the same and are omitted in this comparison. The pertinent elements of construction under Scheme “A” would cost $123.3 million. This total includes 11,000 feet of tunnel to convey consolidated North System flows from Deer Island to Long Island; it requires rehabilitation of the existing Deer Island pump station; and it adds $39 million for the portions of existing CSO plans readily adapted to this alternative. Scheme “B” would cost $214.4 million for the comparable volume of wastewater and CSO treatment. This total would include two separate tunnels to convey existing wastewater flows to Long Island; a new pump station on Long Island; rehabilitation of the existing pump station at Deer Island; a new headworks facility for CSO at Columbus Park; construction of collection interceptor lines for CSO to Columbus Park; and conversion of the Deer Island SIP into a CSO treatment facility. As a further assumption, it was concluded that under Scheme “B” additional cost savings of approximately $9 million could be realized if the pump station at Long Island were built to consolidate flows from Nut Island and Columbus Park. This savings would therefore reduce the comparative costs of this scheme to $205.4 million. The cost savings between these two options can now be compared. Table No. 2 graphically portrays these savings. Due to the considerable additional construction necessary to implement wastewater treatment under Scheme “B”. This option would cost an extra $82.1 million to develop. The volume of sewage to be treated under both schemes is 930 ------- mgd, while a total of 213 mgd CSO can readily be consolidated and treated in each. As described in the following section on Environmental Consequences, there are additional costs, not readily quantified, which further limit the feasibility of the proposed new CSO scheme. POTENTIAL ENVIRONMENTAL CONSEQUENCES As a further element of comparison between the two schemes, the potential environmental consequences of each were examined. Under both schemes, there would be significant environmental impacts resulting from the construction and operational activities necessary to develop these major metropolitan area wastewater treatment facilities. By contrast, the potential impacts of the proposed scheme which introduces new CSO treatment at Deer Island would be beyond those associated with the siting of major treatment facilities as proposed in the other options. Such impacts involve broader construction activities in the City of Boston and significant water quality impacts from temporary raw sewage discharges to Boston Harbor. As described in the screening review, the potential impacts of the option which consolidated all treatment at Long Island and implements CSO abatement plans of the MDC (Scheme “A’ t ) are associated with the construction and operation of major treatment facilities and would be comparable in many cases to those for other siting options. While the impacts associated with consolidation of treatment at Long hand would be significant, particularly including construction activities at Deer Island and Long Island plus traffic through Wintrhop and Quincy, there would also be introduced the potential for benefits at both Deer Island and Nut Island and in the surrounding neighborhoods from the reduction of treatment facilities. 13 ------- The scheme which proposed new CSO facilities at Deer Island (Scheme 11811) would introduce additional adverse impacts, beyond those noted above, associated with the conveyance of sewage from the Columbus Park Headworks to Long island via a New BMDT. It would also eliminate any possible benefits to the neighborhoods closets to the Deer Island site. Specifically, this scheme would require a connection of a proposed New BMDT to be constructed from the existing Columbus Park Headworks which now receives up to 438 mgd of sewage daily. In order to make the final tap-in of a new deep rock tunnel at the headworks that volume of sewage would have to be diverted while the headworks were dewatered and the final connection was made. Due to the complexity of the anticipated construction work involving undergruond pressurized sewers, it appears likely that the time needed to complete such final connections of sewer lines to headworks could take between 4 to 8 weeks. The existins sewage volume of up to 438 mgd would have to be diverted and most like’y would be discharged directly to the Harbor during this period of time. It should be pointed out that the substantial environmental impact of raw sewage overflows associated with the diversion of the Ward-Columbus system to Long Island could be alleviated, although not eliminated, by utilization of the old BMI. The old BMI could be utilized to convey flows through the proposed CSO headworks and through a temporary connection to the new shaft in the tunnel to Long Island. In order to effect this temporary diversion, the following would be necessary: ------- 1. l1’-6” slide gate in new Long Island tunnel shaft suitable for 125 psi seating pressure. 2. Temporary construction from new CSO headworks to this shaft. 