FINAL
ENVIRONMENTAL IMPACT STATEMENT
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
PROPOSED WASTEWATER COLLECTION AND TREATMENT FACILITIES*
SCARBOROUGH, MAINE
PREPARED BY
ENVIRONMENTAL PROTECTION AGENCY
REGION I
BOSTON, MASSACHUSETTS
VOLUME II
:egional Administrator

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This Environmental Impact Statement (EIS) has been prepared
pursuant to P.L. 91-190, the National Environmental Policy Act
(NEPA) of 1969, and Executive Order 11514, "Protection and Enhance-
ment of Environmental Quality" dated March 5, 1970. Both NEPA
and Executive Order 11514 require that all Federal Agencies pre-
pare an EIS on such Federal actions, which significantly affect the
quality of the human environment.
This EIS has been prepared in accordance with the regula-
tions and guidance set forth in the President's Council on Environ-
mental Quality (CEQ) Guidelines dated August 1, 1973, and the U.S.
Environmental Protection Agency's (EPA) Final Regulations CFR
40-Part 6, dated April 14, 1975; both concerning the preparation
of Environmental Impact Statements.
Under the statutory authority of P.L. 92-500, the Federal
Water Pollution Control Act Amendments of 1972, the EPA is charged
with administering Federal financial assistance for the construction
of publicly-owned wastewater treatment facilities and their ap-
purtenances. In addition, the EPA will issue permits to municipal
governments to allow the discharge of treated wastewater effluent
into navigable waters in such a manner as to protect the health
and welfare of the public and the environment. P.L. 92-500 further
establishes a national goal of eliminating the discharge of pollu-
tants by 19 85, and wherever attainable, an interim water quality
goal by July 1, 19 83, which provides for the protection and propa-
gation of fish, shellfish, and wildlife, and provides for recreation
in and on the water.
For purposes of this Environmental Impact Statement, EPA, Region I,
Boston, Massachusetts is the "Responsible Federal Agency" as
required by the National Environmental Policy Act.
To insure that the public is kept fully informed regarding
this action, and that it participates to the fullest extent
possible in the Agency's decision-making process, this final EIS
is being circulated for a 30-day review as required by the CEQ,
August 1, 1973 Guidelines.
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The second volume of the Final EIS on Scarborough's pro-
posed wastewater treatment and collection facility contains
correspondence submitted to EPA during the public review and com-
ment period of the Draft and Supplemental Draft EIS.
The Draft Environmental Impact Statement was forwarded to
the Council on Environmental Quality in early January 1976.
EPA requested comments from local, State and Federal Agencies and
interested individuals. Due to the interest expressed in the
project, and the Draft EIS, EPA extended the comment period for
an additional 15 days.
The Draft EIS produced a significant number of responses.
As a result of the public comments, further analysis of major con-
troversial issues was undertaken. A second report entitled
"Supplement to the Draft EIS" was distributed for public comment
on October 1, 1976. Once again, EPA encouraged public response
and extended the comment period for a total of 60 days.
Comments on both documents were submitted in written form
and in oral presentation at the public hearing on January 29, 1976
and the public workshops on November 8 and 9, 1976. EPA received
comments from local officials, interested citizens and Federal
Agencies. The issues presented in these comments are displayed
in a matrix in Figures I and II of this report. EPA's response
to these issues are included in the section following the matrix.
The actual comments and transcript follow the chapters on EPA's
Response to Comments.
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TABLE OF CONTENTS
SECTION I
SECTION II
SECTION III
SECTION IV
SECTION V
EPA RESPONSE TO COMMENTS ON DRAFT EIS
PUBLIC COMMENTS ON THE DRAFT EIS
PUBLIC HEARING TRANSCRIPT - JANUARY 29, 1976
EPA RESPONSE TO COMMENTS ON SUPPLEMENTAL DRAFT EIS
PUBLIC COMMENTS ON SUPPLEMENTAL DRAFT EIS
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SECTION I
EPA's RESPONSE TO
COMMENTS ON THE DRAFT EIS
7

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This section contains EPA's response to comments submitted
on the Draft Environmental Impact Statement.
The following matrix, Figure I, identifies the major issues
addressed in the comments and refers to the individual, local,
state or Federal agency who submitted the comment.
A detailed response to the issue follows the matrix.
9

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SUMMARY OF COMMENTS PRESENTED
ON DRAFT EIS
ISSUES
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EPA Response to Comments
By Issue
1. ALTERNATIVES
One of the major issues presented by the commentors of the
Draft and Supplement Draft EIS was alternatives. Although the
Draft EIS evaluated 5 alternatives, several individuals were
concerned that certain alternatives were not considered by EPA.
The alternatives requiring further evaluation were:
. Small treatment plants to serve the areas under the
consent order
. The transfer of Scarborough's wastes to South Portland
and Old Orchard Beach
. Advanced waste treatment at Oak Hill
These alternatives were further evaluated and presented on the
Supplement to the Draft EIS. When it became apparent that sev-
eral of the above alternatives were neither cost effective or
environmentally acceptable, three possible solutions of all of
the alternatives evaluated were presented for local agencies and
citizens input. There were:
. Single plant at Prout's Neck with an Ocean discharge
. Full transfer of Scarborough's wastewater to South
Portland
. Expand the Oak Hill facility with advance waste treatment
Public response in writing and at the workshops favored the
South Portland alternative. In response to the Supplement to the
Draft EIS, the City of South Portland indicated that due to a
severe infiltration problem, there was no available capacity at
their treatment facility to adequately serve Scarborough's needs.
EPA and the Maine DEP have met with South Portland officials and
concur with the degree of the infiltration problem.
During one workshop in November, several citizens petitioned
EPA to evaluate a new alternative, should the South Portland option
become infeasible. This new alternative is evaluated in the Final
EIS and is recommended by EPA as the proposed action in which EPA
will participate in funding.
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At this point in the EIS process a total of nine possible
alternatives have been considered. Many are neither environ-
mentally sound nor cost effective. Chapter 3 of the final EIS
describes in detail the environmental and cost analysis of the
most viable alternatives.
Public response to the Supplement report both in writing
and at the workshops conducted by EPA, strongly favored the
South Portland alternative.
Subsequent to the release of the Supplement report, EPA
became aware as to the severity of the infiltration problem in
the South Portland sewer system. Due to the strong support for
Alternative F, EPA met with officials from the State Department
of Environmental Protection, the City of South Portland and the
Town of Scarborough. The purpose of these meetings was to de-
termine whether the infiltration problem in South Portland could
be corrected in order to provide adequate capacity at the South
Portland treatment plant for Scarborough.
Based upon the recommendations of the City of South Portland
and the review of the technical data available, EPA and the Maine
DEP do not consider this alternative to be technically feasible.
In response to the infiltration issue at South Portland,
several local organizations petitioned EPA to examine a new
alternative which consisted of building a new treatment plant at
Oak Hill and discharging the treated effluent to the Fore River.
EPA has evaluated this alternative utilizing the same ranking
criteria used in the Supplement Report. The following Table ranks
each of the alternatives, including Alternative "G" in terms of
acceptibility.
TABLE I
Ranking of the Alternative Systems"*"
in Terms of Acceptability (Most to Least)
Costs
2
Primary
Environmental
Effects
Secondary
Environmental
Effects
Public Admini s t ra t ive Political
Health	Feasibility	Opposition
Risk
F,G
A
C
C,G
F,G
A, C
A,C
G
C,F
A
A,C,F,G
F
A
G
F
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1.
A: Single Plant at Prouts Neck
C: Expanded and Upgraded Oak Hill Plant, discharge to
Nonesuch River
F: Full Transfer to South Portland
G: New Plant at Oak Hill with discharge to Fore River
2.
Cost estimates are within 15% range for each Alternative.
See Chapter 3 for complete description of costs.
On the basis of the Alternatives Evaluation, EPA has recommended
Alternative "G" as the proposed action. A detail description
of the proposed action is described in Chapter IV of the Final EIS.
2.	DISINFECTION OF TREATMENT PLANT EFFLUENT
Several comments referred to the ineffectiveness of chlorine
in killing viruses in the effluent and suggested alternate methods
including the use of ozone, ultrasound, and ultraviolet light. The
use of ultrasound and ultraviolet light is relatively new in the
field of wastewater treatment, and reliable operation of these
techniques on a large scale has not been demonstrated. Ozone, at
higher than normal dose, is regarded as more effective than chlor-
ine in virus inactivation. However, operating data on a full
scale application of ozone for virus inactivation is not available.
Assuming that such an application is feasible, a comparison of
cost effectiveness of chlorine and ozone was made. This evaluation
concluded that for standard disinfection chlorine is more
cost-effective than ozone, but for greater virus inactivation,
ozone would be more cost effective.
With the new proposed action there will be no discharge off
Prout's Neck which has been an issue with respect to virus in-
fection. The discharge to the Fore River is not anticipated to
affect any recreation areas where virus infection could occur.
With the elimination of existing direct untreated discharges in
the proximity of recreational areas, the probability of virus
infection will be greatly reduced.
3.	SLUDGE DISPOSAL
The Draft EIS did not fully evaluate the options for dis-
posing of sludge generated from the operation of the treatment
plant. In response to public comments, the following options were
evaluated:
Land spreading of liquid sludge, with storage in
a lined tank during winter months
Land spreading of partially dewatered sludge with
storage in a lined tank during winter months
Land filling of partially dewatered sludge.
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The first option was found to be more cost effective in the near
term, when the treatment plant would be operating below its capac-
ity and producing a small sludge volume. However, the last option
was found to be more feasible over the long term, when the treat-
ment plant would be operating at its capacity. This evaluation is
presented in more detail in Chapter III of the Final EIS.
In addition to the above option, composting of sludge should
be evaluated by the Sanitary District during the design phase of
the project.
4.	USER COSTS
Some residents expressed concern that the user costs beyond
Phase I of the proposed action were not evaluated in the Draft
EIS. Others presented their own estimate of the user cost for
Phase II.
The Draft EIS did not present estimates of the user costs
for Phase II or beyond because these estimates would depend on
preliminary sewerage designs, which have not been performed. In
response to the public comments, a preliminary estimate of the
user cost for serving all of the planned service areas was ob-
tained. This estimate is presented in the Chapter on the proposed
project. Note that the range of user costs will vary depending on
the number of users and the availability of FMHA loans and grants
to assist in financing the non—eligible portions of the project.
5.	CONSTRUCTION IMPACTS
Some residents commented that the Draft EIS failed to display
the outfall route through the Prouts Neck area and failed to eval-
uate the impact of outfall construction on the Prouts Neck environ-
ment and on marine life. There was also concern expressed that
feasible, alternative outfall routes were not evaluated. More
general concerns were expressed over the construction impacts on
Higgins Beach and the impact of dredging and filling in the wet-
lands and waterways.
The impacts during the construction of the treatment plant,
the sewers and pumping station, and the outfall, including the
dredging and filling impacts, are discussed in Chapter IV of the
Final EIS. The location and evaluation of the alternative outfall
routes were presented in the supplemental report to the Draft EIS
and are included in the Alternatives Chapter of the Final EIS.
The impact on traffic flow during the construction in the
Higgins Beach area and the other parts of the town can be mitigated
by scheduling the construction during the spring, late fall, or
winter, when the tourists and summer residents are gone.
The existing sewerage system in the Higgins Beach area would
be maintained until the new sewage system is installed. Therefore,
no adverse public health effects are expected during the construc-
tion of the new sewage system.
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6. POPULATION GROWTH AND PLANNING
Some residents commented that the proposed wastewater system
would induce uncontrolled growth in Scarborough, while others
suggested that a range of population growth projections be consid-
ered.
Soon after the Draft EIS was issued, the Greater Portland
Council of Governments, in cooperation with the Scarborough
Planning Board, projected three growth scenarios for Scarborough.
In a Supplement to the Draft EIS, entitled "Planning and
Growth Strategy," the effects of three scenarios on community ser-
vices was analyzed and recommendations were made for implementing
a strategy to control growth. Subsequent to releasing the Supple-
ment to the Draft EIS, EPA formally requested the Planning Board,
Town Council and the Sanitary District to select a growth strategy
which just represents the long-term desires of the Town. EPA
received from the Planning Board and Town Council a Statement in
support of the moderate growth scenario. The Final EIS recommends
a project with the capacity to serve the moderate growth scenario.
The Final EIS also provides a description of the impact of this
growth strategy plus providing planning recommendations to mitigate
or avoid these impacts,
7. NONPOINT SOURCE POLLUTION
Some residents commented that the nonpoint sources are
believed to contribute significantly to the total pollution load
to the water bodies in Scarborough, and that the projected growth
in Scarborough will further increase the nonpoint source pollution
loads. They further stated that since the proposed project does
not provide for the treatment of the nonpoint source pollution,
the benefit derived from treating the point source pollution in
terms of restoring the productivity of the marsh will be limited
or negated by the increased nonpoint source pollution load result-
ing from increased population and the attendant intensified use
of land.
Currently data on the nonpoint source pollution in Scarborough
is not available. The methods to predict the nonpoint source
pollution, particularly bacterial run-off, are not fully developed and
are very imprecise. Lack of data on the marsh hydrology further
complicates prediction making of run-off. Therefore, only a very
approximate estimate of the nonpoint source pollution levels with
an accuracy of * 100 percent can be obtained. Such an estimate
was obtained for the bacterial run-off and is discussed below.
The bacterial run-off in Scarborough was analyzed by using
the methods described in the EPA Report, "Loading Functions for
Assessment of Water Pollution from Nonpoint Sources." The folr
lowing assumptions were made:
Pollution loadings were based on curb miles for
the drainage basin and reflected run-off from sew-
ered areas.
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Die-off of bacteria during the transport of the source
to the stream was not considered.
Pollution loadings were based on the existing population.
National and regional climate means were used for estim-
ating the total and fecal coliforms.
Based on the above analysis, the coliform concentration in the
immediate area of the mouth of the estuary would range from 500 to
1,000 MPN/100 ML* for total coliforms and from 30 to 450 MPN/100 ML
for fecal coliforms. Since this analysis did not consider the
bacteria removal by the salt marsh, which is believed to remove
about 98 percent of the coliform bacteria, the above results can
be regarded as highly conservative,
A comparison of these results with the Maine water quality
standard for shellfish growing areas indicate that the estimated
bacterial levels from run-off exceed the fecal coliform standards
for direct shellfish harvesting and could not meet the standards
for depuration harvesting. Currently, the bacterial levels in
the shellfish growing areas in Scarborough exceed both the direct
and the depuration harvesting standards. However, the bacterial
levels in Scarborough's waters have shown wide variation over
the years.
Assuming that bacterial run-off would increase directly in
proportion to the population and no nonpoint source pollution
controls are implemented, the coliform concentration in the shell-
fish growing areas of Scarborough would be expected to approxim-
ately double during the next 25 years, if the population of
Scarborough nearly doubles during the same period (as projected
under the high growth scenario). If no bacteria removal by the
salt marsh is assumed, the above results indicate that even
depuration harvesting may not be possible under the high growth
scenario. However, the salt marsh is likely to remove some
bacteria, hence depuration harvesting would be possible under the
high growth scenario.
In summary, the results of a very crude nonpoint source
pollution analysis indicate that direct shellfish harvesting in
Scarborough would not be possible unless the existing nonpoint
source pollution is abated. However, depuration harvesting could
be possible even under the moderate growth scenario.
In addition, EPA has suggested to the Town that land use as
well as other planning recommendations be implemented which could
mitigate or reduce potential problems resulting from nonpoint
sources.
* Most probable number per 100 milliter.
The Maine water quality standards for shellfish areas require
total coliform less than 70 and fecal coliform less than 15/100
ML for direct harvesting and total coliforms less than 700 and
fecal coliforms less than 150/100 ML for depuration harvesting.
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8. ARCHEOLOGICAL IMPACT
The U.S. Department of Interior commented that the archeo-
logical impact of the proposed project be evaluated by a quali-
fied archeologist. Dr. Perlman of the University of Maine
conducted an archeological survey of the Prout's Neck treatment
plant site, and concluded that the construction would not have
an adverse archeological impact on that site.
Since the archeological survey was conducted EPA has rec-
ommended constructing the proposed wastewater treatment facility
on a site adjacent to the existing facility at Oak Hill. EPA
has coordinated with the Maine Historic Preservation Officer who
has determined that this site contains no major potential archeo-
logical resources. (See attached letter).
All pump stations and interceptors are proposed to be lo-
cated along existing rights of ways which have been previously
disturbed due to other construction activities.
9. IMPACT ON CLAM RESOURCE
Comments were received to the effect that the clam production
figures stated in the Draft EIS are based on insufficient and
inaccurate data. It was also pointed out that the potential in-
crease in the clam productivity due to pollution abatement is
overstated in the Draft EIS, not only because of the use of the
inaccurate clam production data, but also because another major
problem, predation, was not considered.
The 1946 clam production figure of 118,286 bushels for
Scarborough as stated in the Draft EIS was extracted from the
Comprehensive Plan* for Scarborough. This figure is believed to
be a gross estimate of clam production for.the entire Cumberland
County, rather than for Scarborough alone.** The actual 1946
clam production figures for Scarborough are not available.
The 1975 clam production figure of 10,000 bushels for
Scarborough as stated in the Draft EIS is based on the data provid-
ed by the Maine Department of Marine Resources. According to
Mr. William Bayley of Scarborough, this figure represents the total
amount of clams processed by the three depuration plants in
Scarborough, of which only 40 percent came from the Scarborough
estuary.*** Thus, the actual clam production in 1975 in Scarborough
was 4,000 bushels.
* "Comprehensive Development for Scarborough, Maine" James A.
Sewall Company, 1964.
** Comments on the Draft EIS by Mr. Edward Wong, Natural
Resources Offices, EPA, February 6, 1976.
*** Record of Public Hearing on Draft Environmental Impact State-
ment on Wastewater Collection and Treatment Facilities in
Scarborough, Maine, January 29, 1976. P.105.
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Pollution abatement alone is not likely to increase the clam
production in Scarborough but proper resource conservation and
management and predation control are also required to increase the
clam production over the present level. Green crab predation is
a major problem in some clam growing areas in Scarborough.
10.	GEOHYDROLOGY
The Draft EIS stated that relatively little is known about
the geology of the Scarborough area, and that only a few ground
water wells exist in Scarborough.
A geological map for the Scarborough area has been prepared
by the Main Geological Survey, which provides geological infor-
mation for the Scarborough area, which was not presented in the
Draft EIS. This additional information has been revieved and con-
sidered in EPA's final recommendation.
With respect to the use of ground water, the Draft EIS in-
correctly noted that there were few wells in the town. Numerous
wells do exist in the areas west of the Main Turnpike where no
centralized public water supply system exists.
11.	INFILTRATION
Some residents commented that because of the high water table
in the area, the infiltration rate would be high, hence the pro-
posed treatment plant capacity would be reached upon completion
of the system.
The infiltration rate in the existing Oak Hill sewerage
system is believed to be at normal level of about 2 00 gallons per
inch diameter per mile per day. The new sewage system would be
designed to limit the infiltration to the above rate, which would
be generally acceptable to EPA. The total flow contribution from
the infiltration is not expected to be significant. Also, the
treatment plant would be designed with sufficient capacity to
treat the total flow accounting for the infiltration.
Another concern presented was the infiltration problem in
South Portland. EPA and the Maine DEP have reviewed a preliminary
report prepared by the consultants to South Portland and concur
that adequate capacity would not be available at South Portland
for several years.
12.	TREATMENT PLANT RELIABILITY
Some residents commented that biological treatment systems
similar to that proposed, are known to malfunction, and that the
Draft EIS did not evaluate the probability and consequences of
such malfunctions.
There is always a possibility of the malfunctioning of the
biological system because of an inadvertent discharge of incompat-
ible wastes into the sewage system. However, the probability of
20

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such an occurence is regarded to be extremely low, because all dis-
charges of incompatible wastes are required to provide pretreatment
of their wastes prior to the discharge into the sewerage system.
The existing Oak Hill treatment plant in Scarborough has been in
operation for 10 years, with only one instance of malfunctioning.
This was caused by the discharge of an unexpectedly high waste
volume by the Humpty Dumpty Potato Chip Company. Once the waste
load was established, and adjustments were made at the treatment
plant, the problem ceased. The proposed plant will have increased
monitoring of the influent thus further reducing the probability of
a malfuntion.
Should the biological system malfunction, primary treatment
and disinfection will always be provided. Once a malfunction is
detected, appropriate actions to protect public health will be
taken. The receiving water will be monitored to detect the level
of bacterial contamination. If high contamination is found, shell-
fishing and water contact in the affected areas will be restricted
until the problem is corrected. Probable malfunction is expected
to be temporary.
13. OTHER ISSUES
Several other issues were raised during the public review, and
these are discussed below.
(1)	Federal Water Pollution Control Act Requirements
for 19 83
Two commentators asked whether the proposed secondary
wastewater treatment plant would need to be significantly
upgraded in order to meet the 1983 requirements of the
Federal Water Pollution Control Act.
By July 1977, all publicly-owned wastewater treatment
works are required to produce an effluent which meets the
national effluent limitations based on secondary treatment or
which meets more stringent limitations as necessary to attain
locally appropriate water quality standards. By 1983, the
Water Pollution Control Act specifies, these treatment works
need to attain effluent limitations consistent with "best
practicable waste treatment technology." No national re-
quirements have been promulgated for this 1983 requirement,
and EPA is not currently developing such national guidelines.
Although there is some uncertainty over whether such require-
ments will be imposed on a nationwide basis, EPA's current
policy suggests either that no nationwide requirements will
be imposed, or if some requirements are imposed, they will
require very limited improvement over the effluent produced
by secondary treatment.
(2)	Conformity With the Coastal Zone Management Goals
The Department of Commerce commented that the Draft EIS
did not evaluate the conformity of the proposed project with
the objectives of the Coastal Zone Management (CZM) program.
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Although the CZM program for Maine has not been approved,
Maine has state laws governing land use in areas adjacent
to water bodies which will form the basis for CZM plans and
other plans for preservation and management of coastal areas.
Neither the proposed project nor any of the alternatives con-
flict with the regional and local plans for the conservation
of the coastal areas,
(3)	Reliability of Data Related to Effluent Dispersion
Some commentators implied that the Draft EIS ignored the
results of the drift bottle and drogue buoy experiments con-
ducted by Whitman and Howard, because the results were not
favorable to the proposed action.
The drift bottles and the drogue buoy experiments were
conducted to determine the direction and speed of the surface
currents near the proposed outfall. However, the wind di-
rection and speed during these experiments were not measured.
Therefore, the wind influence on the drift bottles and the
drogue buoys cannot be reliably assessed. Hence, these
experimental results were not included in the analysis pre-
sented in the Draft EIS.
(4)	Impact on Parks and Recreational Areas
The Department of Interior commented that the impact of
the proposed project on parks and recreational areas needs to
be evaluated.
The only significant direct impact on land use of the
alternative recommended in the Draft EIS would occur from the
construction of the treatment plant. The proposed 8-acre
treatment plant site is currently vacant with no structured
recreational use. Construction of the treatment plant would
preclude any future recreational use of the site. However,
this would not significantly diminish the potential for
recreational opportunities in Scarborough. In any event, the
new action allows for this land area to be utilized for rec-
reational uses should the Town decide to do so.
Any indirect impact on the recreational and park areas
would result from future growth in Scarborough. However,
by sizing the treatment plant to meet the needs of the moder-
ate growth scenario and by implementing suggested growth
management measures, the possibility of uncontrolled growth
resulting from excess sewerage system capacity will be limited.
Secondary impact on the recreational and park areas can thus
be avoided. EPA and the U.S Fish and Wildlife Service have met
to discuss the potential impacts of the project on national
recreational areas. A letter outlining their implementation is
included in the Final EIS.
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(5)	Impact of Abandoned Septic Tanks
The Department of Interior commented that the impact of
abandoning the septic tanks as a result of installation of
sewers needs to be evaluated.
It is estimated that about 1,500 residential units cur-
rently served by individual septic systems would be served by
the proposed sewer system.* After connecting to the sewer
system, the property owners will be required by the state and
local code to pump out the septic tank sludge and fill the
septic tanks with suitable fill material. The septic tank
sludge will be treated in the proposed treatment plant.
(6)	Application of Value Engineering
One resident suggested that the value engineering tech-
nique be applied to the selection of the alternative system.
EPA requires value engineering for those treatment
plants whose costs will exceed $10 million. Although value
engineering may be necessary for smaller projects, EPA does
not believe it is necessary for the Scarborough project.
(7)	Impact in the Dunes
Several residents expressed concern that the proposed
treatment plant would threaten dunes in the Ferry Beach area.
The treatment plant site is located entirely inland
from Ferry Beach and no dunes exist now on the site set
aside for the plant. Providing all construction activity is
kept inland from Ferry Road and away from the existing dunes•
on the seaside of the road, the dunes will be unaffected.
There is no reason to believe that the operation of the plant
will affect those resources.
Areas served by septic systems include Blue Point, Pine Point,
Dunstan, Willowdale, Oak Hill North, and Black Point-Prouts
Neck. The Oak Hill and Higgins Beach areas have existing
sewer systems.
23

