PUBLIC RECORD OF DECISION
ON THE FINAL
SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT
LONG-TERM RESIDUALS MANAGEMENT
FOR METROPOLITAN BOSTON
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
BOSTON, MASSACHUSETTS
APPROVED BY:
flE BE LAG A
IONAL ADMINISTRATOR
DATE
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RECORD OF DECISION
TABLE OP CONTENTS
Page No.
I. Introduction 1
II. Screening and Evaluation of Alternatives 2
A. Development and Screening of Alternatives .2
B. Detailed Evaluation of Alternatives 9
III. EPA Decision 21
A. Environmentally Acceptable Alternatives 21
B. Environmentally Preferable Alternatives 24
C. Preferred Plan 25
IV. Mitigation and Monitoring ...26
A. Residuals Processing 26
B. Water Quality Monitoring and Protection -
Walpole MCI 27
C. Other Mitigation Measures 31
V. Conclusion 31
Appendix A Summary of Public Comments on the FSEIS
and Agency Responses
Appendix B Public Comments on the FSEIS
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U.S. ENVIRONMENTAL PROTECTION AGENCY
RECORD OF DECISION
ON THE FINAL SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT
ON
LONG-TERM RESIDUALS MANAGEMENT FOR METROPOLITAN BOSTON
I. INTRODUCTION
The U.S. Environmental Protection Agency (EPA) has prepared this
document as its Record of Decision (ROD) for the Final
Supplemental Environmental Impact Statement (SEIS) on Long-term
Residuals Management for Metropolitan Boston. The Final SEIS
evaluated a variety of alternative sites and processing
technologies for handling residuals from the proposed
Massachusetts.Water Resources Authority (MWRA) secondary
wastewater treatment facilities at Deer Island. The residuals
project is one component of an overall effort by the MJ'RA, tht
Massachusetts Executive Office of EnvironmentaX Affairs (EOEA)
and Department of Environmental Protection (DEP), and EPA to
reduce pollution of Boston Harbor and Massachusetts Bay.
The SEIS supplements EPA's 1985 Firtal Supplemental Environmental
Impact Statement for the Massachusetts Water Resources
Authority's Proposed Siting of Wastewater Treatment Facilities
for Boston Harbor (Siting FE1S) which recommended that a new
secondary wastewater treatment plant be constructed on Deer
Island (adjacent to Winthrop, at the northern edge of Boston
Harbor) to replace the existing primary plants on Nut Island (in
Quincy) and Deer Island. EPA determined in the Siting FEIS that
the new plant could be sited irrespective of the selection of the
location and type of processing technologies necessary for
management of the wastewater treatment byproducts, or residuals,
including grit, screenings, and sludge. However, the ROD for the
Siting FEIS required further environmental review to be conducted
in order to evaluate the potential impacts of the residuals
facilities. The SEIS provided this environmental review.
Concurrent with EPA's environmental review, MWRA conducted
environmental review and facilities planning for the residuals
management facilities in compliance with Massachusetts
Environmental Policy Act (MEPA) regulations. In August of 1989,
MWRA published its Final Residuals Management Facilities Plan
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which contained its final recommendations for residuals
management technologies and sites.
The MWRA is responsible for selecting and implementing the
residuals management program. EPA's primary responsibilities are
to fulfill its commitment to prepare additional environmental
analyses concerning residuals management as specified in the ROD
for the Siting EIS, to ensure compliance with the Clean Water Act
and the National Environmental Policy Act (NEPA), and to provide
an independent analysis of the MWRA's residuals management plan
and its Environmental Impact Report and Facilities Plan. In
preparing its NEPA environmental review, EPA drew its own
conclusions but made use of the information generated by the MWRA
in its environmental review as long as it met EPA's needs under
NEPA. Additional information or analyses were provided by EPA
where needed. This "piggy-back11 approach allowed EPA to conduct
a more efficient environmental review than otherwise would have
been possible.
EPA published it's Draft SEIS on Long-Term Residuals Management
for Metropolitan Boston in May 1989 (May 19, 1989 Federal
Register). Public hearings were held in Quincy, Cambridge, and
Walpole, Massachusetts in July 1989. Oral and written comments
on the Draft SEIS were received during a sixty day comment
period. The Final SEIS, which responded to these comments, was
published in November 1989 (December 15, 1989 Federal Register)
and was also followed by a sixty day public comment period. This
Record of Decision has been prepared taking into consideration
comments received on the Final SEIS. The comments submitted and
responses to them are attached as Appendices B and A,
respectively.
The Draft and Final SEIS satisfy federal environmental review
requirements in accordance with the EPA and Council on
Environmental Quality (CEQ) procedures for implementing NEPA as
set out in 40 CFR Parts 6 and 1500, respectively.
This Record of Decision sets forth EPA's final decision on MWRA's
long-term residuals management program for Metropolitan Boston.
This ROD is being circulated to inform the public of this
decision and respond to the comments submitted on the Final SEIS.
II. SCREENING AND EVALUATION OF ALTERNATIVES
II. A. Development and Screening of Alternatives
NEPA regulations require that EPA, during environmental review,
explore all reasonable alternatives in its SEIS and ROD. When
the range of potentially reasonable alternatives is impracticably
large for analysis, NEPA directs that a reasonable range of
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alternatives illustrating the full spectrum of potential impacts
be analyzed.
Because the number of conceivable options for processing or
disposing of MWRA residuals was immense, at several stages in the
EIS process EPA made preliminary comparisons among alternatives
based on the information available at that stage of the review
process. The purpose of these preliminary screening steps was t'o
reduce the number of alternatives carried into the next stage of
analysis. This screening was necessary to make the process more
manageable and to focus analysis on the key issues. At each
stage of the screening process, EPA ensured that a reasonable
range of options would be carried forward. NEPA guidelines were
the basis for criteria used for alternatives screening.
The screening process used is discussed only briefly here, is
depicted graphically in Figures 1 and 2, and is described in
detail in Chapter 2 of the Draft SEIS. Ten major technologies
were originally considered (on a non-site-specific basis), along
with four modes of transporting residuals materials. System
alternatives, the combinations of residuals processing
technologies and transport modes, were screened using three of
the four NEPA implementation criteria: capital and operating
costs; physical, legal, or institutional constraints (including
but not limited to technical feasibility); and compliance with
regulatory requirements. The NEPA criterion of direct, indirect,
and cumulative environmental effects could not be meaningfully
applied at this stage, because the technologies and
transportation modes were being considered only on a non-site-
specific basis-
Several major sludge processing technologies were identified as
not practical for the MWRA residuals management system, leaving
four potentially viable major technologies:
• landfilling of grit and screenings, ash (from incineration,
if selected), and sludge (as a backup to the other
technologies);
• composting of sludge to produce a soil amendment product for
marketing or distribution;
• heat drying (pelletizing) of sludge for use as a fertilizer-
type product for marketing or distribution; and
• combustion of sludge, with landfill of the ash.
All four possible transportation modes identified as potentially
viable (barge, truck, pipeline, and rail) were retained for
further consideration (although rail transport was not considered
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Identification
of Candidate
Options at
. 10 Sites
Inventory of
300 Sues
Technical and Environmental
Evaluation of Sites ana System
Alternatives
Screening Evaluation of
Candidate Options Using
Technical. Cost. Environmental,
and institutional Criteria
Technical and Cost
Comparison of Generic Disposal
and Transportation Options
FIGURE 1. OVERALL LOGIC OP THE 8EIB
ALTERNATIVES SCREENING
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TIME FRAME
SCREENING
PROCEDURE
JAN.-JUNE 1987
DEVELOPMENT
OF SYSTEM
ALTERNATIVES
IDINTIFICATION
OF CANDIDATE
OP I IONS
JUNE 1187 - APRIL 1988
APRIL - NOV. I98B
SELECTION OF FINAL
OPTIONS FOR DETAILED
EVALUATION
Ul
ALTERNATIVES
RETAINED
FOR FURTHER
EVALUATION
COMPOSTING ANO
DRYING/COMBUSTtON
LANDFILL OF MINOR RESIDUALS
300 POTENTIAL SITES
TF.O.I INOl OGY/SITE
COMfll NATIONS:
- TRANSFrn AT OUINCY FRSA
OH LYNN
- PROCESSING AT OUINCY.
LYNN, DFF.0 I.. SPECTACIE I..
STOUGMJON. WALPOLE BIRD.
WILMINGTON
LANDFIL L AT ROWE OUAnRY.
WALPOLE N , WALPOLE MCI
PROCESSING AND LANDFILL
AT SPECTACLE I .WALPOlE N
- TRANSFER AT OUINCY FRSA
- ANY PROCESSING AT
STOUGHTON OR SPECTACLE I.
- DRYING/ COMPOSTING
AT OUINCY
- LANOF1LL AT ROWE OUARRY
OR WALPOLE MCI
- THERMAL PROCESSING AT
DEER I.
ALTERNATIVES
NOT RECOMMENDED
FOR FURTHER
EVALUATION
- DEWATERED SLUDGE LANDFILL
- OCEAN DISPOSAL
- LAND APPLICATION
- LONG TF RM PRIVATIZATION
ANY ACTIVITIES AT REMAINDER
OF 300 SIIF.S
COMBINI D COMPOSTING PLUS
COMBUSI ION AT DEER I
ANY PROCESS AT WALPOLE
BIRD. WILMINGTON, OR LYNN
TRANSFER AT LYNN
COMBUSTION AT OONICY FRSA
LANDFILL AT N WALPOlE OR
SPECTACLE ISLAND
FIGURE 2. SUMMARY OP LONG-TERM RESIDUALS MANAGEMENT
ALTERNATIVES SCREENING 8TEPS
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to be a likely component for most sites). The original inventory
of sites considered included approximately 300 sites, nearly all
of which were within the 43 community MWRA service area. These
sites were grouped into three broad categories: island, coastal,
and inland.
Combined with the system alternatives, several general .site needs
were identified: a landfill site, one or more processing sites,
and a coastal site for transfer of materials. EPA then used the
following screening criteria to evaluate the suitability of each
site for these potential uses:
• Technology-specific environmental suitability (including
engineering suitability, noise environment, land use,
cultural resources, transportation access, surface water,
ground water, wetlands, ecology, and air quality)
• Site-use flexibility (including potential to be part of
preferred or least-cost alternatives by consolidation or
dispersal of facilities)
• System compatibility (logistics)
• Permitting feasibility
• Retention of a variety of site types (island, coastal,
inland)
• Potential conflicts with other unrelated environmental
remediation projects
In applying these criteria, EPA placed particular emphasis on
identifying potentially unmitigable constraints or site
conditions in the following categories:
• Existing on-site or near-site contamination
• Preemptive or incompatible land use
¦ Transportation access
• Potential conflicts with drinking water supplies
• Physical and land-use features that could limit the
attainment of air quality objectives
• Potentially unmitigable conflicts with wetlands or
endangered species
This screening was done using publicly available information
about each site, and resulted in the identification of ten sites
that were potentially suitable for a variety of uses. The range
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of site types and locations retained satisfied the need for
evaluation of a reasonable range of alternatives under NEPA, as
shown in Table 1. These made up the candidate options, or
combinations of site uses and transport linkages, subject to
further investigation.
TABLE 1. SUMMARY OF CANDIDATE OPTIONS
Composting Thermal Landfill*31 Processing
and/or Processing plus
Thermal Only(2) Landfill®
Processing'2'
Coastal Sites'1'
Quincy FRSA
X
X
Lynn S. Hrbr
X
X
Island Sites
Deer Island01
X
Spectacle Isl.
X
X
Inland Sites
Wilmington
X
Stoughton
X
Walpole Bird
X
Rowe Quarry
X
Walpole MCI
X
Walpole N.
X
X
Notes:(1) Coastal
Transfer at
Quincy FRSA or
Lynn
South Harbor;
digestion assumed to occur at Deer Island.
(2) Raw or digested sludge; thermal processing includes
heat drying and/or combustion. Dewatering assumed to
occur at island or coastal sites.
(3) Landfill of grit and screenings, combustion ash, and
backup for sludge cake and sludge products.
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Upon identification of the candidate options, field and
background data were collected for each site. The list of
candidate options was then further reduced by screening using the
technical, cost, environmental, and institutional constraint
criteria listed in Table 2 (and defined in Chapter 2 of the Draft
SEIS). These criteria were developed using the NEPA requirements
and were applied to each option using the site-specific data
available for each site use.
TABLE 2. CANDIDATE OPTIONS SCREENING CRITERIA*
Technical Criteria
Reliability
Flexibility
Environmental Criteria
Wetlands and ecology
Air quality
Land use
Transportation and traffic
Public health
Cost criteria
Capital costs
Operations and maintenance costs
Total present worth costs
Institutional Criteria
Timely implementation
Equitable distribution of regional responsibility
Coordination and competing public use
Consistency with NEPA requirements
Consistency with MWRA stated recommendations
* see Chapter 2 of the Draft SEIS for definitions of criteria
The alternatives surviving this screening step were subject to
detailed evaluation in the SEIS, and are shown in Table 3.
Similar to the previous stage of screening, EPA decided that for
the final analysis it was appropriate to evaluate all of the
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potentially viable suitable uses for each site. This analysis
allowed the maximum potential impacts for each site use to be
established. Within these boundaries, the impacts of different
combinations of site uses could be deduced by interpolation.
This also facilitated full comparison of the options, and
promoted flexibility in determining how to combine site uses to
make up a full residuals management option. Finally, this
approach maximized the number of reasonable alternatives being
evaluated in the EIS.
TABLE 3. SITES AMD POTENTIAL USES
SUBJECT TO DETAILED ANALYSIS IN THE SEIS
SITE
Dewater Heat Dry Combust Compost Landfill
Walpole MCI
Rowe Quarry
Stoughton
Quincy FRSA
Spectacle Isl.
Deer Isl.
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
II. B. Detailed Evaluation of Alternatives
Chapters 4 and 5 of the Draft SEIS, and Chapter 3 of the Final
SEIS discuss the existing and projected environments in the
vicinity of each of the final candidate sites, and predict the
impacts of each residuals management option at those sites. This
section summarizes those findings and suggests mitigation
measures for impacts predicted to be significant.
Walpole MCI (Landfill)
No significant air quality or odor impacts are expected under any
construction or operating conditions. Grit and screenings could
potentially generate odors; however, they would be landfilled
only in relatively small quantities. Using proper management
procedures such as daily cover, landfilled grit and screenings
would not generate noticeable odors or air quality concerns. Ash
or heat-dried pellets would not contain volatile materials, which
are generally the source of odors. Dewatered sludge cake, if
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landfilled, could generate odors, but these could be controlled
through proper landfill management. Therefore, air quality and
odor impacts at the site would be acceptable.
Under normal operating conditions, there would be no surface or
ground water impacts because all water exposed to the landfilled
material and associated contaminants would be contained on site.
The landfill's design, including the proposed double liner,
leachate collection, and runoff control systems, should prevent
contaminants from reaching surface or ground water. In the
unlikely event that all of these controls fail and a leak
develops in both liners, there would be potential for
contaminants to reach adjacent ground and surface waters,
although the concentrations of contaminants would be low and the
lengthy transport times predicted (at least 30 years) would allow
for remediation and predicted impacts to these waters would be
minimal. However, EPA is requiring a number of mitigation
measures to augment ground and surface water protection as
described in Section IV of this ROD.
Because no significant air or water impacts are expected, there
are no expected pathways of exposure for public health impacts.
Noise generated by trucks and earth-moving equipment,
particularly during emergency landfilling of dewatered sludge,
could generate significant impacts for the closest receptors. At
some receptors, including the Stop River wetlands and associated
wildlife habitat, the change from a relatively quiet ambient
condition could result in a potentially significant impact. EPA
recommends that noise impacts be mitigated through berm
construction, using excess on-site material, and the use of
earth-moving equipment specially modified to reduce noise.
In the event that emergency landfilling of dewatered sludge
became necessary, there could also be significant traffic and
noise impacts at the site and along the Winter Street
transportation route. Under these conditions truck traffic could
more than double on local residential streets. The physical
characteristics of the streets are not well suited to heavy
trucks, which exacerbates the impact. EPA recommends that the
impacts of trucking during this emergency situation be mitigated
by splitting the truck traffic between the Pine Street and Winter
Street access routes. Adverse traffic impacts would remain, but
they are not expected to be significant because they are not
expected to occur for periods longer than a few days. During
other operating conditions, the increased truck traffic
(approximately 4 to 5 trucks per day for grit and screenings
landfilling) is not expected to significantly impact traffic or
land uses along the transportation corridor.
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A range of effects on property values could result from the
location of a negatively perceived facility, such as residuals
landfill. However, a particular land use's potential effect on
surrounding property values depends on a composite of factors
such as public perception, prevailing market conditions,
prevailing winds, degree of natural buffering, the nature and
extent of the activity, traffic, and distance to residential land .
uses. The Walpole MCI site is relatively isolated and generally
buffered from neighboring residential areas by wooded and
undeveloped land. The adjoining prison properties are even less
susceptible to land use, visual, and socioeconomic impacts than
are residential or commercial properties. Consequently, landfill
development at this site is not predicted to generate significant
adverse impacts in these categories.
Finally, because there is a potential for finding significant
archaeological remains (prehistoric and historic artifacts) on
the site, a more intensive archaeological survey would be
required prior to construction.
The Walpole MCI site is environmentally acceptable for a
residuals landfill, however if no mitigation measures are put in
place, potentially significant noise, traffic, and water quality
impacts could occur. Additional measures that could be initiated
to further reduce potential impacts at the Walpole MCI site are
shown in Table 4.
Rowe Quarry (Landfill)
As at the Walpole MCI landfill site, no air quality or odor
impacts would be expected, assuming standard landfill operating
practices, such as daily cover, are used. Also similar to
Walpole MCI, the Rowe Quarry landfill would have a double liner
and leachate collection and runoff control systems, so there
should be no ground or surface water impacts. Even if the liner
system did leak, the implications for ground water are not
considered significant because the concentrations of contaminants
would be low and the groundwater in the area is not a significant
resource (e.g., for drinking water). A major undetected and
unremediated leak in the liner system would have to occur for
there to be a risk of exceedances of applicable water quality
criteria at the nearest water body, the adjacent Rumney Marsh (a
significant ecological resource). Again, this possibility could
be mitigated by the installation of a ground water monitoring
system downgradient of the landfill and a commitment to remediate
any groundwater contamination caused from a landfill leak before
it reached the marsh.
Because no significant air or water impacts are expected, there
are no expected exposure pathways for public health impacts.
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Noise generated by trucks and earth-moving equipment,
particularly during emergency landfilling of dewatered sludge,
could generate significant impacts for the closest receptors.
However, noise impacts already exist at receptors around the Rowe
Quarry site from ongoing quarry operations. Noise impact could
be somewhat mitigated -by requiring specially modified equipment;
however, other forms of mitigation are limited because material
is not available on site to construct berms and because the
elevation of the receptors relative to the landfill operations
would make berms less effective.
Although residences and other active land uses are close to the
site and there is only minimal buffer, no significant land use,
socioeconomic, or visual impacts are expected because landfill
activities would not be perceived to be significantly different
from the current quarry operations. Similarly, although the
nearby Rumney Marsh is an important ecological resource, the
change in activity from quarry to landfill operation is not
predicted to alter any ecological resources or processes there.
There is potential for impacts to significant historical
resources at the Rowe Quarry site, and a survey would have to be
conducted before construction to determine if the quarry or
associated buildings are eligible for the National Register of
Historic Places.
Projected traffic along the access route to Rowe Quarry generally
is not excessive and the addition of residuals vehicles would not
result in deteriorated service under any operating conditions.
The relatively small percentage increase in trucks is not seen as
significant and even this small increase would be at least
partially offset by elimination of trucks associated with quarry
operation if the site were converted to a residuals landfill.
The Rowe Quarry site is environmentally acceptable for a
landfill; however, there could be potentially significant water
quality and noise impacts if no mitigation were initiated. EPA
recommends that the mitigation measures discussed above be
implemented to reduce the significance of such impacts.
Additional measures that could be initiated to further reduce or
prevent potential impacts at the Rowe Quarry site are shown in
Table 4.
Stoughton (Heat Drying, Combustion, Composting)
Some adverse air quality impacts could result from the
incineration of residuals at Stoughton. One exceedance of a
state ambient air quality limit was predicted using a predictive
air quality model. However, it is not certain that this one
exceedance would result in severe environmental or public health
impacts, and is therefore not considered to be unacceptable by
EPA. No significant air quality impacts or exceedances were
predicted from any combination of heat drying and composting at
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the site. Composting would be the most odorous process at the
site, but the distance to the nearest receptor is far enough that
no significant odor impacts would be expected.
Potentially significant adverse water quality impacts were
predicted for incineration at the Stoughton site, using a
predictive model to determine the impacts from dry weather
deposition from incinerator emissions. Results showed that such
deposition could result in numerous exceedances of aquatic life
and human health water quality criteria in nearby Brockton
Reservoir and Glen Echo Pond. Additional deposition of
contaminants during wet weather (e.g., from precipitation) was
not estimated, but would increase the magnitude of the adverse
impact. The predicted water quality impacts would have
significant adverse effects on aquatic life in the two water
bodies and could have public health implications because Brockton
Reservoir is slated to become a public water supply. The water
quality and public health impacts resulting from deposition due
to heat drying and composting, however, were not predicted to be
significant.
If all materials handling were conducted outdoors at the
Stoughton site, there would be significant noise impacts, which
in turn could potentially affect adjacent land uses. However,
the noise impacts could be mitigated by confining most of the
handling operations to areas shielded by noise barriers.
Potentially adverse impacts were also predicted from processing
operations, with noise from fans and blowers being of particular
concern. These impacts could be mitigated by designing low noise
generating mechanical systems and minimizing building openings.
Under the maximum traffic scenario (both heat drying and
composting at the site), the transportation impacts would be
significant because of the large number of trucks going to and
from the site. This impact could be at least partially mitigated
by expediting the planned reconstruction of the Route 24/Route
139/Page Street area and by upgrading and signalizing the
affected Route 139 intersections. Because composting would be
the largest generator of traffic, if incineration and heat drying
(together or alone) were located at the Stoughton site, no
significant impacts are expected. With composting alone at the
site, the number of trucks is reduced by about 30 percent from
the maximum. Although this would still result in adverse traffic
impacts, these impacts would be mitigated by the above Route 139
improvements.
No significant visual, land use, or socioeconomic impacts would
be expected from residuals processing at the Stoughton site
because the industrial nature of the site and surrounding area
are generally compatible with residuals processing. Thus, no
substantial change is predicted to occur as a result of
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developing the site for any combination of composting, heat
drying, or incineration. Also, much of the operation at the site
could be buffered from any sensitive visual resources.
The Stoughton site is environmentally acceptable for either heat
drying or composting, alone or in combination. Incineration is
not acceptable at the Stoughton site because even though state-
of-the-art air pollution control equipment is proposed for the
incinerator, it is not presently predicted to be sufficient to
mitigate the predicted water quality impacts from an incinerator
at the site. For heat drying and composting there is potential
for significant traffic and noise impacts. The EPA recommends
that the mitigation measure discussed above be implemented to
reduce the significance of such impacts. Additional mitigation
measures that could be initiated to further reduce potential
impacts at the Stoughton site are described in Table 4.
Quincy FRSA (Transfer, Dewatering, Composting)
No significant air quality impacts are expected from heat drying
and composting at the Quincy FRSA, either alone or in combination
with impacts from other sources in the area. However,
significant odor impacts could result from the composting
facility, particularly because of its proximity to potential
receptors. Such odor impacts can be mitigated with good
engineering practices including monitoring of the scrubber to
ensure control of mercaptan, the main odorous compound of
concern.
No significant water quality impacts are expected for the Quincy
FRSA site. Deposition of air pollutants would not be significant
because any pollutants deposited into the Weymouth Fore River
would be sufficiently flushed and diluted by the river, and would
not exceed applicable water quality criteria. Due to the absence
of predicted significant air or water quality impacts, no
exposure pathways for public health impacts are predicted.
Construction noise should not have a negative impact. Although
construction noise would be extremely difficult to suppress, it
would be temporary, and the area has a history of high ambient
noise levels during the daytime which are within the range of
anticipated construction noise levels. Operating noise impacts
are expected to result from residuals handling and processing at
the Quincy FRSA. However, the noise impacts are minimal from the
heat drying and off-loading areas because of their distance from
receptors. Operating noise at the compost facility can generally
be mitigated by designing low noise generating mechanical systems
and by minimizing building openings. Materials-handling
activities, particularly at the composting facility, could also
be noisy. This impact could be mitigated by enclosing all
loading and off-loading areas and by providing a bermed area for
idling trucks that are waiting to load or off-load. Use of
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enclosed, insulated pipes for conveying materials would also
mitigate noise impacts.
There would be increases in truck traffic at the Quincy FRSA
resulting from residuals processing, and the traffic could
temporarily overlap truck traffic generated by MWRA's use of the
site as a staging area for construction of the new secondary
wastewater treatment facility at Deer Island. The site access
route is already heavily travelled by truck traffic, however, and
the impacts from the additional traffic generated by residuals
activities are not considered significant.
Potential land use and visual impacts at the site are not
considered significant, largely because the site has a long
history of intense industrial use and residuals processing would
be a similar use of the property. Similarly, the industrial
nature of the site has generally preempted the existence of
ecological resources at the site; thus, use of the site would not
have significant ecological impacts. Long-term residuals
processing at the Quincy FRSA would not result in significant
socioeconomic impacts, and could potentially offset the effects
on the local community of the departure of the former
shipbuilding industry by making at least part of the site active
again.
The Quincy FRSA site is eligible for the National Register of
Historic Places as an historic district. One building in the
area designated for composting is considered as contributing to
the historical significance of the district. Any adverse effects
resulting from use of this area are considered to be mitigable.
The Quincy FRSA site is environmentally acceptable for transfer,
dewatering, heat drying and composting (alone or in combination);
however, without mitigation there could be potentially
significant odor, noise, and historic resource impacts. The EPA
recommends that the mitigation measures discussed above be
implemented to reduce the significance of such impacts.
Additional measures which could be implemented to further reduce
potential impacts at the Quincy FRSA are shown on Table 4.
Spectacle island (Dewatering, Heat Drying, Combustion,
Composting)
As with the other sites evaluated for incineration, one
exceedance of a state ambient air quality limit was predicted
using a predictive air quality model. However, it is not certain
that this one exceedance would result in severe environmental or
public health impacts, and it is therefore not considered to be
unacceptable by EPA. The combination of heat drying and
composting with no incineration would not have significant air
quality impacts.
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Since no water quality impacts are expected from processing at
Spectacle Island (any pollutants from air emissions deposited in
the harbor around the island would be diluted and would not
exceed water quality criteria), water quality would not affect
public health.
The isolated nature and public ownership of Spectacle Island
would render the noise, land use, visual, and socioeconomic
impacts of any residuals processing scenario for the island
minimal. The ecology of Spectacle Island reflects decades of
disturbance, and although a large nesting bird colony was
reported to exist on the island it appears to have been
abandoned, so ecological impacts from residuals facilities would
not be significant.
Barge transportation to and from the island is not predicted to
result in any significant impacts. Use of piers constructed for
potential DPW projects at the island would minimize or eliminate
any additional impacts from construction of piers for residuals
facilities. Construction of a pipeline from Deer Island to
Spectacle Island could have significant impacts on water quality
and aquatic life during dredging operations. In order to
mitigate these impacts, the planning and design for the pipeline
would have to consider and minimize impacts in the areas of
dredging and construction methods, location of pipeline route,
quality of dredged material, and dredged-material disposal sites
and methods.
Spectacle Island is environmentally acceptable for heat drying
and composting (either alone or in combination) and is also
acceptable for incineration. EPA recommends, however, that the
mitigation measures discussed above be implemented to reduce the
significance of such impacts. Measures that could be initiated
to further reduce potential impacts at the Spectacle Island site
are shown in Table 4.
Deer Island (Dewatering, Heat Drying, Combustion)
As at the other potential incineration sites, one exceedance of a
state ambient air quality limit was predicted. However, it is
not certain that this one exceedance would result in severe
environmental or public health impacts, and it is therefore not
considered to be unacceptable by EPA. Any combination of
digestion, dewatering, and heat drying (in addition to the new
secondary wastewater treatment facilities) without incineration
would not result in significant air quality impacts. The
pollutants emitted from an incinerator or a heat dryer would not
be the same pollutants emitted from the new wastewater treatment
plant, so no impacts are predicted from interactions between
these emissions.
16
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TABLE 4. RECOMMENDED MITIGATION MEASURES
I sue |
B::=:ti»s»esxKSS»ttisnzxBst»33iiieis::r:sss::::::::::E:£=::::::::
IMPACT
U
A
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P-
0
1
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N
C
I
TRAFFIC AMD NOISE IMPACTS ON WINTER STREET DURING
EMERGENCY LANDFILLING OF DEWAIERED SLUDGE
ODOR GENERATED IT GRIT AND SCREENINGS
LEAK IN LANDFILL LINER SYSTEM COULO CONTAMINATE WATER
NOISE GENERATED BY LANDFILL OPERATION
POTENTIAL CULTURAL RESOURCES ON SITE
LOSS OF PRIME FARMLAND ON SITE
RUNOFF FROM LANDFILL COULD AFFECT SURFACE WATER
AND/OR WETLANDS
POTENTIAL SEDIMENTATION DURING CONSTRUCTION
NOISE GENERATED IT BACKUP SAFETY SIGNALS ON LANDFILL
EQUIPMENT/TRUCKS
DEGRADATION OF WETLANDS AND ASSOCIATED HABITAT
POTENTIAL DISPLACEMENT OF WILOIIFE AND WILDLIFE HABITAT
INSUFFICIENT LANDFILL CAPACITY
mannmmtinmnnnmiinBMinnMutmiKiaiiBneiitftii
ODOR GENERATED BY GRIT AND SCREENINGS
RECOMMENDED MITIGATION
SPLIT THE TRAFFIC BETWEEN WINTER STREET AND PINE STREET ROUTES
R
O
W
E
a
u
A
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LEAK IN LANDFILL LINER SYSTEM COULD CONTAMINATE
GROUNDWATER
NOISE GENERATED BY LANDFILL OPERATION
SUSPECTED HISTORICAL SIGNIFICANCE OF STONE CRUSHER
BUILDING
RUNOFF FROM LANOFIll COULD AFFECT SURFACE WATER
A NO/OR WETLANDS
POTENTIAL SEDIMENTATION
NOISE GENERATED BY BACKUP SAFETY SIGNALS ON
LANDFILL EQUIPMENT/TRUCKS
VISUAL IMPACT TO TOWNLINE TRAILER PARK, NORTH SNORE
ASSEMBLY OF GOO CHURCH ANO RESIDENTS AT RIM OF QUARRY
FREQUENTLY COVER GRIT AND SCREENIHGS AND MINIMIZE THE WORKIHG FACE
MONITOR LEACHATE VOLUME AND ALL MATERIALS TO BE DEPOSITED IN THE SITE, INCLUDING SOIL
CONDUCT LANOFIll MONITORING PROGRAM ANO PERIODIC LEAK DETECTION TESTS
INSTALL AND MONITOR GROUNDWATER MONITORING WELLS BETWEEN LANOFILL AND WELLFIELDS,
AND UPGRADIfNT OF LANDFILL FOR BACKGROUND DATA
TEMPORARILY DIVERT LEACHATE TO SEWER, REPAIR LAHDFILL LEAK
IN THE EVENT OF CONTAMINATION, REMEDIATE OR REPLACE PUBLIC AND/OR PRIVATE WATER SUPPLIES
DESIGN BERMS TO ACT AS NOISE BARRIERS TO COWVNITY
SURVEY TO IDENTIFY ARCHAEOLOGICAL RESOURCES; DEVELOP MITIGATION IF'NECESSARY
ACQUISITION BY MWRA OF PRIME FARMLAND IN THE VICINITY OFWALPOLE MCI SITE
CONTROL OR CONTAIN RUNOFF
MONITOR NEARBY SURFACE WATERS, SAMPLE THE STOP RIVER ABOVE, BELOW AND ADJACENT TO
SITE AND ABOVE AND BELOW STORMUATER OUTFALLS
CONTROL OR CONTAIN EROSION WITH HAY BALES, SILT FENCES, BERMS, ETC.
MINIMIZE THE NEEO FOR BACKING UP OR ELIMINATE TRUCK BACKUP SAFETY SIGNALS BY
PERSONNEL SAFETY TRAINING, AND EXCLUDE UNTRAINEO PERSONNEL FROM SITE
MODIFY FOOTPRINT DESIGN TO AVOID BORDERING VEGETATED WETLANDS AND WETLAND BUFFERS
LIMIT CONSTRUCTION TO NON-BREEDING PERIODS
CLOSELY MONITOR PERFORMANCE OF HEAT DRYERS AND CENTRIFUGES
RESERVE SPACE AT PROCESSING SITE FOR AT LEAST TWO ADDITIONAL NEAT ORYERS
Kiicss«iNtsse:cisic:s:ttB:B:fc>ete:t:KtisBastRc>s3f9s:i«tt>8icttea:::c:s:;::ss:::s:::sss:
FREQUENTLY COVER GRIT AND SCREENINGS AND MINIMIZE THE WORKING FACE
MONITOR LEACHATE VOLUME
CONDUCT MONIIORING PROGRAM AND PERIOOIC LEAK DETECTION TESTS
DESIGN BERMS TO ACT AS NOISE BARRIER TO COMMUNITY
HISTORICAL/ARCHITECTURAL AHALYSIS OF STONE CRUSHER BUILDING FOR DETERMINATION OF
ELIGIBILITY FOR NATIONAL REGISTER; DEVELOP MITIGATION IF NECESSARY
CONTROL OR CONTAIN RUNOFF
COMTROt OR CONTAIN EROSION WITH HAY BALES, SILT FENCES, BERMS, ETC.