3. Temporary unrestricted connections from all sewer systems to new CSO facility. Under this scheme, all sewage flows would first be diverted through the new CSO headworks and the new tunnel to Long Island SIP. After this was done, the new shaft into the existing Columbus-Deer Island tunnel could be completed, the tunnel dewatered, and the connection at the Columbus Park shaft and the connection to the new tunnel completed. As stated above, this possible method of construction would not avoid sewage overflows because of the hydraulic restrictions in the total system, but could substantially alleviate that serious problem during construction. Determination of the amount of overflows under this scheme would require extensive hydraulic analysis, and the potential improvements from such a method of construction of the connections at Columbus Park will need detailed engineering analysis before its suitability is judged. Such an approach is presented here to reflect the assumuption that this scheme does have possible benefits which warrant consideration of such methods. While no cost estimates have been made 0 f the environmental consequences under either construction scenario, it appears that such potentially harmful inipacts as those associated with Scheme “B” could in themselves, render this scheme unacceptable. A further contrasting element between these two schemes is also important to note. Unlike Scheme “A”, this scheme would eliminate any potential benefit at Deer Island from the reduction of present wastewater treatment facilities there. The conversion of the Deer Island SIP, as proposed in this scheme to a CSO facility, would c ------- maintain the existing tanks, support buildings and garages in addition to the necessary pumping facility. The size and operational elements of the Deer Island site as a CSO facility would be seen as similar to its current usage. Impacts from traffic during construction and operation, potential odor problems, and visual impacts would remain and would require further mitigation measures to address. Another environmental consequence associated with this new CSO scheme involves the problem, noted in a previous section, of the under-utilization of the od BMDT for consolidated CSO flows to Deer Island. The CSO readily conveyed to the old BMDT under this scheme would only divert 213 mgd to the BMDT conduit which has a capacity of 438 mgd. The odor and operational problems of such usage were described previously. In order to increase the CSO flows up the capacity of the BMDT additional flows from the Inner Harbor area, the old BMI conduit, or other parts of the Dorchester Bay area would have to be consolidated and conveyed to the new Columbus Park Headworks. Such additional consolidation and conveyance of CSO up to 225 mgd appears to be beyond what is readily accomplished. It would involve further disruption, higher costs, and greater environmental impacts beyond those described above. By contrast, the alternatives provided by existing CSO plans for additional treatment would appear to accomplish the same CSO abatement goals at a more acceptable level of environmental consequence and with comparable costs. ------- PAGE NOT AVAILABLE DIGITALLY ------- FI GURE 4 1. 1 - - - Lt 7 JA 1 4 : _ - - - --I. * T • • •. :: : -tJ//.7,). 7 ’ T F ,tvs L 1 I : : C Z ’ eSZ, 7 4 - 1 1 IT JfIjiIt1 T1 4 ________ f t :;ç4 .j y: j , q, 4.;c A.:’q f::.. L:.1 ‘j1—. Jflt £ J d ? 7- 7 L’ 7 T T t: ___ T H1 L t inJ t ±i tj : jr t*i s — I - L - :.::...1. - zz Q;7 L - ; - :“T. C ,i— -— : 1:H _- - iiiL L’ hT • :: :U : ÷-- - 1 - ::.1 .t• ‘N ! T. 4G r i ti y 4m H • S if f -/y(Y w y - -. - - ‘S7L 4 .. i :1 • ‘)/ / 1 . i.• • . — . . • • .1 : 7 • • -7 : 4 /4 •: __ ______ ...j: f:j: IL:i:i ;1 U ±. 5)i •4 9 {} ifZ -4 r L L.4 1 .- T• -1::f TI F ‘r -’ 4. - ::L±i i 4 L • - - ____ I ____ :: HflT. __ - 1:.. _1 -____ • ..:. :.H..: : z, :... .. . .:I: i::: j.::: & i . t .t I I 14 1441 T i : • ------- TABLE 1 CONSTRUCTION COSTS Descri ption SCHEME “A”: CONSOLIDATED TREATMENT AT LONG ISLAND WITH SEPARATE CSO MITIGATION 1. 11,00 L.F. of 16’ Diameter Tunnel 2. Rehabilitate Pump Station at Deer Island 3. Demolition at Deer Island 4. Collection of CSO in Old Harbor (from CDM Report) II SCHEME “B”: CONSOLIDATED TREATMENT AT LONG ISLAND WITH DEER ISLAND CSO MITIGATION 1. 21,500 L.F. 11’06” Diameter Tunnel from Columbus Park to Long Island 2. 11,00 L.F. 12’ Diameter Tunnel from Deer Island to Long Island 3. New 438 MGD Pump Station at Long Island 4. Rehabilitate Existing Pump Station at Deer Island 5. New Headworks at Columbus Park 6. Demolish and Convert Deer Island into CSO Treatment Facility 7. Construction of 9000 L.F. of (Collection only) CSO Interceptor (CDM Report) Million $ 66.3 17.0 1.0 39.0 *Jf Nut Island and Columbus Park flows are combined into one pump station at Long Island, an additional $9 million savings is estimated. Total 123.3 * 89.5 45.7 40.0 14.0 11.6 3.0 10.6 214. - 9.0 205.4 Total Total ------- TABLE 2 COST COMPARISON OF DEER ISLAND SUBOPTIONS SCHEME A ( ?\ $3 9m SCHEME B $32.2m Sewage Treatment TOTAL $123.3m $ 205.4m Di fference + $82.lm CSO Pollution Abatements $84 3m $173.2m* *TIlis figure assumes a $9 million savings for consolidated pumping at Long Island ------- REFERENCES 1. MDC, Report on Combined Sewer Overflows in the Dorchester Bay Area . Camp, Dresser & McKee, Inc. - October 1980. 2. MDC, Discharges from Moon Island . Camp, Dresser & McKee, Inc. - Draft Report March 28, 1984. 3. MDC, EMMA Study - Volume No. 9. Metcalf & Eddy, Inc. - October 1975 4. MDC, Combined Sewer Overflow Report . MDC, Inner Harbor Area Facilities Plan . O’Brien & Gere Engineers, Inc. - January 1981 ------- |