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REFERENCES
1. "An Analysis of Alternative Wastewater Collection and Treat-
ment Systems for Scarborough, Maine," prepared for the U.S.
EPA, Region I, by Booz, Allen & Hamilton, Inc., September 30,
1976.
2.	"An Analysis of Certain Environmental Issues Related to the
Proposed Wastewater Collection and Treatment System in
Scarborough, Maine," prepared for the U.S. EPA, Region I, by
Booz, Allen & Hamilton, Inc., November 8, 1976.
3.	"Planning and Growth Strategy in Scarborough, Maine," prepared
for the U.S. EPA, Region I, by Booz, Allen & Hamilton, Inc.,
October 1, 1976.
4.	Arthur M. Hussey, II, Geologic Map of the Portland Quadrangle,
Maine, GM-1. Department of Economic Development, Maine
Geological Survey, Augusta, Maine, 1971.
5.	Telecon with Mr. Donald Dargie of Whitman and Howard, Inc.,
December 16, 1976.
6.	Optimum Location of the Proposed Prouts Neck Ocean Outfallf
Scarborough, Maine, Whitman and Howard, Inc., March 1974.
24

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SECTION II
COMMENTS SUBMITTED TO EPA ON
THE DRAFT ENVIRONMENTAL IMPACT
STATEMENT
25

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RESPONSE TO DRAFT ENVIRONMENTAL
IMPACT STATEMENT, SCARBOROUGH, MAINE,
EPA REGION I, GIVEN AT PUBLIC HEARING
JANUARY 29, 197 6
By: William J. Brooks
26 Morning Street
Scarborough, Maine
The key to the Scarborough sewer problem is this:
The Town Council wants massive rapid growth.
This requires a large sewer system.
Large sewer systems require high taxes.
To keep the taxes as low as possible makes it
necessary to have the most Cost-Effective
System rather than the one that will fulfill
the Federal requirement of NO POLLUTION in
the waters by 19 85.
A system to meet the Federal requirements
requires the "best available technology by
July 1983 for industrial sewage" and for
"publicly owned sewer systems a minimum of
secondary and the best practicable technology
by 1985. (See Water Pollution Control Act,
1972 PL 92-500)
MOST ADVANCED TREATMENT PLANT AVAILABLE
A large advanced treatment plant would be more expensive than
the most cost effective plant.
Therefore, in order to keep taxes within bounds and have
advanced treatment, it is obviously necessary to build a sewer
system for only the presently polluted areas as named in the consent
order of the Maine Board of Environmental Protection.
The most logical system would seem to be:
1. A separate plant at Higgins Beach (See
Robert Hodgdon's and Lillian Lee's responses
to this EIS) with an effluent pure enough to
27

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-2-
go into the marshes and estuary. The
technology is available.
2.	Either a separate plant at Pine Point,i.e.
advanced treatment, with pure effluent to the
marsh or else an advanced treatment plant that
would be tied in to the Old Orchard plant.
(THE POSSIBILITY HAS RESURFACED OFFICIALLY
THAT OLD ORCHARD WANTS TO HAVE THE PINE POINT
SEWAGE SO IT CAN THEN UPGRADE ITS PLANT TO
ADVANCED TREATMENT AND THUS MEET THE REQUIRE-
MENTS of pure waters by 1985.)
3.	or else, all Western area of Scarborough,
including Pine Point, could be piped along
the old railroad right of way to an upgraded
to tertiary treatment plant at Oak Hill whose
pure water effluent could go into the marsh.
There are still other alternates which could be considered by
the engineers and EPA IF IT IS RECOGNIZED THAT THE ANSWER IS NOT
NOT.' IN A SECONDARY SYSTEM BUT A TERTIARY (ADVANCED TREATMENT) WITH
PURE ENOUGH EFFLUENT TO GO INTO THE MARSHES AND ESTUARIES. IT CAN
BE DONE.
These types of plants should have been planned long ago and
might have been planned if_ the town controlling politicians had
not vetoed them every time they were suggested by the opposition
to Plan A. (ALT I).
Any delays that have been encountered by the opposition that
was necessary to Plan A are not the fault of those who were opposed.
All the town politicians in and out of office have known for years
what the opposition thought about Plan A, but they just refused
to let Whitman and Howard consider those alternates. BUT, EVEN
MORE SURPRISING IS THAT AN ENVIRONMENTAL PROTECTION AGENCY WOULD
BE SO MUCH MORE INTERESTED IN PROTECTING THE POLITICIANS THAN THE
ENVIRONMENT. EPA KNOWS THAT ADVANCED TREATMENT TECHNOLOGY IS
28

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-3-
AVAILABLE, AND THAT SECONDARY DOES NOT KILL 99% OF VIRUSES, AND
THAT IT WOULD BE BETTER FOR THE ENVIRONMENT. EPA SHOULD HAVE
TURNED THIS WHOLE THING AROUND. MAYBE AFTER THIS EXPOSURE IT
WILL BE DONE, OR MAYBE A COURT WILL HAVE TO DO IT.'
This draft EIS has the major fault of modifying all conclu-
sions that would oppose Plan A (ALT I) downward, and of modifying
all conclusions that would upgrade Plan A upward, so that the
policies of the Town Council and the controlling politicians that
"the town will have population growth whether the people want it
or not", are encouraged!
Neither this Town, nor any town, must have population growth
IF CONDITIONS ARE NOT RIGHT FOR IT. SUCH A THESIS HAS BEEN UPHELD
IN THE COURTS.
THE CONDITIONS ARE NOT RIGHT FOR POPULATION GROWTH IN SCAR-
BOROUGH . The soil conditions are not right for cesspools, septic
tanks, etc; the marshes and estuaries must not be polluted, and
the people will not stand for high taxes when they know what they
are not getting that which they could have had for the same taxes
in the form of a smaller advanced treatment plan and system that
would retain the rural environment that they indicated in surveys
j
they want.
Neither may we destroy our scenic cliffs at the Winslow Homer
Studio by dirtying them with grease and other solids left in the
15% of the secondary effluent that comes out of the diffuser, and
spreads over the top of the water till it reaches the rocks and
sticks to them turning them into a dirty gray, uniformly. I mean
29

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-4-
the Winslow Homer Home and Studio that is a national shrine that
may not have negative impact on it! We must sewer our storm
water runoff so that no more oil or dog manure and other wastes
go into the waters.
That is a very important aspect of waste water treatment which
has just surfaced here in Scarborough. I have not heard anyone
speak of it yet, and it is not in the EIS, although the EPA knows
about it. That is—this matter of treatment (after collection) of
all street storm runoff before it gets into the estuaries and
marshes.
The Water Pollution Control Act arranged for the designation
of billions of dollars for it. An article in the New York Times
of January 22, 1976 brought it dramatically to my attention.
It seems that as soon as Vice President Rockefeller's Water
Quality Commission reports to President Ford, he plans to send
amendments to that Act to Congress. The 300 billion dollars set
aside for storm water cleanup systems will be cut very drastically.
Scarborough therefore must not go into a massive secondary plant
until it can afford to get all its waters cleaned up by advance
treatment including storm water runoff. Scarborough must not
encourage the population growth that would produce many streets
that would compound the storm water runoff problem. It will be
expensive enough to sewer human wastes by advanced treatment and
find some way to also clean up storm runoff, without planning a
massive secondary treatment plant that will take care of human
sewage and storm water runoff. But if the 1985 requirements are
30

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-5-
to be met by Scarborough, we must take care of present pollution
first with a plant that won't send 15% of its suspended solid
effluent (containing viruses) into the ocean.
Furthermore, President Ford is planning to cut out all federal
funds for ANY SEWER SYSTEM PLANNED TO TAKE CARE OF PREDICTED
POPULATION GROWTH. He hopes Congress will pass those two amend-
ments, and I have no doubt they will. So once again, Scarborough
will not get as much Federal money as thought and what Scarborough
will have to do to clean up present human and storm water pollution
will cost an inordinate amount, as it is, to the present taxpayer
with advanced treatment plants.
There is another area of the EIS that is very deficient.
Discussing the geology of the area, the statement on P..II-2,
Sec. 2.1.2 says that "relatively little is known of the geology
of Scarborough and its neighbors". AS A MATTER OF FACT A VERY
DETAILED REPORT AND STUDY OF THE GEOLOGY OF THE AREA WAS PUBLISHED
BY THE MAINE GEOLOGICAL SURVEY IN 1971, by D. Hussey of Bowdoin.
It is Geologic Map Series, GM1, Geologic Map of the Portland
Quadrangle. It is not listed in the EIS references. It is
astounding that supposedly knowledgeable engineering companies
could overlook such a work. One question to the State Geologist
would have revealed it. No wonder the competency of Whitman and
Howard is under question in many places, but why did not Booz,
Allen & Hamilton think of it, or the EPA?
I will not go into details, but the whole Town has lots of
hard rock that would have to be blasted through, and Prout's Neck,
31

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in particular, where the outfall is supposed to go, is a very
complicated area with seven difficult rock formations of very
hard rock that would have to be blasted through to get the out-
fall to the ocean. At the South Point, where the outfall was
originally scheduled to go, the cliffs at the shore are forty
feet (plus) high. Some blasted job!!I How much more simple and
economical to plan tertiary plants with pure effluent going into
the marshes. Why didn't the EIS require pinpointing outfall
location? Good Question! Before I stop, I want to protest!!!
The rules of making up an EIS say there should be public
participation. I say you violated those rules by allowing so
little time to prepare an answer to the EIS. Yes, I know that
we had an extension till March 7 to get in our final written
answers. But the public hearing is far more important than
making a written statement. And there is even more that should
be done besides speaking and sending in a written statement.
That is this!
I happen to be a member of the Environmental Caucus that
chooses the representatives of the Environmentalists of Long
Island, New York to the Citizen's Advisory Committee of the
208 study for the Nassau-Suffolk Regional Planning Board studying
the waters of Long Island, and primarily what to do with the waste
waters of any development that might be allowed in the future on
Long Island (outside of New York City). I know the chairman of
the public Scarborough hearing mentioned that Scarborough opponents
of ALT I should go to the C.A.C. of the 208 of the C.O.G.
32

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-7-
Portland Region. But that organization is not working in a
manner that gives much public participation. The one repre-
sentative from Scarborough can't raise much dust about
Scarborough's problems. He just isn't listened to.
Portland is having the same problems Scarborough is.
Economic Director Neilly, whom I just happened to hear when
I visited the Rotary Club, said his goal was to make Portland
a "great port" but that that required "millions of people" in
the hinterlands, "AND THEY DON'T WANT TO DEVELOP THEIR RURAL
TOWNS IN THAT WAY."
All the rest of the towns around Portland have denied
development, but NOT THE SCARBOROUGH POLITICIANS WHO CONTROL
TOWN COUNCIL. These politicians do not care that Scarborough
citizens have stated three times that they want a rural environ-
ment, slow growth, etc. but the politicians (some of whom are
in office, some on the committee of the dominating political
party) do not care. As proof of that last statement look at
this: I live at Higgins Beach. In the summer of 1974 the
town put up signs on Higgins Beach saying that the waters
east of the sign spot were too polluted to allow swimming so
it was prohibited. The signs lasted only two days, when they
were taken down. I have found out why they were taken down
and not put back up. The owner of certain rental cottages
in the banned area went to town hall and told them that he
could not rent cottages and then later tell his tenants that
they could not swim in the waters in front of their cottages.
33

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-8-
So they took the signs down. That's what the town fathers care
about the health of little children who played in the runnels
full of primary sewer water in that section of the beach. Did
the signs go up last summer and was the man told to tell his
prospective tenants before rental that they could not swim in
the waters in front of their cottages? No, the signs did not
go up. Was the water just as polluted as the previous year?
It surely must have been. Would an honest set of town fathers
ever have allowed the signs to come down in the first place?
Would they have had them put back before the rental season
began the following year?
I am telling you this to give you the idea that you, the
EPA, the Federal Environmental PROTECTION AGENCY have been
conned and taken in (along with the DEP, which, however^ at
least wrote a consent order) by the town politicians.
This EIS response that we opponents of Plan A (ALT I)
have written will, I hope, show you that you must do a complete
turn around. The whole picture has changed since all the work
was done. Especially Ford and the Democrats, nationally, are
talking budget stringency. So you'd better make a very modern
and careful analysis of what's cookin. It still amazes me that
you, in a Regional Office, are so asleep that I, a layman, had
to point this out to you.
GETTING BACK TO WHAT I FIRST SAID ABOUT YOUR ALLOWING SO
LITTLE TIME FOR ADEQUATE PUBLIC PARTICIPATION: HOW could you
take from Nov. 1, the day the first draft came out (we were
34

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-9-
in your office that day explaining our position to your staff)
until December 24 to rewrite the EIS, which took months for
the engineers to review, and yet you produce this draft in the
middle of the holiday season, and try as we might (and we tried
in many ways to get copies of the first draft SO WE COULD STUDY
IT) WE DIDN'T get copies of the second draft until about the
second week in January. They came dribbling in a copy at a
time, yet we were supposed to be able to organize our people,
know what topics to assign to this one and that one, provide
the material for them to study, meet again to organize our
approach, and come up with a public participation that was
sensible and right. I swear the more we look at your production
of the EIS the more it looks like your men were in political
cahoots with the big money boys of the controlling politician
group. Is that the way to run an environmental protection
agency?? What was the justification for releasing the first
draft EIS to newspapers who were .allowed to comment, but we of
the "public participation" group could not get copies even
though we went through U.S. Senators?? We finally got one
copy through a back door. And when the second draft came out
it was like pulling teeth trying to find copies. Yet WE WERE
IN YOUR OFFICE ON NOVEMBER 1 and gave our names and addresses
at that time, with requests for copies for the committees
that have a right to study this EIS. Yet we did not receive
either first or second drafts until we persistently bugged
you. I went to Maine from my New York home at Thanksgiving
time, at Christmas and again in January to attend to this
35

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10
sewer business. When I went home in early January, I telephoned
your offices and told them my story. UNBELIEVABLE AS IT MAY
SOUND, THERE WAS A COPY IN THE MAILS SPECIAL DELIVERY AT MY
NEW YORK DOORSTEP THE VERY NEXT MORNING. SOME SECRETARY WAS
ON THE JOB, BUT WHERE WERE THE OFFICIALS WHO HAD BEEN GIVEN
OUR NAMES ON NOVEMBER 1. That is why I feel and others feel
that your agency needs a shakeup. Are you interested in names
and places??? I could say a lot more' But perhaps this is
enough. Suffice it to say, this ballgame is not going to stop
until what is right is established.
36

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37

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REG: EIS DRAFT Hearing
I fully realize that an adequate Sewer System is desperately needed
in this town.
However, being a resident of WEST SCARBOROUGH, which means I will
never recieve any of the benefits from this Proposed Sewer System,
I feel and object to any intention of being forced to help pay for
this benefit for this part of Scarborough.
I do feel that a paragraph completly and accurately stipulating that
NORTH and WEST SCARBOROUGH, will not and never will be taxed, fined,
burdened, or forced to pay the user fee or parts thereof, whatsoever,
until the Sewer System runs 100 feet from our property.
The reason for this stipulation paragraph is: The town has no intent-
ion, desire or will to bring the Sewer System across the Turnpike and
we feel our taxes are overburdening now for the few benefits we re-
cieve on the other side of the turnpike, as it is so often called.
We do not have good police protection, nor do we have a water system,
and we do not want to pay for this Sewer System that will only benefit
the users.		
Also, If the Proposed Sewer System is handled anything at all like,the
Sludge Disposal Sites in this town, we are in desperate need of heip.
Stateing one Example: Only because I am well aware of this particular
disgrace from the Town of Scarborough, Against the Town of Scarborough.
Letter from the Scarborough Planning Board to the Scarborough Appeals Board.
Lets just hope that this town does a more acccurate and less costly (not
just in dollars but in land,air,water quality control and abuse.) job
than what they brought about into this town with their uncaring, Hurry up
and wait to see attitude.
From what I have seen,read, and heard, we are in for the same type of
mismanagement and abuse from the Proposed Sewer System as we have received
with the Sludge Disposal Systems.
LLER
340 Broadturn Road
WEST SCARBOROUGH,MAINE
38

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November 13, 1974
SUBJECT: Special Exception Appeal by D. H. Winslow
Sav/age Treatment Facility
TO: Scarborough Zoning Board of Appeals
The Planning Board has reviewed the- D. H. Winslow appeal at our Novem-
ber 12, 1974 meeting, We offer the following observations and opinions
for your information,
1)	A septic tank sludge disposal area is a needed facility and appears
appropriate in a PF zone. Nonetheless such a proposal must be
iudged as acceptable on it(T*merits /md impact on the local neighbor-
hood and environment. Never considef^cr even though we petitioned
Had a good supported turnout A many meetings
objecting.
2)	The D.E.P. has issued a license tor the subject facility." Apparently"
the facility meets the "Maii]^ Guidelines for Septic Tank Sludge Dis-
posal on Land" requirements but substantial proof to that fact should
be obtained.' The licensing procedure should be scrutinized for com-
pleteness and accuracy," Never scrutinized- no proof just objections
apparently meaning- who knows - who cares...
3)	Water quality monitoring provisions, to determine the impact of such
a facility on the environment, have not been proposed. Monitoring of
water quality, should .be a part	on land,'' ,
Was this Monitoring ever done/? NO who is responsible/
/\ a	i i' i u ij v - i «. "7"	wasn't, this completed.
4)	A very close look should be taken at the impact of sucn a facility on
the local neighborhood before you take any action^j^ft Petitions Lawyers
The whole neighborhood objected!!!!!! Objections, 'Complaints.'"
5)	If you judge that the appeal is appropriate and have satisfied your- i>ettf
self that the impact of such a facility is justified, the precedence
has been set for the detailed proposal to be reviewed by the Planning
Board under the Nonstatutory Subdivision Ordinance„
6)	The Planning Board does not offer an opinion of approval or disapproval
because the appeal is a complicated one and(our first hand information
is limited.)(We suggest you accept our opinions on their merit and weigh
the impact on the environment and neighborhood against a substantial
need for such a facility.) Why didn't someone or some dept, office e1
within the town government take inititive and find out more
information instead of passing the buck on & on.
. sincerely yours,
This letter for the 3rd time mentioned
f impaction loeal neighborhood shouM-5
be considered. 7	,
We protested loud & clear yet we
still au&bonbarded with this outrag-r0m Kuczkowski for the
eous land abuse.	Scarborough Planning Board
TK/lfc
39