MINIMIZE THE NEED FOR BACKING UP OR ELIMINATE TRUCK BACKUP SAFETY SIGNALS BY
PERSONNEL SAFETY TRAINING. AND EXCLUDE UNTRAINED PERSONS FROM SITE
^CONSTRUCT A HIGHER BANKING WITH VEGETATION BUFFER ALONG ROUTE 1. AND AD]
VEGETATION ALONG RIM OF QUARRY
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IONAI
-------
TABLE 4. - CONTINUED RECOMMENDED MITIGATION MEASURES
I |
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tiamiKssBsnmusssasKsssumfitsntnttnsnessscststsiseaBCtcssettistsxsttiigesxsKSSNBssaBt&ssssssssssssszssssssssss
IMPACT | RECOMHENDEO MITIGATION
l>»lsm>Hcmnif>mismnHxin»tiltttn»l«ni>fnincrts:ia;3sc»£:tzKtsii»ssninnBtmKs>«SBis»neBstssss»is»s
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TRAFFIC AND H01SE IMPACTS ON STREETS WHICH CROSS
ROUTE 139 (PACE. TURNPIKE)
TRAFFIC IMPACTS ON ROADWAY SURFACE
MATERIALS HANDLING OPERATION NOISE IMPACTS
NOISE IMPACT FROM PROCESSING EQUIPMENT
POTENTIAL CULTURAL RESOURCES ON SITE
CONFLICT WITH THE STOUGNTON REDEVELOPMENT AUTHORITY PLANS
CONFLICT BETWEEN RESIDUALS FACILITY SITE AND TOUN'S
ZONING ORDINANCE
EROSION IMPACTS TO SURFACE HATER DURING CONSTRUCTION
ODOR IMPACTS FROM THE COMPOST FACILITY
BACKUP SAFETY SIGNALS NOISE
VISUAL IMPACT OF EMISSION STACKS
ROADWAY RECONSTRUCTION AT ROUTE 24. ROUTE 139, AND PAGE STREET INTERSECTION
UPGRADE INTERSECTION AT ROUTE 139 AND TURNPIKE STREET
SIGNALIZE INTERSECTIONS ON ROUTE 139 At PAGE AND TURNPIKE STREETS
UPGRADE PAVEMENT ON ROUTE T39 AND TURNPIKE STREET
ENCLOSE All UNLOADING AND MATER MIS HANOI f MS OPERATIONS
LOCATE MATERIALS HANDLING AREAS WHICH CANNOT BE ENCLOSED AS FAR FROM SENSITIVE
RECEPTORS AS POSSIBLE
PROVIDE OESIGN THAT MEETS NOISE CRITERIA AT RECEPTORS
SURVEY TO IOENTIFY PRESENCE OF NATIONAL REGISTER ELIGIBLE RESOURCES AND
DEVELOP MITIGATION IF NECESSARY
REDUCE AMOUNT OF ACREAGE NEEDED FOR SITE USE, AllOU FOR ADEQUATE BUFFER
CLOSE COORDINATION BETWEEN MWRA AND SIOUGHTON TO ENSURE COMPLIANCE WITH TOWN'S
PERFORMANCE STANDARDS FOR OOORS
CONTROL OR CONTAIN EROSION WITH HAY BALES, SILT FENCES, BERMS, ETC.
MAXIMIZE SCRUBBER EFFICIENCY USING GOOD ENGINEERING PRACTICES
CAREFUL MONITORING OF pH IN FIRST-STAGE SCRUBBER SOLUTION
MAINTAIN MERCAPIONS REMOVAL EFFICIENCY IN SECOND-STAGE ABOVE 95X
MINIMIZE THE NEED FOR BACKING UP OR ELIMINATE TRUCK BACKUP SAFETY SIGNALS BY
PERSONNEL SAFETY TRAINING AND EXCLUDE UNTRAINED PERSONS FROM SITE
CONSTRUCT STACKS OF MATERIALS OR COLORS WHICH BLEND MORE EASILY INTO SURROUNDING TERRAIN
Htss:ssa8K«BSt&s:«sisnxss:«:sssesss:«es»««cs»esccsecmn*3SS8SS3s«KSSsr:r3S9Ssss:sse
-------
TABLE 4. - CONTINUED RECOMMENDED MITIGATION MEASURES
I SITE I
0
u
1
N
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T
F
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S
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IMPACT
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RECOMMENDEO MITIGATION
nnfinatssMtssscsKsssscsssBsssesss
TRAFFIC IMPACT UNDER WORSE-CASE CONOITIONS
OOOR IMPACTS FROM THE COMPOST FACILITY
MATERIALS HANDLING OPERATION NOISE IMPACTS
NOISE IMPACT FROM PROCESSING EQUIPMENT
BUILDING ON COMPOSTING SITE CONTRIBUTES TO CULTURAL
SIGNIFICANCE OF SHIPYARO
TRAFFIC IMPACTS ON COMMERCIAL STREET ANO ROUTE S3
(WEYMOUTH LANDING)
ROADWAY TRANSPORTATION AND NOISE IMPACTS DUE TO
HEAVY VOLUME OF TRUCKS
EROSION IMPACTS TO SURFACE WATER DURING CONSTRUCTION
BACKUP SAFETY SIGNALS NOISE
VISUAL IMPACT OF EMISSION STACKS
POTENTIAL DISTURBANCES TO MARINE HABITAT AMI BENTHIC
POPULATIONS FROM A SLUDGE SPILL
UPGRADE ANO SIGNALIZE INTERSECTION AT EAST HOWARD STREET AND ROUTE S3
MAXIMIZE SCRUBBER EFFICIENCY USING GOOO ENGINEERING PRACTICES
CAREFUL MONITORING OF pN IN FIRST-STAGE SCRUBBER SOLUTION
MAINTAIN MERCAP10NS REMOVAL EFFICIENCY IN SECONO-STAGE ABOVE 95%
ENCLOSE ALL UNLOADING AND MATERIALS HANDLING OPERATIONS
LOCATE MATERIALS HANDLING AREAS WHICH CANNOT BE ENCLOSED AS FAR FROM SENSITIVE
RECEPTORS AS POSSIBLE
PROVIDE DESIGN THAT MEETS NOISE CRITERIA AT RECEPTORS
EVALUATE ALTERNATIVES AND DEVELOP MITIGATION IF DEMOLITION PROPOSED
UPGRADE INTERSECTION GEOMETRY AND SIGNALIZATION
LIMITED USE OF RAIL TRANSPORTATION AND COVERING ALL RAILCARS TO
ENSURE THAT RESIDENTIAL USES ALONG THE ROUTE ARE NOT IMPACTED
ESTABLISH PROTECTIVE PROCEDURES TO BE USED DURING CONSTRUCTION
MINIMIZE THE NEED FOR BACKING UP OR ELIMINATE TRUCK BACKUP SAFETY SIGNALS BY
PERSONNEL SAFETY TRAINING ANO EXCLUDE UNTRAINED PERSONS FROM SITE
CONSTRUCT STACKS OF MATERIALS OR COLORS WHICN BLEND MORE EASILY INTO SURROUNDING TERRAIN
DEVELOP A SPILL PREVENTION AND CONTINGENCY PLAN
esssssssecsssssssssstsssctsssMsiasrctesfs*:
-------
TABLE 4. - CONTINUED RECOMMENDED MITIGATION MEASURES
tS«SStStStS»tM
I SITE |
«S3R»StS»SSSSI
IMPACT
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| RECOMMENOED MITIGATION
DISTURBANCE OF A NATIONAL REGISTER ELIGIBLE SITE ON
THE SOUTH SIDE OF THE SOUTHERN DRUM.IN
NOISE IMPACT FROM PROCESSING EQUIPMENT
CONSTRUCTION OF PIPELINE MAY INTERFERE WITH NORMAL
SNIPPING AND RECREATIONAL BOATING
ODOR IMPACTS FROM THE COMPOST FACILITY
EROSION IMPACTS TO SURFACE WATER DURING CONSTRUCTION
CHANGES IN VIEWS OF THE SITE FROM THOMPSON ISLAM)
AND SQUAW ROCK PARK
VISUAL IMPACT OF EMISSION STACKS
POTENTIAL DISTURBANCES TO MARINE HABITAT AND BENTHIC
POPULATIONS FROM A SLUDGE SPILL
VEEcn»s»xsxsn>»c«»»istimfisBESxiscns«Kstsit«ne«&»»s:
EROSION IMPACTS TO SURFACE WATER DURING CONSTRUCTION
DEVELOP MITIGATION IF DISTURBANCE UNAVOIDABLE
PROVIOE OESIGN THAT MEETS NOISE CRITERIA AT RECEPTORS
CLOSE COORDINATION BETWEEN MURA AND PRIVATE AND PUBLIC AUTHORITIES TO ENSURE THAT
OPERATION AND UTILITY PIPELINE INSTALLATION DOES NOT SEVERELY IMPACT SHIPPING
AND BOATING ACTIVITIES
MAXIMIZE SCRUBBER EFFICIENCY USING GOOO ENGINEERING PRACTICES
CAREFUL MONITORIHG OF pH IN FIRST-STAGE SCRUBBER SOLUTION
MAINTAIN MERCAP10NS REMOVAL EFFICIENCY IN SECOND-STAGE ABOVE 95X
ESTABLISH PROTECTIVE PROCEDURES TO BE USED DURING CONSTRUCTION
PROVIDE FUNOS FOR DEVELOPING EDUCATIONAL PROGRAMS AND FACILITIES ON THOMPSON
ISLAM) TO DISCUSS MURA RESIDUALS (ACUITIES
CONSTRUCT STACKS OF MATERIALS OR COLORS WHICH BLEND MORE EASILY INTO SURROUNDING TERRAIN
DEVELOP A SPILL PREVENTION AND CONTINGENCY PLAN
I
E S
L
E A
N
R D
VISUAL IMPACT OF EMISSION STACKS
POTENTIAL DISTURBANCES TO MARINE HABITAT AND
BENTHtC POPULATIONS FRGH A SLUDGE SPILL
ESTABLISH PROTECUVE PROCEDURES TO BE USED DURING CONSTRUCTION
CONSTRUCT STACKS OF MATERIALS OR COLORS WHICH BLEW) MORE EASILY INTO SURROUNDING TERRAIN
DEVELOP A SPILL PREVENTION AND CONIINGENCY PLAN
-------
Because no adverse water quality impacts were predicted from
processing at Deer Island (any pollutants from air emissions
deposited in the harbor around the island would be diluted and
not exceed water quality criteria), water quality would not
affect public health.
No other significant environmental impacts are expected for Deer
Island. The island is already designated for wastewater
treatment and it is publicly owned, so no land use, visual,
socioeconomic or ecological impacts were predicted. No
significant transportation impacts would occur because all
transport of sludge or sludge products would be by barge using
pre-existing piers. The area of Deer Island designated for
residuals management is far removed from noise receptors, so the
elaborate noise mitigation measures planned for the new
wastewater treatment facilities would be adequate to prevent
significant noise impacts from construction or operation of
residuals facilities.
Deer Island is environmentally acceptable for digestion,
dewatering, and heat drying (either alone or in combination) and
is also acceptable for incineration. Measures which could be
initiated to reduce potential impacts at the Deer Island site are
shown in Table 4.
III. EPA DECISION
III. A. Environmentally Acceptable Options
As summarized above, in the SEIS EPA evaluated the potential
impacts of various residuals management options, and identified
mitigation measures which could be used to reduce the predicted
impacts for each site use. In the Draft SEIS the alternatives
which were determined to be environmentally acceptable, as a
result of the evaluation and with the mitigation measures
described, are shown in Table 5. The environmentally acceptable
site use alternatives in Table 5 can be combined in many ways to
fashion an integrated plan for MWRA's residuals management
program. However, the feasibility of the integrated plan to
provide a reliable managment program for the full project
planning period (1995-2020) must also be taken into
consideration.
21
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TABLE 5. ENVIRONMENTALLY ACCEPTABLE ALTERNATIVES
SITE Dewater Heat Dry Combust Compost Landfill
Walpole MCI
X
Rowe Quarry
Stoughton
Quincy FRSA
X
X
X
X
X
X
Spectacle Isl. X
X
X
X
Deer Isl.
X
X
X
* Deer Island components carried only as backup options in
recognition of the burden carried by the City of Winthrop as a
result of the new secondary wastewater treatment facility.
In MWRA's Draft EIR, its recommended plan was a combination of
heat drying and composting of sludge at the Quincy FRSA and
landfilling of grit and screenings (and dewatered sludge on an
emergency basis) at the Walpole MCI site. Although all of these
site use components fall within the range of environmentally
acceptable alternatives, EPA was not fully convinced that the
MWRA's recommended plan would fulfill the need for an adequate
plan for the full planning period (1995-2020) because the plan
relies on the beneficial reuse of sludge products which currently
have projected contaminant concentrations that could jeopardize
their marketability. In addition, there was concern that
competition from other new generators of similar products could
decrease the potential market available to MWRA. In the Draft
SEIS, EPA laid out five steps that MWRA should take to help
guarantee that adequate sludge product distribution takes place
throughout the planning period:
• MWRA should commit to maximize landfill capacity, in the
event it cannot market its product, by landfilling heat
dried pellets rather than dewatered sludge.
• MWRA should obtain commitments from government agencies to
use MWRA's product for their fertilizing and soil
enhancement needs.
22
-------
• MWRA should obtain DEP classification of the compost
produced by the Deer Island pilot plant and should begin a
program of significant distribution of that product.
• For metals which potentially exceed regulatory standards for
the distribution of sludge products, the MWRA should develop
a plan for confirming the projected levels of these
pollutants, and then if confirmed, for reducing these levels
through pretreatment, source reduction, or targeted
enforcement.
• MWRA should develop a marketing strategy for sludge
products.
Like the MWRA, the EPA supports beneficial reuse of sludge and
sludge products. However, without the assurances listed above,
upon issuance of the Draft SEIS the EPA had reservations that the
MWRA's Draft EIR recommended plan would establish a reasonably
adequate program for residuals management for the full 25-year
planning period. In the Draft SEIS, EPA suggested two
alternative residuals management plans that could be fashioned
from the acceptable sites and technologies shown in Table 5 that
would provide an adequate program for the full planning period.
The first alternative combines heat drying and composting at the
Quincy FRSA (the MWRA's preferred site) with landfilling at both
the Walpole MCI and Rowe Quarry sites. If a significant portion
of the sludge products were not successfully distributed and were
heat dried, adequate capacity would exist to dispose of all
sludge pellets in the two landfills.
The second, and less desirable, alternative combines heat drying
and composting at the Quincy FRSA and landfilling at the Walpole
MCI site (both MWRA's preferred sites) with incineration at
either Spectacle Island or, if needed, Deer Island. Because
incineration provides more volume reduction of sludge than heat
drying, should MWRA be unable to distribute a significant
percentage of its sludge products it could incinerate the sludge
and have adequate capacity for the incinerator ash at the Walpole
MCI landfill. This alternative is contingent on the results of
additional air quality analysis for incineration being
acceptable. If this alternative were chosen, Spectacle Island
would be preferred over Deer Island as the incinerator site
because the Town of Winthrop (which could be impacted by
incinerator emissions) already hosts the MWRA's secondary
wastewater treatment facilities, and fairness concerns dictate
that it should not have to bear further waste treatment burdens
beyond those currently planned unless absolutely necessary.
23
-------
With issuance of the Final EIR, MWRA chose to eliminate
composting as a sludge processing technology, thereby relying
even more heavily on beneficial reuse of the heat dried sludge
pellets. However, MWRA has also responded to EPA's
recommendations, as follows:
• In the Final EIR, MWRA committed to emergency landfilling of
heat dried sludge pellets rather than dewatered sludge ca"ke
whenever possible. MWRA has also executed an agreement with
EPA to ensure that landfill capacity is rationed prudently
throughout the project planning period.
• The MWRA Board of Directors authorized the MWRA to seek
agreements with state agencies to use MWRA sludge products.
MWRA also committed in the Final EIR to try to persuade
state agencies to agree to accept and use sludge product of
suitable quality, and has held informational meetings with
these agencies to educate them about use of the pellet
product.
• MWRA currently is conducting the sampling and analysis
required for DEP classification of the pilot compost, and
expects to file for classification during the summer of
1990. Classification and distribution of the compost will
help establish MWRA as a producer of beneficial sludge
products and demonstrate its ability to negotiate the
regulatory process (which will also be necessary for the
classification of heat dried sludge pellets).
• Although MWRA continues to make significant improvements in
their Toxics Reduction and Control (TRAC) program,
deficiencies do remain. Improvements are needed to upgrade
data management and enforcement management systems,
establish suitable local limits and reduce the
concentrations of molybdenum to below Massachusetts
standards. MWRA has, however, continued to bring
enforcement actions against dischargers to the MWRA sewer
system.
Over the past few months, MWRA has made changes in their
sludge sampling protocols and laboratory test methods to
improve the accuracy of the analyses. Recent data collected
has shown improvements in the quality of the current sludge,
resulting from the use of these sampling and analysis
techniques. In addition, MWRA will soon be instituting an
improved sludge sampling and analysis program using state-
of-the-art instrumentation for improving detection limits
and monitoring more sludge characteristics. This will allow
better projections of future sludge and sludge product
quality to be made.
24
-------
• MWRA committed to a marketing strategy in the Final EIR, but
needs to further pursue identification of methods of
contacting prospective buyers, advertising, transporting the
product, and providing assistance to buyers in obtaining
appropriate permits.
After having considered the MWRA's proposal, public comments, all
available information, and after performing some additional
technical analyses for the Final SEIS, EPA determined that the
MWRA recommended plan (digestion on Deer Island, dewatering and
heat drying at the Quincy FRSA, and landfilling at the Walpole
MCI site) will, along with some additional mitigation measures,
be environmentally acceptable for reliable sludge processing and
disposal throughout the 25-year planning period. The mitigation
measures are described in Section IV of this ROD. The other
options shown in Table 5 were also confirmed as environmentally
acceptable alternatives. These environmentally acceptable
components are unchanged in this ROD.
III. B. Environmentally Preferable Alternatives
In accordance with Federal regulations, the ROD must identify the
alternatives that EPA deems environmentally preferable. This
discloses to the public EPA's assessment of the alternatives on
solely environmental grounds. Thus, environmentally preferable
alternatives are those which EPA believes would result in the
least damage to the biological and physical environment and which
best protect, preserve and enhance historic, cultural, and
natural resources. In determining its environmentally preferable
alternatives, EPA did not consider economics, engineering, or
institutional factors. EPA's environmentally preferable
alternatives are shown in Table 6. The designation of options as
environmentally preferable is conducted solely for the purposes
of full disclosure and compliance with NEPA regulations, and does
not in any way dictate which options are finally recommended or
implemented.
Some alternatives deemed environmentally acceptable in this
environmental review are not also considered environmentally
preferable. However, it should be understood that such
alternatives remain acceptable and could be chosen for
implementation by MWRA at a later date if necessary.
Landfill Alternatives
Although each landfill site individually is considered
environmentally preferable, use of both sites is not. EPA
believes that with responsible management of landfill capacity
and with an appropriate marketing strategy (as discussed above),
impacts resulting from the development of more than one landfill
25
-------
site can be avoided. Implementing more than one landfill vould
generate a larger overall level of environmental impact by
exposing the public and the environment to such impacts at more
than one location. Construction and operation of two landfills
would result in greater overall environmental impact than a
single landfill because the smaller size of the landfills would
not result in proportionately lesser impacts.
Processing Alternatives
Combustion as a residuals processing technology (at any site) is
not considered an environmentally preferable alternative because
combustion does not make use of the potential for sludge products
to be beneficially reused. Reuse takes advantage of the nutrient
and energy value of the sludge to create products which can be
used as an alternative to manufactured fertilizer products. In
addition, combustion could result in potential exceedances of
state air quality limits which could contribute to health effects
from air emissions. Because such health effects are uncertain,
EPA does not consider combustion to be unacceptable.
Composting at the Quincy FRSA or Stoughton site is not considered
environmentally preferable compared to heat drying alternatives
and composting at Spectacle Island. This is because of the
impacts associated with the significantly greater number of
trucks required for transport of dewatered sludge, bulking
materials, and finished compost. Also, potentially significant
odor impacts generated by a composting facility at these sites
could occur at nearby receptors.
TABLE 6. ENVIRONMENTALLY PREFERABLE ALTERNATIVES
SITE
Dewater Heat Dry Combust Compost Landfill
Walpole MCI
X
Rowe Quarry
X
Stoughton
X
Quincy FRSA
X
X
Spectacle Isl. x
X
X
Deer Isl
X
X
26
-------
III. C. Preferred Option
The MWRA, as the entity that will have to build and operate the
residuals facilities, has the primary voice in determining what
combination of sites and technologies would most optimally serve
its needs for residuals management. EPA's role is to evaluate
the MWRA's proposed program and alternatives to it in accordance
with NEPA and to ensure that the sites and technologies selected
are environmentally acceptable and will result in long-term
compliance with the Clean Water Act.
With the mitigation measures outlined in Section IV of this ROD,
EPA believes that the MWRA recommended plan of digestion on Deer
Island, dewatering and heat drying at the Quincy FRSA, and
landfilling at the Walpole MCI site will be environmentally
acceptable for reliable sludge processing and disposal throughout
the full 25-year planning period. These program components" are
also among the environmentally preferable alternatives.
Therefore, recognizing MWRA's primacy in determining what
combination of sites and processes would best serve its needs,
the MWRA's proposed residuals management plan is approved by the
EPA.
IV. MITIGATION AND MONITORING
The following is a discussion of mitigation measures that EPA
feels the MWRA should take in order to minimize the potential for
any adverse environmental impacts resulting from implementation
of the recommended residuals management plan. This discussion is
also contained in Chapter 6 of the Final SEIS.
In order to ensure that these mitigation measures are
implemented, EPA will include appropriate requirements in
whatever permits are issued by the Agency for the residuals
facilities, such as NPDES permits (for any discharges of treated
wastewater effluent or stormwater, and sludge management). EPA
will also, as appropriate, include necessary conditions in any
related grants that the Agency might make to the MWRA.
IV. A. Residuals Processing
MWRA has acknowledged that, assuming at least one heat drying
train is sometimes unusable, in the later part of the.project
period sludge generation would exceed the capacity of the
proposed six heat drying trains. In addition, if the centrifuges
do not perform at the expected level at all times (at least 25
percent solids), sludge generation would exceed heat drier
capacity in the later part of the project period. Therefore, EPA
27
-------
recommends that MWRA act to ensure that space will be available
at the Quincy FRSA for possible construction of at least two
additional heat drying process trains. The heat drying
facilities should also have the flexibility to allow for full use
of all available heat dryers, regardless of which centrifuges are
operational.
The performance of the heat dryers and centrifuges should be
closely monitored prior to implementation of secondary treatment
so that MWRA can determine if, when and how many additional units
should be installed. As discussed above and in the Final SEIS,
MWRA and EPA have signed an agreement regarding husbanding of the
landfill to ensure adequate capacity throughout the 25 year
planning period. EPA's acceptance of MWRA's plan is conditioned
on MWRA adherence to that agreement.
IV. B. Water Quality Monitoring and Protection - Walpole MCI
The proposed residuals landfill at the Walpole MCI site should be
designed using state-of-the-art technology for a residuals
landfill and in full accordance with guidelines established by
the DEP Division of Water Pollution Control (DWPC). EPA
recognizes, as does the MWRA, that "state-of-the-art" for
protective landfill technology may change. Therefore, MWRA will
reassess the proposed design during the design stage to determine
the most appropriate lining system for the residuals landfill (at
least as protective as the one proposed and evaluated in the
SEIS). The following recommendations for monitoring at the
landfill site will ensure that in the unlikely event of a leak,
detection will occur quickly and remediation can occur in a
timely manner to ensure protection of ground and surface water
quality.
Leachate Collection system
The Walpole MCI residuals landfill will have at least a double
liner and double leachate collection system. Systematic sampling
and testing of both systems should be required in order to
monitor the quality of leachate entering the sewer system.
Systematic testing can be used to establish a baseline of the
quality and quantity of the leachate so that any irregularities
that may indicate a leak would be immediately apparent. A
leachate flow monitoring program should be established in order
to ensure that the liners perform continuously at their optimum
levels. The leachate collection system must also be designed to
keep the leachate separate from uncontaminated stormwater.
Landfill Monitoring
The proposed design and operation of the residuals landfill is
expected to fully mitigate any potential adverse impacts.
However, a systematic sampling and testing program must be
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established in order to detect and evaluate any potential
contaminant releases to the areas surrounding the landfill site.
Materials Monitoring. A monitoring program should be
established for all materials which are deposited on site
during both the construction and operation phases of the
project. Soils used in the construction of the landfill
liner, leachate collection and capping systems should be
sampled prior to use. All grit and screenings deposited
within the landfill during normal operations should be
tested, as should any pellets or sludge which require
disposal. The materials monitoring program will thus
provide a measure of quality control over landfill deposits
and construction materials.
Groundwater Monitoring. In the unlikely event that both the
primary and secondary liners failed and the leak was not
detected by the leachate collection system, there would be a
potential for on site contamination of groundwater to occur.
Therefore, a series of monitoring wells should be installed
surrounding the site to provide an early warning of
contaminant migration from the landfill before significant
impacts occur. The wells should be sampled at regular
intervals and be compared with background data in order to
detect changes in groundwater quality. As discussed in
Section 3.4 of the Final SEIS, the rate of contaminant
migration is expected to be on the order of hundreds to
thousands of years and thus the early detection afforded by
these wells will provide sufficient time for cleanup and
repair. As with all aspects of the landfill design, the
exact number and location of the monitoring wells should be
defined during the design stage and will be subject to
complete DEP approval. However, for purposes of
illustration a possible monitoring well configuration was
developed for the Final SEIS, and is shown in Figure 3.
The approximations of the locations and spacing of wells
were determined using numerical and statistical
approximations of the likely path and shape of a possible
leachate plume. A discussion of the method used is included
in Appendix A of the Final SEIS. The results of the
analysis suggest that, in general, a monitoring well spacing
of approximately 500 feet to 1000 feet would be sufficient
to detect a potential leachate plume. A spacing of
approximately 400 feet would probably be needed in areas
where the monitoring wells are closer to the landfill, such
as between the site and the private wellfields located along
Winter Street. In all, the analysis predicted that
approximately 12 wells would provide sufficient capacity for
contaminant detection. As discussed above, the actual
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Ututl
Cedar Swamp
n»
tn^tituU
W&lpole
%
Vyf—'_V
fumping
B»> St
AlMki
kCA
SCALE IN METERS
2000 0
SCALE IN FEET
LEQEND
_ APPROXIMATE SITE BOUNDARY
_ APPROXIMATE LANDFILL BOUNDARY
APPROXIMATE LOCATION OF
POTENTIAL MONITORING WELLS
FIGURE 3. POSSIBLE MONITORING WELL LOCATIONS - WALPOLE MCI
30
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location and number of wells will be defined and approved
during the design stage.
While the well configuration shown in the figure is
approximate only, it serves to highlight the general areas
which should be monitored. A series of monitoring.wells
should be installed along the slope between the landfill and
the eastern side of the Stop River, with an additional well
adjacent to the Stop River impoundment. Wells should also
be installed along the northern boundary of the site between
the landfill and the private wells and along the western
boundary between the landfill and the Neponset Sole Source
Aquifer. A well should also be located upgradient from the
site to provide representative background groundwater
quality data. It is recommended that at some monitoring
locations a cluster of wells be installed in order to obtain
samples at various depths throughout the aquifer. Bedrock
wells may also be required to monitor flow in fractured
bedrock.
EPA recommends that MWRA utilize existing monitoring wells
wherever possible, both prior to and during the landfill
operation stage. For instance, the existing wells can be
used to monitor groundwater quality in the period prior to
landfill construction and operation. Quarterly water level
measurements would also provide additional data for design
of the final monitoring well configuration . Staff gauges
and piezometers should be installed as well for continued
investigation and evaluation of the site's groundwater flow
regime. In order to ensure the establishment of a
comprehensive, tailor-made monitoring program, MWRA should
provide an opportunity for EPA. and DEP input into the
design, installation and operation of the monitoring wells.
The sampling schedule and list of parameters should be
defined in the plan of operation. EPA recommends that all
observation wells be sampled on a quarterly basis and
suggests that MWRA sample and test the two nearby private
wellfields once a year at the request of the individual
property owners. The list of sampling parameters should be
continually evaluated and refined throughout the life of the
project. At the very least, MWRA should sample for metals
and total organic carbon, with additional sampling for other
more specific parameters as the need arises. MWRA should
continue to evaluate the results of pilot studies and
conduct additional leachate analysis prior to landfill
operation in order to further define a list of likely
sampling parameters. MWRA may choose to monitor for
contaminants which migrate most quickly (i.e., those with
zero or low retardation factors) and should also sample
periodically for contaminants for which drinking water
31
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standards exist. In addition, advances in wastewater
treatment or groundwater monitoring may be realized in the
period prior to actual landfill operation and may influence
the list of sampling parameters. Several factors can
therefore potentially affect the choice of sampling
parameters.
The remedial action to be taken by MWRA in the event of a
landfill leak should depend on the amount of residuals
material deposited in a particular cell, if the cell is
Hearing capacity it should be capped to prevent further
infiltration thereby halting leachate production. If the
cell leaks before it reaches capacity, the residuals
material should be removed so that the leak may be found and
repaired. Repairing the leak in this fashion will therefore
preserve cell capacity.
Surface Water Monitoring. A sampling and testing program
should be established to monitor nearby surface waters. As
noted above, runoff will be diverted around the site to
minimize the potential for stormwater contamination.
Although no contamination is expected to occur, all
stormwater discharges to surface waters should be monitored
at regular time intervals. In addition, the Stop River
should be sampled both above anc oelow all stormwater
outfalls. The Stop River impoundment also should be
monitored at various locations.
contingency flans
The combination of state of the art technology and the rigorous
environmental monitoring described above is expected to provide
complete mitigation of any impacts which might occur from
operation of the proposed Walpole MCI residuals landfill.
Nevertheless, a detailed contingency plan must be prepared prior
to construction of the landfill and this plan should identify all
the appropriate design features and monitoring plans which will
be required to prevent contamination of the site and surrounding
areas. The contingency plan should also include a discussion of
methods to be implemented by MWRA in the event that remedial
action is necessary. In the unlikely event of leachate
contamination of water supplies, MWRA should either remediate or
replace public and private water supplies.
IV, c. Other Mitigation Measures
In addition to those measures outlined above, the following are
recommended by EPA as additions to the MWRA-recommended plan.
32
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• Whenever possible, residuals barge trips to and from Deer
Island should be limited to the daytime, when they will not
add significantly to the ambient noise level.
¦ MWRA should continuously monitor the landfill for methane
gas production and if excessive amounts of gas are produced
the problem should be remediated immediately.
• Materials excavated in preparing the Walpole site for the
landfill should be used to form berms on the site to
mitigate noise and visual impacts and to reduce the number
of trucks leaving the site during this stage of the landfill
construction.
V. CONCLUSION
EPA has conducted an independent environmental review of the
MWRA's plans for long-term residuals management for Boston-, as
directed by the National Environmental Policy Act and stipulated
in the Record of Decision on the 1986 treatment plant Siting EIS.
This process has been subject to extensive public scrutiny,
through a number of public meetings, hearings, and public comment
on both the Draft and Final Supplemental Environmental Impact
Statements. EPA believes this open process has resulted in a
fair and reasonable conclusion.
After careful and objective analysis of a range of reasonable
alternatives EPA has, with the mitigation measures stipulated in
the preceding section, approved the MWRA's proposed long-term
residuals management plan:
¦ digestion of primary and secondary sludge at Deer Island;
• transport of the digested sludge by barge from Deer Island
to the Quincy FRSA;
• dewatering and heat drying/pelletizing of the sludge at the
Quincy FRSA; and
• landfill of grit and screenings, with backup capacity for
heat dried pellets or dewatered sludge cake, at the Walpole
MCI site.
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APPENDIX A
RESPONSES TO COMMENTS
COMMENTS RECEIVED
As part of the environmental review process for this SEIS, 60 day
public comment periods followed the issuance of the Draft SEIS in
May 1989 and the Final SEIS in November 1989. Responses to
comments submitted on the Draft SEIS were provided in Chapter 4 of
the Final SEIS. Similar to the Draft SEIS, the Final was
distributed to the Citizens Advisory Committee, libraries or other
repositories, state and federal agencies, local governments, ana
other interested parties.
Written and oral comments on the Final SEIS were received from
state and federal government agencies, representatives of some of
the communities that could potentially be affected by the project,
and a number of other interested organizations and private
individuals. EPA has reviewed each comment in preparation for this
ROD. Because of the number of comments received and their similar
subjects, the comments have been grouped and summarized here.