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Kirkwood Road
Scarborough, Me.
March 1, 1976
Kr. Wallace Stickney
EPA
Kennedy Bldg.,
Boston, Mass.
Dear 2-ir. Stickeny;
I wish to add a few additional comments pertaining to
the Scarborough EIS.
Both the Planning Board and the Sanitary District have
discussed the draft in their meetings of the past two weeks and most likely
you will get statements from them going along with Plan A»
But before you give any weight to their comments I feel
you should know some of the makeup of the boards.
The Planning Board has had all but one member resign from
the board in the past four months and I believe the chairman, Thomas Kuxckowski,
is the only experience member remaining. It is my understanding that at least
two of the new members have some connection with real estate. One member^ who
was defeated for the council because he favored Plan A, has approximately 70
acres of land in the family which they hope to develop as soon as possible.
The Sanitary District met this past week with only five of
its seven members present. They were considering the impact statement.
This board has three of its members connected with real
estate and the chairman of the board represents a firm that has considerable
property for sale in the Scarborough area, -^t would be difficult for these
members to divorce their bias to make an unbiased decision on the sewers®
At the Sanitary District board meeting the Whitman & Howard
representative stated that his firm had the tape recording of the hearing for
study. Our members are wondering why your staff aid not give us the same
opportunity to study the tapes„
Tie"	/
Prfes. Scarborough Taxpayers
Af/1.0 -
' J 7S7&
43
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FEB I S 1978
RICHARD A. LEVY, M. D,
128 CHADWICK STREET
PORTLAND, MAINE 04101
Telephone 772-1515
February 13, 1976
Mr. Wallace Stickney
U.S. Environmental Protection Agency
Room 2203
JFK Federal Building
Boston, Massachusetts 02203
Dear Mr. Stickney,
Enclosed is the statement I read at the Environmental Impact
Statement Public Hearing in Scarborough on Thursday, January
29. Attached to that statement is a bibliography indicating
the reference material containing the data on which the pre-
pared statement was based.
If you have any questions regarding the information contained
in this statement, please do not hesitate to contact any of
those five physicians sharing in the preparation.
^Sineerely Yours,
Enclosure
ccs Senator Muskie, Senator Hathaway, Rep. Emery and Rep. Cohen.
pS! 0 K U <0 -¦ + ,
Richard A. Levy, M.D
RAL/cw
44
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The physicians who have prepared the following statement are all
residents of Scarborough and practice medicine in the Greater Port-
land area. They are George Lord, M.D., Robert Ritchie, M.D., George
Higgins, III, M.D., James Maier, M.D., and Richard A. Levy, M.D.
These physicians have a combined medical experience involving more
than 60 years, not including their years in medical school, and rep-
resent a varied cross-section of medicine including medical research,
public health, mental health, pulmonary disease and family practice.
Dr. Lord is a graduate engineer, having received his degree from the
Coast Guard Academy, and practiced engineering prior to his medical
education and subsequent career. In addition, he is a trained diver,
was a member of the sea lab team in the U.S. Navy, and is personally
familiar with the waters, both over and under, off this coast of
Maine. Dr. Ritchie is the director of a large medical research lab-
oratory at the Maine Medical Center, a member of the Federal Drug
Administration, and has many years of experience in the investiga-
tion and collection of data. Dr. Levy has had several years experi-
ence in medical research, public health, and in the design, organiza-
tion and carrying out of community medical programs. Drs. Higgins
and Maier are daily involved in delivering health services to fami-
lies and individuals, and have special concerns for the issue of in-
fectious disease in relation to children in the community. All these
physicians have spent considerable time studying the health aspects
of the proposed treatment systems. They have had at their disposal
the Health Sciences Library at the Maine Medical Center and the
MEDLARS Computer Facility, hooked up with the Harvard School of Medi-
cine Library, providing a copy of any scientific paper written any-
where in the world. They have given considerable thought and concern
to the issues, and have based the following statement on facts and
their experienced medical judgment.
The undersigned physicians believe that the sewage treatment facili-
ty proposed by Whitman and Howard (Plan A) constitutes a potential
health hazard to the community and its visitors. We believe that
the method by which data was obtained for the purpose of determining
the relative safety and hazards of both the treatment process pro-
posed and the location of the outfall to be scientifically and medi-
cally unsound.
We would like to address ourselves first to the question of disin-
fection of the effluent, and the actual hazard to health of viruses
discharged into seawater. The following material to be discussed
relates to the Environmental Impact Statement, Section III, Item 3.2,
Section IV, Item 4.1, Section V, Item 5.1.5. We will assume that no
secondary treatment plant is 100% effective, and that a reasonable
percent of effectiveness is somewhere between 85 and 90%. This es-
sentially means that about 10% or more of sewage is not effectively
45
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Page 2
treated, and that therefore a certain quantity of solid material,
bacteria and viruses will be released directly into the ocean.
These viruses are known to cause infectious hepatitis, myocarditis
(coxackie) and poliomyelitis. Dr. Gerald Berg, Chief of Virology
at the EPA Water Quality Office, states in a paper entitled "Re-
moval of Viruses Prom Waste Water" that . . . "It is a common ex-
perience that the efficiency of treatment systems is much greater
under lab conditions than under the difficult to regulate conditions
that exist in the fieldj activated sludge treatment is no exception.
When samples were taken from primary and activated sludge effluents
in the same plant, secondary effluents contained only 53 and 71%
fewer viruses than the settled primary effluents." Dr. Berg stated
in the same paper that "safe water requires terminal disinfection.
Chlorine, universally applied to many needs for decades, suffers
many shortcomings. Since most effluents contain ammonia, some-
times at levels that exceed 20mg./liter, chlorination is likely
to produce only chloramines. Chloramines are toxic to fish and
life that serve as fish foods . . . and are slow disinfectants."
In the 1973 annual report of Environmental Research, published
by the U.S. EPA, National Environmental Research Center in Cinci-
natti, it is stated on page 19 " . . . Evidence indicates the
proof of destruction of coliform organisms does not necessarily
insure all viruses are killed. In addition, there is growing
concern regarding the low virucidal potency of chloramines (chlor-
ine, upon entering an effluent of seawater, will partially be
bound to ammonia and form chloramines), toxicity of chlorine and
the possibility of producing undesirable, organic chlorine re-
action products." Chlorinated hydrocarbons are currently being
investigated as potential carcinogenic (cancer producing) agents.
In the same report it is stated that "more than 100 viruses are
excreted by man, and may be discharged into waterways . . . since
the importance of viruses resides not in number, but in their in-
fectivity, a high degree of virus removal is desirable." There
is no reliable or available research at this time to indicate
what happens to a viral sample when it enters seawater, that is
to say whether the virus dies, remains virulent, has its potency
diminished, or whether it still is capable of producing disease
in humans. We do know from our studies of recent research that
coliform counts do not indicate what viruses are present in efflu-
ent, in what quantity, whether or not they might cause disease,
or to sum it up whether or not the water that has been sampled
for the coliform test is actually safe. There is a controversy
regarding the effect of seawater on viruses, which has not yet been
solved. We were unable to find a reliable research project, which
validated or invalidated the opinion that viruses are killed in
seawater. Live, human viruses have been found in shellfish, indi-
cating their viability in seawater. During the course of our re-
46
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Page 3
search we've come across a very disturbing fact, and that is that
viruses are now being linked to cancer. The Epstein-Barr Virus,
in particular, is associated with cancer of the nose and throat,
and Burkitt's Lymphoma. The 197& edition of Advances in Internal
Medicine indicates that medical researchers are a step away from
linking viruses to breast cancer. Viruses are now known to remain
latent in people, causing their diseases weeks, months, cr even
years after the original infection. This subject was discussed
at some detail by Dr. Ritchie at the public hearing, held in June
197*+, in relation to this proposed sewer system. Secondary treat-
ment systems have been designed in the past with no knowledge of
the viral cause of cancer. Certainly this new knowledge indicates
that systems must be designed to take into account this very im-
portant, potentially life threatening fact. The proposed system
does not so do, and will admittedly dump a certain number of un-
treated viruses into the ocean and environment. In a scientific
paper published in 1973» Professor Otis J. Sproul, Department of
Civil Engineering, University of Maine, entitled "Quality of Re-
cycled Water: Fate of Infectious Agents," stated that the "number
of viruses in waste water are always small, but the number required
to produce an infection in man is also very small. We must be con-
cerned about the presence of only one virus particle in water."
Dr. Sproul goes on to report that in activated sludge treatment
processes that "field reports show that removals of 90% and les£
are obtained in actual plant operation*" What this means, in re-
ality, is that residents and visitors swimming in our ocean waters
will be exposed to 10% or more, meaning up to 300,000 gallons/day
or more of inadequately or nontreated effluent, containing an un-
known quantity of lethal virus. Also in that paper, Dr. Sproul
goes on to say, when discussing disinfection, that chlorine reacts
with ammonia and proteins which are present in waste water to pro-
duce chloramines and chloroproteins, and that "these have a con-
siderably reduced potential for virus inactivation." (This, of
course, reinforces the statement made by Dr. Berg, mentioned above,
as well as many other researchers in the area.) Dr. Sproul goes
on to state that the work of Lothrup and Sproul have shown that
only 50% or less of polio virus Type I were inactivated at Irsg./
liter of combined chlorine residual with a 30-minute contact per-
iod. Contrary to the figures given in the statement prepared by
Booze-Allen, 90fo or more of disinfection does not take place when
the effluent is held for 30 minutes with a combined chlorine re-
sidual of lmg./liter. This old standard is no longer applicable
with the knowledge we now have of virus resistance to disinfection.
A series of papers read at the University of Illinois, College of
Engineering, 13th Water Quality Conference, February 1971, provides
abundant data and new research findings indicating the very complex
problem of adequately disinfecting viral samples. Dr. Sproul also
states in his paper that high chlorine residuals, required to in-
47
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Page *»•
activate viruses in waste water, cause persisting* active chlorine
compounds in receiving water. These compounds have been reported
to kill fish and other organisms at low concentrations and to taint
shellfish and fish flesh at lower concentrations. Dr. Sproul also .
states in his paper that research has shown conclusively that solid
material in effluent protects viruses from exposure to disinfection.
In order that adequate disinfection take place, total removal of
solids is necessary. This is certainly not provided by the second-
ary treatment plant proposed in Plan A, by Whitman and Howard. In
the many papers presented at the Water Quality Conference held at
the University of Illinois, mentioned above, it is stated repeatedly
that disinfection is the key to killing viruses in waste water efflu-
ents, and that at present, inadequate viral kills are obtained by
standard disinfection systems utilizing chlorine. A new approach,
utilizing ultrasound, which breaks up solid matter into small par-
ticles, provides greater opportunity for contact with the disinfect-
ant. The most effective disinfectant is regarded to be ozone, A
combined system using both ultrasound and ozone is reported in a
paper published in Applied Microbiology. March 1975. by researchers
at the University of Notre Dame, and has been tested in the field
in Indiantown, Florida, in a municipal treatment plant for over one
year. This process is commercially available. On page 111-21, under
Section 3 of "the Environmental Impact Statement, "Alternative Disin-
fection," it states that "because of the concern of the problem'of
monitoring the effectiveness of ozonization, the design engineer
was encouraged to select chlorination as the means of disinfection."
The problem of ozone monitoring existed at one time, but is no longer
the case. An automated, reliable, commercially available feedback
system is incorporated into the ITT-KERAG (Swiss-manufac-ured) ozone
generator and constantly monitors the ozone level, keying in more or
less production as is necessary. It does not make logical or common
sense that we continue to use chlorine in the disinfection process.
It was stated two years ago, at the public hearing regarding the pro-
posed system, that viruses could not be isolated from seawater and
adequately studied. We have discovered in our research that that was
not true then, and it is certainly not true now. Various filter sys-
tems have been designed and are in operation, which isolate virus
samples from quantities as much as 300 galloj3_s/minuts, and both
artificial and tissue mediums have been developed on which viral cul-
tures can be reliably grown. These latter techniques result in what
is known in the trade as plaque-forming units and tissue culture in-
fective dose. Scientific measuring of viruses in seawater effluents
can be accomplished, and we can no longer bury our head in the sand
and say that no one knows if viruses are there or not. There is a
side issue relating the difference in viral kill qualities between
chlorine and ozone not mentioned in the EI3, which has profound ef-
fect on'the Snvironment into which the disinfectant is discharged.
It is known that with chlorine, dangerous and toxic compounds remain
48
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Page 5
after its use in the treatment process. Ozone rapidly converts into
oxygen and provides no after-disinfection chemical or compound what-
soever, To proceed with a treatment system, as proposed by Whitman
and Howard, would insure that a certain number of Scarborough towns-
people, and in particular their children, utilizing the recreational
waters, as well as visitors, will be exposed to infectious disease.
It is also likely that the risk for contracting cancer would be in-
creased as well due to the presence of chloroproteins, chlorinated
hydrocarbons, nitrosamines, and most importantly the link between the
virus particle and certain forms of cancer.
We are very concerned with the apparent fact that no thorough, care-
fully investigated alternative method of treatment (as opposed to
transfer) has been considered in any of the proposals made by Whit-
man and Howard, or subsequent studies by Hunter-Ballew and Booze-
Allen. It is our understanding that this is required by the Federal
Water Quality Control Act.
We will briefly comment on fractional plants for'the town, with
multiple point sources for outfalls. (Viewpoint of public health.)
It is certainly more desirable to not concentrate the effluent, but
to have more than one ocean outfall. It is also very desirable to
control the Higgins Beach pollution problem as rapidly as possible,
and it is likely that would happen much faster if a plant were to be
built at Higgins Beach to handle the effluent now running freely,
both by point and non-point sources, into those highly utilized rec-
reational waters. In our researching the Sonazone process, we did
note that their plants are constructed in six to eight months at an
approximate cost of $1.35/gall°n/day, which would certainly be quick-
er and cheaper than the plant proposed by Whitman and Howard. Also
in relation to Higgins Beach, we are concerned with the total lack
of provisions in any of the proposals made by Whitman and Howard, or
subsequent reports by Hunter-Ballew and Booze-Allen, for sanitary
facilities (or their cost) during the approximately anticipated twelve
months between the beginning of construction and the function of the
new sewer system. No provision is made for the disposition of human
waste, nor other effluents during the interval when the old system
will be broken into and admittedly will not function.
Another disturbing medical fact has come to light during our inves-
tigation of this problem. Sludge, removed from biological treatment
plants, is crawling with live viruses. There is no way that this
mass of material can be adequately disinfected. It is likely that
it constitutes as worrisome a public health problem as the effluent
entering the water directly. It is stated in the Environmental Im-
pact Statement that the sanitary district has made arrangements to
experimentally spread sludge from the proposed plant on local golf
courses 'and farm fields. It is known that sludge leaches into
49
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Page 6
ground water, and can be carried into streams as well as open wa-
ters, not only contaminating water supplies but endangering people
utilizing waters for recreational use. There is no research avail-
able to indicate what the hazard is of walking over a golf course,
or living down wind of a golf course, that has been fertilized by
a concentrated dose of virus, surrounded by sewage residue. As far
as farm lands fertilized by this manner, it would be very important
to set up a carefully controlled, systematic research study involv-
ing the culture or produce from that farm land, as well as a public
health study of the incidence of infectious disease in "people eat-
ing that produce.
Next we will address ourselves to the second major problem of the
proposed treatment system. We believe that the method by which the
data was obtained for the purpose of determining the relative safety
or hazards of both the treatment process proposed and the location
of the outfall to be scientifically and medically unsound. Much of
the data and information on which opinions have been based, regard-
ing the safety of this system, were collected from studies done by
Whitman and Howard. It is a basic rule of thumb, in medical and
scientific investigation and research, that data be collected by an
independent investigator, who in no way stands to profit by the even-
tual outcome of the study under consideration. An excellent example
of how such a conflict of interest can influence the collection'and
interpretation of data, is both the Drift Bottle Study and the"Drogue
Buoy experiment carried out by Whitman and Howard, in relation to
the location of an outfall. The results of the Drift Bottle Study
were unfavorable to the proposed location of the outfall, with the
large majority of the bottles found on local beaches, indicating
quite clearly the strong influence of prevailing winds in the area.
The results of this study were discounted by Whitman ana Howard be-
cause "the bottles were improperly ballasted." The fundamental rule
of research was ignored, that an experimental study be repeated if
the investigator doubt the reliability of the initial result. This
was not done. Logically, the ballasting of the bottles has little
to do with the fact that they were pushed in by prevailing winds to
the beaches; regardless of how deep the bottles sit in the water, the
fact is they were blown in to the beaches, as would any other mass
floating on the surface. The published Environmental Impact State-
ment comments on the likelihood that the effluent plume, rising from
the outfall, would rise to the surface and be subject to prevailing
winds. In a similar fashion, the investigators chose to interpret
the results of the Drogue Buoy Studies as indicating the current did
not flow in a direction which would bring effluent into recreational
and beach areas. It is very clear that the basic data obtained from
these studies shows currents to go in every which direction, and that
50
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Page 7
material is likely to be carried both into Scarborough and Higgins
Beach, as well as toward Orchard Beach, as well as out to sea. Lo-
cal fishermen and boatmen have known for many years that the cur-
rents off the coast of Maine, and in this area in particular, are
quite erratic and unpredictable, and vary from season to season and
tide to tide, and weather condition to weather condition. Certainly
there was no opportunity, as described in the original Drogue Buoy
experieiaents, to monitor the effects of currents by this method at
varying seasons and times of the year. It is logical to conclude
that a large quantity of effluent would be carried by the current
toward shore and the beaches on one day, while on another day it may
go in.another direction; what is important to note is that there is
no dependability in terms of drift or current, and that therefore
the community is placed at risk. Drogue Buoy Studies are not defini-
tive in the study of currents in relation to the dispersion of a
liquid and/or semi-solidv material. A dye study, in which a known
quantity of liquid dye dispersed in a known unit of time, would have
given a much more accurate and reliable indication cf what actually
happened with the release of an effluent. Therefore, the basic in-
vestigative techniques utilized by the engineers studying the ques-
tion of "where will the effluent go" are incomplete and unreliable.
We are further concerned with the issue of conflict of interest in
relation to the choice of a treatment process or system. The Water
Quality Conference, held at the University of Illinois mentioned
above, stressed the point that research and field operation indicates
the swing from biological treatment plants to physical-chemical treat-
ment plants. The design engineers (Whitman and Howard) appeared to
be unaware of this trend in modern technology, and are apparently in-
experienced in designing such systems. It is not likely that Whit-
man and Howard would propose a system they would neither design nor
supervise the construction of.
In summary then, the undersigned physicians believe that the sewer
treatment system proposed by Whitman and Howard (Flan A) constitutes
a health hazard to the community. Based on information and research
data available, it is our opinion that if the proposed system is put
into operation, the residents of Scarborough and their visitors will
be exposed to viruses causing infectious diseases and linked to can-
cer. More adequate and commercially available disinfection systems
are available. In our opinion the disposal of sludge has been poor-
ly researched and planned, and the proposal for its disposition con-
stitutes a severe health hazard. We believe the original studies,
carried out by Whitman and Howard in relation to the location of an
outfall, to be incomplete and the data unreliable. Its present lo-
cation would appear to be exactly where it will carry the most di-
51
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Page 8
sease producing organisms to the largest number of people using the
recreational waters off the Scarborough coast. We are especially
concerned with the lack of provision of sanitary health measures at
Higgins Beach during the proposed construction phase.
George Lord, M.D.
Robert Ritchie, M.D.
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George L. Higgins, III, M
James Maier, M.D.
Richard A. Levy, M.D.
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52
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3IBLIOGRAPHY
1.	M. N. Baker, "The Quest for Pure Water," The American Water Works
Association. 19^-91 New York.
2.	J. L. Melnick, "Detection of Virus Spread by the Water Route,"
Proceedings of the 13th Water Quality Conference, University of
Illinois at Urbana-Champaign (1971).
3.	G. Berg, "Removal of Virus by Water and Waste Treatment Processes,"
Proceedings of the 13th Water.. Quality Conference, University of
Illinois at Urbana-Champaign (1971).
4.	"The Pollution of Rivers," Engineering, 2 (1866), p.290.
5.	T. G. Metcalf, "Biologic Parameters in Water Transmission of Vi-
ruses," Proceedings of the 13th Water Quality Conference, Univer-
sity of Illinois at Urbana-Champaign (1971).
6.	N. Zollner and H. Lydtin, "Increased Incidence of Abnormal Car-
diac Findings in Coxsackie Infection of Adults," Deutsch Medi-
2inische Wochenschrift, ^5 (1967)* pp. 20^9-2055.
7.	G. R. G. Monif, C. W. Lee and G. D. Hsiung, "Isolated Myocarditis
with Recovery of Echo Type 9 Virus from the Myocardium," New Eng-
land Journal of Medicine, 277 (1967)» pp. 1353-1355.
8.	G. E. Burch, S. C. Sun, K. C. Chu, R. S. Sohal and H. L. Colco-
lough, "Interstitial and Coxsackie Virus B. Myocarditis in Infants
and Children," Journal of the American Medical Association, 203
(1968), pp. 151-155.
9.	G. C. Brown and T. N. Evans, "Serologic Evidence of Coxsackie-
virus Etiology of Congenital Hearth Disease, Journal of the Ameri-
can Medical Association, 203 (1968), pp. 55-62.
10.	D. R. Gamble, M. L. Kingsley, M. G. Fitzgerald, R. Bolton and
K. W. Taylor, "Viral Antibodies in Diabetes Mellitus,British
Medical Journal, 56:71 (1969)» p. 637.
11.	C. 0. Carter, "Section of Epidemiology and Preventive Medicines
Congenital Defects," Proceedings of the Royal Society of Medi-
cine, 61 (1968), pp. 991-1000.
12.	G. C. Ray, V. L. Tucker, D. J. Harris, F. E. Cuppage and T. D. Y.
Chin, "Enteroviruses Associated with the Hemolytic-Uremic Syn-
drome," Pediatrics, 46 (1970), pp. 378-388.
13.	J. W. Mosley, "Transmission of Viral Diseases by Drinking Water,"
Transmission of Viruses by the Water Route. G. Berg, ed., New
York: J. Wiley & Sons (I967), pp. 5-23.
53
-------
Page 2
1^. P. Rutledge, H. G. Skinner and E. D. Jorris, "Reports on Three
Outbreaks, (b) Washington Island, Wisconsin," Hepatitis Surveil-
lance (NCDC) Report No. 29 (1968), pp. 16-18.
15.	L. J. Morse, A. Gurwitz, E. E. Reilly, Jr. and N. Fiumara, "In-
fectious Hepatitus Outbreak: College of the Holy Cross, Worces-
ter, Massachusetts," Morbidity and Mortality, 18 (1969). dd. 357-
358.
16.	J. A. Harrel, Jr., R. L. Carpenter and C. A. Austin, "Infectious
Hepatitis - Hatfield, Arkansas," Morbidity and Mortality, 19