The approach used in responding to comments here parallels that
used in responding to comments on the Draft SEIS; the same issue
categories have been used. Each comment letter has been given an
identification number, and has been reproduced in Appendix B.
Table A1 presents a matrix for locating the issues raised in each
comment letter, corresponding to the issue headings for the
responses given below.
Some comments received were either very general or expressed the
writer's opinion without addressing a particular issue. These
comments are categorized as "general comments" in Table A1 and were
considered but do not require a direct response. Comments on MKRA
documents which were incorporated by reference in comments on the
SEIS are not responded to specifically here. However, all of these
comments have been read and considered as part of the decision-
making process. Also, EPA has itself already filed detailed public
comments on the MWRA's environmental review documents under the
MEPA public review process. Finally, the substance of some
comments has been addressed previously in the Draft or Final SEIS
or is directly covered in this Record of Decision; in such cases,
the reader is referred to the appropriate section of the relevant
document.
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TABLE A-l. COMMENTS RECEIVED ON THE FINAL SEI8
Air Quality & Odor
Ecology j|
Editorial ||
Ground & Surface Water |[
Landfill |
Marketability
0)
(0
'H.
0
S;
Policy & Regulations
Prison ||
| Public Health
Sludge Character ||
Socioeconomic ||
Technologies
Transportation
Utilities
General
Letter
ID #
Commentor, Affiliation
01
R.G. James Hunter, Walpole
X
X
X
02
Mayor George V. Colella, Revere
X
03
Mary Jane Wachtel, Norfolk
X
X
04
Samuel R. Maloof
X
X
05
Karen DeAngelo, Norfolk (1)
X
X
X
X
X
06
Joseph Tinney, Walpole (1)
X
X
07
Thomas W. Conrardy, FL DER
X
X
08
Mr. & Mrs. David McKlwee, Norfolk
X
X
X
X
X
09
Timothy & Christina Wider, N'folk
X
X
10
Larry Bassignani, Norfolk (2)
X
X
X
X
X
25
S. David Graber, for Winthrop
X
X
X
X
-------
Air Quality & Odor
Ecology
Editorial
Ground & Surface Water
Landfill
[ Marketability
Noise
Policy & Regulations
Prison
Public Health
Sludge Character
Socioeconomic
Technologies
Transportation
Utilities
General
Letter
ID #
Commentor, Affiliation
26
James Giebfried, Norfolk
X
X
X
X
27
William F. Lawless, ACOE
X
X
X
X
28
Carol S. Minkwitz, Walpole
X
X
X
29
Gillespie Assoc., for Walpole
X
X
X
30
Harlan M. Doliner, for Winthrop
X
X
X
31
David Standley, for Quincy
X
X
X
X
X
X
32
William Gaughan, MA DEP
X
X
X
33
John C. Hahn, Walpole
X
X
X
X
34,35
Robert C. Howard, Norfolk
X
X
X
X
X
X
X
X
X
36
John W. Giorgio, for Walpole
X
X
X
X
X
X
X
37
Christopher H. Little, for N'folk
X
X
X
X
X
X
Notes: (1) Comments submitted over the telephone
(2) Also comment letters numbered 10 through 24 and 38
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AIR QUALITY AND ODORS
Methodology
Some commentors reiterated their dissatisfaction with the air
quality assessments for the Quincy FRSA and Deer Island sites, or
with the Final SEIS responses to comments on that subject. The
issues raised include synergistic effects of air emissions/
projected emissions of pollutants, and the information used in the
predictive air quality model. One comaentor was concerned that
the SEIS did not adequately address control of odors from
facilities at Deer Island. Another commentor felt that there was
insufficient analysis of impacts from odors from the proposed
landfill. In Section 5.4 of the Draft SEIS, EPA described the
computer modelling that was conducted to predict changes in air
quality resulting from residuals processing, and the derivation of
information input to the model. Emission rates of pollutants,
including odorous compounds, from each process were either derived
from information from extensive literature searches or estimated
using data from actual pilot testing. The results of the computer
model were used to assess not only the direct effects on air
quality at ground level, but also the effects on water quality and
soils (from deposition of particulates emitted) and potential
effects on public health. EPA feels that the evaluation conducted,
along with further information provided in Sections 5.4.2, 5.4.3,
and 5.6.2 of the Final SEIS, addresses these issues to the extent
appropriate for this level of analysis, and supports the findings
of the Draft and Final SEIS and this ROD.
As reported in Section 5.4.5 of the Final SEIS, there was no
information found in the literature that could be used as a basis
for predicting odor impacts from landfilling residuals other than
qualitatively. EPA did make the conservative assumption that
significant odors could be produced during landfill operations (see
Section 5.4.3.1 of the Draft SEIS); thus requiring daily covering
of landfilled materials. This is a common practice that has been
shown to be effective in mitigating the effects of odors from
landfills.
Greenhouse Gases
One commentor requested a quantitative response to the issue of
the residuals processing facilities contributions of greenhouse gas
emissions and the consequent contribution to the greenhouse effect.
Emissions of carbon monoxide and nitrogen dioxide were discussed
in Section 5.4 of the Draft SEIS. Methane is not expected to be
emitted by the incineration, heat drying, or composting processes.
The predicted emissions of carbon monoxide and nitrogen dioxide
were a fraction of the applicable regulatory limits. It is not
possible to quantify the impact that these emissions would have on
the greenhouse effect, particularly considering the many other
sources of these pollutants. It should be noted that, in part due
to air emissions, incineration at any site is not considered by EPA
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to be one of the environmentally preferable alternatives (see
Section III of this ROD).
ECOLOGY
Commentors bad concerns regarding protection of wetlands and
wildlife at the Walpole MCI site, and compliance with Section 404
of the federal Clean Water Act. Impacts to wetlands adjacent to
the Walpole MCI site would only occur if the landfill leaked and
leachate was not collected. Discussions of the potential effect
of such a leak on wetlands and wildlife were presented in Section
5.8.2 of the Draft SEIS, and discussed further in Section 5.7.1 of
the Final SEIS. As stated in Section 5.7.2 of the Final SEIS, no
direct impacts on wetlands are expected, and indirect impacts would
not be significant. However, review of the wetland delineation by
local, state, and federal authorities will be necessary, as
required by Section 404 of the Clean Water Act and Presidential
Executive Order No. 11990.
GROUND WATER AND SURFACE WATER
Walpole MCI Bite
Several commentors felt that the EPA water quality analyses for the
Walpole MCI site were inadequate and did not account for
information presented along with comments on the Draft and Final
8EIS. The issues raised in these comments include fractured
bedrock, bedrock ridges, groundwater elevations, hydraulic
properties of soils, and ground/surface water interactions. One
commentor felt that because the site is part of the "estuarine
zone" of Massachusetts Bay, siting the landfill there would violate
the goals of the National Estuaries Program and the protection of
Massachusetts Bay. All of the information that was submitted
during the SEIS process has been considered. Thorough descriptions
of the ground and surface water evaluations for the Walpole MCI
site and the conclusions reached are presented in Sections 4.4.3,
5.5.2, and 6.2.1 of the Draft SEIS and Sections 3.3, 3.4, 5.1, and
Appendix A of the Final SEIS. Enough data has been collected to
adequately characterize the groundwater hydrology of the site and
conservatively predict the impacts of an undetected and
unremediated landfill leak. EPA feels that the level of
information available and evaluations conducted are sufficient to
support the conclusions described in the Record of Decision.
The Stop River is a tributary of the Charles River, which is part
of the Massachusetts Bay watershed. However, EPA does not believe
that locating the residuals landfill at the Walpole MCI site will
result in significant impacts to the water quality of the Stop
River. Therefore it will not contribute to the degradation of the
Charles River or Massachusetts Bay. In fact, the MWRA long-term
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residuals management program will have a very beneficial effect on
the water quality of Massachusetts Bay by discontinuing the
discharge of sludge to Boston Harbor.
Mitigation and Contingency
One commentor felt that the landfill monitoring described in the
SEIS should be required, but wanted to know how long monitoring
would continue after landfill closure and what contingencies would
be required if the Stop River became polluted. Several commentors
referred to the monitoring and mitigation scheme as being
inadequate. EPA feels that the MWRA proposed design, incorporating
the measures described in Section 6.4.2 of the Final SEIS, is
sufficient to protect public health and the environment. Measures
taken to remediate contamination of the ground water (such as in-
place treatment of ground water) would also remediate contamination
of the Stop River. The MWRA will be required, through state and
federal permits and approvals, to monitor the landfill during
operation and after closure. There is no regulatory limit on the
duration of the monitoring program after landfill closure;
monitoring will be required for as long as the permitting agencies
feel is necessary to protect ground water. Also, the monitoring
and mitigation scheme will be subject to revision based on the most
up-to-date information available during landfill design and
operation.
LANDFILL
Landfill Capacity
Several commentors expressed dissatisfaction with the analysis of
landfill capacity at the Walpole MCI site, and feel that any
reduction in the land area actually available for the landfill
would mean that the site cannot meet the minimum landfill capacity
being required by EPA in an agreement with MWRA. one commentor
felt that a schematic of the landfill design should contain the
quantity of residuals. Sections 2.3, 2.6, and 5.3.1 of the Final
SEIS provide information regarding capacity of the landfill, and
how the proposed management of landfill capacity satisfies EPA's
needs. It should be noted that all of the capacity figures cited
by MWRA and EPA are estimates, based on the information available
to date. We fully expect that these numbers will be refined during
final design. Understanding this, the August 10, 1989 agreement
executed between EPA and MWRA is intended to ensure that landfill
capacity is not "used up" too soon (and therefore not available as
a backup method of sludge disposal throughout the full project
planning period), rather than setting a specific requirement of
capacity that must be available. However, if for any reason the
available landfill capacity is significantly reduced, EPA will need
to reevaluate whether. the remaining capacity is sufficient to
assure adequate backup disposal.
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Section 5.7.1 of the Draft SEIS discusses the visual impacts that
would result from implementation of the residuals landfill at the
Walpole MCI site. In addition, Section 2.8.2 in Volume 2 of the
MWRA's Draft Environmental Impact Report (February 1989) presents
several projected views of the landfill after development.
Landfill Design
Several commentors expressed concerns that the proposed landfill
liner and monitoring well systems would not be reliable, and are
not state-of-the-art. The possibility of earthquakes and
generation of landfill gas were also questioned. One commentor
requested that EPA state the probability of a landfill leak,
contamination of water resources and wildlife, and effect on public
health. The landfill design, monitoring plans, and mitigation
have been discussed extensively throughout the Draft and Final
SEIS. EPA feels that, with the monitoring and mitigation measures
stipulated in Section IV of this ROD, the landfill design proposed,
for the Walpole MCI site is sufficient to protect human health and
the environment. However, state-of-the-art technology for landfill
design continues to improve. For this reason, during the design
phase MWRA will reassess the proposed design to determine the most
appropriate technology - at least as protective as the currently
proposed design - for the residuals landfill.
There are no active faults in the vicinity the Walpole MCI site,
nor are there even any capable faults in New England (there has
been no movement in the last 35,000 years and no multiple movements
in the last 100,000 years). Consequently there is no reason to
believe that the possibility of an earthquake should be accounted
for in the landfill design. Landfill gas is discussed in Section
5.3.2 of the Final SEIS, and is not expected to be hazardous.
It would be speculative for EPA to state a statistical probability
for a landfill leak to occur. It has been acknowledged in the
Draft and Final SEIS that landfill leaks can occur. A detailed
discussion of the mechanisms involved in the transport and fate of
landfill leachate is presented in Section 5.2.2 of the Draft SEIS
and Section 3.3 of the Final SEIS. These conservatively conducted
analyses show that only under extreme worst case conditions would
a landfill leak have any significant impact on ground and surface
water, and a good monitoring program should be able to detect such
a leak with adequate time to remediate any adverse impacts.
MARKETABILITY
Several commentors expressed concern that the KWRA heat dried
pellet product would not be marketable due to high levels of
toxics, and would therefore end up being landfilled. One commentor
requested that EPA abate the uncertainty about marketability of
MWRA sludge products by negotiating an ad-hoc agreement that will
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protect the MWRA's and ratepayers1 investment in residuals
processing facilities from any adverse outcome of the Federal
regulatory process. Although EPA continues to have concerns
regarding potentially high levels of some pollutants present in
MWRA sludge, we believe that MWRA will be able to distribute and
market enough of the pellet product to assure a reliable long-term
sludge management program. However, an integral part of that
management program must be an adequate backup disposal method such
as sufficient available landfill capacity.
Regarding future sludge management regulations, it is assumed that
any applicable regulatory limits or requirements will be
implemented with the goal of protection of human health and the
environment. EPA cannot, and it would be inappropriate for EPA to
attempt to supersede state or federal requirements by executing
such an agreement with the MWRA.
As for existing sludge regulations, the Massachusetts Department
of Environmental Protection has taken the position that even if
EPA's conservative projections of elevated Molybdenum levels were
to occur, this "still should not pose a significant roadblock to
development of in-state and out-of-state markets for MWRA's sludge
pellets" (see comment letter #32). As discussed in Section III of
this ROD, MWRA has already begun to make progress on identifying
problem pollutants present in the wastewater and actions that can
be taken to reduce levels of those pollutants.
NOISE
One commentor expressed dissatisfaction with the responses that
were provided in the Final SEIS to earlier comments regarding
noise. The earlier comments were concerned primarily with the
noise assessment methodology and assumptions used. EPA believes
that the evaluations presented in the Draft SEIS (Section 5.6.8)
is sufficient to support the conclusions presented therein (and
confirmed in both the Final SEIS and this ROD), and stands by the
responses in Section 5.12.2 of the Final SEIS.
POLICY AND REGULATIONS
Alternatives
Some commentors did not feel there was an adequate range of
alternatives evaluated, and disagreed with the definition of the
no-action alternative because it did not include the private
disposal of residuals and sludge at commercial landfills. One
commentor requested that a supplement to the Final SEIS be prepared
by EPA pursuant to 40 CFR Section 1502.9(c) of the regulations
implementing NEPA. The no-action alternative for this SEIS was
defined as that which would occur in the event interim measures
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(disposal of grit and screenings at a commercial out-of-state
landfill and the short-term residuals management program) were
discontinued in 1995. If these measures were discontinued, and no
long-term measures were taken, it was assumed that the present
method of sludge disposal (ocean dumping) would be resumed. This
was considered environmentally unacceptable and illegal, and no
further evaluation of this no-action alternative was conducted.
It should also be noted that landfilling of sludge as a primary
disposal method and long-term privatization were considered as
major sludge management technologies, but screened out early in the
SEIS process, as described in Section 2.2 of the Draft SEIS.
As discussed in Section 5.2.1 of the Final SEIS, EPA feels that a
suitable number and range of types of alternatives were evaluated
at each stage of the SEIS process. 40 CFR Section 1502.9(c) states
that:
"Agencies:
(1) Shall prepare supplements to either draft or final
environmental impact statements if
(1) The agency makes substantial changes in the proposed
action that are relevant to environmental concerns; or
(ii) There are significant new circumstances or information
relevant to environmental concerns and bearing on the proposed
action or its impacts.
(2) May also prepare supplements when the agency determines
that the purposes of the Act will be furthered by doing so."
As noted above, all additional information presented has been
considered by EPA. Although the additional information is useful,
it has not led to a substantial change in our conclusions regarding
the impacts of the project. Therefore, it does not rise to the
level of requiring a supplement.
Regional Responsibility
one commentor stated that failure to consider the prisons adjacent
to the Walpole MCI site in terms of regional responsibility renders
the entire environmental review process for this project fatally
flawed. EPA stands by the definition of regional responsibility
as described in Section 2.4.1.4 of the Draft SEIS and Section 5.2.2
of the Final SEIS. EPA also notes that the Massachusetts agencies
working or commenting on this project also approve of this
definition, which bears on the distribution of state run facilities
throughout the Commonwealth.
Environmental Regulations
Several commentors questioned the adequacy of the SEIS analyses of
compliance vith state and federal sludge management regulations,
and the conversion of land use under the federal Farmland
Protection Policy Act. As discussed in detail in Section 5.5.1 of
the Final SEIS, regulation of wastewater residuals by the
Massachusetts Department of Environmental Protection is a matter
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of state law, and the SEIS reflects the DEP position. It is
premature to evaluate the MWRA residuals management plan in light
of proposed federal sludge management regulations (proposed at 54
Fed. Reg. 5746, February 6, 1989) because the proposed regulations
will be undergoing significant revision prior to final
promulgation. However, MWRA will be required to comply with
whatever standards or .guidelines are in effect at the time of
facility operation.
Section 4201(b) of the federal Farmland Protection Policy Act
directs Federal agencies to evaluate effects of federal programs
on the conversion of farmland to nonagricultural uses, and consider
alternatives that could lessen such effects. EPA's evaluation of
the effect of siting the residuals landfill at the Walpole MCI site
has been addressed in Sections 4.1.2.2, 4.1.4.4, and 5.2.2 of the
Draft SEIS.
Navigable Waters Act
Several comment letters stated the opinion that the siting of the
residuals landfill at Walpole vould violate provisions of and be
inconsistent with the goals of the Clean Water Act. In particular,
some of the comment letters declare that the proposed landfill will
violate the Clean Water Act's requirements that Best Practicable
Control Technology (BPCT) and Best Available Technology
Economically Achievable (BAT) be used. These comments have already
been addressed in Section 5.2.4 of the Final SEIS. In addition,
however, EPA has considered these comments and does not believe
that siting the proposed landfill at the Walpole MCI site violates
the Clean Water Act or that it is inconsistent with the Act's
purposes. Rather, the landfill is part of a program to end the
current and long-standing violations of the Clean Water Act by the
discharge of inadequately treated wastewater and sludge to Boston
Harbor. Therefore, the landfill, as part of the MWRA's overall
residuals management plan, will help to achieve the goals of the
Clean Water Act. Of course, the landfill must also be operated and
sited in compliance with the sections of the Act that apply to
protect waterways and wetlands. As discussed in the Draft and
Final SEIS and this ROD, EPA believes the proposed landfill at the
Walpole MCI site will comply. Moreover, EPA has proposed
mitigation measures (see Section IV of this ROD) to help ensure
that this is the case. Existing regulatory programs will continue
to apply to the landfill operation. If the applicable regulatory
programs change or proposed operations change, the regulatory
agencies will respond accordingly at the time.
The levels of required treatment (BPCT and BAT) set forth in
Sections 301(b) (1) (A) and 301(b) (2) (A) of the Clean Water Act apply
to certain types of point source discharges of pollutants to waters
of the United States. They do not apply to the proposed landfill
generally because it is not a proposed point source discharge.
Other standards that may in the future apply to the landfill
A-10
-------
operation, such as the federal sludge management regulations, will
be applied as required once they are in effect.
Compensation
One commentor suggested that it is appropriate for EPA to support
the concept of compensation to communities hosting facilities
serving the regional good. EPA feels that economic compensation
to host communities as mitigation must be made at the discretion
of the MWRA. Appropriate mitigation measures, to minimize or
prevent adverse environmental impacts of the proposed project, have
been described in Sections II and IV of this ROD as well as in the
Draft and Final SEIS's.
Segmentation
Some commentors reiterated a concern voiced in previous comments
that the environmental review process for the wastewater treatment
facility and the residuals management program were illegally
segmented. This issue has been addressed in Section 5.2.1 of the
Final SEIS and in detail in the Final EIS and ROD on Siting of
Wastewater Treatment Facilities for Boston Harbor. It is EPA's
judgement that the siting decision for the secondary treatment
plant does not determine or improperly influence the decision on
long term sludge management, nor would the sludge disposal decision
(if it had been made simultaneously with the treatment plant siting
decision) either have foreclosed or demanded any particular
treatment plant site. EPA's position on the tiering and timing of
Boston Harbor cleanup environmental reviews remains unchanged from
its views as stated in prior environmental review documents,
including the Final Siting EIS and ROD.
PRISON
Some commentors felt that EPA had not adequately assessed the
impacts of the proposed landfill on the prison facilities adjacent
to the Walpole MCI site. EPA has in fact included the prisons,
including both staff and inmates, as sensitive receptors throughout
the environmental analyses. Thus, EPA analyses have included
consideration of the potential environmental effects of the
landfill on the prison population. For example, possible landfill
impacts on the prison water supply and odor and visual impacts on
the prison population were evaluated. In addition, EPA conducted
a literature search to identify any studies about prison
populations that would yield any further pertinent information.
No such information was found, and EPA believes it would be
unreasonable to draw any conclusions regarding any unique impacts
the landfill might have on prisoners or prison employees beyond
those drawn concerning the general population of the area.
A-ll
-------
PUBLIC HEALTH
Borne commentors had concerns with potential toxicity of the sludge
or material that would be landfilled. One commentor felt that
because EPA did not comment on the K9RA*s public health risk
assessment, it neglects the interrelationship of environmental
protection and public health. Public health - including potential
toxicity of sludge and pathways of exposure - was discussed in
Sections 4.8 and 5.9 of the Draft SEIS, and Section 5.6 of the
Final SEIS. Although EPA did not comment specifically on the MWRA
Public Health Assessment (August 1989), that report was considered
in the development of the Final SEIS.
RESIDUALS CHARACTERIZATION
Minor Residuals (Grit 6 Screenings)
Some commentors felt that analyses of the quality of grit and
screenings was inadequate. The quality of grit and screenings is ^
discussed in Section 3.1.5 of the Draft SEIS and Section 5.5.1 of*
the Final SEIS. Characteristics of future grit and screenings are
not expected to be significantly different from current grit and
screenings because these materials are removed from the wastewater
before it enters the treatment system. Results of toxicity testing
of current grit and screenings indicate that they are not hazardous
waste (see Table 3.1-16 of the Draft SEIS). EPA feels that this
information on grit and screenings is sufficient to allow impacts
to be conservatively predicted.
Sludge and Heat Dried Pellet Characteristics
Several commentors felt that the evaluation of sludge quality was
inadequate. As discussed in the Draft and Final SEIS (Sections 3.1
and 3.2, respectively), EPA reviewed the available data on the
quality of materials handled at the existing MWRA facilities,
including extensive sampling of the wastewater influent to and
sludge produced at the existing Deer and Nut Island wastewater
treatment facilities. Projections of future residuals qualities
were then made using this data along with conservatively predicted
efficiencies of the new secondary wastewater treatment system to
be constructed at Deer Island. Conservative assumptions were
always made to allow a sufficient margin of safety in the analyses.
It is not possible to more specifically characterize future
residuals at this time because they will not exist until completion
of the new secondary wastewater treatment facilities at Deer
Island. The mwra will continue to analyze existing wastewater and
sludge to allow more refined projections of future sludge quality.
MWRA will also monitor the quality of residuals once the proposed
facilities are in operation (see Sections III and IV of this ROD).
A-12
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SOCIOECONOMICS
Several commentors were dissatisfied with the Final 8EIS discussion
of property value effects of the proposed landfill at the Walpole
MCI site. In particular, they felt there should be a quantitative
analysis of the impact of the landfill on the Town of Walpole*s tax
base and ability to raise revenue for municipal services. One
commentor felt that the information used in the analysis was
outdated. Another was concerned that development potential was not
adequately addressed. Property value impacts were addressed in
Section 3.6 of the Final SEIS. The analysis concluded that there
can be a range of effects on property values which depend on a
variety of factors, and it is not possible to accurately predict
those impacts - or quantify them. Although some of the studies
cited are several years old, they are the sources of information
which EPA feels are relevant to the evaluation. Potential
development and alternative land use was discussed in Sections 5.2
and 5.13 of the Draft and Final SEIS, respectively.
TECHNOLOGIES
One commentor felt that composting at the Quincy FRSA site was not
an acceptable technology. others felt that the mwra should use
commercial landfills, or alternative treatment technologies,
including vide area ocean dispersal of electron-treated sludge.
Alternatives which EPA believes are environmentally acceptable,
including composting at the Quincy FRSA site, are presented in
Section III of this ROD. Use of commercial landfills and ocean
disposal were considered during the screening process, but were
determined to be nonviable options for making up MWRA's long-term
residuals management program early in the evaluation (see Section
2.2 of the Draft SEIS). Of course, MWRA is free to try to obtain
any available landfill capacity for its sludge, if it can meet all
regulatory requirements. It simply cannot rely on private
landfills to form the basis of its whole residuals management
program.
TRANSPORTATION
Some commentors felt that the SEIS evaluation of traffic impacts
associated with use of the Walpole MCI site was inadequate. As
discussed in Section 5.3.4 of the Draft SEIS, EPA believes no
adverse impacts from traffic associated with the proposed MWRA
landfill at the Walpole MCI site would occur under operating
circumstances other than the extreme case during which dewatered
sludge would be landfilled as a backup measure. This situation
would not persist for more than a few days at a time, and traffic
could be split between two access routes to minimize the effects
to the extent that they would be considered insignificant.
A-13
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UTILITIES AND COST
Bone commentors suggested that EPA should conduct additional
analysis, particularly regarding cost, to address concerns about
the ability of the local sewer and water supply systems to support
the proposed landfill at the Walpole KCI site. As discussed in
Section 5.1.3 of the Draft SEIS and Section 5.11 of the Final SEIS,
cost was not used by EPA in the final evaluation of residuals
management options because the potential difference in cost between
management options was within the range of error associated with
the cost estimates, effectively rendering costs equal for each
option.
Section 2,5 of the Final SEIS describes MWRA's plans for meeting
utility requirements for the residuals landfill at the Walpole MCI
site. EPA feels that the MWRA's proposed plan for utilities at the
site is reasonable, but the alternative measures described are also
acceptable.
EDITORIAL
The following editorial changes correspond to the Draft ox Final
Long-term Residuals Management 8EIB, as labeled.
DRAFT SEIS
Page 3-42, Section 3.3.1. Fifth paragraph, second sentence
reference to Table 3.4-3 changed to Table B.4.
Page 4-60, Table 4.2-?, Note (c) reference to Section 5.2.B
changed to Section 4.2.8.
Page 4-67, Section 4.3.2.2. First paragraph, third sentence
"Neither the potential sewage sludge incinerator, heat drying
facility nor composting facility for residuals management are not
one of the 28 listed source types." changed to "Neither the
potential sewage sludge incinerator, heat drying facility nor
composting facility for residuals management are one of the 23
listed source types."
Page 4-181/ Section 4.7.8.1. Fourth sentence reference to Figure
3.4-16 changed to Figure 3.4-14.
Page 4-196, Section 4.9.5.4. Second paragraph, first sentence
reference to Figure 5.2-1 changed to Figure 4.2-1.
A-14
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Pages 5-111 and 5-112. All references to Section 4.9.2 changed to
Section 4.9.3.
Page 5-111, Section 5.10.2. Second paragraph, first sentence
reference to Section 4.9.4.4 changed to 4.9.5.4.
Page 5-111, Section 5.10.3. First sentence reference to Section
4.9.5.3 changed to Section 4.9.6.3.
Page 5-112, Section 5.10.4. Second sentence reference to Section
4.9.6.3 changed to Section 4.9.7.3.
Page 5-112, Section 5.10.7. First sentence reference to Figure
4.9.9 changed to Figure 4.9.10.
FINAL 8EIS
EPA apologizes for the inadvertent omission of a full copy of the
U.S. Army Corps of Engineers1 comment letter on the Draft SEIS.
That letter has been reproduced along with their comment letter on
the Final SEIS (see Appendix B) . We also apologize for the
inadvertent omission of Table 6.4-1 from some copies of the Final
SEIS due to a printing error. Anyone who requested a copy of this
Table was supplied with one.
Page 6-1, Table 6.2-1. Composting at the Stoughton site should
also be denoted an acceptable site and technology combination.
Page 7-1, Section 7.1. Last sentence of change to page 3-35 of the
Draft SEIS should be deleted, as requested by the Massachusetts
DEP.
A-15
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APPENDIX B
PUBLIC COMMENTS ON THE FINAL 6EI6
-------
January 16, 1990
01
Julie Belaga
Regional Administrator
U. S. Environmental Protection Agency
JFK Federal Building
Boston, MA 02203
Dear Julie:
As you know, the HWRA plana to convert the sewage of
2,500,000 people and over 5,000 builMim Into palletized
• lodge, end then Mil It ae fertilizer. It has entered Into
a contract with NBFCO to take Its output through 1995, and
plans to handle the Marketing Itself after that.
However, if the toxic content of the pelletlzed sludge Is
too high, EPA standards will not allow it to be used as
fertilizer, and Instead It will all have to be disposed of
In the proposed South Halpola landfill. The test results I
have seen froa The National Toxics Caapalgn make It clear
that the sludge will not be saleable under the EPA's
proposed guidelines, which take effect in 1991.
Furthermore, the proposed site in South Walpole sits on top
of a groundwater divide flowing both into the Stop River and
the Keponset River. Aa a sole source aguifer, it supplies
water to the prison complex wells, the Southborouqh Hospital
wells, local residents* wells, and the town wells of Norfolk
and Walpole.
The toxic materials in this sludge h»ve caused cancerous
growths and skin ulcerations on the fish in the Boston
Harbor. 1 fear they will do the saae to us and our
children.
EPA experts have told us that all landfills leak, even
state-of-the-art landfills, and that leaks cannot be located
precisely or repaired because of the successive layers of
sludge covering then.
In short, I believe that the Boston Harbor Project is rea lly
a "Toxics Transfer Prograa" and not a "Cleanup", and that
our drinking water and our health are being imperiled
needlessly with the foreknowledge of all state environmental
authorities involved.
01
Because of the threat poaed by the landfill to our drinking
water and health, I an asking you to intervene In three
ways:
to prohibit the siting of the landfill In South
Walpole, or in any town sourclng Its own water
to recommend the use of existing or new commercial
landfills for sludge disposal, which is entirely
acceptable to the DEI'
alternatively. If the HWRA must have its own
landfill, to restrict the siting to one of the
4J cities and towns altea
-------
OCOIIGE V COICLiA
THt CITY Of
nevcnc. Massachusetts
orricc or the mayor
CITY HALL
02
ja.i l 2 rj 'J
January 2, 1990
Mr. P:ul 6. Keougn
Acting Regional Administrator
U.S. EPA, Region One
JFK Federal Building
Boston, Massachusetts 02203
RE: Final Supplemental Environmental Impact Statement
(SEIS) on Long Term Residuals Management for
Metropolitan Boston
Dear Hr. Keough:
The City of Revere has reviewed the Final SEIS on residuals
management for the Massachusetts Hater Resources Authority
1'l ( 11 'Y
George V. Cole 11 a
Mayor
GVC/eg
-------
Mary Jane Vachtel
10 Fosdvlcv Id.
Norfolk, MA 02056
03
JM I 2 f0?0
Mr. VI111 aa K. RtlUf* Adalnlatntor
United States Environmental Protection Agency
Vathlngton, D.C. 20640
Dear Mr. Reflly,
The MWRA plana to build a landfill lo Valpola oext to the Stop River, a
tributary to the Charlea River, lor duaplag the dally toxic waste It collects from
Ita harbor clcaoup prograa. In order to do io» ft require# a leglalatlve vote
which elIowa transfer of the land froa MCI to MVRAI
All atudlea, (Including EPS'e) ahow that, no aatter hov the landfill la built.
It will eventually LEAK, Once It doaa, Ita leakage will contaminate not only the
drinking water of the residents of Norfolk and Valpola* but alao the Stop and
Charlea Rivera THAT FLOW RIGHT Into Boatoo Harbor aod will MAKE theae two rlvera
the Maaeachuaetta LOVE CANAL.
Even with the beat known technology we have today, there la no proven way to
atop a landfill froa leaking once It atarta, ao If yoo allow a landfill to be built
at the Valpola site, once It atarta to leak* It will coot 1vue to faed Ita
pollutanta Into tha envlronaent and the Stop aad Charlea Rivera year after year!
Norfolk resldenta back the need to clean up Boaton Harbor I00X, but It auat be done
right. If It Isn't, our atate will have Ita own Love Canal. The KURA auat be
STOPPED froa naklng onell Denying the MCI land tranafer to the MWRA will prevent
the MWRA froa aaklng a LOVE CANAL In our atate, and I urge that you do everything
that you can to prevent thl* castrophe.
Vary truly youra.
Mary Jane Vachtel
-------
sW, ii twa
Fl\\ iltaft SFJ5 WUw. Ifetrin«. W ??, I!M!>
Iv^ T^rffi ft estduah Mangftwitt foi MfUofiulcUtt ftasUm
STATEMENT
Saimtc't R i*l» I).
My AkiM is Or. StimiM H. Ma tool W t h«(« he*»n • ronwlutrt in Hte
»(utige nuniKtRveni siei tot iW put ken ya«. F ike of
ocean *i>«U)p degrade ihe i»»r>ne ««viroQ-
Oeflt*.
Imptementaltcin of a sludge disposal alternative based solely on Un<\ di*
{WMi, such u eom^Mtinj/^ tfiyini »»th or in cmibniaticM
with ttwitwtaitoti, over (fie t>h}*e1 ions of the commanitie» involved is neither
a practical no* a politically decttt? final deeisro»»,
Now, I would like to comment briefly cwi the sludge maruflenvnt pUn
Aflnptd by ihe MM/It A Board ami the change* '** »»nI plan swjfcest'Nj hy
the CPA. The MWRA liu rhnsen 1 t> produce and market cfMijjtcstrd .md
heat-dried (peflelized) sludge. tto*ever (he EPA, wrtlj justifiratmn* xn-
ototy questions the marketability of these product? boeause of 1) f Pis* in Italy hav4*3linMfn that composted sUt*l$e may net h< f,n:
and sh'Wihi he furt^-r tiistflffttoi prior to ill bindjin^ «i»d us*-.