(1970), pp. 281-282.
17.	F. Taylor, J. H. Eagen, H. F. D. Smith, Jr. and R. F. Coene, "The
Case for Water-borne Infectious Hepatitis, "American Journal of
Public Health, 56 (1966), pp. 2093-2105.
18.	V. Defendi and F. Jensen, "Oncogenicity by DNA Tumor Viruses:
Enhancement After UV and Cobalt-60 Radiations," Science, 157
(1967), pp. 703-705.
19.	E. W. Akin, "Enteric Viruses in Ground and Surface Waters: A Re-
view of Their Occurrence and Survival." Proceedings of the 13th
Water Quality Conference, University of Illinois at Urbana-
Champaign (1971).
20.	L. Coin, M. L. Menetrier, J, Lobonde and M. C. Hannoun, "Modern
Microbiological and Virological Aspects of Water Pollution,"
Proceedings of the 2nd International Conference on Advanced
Water Pollution Research, 0. Jaag and J, K. Boors, eds., Oxford:
Pergamon (1965)•
21.	T. G. Metcalf and W. C. Stiles, "Viral Pollution of Shellfish in
Estuary Waters," Journal of the Sanitary Engineering Division,
ASCE, 9^ (1968), p. 595.
22.	D. M. McLean, "Infection Hazards in Swimming Pools," Pediatrics,
22 (1963). PP. 811-818.
23.	N. A. Clarke, G. Berg, P. W. Kabler and S. L. Chang, "Human
Enteric Viruses in Water: Source, Survival and Removability,"
International Conference on Water Pollution Research, London,
1962, New York: Pergamon.
2k-. M. D. Sobsey and R. C. Cooper, "Laboratory Studies on the Survi-
val of Poliovirus in Algal-bacterial Waste-Water Treatment Sys-
tems," Proceedings of the 13th Water Quality Conference, Univer-
sity of Illinois at Urbana-Champaign (1971).
54
-------
Page 3
25.	W. F. Hill, "Detection of Viruses in Water: A Review of Methods
and Application," Proceedings of the 13th Water Quality Confer-'
ence, University of Illinois at Urbana-Champaign (1971).
26.	C. Wallis, "Development of an Apparatus for Concentration of
Viruses From Large Volumes of Water," Proceedings of the 13th
Water Quality Conference, University of Illinois at Urbana-
Champaign (1971).
27.	E. E. Geldreich and N.A. Clarke, "The Coliform Test: A Criter-
ion for the *Viral Safety* of Water," Proceedings of the 13th
Water Quality Conference, University of Illinois at Urbana-
Champaign (1971).
28.	L. J. McCabe, J. M. Symons, R. D. Lee and G. G. Robeck, "Survey
of Community Water Supply Systems," Journal of the American Wa-
ter Works Association, 62 (1970), pp. 670-687.
29.	0. J. Sproul, "Recent Research Results of Virus Inactivation by
Water Treatment Processes," Proceedings of the 13th Water Quality
Conference, University of Illinois at Urbana-Champaign (I97I).
30.	0. C. Liu, "Recent Research on the Chlorine Effect on Human En-
teric Viruses in Water," Proceedings of the 13th Water Quality
Conference, University of Illinois at Urbana-Champaign (1971).
31.	J. R. Neefe, J.B. Baty, J. G. Reinhold and J. Stokes, Jr., "In-
activation of the Virus Infectious Hepatitis in Drinking Water,"
American Journal of Public Health? also in National Health, 37
(19^7), PP. 365-372.
32.	D. 0. Cliver, "Virus in Water and Wastewaters Efects of Some
Treatment Methods," Proceedings of the 13th Water Quality Confer-
ence, University of Illinois a.t Urbana-Champaign (1971).
33.	C. W. Kruse, "The Enhancement of Viral Inactivation by Halogens,"
Proceedings of the 13th Water Quality Conference, University of
Illinois at Urbana-Champaign (1971).
3^. J. H. McDermott, "Disease-free Water Called Possible at 2.00 Per
Person," The Environmental Health Letter. 9:20 (1970), p.
35.	0. J. Sproul, "Quality of Recycled Water« Fate of Infectious
Agents," Canadian Institute of Food Science and Technology Jour-
nal, Vol. 6, No. 2, pp. 91-95.
36.	E. Shannon, "Polluted Water Tied to Illness," Newsday, November
17, 1975.
55
-------
Fage 4
37.	G. R. Burleson, T. M. Murray and M. Pollard, "Inactivation of
Viruses and Bacteria by Ozone, With and Without Sonication,"
Applied Microbiology. March 1975» PP. 340-344.
38.	G. Berg, "Water Pollution Microbiology," Journal of Water Pol-
lution Control Fed.. Vol. 46, June 1974, pp. 1408-14-13.
39.	D. J; Reish, "Marine and Estuarine Pollution,M Journal of Wa-
ter Pollution Control Fed., Vol. 45, No. 6* June 1973, pp.
1310-1315.	~~
40.	M. M. Varma, B, A. Christian and D. W. McKinstry, "Inactivation
of Sabin Oral Poliomyelitis Type I Virus," Journal of Water Pol-
lution Control Fed., Vol. 46, May 197^, pp. 987-991.
^1. Environmental Research In 1973, Annual Report, U.S. Environ-
mental Protection Agency, National Environmental Research Cen-
ter, Cincinnati, Ohio.
42. L. Gross, Oncogenic Viruses, 2nd ed. Oxford, Pergamon Press (1970).
^3. J. F. Sambrook, H. Westphal, P. R. Srivivasan and R, Dulbecco,
"The Integrated State of Viral DNA in SV^g-'transformed Cells,"
Proc. Natl. Acad. Sci. U.S.A.,60:1288, (1968).
44.	T. L. Benjamin, "Virus-Specific RNA in Cells Productively In-
fected or Transformed by Polyoma Virus," Journal of Mol. Biol. ,
16:359, (1966).
45.	J. H. Pope and W. P. Rowe, "Detection of Specific Antigen in
SV4o-transformed Cells by Immunofluorescence." Journal of Exp.
Med., 120:121, (1964).
46.	D. E. Kohne and R. J. Britten, "Hydroxyapatite Techniques for
Nucleic Acid Reassociation," in Cantoni, G. L. and Davies, D. R.
(eds.)j Methods in Nucleic Acid Research, Vol. 2, New York?
Harper and Row, (1971), pp. 500.	~
47.	L. D. Gelb, D. E. Kohne and M. A. Martin, "Quantitation of Sim-
ian Virus 40 Sequences in African Green Monkey, Mouse and Virus-
Transformed Cell Genomes."J. Mol. Biol., 57»129» (1971).
43. R. Dulbecco, "Cell Transformation by Viruses and the Role of
Viruses in Cancer," J. Gen. Microbiol., 79«7» (1973).
49. L. V. Melendez, M. D. Daniel, R.D. Hunt, C. E. 0. Fraser, F. G.
Garcia, N. W. King and M. E. Williamson, "Herpesvirus Saimiri:
V. 'Further Evidence to Consider This Virus as the Etiological
Agent of A Lethal Disease in Primates which Resembles A Malig-
nant Lymphoma." J. Natl. Cancer Inst., 44j 1175i (1970).
56
-------
Page 5
50.	R. Laufs and L. V. Melendez, "Oncogenicity of Herpesvirus Ateles
In Monkeys," J. Natl. Cancer Inst., 51:599, (1973).
51.	W. P. Rowe, J. B. Humphrey and F. Lilly, "A Major Genetic Locus
Affecting Resistance to Infection with Murine Leukemia Viruses.
III. Assignment of the Fv-1 Locus to Linkage Group VIII of the
Mouse," J. Exp. Med. 137:850, (1973).
51a. F. L. Graham, A. J. van der Eb and H. L. Heijneker, "Size and
Location of the Transforming Region in Human Adenovirus Type 5
DNA," Nature, 251:687, (197*0.
52.	C. Basilico and G. DiMajorca, "Radiation Target Size of the Ly-
tic and the Transforming Ability of A Polyoma Virus," Proc. Natl.
Acad. Sci. U.S.A. 5^:125, (1965).
53.	R. Duff and F. Rapp, "Properties of Hamster Embryo Fibroblasts
Transformed in Vitro After Exposure to Ultraviolet-Irradiated
Herpes Simplex Virus Type 2, J. Virol. 8:469, (1971).
5*+. J. F. Enders and G. Diamandopoulos, "A Study of Variation and
Progression in Oncogenicity in an SV^Q-transformed Hamster Heart
Cell Line and its Clones," Proc. R. Soc. Lond. (Biol.) 171:^31*
(1969).
55.	G. W. Kafuko, B. E. Henderson, B. G. Kirya, G. M. R. Munnube,
P. M. Tukei, N. E. Day, G. Henle, W. Henle, R. H. Morrow, M. C.
Pike, P. G. Smith and E. H. Williams, "Epstein-Barr Virus Anti-
body Levels in Children from the West Nile District of Uganda,
Lancet 1:706, (1972).
56.	G. Miller, "The Oncogenicity of Epstein-Barr Virus," J. Infect.
Pis. 130:187, (197*0 •
57.	G. Henle, W. Henle and V. Diehl, "Relation of Burkitfs Tumor-
Associated Herpes-Type Virus to Infectious Mononucleosis," Proc.
Natl. Acad. Sci. U.S.A. 59:9**, (1968).
58.	A, S. Evans, J. C. Niederman and R. W. McCollum, "Ser©epidemio-
logic Studies of Infectious Mononucleosis with EB Virus," N.
Engl. J. Med. 279:1121, (1968).
59.	G. Miller, J. C. Niederman and L. L. Andrews, "Prolonged Oro-
pharyngeal Excretion of Epstein-Barr Virus After Infectious Mono-
nucleosis," N. Engl. J. Med. 228:229, (1973).
57
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Page 6
60.	M. A. Epstein, G. Henle, B. G. Achong and Y. M. Earr, "Morphologi-
cal and Biological Studies on A Virus in Cultured Lymphoblasts from
Burkitt*s Lymphoma," J. Exp. Med. 121:761, (1965).
61.	M. H. Miller, D. Stitt, and G. Miller, "Epstein-Barr Viral Antigen
in Single Cell Clones of Two Human Leukocytic Lines," J. Virol..
6:699. (1970).
62.	M. K. Walters and J. H. Pope, "Studies of the E3 Virus-related An-
tigens of Human Leukocyte Cell Lines," Int. J. Cancer, 8:32, (I97I).
63.	B. M. Reedman and G. Klein, "Cellular Localization of an Epstein-
Barr Virus (EBV)-associated Complement-fixing Antigen in Producer
and Nonproducer Lymphoblastoid Cell Lines," Int. J. Cancer, 11:^99,
(1973).
6b. M. Nonoyama and J. S. Pagano, "Detection of Epstein-Barr Viral
Genome in Nonproductive Cells, " Nature (New Biol.), 233* 103» (1971).
65.	T. Lindahl, G. Klein, B. M. Reedman, B. Johansson and S. Singh,
"Relationship Between Epstein-Barr Virus (EBV) DNA and the EBV-
determined Nuclear Antigen (EBNA) in Burkitt Lymphoma Biopsies
and Other Lymphoproliferative Malignancies," Int. J. Cancer 13»76^,
(197*0 •
66.	J. S. Pagano, C. H. Huang and P. Levine, "Absence of Epstein-Barr
Viral DNA in American Burkitt's Lymphoma," N. Engl. J. Med., 289:
1395, (1973).
67.	G. de-The, J. C. Abrosioni, H. C. Ho and H. C. Kwan, "Lymphoblas-
toid Transformation and Presence of Herpes-type Viral Particles in
A Chinese Nasopharyngeal Tumor Cultured in Vitro," Nature (Lond.),
221:770, (1969).
68.	H. zurHausen, H. Schulte-Holthausen, G. Klein, W. Henle, G. Henle,
P. Clifford and L. Santesson, "EB-virus DNA in Biopsies of Burkitt
Tumors and Anaplastic Carcinomas of the Nasopharynx," Nature, (Lond.),
228:1056, (1970).
69.	H. Wolf, H. zurHausen and V. Becker, "EB Viral Genomes in Epithelial
Nasopharyngeal Carcinoma Cells," Nature (New Biol.), 2*44:2^5, (1973).
70.	G. Klein, Personal Communication.
71.	G. Rocchi, J. Hewetson and W. Henle, "Specific Neutralizing Anti-
bodies in Epstein-Barr Virus Associated Diseases," Int. J. Cancer,
11:637, (1973).
58
-------
Page 7
72.	W. Henle, G. Henle, P. Gunven, G. Klein, P. Clifford and S. Singh,
"Patterns of Antibodies to Epstein-Barr Virus-induced Early Anti-
gens in Burkitt's Lymphoma. Comparison of Dying Patients with Lohg-
term Survivors," J. Natl. Cancer Inst., 50:1163, (1973).
73.	P. J. Fialkow, E. Klein, G. Klein, P. Clifford and S. Singh, "Im-
munoglobulin and Glucose-6-Phosphate Dehydrogenase as Markers of
Cellular Origin in Burkitt Lymphoma," J. Exp. Med., 138:89, (1973).
7'+. G. Dalldorf, C. A. Linsell, F. C. Barnhart and R. Martyn, "An
Epidemiologic Approach to the Lymphomas of African Children and
Burkitt*s Sarcoma of the Jaws," Perspect. Biol. Med.. 7:4-35, (196*0.
74a. D. Burkitt, "Etiology of Burkitt's Lymphoma—An Alternative Hypo-
thesis to A Vectored Virus," J. Natl. Cancer Inst., 4-2:19, (I969).
75.	D. Kufe, I. T. Magrath, J. L. Ziegler and S. Spiegelman, "Burkitt's
Tumors Contain Particles Encapsulating RNA-instructed DNA Polymerase
and High Molecular Weight Virus Related RNA," Proc. Natl, Acad. Sci.
U.S.A., 70:737, (1973).
76.	W. Henle, V. Diehl, G. Kohn, H. zurHausen and G. Henle, "Herpes-
type Virus and Chromosome Marker in Normal Leukocytes After Growth
with Irradiated Burkitt Cells," Science, 157:1064, (1967).
77.	G. Miller, T. Shope, H. Lisco, D. Stitt and M. Lipman, "Epstein-
Barr Virus: Transformation, Cytopathic Changes, and Viral Antigens
in Squirrel Monkey and Marmoset Leukocytes," Proc. Natl. Acad. Sci.
U.S.A., 69:383. (1972).
73. G. Miller and M. Lipman, "Release of Infectious Epstein-Barr Virus
by Transformed Marmoset Leukocytes," Proc. Natl. Acad. Sci. U.S.A.*
70»190, (1973).
79.	T. Shope, D. Dechairo and G. Miller, "Malignant Lymphoma in Cotton-
top Marmosets After Inoculation With Epstein-Barr Virus," Proc.
Natl. Acad. Sci. U.S.A., 70:2487, (1973).
80.	M. A. Epstein, R. D. Hunt and H. Rabin, "Pilot Experiments With
EB Virus in Owl Monkeys (Aotus Trivirgatus) I. Reticuloprolifera-
tive Disease in an Inoculated Animal," Int. J. Cancer 12:309, (1973).
81.	L. Falk. L. Wolfe, F. Deinhardt, J. Paciga, L. Dombos, G. Klein,
W. Henle and G. Henle, "Epstein Varr Virus: Transformation of Non-
human Primate Lymphocytes in Vitro," Int. J. Cancer 13:353» (1974).
59
-------
Page 8
82.	G. Miller, T. Shope and D. Coope, "Aspects of the Pathogenesis
of Lymphoma in Cotton-Top Marmosets Following Inoculation of EB
Virus," in W. S. Robinson and C. F. Fox, eds., Mechanisms of Virus
Disease, Vol. 1, Reading, Mass. W. A. Benjamin^ (1974), pp. 429-
83.	G» Miller and D. Coope, "Epstein-Barr Viral Nuclear Antigen (EBNA)
in Tumor Cell Imprints of Experimental Lymphoma in Marmosets,"
Trans. Assoc. Am. Physicians, 87:205» (1974).
84.	A. J. Nahmias, Z. M. Naib and W. E. Tisey, "Epidemiological Stud-
ies Relating Genital Herpetic Infection to Cervical Carcinoma,"
Cancer Res. , 34:1111* (1974).
85.	E. Adam, E. K. Sanders, J. L. Melnick, A. H. Levy and W. E. Rawls,
"Antibodies to Herpesvirus Type 2 in Breast Cancer and Cervical
Cancer Patients," Cancer, 33s147» (197*0.
86.	A. Sabin, "Herpes Simplex-genitalis Virus Nonvirion Antigens and
Their Implication in Certain Human Cancersj'Unconfirmed," Proc.
Natl. Acad. Sci. U.S.A., 71:3248, (1974).
87.	I. Royston and L. Aurelian, "Immunofluorescent Detection of Herpes
Virus Antigens in Exfoliated Cells from Human Cervical Carcinoma,"
Proc. Natl. Acad. Sci. U.S.A., 67:204, (1970).
88.	L. Aurelian, J. D. Strandberg, L. V. Melendez and L. A. Johnson,
"Herpesvirus Type 2 Isolated from Cervical Tumor Cells Grown in
Tissue Culture," Science, 174:704, (1971).
89.	N. Frenkel, B. Roizman, E. Cassai and A. Nahmias, "A DNA Fragment
of Herpes Simplex 2 and Its Transcription in Human Cervical Cancer
Tissue," Procl. Natl. Acad. Sci. U.S.A., 69:3784, (1972).
90.	H. zurHausen, H. Schulte-Holthausen, H. Wolf, K. Dorries and H.
Egger, "Attempts to Detect Virus-specific DNA in Human Tumors. II.
Nucleic Acid Hybridizations with Complementary RNA of Human Herpes
Group Viruses," Int. J. Cancer, 13:657, (1974).
91.	S. Sprecher-Goldberger, L. Thiry and P. VandenBussche, "Use of
Immune Lymphocytes to Detect Expression of Herpetic Genome,"
Nature (Lond.), 250:768, (1974).
92.	G. Darai and K. Munk, "Human Embryonic Lung Cells Abortively In-
fected with Herpes Virus Hominis Type 2 Show Some Properties of
Cell Transformation," Nature (New Biol.), 24l:2o8, (1973).
60
-------
Page 9
93» B. Garfinkle and B. R. McAuslan, "Transformation of Cultured
Mammalian Cells by Viable Herpes Simplex Virus Subtypes 1 and 2,"
Proc. Natl, Acad, Sci. U.S.A., 71:220, (197*0.
9^. A. J. Nahmias, M. N. Zuker, W. E. Josey, P. A. Murphy and C. F.
Luce, "Sarcomas After Inoculation of Newborn Hamsters with Herpes
Virus Hominis Type 2 Strains," Proc. Soc. Exp. Biol. Med., 13*+:
1065, (1970).
95.	T. -J. Bittner, "Some Possible Effects of Nursing oh the Mammary
Gland Tumor Incidence in Mice," Science, 8^:162, (1936).
96.	P. Bentvelzen, J. H. Daams, P. Hageman and J. Calafat, "Genetic
Transmission of Viruses That Incite Mammary Tumor in Mice," Proc.
Natl. Acad. Sci. U.S.A.. 67:377. (1970).
97.	E. M. Jensen, I. Zelljadt, H. C. Chopra and M. M. Mason, "Isola-
tion and Propagation of A New Virus from Spontaneous Mammary Carci-
noma of A Rhesus Monkey," Cancer Res., 30:2388, (1970).
98.	B. MacMahon, P. Cole and J. Brown, "Etiology of Human Breast Can-
cer* A Review," J. Natl. Cancer Inst., 50:21, (1973).
99.	B. E. Henderson, D. Powell, I. Rosario, C. Keys, R. Hanisch, M.
Young, J. Casagrande, V. Gerkins and M. C. Pike, "An Epidemiologic
Study of Breast Cancer," J. Natl. Cancer Inst,, 53:609, (197*0.
100.	J. C. Paymaster and P. P. Gangadharan, "Cancer in the Parsi Com-
munity of Bombay," Int. J. Cancer, 5:^26, (1970).
101.	N. H. Sarkar and D. H, Moore, "On the Possibility of A Human
Breast Cancer Virus," Nature (Lond.), 236:103, (1972).
102.	H. Chopra, P. Ebert and M. Woodside, "Electron Microscopic Detec-
tion of Simian-type Virus Particles in Human Milk," Nature (New
Biol.), 2^3:159, (1973).
103.	R. Axel, S. C. Gulati and S. Spiegelman, "Particles Containing
RNA-instructed DNA Polymerase and Virus-related RNA in Human
Breast Cancer," Proc. Natl. Acad. Sci. U.S.A., 59:3133, (1972).
10^. R. Cailleau, R. Young, M. Olive and W. J. Reeves Jr., "Breast
Tumor Cell Lines from Pleural Effusions," J. Natl. Cancer Inst.,
53:661, (197*0.
105. J. Keydar, Z. Gilead, S. Karby and E. Harel, "Production of Virus
by Embryonic Cultures Co-cultivated with Breast Tumor Cells or In-
fected with Milk from Breast Cancer Patients, Nature (New Biol.),
241:^9. (1973).
61
-------
Page 10
106.	R, Axel, J. Schlom and S, Spiegelman, "Presence in A Human Breast
Cancer of RNA Homologous to Mouse Mammary Tumor Virus RNA," Nature
(Lond.), 235:32, (1972).
107.	E. S. Priori, D. E. Anderson, W. C. Williams and L. Dmochowski,
"Immunological Studies in Human Breast Carcinoma and Mouse Mam-
mary Tumors," J. Natl. Cancer Inst., 48:1131, (1972).
108.	L. Gross, '"Spontaneous * Leukemia Developing in C3H Mice Following
Inoculation in Infancy, with A-K Leukemic Extracts, or AK Embryos,"
Proc. Soc. Exp. Biol. Med., 76:27, (1951).
109.	W. P. Rowe, J. W. Hartley, M. R. Lander, W. E. Pugh and N. Teich,
"Noninfectious AKR Mouse Embryo Cell Lines in Which Each Cell Has
the Capacity to be Activated to Produce Infectious Murine Leukemia
Virus," Virology, 46:866, (1971).
110.	F. Lilly and T. Pincus, "Genetic Control of Murine Viral Leukemo-
genesis," in G. Klein and S. Weinhouse, ed. Advances in Cancer Re-
search, Vol. 17, New York: Academic Press, (1973)»pP» 231.
111.	R. J. Huebner and G. J. Todaro, "Oncogenes of RNA Tumor Viruses
as Determinants of Cancer," Proc. Natl. Acad. Sci. U.S.A.. 64:
1087, (1969).
112.	Editorial: "Epidemiology of Leukaemia," Lancet, 1:82, (1972).
113.	H. P. Wagner, H. Cottier and E. P. Cronkite, "Variability of Pro-
liferative Patterns in Acute Lymphoid Leukemia of Childhood,"
Blood. 39:176, (1972).
114.	G. R. Newell, W. W. Harris, K. 0. Bowman, C. W. Boone and N. G.
Anderson, "Evaluation of 'Virus-like' Particles in the Plasmas
of 255 patients with Leukemia and Related Diseases," N. Engl. J.
Med., 278:1185, (1968).
115.	M. G. Sarngadharan, P. S. Sarin, M. S. Reitz and R. C. Gallo,
"Reverse Transcriptase Activity of Human Acute Leukaemic Cells:
Purification of the Enzyme, Response to AMV 70S RNA, and charac-
terization of the DNA Product," Nature (New Biol.), 240:67, (1972).
116.	W. Baxt, R. Hehlmann and S. Spiegelman, "Human Leukaemic Cells
Contain Reverse Transcriptase Associated with A High Molecular
Weight Virus-related RNA," Nature (New Biol.), 240:?2, (1972).
117.	W. G. Baxt and S. Spiegelman, "Nuclear DNA Sequences Present in
Human Leukemic Cells and Absent in Normal Leukocytes," Proc. Natl.
Acad. Sci. U.S.A., 69:3737, (1972).
62
-------
Page 11
118.	W, Baxt, J. W. Yates, H. J.. Wallace, Jr., J. P. Holland and S.
Spiegelman, "Leukemia-specific DNA Sequences in Leukocytes of
the Leukemic Member of Identical Twins," Proc. Natl. Acad. Sci;
U.S.A., 70:2629, (1973).
119.	G. Miller, "Human Lymphoblastoid Cell Lines and Epstein-Barr
Virusi A Review of their Interrelationships and their Relevance
to the Etiology of Leukoproliferative States in Man," Yale J.
Biol. Med., ^3:358, (1971).
120.	J. Minowada, T. Ohnuma and G. Moore, "Rosette-forming Human
Lymphoid Cell Lines. I. Establishment and Evidence for Origin
of Thymus-derived Lymphocytes," J. Natl. Cancer Inst., 49:891*
(1972).
121.	J. Kaplan, T. C. Shope and W. D. Peterson, Jr., "Epstein-Barr
Virus-negative Human Malignant T-cell Lines," J. Exp. Med. 139:
1070, (197^).
122.	M. Kotler, E. Weinberg, 0. Haspel, U. Olshevsky and Y. Becker,
"Particles Released from Arginine Deprived Human Leukemic Cells,"
Nature (New Biol.), 244:197t (1973).
122a. R. E. Gallagher and R. C. Gallo, "Type C RNA Tumor Virus Isolated
From Cultured Human Acute Myelogenous Leukemia Cells," Science,
187:350, (1975).
123.	J. U. Gutterman, G. Mavligit, K. B. McCredie, G. P. Bodez, E. J.
Freireich and E. M. Hersh, "Antigen Solubilized from Human Leu-
kemia: Lymphocyte Stimulation," Science, 177slll4, (1972).
124.	p. J. Fialkow, J. I. Bryant, E. D. Thomas and P. E. Nieman, "Leu-
kaemic Transformation of Engrafted Human Marrow Cells in Vivo,"
Lancet, 1:251, (1971).
125.	L. V. Melendez, R. D. Hunt, M. D. Daniel, C. E. 0. Fraser, H. H.
Barahona, F. G. Garcia and N. W. King, "Lymphoma Viruses of Mon-
keys: Herpesvirus Saimiri and Herpesvirus Ateles, the First Onco-
genic Herpesviruses of Primates—A Review," in Biggs, P. M., de-
The, G. and Payne, L. N.»eds,: Oncogenesis and Herpesviruses,
Lyon, Int. Agency for Res. on Cancer, (1972), pp. 451.
126.	L. Falk, J. Wright, L. Wolfe and F. Deinhardt, "Herpesvirus
Ateles: Transformation in Vitro of Marmoset Splenic Lymphocytes,"
Int. J. Cancer, 14:244, (1974),
127.	R. M. McAllister, "Viruses in Human Carcinogenesis," Prog. Med.
Virol.. 16:48, (1973).
63
-------
Page 12
128.	T. Albrecht and F. Rapp, "Malignant Transformation of Hamster
Embryo Fibroblasts Following Exposure to Ultraviolet-irradiated
Human Cytomegalovirus," Virology, 55:53, (1973).
129.	D, J. Lang, L. Montagnier and R. Latarjet, "Growth in Agarose
of Human Cells Infected with Cytomegalovirus,M J. Virol., 1^:
327, (197*0.
130.	L. P. Weiner, R. M. Herndon, 0,. Narayan and R. T. Johnson, "Fur-
ther Studies of A Simian Virus 4o-like Virus Isolated from Human
Brain," J. Virol.110, 1*1-7» (1972).
131.	E. 0. Major and G. DiMayorea, "P/Ialignant Transformation of BHKg^
Clone 13 Cells by BK Virus A Human Papovavirus," Proc. Natl. Acad.
Sci. U.S.A., 70*3210, (1973). .
132.	A. E. Churchill, L. N. Payne and R. C. Chubb, "Immunization A-
gainst MarekBs Disease Using A Live Attentuated Virus," Nature
(Lond.), 221: 7*^» (1969).
133.	F. Rapp and R. Duff, "In Vitro Cell Transformation by Herpes-
virus," Fed. Proc., 31»l66o, (1972).
13**. G. Miller, J. Robinson, L. Heston and M. Lipman, "Differences
Between Laboratory Strains of Epstein-Barr Virus Based on Immor-
talization, Abortive Infection and Interference," Proc. Natl.
Acad. Sci. U.S.A., 71i*M>06, (197*0.
135.	R. Laufs, "Immunisation of Marmoset Monkeys with A Killed Onco-
genic Herpesvirus," Nature (Lond.), 2^9:571* (197*0.
136.	W. Jarret, L. Mackey, 0. Jarrett, H. Laird and C. Hood, "Anti-
body Response and Virus Survival in Cats Vaccinated Against Fe-
line Leukaemia," Nature (Lond.), 2*1-8:230, (197*1-).
137.	R. Hoover and J. F. Fraumeni, Jr., "Risk of Cancer in Renal-
transplant Recipients," Lancet 2:55» (1973).
138.	R. Latarjet and J. F. Duplan, "Experiment and Discussion on
Leukaemogenesis by Cell-free Extracts of Radiation-induced Leu-
kaemia in Mice," Int. J. Radiat. Biol., 5J339» (1962).
64
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INTERNAL MEDICINE
PULMDNARY DISEASE
BY APPOINTMENT
GEORGE P. LORD, M.D.
7 BRAMHALL STREET
PORTLAND, MAINE 041D2
Telephone 772-1B77
January 29, 1976
Mr. John McGlennon, Regional Administrator
JFK Federal Building, Government Center
Boston, Massachusetts
Dear Mr. McGlennon:
I appreciate the opportunity to review the Environmental Impact State-
ment for Scarborough, Maine, prepared by your office. It certainly re-
presents a great deal of work, and answers some questions relating to
the proposed sewer in Scarborough.
As a member of the concerned citizens of Scarborough and a candidate
for the sewer district in Scarborough, I have a continuing interest in
the problem. Among those whom I have asked to help is a we I I-respected
engineer, a member of the Army Corps, of Engineers, Mr. John MacLeer.
He is a personal friend and I have discussed the environmental problems
of Scarborough with him in an informal way. He would be most apprecia-
tive if he could receive a copy of the Environmental Impact Statement.
His address is below, and from what I understand of his co-workers, his
credentials are impeccable and I am sure he can do nothing but improve
the reception of this statement among those of us who remain concerned
about the treatment facility under consideration.
I appreciate your help.
Very sincerely,
J
George P. Lord, M.D.
GPL:smf
c: MacLeer
jMi 3 0
John MacLeer
60 EI an Street
Wickford, R.I. 02852
65
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QUALITY HOMES OF DISTINCTION
isbara Construction Co., Inc.
P.O. BOX 485
SCARBOROUGH, MAINE 04074
883-5528
January 28, 1976
Scarborough Town Council & Sanitary District Public Hearing
January 29 th
Town Hall - Route 1
Scarborough, Maine 0i|07ij-
T0 WHOM IT MAY CONCERN:
Rocco C. Risbara, Jr., Citizen of the Town of
Scarborough and Marcia Risbara wish to see Scarborough
have its Sewer and have its orderly growth.
Thank you
RO#CO C. RISBARA, JR
RCRrkfb
66
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January 28, 1976
Mr. John McGlennon
Environmental Protection Agency, Region I
JFK Federal Building
Boston, Massachusetts 02203
RE; EIS, Scarborough, Maine
Dear Mr. McGlennon:
As a member of the Prout's Neck community, I would like to propose an
alternative plan for the sewer outfall relative to Alternative I of
the Environmental Impact Statement for the Wastewater Collection &
Treatment Facilities, Scarborough, Maine. My idea as sketched in
blue on Figure 3.1-1, sec III-5, involves a complete bypass of the rock
ledge concerned -in the construction of the sewer outfall through Prout's
Neck.
As a matter of practicability, the present proposal to blast through
the Prout's Neck ledge appears absurd. At the maximum elevation above
high water mark the outfall will drop 40-50 ft. at a severe angle and
another 50-60 ft. to the ocean floor. The total descent involves a
vertical drop of 90-110 ft., at an extreme angle. As a point of logic,
the pipe cannot be exposed to the ocean waves along its descent and
must be dug into the rock at cost and degradation to the natural
rock formations. The proposed plan will also degrade the natural
setting of Prout's and may permanently damage its ecological setting.
The outfall, as I propose, should course around the extreme limits
of the rocky outcroppings of Prout's Neck. This alternative should
avoid all unnecessary blasting as the sandy characteristics of the
bottom can be dredged easily to clear an underwater trench within
which to drop the outfall pipe and cover it permanently. Advantages
to this proposal include a gradual angular decline, a no-frost situa-
tion, and a simplified and potentially less costly construction problem.
The determination of the outfall's terminal point can be the same as
the proposed site and dilution considerations need not be modified.
The new outfall pipe will involve a long gradual curve and can be
easily submerged with minimal disruption of ecological balances
within the area.
The overall construction costs should be minimized - labor, time for
construction and disruption to the quality of life will be substanially
reduced. The proposal is proved technologically feasible by recent
advances in the construction of submerged oil pipelines.
67
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Mr. John McGlennon
Page 2
Please seriously consider my proposal as it represents a superior
alternative to the present plan while assuaging doubts and concerns
for residents inhabiting Prout's Neck.
Sincerely,
OCTDEN T. ROSE
ffirout.' s Neck, Maine
Winter Address:
Box 272
Manchester, I:A
cc: The Honorable George R. Sprague
68
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FIGURE 3.1-1
Location of Key Facilities
in Alternative One
TREATMENT PLANT
PUMPING STATION
GRAVITY SEWER
FORCE MAIN
i
Southi
1 St«u-6«h
ap (, for Boy*
rEKCMANOi
mm
"»«d Of«i
Pleasant
Hill
¦Orfitill
i/r-f'L.
¦¦ >J