The RPA has RMRgeate*! that the MWRA consider tta frdlnwm* im* ,il
t^rnative restdtiab management plans: the combination o< hr^e drying s*iwt
I
04
<<«rn(»r»»ifij5 «.f -.W^c with Undttlhng; <>t the <-f
* "iNl'iwiifK lieat >frv>n^ »nri i t>nfpmt»i>K with fAtnffifftn< *1 Mf'fain!
itkMiM-c.ihon *1 S|«rr tarlr nf tlvrs*' *fl«Trr.t!(WH 4s
* ,iJ- «.r |»i/c tt.'.il I <•! t <.eit|tosC »i«» «-»»>
ii.'UHi srrtM'. Atlrl «|iout luwuiteds flf miHiorrs 'lolUrs *i» ]»!•.»{«<«¦
J'liufnu It, lit. mt-rattrrn Iis(K)saI i»f iNr « )n- n 1
|l| 1 (f'W 4ll IIV rfljtfvr fonnAri^iuans, f n»?•*»•>-I
MUH ^ i nii^iilii'r as ill i>acli »i|> stu»jge nuikajt^• 1 lir
fiTm: "*\Viili' ArtM n»Ji^v'. f'/njwrly
i»v.ni fi#»l ami! uMw*«»e«l ii iimv It-* a more ^r,r/ !)•¦»• f> .i f »i»^ in*
iiiuimsIimIiv' injini^i-nirfit rhmi l.inH <*»>( *-*m |.r<»*««!•• .t
^ aIim^Ic > j»r«»-
WtHtimi uf i-oinitverfwtly tmport^nt fish ft 19 interiMinjc *t» ciate *-
F.IM \ lews «ew«(5f *)utlgf» as 9 wMlr wlicn <»/ ^r^ i|ip hu» as
» f<-s*riirtf whew jf>pl»eii on rr**perfy ap|iM in the ur*,in, il irntW he
h<*nefirtal to irifirnir1 iif^ an -wine timsteil scientific Ua*r sfunvr*.
Iit MHiirairy, ( wish to rntrr»i< that while ifw: {wMw i> ^weally
1r» llir im ^i) >fispisa( of sUitfge, it rs tnuch more opftos*-'$ to tJir)T <{ispn4«.l >m
UihI hi tn ttc »t nK^j'hru*, both "f wiikh are cfmer ft> ihetr living rnviftt-
meni. Vropfjiy niana^eJ ucean dispersal d/ »;|ectif>n-tr^Air.J
have s"v*»ral benefits: the ^orMervatwjn of scarce fsnri fesa«rc:»-s. the jir«ie< •
ticm i^rouiKlwatrr; thr nrtr»int>2alion >»f fiuman health re>U«r«'4 water
an>l <»ewer ifiar^rs f«» the 1.1 trlifs arifi 10*115; and tti«r f«»r tMre r?w}»V» n» w^l mi.
* t«h {Uy»»h) My <>w|t ihffmmlctumir r*lculalinna eb«t rh<-11 vi a.\-. )•.-».),
cmAtKnuf» *i»)](« will t>» tnn««|pte<9 lf> oh furwiTju-m aii.I w«U
('« runc*utri» «W S)rrc«ty *')V >»«< rarnnt •«!> mi ik* (<%-• *-!f r»ai
«1 MuTi'lITi
-------
' -ye
' " Florida Department of Environmental Regulation
IWlH 1t»W. IS I lllk <" III. If, • 'MNMU.ltl SUMM- • IiIIiIm-.^! I'll Mill:! V V> '««l
I III It;
/
. lloI'Mi'MiM/. I.KI'IIIUM lljtt |WX llllMJIMI Si. Ii'lll) l«.lm sin >1. i J.mnIjiiI SnirUly
January 2, 1990
07
Ann Rodney
U.S. EPA, Region I
HEP - 1900C
JFK Federal Building
Boston, Massachusetts 02203
Dear Ms. Rodney:
The Florida Department of Environmental Regulation has concern;;
with the Final Supplemental Environmental Impact Statement for
Long-Term Residuals Management for Metropolitan Boston dated
November 1989. The selected alternative of heat drying and
marketing processed sludge will apparently depend largely on
exporting sludge products out of the State of Massachusetts. The
State of Florida is potentially a major destination for these
sludge products.
The information on the projected chemical characteristics of the
sludge has not been consistent or firmly established through the
environmental review process. This latest document contains
information that the projected concentration for molybdenum is
greater than previously expected and also greater than the
allowable Massachusetts limit for application to either
agricultural or non-agricultural lands. Earlier documents
contained information suggesting there may be difficulties in
meeting Massachusetts standards for other metals including
mercury. Apparently, this is not a serious concern for tho
Massachusetts Hater Resources Authority (HWRA), as long as there
are other states with standards sufficiently low to allow land
application of the MWRA sludge products.
There seems to be something missing from this environmenta I
review. If there is a legitimate technical basis for the State
of Massachusetts standards, there is every reason to believe the
same environmental and public health concerns would exist
wherever the sludge products are utilized. In fact a case may be
made that Florida is pQEfi sensitive to heavy metals in sludge
because of the low cation exchange capacity of our soils and
shallow ground water conditions.
The environmental review should focus on whether the MWHA sludge
products are suitable for land application or distribution and
Ann Rodney
January 2, 1990
Page Two
07
marketing Irrespective of state boundaries and whether the
Massachusetts standards are appropriate. Without this type of
analysis we may have to seriously consider upgrading our
standards for imported sludge products to match those of the
state of origin of the sludge products.
If you have any guestions please contact me at (''(>1) 4 nil - ¦!'.>Z4.
Sincerely
)
•' ••• 1 '
Thomas W. Conrardy, P.E., Residuals Coordinator
Domestic Waste Section
Bureau of Water Facilities and Planning Regulation
TC/pg
-------
Mr. anil Mrs. David 'Id lwf
1S2 Seekonk St.
Norfolk, HA 02056
(509) S28-10S5
December 21, 198!)
Hear Hs. Rodney:
Please reject the h'alpole/Norfolk sludge site.
As a young family llvlnn in close proximity to t!ic
proposed site, we plead with you to support eitlier
Spectacle l»lan.l or Rowc Quarry-
As lifetime residents of tlic Norfolk arrj anil
having worked very hard to fulfill our dream of
owning a hone In Korfolk, Me feel severely threatened
by this seemingly rash decision made by the MNRA.
lhelr report is filled with inaccuracies, for
Instance, their water table measurement was taken
during the wrong time of year during one of our
worst droughts; and there are endangered species of
wildlife present on this SO-plus acres, a fact they
have ailsrepresented.
No amount of convincing will alleviate our fears
about our private well being contaminated by diseased
medical waste, dead rats, used personal hygiene
products. fCBs or other so-called "screenings." not
to mention raw sewerage. A liner the thickness of (en
gartngc hags could easily puncture nnd ruin our water
supplies .inJ tnil.Hirer our family's health.
In federal Court there has been extensive
litigation recently involving cancer victims in l.'ohurn
against K.R. Grace Company. Years from now could it
be Morfolfc/h'.ilpole v. Commonwealth of Massachusetts''
lor heaven's sake, Norfolk is not even in the IIKltH
district. Once our water is polluted, who do we turn
to for water?
Kalpole has generously offered to expand their
prison to accommodate a larger prisoner population in
return for rejecting the Malpole site. This seems tike
an irresistahle offer to the State, one that shoul.l he
accepted given the recent problems of siting addition*!
08 "i,Ke 2
prisons. My the way , haven't our two to»»«s ihotc than
fulfilled our regional respons i l» 1111 y l»y housing Inmates?
lite choosinp of this site lias been carried out in
a very prejudicial manner. Mow many of the original
sites were ruled out because MWRA members or other
politicians lived close by? Imagine the outrage If a
landfill was proposed for. say, the town of Dover!
Imagine the outrage! It would not even lie considered
obviously because too many we 11 - to do nnd influential
people Iivc there.
kli.it about the odor or airborne toxicity m.iy
have to endure ftom this landfill? The *twnA did not
even address that. What about *he safety of our
children when trucks will he transport inp toxic wastes
by truck over small country roads with no sidewalks?
h'liiit about Stop Hlver and the ponds It feeds that our
children fish from and ice-skate on? What about the
Charles Itiver and all the towns downs t rrtim? t.'hat
about our pets, who wander freely in Norfolk, inpestinj*
something deadly from this landfill? Have you even
thought about how to evacuate the thousands of
prisoticas at Kalpole and Norfolk prisons in case of .i
chemical leak? What about the prisoners' rights?
Yes, Boston ITarbor needs to be cleaned up. but not
at tne cost of polluting our towns, He. in Norfolk,
have made a concious decision to live out here away
from the City and its pollution in order to raise our
families. Don * t dump you r was tc lie re! ill's just not
fair! No town should be burdened with t'tis I ittd of
landfill. It snould be dunped on an island, in :i
puuetute-proof quarry or transported to a special
iiazatdous waste dump out of stfttf. You I'onldn't
this landfill it: your no i j'Jiborhood, especially kIicii
tucio kinds of serious issues arise. «h»r very lives
aud piopeit) arc in jeopardy. I»is ;tti iitsult ?<>
tin? tm»ns of lorfrll .mil I-.'a I po I <*.
Iiclp restore our faith in our Starr fiove r»i»rii t .
I'lease stop this snowball from rolling. Reject the
Kalpole/Norfolk site as a landfill. h> )ool forward
to your reply.
S iu«c rc I y ..
_ iLA
• ..
U.ii- | ij . »' | iiu- i JI < I ! r ii- ' '¦ ' I ' '
-------
November I'-lBJ
l\*ul »j . I eouyh
Ac i i r»g f-egi onal Arimi mi st r al-'-r
U.S. Environmental Fr ot ec t i on Ag«»iv: y
Jo#in F. # ennedy Federal r«nt Idmtj
Mosl..n, MA WjjMr:
Di*<«r Mr.
If the MWI-A is allowed to >.ontimii* with its proposal U-
•ronstritct 4 sludge dump At the Winter Street site in
Walpole, Massachusetts, this landfill will .:r*nt«m»nAle ••<»»
rtrinltng water, pollute the water* of th»» Stop an.1 »*h<»r h»-»
l-'i ver t arid caus*- spr iviiv harm to our rhvi ronmrnt. fhi*>
landfill proposal miiil b«> sloppod!
We have a three year -.-Id child and fear for her health if
the proposed sludge landfill is allowed to be construe led.
We feel that both Norfolk and Walpoles water sources are
beinQ threatened by the HUfA proposed landfill. Children
drinking water polluted by toxics have a greater charier* ol
of developing leukemia. There is greater number of
mi' carriage's and children horn with abnormal i t i es wh*-r e
the water has been cont ami naled by toxins. Can w
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10
P.O.Box B3 Norfolk, HA 02058 (MB) 528-5085
12-05-80 OH doc4 pg4
Ha. Julia Balaga
Administrator
USEPA, Raglan 1
J.P.R. Federal Bldg.
Boston, MA 02203
r»: Federal Code 33 and CFR 40
D*it Mb. Salsngs:
1 wish to Introduo* ths additional raaaona «hr MWRA'a
selection of and John Dsflllara, (Secretary of HOM), recent
approval of tha HWRA landfill alta In Wslpols la wrong and mist be
prsrsntsrf by tha HSBPA.
1. ref: coda 33s aeotlon 1311, 1382. at tl.: Tha site has
navigable water aotiraa both 1a It and en Its bcundries which
consist* of tha Stop River, a Charlas River tributary, plus acres
of wetlands ret, HWRA refuaes to adhere to their protection laws.
2. tha USBFA ha* plaoad top priority and eaphasiaea
tha naed to raaova pollutants froa our navigable watara and
wetlands; ref: section 1289. NWRA'a building of a landfill site
In Itlpal* will be direct defiance of these SPA priorities!
3. ref: oode 33; aaotlon 1330: This section clearly atatea
that In design of seaaga disposal, tha dsatgnsr should uaa
*»t«. USBPA a tod lea have found that all landfill will
leak and pollute tha watara both In and outside thalr boundrlea.
The HWRA has failed to reoogalse or aaa this ealstlng data.
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15 flee. 1989 rarfi do. !> pg I
Ha. Ann Rodney
USErA. Region I
HBP-1900C
JFK Federal Building
Boston. HA 02203
re: Comments on HUM selection of Halpole Landfill site
Dear Hs. Rodney:
The Hassachusetts Hater Resource Authority. (HHRA), In Its
selection of the Nalpole site for disposal of Its sewage Materials
( grits I screening, sludge, sludge fertilizer and ash ]. falls to
¦eet the laws, guidelines and regulations of our nations Clean
Mater Act. Navigable Hater Protection. Public Law 100 4. TuM le
Lau 100-653. and CPR40. and I call upon the U3EPA to protect the
envlroaent of our nation by denying approval of and use of the
Halpole site to the HHRA for disposal of its sewage aattrials.
Study of the Halpole site shows that it has navigable water in
it. (a Charles River trlbutory naaed Stop River, a aaall unnamed
creek which flows Into the Stop River and wetlands), all of which
are part of Boston Harbor's ritrarine systea, plus it has eany
acres of wetlands on Its border, and has several public wells
nesrby ahich are sola source drinking water supplies to thousands
of nearby residents therefore, use of the Valpole site would be In
direct defiance of the objectives. regulations, and laws of our
land established for protection of Its envlroaent.
The following is a brief list of laws, guidelines, and
regulations use of the Halpole site fails to adhere to:
Public Law 100-4:
1251(a) et seq: The objective of this chapter is to restore
and lalntlia the aheaical, physical, and biological integrity of
the Nation's waters.
By placing a landfill which shall contain materials capable of
contaainating water In an area that has navigable water, wells and
wetlands in, the HNRA fails to aeet the objectives of 1251(a).
It should at so be noted that the HHRA, is its selection of the
Halpole site, and the USEPA in its initial approval or the site,
have failed to use the guidelines of sec. 1330. one being that
existing data aust be usedl Existing data such as the studies
dona for the USEPA by Geoservlce and by Geraghty t Miller have
found that all landfills leak and contaainate water of their area!
With rivers running through the aita and public wells nearby, its
selection and uae la in direct defiance of 33 U.S.C A 1251 et
seq., aa well aa Executive Order 12SB0.
Public Law 100-853 clearly atates that Boston Harbor cleanup mist
not only cleanup and protect the Hassachusetts Bay but the plan
auat.oocoBDaaa its entire ecosyataa and thet it is necessary that
loog^taxa health la ensured. Placing a sewage landfill which will
eventually pollute the navigable waters flowing into Boston Hirhor
falls to adhere to this public lew!
2
15 Dec 1909
Hs Ann Rodney, USEPA
rnrfi 11 < *c 0 f »r
1
Public Law 100-4 (cont.)
1345 d)(2)(D) Hiniaua Standards: Placeaent of a landfill site
in Halpole falls to aeet these requireaents as a site In Halpole
cannot insure public health or water protection.
U.S. Code 33
1251(a )(I ).(2).et seq.: Placeaent of a sewage landfill in Halpole
by the HHRA fails to aeet the objectives of 1251.
1251 Notea of Decision. Note 5. Purpose: To regulate to the
fullest...extent possible those sources emmlttinR pollution into
rivers, streams find lakes and. to ezeveot.entiy of pollutants into
navigable waters. The HHRA falls to adhere to this guideline by
placing Its landfill in an area which has navigable water/rivers
In its area Selection of a site which does not have t.neh writer in
Its area mun.t he done to meet thf.se guidelines.
1311(a): Use of a sewage landfill in Halpole f.iilr, to sillier? to
the sections called out in 1311(a) and therefore will be unlawful!
1311(b)(1)(A) The HHRA by selecting the Halpole site fails to use
the BPCTCA as selection of a site which lias less enviroaental risk
and no navigable waters or public wells In nearby vicinity would
be the BPCTCA and aust be dona!
1311(b)(1)(C) Here again the BPCTCA requires that a site be used
which has less enviroaental or health hazard risks!
1311 Notes of Decision Note IB: clearly shows that the Stop River
and saall creek In the landfill site at Halpole which flows Into
it are navigable waters. The U.S. v Phelps Dodge Corp. clearly
shows that discharge of pollutants aust also extend to pollutants
that could and UD In a body of water, including underground waters
Note >14. The HHRA selected the Halpole site using Its proposed
cost as a priaary reason for Its selection. However, note * 14
clearly shows that in deternlning "best available", no formal cost
benefit is required. Protection of the envlroaent. potential risk
to health and the envlroaent should have been the priaary
objective HHRA used in site selection but. it was not!
Note <15 Pollution control under BFCTCA requires th.it more
stringent Stan.lards should be net. Public Law pertaining t<> the
Boston Harbor cleanup and protection oT its entire riverine
requires that the Halpole site not be used .is Joes the note
regarding relocation of a discharge point.
1312(a), et seq. Use of the Halpole site can.not and Hill.not
insure protection of the public water supplies, fish and wildlife
and recreational use of the waters both in the area and that flow
to Boston Harbor from the navigable water in the Halpole site
1317(a) et seq The HHRA, by its own words, plans to dispose
of toxics in Halpole which fail to aeet federal regulations Tor
landfill disposal; cadaiua is one. It also plans to dispose of
toxics into the landfill site which are aga Inst r.t .at » rc«u I at ir.ns
for dlrf-oeal into lftndMll r.lt<-«. *ynnld<- I r.
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3.
IS Dec. 1988
Hs. Ann Rodney, USEPA
U.S. Code 33 (cont.)
1341(a)(1) et sen: Subchapter 1341 clearly states that
construction or operation of facilities Bhlch aai_iesu.lt In an*
disc bane must coaply with applicable provisions of various
aectiona of U.S. Code 33. An HNRA landfill site In Hiilr'l'
not meet the requirements called out in 1341
1342(a), et seq: A landfill site in Nalpole fails to Beet the
requireaents of 1342. For instance. 1342(b)(1)(A) calls for
coupIlance with 1311.1312.1316.1317 • 1343. A landfill in Nalpole
does not! 1342(b)(1)(D) states that tha prograa aust be able to
control Cflllttlloo into. Mel IS. Yet, there Is QQ mi the HNRA can
control pollution into veils of the area and. in Norfolk all
faallles obtain their water froa veils. MS of the families froe
the wells that are In near vicinity to the Nalpole site just as
does the nearby hospital! HNRA can not neet 1342(b)(1)(D)'.!
1342 Notes of Decision, note *10 states that if a program does not
coaply If there are toxic pollutants Injurious to .human health
Here again use of the Nalpole landfill fails to «.e»*t the
provisions for IJSEFA site approval or issuance of a permit.
1344 Note 43, -- Presumptions: Code 33 clearly states that
presuaptions should not be used In the Clean Nater Act. However,
the HNRA presumes its landfill will not leak; presumes It can do a
quick fix If It does; presumes many other things in Its plan yet.
existing data shows EPA presumptions sre wrong, shouldn I be u«.ed.
1345: Approval of end issuance of a permit to use the
Nalpole landfill site by the HNRA aust be denied as it will result
In pollutants entering the navigable water and will be in defiance
of the guidelines of 1345(a) to (f)
1362 Notes of Decisions: Factors called out in note *3
clearly show that the Stop River; the saall unnamed .-reek In the
site that flows Into the Stop River: Its wetlsnds; and the Charles
River sre navigable waters and therefore all laws applying to
navigable water protection must be applied to EPA's decision
making and. in accordance with those laws It aust deny the HNRA
its approval of the Nalpole landfill site. Notes • 6, 7 & 8 add
to the proof that the- waters in, nearby, and flowing from the
Nalpole landfill site are navigable waters and must be- prvlfi tid
by the USEPA.
Note III clearly shows that point source discharge will be a
landfill and that conveyance of pollution m result from natural
phenonenas such as earthquakes, heavy rainfalls, ect. Nhereas the
Nalpole site sits In an area that has had such phenomena* and ri I s
In a hltfh risk area for water pollution it must not t.» «I II'vp.i
¦r
It should also be noted that both state ami federal
envlromental protection laws prbhlblt the disposal oT medical
waste Into the waters of our land. Nhereas MNPA sewage mater in)
has medical u.iste It must be denied use of the Nalpole r. i I e
cac6 doc9 pg3
11
4.
15 Dec. 1909
Hs. Ann Rodney, USEPA
U.S. Code 33 (cont. )
The HNRA progrna also falls to coaply with the definitions
called out by our federal envlromental protection laws as they
defIne grits and screening, sludge, sludge pellet fertilizer and
ash as solids in the field of sludge disposal yet. the MNPA rails
to adhere to the-.e definitions but. in order to obtain npi-rnvn I .>r
an.l a permit for use of a landfill at Nalpoie it must
1344(a) et seq: The USEPA must deny the MHRA approval of or
issuance of a license to us* the Nalpole site as a landfill for
its sewage material as It falls to comply with the specifications
cat led out in 1344.
1319: The HNRA has failed to adhere to the regulations of 1310
as It has failed to advise the public that existing reports and
studies have found that all landfill will leak and pollute the
waters of their area, (ref. studies done for USEPA by Geoservite
and Geraghty I Killer). It has In fact allowed invalid statements
to he printed without calling for correction ie: our landfill?
will not leak; should .i leak occur the HNRA could do a quick ri».
only grits t twigs will be dumped at Nalpole s site: treT note 8).
It should also be noted that the HNRA. the state's Executive
Off ice of Envlromental Affairs and USEPA have been given
sufficient information regarding the Nalpole site's inability to
aeet the federal laws and regulations pertaining to use of the
Nalpole site for disposal of sewage materials and it is expected
that all actions taken shall be in compliance with them.
Should any person violate these laws, guidelines or retfu I at lens
then appropriate legal action shall be taken.
Code of Federal Regulations 4R
At this time it is Impossible to determine Just which type or
landfill disposal site the HNRA must use. what disposal site
guidelines must be used, as the HNRA does not know what exactly
what the fill material chealcal or biological substance will be at
the time of disposal. it can only presume what it uiI) he.
However, regardless of what It. might be, the proposed Vilpole nt»
will tint meet the regulations required fur ?>tiy landfill 5 i».
Ill snslysis of use of the Nalpole site, exirtinrr data such as:
the USEPA studies have found that all landfills will leak ant
contaminate the waters both inside and outside their houndries;
thst USEPA requires that entry of pollutants Into rivers, streams,
lakes. and navigable waters must be prevented; that control of
pollutant discharge. (which Includes landfill site selection),
must be extended to the fullest point as it ronld/m:»v end up in
our waters; oust be givenforenost.prlority!
cac6 doo9 pf*4
11
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11
S. cacB dorfl pits
19 Dec. 1980
Hs . Ann Rodney, USEPA
There are several areas In th* HWRA'b harbor cleanup plan
outside Ita landfill alia selection where the HIM baa Failed to
adhere to the laws. guidelines and regulations of our Clean Hater
Aot and Navigable Water lina that the USBPA ahould address and
aake the MWRA change It* plan so that they are iet. One relates to
priorities, and the federal rules state that priority Bust be
applied to rainwater overflow which causes pollution to our
navigable waters. The HWRA has spent hundreds of Billions of
dollars and several yearn In Its harbor cleanup project yet. Its
plan still lacks a fix to the rainwater overflow which causes
pollution to the Nassachuaetts Bay and beachea! They also state
that decisions should not be asde on presuaptlons. Oncoalng
federel regulations will Bake the sludge fertiliser the HUM
proposes to produce unaarketable. require that It be thrown away.
However, even bo, the HWRA plans to spend cloae to one billion
dollars to construct a sludge fertiliser producing plsnt under the
prsauaBtAflll that the federal governaent shall reduce its oncoming
regulations to the aaount of tonics In sludge fertilizer.
HWRA'a failure to adhere to these federal regulations shows that
Its entire harbor cleanup plan is not approvable br the USEPA.
Nlscellaneous:
Rote S of sec. 1251 states that: It is the Intent of the Clean
Mater Act (33 U.S.C.A. 1251 st aeq.] to cover, as auch as
possible, all waters of the United States Insteed of Just soae:
The USBPA's approval of a landfill site In Walpole which has a
river, an unnaaed oreek and wetlands In It and public wells nearby
falls to follow these goals set for enviroaentel protection of our
land and therefore Bust be corrected by denying approval of the
Walpol* site.
thet: This chapter was enacted to prevent entry of pollutants Into
navigable water and to control pollution at Its source: Placing a
landfill In Walpole fails to follow the guidelines of chapter 1251
Section 1345(a) states: Notwithstanding any other provision of
this chspter or any other law. in any ease where the disposal or
sewage sludge resulting froa the operation of a treataent works
as defined In section 1292 of this title (including the reaoval of
in-place sewage sludge froa one location and its deposit at
another locetlon) Mould.result in any pollutant froa such sewage
sludge entering the navigable waters, >uch.j!ispoaai-ift.Broblblted:
Whereas the USEPA knows rroa its own studies that landrills leak
and oontaalnate the waters outside their boundries; and knows that
the Walpole site has navigable water In It; and knows that the
BPCTCA auat be used In protecting the waters of our nntton: it
nust not approve of the Walpole site!
Section 1201(d) states: The administrator shall encourage
waste treataent that; <4) the ul'tlaate dlapoaal of sludge In a
aanner that will no| result In enwlraaental hazards1 Approval or
the Walpole site falls to adhere to this Congressional Declaration
ci»c6 dor9 pg6 11
IS Dec. 19B9
Ms. Ann Rodney, USEPA
There are Bany lawa, guldelinea and regulations In U.S.
Code 33 and CPR 40 ror the protection of wildlife. There is
conalderable wildlife living in the Walpole aite whose lives will
be seriously arrected IT the HWRA la allowed to. place its landMU
there. For Instance, the yellow bellied sal'saander which is an
endangered species, blue haron. wild geese, deer. ect. It would
be in direct defience or U.S. Coda 33 and its regulations to place
a landfill site In Walpole as it would Jeopardize the existence of
soae plus seriously affect the breeding and nesting areas of
others.
Regarding the snail creek which flows directly through the
aonof111 sections proposed by the HWRA, by U.S. Code 33 Is a
navigable water, (see encl. HWRA Bap figure 4-7). US. Code 33
sec. I3S2 and others show that It is navigable water th^rpforp.
the approval arid use r.f the Walpole site nur.t hp denied.
Regardless of what type of site Is used, itr selection nnd use
requires that a
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12-2B-8B CACB D0C4 po. j 2
Mr. Ink 1. IUI«
Aaalataat Mllenal Coonaal „
03«P». I«ilm 1 IXC ? 9 1
J.f.I Mttil
ItllW, Mt 02203
Bear Mr. SI*in:
¦hi I* avalting anaaar ta the qeaationa I aakad yoa In ay
letter of ll-U-ll yavlaa aaa doaa m nil data and the findings
appear to oontodlat roar (titMtRt that tho HIM la net
adalntstritlng tin aaotlon 19* program or. at laast ahoa that It
ahoald be,
ta r«« knaa rte* the data I (otiitdtd to you, tlw Valpole
landfill alta Ma navigable aater la it t* nail «a nlltadi aboaa
aatata floe Into tha navigable aatara. Vatara that ara part of
•oaten Harbor's riverine. latere that auat be protected In
accordance with Pub. Laa 100 - BBS and OSC 33. (MM tit end).
Im( it ton look at tha aeaorandua aant tin HIM eiecotive
dlreotor faul Laay to Ita COB J aha taTIUaia oa II 1M»i
(paiee lt.ll ¦ 11 anal.), regarding Ita analpata of aaa of tha
Spectacle 1aland (or a aaaaga landfill alta pea alll aaa that Mr.
tavy oalla out BeatIon ••• regolatloaa aeveral tlaaa. »»«« atataa
Ma ooaaara that under aaotlon 4U regolatloaa that Spectele
Island say not ha applicable tor aaa aa a aaaaia landfill.
Ron can It ha that aaetloa <11 la app Had to Spectacle la land
aaa hut not ta tha Valpola landfill alta* Naa aaa poo, tha
Hiri Jaatlfy tha clala that aaetloa «M la mot reqolred at tha
•alpala alta «han It haa an avan greater envlroaental rlek. offere
rar greater baalth hararda ta people than Spactacla 1aland doeaT
Hi. sttit, U.S.Coda at and Ita ragalatlona elaulf atata that
¦hen thera ara practicable alternatlvea aheae oaa mill have laaa
adaarao effecte on tha envlronaant, on tho aquatic eooapatea. than
(hay ahould ha oaadl Tbaro ara anoh altaa In Haaaachuaatta!
Tfca MM haa reviewed aoch altaa la Ita tandflll aalaction aark!
therefore. Boaten VSCFI'i approval of tha lalpole alta la in
dlraat daflanoa to our Claan later l«t. Pleaae advtae ahp tha
toatoa Oliri haa not addraaaad thla iaaoe. ahy it la aot naiad tha
goMellnaa and regulation! of VSC 93 and Fob. Laa IM-H5 ta
protect all water* and environment of on* nation, thank you.
Youra truly.
s „
lattf Basalgnanl
f.O. Boa B9
Norfolk, Hit 0Z0M1
27 Dec. 1089 cioS
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26 Dec. 1989
oaoB doe9 pg0
Ha. Ann Rodney
USBPA. Mglon 1
Rir-imc
Jri Fadara1 Bid*.
Boaton. MA 82203
re: CMimt* on NVM use, USBPA approval of the Nalpole landfill
Dear Ns. Rodney:
Sectten 1930 of USC 33 oleerly atatee that priority auat ba
given to protection of oar netlon'o eataary and eetuerlne aonaa.
And, that the eatoarlna zona shall Include the associated aquatic
ecosystea and trlbutarlea ahlch drain Into It.
Public La* 100-653 atataa that tha Haaaachuaetta Bay and Its
riverine systen fall under the national aatuary program. ( 9M end).
Public law 100-4 atatea that: tha nation's estuaries are of
great laportance to fish and vlldllfe.
Tha Nalpole landfill alto contains both land and aetera ahlch
aro part of oar atataa eatoarlna tono. ploa haa flak and alldllfa
whose 11vea will ba seriously affected if a sewage landfill Is
plaoad In Nalpole. Use of tha Nalpole landfill alta will be In
direct defiance to tha objectives of oar national eatuary progran.
Baaed on thaaa facta It la OSBPA, Region I'a responsibility to
as* that the NIH la not alloaad to bolld and uaa a landfill In
Nalpole end 1 deaand that It perfora ita environaental protection
duties snd deny approval of the Nalpole landfill alt* to the HIM.
Youra truly,
N-
Larry Basslgnanl
cc Mark A. Stein
Norfolk CAC P.O.Box 83 Norfolk-, NA 02098 (908) 928-5089
12 29-89
oioB docO pgl0
Ha. Ann Rodney
USBPA. Region 1
HBP-1900C
J Pit federal Bldg.
Boston. HA (12203
re: Connents on Nalpole landfill. USC 33 sec. 1330
Dear Ha. Rodney:
Further review of USC 33"a aectlon 1330 clearly ehows that no
landfill of any type can be built at the HNRA s proposed Nalpole
landfill site!
Whereas the waters In and sround the Nalpole site are part of
• recognized "sstuarlne zone" (ref: Pub. Lew 100-893. USC 33 seo.
1330), and there la nuaeroos types of wildlife living In the
eetosrlne zone, using It for breeding grounds, ect.. any type of
landfill operation. (loud noise. bad odora. contaalnated water,
ect). would cause serious hara to their Indigenous life.
Section 1330 statea that alldllf* living In an estuerlne zone
¦list he protected and. wherese the HNRA already has a practicable
alternative landfill site ehlch la not In or close to our etate'a
estuarlne zone, (the Rowe Quarry), then In acoordance with
U.S.Code 33 It auat be used or. whet It ehnuld have.dona.In
the flrat DlaO«^ find another landfill alta whoae operation will
hove no adverse affect to our etate'a estuarlne zone, that offers
the least risk to ours statea envlronaentl
Beeed on thla fact 1 deaand the OSBPA. Region 1 perfora Its
environaental protection duties and deny approval of the Nalpole
alte to the HNRA.
Tours truly.
Larry Besslgnanl
PS: In review of the USBPA PSB1S of Nov. 1989 It appears that
aeveral of ay lettere eent to the NNRA'e Paul leough were not
forwarded to the erpropriete departnente. Therefore, please add
the end copy of ey letters to Hr. Keough to tiy current rotiment
f>»re*s. Thank yon.
encl: drwalnga obtain'' froa HNRA showing Zone 2 ami Charles River
watershed at Nalpole landfill alte.
Norfolk CAC £.0. Bo* 83 Norfolk, HA 02058 (508) 52n 5085
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12-30-69
Ha. Ann Mmr
¦SRPA. Melon I
NtP-lflMC
JTI Federal Bldg.
Boston. NA 02203
re: Conrnt* on Vilp»U Landfill. 09IM approval or It.
Dear Ms. R«ln«i>:
Please add this latter to ay earlier letter of connents
regarding BSC 33, sac. 1300.