West Sosu-boVv
(UunsUnJ. -
r v '
Chlm
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February 12, 1976
The Honorable John McGlennon
Regional Administrator
Environmental Protection Agency
JFK Building
Boston, MA 02203
Dear Mr. McGlennon:
In this letter, I further my discussion of the Environmental Impact
Statement (EIS) for Scarborough, Maine (Re: Letter of 1/28/76).
I voice my largely philosophical concern as a member of the Scar-
borough community who is threatened by an ill defined need for growth
and the lack or an integrated growth policy. I believe that the
EIS should be re-assessed to determine the potentially negative
impact of its proposal. It should be re-directed and a positive
growth policy strategy should be promoted before any decisions are
made.
The lack of an integrated growth policy will lead to the deterioration
of Scarborough's semi-rural environment and create a poorly inte-
grated urbanized society. Without positive growth management, the
proposed sewer treatment facility will permanently disrupt the
natural and human environment of Scarborough. New alternatives must
be devised. In this letter, I discuss the cause-effect relation-
ships leading towards the proposed implementation of the EIS pro-
posal. I further my discussion by advising re-assessment of the
proposal.
The synergistic effect of uncontrolled growth on Scarborough may
seriously effect the town's environment. Despite sewerage treat-
ment plans, the quality of life and overall environment will be
impaired. The effect of growth is obvious. The demand for this
growth is not well established.
The EIS does not address itself to the causes of public demand as a
factor for growth,,and if a demand exists, it does not determine its
source. The EIS does not address itself to the need for development
of a sound growth policy for Scarborough. The EIS is severely
deficient in this respect.
Scarborough's growth was recently limited by a building moratorium.
It has terminated the rapid development that occured prior to 1973.
The causes for the moratorium were inadequate municipal sewerage
policy and developer irresponsibility for installing development
scale sewerage treatment facilities.1
1. Maine law allows development to occur if the developer installs
and maintains its own sewer system or if municipal sewerage is used.
70
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The Honorable John McGlennon
Page 2
The cause for the construction of the sewer project as well
as for growth demand is directly related to developers who will
not build unless the town supplies them with municipal sewerage.
Developers own a substantial portion of undeveloped land that
will be benefitted by Alternative One proposal. They plan to
build only when Alternative One is given the go-ahead and it
appears they will not take responsibility for constructing and
maintaining their own treatment facilities.
The growth of Scarborough should not be dictated by developers
alone. Development must be made orderly. Developers should be made
answerable to an integrated growth policy that Scarborough does
not have but should formalize. Before random development patterns
occur and before Alternative One is activated, an interactive
growth policy must be determined.
If in time, Alternative One is seen to be biased to benefit
anyone other than the total environment of the town, it should be
re-analyzed. The analysis must include all levels of Federal,
State and local governments as well as representatives from the
necessary private sectors.
The EIS does not address itself to the formulation of growth policy
objectives. Growth policy must be determined before Alternative
One is activated. Alternative One is deficient, its potential
negative impact is great on all levels of the natural and human
environments. It should be re-analyzed and integrated with an
inter-active growth policy before it can be accused of stimulating
environmentally destructive growth.
I would hope that these thoughts prove constructive. If you have
any questions, or wish to discuss my thoughts, please do not hesitate
to contact me.
I apologize for this letter's submission over the requisite time but
I feel strongly that the ideas contained herein should be taken into
consideration.
Sincerely,
0GDEN T. ROSS
liox 272
Manchester, MA 01944
71
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WAR 8 1976

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March 6, 1976
Prouts Neck, Maine
IN RE: DRAFT ENVIRONMENTAL IMPACT)
STATEMENT WASTE WATER COLLECTION )
AND TREATMENT FACILITIES IN SCAR-)
BOROUGH, MAINE	)
Mr. Wallace Stickney
U.S. Environmental Protection Agency
Region I
JFK Building
Boston, Massachusetts
Dear Mr. Stickney,
Briefly, I propose to state a series of opinions and facts to
indicate why "PlanA" is wrong for Scarborough, Maine.
When the D.E.P., following the Federal Guide Lines said they
favored a one plant system, the door was opened for the design of a
costly and massive system. One plant systems may be best in many
cases, but Scarborough, because of its size, geographical composition,
and population is unusual and needs a more imaginative concept.
The second compounding error in procedure that helped create the pro-
posed massive sewer plan was the selection of areas that needed to be
sewered. The D.E.P. examined seven watersheds, found them to have
high coliform counts and stated those areas had to be sewered. Per-
haps a more effective approach would have included going one step
further to determine by whom, how, and why this pollution was being
created,with the end in mind of making corrections at the sources.
These two unfortunate decisions should be reviewed, as they are the
root of the problem.
Next, I would like to state an opinion about the attitude of the
District Trustees, that also indicates a lack of business-like think
ing, that many people have come to believe is also a basic problem
with this type of decision making body. The District Trustees feel that
they have a mandate from Augusta and from the E.P.A. to clean up
pollution in the most cost effective way. They do not feel a need to
consider the results of evaluate them. Their job is one of getting the
TO BE INCLUDED WITH COMMENTS OF
CONCERNED CITIZENS IN OPPOSITION
TO RECOMMENDED ALTERNATIVE I
75
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page two
project completed—in fact, the D.E.P. is forcing them to vote
affirmatively on the only plan the D.E.P. and Whitman and Howard
have seriously considered.
There is evidence in the field that the work of Whitman and
Howard does not always measure up, and this is compounded by the
fact that the Trustees don't feel qualified to question their engin-
eers on technical matters.
Perhaps the most overlooked point, as far as the E.P.A. is
concerned is the future cost to the local taxpayers, but this is
most important to us. We do not wish to burden the people in Scarb-
orough for generations to come with sewer costs that could have been
greatly reduced simply by having imaginative engineeririgwithout the
inane D.E.P. requirements, previously mentioned. Who is going to pay
for the maintenance of an ocean out-fall placed in a location recogniz-
ed for its powerful surf? Will it be the Scarborough user, the Scarbor-
ough taxpayer, the D.E.P.?
Our town budget is $5,000,000. The users' fee will take an
estimated $450,000 (9%) more from Scarborough taxpayers, and there is
good reason to believe this will be insufficient. To spend $19,173,000
for 1377 units, 258 of which are already on the present sewer,
($13,924 per unit) is beyond any measure of common sense. By compar-
ison $87.88 is the user fee in Ogunquit, Maine	the Scarborough
proposal is between $200-$237, or 2.7 times more expensive.
Your office has final responsibility in this matter. This is
because no provision was made for review by the voters, through
referendum. The only body the exercises any control seems to be the
E.P.A.. This is a good example of how and why the taxpayers' money
is often proposed to be spent imprudently.
In closing, may I suggest that a Value Engineering Study be
undertaken, with particular emphasis on determining an alternate
concept that would be less expensive, and less damaging to the
environment.
rumcao opi a^uc
P.S. Will you kindly let me know the decision, when it is made--and
the reasons for reaching it? Thank you
Sincerely yours
76
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MAR b 1976
STATE OF MAINE
CUMBERLAND, SS.	March 5, 1976
IN RE: DRAFT ENVIRONMENTAL IMPACT
STATEMENT WASTE WATER COLLECTION
AND TREATMENT FACILITIES IN SCAR-
BOROUGH, MAINE
) .COMMENTS OF CONCERNED CITIZENS
) IN OPPOSITION TO RECOMMENDED
)	ALTERNATIVE I
TO: U. S. Environmental Protection Agency
ATTN: Wallace Stickney
Region 1
JFK Building
Boston, Massachusetts
Gentlemen:
We represent the Scarborough Citizens Ad Hoc Sewer Commit-
tee which is opposed to the recommendations for adoption of
Alternative 1 made in the "Draft Environmental Impact Statement
Waste Water Collection and Treatment Facilities in Scarborough,
Maine" prepared for the Environmental Protection Agency by Booz,
Allen and Hamilton, Inc., of Bethesda, Maryland, and dated
November 26, 1975.
Representatives of the Scarborough Citizens Ad Hoc Sewer
Committee appeared at the hearing which the EPA held in Scar-
borough, Maine, on January 29, 1976, and testified in abbreviated
fashion in deference to the hearing officers and the length of
time allocated for the hearing. We were, however, assured that
the more fulsome written statements of these same witnesses will
be read in detail by responsible officials of the Environmental
Protection Agency and the hearing officer, Mr. Stickney, extended
the time within which to file more fulsome statements to March 7,
1976.
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-2-
Accordingly, we are herewith submitting the following state-
ments of representatives of the Scarborough Citizens Ad Hoc Sewer
Committee for your consideration in reviewing the Draft Environ-
mental Impact Statement and judging its adequacy:
1.	Statement of Lillian C. Lee, former Trustee
of the Scarborough Sanitary District, biology teacher
and master of public health. Mrs. Lee's statement
discusses in great detail the failure of the Draft
Statement to adequately consider the alternatives
which were considered, failure to consider all
reasonable alternatives, failure to adequately
examine the adverse impact of the proposed discharge
upon the public bathing beach and shellfishing beds,
failure to consider alternative treatment systems
and alternatives to the proposed degree of treatment
and its failure to adequately consider the secondary
effects of the plant upon the growth of the Town and
the costs of the plant and of the system to the cit-
izens. Finally, Mrs. Lee sets forth some of the
alternatives which were available for review by the
drafters of the Draft Statement but which were not
considered.
2.	The statement of Drs. Levy, Lord, Ritchie,
Higgins and Maier, well-known, recognized and qualified
physicians and scientists. This statement discussed
the proven potential health hazard to Scarborough cit-
izens and its visitors from the massive proposed dis-
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-3-
charge into the ocean, the health hazards which could
result from the uncontrolled disposal of sludge, the
inadequacy of the Draft Statement to consider more
sophisticated yet less expensive methods of treatment
and failure to consider the impact of the discharge
upon Scarborough's vacation industry, one of the Town's
most important revenue sources.
3.	Statement of Mr. K. Cashman, a former member
of the Scarborough Planning Board. This statement
discusses the failure of the Draft Statement to
adequately consider the substantial impacts which
Alternative 1, if adopted, would have on the community
growth in Scarborough and discusses the failure of the
Impact Statement to adequately discuss the substantial
adverse effect of storm water runoff resulting from
construction of the plant upon water quality.
4.	Statement of Mr. R. Pelletier, accountant.
This statement discusses the general inadequacy of the
Impact Statement and the projected costs of Alternative
1, particularly with regard to the user fees which are
likely to result.
5.	Statement of Robert Hodgdon of the Higgins
Beach Association (which has a membership of over 170
people). This statement points out that the proposed
Alternative 1 would only abate a serious problem at
Higgins Beach and not solve it, that the proposed Alterna-
tive 1 would result in unreasonable and exhorbitant
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-4-
costs to the citizens of Scarborough, and finally
indicates support for a local treatment plant to deal
with the Higgins Beach problem.
6.	Statement of Mr. William J. Brooks. This
statement summarizes many of the comments made by others
but also points out the serious problems presented
by the geology of Scarborough and reviews the serious
problems resulting from uncontrolled storm water run-
off.
7.	Statement of John H. Lee, President of the
Scarborough Taxpayers Association. This statement
points out the total neglect of the Draft Statement
to deal with the problem of the disposal of sludge
resulting from the treatment plant, the contradictions
in population estimates in the report, the contradic-
tions in user cost estimates in the Draft Statement,
and summarizes some of the comments made by other
witnesses.
8.	Petitions signed by over 600 citizens of the
Town of Scarborough in opposition to the recommended
plan.
9.	Petitions signed by over 350 citizens of
Scarborough (some of whom signed the petition referred
to in paragraph 8 above) requesting more planning.
The Scarborough Citizens Ad Hoc Sewer Committee represents
approximately 325 citizens but believes itself to be representative
of at least 1,000 citizens of the Town of Scarborough. Specif-
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-5-
ically, the Scarborough Citizens Ad Hoc Sewer Committee consists
of the Higgins Beach Association with over 170 members, the
Scarborough Taxpayers Association, with over 100 members, the
Scarborough Sensible Sewer Committee with over 20 members, the
Concerned Citizens Committee with over 25 members, and over 10
individual members.
It is the position of the Scarborough Citizens Ad Hoc Sewer
Committee that the Draft Environmental Impact Statement is inade-
quate and fails to comply with the provisions of 40 C.F.R. Section
6.304 in the following general respects:
1.	The Statement is a justification for decisions
already made.
2.	The Statement was prepared without using a
systematic interdisciplinary approach and does not
incorporate all relevant analytical disciplines to
provide meaninful and factual data information and
analyses.
3.	The Statement does not include all facts
necessary to permit independent evaluation and appraisal
of the beneficial and adverse environmental effects of
alternative actions.
4.	The Statement purports to be written in the
context of a decision not having been made and purports
to not favor any one alternative yet fails to treat
all feasible alternatives at similar levels of detail.
5.	The Statement is inadequate and indeed in
some cases inaccurate with regard to the land use
81
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-6-
patterns and population trends in the project area.
6.	The Statement fails to weigh all feasible
alternatives and is a far cry from the required
"rigorous examination of all alternatives".
7.	The Statement fails to describe the many
secondary environmental impacts resulting from the
adoption of the alternatives, particularly Alternative
1, and more particularly the secondary environmental
impact of the disposal of the sludge resulting from
the treatment plant and the adverse environmental
effects of the massive amount of inadequately treated
sewage proposed to be discharged into the ocean and
equally importantly, the impact upon the development
of presently undevelopable land within the Town of
Scarborough.
8.	Many of the scientific conclusions in the
Statement are based upon inadequate scientific research
and depend upon faulty methods of research.
9.	The Statement fails to consider the long-term
productivity of intertidal zone resources to the extent
that its premises are at best incomplete and in some
cases incorrect.
10. The Statement fails to give consideration
to windfalls to be gained by owners of presently
undeveloped and undevelopable property if a sewer
is constructed.
While we urge you to read thoroughly each of the written
82
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-7-
statements enclosed herewith, we would point out the following
comments contained in the statements and expanded on therein:
1.	The impact of the construction of the sewage
plant for three miles of rural farmland is not con-
sidered.
2.	The impact of the actual construction of
the sewer pipes and construction of the treatment
plant itself upon the environment is not considered.
3.	The probable need for blasting in areas of
frontal dunes is not considered.
4.	There is no plan for dealing with the 3,000
to 4,000 cars per day which traverse the area at Higgins
Beach during the summer, during the construction period.
5.	There is no serious consideration given to
the problem of sludge disposal. Region 1 of the
Environmental Protection Agency should be especially
sensitive to this failure having had recent unfortunate
experiences with the Paris Utility District of South
Paris, Maine, which failed to provide for sludge dis-
posal until the treatment plant in South Paris was on
line.
6.	The Statement contains nothing to enable
the Environmental Protection Agency or citizens of
Scarborough to determine the cost of sludge disposal
and the effect of its cost upon capital outlay and
user fees.
7.	The Statement fails to pinpoint the precise
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location of the proposed Prout's Neck outfall and
accordingly does not adequately predict the ocean
flow of the secondarily treated waste from that
outflow.
8.	The essential study of the current flows
in the areas in which the waste is proposed to be
discharged were discounted by the engineers solely
because results of the tests indicated serious
problems with the proposed Alternative 1.
9.	The Impact Statement examined only those
time-worn solutions offered by the Scarborough
Sanitary District engineers, Whitman & Howard, and
no consideration was given to alternative suggestions
by engineers other than Whitman & Howard.
10.	The costs and the primary and secondary
environmental effects of proposed Phase 2 and Phase
3 of Alternative 1 are wholly omitted.
11.	The draft Thomas Griffin plan, which could
result in a less expensive and less environmentally
damaging treatment solution, was wholly disregarded
(see statement of Lillian Lee).
12.	The proposed alternative of transferring
some of the wastes to Old Orchard for treatment was
not considered, despite the fact that the Town Manager
of Old Orchard in a letter to the Town Manager of
Scarborough dated January 27, 1976, indicated serious
84
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-9-
and active interest on the part of the Town of Old
Orchard in receiving some of Scarborough's wastes
(Old Orchard letter attached as Exhibit B to State-
ment of Lillian Lee). The Statement failed to consider
the possibility of transferring some of the waste
from the Town of Scarborough to the Town of South
Portland. That possibility was dismissed with an
explanation that South Portland officials were not
interested in the proposal and that the Department
of Environmental Protection indicated that it would
not stand for any delay in the construction of treat-
ment plants in the area. As explained in Mrs. Lee's
statement, the City of South Portland was not
specifically approached by officials of the Scarborough
Sanitary District with any proposal nor were there
any serious discussions between Scarborough Sanitary
District officials and officials of the City of South
Portland. There is no indication that sending some
of the Scarborough waste to South Portland would
result in any delay in the construction of the South
Portland waste treatment plant.
13.	The Statement's estimates of 1975 population
is in error by a factor by 35% and omits 26% of all
of the family units in Scarborough from its estimate
of the population. Thus, projections based upon such
estimates are equally in error.
14.	The testimony and the Statement indicates
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-10-
that the citizens and the Environmental Protection
Agency have been informed of at least three dif-
ferent user fees and the most likely user fee, i.e.,
$322 per household per year, as set forth in
statements of Mr. Pelletier and Mr. John Lee, is
not discussed at all.
15.	The Statement bases its projections of
the effect of the proposals on growth by assuming
a growth in the Town of 100 family units per year.
As pointed out in the statement of Mr. John Lee,
this growth is understated by at least 271%.
16.	The Statement fails to adequately deal
with the likelihood of up to 300,000 gallons per
day of untreated waste being discharged into the
ocean surrounding Scarborough as pointed out by
Drs. Levy, et al in their statement.
17.	There is inadequate discussion of the
possibilities of ozone treatment and an erroneous
assumption in the Statement that "monitoring is a
problem". As pointed out in the statements of
Drs. Levy, et al, the monitoring of ozone treatment
is no longer a problem.
18.	The Draft Statement fails to consider what
improvement in water quality could be achieved by
better housekeeping in the use of present treatment
facilities and enforcement of present land use and
water pollution laws.
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-11-
We have not attempted to summarize all of the comments
contained in the statements attached hereto or made by the
citizens orally at the hearing on January 29.
However, for the reasons set forth in this memorandum
and as supported by the facts contained in the written and
oral statements of the citizens of Scarborough, it is our
position that the draft Environmental Impact Statement fails
to meet the requirements of the Code of Federal Regulations
and that it should be rejected and returned to the drafters
of the Statement for a more fulsome, honest and truthful
attempt to comply with the requirements of the Federal Code
and with directions to those drafters to engage in extensive
interviews with all of the citizens who have made comments, and
to develop a more realistic, less expensive, more responsive
plan for dealing with the waste treatment problems of the Town
of Scarborough.
Finally, I would appreciate it, if when you have made your
decision, you notify me as the representative of the Scarborough
Citizens Ad Hoc Sewer Committee, of that decision, in writing,
so that we may take whatever action is appropriate in response
to your decision.
ESM/cld
Enc.
cc: William R. Adams, Jr.
George C. Gormley
Dennis Purington
Very truly yours,
E. Stephen Murray
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3 Fern Circle
Scarborough, Maine 04074
February 7, 1976
Mr. Wallace Stickney
U.S. Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. Stickney:
In reply to your request at the Scarborough Public Hearing for
comments on the "Draft Environmental Impact Statement, Wastewater
Collection and Treatment Facilities, Scarborough, Maine" by Booz,
Allen and Hamilton, Inc. I have four comments and a question.
(1) In so far as this is an environmental impact statement - rather
than a planning report - a number of the errors it contains are
probably not that significant (such as the number of beaches in
Scarborough). However, when the errors cause the wrong inferences
to be drawn in terms of the subject at hand they can be quite
serious. Just one example will suffice. On page 11-63 one finds:
In terms of state coastal planning priority areas, Scarborough
lies in priority area 6. Priority was established by the
state according to pressures for development of coastline
areas. This would indicate that pressures were greater in
coastal areas other than Scarborough. (Italics Added)
The further inference which the reader draws from this is that
there are no great development pressures on Scarborough compared to
the rest of coastal Maine; however, the basic fact upon which any
such inferences rest is wrong. The Coastal Planning Unit's
philosophy has been to put high priority on those areas which can
yet be saved, that is, the areas as yet uncontaminated by already
existing rapid development. To see that Washington County is
Priority 5 and York County is Priority 7 is proof enough (at least
one hopes that for those who may not know much about Maine this
statement alone will do). Further proof is found & the Coastal
Planning Unit's statement setting their priorities on the basis of
areas where there is considerable pressure to develop unused land,
where little or no planning activity has existed or is underway,
where there is a lack of soil surveys, and where unique, fragile,
highly significant environments exist ("The Penobscot Bay Resource
Plan", Maine State Planning Office; Augusta, Maine; 1972; page 5).
For a further understanding of the full implications of "unused"
land and "unique, fragile" environments one has only to refer to
88
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2
the major work of the Coastal Planning Unit's chief consultant at
the time this priority system was established. Reed and D'Andrea's
"Conservation Priorities Plan of the Coast of Maine" was based
entirely on the concept of saving as yet unpressured areas before
they too, like Scarborough, were discovered and lost.
The reason for dwelling on minor mistakes such as this is that
whole efforts can be discredited on the basis of such flaws. Of
course when the flaws grow large enough or numerous enough the
whole effort should be discredited.
(2) I am not going to tell you if the latter case is true here.
Since it is quite evident that Booz, Allen and Hamilton have failed
to do much of their homework I hardly feel you can expect the
citizens of Scarborough to make up for their deficiencies by doing
a point by point critique (particularly in light of Point 3 below);
however, I will state that improper preparation is a major fault in
their Environmental Impact Statement. The Scarborough estuary has
been one of the most heavily monitored in the State of Maine. I
have found no reference to this past work nor to all the past
citizen comment made at the various hearings which have been
conducted over the years. A complete review of all past and
present relevant data is obviously important. Although it might
not change the thrust of the present EIS one bit, the point is that
without it we will never know. Like the obvious mistakes
mentioned above this is another deficiency which makes one question
the whole foundation of the report.
(3) Another reason that this information, especially that which one
can draw from past hearings, is important is the disregard which
Booz, Allen and Hamilton have shown for citizen participation.
Having little regard for personal interaction with a wide spectrum
of the Townspeople the least they could have done was perform a
thorough review of past citizen arguments and actions. The need to
include citizen comments and ideas at the start rather than at the
conclusion of such an investigation may be obvious; however, since
it has been so blatantly disregarded I feel it necessary to review
the reasoning involved here. One may feel in agreement with many,
even all, of the elements of an EIS and yet feel compelled to
disagree with it, to be downright destructive in fact because he or
she, in spite of a well known interest in the project, has not been
consulted. As one water resources planner recently said to me,
"You can plow through stacks of literature on citizen participation
but it all repeats itself." I would add that it all repeats itself
on one major point: the need to include meaningful, active citizen
participation in the formative stages of a study or a project, not
as passive critics once it is a fait accompli. EPA's own study on
"Use of Environmental Analyses on Wastewater Facilities by Local
Government" (J.C. Fensterstock and D.M. Speaker, July 1974, page
20) clearly identifies the problem of "early public participation
89
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3
in initial planning stages, including initial conceptual
approaches" (Italics Added). In contrast to the case of not fully
reviewing relevant data here one can unequivocally state that fuller
participation of citizens at the very start would have produced a
much different report - a much completer and a much sounder report.
(4) Let me give just one example of a point I offered to interject
many months ago when representatives from Booz, Allen and Hamilton
were in Maine. The point was originally raised by Robert Hunter in
his early engineering reports (1961-1963) and in his evaluation of
various proposed alternatives for the Maine DEP (1974). It has to
do with the increasing impact of conservative pollutants from (at
this point) virtually uncontrollable non-point sources accompanying
increased growth in the fragile crescent surrounding the estuary. I