Further review of 0SC 33 and Fab. Lew 100-853 ehow that the
HIM, In aeleetlon of the Nalpole alte as ita preferred alte, has
failed to adhere to thetr guidelines, failed to even italltt
the purpose they were drawn, the objectives they sought!
Section 1003(a)(0) of Pub. Law 100-653 clearly atatea that a
ennnartad effort froa all levala of Oovernaent and the pabllo at
large will be necpaaery to nrntact and enhance the integrity or
the Hesseehusetts Bar.
The NIM, In Ita harbor cleanup progrea, hea absolutely
refused to alios a oonoerted effort froa tha public to be applied
ta the eatuarine cone area which aha 11 t>e affected bp Ita cleanup
plan, tt haa. In feat, plaead Itealf as the eole aource,
effort applied to seeing that the porpoea of Public Law 100-6S3 Is
aet. This Is wrong. Is in direct defiance of Pub. Law 100-053!
1 base ay cltl* on the following facts. Norfolk CAC and the
town residents It aarvleaa have, at their own espanae. exerted
enoraooe effort to aae that tha environmental Integrity of the
Haasaehaaetta Bar and ita estuarlne lone are protected. Be have
aade ever? atteapt possible te aae that our work and flndlnga were
a concerted effort with the NIRA. Data froa our studies have been
forwarded to the HIM. Invlroaental expat ta have bean brought In
to analyze, the effect a landfill In falpole would ceuae to the
envtronaent and the national eatuary. have advised the KIM of
the ham Its placing a landfill in Valpole would cauae to the
wildlife living In the estuarlne sons of Its area. We have advised
It of other sitae that would offer leaa adverse lapaot to the
envlronneat, to the eatuarine cone of our stste. It Iiks Invited
the MRU to awet with us for review of our studies. Ve have even
offered to provide the NSRA with free toxic teetlng of Ita e«wege
aaterlele. A wultltude or letter* have been aant to tha HSRA
regarding our coneerna, our flndlnga. and our suggestlona to how
the Kill eould laprove its plsn so that It would oaaee no hsrw to
the estuarlne zone of our stste. fsr Isss hara to the environment
or our stste.
osc0 doeff pgll .
16
2.
12-30-60
He. Ann Rodney
The HIM, however, has failed to reply to our lettere. failed
to addraaa the envlronnental lnforaation oontalned In theai. Ita
executive director. In reply te oar ofrar to Beet with the HIM
for review of our flndlnga. ateted that he, the HWRA eould not
vlslt/aeet with Norfolk residents for review of their work.
The totel lack or conoern the HIM has shown to concerned
cltlcans efforts. Its refuasl to aeet with Norfolk resident for
'•*lew of their sorh or anewer valid aueatlona pertaining to the
waters of their land which haa a section of our atatea eatuarine
cone In It. the reoent reaark aade by Its PR Ban regarding a
landri11 site found that has no estuarlne zone waters In or
nesrby, that ofrers fsr less sdverss lapaot to the envlronaeht
that: the DM* wouldn't use it, have apent too euch tlae on
¦alpole already, olearly ehowe that tha NWRA has no ooneern to
protecting the envtronaent of our atate or, to protecting Its
eatuarine cone.
The facts spaek for theaselves, the HUM by:
A. not adhering to Public Laa 100-653 In Ita landfill alte
•election and,
B. by refusing to work with tha public in a concerted effort
la In direct defiance of Public Law 100-6S3 and USC 33, sec. 1330
oacfl doo9 pa12
16
Therefore, I call upon the USCPA. Region 1 to use to powere
beatowed upon It for proteotlng the envtronaent or our nation,
ptetectlnl Ita eatuarine conea and do so by denying approval of
the lalpole landfill alte to tha MORA.
Tours truly,
Larry Baaelgnanl
Norfolk CAC
P.O. Box 03
Norfolk, HA 02050
-------
2 l»n. 1390
cae6 doc9 pg13 17
Mb. Ann Rodn«y
tiserih. Region 1
tf«P~1900C
JFK FedreaT Bldtf
Boston. HA 02203
r«: Comtenls on HlfRA selection of tfelpole landfill site
Pear Ms. (todn»y:
Uo to this point ey Nvi been directed to the lavs,
regulations rmd guidelines thi NVttA Ills failed to adhere to in Its
selection of the tfalpole landfill alto.
They show thai the sites location has:
#. free flowing water* lit It utile!) are part of Boston Harbor s
e^oriyslen, waters which are part of a national estuary.
I. thousands of residents In the town It la located In uho
retire (tells for for their drinking water as do the residents of
Its neighboring towns.
C. vet land a and a mil ereeli within the alte whose waters flow
Into ttis Stop Rlvar on Its western alda which is part of Boston
Harbor s ecosystem. It also has hundreds of seree of swamp land on
its eastern and southwestern borders* (ref: Cedar Swear)
D. public wells nearby which provide drinking water to over 501
of Norfolk's residence® as wall as its schools which are attended
by not only children from Itarfolk but also children ftc* tha towns
of tfrenthss and Plsinvllle, tso (?) of our atata'a largest
correctional Institutes which ere located on It* border*; and e
nearby public hospital.
B. hes both navigable wsler ami tha Charles Rivrr wnter shed
within its bound* les, (refr HNM sets ft bounds, t>EQE 1987 report).
the combination of these facts In cnjunctlon with the VSEfA
existing data which shows that all landfills teak and contaminate
the water's of their area Is sore than sufficient information
required for a party concerned with envlronsentel protection to
realize that oae of the Velpole site le wrong* Show that, with
proper sits enslysis/coftcerfi, the Valpole site should have h*en
dropped froa consideration long before now!!
There ls« however, an antremaly Isportent factor that should
have been looked at long bafors now. Jt requires no law, no
regulations, no guidelines. It is ilulftJSOUOiLssaasI
2.
2 Jan. 1909
lis. Ann Rodney
One* the HURA ndde the heavy rainfall eeotlon to Itn harbor
cleanup prograa the prograa will have four aajor sections.
1. a heavy rainfall overflow protection
2. a prlnary and eecondery treatsent
3. a sludge fertiliser production
4. a landfill Tor disposal of sludge and sewage materials
The overall tost., once the heavy rainfall section ad-l^d.
will be in ex^55 of seven (7) billion. dollars-
According to the HWRA the Nelpole landfill will roat right
around 25 million dollars This figure amounts to oclv 0fl.T>7X *>T
th*» overall Boston Harbor cleanup program.
Vhen you analyze the wastewater end sludge naterials that' the
NtfRA plana to dispose of In Ita landfill you see that it one of
the most highly toxic, moet highly polacness that we have in our
nation. Based on thle fact the landfill elte used must be one
that offera the least possible health hazard and water
contamination possible! let* shan you look at the facta called
out In page 1. A to C, anyone sees that the Valpole site doesn't.
If for, whatever reeeon, the landfill site fells to vorh es
preeumed, the entire harbor cleanup operation fella to work. Al)
because of e section of the prograa that costs lesa than 1/2 of t*
of the entire projeot. Thle la sbflUKdt Or, ns shown 1n the
fuldltnes for CcDBoa.SeflStf, Is called bring "penny wise end pound
fno IIsh".
The HKFA refuses to address this factor. It, In fact,
appears to have spent aora tlaa and effort on where its office
space should be placed then where it plane to dlspoee Its
thousands of tone of polsoness sewage waste. Shows no concern to
speeding 502 sore for its office than Its landfill. A mistaken
office site selection will not kill people, a sludge lendTill
ulll!
Due to waste disposal In improperly se|*rted sites oui nation
has hundreds, no thooeanda of areas with contmmlneted land and
polluted waters. People here died froa It, people are seriously
ill from It today. Children have learn lei g- dlaabl 11 ty froa It'
An enormous amount of our intend waters are undrInknble today,
unusable today, all beomuse of waste disposal In Improperly
selected, unsafe landfill sites.
With the naoont of eioney the NIFA proposee to »pend on the
Boston Harbor cleanup plan, thara ia abaojuteiy no re«*<*n this
mhomld happen h»r». But, according to enlisting MSFPA data. If th*
Valpole site In used It will.
cec6 doc9 p
-------
3.
2 Jnn. 1990
H5. Ann Rodney
Let us analyze what ulll happen when, after several years of
operation, toy one of the four (4) sections should fall t» operate
as presuned.
1. When the rainwater overflow section Tails to operate nr.
presuned very little health or environmental hazards arc create!.
Repair can t-e done rapidly.
2. When the prinary and secondary treataent facility fails to
operate aa presumed very little health or Inner land/water
environnental hazards are created. Repair can be done rapidly.
3. When the sludge * producing facttlty fails to operate as
presuned HD health of environental hazards are created. Repair can
be done rapidly.
4. When the landfill falls to operate as presuned but. leaks as
existing USEPA data says It will, the thousands of tons of toxic
sewage Materials In It will spread contanlnation not only into Its
land area and Its waters but, also Into the waters of Boston
Harbor's eccsyaten. Repair can not be done rapidly. Hay not he
able to be done at all. The repair cost will be enornous. mny
require super fund assistance.
It Is tine for the NMRA, the various state departments and I lie
USEPA, Region I to face the facts and apply coaaon sense to the
Boston Harbor cleanup Job. The landfill site's location aust be
able to provide absolute health and environental protection for
aany years, no generations to coae. Hust be In an eree that does
not have a high environmentel risk potential! Even if It nesns
the NWRA nust spend a greater percentage of aoney for it,
especially when the aaount will be such a tiny percentage of
the total project cost end It Is such an iaportant project.
tours truly,
Larry Basslffnani
Norfolk CAC
P.O. Bex 03
Norfolk. HA 02056
cacS doc!) pgl5
17
4 JAN. 1900
Ms. Ann Rodney
USErA, Region I
HEP-I900C
JFK Federal Bldg
Boston. NA 02203
re: Coaimenty on MHRA's Halpole landfill, Imrl-or rlt-nniip pri'irrl
Dear Ms Rodney:
U.S.Code 33, sections 1288 snd 1313 state that a waste
treataent plan such as NHRA's harbor cleanup project nust have a
planning process.
Section 1208(b) states that any project plan prepared nnsl he
able to aeet the waste treataent needs over a twenty (20) year
period. The MHRA plan says 25 years.
With HURT'S selection of the Halpole landfill site fur
disposal of its sewage neterlals; grits I screenings, dfuatored
sludge, uniol.) sludge fertilizer I ash, it is unnl.le to neet.
either the II5C 33 rrflnlst Ion oc , its oun .
This is clearly shown on page 4 (enc1 ). of Mr. John OeVillnrs
certificate on FEIR papers where he states that. with disposal of
its unsold sludge rrrtillzer. the Halpole landfill site s useful I
life is only twelve (12) years.
Hith its current plan, without a useful! disposal site, the
entire HWRA project becones Inoperative and therefore the plan
falls to comply to the pernlt conditions of U.S.Code 33.
Based on this fact I deaand that the USEPA, Region I deny
approval of the Halpole landfill site and any other sections of
IfHRA's harbor cleanup project which requires use of a disposal
site. Thank you.
Yours truly,
Larry Basslgnani
Norfolk CAC
P.O. Box S3
Norfolk, NA 07O56
rftcG (incfl pj? 1 tj ^
PS. in ay letter of 1-2-90 (ref; cac8 doc9 pg]5). on sheet 3. line
10, please Insert the word fertlllzer between the words sludge
end producing. Thank you.
-------
8 Jan. 1880
cac8 dooB pgl8
Ki. Ann Rodney
U3BPA, Region 1
HBP-1900C
JFK Federel Bids.
Boston, HA 02203
re: Coanents on HMRA's proposed use of the Malpole landfill
Dear Ms. Rodney:
The prlnry objection called for by our Congreea in the Clean
Hater Aot la the restoration and aalntalnance of our nation's
eaters, all Its waters. This includes lakes, ponds, rivers,
oreeks, surface eater, underground water sources, drinking eater,
ect.
U.S.Code 33, section 1251 at. seq. clearly states that any
work done on pollution proteotion, waate treataent aanageaent
plans and praoticss should be such that it protects all eaters and
do so for ss long as possible, that all sork done should be done
in such a aanner that it offers the least possible envlronaental
hazard riak to our eaters. And. it provides guidelines and
regulationa which should be followed to aeet the water protection
goals.
The HNRA, in selection of the Malpole site, has failed to
follow the guidelines given and the existing data available
for aaxiaua water protection. Thla haa been shown In ay earlier
letters snd is called out on the enoloaed HNRA aap which shows the
Malpole site snd the dsta on its reverse side.
Based on the dsta forwarded in ay preoeding letters of conaent
unit the data ahown and called out in thia letter end its enolosed
paper, (alts area aap 1 data), it oan easily be Been that use of
the Malpole site for s sewage landfill falls to aeet goals,
obligations and laws established for weter protection therefore, I
deaand that the USEPA. Region 1 perfora its envlroneenta1
proteotion duties snd deny spprovsl of the Malpole site to the
HNRA. Thank you.
Yours truly.
Larry Basalgnanl
Norfolk CAC
P.O. Bos 83
Norfolk. NA
7 Jan. 1990
cac0 docS pgl9 20
Hs. Ann Rodney
USEPA, Region 1
NRP-1900C
JFK Federal Bldg.
Boston, HA 02203
re: Continents on HWRA's proposed use of the Malpole landfill
Dear Ms Rodney:
U.S. Code 33, section 1342(o) clearly Btates that all waste
disposal projects shall be designed so that It prevents
backaliding, that anti-backsliding Bust be Incorporated Into all
projects in order for It to recleve a pernit froa the USBrA.
This, of course. Beans that the USEPA would certainly not
grant approval to any waste disposal projeot or section of it
which does not provide a very strong and a very stringent
anti-backsliding design.
Here again it can be seen thet the selection of the Malpole
landfill aita falls to aeet the goals, guidelines, regulations and
laws of our Clean Mater Act/USC 33 as it is unable to aeet the 20
year planning process requirenents. In feet, shows that Its plan
If far less stringent than the alnlaua requirenents established
for protection of the waters of our lap
Based on this fact T ItoW"wt "The USEPA deny approval of
the Malpole site to the HMRA. And, deaand that it not allow
presuaptions to be used by the HMRA^sa a counter to its Inability
to aeet the required planning prooess. Thank you.
sqw-iww ,
Tours truly.
Larry Basslgnani
Norfolk CAC
P.O. Box 83
Norfolk, HA 0205B
-------
13 Jan. 1990
cac6 doc9 pg22
Na. Ann Rodney
USEOA, Region 1
HBP-1900C
JFK Federal Bldg.
Boston, HA 02203
re: Letter of coaaents on HHRA's plan to use Halpole landfill site
Dear Ms. Rodney:
Throughout U.S. Code 33 and CFR 40 regulations for design of
waste disposal prograaa, (also for USBPA project spproval). It is
stated that the project au6t use BATEA. (Best Available Technology
Bconoaically Achievable).
Here again the HHRA, by selecting the Halpole site as its
preferred landfill site, haa failed to Beet, adhere to the goals,
objectives, regulations, and laws of our nation estsblished for
environmental proteotlon.
This is clearly shown by the figures in HHRA's Aug 1989 FEIR
and Hr. DeVillara letter which both atate that the Halpole site
will only taat for twelve (12) yeara when HHRA disposes or the
•lodge fertilizer it produces in It.
Hhst this aeans Is that, instead of opersting for twenty (20)
yeara aa it ahould, the HHRA will be forced to find, purchase and
build a new disposal site long before the the twenty (20) year
operating period haa been reached.
Nobody knows whst land and construction is going to coat
twelve (12) yesra froa now but, if we use the cost increase that
haa occurred over the past twelve (12) yeara, it aeans that the
additional alte required will cost three tiaes aa auoh as It would
today. Frankly. no coapetent business would design a 7* billion
dollar projeot that is suppoaaed to operate for twenty (20) years
which had a section It knew will be unusable in twelve (12) years!
Bspeolally when the cost of the section thet will becoae unusable
is less than IS of the total project cost!)
7» billion dollar project design aust not be done on presunptions!
This is poor nsnageaerit, definately a bad business plan and.
CCilttlflly not-ft otoJftcL-aaing-BAiaL. Based on this ract I dcnand
that the USEPA deny the HHRA approval of the Halpole site and nake
it find a landfill site that will operate for twenty (20) years
under all possible disposal conditions plannedl
Toura truly.
Larry Bassignani
Ror<^^^RC P.O.Box 63 Norfolk, HA 02056 (508) 520-5085
14 Jan. 1990
cac6 doc9 pg23
Hs. Ann Rodney
USEPA. Region 1
HEP-1900C
JFK Federal Bldg.
Boston, HA 02203
re: Letter of coanents on HHRA's plan to use Halpole landfill site
Dear Hs. Rodney:
Two of the primary objectives of our Clean Hater Act is to insure
that waste disposal causes no hara to the watera of our land and
that the disposal of aaterlels will pose no unacceptable risk to
hunan health. However. the selection and proposed use of the
Halpole site by the HHRA fails to seat these goals, objectives.
As EPA knows froa ay earlier letters of coanents the Halpole site
either has in It or is surrounded by watera such as: a river, a
creek, wetland, swaap, publlo wells, a Zone 2 aqulfier. a Charles
River Hatershed, ect. EPA also knows that the HHRA plans to use
the site to dUBp the sludge fertilizer it produces and knows froa
Its own studies that all landfills will eventually leak.
The two (2) sheets enclosed contain data taken fron EnviroNet and
EPA's 1906 "Doaestic Sewage Study", and they clearly show that
use of the Halpole site will cause both a serious health hazard
and water pollution to occur. Even worse, they show HHRA'b total
lack of concern to the protection of our environaent and our
peoples health, as it knows the value of the nearby wells and
certainly should know the value of the Stop and Charles Rivers!
The staple fact that sludge fertilizer is believed to be the cause
of ALS, (Lou Gehrig's Disease), that cadalua Is rapidly taken up
by plants, thst phthslstes and aost chlorinated coapounds are
bioaccuBulative in aquatic ecosystena, shows .that a site which has
as much water in its area as the Helpole alte does should not be
used for duaping HHRA sewage aaterials. Shows that, in accordance
with USC 33 regulations, a site which offers less environmental
and health hazard risks aust be used!
Hhy the HHRA refuses to sddress these environaenta1 hazard risks
is beyond all logic. But soaeone aust! Therefore, based on these
facts I demand that the USEPA, Region 1 perfora its environmental
protection duties and deny approval of the HaJijole site.
Yours truly.
Larry Bassignani
Norfolk CAC P.O Box B3 Norfolk. MA PI2PSH Minr,
-------
23
15 Jan . 1990 c-ac6 doc9 pg'<.'tf
Ha. Ann Rodney
USEPA. Region I
hep-1900c
JFK Federal Bldg.
Boston, HA 02203
rf: Continents on HNRAs use of Nalpole landfill site-
Dear Hs. Rodney:
tio that there is no question ,to Walpole site's w;it*r.
wildlife, ires, ect. being pari of our National Estuary I'rograti
enclosed is copy of rages 105 - 109 (IISC 33 - Sect. 1330)
As you can see, an "estuary " and "estuarlne zone" »:.1 of
all associated aquatic ecosyaten and tributaries which flow into
it. Whereas the Stop River* (a Charles River tributary), the
unnamed creek and wetland waters at the Walpole site flow into
Boston Harbor via the Charles River then, according to 33.
the* ere part of our state's estuarlne zona!
One can only «onder how, when the Federal Government places
such priority on estuarlne zones* the HtfRA could have even
considered use of the Valpoie site In the first place! And. how
USBPA, Region 1 could have overlooked this important factor in its
initial approval of the site. Please advise.
Section 1314(k) clearly states that in accordance with Sn <*f
l.he Amy ell plans for water disposal aust neet section 1200 of
USC 33. Section 1206 states that all programs oust be designed so
that they work for twenty <20) years. Use of the tfalpole site does
not. Therefore its approval aust be denied!
What ever landfill site the MWRA finally i;elects, it Mist I e a
site that Is able to operate for at least 20 years under all
possible conditions of the plan.
Based on these facts 1 deran.J that the USEPA deny approval of
the tfalpole landfill site. Thank you.
Yours truly.
Larry Bassignsnl
PS: in ey letter to you of !-6-90/cacf> doc9 pg!8 please rhnngf?
the word following orinary In the first sentence fro* objection to
Thank you.
Hoi folk CAC T O.Box 63 Norfolk, HA 02056 (50F») 52U UUl!.
17 Jan. li>:«*
i.acb docCl pg 2-1
Hs. Ann Rodney
USEPA, Region I
HEP-1900C
JFK Federal Bldg.
Boston, HA 02203
Hi Roif-nfty:
Throughout tl»o Clean Water Art/IISC 33 it clearly states that
Htfi lis primary ojectiveis to maintain protection of th? waters
of our nation end that selection of waste disposal facilities
sh>Mi 1 d bi> area that provides the learst possible rnvir-'ninpnUl or
hon 11 h h;i. a r rt risk!
Th. H«PA. in iff; v.f the Uu l|.r*K- it. h.: t .. i I -
r..| low these n.nd;« t «>r y guidelines. This is clearly n in Volume?
4 of its FETH of Aufl . 1989 covering landfill evaluitirm
If y •« look al pages 5 II ami f» 18. (rncl ). yon IhM in
itr; first c v a lu j 11 vn it places a. favorable ralin»; on th«. ecology
and wetlands criteria on the Rowe Quarry site and an unfavorable
on the tfalpole-HCI site. Rased on the goals and objectives sought
by our Clean Water Act, this factor alone should have eliminated
the tfalpole-HCl!
Hext, when you look at the second-level of evaluation of
landfill alternatives, (page 5-18), you aee that the rating for
the ecology and wetlands at the Rowe Quarry reealns favorable but.
that the tfalpole-HCf has risen fros unfavorable t- neutral. Here
again the sieple fact that the Rowe Quarry recievcd a
higher/better ratine in the ecology and wetlands criteria ehows
that it mist be the site used. The facL that the NURA also gives
the Rowe Quarry a "higher rating' In the peoples drinking water
category than the Walpole-HCI site. (ref. page 5-17], adds to the
fact thet it should have been the selected site.
A point that also must be addressed Is. how coi/id the Wijlfc-K'
citf rating In ecology and wetlands have rlztn frost unfavorable to
neutral? Nothing has changed at the Valpole-MCI site which would
have leproved its ecology and wetlands criteria! In fact . the
discovery of the onnaoed creek that is in the Ualpol'* site and
whose waters flow into the Stop River should have reduced the
rating, certainly not improved it fros unfavorable to neutral!
Based on thfcs'e facts f denand that the MSbTA f>*rfr>rm it^
environmental protection duties and deny approval of the Walpole
site to the HtfRA. Thank you.
Yours truly,
—
tarry Basslgnani
Norfolk CAC P.O Ron G3 Norfolk, HA 02O5B < M1H) M1«0
-------
S. David Graber
CensoMnt Enfinwt
niitw
ttll nun Road tmmonmfntalFltydravHc/Mrchanlcjl Enginaada®
SIwbMmIi MnudwKlliOW! Walar Quality ManacMwnl PImiIki
16171341-0390 environmental AnalytlWModelinf/RMeaich
January 11, 1990
U.S Envtronoantal Protection Agency, Region I
JFK Federal Building, HQE-I900C
Boston, MA 02201
ATTN: Ms. Ann Rodney
SUBJECT: TSEIS - Lanf-T#ra Ruldull Htnaqeunt for Metropolitan
Boston
Ladles fc Gentlamn:
On behalf of tht Sel«ctMH of tha Town of Hlnthrop, this letter
provldea technical eaannti on tk* subject rinal Supplemental
Environmental Impact Statement, dated November IT, 1919. Separata
legal comnenta are being Bubaltted by Hlnthrop's attorneys.
Me commend EM and their consultants for preparation of an FSEIS
which Is readable end avoids burdening reviewers with repetition
of earlier documentation. Proa an Immediate, practical etandpolnt
our most Important cements are provided below under the head I ng
of MEZD FOR FURTHER BNV1R0IMCIITM. REVIEW/MITIC*TIOH. The brevity
of that section la dua to the Inclusion of attachments, which we
urge td to review In detail as part of those consents. That
•action addresses important laauea that should not ba overlooked
aeld other concerns that have received aore conspicuous atten-
tion. He hope that tha ROD will reflect serious consideration of
those comments. Additional comaents are provided under the
headings of ACCEPTABLE TECHNOLOGIES, and MISCELLANEOUS.
Hf.ro roii nruTHER environmental revtew/miticatiom
Hlnthrop's DSE1S comments stated the Town's concerns that control
of odors (and air quality aore generally)-be a primary focus of
the FSEIS. Specific areas were aentl'ied for consideration. The
U.S Enuironmentel Protection Agency, Region I
January 31, 1990
25
response to this tn the FSE1S la a three-sentence dlscusslo
(page S II) of storage tank and centrifuge odor control. 1
addition to air dlsplsesd froa sludge storage tanks, sources o
Importance Include digester gas utilization (power plant, etc.)
gravity thickener vent gas, air vent eshsust from centrifuges an
various sludge wet well*, air displaced froa sludge storag
tanks, digester cleaning operations, possibly waste-gas flares
etc. tn more recent FEIR convents, Hlnthrop elaborated on thi
need for additional envlronaental review In this area. Including
the need to address cuaulatlve air emissions and assoelatec
mitigation. Excerpts of those comment* under the heading "Neec
for Further Envlronnental Review" (and related Attachment I
thereto) ar<- attached. The ROD should address thi-r.e concerns Id
det all.
Section 6.4.3 (Other Mitigation Measures) an.I Table 6.4 1
|Recostmended Mitigation Measures) should, via the ROD, address
the above end ehould otherwise reflect the aagnltude and Impact
Of the Deer Island facilities In relation to those at the other
si tea.
ACCEPTABLE TECHKOI.OGI ES
Hlnthrop appreciates the FSEIS acceptance (Section 6.4), as Its
preferred plan, of MHRA's plan which svolds Incineration anywhere
and ellalnates heat drying on Deer Island. The Immediate Impor-
tance or some of Hlnthrop's comments sre diminished accordingly.
However, to the entent that those technologies or locations are
found "acceptable" In the 0SEI9 and FSEIS, and considering that
the future could bring resurrection of "acceptable" technologies
or locations, we will comment on mame of the rationale presented
In the FSEIS.
Rationale lor the acceptability of heat drying on Oeer Island Is
given In Subsection 5.9.1. Hlthout repeating other earlier
arguments, we note that one of the main arguments presented by
Hlnthrop In support of dropping heat drying at Denr Island was
the limited land area available. It Is useful to note In this
regard that the space available for residuals processlnq on Deer
leland has dwindled from the 20 acres considered during much of
the RIIFP process by 11 acres to a total presently of only 9
-------
II.S Environmental Protection Agency, Region I
January 31, 1990
25
-3-
dcres.' This confirms the inability to site additional residuals
management facilities on Deer Island, and also greatly Increases
the difficulty of designing those Deer Island residuals
facilities which are part of the preferred plan (primary and
waste-activated sludge thickening, anaerobic digestion,
sludge thickening, and associated sludge storage).
Winthrop'g detailed, quantitative comments regarding Doer Island
noise impacts are responded to in FSEIS Subsections 3.7.3 and
5.12.2. The responses simply reiterate or refer back to the
DSEIS, the Inadequacy of which provoked the comments In the first
place. That is not responsive.
The responses to Wlnthrop^s comments on incineration air quality
Impacts are deficient In many respects. Some particulars are
glvon bolow:
Hinthrop's specific comments that combined effects of the
mixture of air toxics be considered 1b responded to (FSEIS
page 5-20) by stating that while the methods proposed are
used to evaluate mixtures in the workplace, "It Is not
considered a standard method for evaluating contamination
In water or ambient air". "Therefore, this evaluation of
additive effects was not made." That is not a good reason
for doing less than the best that can be done with
knowledge currently available, accepting the burden of
proof, and if erring doing so on the side of public health.
The arguments regarding synergistic effects on FSEIS page
5-20 are similarly Inadequate, principally for reasons
given in our DSEIS comments.
Consideration of asbestos emissions is added In the FSEIS
(page 5I3| for heat drying only. Asbestos emissions have
not been considered in conjunction with Incineration.
In the response to Hinthrop's comments regarding phosphoric
acid emissions (FSEIS page 5-12), there is still no
explanation of the basis for the assumed emission rate.
The FSEIS statement (page 5-24) that air quality impacts
were examined "c.-3ely" for Deer Island is clearly refuted
1. "Predeslgn Report (Final) - Deer Island Residuals Facilities
DP - 13/17", Prepared for HWRA by Black I Veatch, September
1989.
25
U.S Environmental Protection Agency, Region I -4-
Jantiary 31, 1990
by our DSEIS comments, particularly those pertaining to
interactive sources.
Wlnthrop's DSEIS comments suggested a comparison bo made of
the comparative rates of greonhouse gas emissions for the
various technology mixes. The response (FSEIS, page 5-14)
merely states that the concent rat Ions of two of the
greenhouse gases (CO and NO2 - methane is Ignored for the
comport. I ng and heat drying tcchnol og I es) are a fraction of
the Nat Ion.il Ambient Air Quality Standards and thus are
con^ldorod to be Inslgnlf1 cant contributors to the
greenhouse effect. Obviously no one source Is a significant
contributor to the greenhouse effect. What Is significant
Is the combination of all similar sources, and the role
that EPA policy and decisions (e.q. those regarding
"acceptable'* technologies) play in that connection. A good,
quantitative response to the quost. ions posed would be
useful In addressing that broader Issue, and is again
request ed.
The following from the Residuals FEIR (August I9B9, Volume
2, page 112) Is noteworthy: "With respect to public health
concerns over combustion emissions, very little data Is
available to alleviate those concerns. It Is noted in the
Public Health Assessment that the health risks associated
with combustion are far greater than for heat drying or for
compost i ng...."
MISCELLANEOUS
The FSEIS responds substantially to the concerns expressed in
Hinthrop's DSEIS comments under the heading of Emergency Backup.
The response (pages 2-1 & 2, 2-5 & 6, 6-5), for which EPA is
commended, focuses on additional heat dryer capacity. In
preparing Its ROO, we ask that EPA consider Winthrop's more
recent FEIR comments (excerpts attached) under the headinq of
"Firm Capacity fc Backup".
The analysis of landfill leachate impacts on the Stop River has
been much improved. The opposing effects of additional aquifer
attenuation phenomena and lower river flows have been considered.
The Stop River low flow Is much more reasonable than used for the
DSEIS, but remains about three times greater than that used in
our DSEIS comments. With the limited Information presented in the
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II.S Environmental Protection Agency, Region I
January 31, 1990
25
FSfcIS, it is not possible to determine whether the FSEIS value is
more appropriate; the hydrologlc extrapolation procedure may be
Inaccurate since It does not to take Into account such factors as
artificial withdrawals and discharges along the waterway.
Section 5.5 (Residuals Characterization) could have provided much
better, more assuring responses.
None of the corrections suggested under the "Miscellaneous"
heading of our DSEIS comments have been Included in Chapter 7 -
Errata.
Thank you for the opportunity to submit these comments.
cc: (w/o Att.)
Robert E. Noonan, Chairman, Winthrop Board of Selectmen
Richard P. DiMento, Winthrop Selectman
Richard N. Bangs, Winthrop Selectman
Virginia L. Wilder, Winthrop Dir. of Community Development
Emllie DIMento, FPCAC/Wlnthrop
Mary Kelley, Chairman, Winthrop Conservation Commission
Thomas E. Rellly, Jr., MWRA Board of Directors
Kathleen Hearn, MWRA
Eric Buehrens, MWRA
Dan O'Brien, HWRA
Carrie Fuchs, MWRA
Steven G. LIpman, DEQE
Marilyn llotch, MWRA
Harlan Dollner, McGregor, Shea i Doliner
David Standley, Qiilncy Consultant
Very truly yours
S. David Graber
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Response tot EPA Final EIR
From( James Glebfried
J1* Robin Road
Norfolk, MA 02056
Datea January B, 1990
Concerni The MWRA proposed landfill doea not protect
the public health and environment.
The EPA study by Brown,Thomaa ate. In 1987
Indicate problems with the use of flexible membrane
liners. They Indicate that facllltlea that have function
well for years with flexible membrane liners have
been known to fall rapidly when exposed to chemicals
for which they were never Intended.
The MWRA has not done any published compatibility
studies nor can It since the waste varies In the system
second by second. There Is no planned manifest to
record the type of waste to be dumped. This
can only lead to future Incompatible reaction ns
newly created material react with previously dumped
materials.
Response toi EPA Pinal EIR
From James Olebfrled
31* Robin Road
Norfolk, MA 02056
Datei January 8, 1990
Concernt The MWRA landfill design does not protect
public health and the environment.
EPA study by Ixibel 1986 indicates numerous
concerns or leaking from landfills causing contamlnantn
to leak, percolate or be Injected to aquifers. As
contaminants trsvel through the soil and Into a ground
water system, they may be slowed down.or degraded by pro-
cesses that are complex and not completely understood,
but tlose natural processes are NOT totally effective
for all contaminants. For example,soils were once believed
to be cfnble of binding and holding all chemicals.This
is now known to be false for some Important end
widely used classes of chemicals, like organic Bolvpntn
such as tri and tetrachloride.