realize this is still very much an open question. Only recently has
the whole problem of urban stormwater runoff been redefined from one
of getting rid of it with the least effort to one of recognizing its
pollutant components, and if the problem is still being defined, the
solutions are even further off. In spite of this the whole question
cannot be simply dismissed. On page VI-15 of the EIS we learn that
problems associated with the increasing non-point problem (suspended
solids, BOD, and nutrients) will have "no significant impact on
water quality." I have to raise my eyebrows slightly at this. When
I see a major 208 areawide water quality planning effort funded by
EPA in this region largely to cope with non-point source problems it
leaves me slightly bemused. However, when I see no consideration at
all given to all the possible conservative pollutants resulting from
proliferating runoff sources I have to start pounding my fist. Even
if it is only for the sake of a mere sham consistency I submit that
you must either do something drastic about the Environmental Impact
Statement or curtail 208 planning in Scarborough.
In the Maine DEP files (all completely open to the Maine public)
there are some notes taken by William Hinckley, former Chief of the
Engineering Section, on a meeting held in Scarborough between him,
the Town Manager, Mr. Steele, and representatives from EPA back in
the early 1970's or late 1960's. He sensed a lack of interest on
EPA's part in the Scarborough situation: it was too complicated, too
many non-point sources, no major "bad guys" one could go after. Let
us hope that in the intervening years EPA has become somewhat more
sophisticated in recognizing that a thousand non-point sources can
be even more difficult - and therefore more challenging - to deal
with in their complexity than one major pulp mill. And in so far as
they act cumulatively they can also be as threatening.
I have reviewed errors, omissions, lack of proper citizen
participation, and failure to fully describe the non-point
situation; now I would like to ask a question. As you know the
original decision (and one which I favor) to build a decentralized
wastewater system was blocked by marine interests because of its
possible impact on the estuary. At the last hearing I heard Bill
Bayley say he felt that the proposed centralized system with an
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4
outfall off Prouts Neck would yield no major Increase In clam
production. 1 am quite honestly dumbfounded. After all these years
and all this wasted money the marine Interests step forward and say
the alternative plan which by their veto power they in fact dictated
will not do any good either. This is not a criticism of the
engineers, your consultants, any government agencies, or the clam
diggers. It is a simple, bewildered "What is going on here?"
1 have tried to be brief and failed, but the failure is a result of
the GIS and not my verbosity. To counter any belief which may arise
in the minds of Scarborough citizens that this Environmental Impact
Statement has been done solely as an exercise by EPA in protecting
itself against any future court actions 1 feel that a much more
balanced report should be written - from the ground up, one which
gives a fully balanced view drawn up on the basis of thorough
research and real citizen participation.
Sincerely,
Richard Harvey \
copies: Fred Sheehan, Greater Portland Council of Governments
Dennis Purington, Maine Department of Environmental Protection
Gerald Appleby, Scarborough Sanitary District
91
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29 1976
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ENVIRONMENTAL I MP A CT . STAT EM 5NT .!
OVERSIGHTS CONCERNING COMMUNITY GROWTH
AND WATER QUALITY. /
Subpart E,paragraph 6.5^(a ) of the EPA rules and
regulations, Preparation of Environmental Impact Statements
states "Factors that must be considered In determining'If
induced"changes are significant include but are not limited
to: the land area subject to Increased development as a result
of the treatment' works;the relative Increase in population
which may. be induced;the DOtential for overloading sewage
facilltes;the extent to which landowners may benefit from
the areas subject to increased development; the,: nature of
land use regulations in the affected area and their potential
effects on the development."
A critical factor in determining the impact of water
treatment facilities on a community's natural and man made;
environment is the numerical increase and physical location
of population caused by the facilities. The Environmental
Impact Study has made population projections both with
and. without the proposed treatment facilities. They have
then drawn conclusions about the impact: of the proposed
facilities on the natural and manmade environment.
The Environmental Impact, Statement,Para. ?.?.?(1) Population
Profile States:"Projecting.populatlonfor any one area can
involve a variety of factors and components analyzed;
99
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however, the margin for error Is yrlde given the vagaries
of consumer trends and preferences. This margin:increases
6ach succeeding decade included within the span of
the projection. " The study bases its impact conclusions
on one populat ion project ion,recognizes the very wide margin
of error in population projections and yet does not address
the sensitivity of conclusions to varying population levels.
The conclusions concerning the proposed waste water facility's
environmental impact could substantially change if the population
trends were higher than assumed. No confidence level is
established for the population projections; therefore, how
realistic are the conclusions drawn from this imprecise data?
One purpose of the Environmental Impact Study l.s assesmment
of the impact of waste water facilities on the natural and
manmade environment. SPA Rules and Regulations,Subpart E,
para. 6.57(b) states "The impact statement section entitled1
•Environmental impact on the Proposed Project or Plan* shall
contain a description of the environmental impact that the V:-.
proposed treatment works or plan might have on the surrounding-
area. Both adverse and beneficial effects neied to be discussed."
The Environmental Impact Study concludes in paragraph 5. 1.5(
"Thus, the proposed actions would eliminate all the discharges
of untreated sewage into the estuaries of Scarborough and in
the Higgins Beach area. The water ouallty in these waters
would, therefore, be Improved."
This conclusion is reached without consideration of the
effects of runoff from adjacent land on estuary water nuality.
100
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The majority of the population growth projected /by the study
will settle on land around the Scarborough estuary. The map
of Fig. ?.zoning map of Scarborough) shows the estuary
surrounded by land zoned R-?, R-4,R-10 and B-l. All these
zones allow substantial, high density development. In addition,;
the map of figure ^.l-l(locatin of proposed key facilities
and general areas to be sewered.) indicates sewers will serve"
all areas surrounding the estuary. The present Scarborough
Zoning Ordinance allows land serviced by sanitary sewers
to be developed to the maximum density allowed in that zone.
These facts indicate a significant number of dwelling units
could be built surrounding the estuary. The map of figure
?.1-1(Natural Drainageways in Scarborough) shows all land
east of the turnpike drains into the estuary.
The concentrated development of dwellings around the estuary
will lead to a substantial increase in runoff, ^onclusion
reached in the Hunter-Ballew report was " Runoff from
developed land surrounding the marsh could offset any improvement
in water quality achieved by installing sanitary sewers."
No consideration has been given , in the Environmental Impact
Study, to the effect of increased runoff from developing lands
on estuary water quality. The effect of the proposed plan
allowing development of land adjacent to the estuary, the
increase in runoff from the developed land and the impact
of the runoff on estuary water quality has not been investigated.
This oversight violates the EPA Rules and Regulations, SubpartE
para. 6.5Ma). The study must Investigate the secondary effects
of the proposed water quality management strategy.
101
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JOHN! I.UK
8 C ARDOIIO
AD HOC
E.I.S.
COMMITTEE
2»i976
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January 29, 1976
Scarborough, Maine
To: The Environmental Protection Agency, Boston, Massachusetts
Subject: Hearing at the Scarborough Junior High School,
Scarborough, Maine, January 29, 1976
From: John H. Lee, President, Scarborough Taxpayer's Association,
Inc.
After a careful examination and study of the Environmental
Impact Statement, we find that there are many discrepancies
which should prevent fast action to approve Phase I of the
proposed sewer system for the Town of Scarborough. We shall
try to enumerate many of what we term deficiencies not paying
any particular attention to their order in the Environmental
Impact Statement.
The statement includes a great deal of information about
the disposal of sludge that is accumulated at the treatment
plant but how it is to be treated, where it is to be placed,
and how much it is going to cost has not been included in the
report. This additional cost is important to the taxpayers and
where it is to be dumped is a most important decision. Whitman
& Howard should have learned their lesson in So. Paris about
where to dump sludge yet there is nothing definite in the
statement. After the So. Paris treatment plant was built the
sludge problem came to light. I believe there were five hearings
before the DEP and I'm not certain if it has been settled yet.
I have here a brief regarding the incident and I'm sure the EPA
knows quite well that the sludge removal phase should be properly
defined.
103
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-2-
The statement has much to say about the outfall at Prouts
Neck but exactly where it is to be placed has not been pin-
pointed. A change of position could mean increases in cost and
furthermore could effect the waters more in one position than in
another.
The treatment plant is the first major construction but as
to where it will go does not seem to be definitely decided.
Why wasn't an option obtained on the necessary land that seems
most desirable? This delay in such a decision could mean another
increase of costs to the taxpayers and could be embarrassing to
settle.
Why hasn't the whole story been told on the sewering of
Scarborough? Facts and figures concerning Phase II and III
have been omitted from the statement yet this is an essential
part of the complete picture. It is important to the people in
Blue Point and West Scarborough that they know the answers.
The EPA should be concerned with an incomplete financial and
environmental review. Yes, we know the decision is on Phase I
relative to the grant but you should get the full story.
Why hasn't the statement included the plan of Thomas Griffin
Associates that was submitted to the Sanitary District and the
DEP some time ago? This plan was considerably less in cost
than any described in the statement. If it's to be decided on
cost effectiveness then the Griffin Plan is a great deal more
cost effective.
104
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-3-
Why was it that only one person from the opposition was
interviewed when many names of prominent persons with expertise
were given to the consultants?
Why was it that Whitman & Howard was called in after the
preliminary draft was out to help make changes for the final
draft without asking others to sit in?
Since we are trying to control pollution consideration
should have been given to the bale site relative to its leachate.
The more one reviews the Environmental Impact Statement, the
more one questions the reliability of it.
On page ii-30, table 2.2-2 (1975 population estimate of
Scarborough) the figure of 754 family units is very much in
error. The total of individual family units should be 1019
or a difference of 265 units. This effects other estimates in
the chart. The town annual reports will verify the difference.
Let us look at the user fee. Originally the user fee was
$137 until a decision had to be made to the DEP and the engineers
said it had to be at least $188. The total annual user fee
in the preliminary report was $163. Then, the final statement
appears and it's $200 or $237. The user fee for Phase II and III
was not included, hut if it were, using the information in the
statement, and combining it with Phase I, it would be approximately
$322. Shouldn't the EPA know these answers and how about the
taxpayers?
105
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-4-
It's only a small point, but it has to do with consistency —
on page 11-82 relative to "there are a few privately owned
ground water wells in Scarborough". The building inspector says
there are hundreds.
The consultants in reverse figuring from the projected
population in 1995 back to the estimated population in 1975
arrive at an annual figure of dwelling unit construction to be
139 per year, saying it was high and perhaps 100 would be more
realistic. But with a close look at the years 1970-1971-1972
there were 814 family units built at an average of 271 per year
with 511 being built in 1971. This building was taking place
with very little sewering. Did our consultants investigate the
R-10 area from Black Point Road to Route 1? What do you suppose
will happen with a large sewer in the ground and over 250 acres
zoned for R-10? There is capability for 8,000 people in that
area alone.
The draft states that we .will get our clams back and that
we will be able to do recreational digging, yet, one of our
state officials said a while ago that with the secondary effluent
going out at the neck it would be doubtful if we could ever
get the clams back. Now I ask you, in 1946 there were 118,000
bushels of clams dug plus all the recreational digging and our
present production is 10,000 bushel per year; we are told with
the building of the sewer we may increase our production to maybe
15,000 or 20,000 bu per year. Do you think that is getting our
clams back, 118,000 bu to 20,000? Far from it and nothing has
106
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-5-
been said about aqua-culture?
Scarborough has already done a great deal in cleaning up
its pollution sources. Humpty-Dumpty, Scarborough Downs, Prouts
Neck, Oak Hill, and some of Willowdale have made good headway
and there is no need to saddle the taxpayers with this huge
sewer that will burden the town. It can be done better and much
easier if other engineers were given a chance to compete but it
has been a closeout with Whitman & Howard.
Because of the many inconsistencies of the statement and
Whitman & Howard our taxpayers are concerned about the reliability
of both the statement and the engineers. The greatest bulk
of the material in the statement is from the engineers who have
the most to gain. Reference has been made to Hunter Ballew
but their work was a rehash of Whitman & Howard's writings.
There has been no real technical research by the authors or Hunter
Ballew to verify facts and figures given by Whitman & Howard.
Just an appraisal of the materials furnished by the engineers.
Even the size of the plant can be questioned. This past
week we visited the Kittery treatment plant built by Whitman &
Howard and it was only operating at 1/3 capacity. The attendant
blamed it on the reduction at the Navy year. Kittery is a 3 mgpd
such as is proposed in Scarborough. A visit to Kennebunk where
Whitman & Howard built two primary plants, one 3mgpd and a second
750,000 gpd, showed that it too was operating at about 1/3 capacity.
107
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-6-
Do we really need a 3mgpd treatment plant?
During our visits to many sewer plants last week we got the
feeling that our engineers were up to their necks in problems
with some of the towns — Ogunquit, Kennebunk, Old Orchard Beach,
Biddeford, Saco, and So. Paris. Some officials had a lot to
say and we were referred to the Maine Times relative to the Saco
situation at Factory Island and I'm sure the EPA is well aware
of this problem. I would like to read this quote by Mayor Zaitlin
of Saco relative to the Saco River Tannery that has been dis-
charging its effluent into the river: "The pollution problems
at Factory Island stem from faulty design and construction,
said Zaitlin. It was designed by Whitman & Howard of Boston
which also designed treatment facilities at Biddeford and Old
Orchard Beach. Those two towns have experienced considerable
problems also. I don't think the firm is reputable, said ZAitlin."
Here is an article from the Biddeford Journal in which Mayor
Boucher blames it all on Whitman & Howard which designed Bidde-
ford' s treatment system.
Now because of the many inconsistencies of the statement,
the appraisal of all of Whitman & Howard's material with no other
engineers' input, the lack of technical research to prove the
accuracy of the engineers' recommendations, the excessive user
108
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-7-
fees that will be charged, the omitting of Phase II and III
facts, both monetarily and environmentally, the assured increase
in growth that will take place effecting all town services so
as to steadily increase the taxes, we feel that the EPA should
delay any action and give the people in the town (who want gradual
growth) the chance to produce a better plan with 208 funds.
Furthermore, we recommend not to rush hastily in operation with
Whitman & Howard because of the many problems they have encountered
in the various towns mentioned.
Sincere thanks
John/Lee, President
Scarborough Taxpaye:
John/Lee, President
Scarborough Taxpayers Association, Inc.
109
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Ill
-------
TO: Environmental Protection Agency
PROM: three members of the Scarborough Conservation Commission
RE: ?ft vJjT0for the proposed Whitman and
Howard treatment plant for Scarborough
As Members of the Scarborough Conservation Commission, we real-
ize that there is a serious pollution problem within the town of
Scarborough, and that there is a grave need for sewage treatment—
but, for treatment that is cost-effective in teras of social, econo-
mic, and environmental criteria. The Booz, Allen, & Hamilton, Inc.
Environmental Impact Statement for the treatment facility as designed
by Whitman and Howard is an inadequate analysis in many respects.
We would like to address ourselves to a few of the deficiencies of
that study,
POINT I: THE ENVIRONMENTAL IMPACT STATEMENT GIVES INSUFFICIENT CON-
SIDERATION TO THE INCREASED VOLUME OF TRAFFIC, AND TO THE NOISE POLLU-
TION GENERATED BY THIS TRAFFIC, IN A PRIMARILY RESIDENTIAL/RECREATIONAL
AREA. See Chapt. 5, sect, 4, pp. v-6, v-22.
We find the study to be lacking in terms of the increased and
heavy traffic on Ferry Road and the Black Point Road. These roads
are basically residential and are already experiencing congestion
during ®any months of the year as access roads to towa-? and state-owned
beaches. These trucks would »lso be operating in areas where there
is substantial pedestrian traffic: on the road to the beach, passing
in close proximity to the beach parking lot, and passing through a
crolfers' crossing. (In regard to noise pollution, please see attached
information sheet.)
POINT II: THE ENVIRONMENTAL IMPACT STATEMENT GIVES INSUFFICIENT CON-
112
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2
SIDERATION TO THE EFFECTS OF THE BLASTING NECESSARY TO LAY AN OCEAN
OUTFALL AT PHOUTS 1ECK. See Chapt. 5, sect. 4, p. v-2.
We find the study to state only that blasting will be neceesary
to lay an outfall pioe. There is no detailed Information regarding
possible effeets of this blasting on the animal and plant life of
the surrounding area.
POINT III: THE ENVIRONMENTAL IMPACT STATEMENT GIVES INSUFFICIENT
CONSIDERATION TO THE LONG-RANGE EFFECTS OF DESTROYING DUNES WITHIN
THE AREA OF THE PROPOSED PLANT, TO POSSIBLE DAMAGE TO THE STATE-OWNED
SALT MARSH AND FRAGILE ECOSYSTEM DIRECTLY ADJACENT TO THE PLANT SITE,
TO GENERAL DAMAGE TO THE AESTHETIC QUALITY OF THE AREA, AND TO Th£
HAZARDS OF BUILDING IN AN AREA HIGHLY SUSCEPTIBLE TO FLOODING, aec ftfc.5, Scd-f,
7p.v-l,v.9(v-i©,
The Scarborough Conservation Commission is presently working
with the Threshold to Maine, Resource Conservation & Development
Project of the Soil Conservation Service, U.S. Dept. of Agriculture,
to preserve and restore the sand dunes at Ferry Beach. Any destruct-
ion of dunes in that area would be counter-productive to these efforts.
(Please see attached pamphlet oil the value of dune areas.}
The location proposed for the building of this plant is in an
extreme flood hazard zone. In light of the problems encountered by
other plants constructed in flood plain areas, such as in Saco, this
seems to be an undesirable site.
We would conclude that, as members of the Scarborough Conservation
Commission, we feel there are many serious questions in regard to
the environmental impact ©-P the proposed secondary treatment facility
which remain unanswered in the Booz, Allen, & Hamilton report. Fur-
ther, we realize that federal law requires municipal sewage treatment
to be of an advanced nature by 1983. In view of the fact that the
final phase of the proposed secondary plant will not be completed
until 1982, at the earliest, we feel that the funds required for con-
113
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sfcruction. would be aore wisely spent on a plant usinsj advanced treat,
raent, rather than to convert the Whitman and Howard secondary treat-
ment plant at a later date. In addition, advanced treatment would
be a sjore effective »eans of reducing the pollution content of the
effluent which would be produced, We therefore feel that the study
is deficient in its failure to consider alternate means of treatment,
and for the other reasons nreviously discussed. We would ask that
these deficiencies be corrected before a final decision on the Whitman
and Howard nrorcosal is made.
Respectfully sub*itted
Sandra A. Bradford, Conser
vation Commission
.	(a*.-JOvxJ.
(jL.s-'O-i U_. ~j-\. ••••
Charles L. Bradfon
Conser
vation Cohm., Town Council
QAlt/YU
tfebecca I. Warren, Conserva
tion Com»,
114
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The Environmental Protection Agency's noise control activities are authorized by the
"Noise Pollution and Abatement Act of 1970 (Title IV of the Clean Air Act)." The EPA
Officj of Noise Abatement and Control was established in April 1971.
The broad mission of the new EPA unit is to identify and classify causes and sources
of noise and determine their effects on public health and welfare. The enabling
legislation calls for the preparation of a special report to the Congress which will
include information on present Federal programs; State and local laws, regulations,
and enforcement capabilities; the state-of-the-art on control technology, and
recommendations on a long-range national noise abatement and control programs.
The law also requires that, for .lie first time, all Federal agencies include noise as a
consideration in preparing statements describing the environmental impacts of their
various projects. EPA has been given the responsibility for reviewing these
statements before they are submitted to the President's Council on Environmental
Quality.
Sound levels in decibels (dB) are calculated
on a logarithmic basis. An increase cf 10 deci-
bels represents a 10-fold increase in acoustic
energy while an increase of 20 decibels cor-
responds to a 100-fold increase in acoustic
energy.
However, the human ear also works logarith-
mically. Hence, cur perception of the noise
increase (loudness) works in such a way that
each 10 dE? increase in conn'", level is perceived
as approximately a diMir.lirr,1 ol loudness. The
noiso prodtby a h'Mv/ ir.:<-.k (HO docibelsl.
for c/.aiMftli¦, mjr, Iv/m.i: a:, lorn! as an alarni
f.lof.k (UU 11'•'.i!j«:I¦.). I.Ill (iMi/ 11an a\ loud ;r.
Inn-way traffic HU *:»•«.ih-'l1.;
Hie wi'jhli'i] A all'	unati". lln: fx<•-
;i:',|jori',i: of iir h'.j'ii m c if by (ilarin'i
mof.t <:i;i;>11a¦.i', f-ii lln: fr<;r;»i»• ur y faiui'j Of 1U0U
to GOO 0 H<;rt/ ' • on ml	measured using
A-v/Cig>itir.:j are often e:;sed as tlBA. The
chart below shows how sound interferes with
speech.
Sound Leveis and Human Response
Noir.*:
I nvH
Curves f.hnw How tho Li*vf-l nl Noise
Vmif.'S Willi Dist.mce
SO
°ts
%
T'lt/laneo Untwuuii I ;.:ki:r c. I..r.cr— it.
Conversational
!,V'J 3 Response	Effects	Relationships
Hearing
Effects
Carrier Dec*
Jet Operation
Jel Takeoff
(2G0 feet)
Discotneque
Auto Horn (3 fee!)
Riveting Machine
Jet Takeoff
(2,000 feet)
Gorti'ccn
t'M>
i Ax 1-n 1:V ^c.^i
•: L-ort