Once the ground water Is polluted Lobel states
restoring a polluted aquifer is generally an extremoly
expensive enterprise particularly when no other
local water source exist.
The Walpole site is solely well water supplied
area with no backup supply available. MWRA literature
Indicates that wastes to be dumped at the site am
among those considered by lobel aa dangerous to the
aqulfer.
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Response toi EPA Pinal BIR
Promt James Glebfried
3<» Robin Road
Norfolk, MA 02056
Date1 January 8, 1990
Concern Flexible membrane liners ahow design characteristic
that produce landfill system failure.
The EFA study by Morrison and Parkhlll, 1987
•haws considerable problems with flexible membrane
llner9(FML)1
1. Chemical Immersion tests indicate
that changes in weight and thickness
of the membrane affected in the tests
were quite rapid.
2. Results of the accelerated outdoor
sunlight exposure testing Indicate that
the one year expoaure may be too long,
resulting in accelerated weathering condi-
tions too severe for some membranes.
3. Of the three thermal methods used to
field seam HDPE PML, evaluated in this
study, the extrusion lap weld produced the
highest shear and peel strengths. The
extrusion fillet weld produced a slightly
higher shear strength than the hot dual
wedge, but the peel strength of theBe two
page 2 ,
aeams were nearly Identical. The peel
teste, however, the hot dual wedge seam
exhibited a failure within the seam area,
and the other two field seams failed
at the seam edge.
•». Generic-type liner specifications are not
sufficient to ensure satisfactory
performance of FML seams when hazardous
waste containment application is used.
5. Short term chemical immersion tests of
up to six months may not be or enough
duration to determine the chemical
compatibility of some PML seams.
This etudy points out numerous problems with
the proposed IWRA landfill design but in particular
these threet
1. The MWRA's failure to do or ability to
do compatibility tests on the liner.
2. The size of the cells and length of time
it would be exposed to the elements would cause
11 to fa 11.
3. Field tests on FKL seams show they will
•fall and leakage will occur at the landfill.
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Response toi EPA Final E1R
Fromi James Glebfrled
3i» Robin Road
Norfolk, MA 02056
Datei January 8. 1990
Concerni The MWRA health risk assessment reports
are nonconcluslve and Invalid.
EPA documents indicate that health risk assessment
are not accurate measures.
The EPA project summary May 1987'Environmental
Epidemiology! The Importance of Exposure Assessment"
atatssi* Unfortunately, most of the exposure and
assessment work currently being done is
of limited value for use In epidemiology
research as directed towards developing
methods for detecting toxic chemicals
in biological samples (as opposed to
living people) or demonstrating that specific
source results In exposere( but not
quantifying that exposure)".
The study further states" While It is Important to
fully understand the source, routea, and extent of
exposure of Individuals to environmental toxicants,
obtaining such knowledge about the population Included
in an epidemiology study may not be practical and
may not be achievable in all cases."
This project was the collective work of over
fifty distinguished scientists respreslntlng academla,
povernment Indnnt.rv In n r r,.,....
Reponse to( EPA Pinal EIR
¦C
Fromi James Glebfrled
3*» Robin Road
Norfolk, MA 02056
Datai January B, 1990
Concernt The Walpole proposed design does not adequately
describe how they will stabilize liquid waste and compact
eoid waste.Also will the EPA assume control of the proponed
site 30 years-post closure.The MWRA han always Indicated it
wants complete control.
The EPA atudy by Gilbert and Murphy discuss stability
concerns of a landfill post closure as it would be the
responsibility of the EPA to monitor and remediate
problems as per l»0 CFR 264.117. The discussion of the
stability of materials does not appear to be adeqi-ntely
addressed In the EIR.
Gilbert states material should bei compacted or
treated to reduce potwtiAl settlement by vlbratiory
rollers, preknded and surcharged,prozzolanlc stabilizing
liquid waste and surrounded by multiple layers of
drainage.
The ability of the EPA to remediate any potential
problem at the proposed site is questionable. The OTA
documents of 1909 Indicate only 19^ of. the Superfiind
Bites have been completely remediated once cleanup
was attempted.
If you the EPA and the MWRA cannot guaranty your
activities don't sell your product. I don't buy your
sales pitch.
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Response tot EPA Pinal EIR /¦
FromiJamea Glebfrled
3*»Robln Road
Norfolk, MA OZO56
Datei January fl, 1990
Concern! Adequate aafe guards at the proposed Walpole
landfill site have not been designed for gases generated
from the toxic materials to be dumped there.
The proposed landfill by the MWRA will produce
gas products that are considered hacardous by EPA
studies to surrounding residents.
The EPA study by Brlggs,1988 indicates there Is
little information on the characteristics and quantities
of condensate produced in landfill gas (IFG) collection
systems.He recommended a change in the EPA's
Environmental Protection Toxicity Teat to a new
Toxicity Characteristics Leaching Procedure. Also
to expand toxic compounds tested from 14 to 52.
This study on LrG concludedt
1. Based on hatardous characteristics
tests for lgnltablllty and Toxic
Characteristics Leaching Procedure.
LPG condensate, and particularly the
organic phase, may be hazardous waste.
page 2
26
2. Regulatory decisions regarding
whether or not condensate gas must be
treated and disposed of as a hazardous
waste must be done.
The EPA must evaluate the MWRA•a materials
now and In the future on condensate gas emission .
To do so will definitely drsi/*mtc- the site an a hazardous
waste landfill.
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Response to i EPA Pinal EIR
Front Janes Glebfrled
3*» Robin Road
Norfolk ,MA 02056
Date January 8, 1990
Concerni Ed studies show design of landfill covers
have nunerous public health and environmental problems.
The EPA study by Dwyer, Walton etc. 1908 indicate
landfill cover problensi
1. The "Help model" Indicate that
these covers ( soil) experience
saturation of top soil layers.This
saturation could be harmful to
vegetation and could result In
excessive surface runoff.
2. Other concerns -vertical per-
colation layer saturation, geologic
conditions, storm nagnltue that the
cover Is Intended to withstand,
local climate regime,threat to
ground water contamination, gas control,
wildlife habitat, prevent animal
burrowlng( use a dry loose cover
of gravel and sand ), control Insects
and blrdsfy Installing a thick compacted
well drained surface layer), and at leant
page 2
24 inches of compacted sand and
gravel between base of the cover
and the waste layer.
The MWR* design does not address all of thene
concerns sufficiently to protect public health nor
the environment.
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Response to, EPA Final EIR
Prom t James alebfrled
3*» Robin Road
Norfolk, MA 020$6
Date¦ January 8, 1990
ConcerniLandfllls should not be sited over fractured
bed rock.
Enclosed 1b the testimony of David Miller to
the Subcommittee on Natural Resources, Agriculture
Research and Envirnonmental Hearing. He is a geologist
with over 30 years experience in ground water.
His testimony Indicates that analysis of ground
water monitoring when bed rock is fractured is extremely
expensive and may not be cost effectively employedi
"In order to obtain credible Inform-
ation, dozens of wells and hundreds
of ground water samples may be required
to develop an analysis of the hydro-
logical system. Such conditions are
common in fracture rock areas and In
regions where a number of different
aquifers comprise a complex now
system...It is my recommendation
that no new land disposal facilities
be allowed under these conditions
regardless of engineering design;
page 2
26
The Walpole site has the Charles River Water Shed and
the Neponset Valley aquifers .Also the site Is over a
fault line and fractured bed rock.
Hr Miller also Indicates that the health risk
assessments cannct be adequately done with present
technology!
" Unlike detection monitoring. com-
pliance monitoring with Its depen-
dence on predictions of contaminant
migration through the subsurface may
be beyond current state-of-the-art
of ground water science. It is not
presently possible to determine how
thousands of Individual chemicals
will react in the ground water
environment or to confidently pre-
dict the aggregate effects of
numerous processes such as atten-
uation, dispersion, and diffusion."
with the MWRA always stating cost as a deciding
factor, Mr Miller's comments on trying to cleanup contamin-
ation from ground water are Importanti
"Restoration costs for a typical
plume of contaminated ground water
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J»g«3
26
can be tana of millions of dollara and can
take decades to ichlm... In those
areas where cleanup cannot b* Justified,
the contaminated aquifer area will
have to be written off."
These statements colnside wit OTA 1969 statements
that i
1. 90)1 of all Superfund sites are landfills.
2. It takes ten years on the average to
cleanup a Superfund alte.
3. Only 19Jt of Superfund sites are completely re-
mediated.
Therefore, the Walpole site Is wrong becauae of the
fractured bed rock, two aquifers at the site and the
extensive cost to monitor water pollution and its
remediation.
3<» Robin Road
Norfolk, «A 02056
January 8. 1990
Ms. Ann Rodney
USEPA, Region 1
kep-19ooc
JPK Federal Building
Boston ,MA 0220J
rei Comments on MWRA's proposed landfill at Walpole for
the final EIR
Dear lis Rodneyi
Enclosed are numerous c-nceme with supporting data.
I am extremely disappointed that the EPA has refused to
meet with the towns of Walpole and Norfolk to verbally
hear our cltixento concerns regarding the final EIR.
I am extremely dlssappolnted that the EPA does not
recongixe the findings of David Lange,former.Chief
hydrologlst for the Superfund,who showed the site is
over a zone II aquifer and the conductivity of the
water will lead to contaminating our water within
five years.
Sincerely^ Yours,
/^ames/Glebrpi^d.M.A. ,Ph.T.
£ / V
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DEPARTMENT OF THE ARMY
NtW IMQUUK) OMStOH COWS or IMGINIIRS
414 l**PflO ROAD
WMTH1M M*SS*CMUSf1»S 01154 9I4S
February 6, 1990
27
CEHED-OO-R
Ann Rodney, Proqraa Assistant
U.S. EnvlronMntal Protection Agency
Region 1
John P. Kennedy Building, HQE-1900C
Boston, Hassachusetts 02203
Dear Ms. Rodney:
Ne have reviewed the Pinal Supplemental Environmental Impact
Statement, Long-Term Residuals Management for Hetropolltan Boston
and provide the attached comaenta.
If you have any questions, please contact Peter Kube at (617)
647-8493.
Sincerely
lam p.
Chief, Regulatory Branch
' ~ I 03J Operations Division
1/9,
03V
Enclosure
Copy futnUhtdi
Massachusetts Water Resources Authority
Attn: Richard D. Fox, P.E., Director
100 First Avenue
Boston, HA 02129
27
Review Comments on Final Supplemental EIS
for Long-Term Residuals Hanagement for Metropolitan Boston
Chapter 2. Modifications of the Proposed Action.
The FSEIS does not adequately compare and contrast the
project alternatives, as required in 1502.14 (b). The FSEIS
should have evaluated the environmental costs of eliminating
composting in favor of pellet production as a sludge disposal
alternative. The reliance on pellet production reduces
operational flexibility and requires that landfill be available
as a backup system. This puts added pressure on landfill
capacity. Although the assumptions for emergency landfill
requirements are thought to be conservative, we boliove the
possibility that additional landfill may be required is very
real qiven the uncertainty in quality of secondary treated
sludge, questions of pellet marketability, and decreased
flexibility in cases of eguipment failure. Ha guest Ion whether
it is reasonable to assume that additional landfills will be
available. Me believe that the guestion of additional landfill
requirements should have been addressed more fully and potential
sites evaluated in the FSEIS. Should additional landfill sites
become necessary, the Corps may request a full alternatives
analysis with respect to 404 (b) 1 guidelines.
Chapter 3. Expanded Technical Evaluation of MWRA-Selected Plan.
This section provides further evaluation of sludge quality
and potential impacts of the project to groundwater and surface
water quality. Scientific uncertainty in the assessment of
impacts was handled using conservative assumptions (worst case
analyses) and discussing the probability or likelihood of
potential negative impacts as recommended under NEPA
(1502.22). Nevertheless, we recommend that aonitoring and
contingency plans be implemented prior to the Record of
Decision.
Specifically we recommend further analysis on the character
of secondary treated sludge as this relates to the' marketability
of the pellets, the quality of leachate and potential water
quality impacts. He also encourage periodic monitoring of
organics in sludge products.
The FSEIS lacked any specific detail on the pretreatment
program. This is a critical eleaent of the wafctewater treatment
prograa. Target goals for the influent and means to achieve
these goals (e.g. source reduction or pretreatment) should be
enumerated.
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27
Chapter 6. Acceptable Residuals Management options and
Mitigation.
The PSCIS should have Included CPA's rationale for agreeing
with the (MRU's preferred alternative and a public discussion of
the environmental and economic trade-offs that were made in
coming to that decision. The fact that all options were deemed
to be environmentally acceptable does not Imply that there are
no Impacts nor even that the impacts of each alternative are the
same.
The DSE1S recommended that the MUM establish a plan for
confirming through additional sludge and Influent aonltoring the
projected levele of netale which have the potential to exceed
regulatory atandards for distribution of sludge products. They
also recommended contingency plans for decreasing influent
concentrations of these metals.
A more detailed contingency plan for ispicts from residuals
should have been prepared In the FSEIS process. The FSEIS
states that monitoring systens at the landfill would provide
opportunity to (Is any leaks but does not outline the steps that
would take place to control the leak and repair if necessary. A
contingency plan with detailed discussion of potential
remediation efforts should have been laid out for the public to
review and comment.
These plans need to be developed and should be reviewed
publicly prior to EPA*• Record of Decision. He slso recommend
that all mitigation measures listed in the FSEIS be Incorporated
Into the ROD.
The FSEIS would be better suited for our regulatory purposes
if it detailed the activities regulrlng Corps actions. This is
not critical so long as decisions made in the MEPA process do
not affect or limit options on actions that may require Corps
permits. Permit activitlea will have to be reviewed by Corps
staff. He will continue to monitor the progress of the project
as It affects actions which may fall within Corps regulatory
jurisdiction (e.g. devaterlng into the Fore River, construction
of water and sewer lines to KCI-Walpole).
Appendix
Comment letter* were poorly orqanited and incomplete. The
Corps detailed commenta on the DSEIS were not Included In fhe
FSEIS. This Is ineon*latent with the Intent of KEPA (1501.9)
which calls for disclosure of public snd agency comments.
27
Summary
Mille there is some uncertainty with regard to potential
impacts, the marketability of pellets, and future landfill
reguireeents, the FSEIS addresses these uncertainties in a manner
that Is consistent with NEPA (1502.22). Me believe the document
is adequate with respect to NEPA compliance provided that the
sitiqatlon plans recoemeded above and in the FSEIS are
impleaented as part of the ROD (See KEPA 1505.3). We reserve
the right to request more Information as detailed plans (or
actions within our jurisdlciton are developed.
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DEPARTMENT OF THE ARMY
WW tMQlAMO OMSION. COUPS Or CNGINICRS
414 numo road
MM1THAM UASSACHUSrtrS 0JJ54 S14S
July 19, 1989
CENED-OD-H
Ann Rodney, Program Assistant
U.S. Environmental Protection Agency
Rpg i on 1
John F. Kennedy Building, ;
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27
comparative impacts. In presenting a grab bag of components, but
not complete alternatives, for impact analysis, the EIS does the
reviewer and decisionmaker a disservice and defeats the purpose of
an EIS under NEPA (see NEPA Regs. 1502.14). Furthermore, it makes
evaluation, from a regulatory point of view, impossible.
C. Please note that the Corps of Engineers' regulatory
authority includes II Section 404 of the Clean Hater Act for
activities involving discharge of dredged and fill material in
waters of the United States, including wetlands, and 21 Section 10
of the Rivers and Haibors Act of 1899 for work tioyon.) m.-an hiqh
water in navigable waters of the United States. Section 404 is
mentioned generically in the EIS, but not in reference to specific
sites or activities. Section 404 jurisdiction may apply to
several construction and operations options. More detailed
information would be necessary on proposed actions, includinq
delineations of resources impacted, should they be part of a
complete recommended plan for residuals management.
Unfortunately, there is no complete recommended plan at this time,
as discussed earlier. Reference to Section 10 is conspicuously
missing in the EIS. Pier construction at Spectacle Island would
fall under Section 10 jurisdiction.
2. Specific Comments
Pg. 3-64, Para. 3 - See note above regarding Section 10
regulatory jurisdiction.
Pg. 4-18, Para. 4 - Deepening the existing Federal channels in
Boston Harbor is scheduled to begin in the fall of 1993, with a
possible earlier start in the fall of 1992, but not in 1989 as in
your EIS.
Pg. 4-163, Para. 1 - The drainage collection area neai the
quarry entrance cannot be disqualified from regulation simply on
the basis of si2e and disturbance.
Pg. 5-93, Para. 5 - Reference to the Wetlands Protection Act
must not be interpreted to imply degree of interest or concern
under Section 404 of the Clean Mater Act.
27
MWRA DSEIS LONG TERN RESIDUALS MANAGEMENT
COMMENTS
HISTORIC AND ARCHAEOLOGICAL RESOURCES
SPECIFIC COMMENTS
1. Paragraph 4.9.2.3 Protection of Historic Properties. This
section refers to 36 CFR 800. Many readers may be familiar
with 36 CFR BOO, but may not recognize the title "Protection
of Historic Properties. We sugqest you add the CFR
reference for clarity.
2. Paragraph 4.9.3 Memorandum of Agreement. "ensure that the
effect of MWRA's Boston Harbor projects on National Reqister
eliqible properties will be accounted for in
compliance...." should change to "ensure that the effect oC
MWRA's Boston Harbor project on National ftegister eliqible
properties will be taken into account in compliance
with..." This language is more in keeping with Section
106. Also, the MOA should be included in the FSEIS, so the
public can see the stipulations that will ensure that
impacts are identified, minimized, avoided, or mitigated.
3. Paragraph 5.9.6.1 Prehistoric Background (Rowe's quarry!.
The MHC does have prehistoric sites on file for Revere.
GENERAL COMMENT: We would like to see evidence of the thought given
to the various possible scenarios for the various sites. If an
alternative is selected without having identified all actual
historical or archaeological sites and evaluating their National
Register eligibility, the historic preservation options are extremely
limited. For instance, if a National Register site is located at the
Walpole facility, and it is not identified until the selection
process is complete, then avoidance or minimization of Impacts may
not be possible. This approach may leave only data recovery
(mitigation) as an option. Therefore, the MWRA would be committed to
data recovery, .whatever the cost. We feel th*t potential costs of
survey, site evaluation, and data recovery should he described and
estimated and incorporated in the decision mnkinq process (SEIS).
3
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Ftl liw
3 Hlllbrook Ave.
Valpole, Ness. 020*1
ffbiwiry 4, H>0
Anna Rodney
Ration 1
MEP-1900C
in Federal Building
Boston, Haas. 02203
tn response to tha BPA Long-Term Residuals Management
for Boston Harbor Pinal Supplemental environmental Impact
Statement, I submit the following comments.
The Valpole/ Norfolk site la Inadequate In size,
environmentally aenaltlve, not cost effective, and a short
sighted, politically expedient decision which will not
achieve the dealred goal to clean up Boston Harbor.
Por the BPA to suggest, In the EIS, that hauling toxlna
from one alte, to dump onto another alte la unconaclonahle.
There ace volumea of Federally generated CPA data
documenting that tha alta will not be using "state of the
art technologysln terms of the liner system. Ve all know
that clay llnera will crack and leak. He can use common
sense to know that a plasltc liner,with seams and the size
of several football stadiums, will eventually be corroded by
chemical leachate or that It too will develop a hole and
leak.
BPA In a 1905 document tella ua that the Pvc leachat*
collection system will clog, and once clogged there will be
no way to clean It out. Tha BIS must provide documented
information to show how. In a worst case scenario, this
would be accomplished.
The technical data submitted by both the Towns of
Norfolk and Valpole must ba thoroughly reviewed, as they
consistently show that ground water contamination will be a
very real threat to our coaaunltltes. Again, there exlata
documentation by the BPA, that atatas even with the best
technologies, landfills will leak approximately 0-40 gallons
of leachate per day. Knowing this fact alone, monitoring
wells will be of no use; since by the time contaminants are
noted at a monitoring well,the ground will have already bean
contaminated and the track record for cleaning up
contaminated ground water Is not one which Is effective or
cheap. Monitoring wells will offer little consolation to our
communities as wa are aware that a 1982-83 study, again
funded by the BPA documents that 43% of the studied
monitoring wells showed defects, and are used largely to
reassure the public.
Tha Towns of Valpole and Norfolk have asked that their
consultants ba given tha opportunity to study the contents
of sludge. The Cltlzena Clearing Rouse for Toalns have even
offered free analysis, va have yet to be Informed of what
sludge pellets, raw sludge, grits screenings will contsln In
the way of toxlna. I can logically deduce that the sludge
28
Paqe - 1
contaminants change on an hourly bqals, depending on what
Industry Is currently dumping Into the sewerage system. BPJ
only examines ( chemicals and their effect on public health
out of the thousanda of chamlcala which surely must lace
Boston sludge. Can this be considered an adequate heelth
assesment? The bottom line la, that until industry provide
a record of zero chemical or toxic dumping Into the sewer
system, the dangers associated with these toxlna mixing wit
sludge Is a very real environmental threat.
Thus far, we the citizens of Norfolk and Valpole, hav
recoqnlzed that MWRA, under a court mandate. Is bowing to
political pressure. It has come*down to the point that BPJ
too can bow to political pressure or flqht for what Is
environmentally sound policy. Sltlnq sludqe In Walpole Is
not sound environmental policy.
Por a truely Long-Term solution to Boston Harbor's
pollution crisis, dumping of toxins must be stopped at the
source.
The mltlqatlon measures outlined In the EIS are
woefully Inadequate. How soon after contaminating ground
water, or the Stop River would the MVRA be required to bag!
clean-up? How long would It take to clean up the Neponset
Bole Source Aquifer? Would the Towns effected ever recover
these natural resources? Vho would pay for It all? Vould
Htm* ever admit that a catastrophic event took place? It
took months and months for DBP to test track TCE
contamination from Metal Bellows, a small company In
0haron,aa the source of contamination to the Town of
Valpole'a public drinking water wells. As yet, clean up,
after years has still not even started. Furthermore, we
aren't assured that 100% of the TCB contaminants will be
removed by the treatment system Metal Bellows will use.
Be assured that the Towna of Valpole and Norfolk will
never allow sludge to be dumped In our towna, on an aqulfei
threatlnq a aole aource aquifer, threatening our achool
children and nearby hospital community.You can also be sure
that the first smells of sludge will cause an explosive
reaction amongst the prison population, and you will read
about It In the news. Ve live In a democracy, where forclr
unpopular,unhealthy and unaound decisions on communities wll
cause a resolve among those citizens to fight the fight
until the truth Is heard and sound policy making takes
place. And we will win because sludge Is not going to be
dumped in our Towns. Ve will win because this Is a polltlca
contest, and our Towns know how the polltcal fight will tak
shape. Ve recognize that BPA officials are political
animals, but in your ranks Is the one leader who will say
STOP THIS NONSENSE, SLUDGB DOES NOT BELONG IN VALPOLE.
Sincerely,
CGnat U-hrvmiuwi
Carol S. Mlnkwltz ^
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FEB os mo
29
ft. W. Gillespie fir Associofes
'/
CONSULTING OfOTICMHICAl ENGINEERS
February 6, 1990
Ms. Ann Rodney
U.S. EPA, Region I
MEP-1900C
JFK Federal Building
Boston. MA 02203
RE: Comments on the USEPA Final Supplementary Environmental
Impact Statement
Long-Term Residuals Management far Metropolitan Boston
Proposed WatpoleMCI Landfill lor Sludge, Grit, and Screenings
Dear Ms. Rodney:
On behalf of the Town of Walpole and WMpoto Citizens Advisory Committee,
please find enclosed our comments on the Final Supplementary Environmental Impact
Statement (FSEIS) for the proposed residual landfill site In Walpole. In our review ol the
FSEIS, we have mainly addressed the following water supply and environmental
engineering Issues: bedrock structure, bedrock aquifer, Neponset Sole Source Aquifer,
hydrogeologic site characterization, monitoring and mitigation plans, and abutting private
wells.
GENERAL ASSESSMENT
We find that the FSEIS accepts a Smiled environmental dataset in its approval ol
the Walpole site. To determine the potential ground water Impact of the ie achate, the
FSEIS relta) lieavfty on protected oonlaminaiit-loading scenarios and simple mathematical
models. The hydrogeology and water resources of the site area have not been explored
In sufficient detail to estimate the probable hydrotugic impacts. Moreover, it Is unclear
iMt the Massachusetts Water Resource Authority (MWRA) wiB be able to properly monitor
the landfill performance or apply successful remedial measures (or any ground water
contamination due to failure ol the leach ate collection system.. The lad that the entire
Walpole she Res within a water resource area requires that the necessary geochomical
and hydrogeologic data should be obtained prim tu acceptance of the site.
The Town ol Walpole has obtained a significant amount of relevant environmental
data since October 1989 (Town of Walpole, 1989). These data point out shortcomings
In MWRA's assessment of the surficial geology, bedrock geology, bedrock topography.
P O (Vx 1 "17 • Vinfixf Maine CM07J • 3?4
R. W. Gillespie & Associates
29 ,
and ground water flow conditions within end around the site, as presented In their Final
Environmental Impact Report (FCIfl). Our Investigations included seismic refraction
profiles, site reconnaissance geologic mapping, and geotechnica! laboratory analyses ol
selected soil samples. IEP, Inc. performed test borings. Installed observation weds, and
monitored ground water elevations for the eastern portion of the site.
These new data are in conflict with many of the interpretations and assumptions
presented in the FSEIS and FEIR, Including Ihe following:
Observation 1: A buried bedrock ridge runs northeast-southwest across the middle ol
the proposed landfill bounds. The bedrock ridge maintains elevations of over a hundred
feet above the bedrock of the ad|acent ereas. The ridge ties in with regional outcrops
botli north and south of the site.
Implications: The bedrock serves to modify the ground water flow regime ol the lower
portion ol ihe sand and sifty sand aquifer. Saturated thickness above the ridge would be
50 percent of that olf the ridge and would alter contaminant transport below a certain
depth.
Observation 2: Bedrock lauds and numerous fractures occur beneath the site; some ere
projected to parallel the bedrock ridge, inspection of a core retrieved at from 120 feet
below ground surface at MWRA's bedrock weds MW 12, and 1N-R indicates that the
bedrock is highly fractured in this area. Other rock cores taken on site also Indicate
some Iracturing (MWRA, 1989).
Implications: The combination of large scale and small scale Iracturing indicates that
the bedrock formation beneath the site (Wamsutta Formation) is probably a good drinking
water resource. The private weds on Wtntor Street are bedrock weds and are most likely
recharged by ground water beneath the proposed site. Contaminant fate end transport
in bedrock is difficult to predict. Bedrock monitoring wells aro not effective due to the
nature of fluid flow in fractured media.
Observation 3: Seismic hazards exists for the area (Barosh el al. 1989). A fault surface
with slickensides Is clearly shown on a outcrop located a few thousand feet north of the
site; the fault Is protected to pass through the middle ol tho site. Holocene age (10,000
years ago to present) movement on this or other faults beneath the site cannot be
discounted
Implications: Slope stability ol a landlilfed studge/soil mixture could be very poor The
risk for slope failure is highest during saturated conditions with oar*hquako loading More
importantly, movement on a lauft extending beneath the site would breach the Nner
systems. Proposed Federal Subtitle D regulations prohibit siting ol o r.otid wasto facility
within 200 feet of a fault which has displaced during Holocene tiinp3 (EPA.
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R. W. Gillespie & Associates
29 ,
Observation 4: Ground water elevation data obtained from both newty installed weds
near the pioposed sHa btkJ Routs 1A and ndsUnn MWRA weds document that ground
water Dow directions are distinct from surface water drainage patterns.
Implications: A portion of the proposed landfill site definitely lies within the Neponset
Sole Source Aquifer giuuid water drainage basin. Numtally, landfills have not bowi
approved within sole source aquifers since degradation of precious water supplies ere
undesirable.
Observation 5: Analysis of sediment samples from borings and shallow excavations
indicate that the geologic formation beneath the site is a terraced, strattfied drumlin. with
layers of sitty sand with gravel (UK) to dean fine to coarse sand (reworked water-born
deposits). Both lab and field permeability estimates for these units Indicate a large
variabtfity for the different soil types. Large vertical gradients In hydraulic head may exist
throughout the site, simitar to that Indicated at nested weff 1N-U, IN I, and IN R. Water
table elevations obtained by the Town of Walpole indicate that the phreatic surface is not
necessarily a planar feature, and that local ground water depressions and mounds may
Influence the local ground water flow. Ground water seepage may be a significant
contributor to the source of the vernal pool located on the western edge of the site and
contribute to surface waters emanating westward from the vernal pool.
Implications: The heterogeneity in hydrauBc parameters for the various subsurface units
Is quite large and leads to uncertainties in possible contaminant transport pathways. The
geologic complexity of the drumlin ID preveifc ttm contaminant hydrogeohxjM hunt
mukbiy simplifying assumptions of aquifer condttions and forces Itlm/het tu obtain
detailed hydrogeotogic information on local surface/ground water interactions, vertical
ground water movement, and horizontal variability In ground water flow direction, aquifer
thickness, and hydraulic conductivity. Bedrock beneath the site has shown evidence of
highly transmissive, water-bearing fractures. With Ihefr present knowledge, neither the
FEIR nor the FSEIS has shown that a monitoring program can be established which
would adequately protect the surface and ground water resources in the area.
Observations: Physical properties of the drumfri tffl have been Investigated by both the
Town of Walpole and MWRA using sieve and hydrometer analyses on 15 relevant
samples. Results indicate that the tW is generally composed of a sllty sand, wilh 10 to 40
percent fines by dry weight (silt and clay size). The geologic classification is a sandy tilt,
not a sllty til as described in the FEIR. Conductivity estimates for various units range
from 10' to 10* cm/s. Generally, the geochemlcal properties of the sediment will be a
function of the day content, which ranges between 0 and 10 percent by dry weight wilh
most less than 5%.
Implications: The ability of the sod to adsorb contaminants such as heavy metals is
dependent on the distribution coefficient of the contaminant, and the bulk density, day
content, organic content, pH and cation exchange capacity of the host soils. Cation
R. W. Gillespie & Associates
exchange capacity is probably the best measured character of soils which refates to the
ability of soils to hold excess elements (Loehr et el, 1079), end is primarily a function of
the day contont and organic content. The day content, being small for the Walpole site
soils, may rondor the uso of tho retardation factors usod In the FEIR arid FSEIS as being
nonconservative in nature. Application of fate and transport models in sensitive
watershed areas requires that soil geochemical properties be measured. A field
experiment to measure parameters such as disporsion and retardation factor is necessary
to evaluate the model predictions.
CQMMEUIS
26.1 Landfill Design
The state of the art technology for landfills liners are double synthotic liners, not a
synthetic end natural double liner as proposed.
26 1.1 Landfill Liner System
The primary and secondary liner permeabilities will probably be greater than 10'
cm/s a very short time after Installation due to the lack of a quality assurance/quality
control program lor the landfill construction. Refercnoo is mode to the secondary liner
as being two feel of natural clay or bentonite but cost considerations have estimated that
the soils would be mixed. There is no discussion of soil amendment applications, no
precise cost enalysJs for sofl emendmonts, no onalysis of soil compatibility with
amondmonts such as bentonito. end there Is no test data to verify tho quantity of
amendment. Moreover, there is no essessment of liner integrity (No liner is 100% secure)
or fate analysis of leachate loss through the liner.
26 1.2 leachate Collection System
The FSEIS and FEIR assume that any leak in the primary layer will be found and
repaired. This is not technically possible for leaks in a cell which is in an advanced stage
of development.
3 2 neeveluatiooil Sludat Quality
The sampling technique, analysis end results of the sludge quality analysis was not
made available to the Town of Walpole at the request of the Walpole Citizens Advisory
Committee. The FSEIS states that the pollutant concentrations did not change between
two measurement periods (March 1988 Ortober 1988; November 1988-May 1989). except
for the mean values for boron and molybdenum. These results are questionable due to
Industrial dient? using the MWRA sewer service; these industrial users should have some
degree of fluctuation in their liquid waste stream, unless they are in total compliance
29
4
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R. W. Gillespie & Associates
29
5
AB metals concentrations w»ould Increase stonMcanMywWi secondary treatment; the
FSEIS slates that it would Increase "somewhat* which Is unclear.
33 Ground Weta Evaluation
The FSEIS states that N Is "unBtely" that the tandM double Bner and leachate
monitorInQ and collection systems would both M simultaneously. This Is not to say that
ll Is unlikely leachate wfll not enter the ground water. There are numerous examples
where they both have fafled (William Sanfour, personal communication. 1990). Landfill
Oners leak due to manutacluring Imperfections, poor workmanship, and accidental causes.
What are the alarms which are referred to when the primary liner has been
breached?
There is not a 25-foot unsaturated zone for most of the site; most of Phase I and
Phase III areas have little more than 4-foot of unsaturated soils, if not less.
The FSEIS and FEIR have not established how the contaminant metals behave in
the soils on site. Particular field and laboratory tests are required to do so.
The wetlands ot the Stop River are closer to being 1.500-feet from the landfill
boundary Instead of 2,000-feet. Speculating that the plume will escape detection Is highly
probable due to the present poor understanding of the site hydrogeology.
The survey of the private wed Is unacceptable. The FSEIS does not recognize that
an the private wells are bedrock weds greater than 190-feet deep. One rock wel In
WeVReld # 1 has a static water level of only 3-feet below surface end yields 14 gpm. The
bedrock water quality Is good. Furthermore, the FSEIS states that WeDfield # 1 and
Wotffieid 92 ere 800 and 1200 feet away from the landffll, respectively. However, Wellfietd
#1 consists ol two rock wells which are no mora than 300 feet end 600 feet from the
landfill, and Wefflield #2 has a well which Is only 900 feet from the landfil. These distance
errors have serious implications to the contaminant transport model results.
3 3.2 Groundwater Quality Impacts
There are deficiencies In the model appfcatlon to the private wells. First, the
retardation factors F\, assumed for the dHferent contaminants are not conservative.
Variability of the retardation factors was not considered. Walton (1984) shows that
Arsenic has a R, which ranges from 1.1 to 10 where the FSEIS used a value of 45.
Similarly the general range for heavy metals is 5 to itf To apply the retardation lactor
for the proposed landfill site soils, some measurements of cation exchange capacity and
organic content ol the sediment matrix should be made. The implications for lower values
R. W. Gillespie & Associates
of R, are that the contaminant transport may eventually reach the private weds at a rate
equivalent to the average ground water seepage velocity (about 0.25 fpd).
Since the private weds are bedrock weds, the contaminant transport rate is
uncertain. Wen data on the existing fracture orientations, hydraulic head, and recharge
areas are necessary to make an accurate estimate of the actual transport rate. A
reasonable estimate for the travel time from the Phase I landfill celt to the private Wefflield
# 1 Is 3 years. This short possible period Is unacceptable to the abutter. Moreover,
remediation efforts tor bedrock contamination would be very difficult if not impossible. No
background water quality data was obtained tor the private wells, making it even more
difficult to assess the potential impact of the landfid on the abutters with on-site water
supplies.
The leachate concentrations used in the analysis are not wed-documented. and
could be significantly higher. A thorough description ot how the leachate values were
obtained should be given. Industrial clients of the MWRA sewer service may have
accidental spills which win elevate the potential sludge and leachate concentration to
higher toxicity levels. Moreover, toxicity ol secondary sludge for some wastewater
treatments states that the total heavy metals produced In secondary sludge could be as
high as incineration ash (loehr et al, 1979). The mobility of heavy metals in landfilled
sludge win also be greater due to the more acidic environment present in the landfill
compared to that present in the treatment plant.
34 Sudacs water Eyalgalioo
The distance to the Stop River from the landfill boundary is 1,300 feet, not 2.500
feet. The travel time value may also be decreased due to the possible surface water
pathway provided by the brook present in the wetlands extending to the west from the
vernal pool.
It would seem thai the leachate fate and transport analysis for both the private
weds and Stop River should take Into account nitrogen loading due to the 3 to 6 percent
nitrogen content In the sludge. Nitrate-nitrogen Is conservative in that it has a Rd=«1. The
Initial concentration of nitrogen in leachate from a sludge dump has not been estimated.
JLLlW9teo!e
The computer modelling of contaminant migration is no substitute for actual field
investigations of the hydrogeotoglc conditions of the site area The conductivity values
used in the FSEIS ground water analysis Is often derived from the Zone II ground water
modeling calibration, which In Hsed takes on many poor assumptions- concerning the
aquifer hydrostratigraphy (see Town of Walpole. 1989).
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R. W. Gillespie & Associates
The deNneattnn of the Neponset Soto Source Aquifer boundary did not receive
careful consideration as stated In (he FSEIS. Our contention Is Itrat the MWRA tfld not
conduct adequate field reconnaissance studies, topographic studies, lateral groundwater
elevation survey, and bedrock outcroppings. For example, MWRA totally missed an
outcropping off Winter Street and Instead estimated the bedrock to be over 30 ft deep at
that location. As shown in the recent ground water study by IFP, Inc for the Town of
Walpole', the ground water flow direction near Route 1A is not parallel to the surface water
drainage direction. The ground water collected to date show conclusively that the ground
water divide does not coincide with Route 1 A. Additional studies may prove to show that
7 acres of the landfill boundary lies In the Neponset Sole Source Aquifer.
5,12 Milioailoo^MLConttDoency
Roth liners leaking at the same time have happened at other "state of the art",
double liner, double leachate collection systems. No environmental monitoring system
has been proven as a viable technique for this site.
5 5 1 Minor Residuals
The operating diffnrenres between a Yeslduals*iandffl and a DEP-dassilied "solid
waste" landfill ere not significant. As noted In the FSEIS, there is no distinction made
between wastewater residuals and solid waste In Subtitle O (EPA, 1988).
5 6 1 Toxicity of Residuals
The time is not sufficient for remediation of the private bedrock weds. The FSEIS
fails to realize that they are bedrock weds and that they are located as close as 300 feet
from the Phase f landfill cell. Leachate concentrations used In the models are not
necessarily worst case.
BAiLUraM Monitoring
The ground water monitoring discussion offered In the FSEIS is poor because of
the lack of understanding of the horizontal end vertical flow situations for the ground
water at the site. Due to the physical setting of the landfill and the ground water flow
patterns, the ground water flow directions are to the East, North and West. The number
ol weds necessary to properly monitor this site could be more than 20. Additionally,
multilevel weds are required due to the vertical hydraulic gradients present in the stratified
geologic units, and the involvement of the bedrock In the ground water system. The
anomalous situation apparent at MWRA nested weds 1N-U, 1N-I, and 1N-R must be
explained by the systematic placement of other nested wed triplets. The bedrock aquifer
has been ignored in the FEIR and the FSEIS. The thought that remedial technologies wffl
clean-up a contaminated bedrock aquifer Is Busionery The clean up of the thick
saturated zones of the site environs would also be expensive and costly. The existing
R. W. Gillespie & Associates
water supplies are best proteciod by a no action plan for the MWRA rocidual landfill
development.
The MWRA wilt not be able to replace contaminated ground water supplies, now
or ever.
CONCLUSION
In summary, the actual hydrogeologic conditions of tho sito are much moro compli
cated than implied in the FSEIS. With tho present data, it oppoars that the Neponset Sole
Source Aquifer may ultimately encompass over seven acres ol tho landfill bounds, and
at toast occupies tho eastern edge ol the Phase V landfill coll Tho rest of tho site is
deemed to be a sensitive recharge erea to community and private wells in tho area.
Additional boring and well data are required to edequately delineate the ground water flow
patterns beneath the site. Moreover, proper monitoring ol the landfill in such a
hydrogeologic setting and romediation ol any failure in tho leachate collection system is
a sorious quostion which is incompetoly answored. From our analysis ol tho potential
ground water quality impact of tho proposed Walpolo landfill site, we recommond that on
alternative action or site be chosen.
Very truly yours.
R. W. GILLESPIE A ASSOCIATES
John P. Jemsek. Ph D.
Robert W. Gillespie. P.E.
cc: James R. Merriam, Town of Walpole. Town Administrator
John W. Giorgio. Town of Walpole. Town Counsel
Daniel Fenno, IEP
Joanne Muti, Walpole Citizens Advisory Committee
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February 6, 1990
U.S. Environmental Protection Agency, Region I
JFK Federal Building, HQS - 1900C
Boston, m 02203
Attentioni Ha. Ann Rodney
Ret PSRI8 - Long-term Realduale Management for .Metropolitan
Boaton
Dear Ma. Rodney¦
V* have reviewed the Pinal Supplemental Environmental Impact
Statement on the long-Term Reaiduala Management program for
Boaton Harbor. This letter preaenta our legal commenta on the
PSBIS on behalf of the Selectmen of the Town of Wlnthrop.
Technical commenta will be provided by the Town's consulting
engineer, S. David Graber, under separate cover-
In oar comnti on the Draft SRIS, we reiterated our
concern* that the environmental review proceaa for the waatewater
treatment facility and the realdoala management program were
illegally segmented. We believe that each facdt of the overall
harbor cleanup program are Integrally linked and that aeparatlng
the environmental impact review akewe the analyaia, and that the
ultimate eltlng of the treatment facility la driven by a number
of factors, not the least of which la reaiduala management.
It la our contention that the point ie further emphasised by
euggeetlons in the Draft 8BIB that heat drying and combustion of
aludge be considered ae a posalble back-up alternative for
reaiduala management in the event that the preferred alternative
la unaucceaeful. We pointed oat that thia option ia not viable
due to apace considerations that were a direct result of the
facllitlea planning proceas undertaken by the Haaaachusetta Water
Resources Authority (MWRA) for the treatment worka.
He are atlll concerned about the lasue of aegmentatlon.
Wlnthrop'a technical cummsnta on the Draft EBI6, aa wall aa theae
aubmitted on the Environmental Iepact Report prepared for the
MWRA, contain slgnlflcsnt detail about the Town'a concerns that
the control of odors and other air quality issues be properly
McGregor, shea « doliner
-2-
30
addreaaed In the environmental review process. The Town's
technical comments epecify areas where air emission sources need
to be evaluated in greater detail. Additionally an analyaia of
cumulative air emissions and thorough consideration of the
requisite mitigation measurea la lacking during thla
envlronaentai review proceaa. Table 6.4-1 Recommended Mitigation
Measures, which was not In our copy of the PSBIS, does not even
list any odor control or air quality mitigation sieasures. These
snd other specific comments on the air quality analysis can be
found In the Town's technical consents. It Is Wlnthrop's
contention that the PSRIS (alls to adequately respond to these
issues.
Thus, • if odor and air quality Issues are to be properly
addreaaedt • It will be done outaide thia proceas. This la
unacceptable because interested partlea will be unable to review
a proper analysis of air quality lasues prior to the
dissemination of the Record of Decision. Wlnthrop strongly
believes that additional environmental review la warranted on the
odor control and air quality issues.
Furthermore, we maintain that the PSBIS was unresponsive to
our Draft SRIS cosSMnts on segmentation. While we underetand
that a project auch aa thia ia incredibly complex, we still
maintain that certain elements, particularly the siting of the
waatewater treatment facility and reaiduala management optlone,
should not be evaluated in aeparate documents written several
yeara apart. Residuals management, aa we have atated earlier,
does drive the ultimate altlng decision. If, in fact, "the final
analyaia of alternatlvea, the combination of aitea, technologies
and operating procedures were evaluated together*, ae atated on
p. 9-8 of the PSBIS, it aeems difficult to ismglne that
combustion of sludge on Deer Island could be seriously
considered.
Although heat drying and combustion remain "acceptable"
techno log lea, Wlnthrop ia pleaaad to aee that BPA accepts the
MWRA's recommendations ' which doea not conaider theae
alternatlvea. As stated in Wlnthrop'a earlier comments, we
believed these to be unacceptable optlona due to spaco and other
conalderations. Again, additional details can be found in the
Town'a technical commenta.
Thank you for the opportunity to provldo thaao commenta.
Ralph R. Wll ln.Br
Environmental Planning Director
HMD/RRWitmd
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MMO SIRNOIEY. P.E.
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31
February J, 1990
Ann Rodney
Mater Management Division
OSEPA Region 1
JFK Federal Building
Boston, HA 02203
Re: EPA SFE1S - Long Term Residuals
Hanagement for Metropolitan Boston
Dear Hs. Rodneyt
These comments on the subject FSEIS are submitted on behalf of
the City of Quincy.
Quincy *s comments on the MWRA*s FEIR are appended, to emphasize
to EPA the continued shortcomings of that process and documents.
EPA has in effect Iterated its finding of acceptability of
composting at the Oulncy site (see Table 6.2.1, "Acceptable Site
and Technology Combinations" and comment 5.2.5 "Acceptability of
Alternatives"I, without In any way addressing Ouincy s concerns
(my letter of 7/18/89, and Ounicy comments to the MWRA,
separately reterencedl or providing any substantiation for its
unwarranted findings. The Record of Decision should cleany
repudiate the acceptability of that alternative.
The SFEIS remains Incomplete and somewhat misleading because it
does not (and could not) reflect important new MKRA data on
sludge quantity and quality. This should be updated in the BOO.
It is indeed disappointing for EPA not to more vigorously
challenge the position of EOSA Secretary, and MWRA Chairm/.n,
ttoyte regarding the criterion "Equitable Distribution of Regional
Responsibility". That position is wholly inconsistent with tne
definition of the criterion in the RMFP support documents and
with the expressed (and voted) pesition of the Board which he
chaired. It also defies common sense and logic. Since the mwra
staff has now rejected the parallel concept of compensation to
host communities for the provision of a regional "goo4" I see
attached memorandum of January 24, 1990 to the MWRA Board) it is
even more appropriate for EPA to support this concept.
• Ii"m two. in—fcJi. iiMniiiimm etna
(V*l Mil MA?
31
CPA should abate the uncertainty about marketability of MWRA
sludge products {EPA's pending regulations* and comment 5.5.2) by
negotiating an ad-hoc agreement that Mill protect the MWRA's and
ratepayers' investment in residuals processing facilities from
any adverse outcome of the Federal regulatory process. Such an
agreement, established pursuant to the present Federal court
proceedings# could set acceptable contamination levels for MWRfc
sludge products and uses; taking precedence for a substantial
time over future Federal regulations.
Tabic 6.2.1 contains a typographical inconsistency with T.ible I
of the Executive Summary* in that Table 6.2.1 does not show
composting at the Stoughton site as an acceptable alternative.
That error should be corrected.
Quincy continues to object to the air quality evaluation of the
Fore River Basin site, on sevcrcl grounds. Failure to utilize
appropriate meteorological variables for the site, and failure *.*>
adequately incorporate multiple current and projected sources in
the area into the exposure assessment leads to an undor-
prediction of health risks facing sensitive population groups.
Additionally, the wrong yardstick is being applied. The MWRA
should be selecting sites based on relative public health impact
potential rankings after the acceptability threshold is achieved.
a
Respect fulIy»
David standley, p.r/.
Consultant to the City of Quincy
Enclosures 121
ccs tw/o enclosures)
Mayor James A. Sheets
Steven HcGrath, City Solicitor
J.A. Macflitchie
Peter (toff
Eric Buehrens, MWRA
Oavid Grabe.
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Ann Rodney
Water Management Division
U.S. EPA, Region I
JFK Rutiding
Boston, HA 02203
Dear Ms. Rodney:
February 6, 1990
RC: Final SEIS
Siting and Evaluation
of Technologies for
Long-term Residuals
Facilitles'
32
The Division of Hater Pollution Control (Division) has
reviewed EPA's Final SEIS for the referenced project and Is in
overall agreement with Its conclusions. The following are
comments on specific issues addressed In the Final SEIS.
Sludge Processing; Pages 2-1 thru 2-6 discuss sludge processing
.issues and the lmplications on other elements of the residuals
manageaent plan. EPA Indicates Its concern about the ability of
the "high solids centrifuges" to consistently produce greater
than 25% solids cake. The conclusion of the FSEIS is that MWRA
must reserve space adjacent to the processing plant at the Fore
River Staging Area (FRSA) to allow for future construction and
operation of 2 additional heat drying/pelletizing trains (in
addition to the 8 proposed to be constructed). The Division h.is
net with staff froa MWRA regarding this issue and the Division
does not believe It has enough data at this tine to make a final
determination regarding the number of processing trains which
will be required during the 2000-2020 period, and that the
information obtained during operation of the ISP(I) facility,
particularly if the Authority agrees to operate a pilot
centrifuge during this period, is needed before a final decision
can be made. Therefore, It seems reasonable and prudent for the
Authority to hold aside space adjacent to the ISPID facility to
allow for eight (8) processing trains to be installed.
* utilii les_l9tjdenum In HHRA's
sludge. Data from the last two years of Deer Island compost
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32
-3-
aonltorlng, aa provided to DEP. Indicates an overall Man of 8.27
¦g/kg with a Maxima concentration of 14. Coarpl lea ting thla
iaaua la data froa KKM'a nipllnq of dlqeater aludge going to
the coapoat plant which lndlcatea up to 107 ag/kg. Even though
the Dlvlalon does not believe Molybdenum will have a significant
impact on pellet distribution these apparent inconsistences in
the sl|idge sampling data should be resolved.
(2) Aa EPA indicates, out of 11 saaplea of combined sludge
produced during the recent trailer-aounted pilot treatment plant
prograa only 2 sludge aaaples had concentrations of copper which
would exceed the Division'a current 1,000 mg/kg Type II standard.
This new asaessaent la significantly lower than the theoretical
expected concentration of 1,240 ag/kg indicated in MHRA's FEIR.
Staff froa HWRA recently presented to the Division
additional sludge sampling resulta which appear to indicate that
tha aludga aanpllng location utilized by the Authority up until
recently at Deer Ialand haa raaulted in concentrations of
contaminants alanlflcantlv higher than they really are, in that
tha sludga being aaapled haa stratified In digester No.4 thereby
artificially indicating high average contaalnant concentrations.
HWRA1a Raaiduala Prograa ataff indicated to tha Dlvlalon that new
aludga data obtained froa a aora repreaantativa sampling point
lndlcatea that its sludga contains algniflcantly lower
concentrationa of contaainants than prior aanpllng data has
indicated. The new data lndlcatea that aludge from both Nut and
Deer Ialand are solid Type II aludga, in fact, all currently
regulated contaainants under 310 CHR 32.00 are Type I except for
Cadalua whoae concentration ia soaewhere between 5 and 10 mg/kg,
while tha Type I and II cutoffa are 2 and 25 ag/kg reapectlvely.
HWRA intends to consolidate all of their new aludge aaapllng data
and file tha lnforaation with tha Dlvlalon as part of a foraal
request for claaalf1catIon of thair sludga under 310 CMR 32.10.
This new lnforaation is important froa both the Interia and Long-
tera Realdual Prograa perapectlvea, and DHPC will keep EPA
inforned of all further actions in thla regard.
• Sole Source Aquifer: Tha FSEIS states on page 5-2, "... EPA
supports tha conclusion [HWRA PEIR] that the landfill footprint
Ilea outside of tha Zona IX and Neponset Sola Source Aquifer
boundariea." Tha atateaant that EPA atill officially conaiders
tha entire landfill footprint to be outaida tha Neponset Sole
Source Aquifer ie iaportant aince EPA and USGS are tha agencies
which dateraine auch boundariea. Aa you are aware, the Towns of
Walpola and Norfolk have inatallad a aeriea of additional
Monitoring walla in an atteapt to obtain data to convince
BPA/USGS that a portion of tha footprint ia within the Sole
Source Aquifer. Staff froa EPA*a Groundwater Section are
following thaae activitlaa and tha Dlvlalon requaata that tha EPA
keep the Dlvlalon Informed of all further activities by EPA
relative to thia issue.
-4-
32
Page 2-11, Section 2.6.1.3, Runoff Control System:
This section states in part, "Storawater may be routed Into
the wetlands along the stop River". It is not clear froa the
text whether this runoff is surface water which emanates from
portions of the sltn which could potentially come into contact
with the residuals or Is non-contract site drainage. HWRA will
need to discus* thin issue with 0EP during preliminary and final
design.
Page 5-7, Last Para:
The Division concurs with EPA's statements regarding the
unreliability of landfill privatisation. In fact, during the
laat couple of years local Boarda of Health have amended.site
aaalgnmenta for aost comaerclal landfill In the commonwealth to
restrict or disallow sludge or sludge based materials from being
disposed of in these landfills.
Page 7-1, Errata Sheet coanent No.l (Page 3-35, Section 3.2.6):
Thla text change unfortunately ia still Incorrect. The last
sentence should' be deleted, aa DWPC has notjnd doea net intend
to increase tha ainiaua separation between the bottom of a liner
and high groundwater froa 4 to 5 feet.
Please contact Steven Lipman (292-5698) if you have any
questions or comaenta regarding thia correspondence.
Very truly yours.
Wllliaa Gaughan ^
Acting Director
WG/SGL/sf
(B-Rodney)
cc: Eric Buehrens, HWRA
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4^t
mIflBfSPirr
January 29| 1990
M*. Ann R>)dn«)r
Rattr ManafaMnl OlvlllM
B.S. MM, n-.= l»k |
JFK raderai Banding
Boat un, HA 0120]
fit:: CmmMi t» Flul Si|>pl»wi)UI Envlreaaenta) lapacl *>l«leamail
Kweabar 1999 Loag-lara Realdeala Management
bear Ma Rmh|i
Tb«r t*ll»rii( are «MW»ti Hit with r«|ar< to Ik* DKM't
prnpnaaa .11 ling •' • landfill la hlf*U, Uaaaauliaaclla oa land
currently pari of tho Stale f'rlaon kaaervalJeat
I. Riltr aepply Valla
tl« ilid} l(i»nd IH* |-olentlal of (alar* private walla In (l«.in
|>r««lally la the prepated laadflll da* I* lb* devalepaeal potential sf
tha span apace/agrlealI oral land aaaoalatad with tallflald *t.
II. Genoral Property Velaoa lapacl
Thla is I* ihu l»tP-Ofc ianaflil ^ste aeu t>>
-the fact that a thirty-flva (IB) percent decreaaa la fair
urkm rsiae haa already bean docuaaaled.
-lb* fact lhal ilwlf <99) parcant of I ha articles cllrd
aar<> or I (tea aell before tba csrranl *aviroaa*atal lairtniti •< the
(anoral papalatlaa accarrad.
-lb* fact that the a tody ia rendered virtually worlhleas by
aoee af the aaeeoptleaa contained la tba 'Llaltatlen af tba Aaalya«a*
tailut. Sine* the aaJvrHy af tba raCereaeed lllerctare aaanaed that
"Individuate all paaaaaa aatflclcnt aeelllty and raaeorrea la
rel«.cat*~( lb* a lady la readarad «•*!«•¦ da* I* tba taut that aoil
l>aa|-Iv'a h»I »rrlL/r«t«are»i raaldaa la tbair raal aetata holJInga,
• bleb ebvloaaly iclfe; In tai< praaeaca af facility 4lllngi t»oh a
landfill.
It; KMUkJi
Tba MUM i FBI It tatally I geared tba taped IN* |.r<.p>4eur|>»*«
of a daap la an overriding public perpaae whan atbar feaa1bla/coat
effective alternallvea eatst.
b. Incorrectly aaaaalng the alto la aarplaa "at ale-owned land*,
*lnc« tha Dapartaant af Corrections haa not aade neb a declaration.
c. nol lapleaentlng Ibe directive lacladed la E0191 which
aandates hla office ta coerdlaate agrlcalteral aanageaeal of tba
proposed alto In Ilea of being the praponent for It'a deal reel Ion.
V. Racoaaaonded Mitigation Met*urea
Table 9.1-1 was.ealtted froa Ibe FIIS. Haa tha emitted portion
of the docoaenl been aaal la all the orlglaal recelpleataf llaa tba
cement period boon eatended aa a reaall af Ibla oalitlanT
Sincerely,
Tollii I*. IliLn
• 91 Winter St.
•rali>ola, MA 0S09I
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34
C.
January 30. 1990 *
No. Julie Belaga
Nr. Paul Raoogh
Bnvlronaenta! Protection Agency
Region,I
JFK Federal nulldlng
Boston. HA. 02203
Dear Ms. ftelngn and /or Mr. Reough.
RE: Pino) Supplemental Fnvlronaental lapact Stateaent - Novnlmr, 1980
h«ar Nr. Reough:
I m anbalttlng this Iftlnr io comment on tb« PSEIS dated November, 1089.
Page 2-1 Paragraph 2.2.2 "lap!leatlona": A reliable aethod of disposing
dried slmlga and dewatered •lodge, while previously not adequately addressed,
la now being hauled to the landfill In Nalpole. Because of the toxlna
associated In the alodge, the NNftA Is finable to aarket the fertilizer pellets.
The EPA fa allowing toxins to be placed In on unreallable landfill and must
consider this hazardous solid waste.
Page 2-3 Paragraph 2.3.1 "Description*: It Is stated that excess sludge or
unmarketed hent-drled pellets that are too toxic to be aarkotad Mill result In
reliance upon the Nalpole landfill. The quantity of each a lodge fa each that
the landfill nay reach capacity well before the alnlaoa 25 year period. Toxlna
which are asaocfated «rlth the alodge will be landfllled, and will create more
of a potential health haxnrd than previously disclosed by the NWRA and CPA
reports. It appsara, due to the nnnarketahlllty of "toxic pellets" that the
toxicity of the landfill will be significantly higher than previously reported
and therefore aore analysis needs to be done before a recoaaendatIon Is
rendered.
Page 2-0 Paragraph 2.5.1 "Natrr": The costs associated with Installing a
water storage facility off tha alternative of a direct hook up to the NNRA
Norwood aupply or water trucked to the landfill site have slgnflcantly
Increaaed the cost of the project. This significant Increase In costs should
necessitate altrrnotlve sites to be looked at because previous sites were
ellalnsted based strictly on econoaics. Under estlaatlon of costs by the NWRA
to landfill In Nalpole has prejudiced the decision to use Nalpole over otlier
sites, therefore the process of selecting Nalpole should he questioned nnd
re-examined.
Page 2-11 Paragraph 2.0.1.1 "Landfill Liner Systea": The KPA should Include
In Its reports* findings for other Isndfllla where t' thick clay liners are
used. National statistics should provide enough fnforaaflon so that the
general public, local coaaunlty as well as shutters csn aske proper risk
•saeasaents. There tn enough Information supplied to local realdents of
Norfolk and Nnlpole by technical experts that contradicts the assumption that
this landfill will not leak. Therefore, the FPA should provide national
statistics regarding all lundfllls using slallnr technologic*
) lili
#
34
Page 2-11 Paragraph 2.0.1.2 "Leachate Collection Systea":. "The operation of
the collection systea will serve to "alnlalxe the potential" for
contaalnatIon." The words "alnlalxe tho potential" Is too vague and
nondescript for the non-lsyaen to aske critical decisions. The objective of
any parent Is to ellalnate the risks for their children. To "alnlalxe the
risk" Is not enough so that I. as an abutter, can aake the critical declalon as
to whether or not I should aove ay residence froa this proximity; I need aore
statistics, f need to aake a risk aasessaent. I need to have aore Information
than Is currently being collected and dlssealnated. I would like to have the
authority to eipreas the probability of risk for s potential contaalnatIoii on a
scale of n to 100%. Words such as "under noraal operating conditions" Is too
broad of an assumption. What If we have an earthquake? Nhat If we have
torrentl.il, abnormal dowopours for nn extended period of tlae?. What If the
leaks go undetected? The last sentence of this paragraph Is way too vague. For
the PPA to recommend In such loose language that samplings and testings "should
be required" or monitoring programs*should be*estsblIshed or a collection
systea "should be designed" shows a very weak position hy the KPA. The word
"should" must be substituted with "shall be required." This paragraph also
t elite about a aec.ondtirt systea to serve as a leak detection systea to collect
leschate until s leok Is found and repaired. The NWRA and EPA should provide
Infaraatlon regarding the cost nnd tlae Involved to find nnd repair much a
leak. The proxlalty of thla site to drinking wells, 2000 of the aost hostile
prisoners, water aquifers and wetlands will necessitate the NWRA to act quickly
to aftfgate any probleas associated with a leak. Therefore, the coapetency of
the NWRA should be highly questioned. Coapetency should be aeasured by past
experiences and the NWRA's ability to solve probleas and funding sources to
flnsnclally solve those probleas.
Page 2-11 Paragraph 2.8.1.3 "Runoff Control Systea": "The existing runoff
pattern will be aalntalned "wherever poaalbla"...*» "etora water "aay be"
routed Into retention basins...". Language such as "wherever possible" and
"aaybe" are way to vague for an abutter to aasess risk. These aust bo
required.
Page 2*10 Paragraph 2.3.2 "Sewer": The saae rationale used for "costs" fur
Paragraph 2.9.1 should be used. The cost of developing a sewerage systea froa
the site to a aunlclpal hookup should be analysed snd scrutinized. Since
leachate will be tojrfc, there should be aore discussions regarding the quality
of leachiite snd Its lapuct on the sewerage systea. Discussions regardlog
trucking of waste water does not address the problem of trucking leachate. If
the sewer systea for Nalpole Is unsuitable, then trucking of leachate will
becoae expensive. Nhst would be the cost and impact of additional trucks?
Page 2-10 Paragraph 2-fi.l "Landfill Design": Figure Z.fi.l "Schematic of Cap
and Mner Systems" should contain the quantity of residuals. Without such
information, an abutter cannot assess the Impart of this mountain of sludge.
Pnge 3-3 Paragraph 3.2.2.1 "Primary Digested Sludge": Very little literature
has been published on the fate of organic compounds on municipal sludge. Nhat
la the risk sssoclated with this and why should a permit be given If little
literature exists?
Page 3-3 Paragraph 3 2.2.2 "Treatment Plant": The F.PA here admits the
marketing of heat dried pellets will necessitate bringing toxic pellets to this
landfill. Nhat Is the risk associated with bringing higher toxicity tn a
landfill than previously reported?
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34
race 3-9 Paragraph 3.3 "Ormmd Mar Bvalaatloa'i In tka rtperl yon «uu
It I* enllkely that both tto llacr m) leachata nonltarlag ifalMi *111 rail.
Mat la the probability o» a aeala af Min aa that abottero eea aafce a proper
rich aaaaaaaaat. Thl« paragraph dlecueaad coataalnated water reaching the
prlaoa water (apply. In aubparagraph 1, pan talk about the Icachata plaae
raacbaa tba Stop River. Ifeoch a plaaa la detected, how "III thle ba HmJ»
The report talk* about 'tbla generally la mllkalp.* M abalter ahould have
¦ore laforaatloa and (pacific probability eapreeeed. Tbla raport la taj vague.
Tha patent I al effects of a landrill laafe aa tba prlvata walla were aot
adequately evaluated In tlx Orefl JKIS. Ineurflclent date -|« provided* In
tlit* EPA report.
Page 3-8 pni-ngranh 3.3.2 -Groundwater quality lapact*': The report predict*
that even la a woret caae eceaerlo af a 80* leak aver 10 yaara. tba pollot Ion
concentration <(111 ba below Raeaachaaette groendvater criteria. Became ay
children play In tha Stop River, eat flab from the stop River and cinoo la the
Stop River. tha atnteaeat "aa adveree gfreeto are predicted* la tsfl vegoe for
an abnttar to aake a rlak aaeeaaeent. Tba tine required to reach peak
contamination at tha private welle would be approalaataly 300 yeara? I do not
onderatand how the EPA could go on to aay there weald be no adverae effecte on
welle. IV cowpntrr noriellng nneuaptlona aaed to arrive at 100 yeare la «
Inadequate. fSiM h»/Ktl "" '"¦* » & ***** <»»'«»»/ ***¦ ft'-' •* /¦»'•'"'** ¦
Pain 3-8 Paragraph 3.4.1 *HI«h Plow Coadltlonn*: The eanclualon that the
flow la 8000 tlaaa the potential leachata do*, therefore oilI have no adveree
water quality lupacta la baaed an Inadequate data. Tba couteelnaata that ara
already la the Blear ahautd be aaaeatad. Contaalnatloa buildup ovar and above
the eclating contaalnatloa caald effect water quality ataadarda. Background
eaacentratlene af aetata, heeauee they ara onknowa and therefore, cannot be
predicted far water quality, la a algntfleant rlak to an abetter of tha Stop
•Ivor. Hhatever leacbate eontrlbutea daring drought per lode to the Diver
coopered with tboae pollatainta already concentrated In the River alt I eaceed
etendarda. I will teetlfy that flab caneuaptlon bp ay children ealata. I have
aleo oboarved that thera la aa *etbnle* really that tlahee tha River froa Hay
through October and rellae upon the pea-fry flab tor their aajor food anpply.
The long tarn erfeete doe to the flnh eonaaaptlon atmuld be eonaldered. not
only due to leocbate contaalaetlon hat to potlatanta that ailet In tha Mver
prior ta the leechete buildup, tn your etntenenl. "In auaaary. poteatlal
contealaatlen of the Stop River In the event of an undetected, unrenltted
landfill leeh le not eepected to be algnlfleant.* tha aord 'algnlfleant* la
too vague. It atiauld be eapreaaed In tern at probability. O-IOOt. In abutar
nnedo to anlte laportant declalena about the rlahe.
Page 3-11 Paragraph 3.0 'Oenerel Property Vnlueo*: Bullehltl * grit end
ocremlaR*'emergency"elodge landrill doae aot adnqaataly deacrlbe tbla « acre
pile af teal**. Plret of all. the toaleltV and baaardaaaaeia af *grlt and
acreealnge* tiaa been totoily and Inadequately deecrlbed and evalaated. Tbla la
aot an energency alodge landfill. Orlt and acreeolnga will contola anything
that la acreeoed out at the beedworke. Tbla Ineludee aaythlng yoar laaglnatlon
caa think of la a woret caee aceaarlo. People will throw dean a eewor grot* on
tba aide or tba roed anything and everything thnt will fit. Including bat aot
Halted to. oil froa changing their eaglaa ell. dirty drag needlee. cheelralt.
eto. Orlt aad acreenlnge todcity aaalyale bae been totelly Inadeqonte In all
tbo report*. Tbla lo not an "eaergency* alodge landrill. It I* kaewa that
tbla landfill will ba need to duap toale pellete. Ny hone vaa eaaeeaed la
October, 1*88 for *200,000 by e promotional appralaer. A* t atand tn ay /
uK
34
front itcn end look •eron thm several hmdrH icret of Mettimf*. field*.
weoda and tba Stop Hlver tkit foraa (no bawtdarlee of ay property. I anvlalon
tha IT^acraa of built op face* and tha lapact It *111 have on tha value of tf
boae. 'Knowing'ft la there vtriaa'kaovlit'U la not there will have «u effect
w the property value. knowing that rlak poteatlal eclat* will have an lapoct
on property valuta. The lapact aaaoetetad with track* during e«eh phone of
eell construction will lapact tha value of the property. Although aupply and
deaend ecoeoelce certainly lapact property valuee. ao tfoce the psychology of
buyer*. The value of a residence 1* ha*ed on «hat a buyer 1* willing to pay
for It. A buyer looking et uy tieee. knowing he >h***protect«d property'abuttlng
It will pay eore than n b«y«r who kntiM e to«le landfill esl*t* or potentially
eailete. your annlyela and tahl« of outlior* 1* totally Irrelevant and outdated
to year noelyala.
P*ge 5-1 Paragraph ft.1.1 "Oronndwnter and Warfare Muter - ttnlpole": Your
eteteeeut that both landfill liner* and leachata collection ayateua would fell
I* "highly unlikely" la too vague. A definition of "highly unlikely* need* to
be eetebllshed. I euggeat uelng * ««*le frou O-toot aa an eapreaalon of
probability. Resident* ao
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34
l'H|f r> 0 Paragraph 5.2.4 "Navigable Nntrri Act": "Minimi/lug the potential
for » discharge" Is too vague. The Act was enacted to prohibit and eliminate
discharges. Your dlsctisslnn strictly talks about residuals materials, It does
not talk about grit and screenings. The regulations regarding hazardous and
solid wast* landfills have been bypassed because this Is nol considered
hazardous or solid waste. Toxic pellets and grit and screenings contain high
levels of hazardous Materials. The clever aanlpulatJon'by the NWRA to avoid
provisions of stringent envlronacnt.il protection laws has resulted In a
potential Imnan health and environmental condition. Policies, Including ante
stringent regnlat Ions for landfills under Massachusetts law*, have cleverly
been surpressed In committees by politics.
I*agr !i -12 Paragraph 5.4. I "Areas of Impact and Air Quality and Odors": A one
kilometer radius as an area for potential air quality nnd odor Impacts for the
landfill Is hot conservative. Within 1 1/2 miles of this side Is the renter of
Norfolk. When adding In the prison population of the most hardened criminals
In the state which are within 500 yards of this landfill, air quality Is a
significant Issue. Airborne diseases and viruses mist be analyzed. A simple
watering down of dust In the summertime or adding a A" cap In the wintertime Is*
Inadequate. The protocols used to define air quality is Inadequate.
Page 5 15 Paragraph 5.4.5 "Odors": The report states "no Information was
available os n basis of predicting od»r lapact froa disposing of wastewater
residuals other than qualitatively." What Information exists about the air
quality of duaplng 230 tons of dried pellets per day In landfllla. What Is the
Information for dumping tons of untreated grit and screenlags In landfills?
The CPA haa aade assumptions that hy keeping the landfill covered dally, will
aake the odor lapacts acceptable. The last sentence of the paragraph that
states the odor lapacts "could potentially be significant" aust be expanded
upon and analyzed In aorc depth. % a«c n*U tAtaJrs a
Wmij 1
Page 5-15 Paragraph 5.5.1 "Minor Residuals": Inadequate analysis has been
conducted nnd reported on grit and screening*, therefore, how can the EPA wake
o atntenant that this landfill will not contain medical or radioactive
materials. Anything that can be flushed down a toilet or that will not pass
through bar racka will be In the grit and acreenlnga and put Into the landfill.
The EPA ahoold conduct VOC analysis and In addition, should analyze the other
lapacts of hazardous and toxic leachate nnd air borne pollutants.
Page 5-IT Paragraph 5.5.2 "Sludge Characteristics": Your statement "the NWRA
will have to conduct toxicity analysis on Ita coablned prlaary and secondary
aludge prior to landfllllng" haa ae totally concerned. Why this atateaent
exists at this point In the approval process concerns me. This sort of
analysis should have been done long before any approvals and permitting
granted.
-5
34
Page !» 1*1 Paragntph 5. t» I "Toxicity": The KI'A nmr I us I on I •»;* * the Impacts on
groundwater or surface witter from the landfill and. therefor*. Impacts on
ptihllc health are^not significant'Is too vague. What Is "significant"? I nm
not a technician; I am not an engineer; I am not a .lawyer. My sole source of
Information Is from your reports. The lack of Information has me concerned.
There Is enough conflicting Information produced hy the local residents here In
Norfolk til*! makes me question the credibility of the NWRA nnd F.PA reports. I
ae simply a father trying to protect his children for the future. The
conflicting reports have created Indecision on my part. The organises
discussed In this paragraph and the potential for public exposure scares i lie
he 11 out of me.
Page 5 22 Paragraph T» 7.1 "Wetlands": The whole valley whiih I rait the Slop
River Valley Is one huge ecological system. The. four prisons combined with the
Wrentham Slate School have contributed to the pollution of the Stop Rlv*r
Valley for decades. The Stop River Valley Is already a dumping ground. Not
only Is it a dumping ground of hard core criminals. It is a dumping ground fro*
tlie byproducts of prisons. The prisons are dumping effluent Into fhe Stop
River, jjnjler (an existing approved EPA permit, the prisons* sewerage treatment
fac 11 I ty^uii^'exceeded the maximum standards froa time to time. The current
sludge dump maintained hy the prison colonies Is on the verge of violating the
environment The fuel used hy the prison generators create a fog In the Valley
on certain «lays and add "acid rain" to the Valley. The whole Valley, as a
result of l he prison colony. Is one huge ecolojlc.il system on the verge. Hy
adding this toxic waste landfill It will be the "straw thai breaks the camel's
back . "
Page 6 (i Paragraph 6.4.2.2 "Groundwater Monitoring": How long will
groundwater monitoring exist? One thousand years? What will happen to the
landfill In the future and what Impact will It have? What are the EPA national
statistics on monltor log rellabl11ty? How many superfund priority sites hail
monitoring systems?
Page 6-8 Paragraph 6.4.2.2 "Surface Water Monitoring": Surface water
monitoring requirements should be demanded by the F.PA Instead of the statement
they "should occur."
Page 6-8 Paragraph 6.4.2.3 "Contingency Plans": A detailed contingency plan
should be prepared prior to permitting": The EPA requirement to hove a plan
prior to construction Is Inadequate and destined to fall down the road
Design features and monitoring plans which will he required to prevent
contaalaatIon and discussions of remedial action should he detailed prior to
peralttIng.
Jittaaary) As a resident abutter to the landfill site, I hav« tried to read and
absorb all the Information generated by the Citizen Action Committee and the
MWRA/EPA reports. I am aot a technical person. Understao«lIng the technical
dnta Is difficult. 1 folly understand the need to clean up Boston Harbor. I
fully uoderstand the need t«> landfill. The need to put It In this particular
site 1 do not understand. Economically there are other a 11ernat. Ivea.
Environmentally there are other alternatives. Rerhaps politically there were
none.
6
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I huiiM like to statu for the record that ayaftlf, ay wife unci ay children are
under deep psychological itr«n because of this siting. II la storting to cause
physical heitlth problems. Tha*fears*osaoclated with the potentlsl risks nre
ooaetlaea overwttelaliig. The tlae used to study this prohlea Is exhausting.
The MtfRA ha* brought snaethlng Into our lives wr did not need. The worrying
about whether the River that borders our property will becoaa aore |»olluted mid
not usable Is bnrdensoac. The worry about the exposure to toxins, cantaalnants
and the resulting health hazards Is hordensoae. Worry about the construction
equipment noise, the nuaber of trucks being used Is burdensoae. The worry
about the whole Valley odors,which already exceed tolerance It* (lie drod of
aoaaei^ Is very burdensoae. The joys of the wildlife and the concern thiii 11
any lie reduced or ellalnated Is worrlsoae. The Indecision on whether to aov«?
our hoae or to stay and tougli It out Is bunlensnae.
The MWRA has been plowing nhend without listening to ay concerns. I would like
to sulialt n letter written to Mr. Paul Levy duted 4/6/89 as an exhibit to thin
letter, which has never been answered. I hope that the EPA has enough aoney and
wlsdoa to forsee the potential prohlcas associated with this landfill site. It
Is easy to aake It a black or white Issue la regards to whether or not the KWRA
Is In coapllance with regulation*. 1 look to the CPA to look boyond the
regulations. I look to the CPA to provide substantially wore data than wh.it
haa been supplied. The CPA, whose salaries are paid by ay tax dollars should
be required to present reports In layaan'a language that will help the leyaan
to aake rlak asaessaents. I aa o risk asaesaor. I aa an educated aaa. I
slaply have a lack of lnforw.itIon the CPA should not aake a decision to allow
the MWRA peralt until all of the conflicting reports and findings have been
i). S. yUa*<> '»c "If /A""yt
addressed.
Robert C. Howard
/jyS Jsaiw-yO • //lc-U aw -to+*'C
-------
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36
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February 6, 1990
P¥ HAND
Ms. Ann Rodney
U.S. Environmental Protection Agency
Reg i on 1
HEP 1900C
J.F.R. Federal Building
Boston, HA 02203
Re: Comments of the Town of Halpole to the Final Supplemental
Environmental Impact Statement - Long-Term Residuals
Management for Hetropolltan Boston ;
Dear Ms. Rodney:
Please consider the following comments of the Town of
Halpole to the above-referenced Final Supplemental Environmental
Impact Statement ("FSEIS").
On November 13, 1989, the Town of Halpole submitted
detailed comments to the Massachusetts Executive office of
Environmental Affairs. These comments concerned the Final
Environmental Impact Report {"FEIR") prepared by the
Massachusetts Hater Resources Authority for the Residuals
Management Facilities Plan. I as enclosing a copy of the Town's
November 13, 1989 comments and request that they bo incorporated
by reference Into these comments on the FSEIS.
The Town's comments are organized according to the paragraph
numbers contained in the FSEIS.
2.1.1. The analysis of landfill capacity .it the Halpole-
MCI site does not adeguately consider a number of regulatory and
other factors which will eventually dictate a substantial
reduction in the available footprint of the proposed landfill.
The Town's comments to the FEIR demonstrate that the landfill
KOPtlMAN ano Paige. P. C.
Ms. Ann Rodney
U.S. Environmental Protection Agency ^^
February 6, 1990 JQ
Page 2
capacity at the Halpole MCI site in fact will not be more than
2.375 Mcy. As a consequence, the site has a total volume
capacity of approximately .795 Mcy less than the minimum amount
required by the EPA. This reduction is due primarily to the fact
that the Commonwealth of Massachusetts solid waste siting statute
and regulations apply to this site. The EPA should be aware that
the Town of Halpole has already instituted litigation seekinq
declaratory and injunctive relief against the Secretary of
Environmental Affairs, the Department of Environmental Protection
anrl the Massachusetts Hater Resources Authority. The complaint,
which was filed on January 10, 1989 in Superior Court in Norfolk
County senks a declaratory Judgment from the Court th.it the
siting of the minor residuals landfill is (subject to G.I.. c.lll.
flSOA .ind )50ki and 310 CMR 16.00 {t seg. If the Superior court
agrees with the Town's contention, the Walpole-HCI site will he
inadequate to handle the minimum volume of residuals require*) by
the EPA.
2.4 The FSEIS is inadequate because it fails to take
into consideration the substandard nature of the access route,
and the alternate truck route which the MHRA proposes to utilize
to gain access to the Halpole-MCI site. Given the narrow and
winding nature of the secondary roads, the EPA has failed to
adequately address the safety concerns regarding the use of these
streets by heavy truck traffic.
2.5.1 The EPA, In assuming that the MWRA could connect
to the Town of Halpole's municipal water system at the
intersection of Hlnter Street and Route 1A is incorrect. The
existing water system in this part of the Town does not have
sufficient pressure or capacity to accommodate a connection by
the MHRA. Therefore, the EPA should analyze the existing system
and determine the necessary improvements and expansion capacity
that would be required before the Town of Halpole would consider
allowing the MHRA to connect to the Town's water supply system.
In addition, the construction of a dedicated water line from an
MHRA community would result in substantial adverse environmental
impacts through the Town of Halpole. No analysis of these
impacts have been conducted by EPA.
2.5.2 Again, the EPA has failed to assess the
environmental impacts associated with the construction of an
additional 9,000 feet of forced main from the end of the existing
sewer system on Route 1A to the proposed r.Ite. In addition, the
EPA has failed to analyze whether the existing sewer has
sufficient capacity to handle the anticipated leachate from the
landfill. In fact, the Halpole Town Engineer has concluded that
-------
Robert C. Howard. Jr.
26 Main Strict
Norfolk. MA 02056
(617) S2A6692
January 19. 1990
Ms. J«ill i* Br hit*
EPA Regional Administrator
II.S Environmental Protection Agency
JFK MersI Building
tins ion. MA 02203
•fi
M
L
Rll: Final SMS Coaaent Period ending February 6. I*i!ll): l.on{»teia
Residuals Management for Metropolitan Boston
Dear Ms. HtrliiRii:
I consider myaelf an "abutter" to the proposed sludge landfill
site InWalpole. Massachusetts. I aa not an engineer or technical
person. I have, however, read every alngle word that was published In
the Finn! Supplemental Environmental lapact Stateaent. November, 19*9.
All hough | sal 11 not pretend to confront thla report frna a technical
point of view, 1 would like to hnve ay letter Included In your fln.il
recommendatIon for the Record of Declson.
For the record. I would like to submit a copy of ay letter to Nt
r.itil l.irvy »l the WWW A dated January 30. I9R9 (marked Exhibit A|. As .i
nontechnical layaan who la an "abutter" to thla alte. I would like to
have the EPA reapond to ae per noon I ly for those questions addressed In
Mr. I.evy In language tli.it I con understand.. My background Includes a
Masters Degree In Business. f na founder and Prealdent of a business
brokerage flra and I hnve held posltlona as a Vice-President of State
Street Bank A Trust Co. and Director of Finance for Prlae Computer.
Inc. As a businessman, my language Includes probabilities of risk
expressed ms percentages. On a scale of 0-100*. what Is the
probability of there being a health hoiard to ay children mtd what .ire
the other probabilities aa asked In the January 30th letter to Mr.
tevy?
I ua very concerned about the competency of the MWKA. Their
bureaucracy has created enough algnlflcant errors In their engineering
studies to bring concern. The political hat of the MWRA casts doubts
upon their fiscal funding resources to mitigate potential probleas
created at thla landfill site. For the record. I would like to submit
a letter (aarked Exhibit B) addressed to Nr. William Moore of
Merrllll.ynch dated Oeceaber 9, 19B9. Thla letter contains examples
of the MNRA'a political nature and the Incoapetency due to their
bureaucracy .
^^Uso
pnli^^^k i
slapT^itsk
lenk lit
enclose, as nii exaaple of why I aa so fearful, n cartoon
recently In the Boston f»lohe (aarked Exhibit C). As an
this landfill site, seeing this cartoon Just a few week*
lo signify thi' MWRA'* lark of responsiveness nipiilillMy. I
till* (|iiest loll, "II It will t ake the MWMA nii lout* to fix a
main arpiaduet in Ft aa i ni'h.tm . Imw I «• n ^ will it »*!<«• M..m ~..
I'a»je <•
Ms. Jul le llel.iga
January 21. 15)90
I would like to see the EPA address the concerns outlined by Mr.
Sanjour'a and Mr. Kaufaan'a letter (which I hereby subalt aarked
Exhibit 0) to the EPA doted July 12. I9BB, ua contained In the Pinal
SETS. They, as part of the EPA. have basically said that this landfill
will leakl When a cell the size of Sullivan Football Stadlua with a
mounded cap on It starts to leak, how Is this going to be qult.kly
repaired at a cost within the scope of the MWRA? It appears these two
gentleaen, who have over a decade of experience In landfills and h;ive
given expert testlaony In Congress, have raised significant enough
doubts to keep the regional EPA froa aovlng forward so quickly. Their
letter seeps to Ite In direct conflict with your approv.il. Again, us a
layman, this aukes ae afraid Who's right? I would like to hear the
EPA Issue the stateaent of probability that I have requested nhove
based upon national landfill data. I aa sure the KPA. on a national
level, has a treaendous aaount of data for double -1Iner landfills
What lias been the historical performance been?
If the whole concept of getting rid of Boston's sludge Is too
toxic to Incinerate, too toxic to a«01 aa fertilizing pellets, and too
toxic to duap Into the ocean, then why 1a It safe to landfill It In
Walpole that Is abutting a river, abutting a sole-source acquifer.
abutting wetlands, abutting 4.000 of the moat hardened criminals In
Massachusetts and abutting four drinking water wells?
It oppears that the Boston District CPA's Office's mission is
slaply to assure that the MWRA Is In coapllance with Federal roles,
regulatlone, codes and laws. I have no doubt that the MWRA has
cleverly coaplled. My hopes, however, are that the EPA will look
beyond the scope of such rules and regulations and look at the
aagnltude of what this toxic landfill could potentially create EPA
should keep In mind that this la no small project. This la a SO I
billion clean-up. This Is 4? arrea of fecea plied tons upon tons Into
the air and below ground. This scenerlo Is very frightening to
soarone who looks at his hoae as his castle, where his young children
literally play In and around the Stop River which abuts thla site.
What will happen to this site 350 yeara from now or 2.000 years from
now? Who will maintain this site when the ratepayers revolt and
cannot pay anymore? There are aany aore forward-thinking questions
beyond slaply the current code compliance.
Although my letter is aore emotional than techniral and my issues
are based aore on fear of the unknown than disputed engineering data, .
ay questions deserve to be answered. I expect the KPA to answer not
only the questions corn -lined In this letter, but those quest ions
contained In ay January 30, IM!) letter to Nr. Levy ns well. An.l
again. I request a response In language that addresses my sp<< lfl«
fears, with expressed prnhahl111les of risk, as opposed to vague,
nondesrrlpt and non-coalttal generalities.
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kopciman ano Paige. P. C.
Ms. Ann Rodney
U.S. Environmental Protection Agency
February 6, 1990
Page 3
sufficient capacity does not exist. SS9 Appendix "1" to these
comments. At a minimum, an extension of the sewer system would
result in a substantial increase In the cost of this project, and
it would have a dramatic effect on the development potential of
the Route 1A corridor. If the MWRA does extend'the Town's sower
system, an analysis must be conducted of the likely environmental
and socio-economic impacts that such a sower system expansion
would have on the Town.
An an alternative, the EPA states that the MWRA could
construct a water storage tank and a wastewater storage tank on
the site. The water and wastewater would then be trucked to and
from the site, thereby resulting in an significant increase in
the amount of truck traffic associated with the landfill.
However, the FSEIS fails to analyze the transportation impacts
associated with this increase in truck traffic. This is
especially significant in light of the fact that the proposed
access routes to the site are admittedly substandard.
3.2 The Town of Walpole is extremely concerned with
the lack of information concerning the hazardous materials
content of the residuals to be disposed of at the Walpole-MCI
site. The FSEIS is replete with references to the fact that
there is little or no estimates as to the concentration of
certain types of hazardous materials that can be expected to be
found in the sludge. This lack of information has resulted in
Inadequate analysis of the potential harmful effects of leachate
and groundwater contamination.
3.3 As the conments of the Town to the FEIR
demonstrate, the MWRA's analysis of the likely groundwater
impacts of the proposed landfill are wholly Inadequate. The
failure of the MWRA to collect sufficient field data regarding
the hydrogeoloqical conditions at the site have rendered any
conclusions regarding water impacts unreliable. The FSEIS does
little to fill in the data gaps which currently exist..
Therefore, as a general proposition, the Town submits that the
conclusions of the EPA with regard to groundwater impacts are
Inadequate due to the fact that insufficient field data has been
collected. The Town is submitting under separate cover
additional comments from the firm of R.W. Gillespie t Associates
regarding groundwater impacts.
3.6 As stated in the Town's comments to the DSEIS, the
EPA has failed to conduct an adequate analysis of the socio-
economic impacts associated with the landfill proposal. The
kopelman ano Paige. P. C
Hs. Ann Rodney
U.S. Environmental Protection Agency
February 6, 1990
Page 4
Town is extremely concerned with the dimunition in value of
private property since this will have a serious adverse effect on
the residents of the Town of Walpole. The Town Is also concerned
with the fact that any such diminution of property values will
have a direct and corresponding adverse effect on the tax base of
the Town. In fact, the Walpole Tax Assessor has already heen
inundated with over 724 requests for real estate tax abatements.
See Appendix "2". As a consequence, the Town stands to lose a
substantial amount of tax revenues. Since property tax receipts
are the primary source of income to the Town, r.uch a decrease
would have a devastating effect on the ability of the Town to
provide basic services. As Paragraph 3.6.1.2 of the FSEIS
acknowledges, one study in Hew York concluded that the siting of
a landfill in a particular community resulted in an 8.7 percent
decrease In the value of housing In that community. Given the
fact that the total valuation of all property in the Town of
Walpole is $1.6 billion, even an 8.7 percent decrease in value
would translate to a total loss in value of over 5139 million.
Obviously, such a substantial loss In value would have a
devastating effect on the residents, and would severly reduce
available tax tevenues to the Town.
Although the FSEIS acknowledges that some diminution in laml
values will occur, there has been absolutely no quantitative
analysis of the likely impact on the Town's tax base and its
corresponding ability to raise revenue to provide basic munlcip.il
services. The FSEIS, therefore, is wholly inadequate in
analyzing this very real adverse impact to the Town.
5.1.1 The FSEIS states that the EPA supports the
conclusion that the landfill footprint lies outside of the Zone
II and Neponset Sole Source Aquifer boundaries. This conclusion
has been made by the EPA without any independent analysis of the
qroundwater divide. The EPA has also failed to oven acknowledge
the detailed analysis and additional field work performed by the
Towns of Walpole and Norfolk in connection with the groundwater
issues. Consultants for the Town of Walpole have been workinq
closely with representatives of the qroundwatrr division of the
EPA concerning the sole source aquifer issue. The enclosed
comments of the Town of Walpole to the FEIR contain a detailed
discussion of the additional field work performed by the Town
which supports a findinq that some portion of the proposed
landfill footprint lies within the sole source aquifer. The kpa
requested that the Town perform some additional field work to
verify these findings prior to the submission of a petition for
-------
Kopclman and Paigc. P. C.
Ms. Ann Rodney
U.S. Environmental Protection Agency
February 6, 1990 «jO
Page 5
in Appendix "3". The additional field work and analysis strongly
supports the sane conclusion; I.e., that some portion of the
footprint of the landfill lies within the recharge area of the
sole source aquifer. Although the Town is In the process of
submitting these results to the EPA in the form of a petition for
a redesignation of the sole source aquifer boundary, the EPA must
conduct its own more detailed analysis of the sole source aquifer
delineation in order to comply with the requirements of the
National Environmental Policy Act.
As the comments to the FEIR demonstrate, the Massachusetts
solid waste siting regulations prohibit the siting of a landfill
within the recharge area of a sole source aquifer except under
certain limited circumstances none of which apply in this case.
Therefore, the EPA should understand fully that the sole source
aquifer issue presents a significant state regulatory problem in
connection with the siting of this landfill. Given the landfill
capacity agreement executed between the MWRA and the EPA, it is
expected that the elimination of the seven acres within the sole
source aquifer boundary will result in a substantial reduction in
the available capacity for the landfill. This reduction will
mean that the landfill site cannot meet the minimum landfill
capacity being require.! by EPA.
5.2.1 As the Town's comments to the DSEFS
demonstrates, the EPA has failed to consider an adequate number
of alternative landfill sites. Since the publication of the
DSEIS, the EPA has done nothlnq to expand the ranqe of
alternatives to be considered. Consequently, the FSEIS is
inadequate under CKQ Guidelines.
The Town disagrees with the conclusion of the EPA that the
no action alternative for this project is discontinuation of the
short term residuals management program after 1995. The EPA
concludes that consideration of the no action alternative would
lead to a resumption of sludqe discharge into Boston Harbor. The
Town disagrees with this characterization of the no action
alternative. In fact, the no action alternative would be to
continue the private disposal of residuals and sludge at
Commercial landfills. Although the EPA states that the private
disposal would jeopardize HMRA's ability to ensure the legal,
environmentally sound disposal of Its sewer sludqe, the EPA fails
to adequately explain why this is the case. Given the fact that
the EPA acknowledges that siting of new commercial landfills is
extremely difficult, a much more detailed analysis of the
commercial landfill option should have been performed by the EPA.
The failure to do so renders the FSEIS inadequate.
Kopclman amo Paige. P. C
Ms. Ann Rodney
U.S. Environmental Protection Agency
February 6, 1990 liT
Page 6 Jv
5.2.2 The EPA has acknowledged that it was proper
for the Secretary of Environmental Affairs to limit consideration
of the criteria of equitable distribution of regional
responsibilities "to highlight the distribution of regional
responsibility specifically with reqard to permanent long-term
wastewater facilities." Throughout the residuals siting process
the Town of Walpole has maintained that the only rational
application of this criteria would be to consider all facilities
which have an adverse impact on a community. Clearly, the
location of four prisons, including the state's maximum security
prison, in the Towns of Norfolk and Walpole adjacent to the
proposed landfill site should have been considered when
evaluating this criteria with regard to the Walpole site. The
failure to do so renders the entire environmental review process
for this project fatally flawed.
5.5.1 The Town of Walpole's comments to the HEIR,
the FEIR, and the DSEIS state that the MWRA, the Secretary of
Environmental Affairs, and the EPA have incorrectly Interpreted
G.L. c.lll, I150A and 310 CHR 16.00 as applying only to solid
waste facilities. As previously mentioned, the Town of Walpole
has instituted litigation seeking a declaratory judgment
challenging this erroneous interpretation of state law and PEP
regulations. This is especially important given the
acknowledgment by the EPA that solid waste disposal regulations
in the Federal sector do not distinguish between solid waste ami
wastewater residuals.
5.B The EPA Incorrectly concludes that the
location of the landfill on Department of Correction property
will not adversely effect the opportunity for Walpole to
participate In the prison expansion grant program. The hundred
acre site under consideration by the MWRA is an ideal site for a
new 500 bed prison. The Town of Walpole has offered to both the
Federal Bureau of Prisons and the State Department of Correction
to support the siting of such a new prison facility. Obviously,
if the MWRA acquires this property for the landfill, the Town of
Walpole will be foreclosed from participating in any further
prison expansion grants for that particular location.
5. IB All of the environmental, stiulies potloimt-il to
date have failed to consider the impacts of .this landfill on the
prison population at MCI Cedar Junction and the three other
prisons located in the vicinity. The fact that the MWRA is
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KOPILMAN AMD PAIGC. P. C
111
Ms. Ann Rodney
U.S. Bnvironaental Protection Agency
February (, 1990
Page 7
proposing to dispose of waste within 200 feet of the perlaeter
wail o( the prison raises serious concerns for the prison
population, especially In light of the fact that no long-tera
health effect studies or other analysis have been perforned
regarding the lapect that this nay have on the prison population.
In addition, as the Town of Halpoie has pointed on numerous
occasions, none of the environmental lapact studies have
considered the security probleae that My arise given the
volatile nature of the Inaate population.
Given the continuing unresolved questions regarding the
potential environaent lapacts associated with the landfill siting
ae well es the new inforaetlon regarding the locetion of the eole
source aquifer boundary, the Town of Walpole request that the CPA
prepare a suppleaent to the FSEIS pursuant to 40 C.F.R.
(1302.9(C).
ly yours.
JNG/na
enclosure
cc: Board of Selectaen
Maipole cltlsene Advisory Conalttee
John DeVlllars, Secretary of Bnvironaental Affairs
The Honorable Edward H. Kennedy
The Honorable John Kerry
The Honorable Barney Prank
The Honorable Francis Woodward
The Honorable Arthur Lewis
Daniel Greenbaua, Coaalssloner, DBF
Paul Levy, Executive Director, HWRA
Paul Keough, Regional Adalnletrator, EPA
Marilyn Morris, Adalnletrator, Town of Norfolk
Judith Kapuscinski, Esq.
Art Rrieger, Esq.
Michael S. Greco, Esq.
Daniel Fenno
Dean Slocua
John P. Jeaaek
Jaaes A. Pappas
Nnn » Ow OM •
37
Tilling ii ast Collins & Graham
ta *B1 Hi 111,
Mk »IM
r W HMW
h* m nf io*
February 6, 1990
Ma. Julie Belaga
Regional Director
Halted States Envlronaental Protection Agency
Region 1
JPI Federal Building
Boston, Massachusetts 02203
Ret United States Bnvlronaeetal Protection Agency's
Final Suppleaentat Bnvlroaaental lapact
Btateaent, Bovaaber, 1919, Long Tera Residuals
toc. HatxoBolltaiLlloaton
Dear Ms. Belaga:
On behalf of the Town of Norfolk ("Town*), the law flras of
Tllllnghast Collies t Orahsa of Providence, Rhode island, and
Andersen ( Krelger of Boston, Massachusetts, subalt the
following coaaents oe the United States Bnvironaental
Protection Agency's ("EPA*) Pinal Snppleaental Environmental
lapact Stateaent, Boveaber, 1919, Long Tera Residuals
Management for Metropolitan Boston (*FEIS").
The Town la disappointed that the SPA has accepted the
Massachusetts Mater Resources Authority's ("MMRA") selection of
the Malpole-NCI location as tha site for e residuals and aludge
landfill. This acceptance Is based, the Town contends, on the
CPA's Inadequate consideration of tha Town's concerns as
presented to the EPA In Its July, 19S9 coaments on the United
States Bnvironaental Protection Agency's Dreft Suppleaenta1
Bnvironaental lapact Stateaent, Nay, 19S9, Long Tera Reelduals
Manageaent for Metropolitan Boston ("DB1B Coaaenta*), and. as
therein Incorporated, the Issues raleed In the Town'a comments
-------
Ma. Julia Belsgs
Nbivilf 6, 1990
Page 2
37
on HNM'a draft Envlronaentsl Impact topoit C0BIB-),
collectively ittieM liklblt *i» and tk« Town's comments
on HWRA'e Final Environmental Impact Beport ("FBIR"), attached
aa Eshlblt »j. The Toon raises, therefor*, aach aod every
Issue rolsed In lt> DRIB Consents and DEM sndPEIR comment*,
attached hereto aa Exhibits *| and B| and incorported
herein.
The Town believes that tha EPA'a acceptance of the Walpole-MCI
site (alls to adequately protect the snvlronmant- and fosters
violation of federal and state statutes and regulations, in
addition to all srguaiants In opposition to HMU's selection of
tha Malpole-MCI sits presentsd In the sttsched Eihlblts Aj
snd Bj, the Town argues the following In support of Its
position.
I. The CPA's FEI8 Ignores modeling completed by the Town's
hydrogsological expert snd, therefore, erroneously concludss
thst the Isndftll site snd footprint sre not In s Zone II area
and the landfill will not threaten ths area groundwater.
II. Tha EPA's scceptsnce of tha Malpola-HCI site approves
conversion of prlM agricultural land to nonagrlcultural uaea
and, thereby, directly vlolatss tbs federsl Feraland Protection
Policy Act, 7 D.8.C. t 4201(b). The EPA gives no explanation
for Its totsl disregard for this federsl statute.
III. The EPA has fsiled to evaluate the resldusls snd sludge
Isndflll In light of Its propossd regolstlons on the disposal
of sswsgs sludge, M Fed. Beg. 5746, Fsbrosry C, 1909. In so
doing, the EPA fosters development of s project which may be In
vlolstlon of federal regulations from the moment It Is
operational.
IV. The EPA's failure to coament on the nnut's wholly
Inadequate public hesltb risk assessment, provided by the MHRA
for the first time In Its FEIR, neglects the Interrelationship
of environmental protection and public health.
V. The EPA's landfill capacity snslysls suffers the same
Inadequacies ss ths HMRA's snslysls. Neither sgenry has
considered carefully the Implications of s need to landfill
sludge or pellets for more than six months.
Based on the Information presented herein, l.h«- Town
respectfully requests thst you
a. reconalder and reverse your acceptance of the
37
Hs. Julie Belaga
Fsbrusry 6. 1990
Page 3
HWRA's selection of the Halpole-MCl location as a
site for s resldusls snd sludgs landfill!
b. Issue such further orders and findings as are
within your authority.
Respectfully submitted by the
Town of Norfolk
By its Attorneys,
ANDERSON t KREIGER TILLINGHAST COLLINS i GRAHAM
/y" r/- -f--
Stephen D. Anderson
Arthur P. Kreiger
33 Mount Vernon Btreet
Boston, MA 02108
(617) S23-1624
Christopher H., Little
Judith Kapuscinski
Christine H. Gravelle
One Old 6tone Square
Providence, RI 02903
(401) 456-1200
2348s
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P O BOX 03 NORFOLK. HA 82056 (508) 5285085
0 Feb. 1990 c»c6 erfnra> Its
envIronasnta I protection duties and deny HVRA une of the Malpole
site. Thank you.
Yours truly.
Larry Basslgnanl
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