10 ;
3 6
Zo ;
to
o
Voiy Annoying
Hc.KiiK) (V.rn:u;
(U hour*.-.)
Annoying
Telephone Use-
Difficult
Quid
Very Quiet
Jus! Audiblo
1 hreshold ol
HiMfi-'O
UJ
Q.T
O:
<
IU
"v
O
H
1-
ID
ci
Z
o
c
Shouting in ear
SiuHitirnj a: ft.
Wr> loud
Conversation, ? ft.
Loud
Conversation, 2 ft
Lul.C
Conversation. -i i\
Normal
Conven-atiOn. 12 ft.
115
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Anchoring die sand
jby a network of little cabl
the beachgrass holds the d
Stephen B. Olsen and John A. Jagschitz
The Coastal Resources Center • Plant and Soil Science
NOAA Sea Grant • University of Rhode Island
Marine Bulletin Number 19
_ - .
\
/ . x
/ ix
' ¦ ¥
SfcJ
¦" '-~z.
\ I
11
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1
Sandy Point, Crescent. . . . Napatree, Misquamicut, Quonochon-
taug. . . . Ninigret, Charlestown. . . . Green Hill, Moonstone
. . . Jerusalem, Sand Hill Cove, Bonnet Shores. . . . Sachuest
. . . Tunipus. . . . Quicksand.
From Block Island to the mainland at Westerly, up the coast
and around Narragansett . . . over to Jamestown, Newport, Mid-
dletown . . . then to Little Compton—27 miles of open shoreline
and 30 magnificent beaches; 12,000 years in the making and re-
making. Rhode Island's barrier beaches, the narrow strips of land
made of sand and cobble and separated from the mainland by a
coastal pond or wetland, are the most fragile natural feature, of
our ocean coast.
These barriers were formed soon after the retreat of the
glaciers, when ocean waves and currents built sandbars across the
openings of shallow bays and coves. Gradually the sandbars be-
came spits that were exposed even at high tide. Then beachgrass
became established, and it worked with the wind to build low
dunes behind a wide sandy beach. The entrapped water behind the
barriers was sheltered from the forces of the ocean and became an
ideal place for salt marshes and a profusion of wildfowl, fish and
shellfish.
117
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2
The grass and the dune: a delicate system
The barriers that have evolved over these thousands of years
are a wonderful example of a delicate but balanced system, able to
meet a rigorous and constantly changing environment. The dunes
that protect the salt ponds from all but the most severe storms de-
pend upon beachgrass for their growth and survival. The blades of
grass trap windblown sand so that it accumulates around the plants.
As the sand builds up, the plants grow upward to escape being
buried. Beachgrass also develops a network of underground stems
that extends the plants laterally and further stabilizes the dune.
We therefore owe the dunes to the grass. When a dune is
stripped of its vegetation, it is exposed to the wind and its sand is
blown into the ponds. Without dunes the barriers can provide
little protection to the ponds and the low lying mainland.
Perhaps the most remarkable feature of the barriers is their
flexibility. These narrow strips of sand continue to survive when
rugged headlands are cut back by storms. Major hurricanes sweep
away anything on the barriers built by men and level all but the
highest dunes. But in the years that follow a storm, beachgrass
again takes hold and soon new dunes begin to form. Although the
barriers are continually reshaped they will, if left in their natural
state, survive.
Man: a new force on the barriers
In recent years a new force has come to threaten the bar-
riers, and it is one to which they cannot adapt. This force is man. As
the state becomes more developed, people in ever growing numbers
come to the barriers to swim, lie in the sun, fish and escape the
confines of an increasingly urban life. Not realizing the damage
they are causing, people walk through the beachgrass and drive
their beach buggies and motorcycles across the dunes. Although a
hardy plant, beachgrass has one great weakness; because the brittle
stalks snap easily the grass cannot survive trampling. Only a few
people crossing a dune at the same point will kill a strip of grass.
Wind erosion follows, making a cut into the dunes through which
waves may flow during the next big storm. The pressure of man
is relentless and it increases each year. Unless steps are quickly
taken many of our remaining undeveloped barriers will be badly
damaged and their beauty and effectiveness as protection against
storms much reduced.
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3
The hurricanes
The barriers are the first line of defense against the sea;
they suffer the full force of ocean storms. In the past 350 years,
every seven or eight years on the average, Rhode Island has been
hit by hurricanes. Thirteen of these caused severe coastal flooding.
What can happen on the barriers is illustrated by the effects
of the 1938 hurricane. At that time summer cottages and homes
lined most of the south shore barrier beaches. When the hurricane
struck in the late afternoon of September 21,1938 the destruc-
tion was staggering. Hundreds of people were cut off from the
mainland, and 48 people died on the barriers alone. During the
height of the storm the combination of sustained high winds and
low atmospheric pressure made sea level rise nine to twelve feet
above normal, submerging the lower dunes. Waves swept over the
barriers and across the ponds. Property damage on the barriers was
over ten million dollars. All but the few barriers with high, well
vegetated dunes were reduced to little more than sand spits.
In the years that followed, beachgrass became reestablished
and the dunes began to rebuild. Within a decade people had begun
to forget the storm; many houses were rebuilt where others had
been washed away. When the next major storm struck in August,
1954, there was another crop of houses to be destroyed. This time
the authorities had plans for evacuating people and only one life
was lost on the south shore barrier beaches. Property damages were
about six million dollars.
Today the number of houses on these same barriers is again
increasing. Many of these houses are built where dunes should be,
limiting the effectiveness of the barrier as a storm buffer. Experi-
ence should have taught us that barriers are best left in their natural
state and protected from man's misuse.
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4
The migration of the barriers
The barriers survive because they are flexible. Ever since
they were first formed, they have been slowly migrating shoreward.
The beaches and dunes you see today are not the ones that formed
12,000 years ago. Those are either on what is now the ocean floor
or have been reshaped and slowly rolled back to their present posi-
tion. This migratory process is caused primarily by a constantly ris-
ing sea level. The rate of increase has varied, but the trend has al-
ways been upward; the present rate is about one foot of rise every
100 years. This will account for an average horizontal loss of some
30 feet of ocean beach during this century. As sea level rises, the
seaward edge of a barrier is eroded and major storms wash sand
into the ponds. Slowly the sand and pebbles that make up the bar-
rier are rolled back into the pond. At the same time the ponds creep
inland and new marshes form. Evidence of this process can be seen
in the lumps of peat that are sometime^ exposed along the beaches.
This peat was laid down by marshes that grew behind an older,
more seaward barrier.
Though the net movement of the barriers is shoreward there
are short-term changes in their shape and position. Some build out
wider beaches and others are eroded. There are seasonal changes
every year. Generally the beaches are wide and slope gently to
the water's edge during the summer months when the ocean is
calm. In the winter, when larger waves are more common, the
beaches are eroded and become steep and narrow.
Photographs are by Robert ]. Izzo except those on page 3 and page 4 (left)
are courtesy of Providence Journal-Bulletin Company.
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5
The salt ponds
The ponds behind the barriers are a uniquely valuable fea-
ture of Rhode Island's coast. Their salinity varies, depending upon
whether or not a permanent breachway to the ocean is present. The
ponds with the greatest variety and wealth of plant and animal life
are those in which fresh and salt water mix. In these ponds salt
marshes flourish. These provide food and shelter to quantities of
juvenile fish and serve as nursery grounds for blackback flounder
and many other valuable species. They also support large popula-
tions of waterfowl. The tides wash organic matter from the marsh
into the ocean where it helps feed populations of coastal fish. In
the ponds, given the necessary mix of fresh and salt water, oysters,
soft-shelled clams, and quahogs flourish. Bluefish and striped bass
come there to feed.
However, the delicate balance of environmental factors in
the ponds can all too easily be upset by man. For example, stabiliz-
ing a breachway and thus increasing the flow of seawater into the
pond has drastic effects, some of them desirable, others not.
Changes in the shape of a pond may alter the patterns of flow that,
in turn, determine the presence or absence of certain plant and ani-
mal species. Pollutants of many kinds leach into the ponds when
the land surrounding them is developed. Many of the changes that
take place, however, are gradual and may not be noticed until the
damage has been done.
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6
Plant grass — but not much
The strength of the barriers lies in their flexibility. In major
storms they may give way, but if left alone they will quickly re-
cover. In the past people thought they could make the barriers more
effective as storm buffers if they built unbroken lines of high,
thickly vegetated dunes along the upper beach. In recent years,
however, many of the scientists working for the National Park
Service, which has spent millions on dune management, have recog-
nized that massive plantings of beachgrass too often only result in
increased erosion. On Cape Hatteras, for example, the man-made
dunes were too close to the ocean and were frequently eroded by
waves. Furthermore, the lack of washovers did not permit water to
flow across the barrier during major storms and relieve pressure on
the ocean front.
This does not mean that all dime building programs are mis-
guided. Much work can be done to correct the human misuse of the
barriers. Where dunes have been cut and eroded by people and
vehicles the damage should be repaired. A barrier with dimes con-
tinually exposed to wind erosion because of the wanton killing of
beachgrass is more vulnerable to small storms than it should be.
Unvegetated sand will blow into the ponds and hasten the land-
ward march of the barrier.
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7
Save the barriers
Above all, man must learn to recognize the value and fragil-
ity of the barrier beaches. We must recognize the importance of the
beachgrass and learn not to walk or drive on it. Local authorities
and citizen groups can do much to educate the public and to man-
age the barrier beaches and ponds. Individuals and groups can en-
courage town and state officials to:
—place brush or snowfences where the dune is eroding be-
cause walkers and vehicles have killed the beachgrass. After
the sand has begun to accumulate, plant beachgrass.
—restrict walkers and vehicles to the beaches and to marked
trails behind the dimes. Access across the dunes to the
beaches must be over stabilized pathways such as elevated
boardwalks beneath which the grass can grow undisturbed.
—ban vehicles and building from the dimes, and provide funds
for dune protection and rebuilding. Barrier beaches may be
zoned as conservation areas to rule out the possibility of
their development. Tax abatements may be granted to en-
courage owners to preserve barrier property in its natural
state.
The Rhode Island Coastal Resources Management Council
recognized the value and fragility of the barrier beaches when
adopting the following regulations to protect them in 1973:
1.	Persons are prohibited from walking on the dunes except
along marked trails or on boardwalks.
2.	Vehicles are prohibited from the dunes and are only per-
mitted on the beach with the Council's permission.
3.	Building is prohibited on all dunes and undeveloped
barrier beaches. The Council may, however, grant permits for
building on developed barrier beaches.
For more information about our barrier beaches and how to protect
them, the following publications may be obtained free by writing
to: Marine Advisory Service, University of Rhode Island, Narra-
gansett Bay Campus, Narragansett, Rhode Island 02882: (1) J. A.
Jagschitz and R. C. Wakefield. How to Build and Save Beaches and
Dunes. University of Rhode Island Marine Leaflet Series Number 4,
and (2) S. B. Olsen and M. J. Grant. Rhode Island's Barrier Beaches.
Volumes 1 and 2. University of Rhode Island Marine Technical
Report Series Number 5.
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Mr. Chairman, my name Robert Hodgdon, resident of Higgins
Beach. I am here representing the feelings and position of the
Higgins Beach Association. Our organization numbering over 170
people, has, for a number of years, been directly involved and
concerned as to all proposals which are designed to relieve
residents of contributing to sewage pollution.
Our organization has made it clear to the town over these
past years that the present 1,000 gallon septic tank located in
the marsh and maintained by the town is totally and legally
unsuitable to continue to serve over 100 dwellings and two hotels.
After reviewing the EIS (Environmental Impact Statement)
our organization can conclude the following:
1.	That under Plan A the problem of waste discharge
at Higgins Beach will be abated — ONLY at unreasonable
and exhausting costs to the resident landowners.
2.	That because of the need to reduce and eliminate sewage
pollution from 234 dwellings at Higgins Beach, it will
be necessary to lay a pipe through Rural Farm land
3 miles to pick up 53 homes in Prouts Neck.
3.	That the environmental impact created by construction
has not been treated or analyzed at all for Higgins
Beach in the EIC Study, particularly existing sewage
discharge and protection of the frontal dune area
from blasting.
4.	That there is no plan to control or divert the daily
average of 3300-4000 cars which go in and off Higgins
Beach driving the average summer days.
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5.	That if Higgins Beach did not exist, there would be
absolutely no economic or environmental justification
to extend a sewer line down Spurwink Avenue.
6.	And finally when isolated to Higgins Beach residents in
this area are going to have to pay an overbearing initial
outlay and a not affordable monthly rate (particularly since
most residents are here less than 1/3 of the year).
Our organization has found it difficult to comprehend most of
this report. However since no representation of the Federal
Agency doing the study interviewed any of our residents, we feel
obliged to tell you now what we have told the town before — as
a course of action.
1.	Our organization supports completely the proposal to
establish a small local treatment plant at Higgins
Beach to remedy a severe pollution problem — without
ever having to expand this plant.
2.	Our organiztion opposes providing sewer lines through
areas of the town that can be sewered by septic tank
systems either above or below ground.
3.	The cost of a Higgins Beach Sewer to both Higgins
Beach residents and to the future development of the
town, will be for far less according to figures available to us.
4.	That an immediate special study be undertaken to determine
the feasibility of the development of a small treatment
plant at Higgins Beach and relate these findings to the
present EIS study.
Personally speaking, this sewer program as outlined under
Plan A with its enormous capital and operational costs up front
could easily act as a 6th voting member on our Planning Board and
a silent town councillor on the Town Council.
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Judged by the standards set by the regulatory agencies, the enviromental assessment
incorporated in the plan is inadequate*
The proposed sludge disposal plan is based on the often tried, land spreading or land
fill method*
The history of 5LUDGE DISPOSAL LAND FILLS* in this area, is a horror story of mater
table pollution and unbearable odors*
In adjacent York County, a pollution control agency is awarding a #50,000.00 contract
to determine why Saco's Land Fill is polluting ground water and filling thB air with odors.
In our area, The Greater Portland Council of Goverments, C*0*G*, has determined that
a 13 million expenditure will be necessary to insure that the nan sludge, solid waste land
fill site, proposed for Scaroborough, will not pollute the water table or the air.
The environmental regulations for the proposed sludge landfill could eventually
cause this part of the project to cost the SEWER USER more than the actual treatment
process*
The molecules of gasss given off, by these land fills, are 100 times smaller than
the soil pores in the proposed clay linings of disposal 3ites*
The methane and carbon dioxide gases produced, can travel up to 600 feet through
clay. These gases raplace the ROOT 9YSTEM OXYGEN OF PLANTS* GRASSES AND TREES. CAUSING
THEflf TO DIE*
The escaping carbon dioxide is soluable in water and produces a hardness, which
renders the water unusable without treatment.
The proposed alternative disposal af sludge, by spreading on golf courses and medi&n
strips, runs headlcng into the disposal methods of the cities in our area, which will 3lso
be producing truck loads of sludge*
Land spreading, at best, is limited to certain times of the year, and the sludge will
be produced all year round*
The sludge from our present plant is beifig land spread* The? testing method used to
determine mjtal concentrations are selective!' rather than spectrographic in nature, and
the analysis, in effect, finds only evidence^pf those metals for which tests are made.
The dangerous build up of concentrated metallic compounds in the soil and water
WUST be taken into eonsideration*
Some other methods of disposal have been concidered in our general area*
Bangor is trying composting*
Saco is conslitertfigi i recycling sludae for production of a soil conditioner and
methane gas*
In other States, the sludge is incinerated to produce activated cerbon for use in
advanced treatment filtnr beds*
With no more imagination, than has been shown in the proposed sludge disposal, wb
can see that there are absolutely no long range plans made for the^_^ISP0S£L>_C£_jyjlJDGE(*
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The casual dismissal of sludge disposal by suggested land absorbtion, is not only
NAIVE, but it also AVOIDS THE REGULATIONS THAT PEWAND OETAILEO PLANS BE FORMULATED.
NINETY1 PER CENT of the homes mast of the Maine Turnpike are on mails, most of them are
shallow u/ells, UJith points driven into the ground. Much of the area is sandy, with a very
high water table.
THE ENVIROIVIENTAL ASSESSMENT, IN THE PROPOSED PLfcN, IS INADEQUATE!
ENGINEERING THAT SUBSTITUTES ONE PR CI BLEW £oR ANOTHER, A5 A SOLUTION, IS NEITHER VALID
OR ACCEPTABLE.
William A. Hillock
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SCARBGRO AD HOG E.x.S. GOMM.
571 PAYNE RD,SCARBORO,ME 04074
MR ULLAGE STICKNEY-DIR	JAN 29 1976
E.I.3. STATEMENT	HArtVEY WARREN-CHAINAN
E.P.A. HEARING
SCARBORO JR.HIGH SCHOOL
GGRHAM RD,SCARBORO,ME
DEAR isIR,
3IN0E THE E.I.S. DRAFT HA3 BEEN AVAILABLE FOR ONLY A SHORT TIME,TO THE
GtA^ivAL PUBLIC AND IN VERY LIMITED QUANTITIES,WE WOULD LIKE TO REQUEST AN-EXTENSION
OF 15 DAYS,TO ALLOW OTHERS TO STUDY AVAILABLE COPIES AND RESEARCH DATA FACM OTHER
oOURCEo .
IN AN EFFORT TG COORDINATE THE STUDIES AND PRESENTATIONS OF VARIOUS CONCERNED
CITI2EN3 AND GROUPS,WE HAVE FORMED THE AD HOC COMMITTEE.
THE CONCLUSIONS wE DRAW FROM THE E.I.S. IREiTHAT NO VIGOROUS INVESTIGATIONS
OR EXTENSIVE EXAMINATIONS WERE CONDUCTED TO COMPILE COMPREHENSIVE DATA FOR EVALUATION
IN THE E.I.S.;THAT THE ENVIRONaENTAL A3SE3MENT IS INADEQUATE AND THAT THE
PROPOSED CURE WOULD BE WORSE THAN THE DISEASE*
the various presentations ..ill show,that in our opiniontthat the engineering
DATA COMPILED FOR THE E.I.S. WAS OBTAINED FOR THE SPECIFIC PURPOSE OF SUPPORTING
THE OUTDATED TECHNOLOGY OF PLAN A.
THAT NOT ONLY -.AS
THERE A FAILURE TO VIGOROUSLY EXAMINE ALTERNATIVE TREATMENT SYSTEMS,BUT THERE WAS A
FLAT REFUSAL TO APPLY FOR 20b FUNDS TO SEARCH FOR AND EXAMINE OTHER PROPOSED
ALTERNATIVE SYSTEMS#	THAT THE DATA
COMPILED FOR THE E.I.S. PAID LIP SERVICE TO THE STUDY GUIDELINES,BUT FALLS FAR SHORT
OF THE GUIDELINES INTENT,.IN SHORT,IT IS SUPuRFlClAL AND WITHOUT DEPTH.
THAT MANY OF THE
CLAIMS MADE,IN THE E.I.S. DATA,ARE MISLEADING,ERRONEOUS AND HIGHLY SUSPECT..
THAT THE DATA SUPPLIED
FOR THE E.I.S, EXHIBITS A VERY SUPERFICIAL AND CALLOUS DISREGARD FOR THE SECONDARY
iiNVIRGN.-iiii*TaL EFFK0T3tOUR JOO YEAR OLD CLAM INDUSTRY IS DISMISSED AS RECkEaTICNaL^WE
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are told that urbanization will occur in our swamps ana wetlands,EVEN WITHOUT THE
PROPOSED UNLIMITED TREATMENT AVAILABLE,WE ARE TOLD THAT TREATMEOT PLANT SLUDGE WILL
GO AWAY,!? DROPPED IN A FIELD AND IGNORED#
PLAN a PRESENTS US alTH THE SOLUTION THAT URBANIZATION ..ILL CURE OUR RURAL
POLLUTION Pu^ LEM3. BROUGHT ON BY PaRTIaL URtf ANIMATION,
This BLUE PRINT FOR THE DES'i'rtUUTlON Or OUR HUKAL waY OF LIFE 13 UNAO'JEPTaBLk
A3 ONE OF THE.ALTERNATIVES FOR SEVERING THE WIDELY SEPARATED SECTIONS OF TOWN
DESIGNATED A3 CRITICAL AREAS*
YuURS TRULY,
HARVEY'WARREN
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Lillian C. Lee, former Trustee of SSD, Biology teacher with
specialization in marine biology. Master of Public Health
from Massachusetts Institute of Technology.
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I have carefully reviewed the Draft Environmental State-
ment on Wastewater Collection and Treatment Facilities for
Scarborough. I would like to point out errors and omissions
and a few inaccuracies by implication. In addition I would
like to mention the salient omissions of analyses which are
required by law and recommended by federal guidelines.
Ill ALTERNATIVES
As stated, "the objective of this statement is to consider
the wastewater collection, treatment, and disposal alternatives
which best protect the water quality of the waters of the State
of Maine, the shellfish harvesting areas, the bathing beaches,
and the public health of the citizens of the area." Plan A
falls short of the above.
Federal Guidelines, FWQA, Design, Operation and Maintenance,
Sept. 1970:
"B. Preparation of Plans and Specifications
111. Discharges to Shellfish ... or Recreational Waters
Discharges in close proximity to shellfishing beds, ...
or contact recreation areas should be avoided. Where
such discharges are unavoidable, special precautions must
be taken. In addition to the items listed above, the
following are recommended and may be required:
* * *
d. Sand filters or polishing ponds following secondary
treatment."
THE PROPOSED OUTFALL IS IN CLOSE PROXIMITY TO A PUBLIC
BATHING BEACH, (Jordan's) AND SHELLFISHING BEDS, (hen clams are
in abundance in this area and are harvested commercially).
Such discharges are avoidable by considering alternate sites,
et., split transfer, So. Portland or the present outlet with
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special precautions and advanced treatment.
Drs. Robert Ritchie, Richard Levy, et al, have addressed
the Public Health implications of the proposed plan. In addi-
tion, U.S.E.P.A. Guidelines under PREPARING A FACILITY PLAN,
Location of Facilities, states:
"c. ...locate outfalls where they will not affect shell-
fishing beds, and contact recreational waters."
Both will be affected with the present plan. Since the outfall
is in close proximity to shellfishing beds, it is not complying
with the law because it is discharging close to shellfishing
beds and recreational areas without the recommended treatment
as referenced in Federal Guidelines. Moreover, stating that
shellfish beds can be opened without using the minimum treat-
ment required for shellfishing beds is misleading.
1. The Environmental Protection Agency's (EPA) Final
Regulations CFR 40-Part 6, Sect. 6.304 concerning EIS stated:
"The EIS shall develop, describe, and objectively weigh
feasible alternatives, including the options of taking
no action or postponing action. The analysis should be
detailed enough to show EPA's comparative evaluation of
the environmental impacts, commitments of resources, costs
and risks of the proposed action and each feasible alterna-
tive."
In addition CEQ Rules and Regulations, Title 40, chapter V §1500.8
states that alternatives include:
"The alternative of taking no action or of postponing
action pending further study; alternatives requiring actions
of a significantly different nature which would provide
similar benefits with different environmental impacts ...
alternatives related to different designs or details of the
'proposed action which would present different environmental
impacts."
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In this regard the EIS has inadequately and erroneously
weighed feasible alternatives and has not complied with the
above law.
A. PLANS PRESENTED BY THOMAS GRIFFIN OF THOMAS GRIFFIN
ASSOCIATES CO. WERE NOT CONSIDERED. The presentation of these
plans was made by Thomas Griffin at a board meeting November 15,
1974. Briefly the plan calls for the enlargement of the Oak
Hill Plant to 1.2mgd. It calls for the existing plant to be
converted from extended aeration to pure oxygen which would
increase capacity from 30-40%. This would be followed by sand
filters and backwashing. With adequate removal of particles,
disinfection with ozone to remove bacteria and viruses, it would
be possible that advanced treatment would discharge an effluent
of better quality than is now being discharged in the estuary.
The above could include Higgins Beach using a shorter, different
routing for Higgins Beach than the one proposed. Or, a separate
plant could be set up at Higgins Beach as proposed to the SSD
meeting December 18, 1974, by Mr. Robert Hodgdon. (Exhibit A)
SSD minutes December 18, 1974. Mr. Griffin's plan should be
considered because it costs significantly less and is more
favorable to the environment than Plan A. This is especially
true since it installs the interceptor along the abandoned
Eastern railroad bed, which removes the line from the precarious
position of being under the Scarborough River and does not require
a million dollar outfall in a nearly pristine area since the
better quality effluent should be allowable in the estuary through
the present outfall.
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B. ALTERNATIVES WHICH PROPOSED THE TRANSFER OF WASTE TO
SO. PORTLAND AND OLD ORCHARD BEACH WERE DISREGARDED ON THE
BASIS OF ERRONEOUS AND INADEQUATE ANALYSES. It is stated that
"transferring Scarborough's waste to So. Portland would require
changes in treatment plant design ... and the Maine Department
of Environmental Protection would not allow any delay in the
construction of the South Portland Project." EIS - 111 - 10.
Mr. Griffin, the consulting engineer, had stated that the So.
Portland plant is based on a twenty-five year design and could
accept waste from Scarborough without delaying construction of
the plant. The EIS does not present specific information in
this regard. Again the EIS has eliminated the Old Orchard Beach
plan with the same arguments that were presented for So. Port-
land. With respect to Old Orchard Beach, the EIS again does
not carefully present information to show that Scarborough
cannot tie in without delay of the project. In fact, I have
recently read a letter addressed to Mr. Applebee, Chairman of
the SSD, stating that "it might be advantageous to all partici-
pating communities ... to take on additional units". Exhibit B
(letter from acting Town Manager, dated January 27, 1976) Also
on November 14, 1974, at 4 p.m. a group consisting of SSD
Trustees, Beaulieu, Lee, concerned citizen Phineas Sprague and
Engineer Griffin met with the Town Manager of South Portland,
Mr. Ronald Stuart who informed us that no contacts were made with
So. Portland regarding regionalization. More recently, this past
week, Mr. Stuart reiterated over the telephone that aside from
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one meeting at a restaurant (Country Squire) on Route 1, around
1968, where the possibility of regionalization was discussed
to his knowledge no further contacts were made. He then went
on to state that he had not been approached, nor had the Town
Engineer, the Town Boards, or the Town Council been contacted
at any later time to discuss regionalization.
Another point which makes the split transfer more cost
effective going to So. Portland is cited in Thomas Griffin
Associates' letter to the board on August 5, 1974. Exhibit C.
The alternate route along the PTRR decreases the cost of going
to So. Portland.
With the above information, it is obvious that the two
alternatives which called for the transferring of wastes were
not adequately considered as required by law and must be reassessed.
C. THE EIS DOES NOT CONSIDER ALTERNATIVES OF A SIGNIFICANTLY
DIFFERENT NATURE AS IS REQUIRED. In actuality the treatment
technique studied is mainly biological treatment with activated
sludge with alternatives in transfer of the influent. From the
previous discussions, limitations of the biotic system have been
noted. These limitations have been noted in Rules & Regulations
Federal Register August 17, 1973: "It was recognized that
secondary processes are subject to upsets over which little or
no control may be exercised". There is an admission of possible
malfunction in the draft statement under alternative four. "It
is questionable also as whether any upset would exert as noticeable
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an impact as that which would occur at the Oak Hill facility."
At any event, a malfunction would cause a noticeable impact
wherever the outfall is located. Such a situation would mandate
looking at advanced further treatment or alternative treatment
techniques.
The EIS did not review possible physical chemical systems
or a combination of biological and physical chemical systems
for the town. After a brief review of the literature and having
talked to experts, it is clear that P-C plans could cost less than
biological systems in some instances and in any case are of
comparable cost (telephone conversation with Walter J. Weber, Jr.,
Professor of Civil and Water Resources Engineering, University
of Michigan).
Water Pollution Control, VoL 74, No. 3 pp. 303-311 (1975).
Water & Wastes Engineering, Vol. 11, No. 3 pp. 32-36 (Mr. 1974)
Water & Wastes Engineering, Vol. 12, No. 11 pp.52-55 (Nov. 1975).
"Physicochemical Treatment of Wastewater", Weber, Hopkins
and Bloom paper presented at the 42nd Annual Conference of
the Water Pollution Control Federation in Dallas, Texas,
October 5-10, 1969.
More specifically, the Superintendent of the SSD received
a letter dated November 1, 1974, from Telecommunications Industries,
Inc. which stated that their Sonozone treatment system produced
an effluent of much higher quality than biologically treated
effluent and construction costs for a typical facility of the
size needed in Scarborough would be equal to or less than the
cost for Plan A. Exhibit E
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With this treatment system, it may be possible to clean up
the polluted areas stated in the consent order by constructing
more than one treatment plant and the higher quality effluent
could be discharged in the estuaries. Please note: ADVANTAGES
OF PHYSICAL-CHEMICAL TREATMENT VS. CONVENTIONAL TREATMENT
"Several times in this discussion advantages of physical-
chemical treatment have been referred to. Perhaps the
most important is the stability of operation provided by a
treatment system based on physical and chemical technology.
Biological systems are notoriously sensitive to changes in
environmental conditions. If a toxic material gains even
temporary entrance to the plant or a hydraulic peak occurs
not only will the efficacy of the biological plant drop
off but recovery may take several days to several weeks.
In a physical-chemical plant the filtration system backs
up the clarifier and carbon system backs up the first two
thus upsets should be unlikely. In addition, it can be
expected that an immediate recovery of the plant will take
place once the source of upset is eliminated. This inherent
stability of performance is also reflected in greater design
and operational flexibility. Whole sections of a physical-
chemical plant can be cut in or out of the process stream
as required, and a temporary overload can be absorbed with
little effect. A list of many of the major advantages of
a physical-chemical system is given in Table 9. Most
have been discussed at some point in this paper." Physical-
Chemical Processes, Technology Transfer Design Seminar,
USEPA, ORD, NERC, Cincinnati, Ohio.
It is clear that the EIS has not considered these alterna-
tives of a "significantly different nature" and a review is
necessary before a decision can be reached.
D. ALTERNATIVES RELATED TO "DIFFERENT DESIGNS OR DETAILS
OF THE PROPOSED ACTION" HAVE NOT BEEN CONSIDERED, SUCH AS:!
Pure Oxygen Activated Sludge System
Different Size Plant
Different Lengths of the Outfall Pipe
Alternatives inadequately considered
eg. Ozonation vs. Disinfection
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The report states that "because of the concern of the
problem of monitoring the effectiveness of ozonation,
the design engineer was encouraged to select chlorina-
tion as a means of disinfection".
This conclusion is erroneous. It can be monitored arid
therefore cannot be disregarded prematurely without adequate
analysis as was done in the draft. Tii Exhibit D. Also reference
to Dr. Berg's statement was misleading in that it did not apply.
By definition, secondary treatment allows 30 mg/1 of suspended
solids and 30 mg/1 of BOD. Therefore, it is not free of solids
and does not meet the conditions to be 99% free of viruses.
Unfortunately, the public and press were misinformed by this
statement. Exhibit G.
From the above sections, it is clear that feasible alterna-
tives have not been sufficiently explored as is required by law
and there has not been a "rigorous exploration and objective
evaluation of the environmental impacts of all reasonable
alternative actions..." Rules & Regulations, CEQ #1500.8-4.
2. The Environmental Protection Agency's (EPA) Final
Regulations CFR 40 Part 6, Sec. 6.304, states that the "EIS
shall describe primary and secondary environmental impacts, both
beneficial and adverse, anticipated from the action".
The draft has not complied with this section of the law for
the following reasons:
142
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-9-
A.	The environmental impact has insufficiently dealt with
the environmental effects of construction of the proposed facilities
on water quality. For example, it is insufficient to say that
"construction of the proposed facilities would have temporary
minor adverse effects" without substantiation. What effect
will blasting the trench for the outfall have on the fish,
lobsters and shellfish of the area which are harvested commer-
cially? This possible impact could be of such a magnitude so
that it cannot be neglected.
B.	There is a lack of base line studies on the marine
biota, in this almost pristine area, as a point of reference
for monitoring. And, the possible effects of residual chlorine
on the biota has not been considered. Chlorine as low as .5ppm
can be deleterious to biota. (Testimony by Dr. John W. Gentile,
Asst. Administrator for the Environmental Protection Agency
Natural Marine Laboratory, West Kingston, Rhode Island - EPA
Hearing Palm Beach May 22, 1972)
C.	THE EIS HAS NOT PROPERLY EVALUATED THE CONSEQUENCES
OF A TREATMENT PLANT FAILURE AND THE PROBABILITY THAT A FAILURE
WILL OCCUR. It is stated that the "reliability of modern plants
is high because of the requirements for standby power, duplica-
tion of machinery, pumping capacity and fail safe provisions."
There are numerous authenticated references which state
that treatment plants are subject to upsets in the biological
treatment phase (refer to 1 C- Advantages of P-C treatment vs.
conventional treatment). There are no fail safe mechanisms
to prevent users from flushing a plethora of Ghemicals and drugs
143
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-10-
down the drains which are toxic to the microorganisms essential
to the treatment. Further, when this failure occurs, there could
be a significant hazard to health due to viral and bacterial
pollution because a 46 times dilution of the effluent as stated
in the Whitman & Howard Mr. 197 4 outfall study, such dilution
predicted as insufficient dilution to protect health and damage
to the marine biota. There could be an astronomical number of
organisms, many of them pathogens washing on shore. What would
be the economic consequences to a tourist area? I recall that
when the news of pollution and sewage of neighboring Old Orchard
Beach was reported in the news, the town became a ghost town
overnight.
D. THE ANALYSIS REGARDING THE SECONDARY EFFECT OF GROWTH
AND COSTS IS QUESTIONABLE. The present plans on plant size in
the impact statements state that the treatment plant is sized
for 3 mgd and a projected population of 27,000 East of the
turnpike, yet the Impact Study makes a population projection for
18,000 in the same time period. The difference between the two
projections will place an undue financial burden on the town.
If the present plan is instituted the town may be forced to adopt
policies that will encourage rapid growth to help pay for the
system. This type of change in policy as a result of the adoption
of the proposed plan has nowhere been assessed in the impact study.
144
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New Business
New business was taken out of order to en$b&.e Mr. Robert
TOdgdon to present His ideas relative to alternate plans for sewering
Higgins Beach and other Scarborough areas.
DISCUSSION OP ALTERNATIVE PLANS FOR SEWERS IN -HIGGINS BEACH:
Mr. Robert Hodgdon presented his ideas to the Trustees, No written,
material was presented, but the following are isome of the points that
he addressed:
1.	Higgins Beach (H.B.) is a fixecj community of 243 parcels
in a small area quite isolated from the other population
centers of Scarborough.
2.	Most H.B. homes on existing sewer system do not have
land available for private systems (septic tanks or
otherwise).
3.	Lateral sewer lines currently designed for H.B. could
be used to feed a small localized treatment plant with
relatively minor engineering revisions.
4.	No extensive expansion is possible in H.B. thus stabil-
izing waste load from this area.
5.	Small treatment plant for H.B. would eliminate need for
sewer line along Spurwink and Black Point Road to pick
up Prouts Neck (Pr. Nk.).
6.	Feels that the homes to be served by proposed public
sewer in Pr. Nk. could use subsurface disposal., systems*
7.	Proposes that land south of existing Oak Hill Treatment
Plant could be developed somewhat undet present provisions'
with subsurface disposal systems. Strict code enforcement
could be used to take care of pollution problems.
8.	Above steps would basically eliminate need to provide
public sewers south of Oak Hill Treatment Plant.
9.	Stated that DEP said a treatment plant at H.B. would
do no harm.
10.	Feels that Dunstan, Pine Point and Oak Hill areas
could be served by an enlarged facility at present Oak
Hill Treatment Plant if Nonesuch River can handle
additional effluent.
11.	Feels that Scarborough Sanitary District should go to
COG for 208 planning funds to study alternative dis-
charge and treatment points.
12.	Feels system proposed above would reduce emotional
impact currently being felt.
145
(OVER)
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13.	Thinks town should reconsider necessity of sewer
lines to serve town versus spending additional
money for strict code enforcement.
14.	Finally, Mr. Hodgdon requested that the Scarborough
Sanitary District investigate installation of a
treatment plant at Higgins Beach and apply for 208
funds to undertake planning.
Another citizen, Mr. Piper, said that many H.B. residents feel
the same as Mr. Hodgdon and would like to have the costs of such an
alternative considered. Much discussion relative to the above ideas
as well as the overall sewerage alternatives followed. —
On a motion by Mr. Applebee, seconded by Mr. Allen, the Trustees
voted (6 yeas, 0 nays) to submit a letter to the Town Council and
Planning Board to include thte following points:
1.	The Scarborough Sanitary District has a proposed sewer-
age system based on existing zoning.
2.	If town boards plan to alter zoning and take concrete
steps to alter growth plans, then the Scarborough
Sanitary District must be so informed to enable develop-
ment of a sewerage system to meet the town's definite
needs and requirements.
3.	Request that both Planning Board and Town Council place
this topic on their next agenda and officially Respond
to the Scarborough Sanitary District in writing relative
to their plans for town growth. Only with such informa-
tion can the Scarborough Sanitary District efficiently
plan to provide the service required by the community.
Old Business
SLUDGE DISPOSAL: Mr. Keene stated that the Scarborough Sanitary
District plans to use a combination of field spreading liquid sludge
and land disposal by Mr. Winslow in 1975. Mr. Winslow has verbally
agreed to maintain the price of $0.04 per gallon for sludge disposed
of at his site and $0.02 per gallon for sludge that he might be called
upon to field spread. This subject will be treated in more detail
when the 1975 budget is discussed at the regular January meeting*
BUDGET COMMITTEE: A budget committee meeting was set for noon
on January 9, 1975.
146
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New Business
New business was taken out of order to enable Mr. Robert
Hodgdon to present his ideas relative to alternate plans for sewering
Higgins Beach and other Scarborough areas.
DISCUSSION OF ALTERNATIVE PLANS FOR SEWERS IN HIGGINS BEACH:
Mr. Robert Hodqdon presented his ideas to the Trustees. No written
material was presented, but the following are some of the points that
he addressed:
1. Higgins Beach (H.B.) is a fixed community of 243 parcels
in a small area quite isolated from the other population
centers of Scarborough.
.2. Most H.B. homes on Existing sewer system do not have
land available for private systems (septic tanks or
otherwise).
3.	Lateral sewer lines currently designed for H.B. could
be used to feed a small localized treatment plant with
relatively minor engineering revisions.
4.	No extensive expansion is possible in H.B. thus stabil-
izing waste load from this area.
5.	Small treatment plant for H.B. would eliminate need for
sewer line along Spurwink and Black Point Road to pick
up Prouts Neck (Pr. Nk.).
6.	Feels that the homes to be served by proposed public
sewer in Pr. Nk. could use subsurface disposal systems.
7.	Proposes that land south of existing Oak Hill Treatment
Plant could be* developed somewhat under present provisions
wit h subs irface disposal systems. Strict code enforcement
could be used to take care of pollution problems.
8.	Above steps would basically eliminate need to provide
public sewers south of Oak Hill Treatment Plant.
9.	Stated that DEP said a treatment plant at H.B. would
do no harm.
10.	Feels that Dunstan, Pine Point and Oak Hill areas
could tie served by an enlarged facility at present Oak
Hi.il Tr' rjtment: -Plar.t if Nonesuch River can handle
addi.tion
-------
13.	Thinks town should reconsider necessity of sewer
lines to serve town versus spending additional
money for strict code enforcement.
14.	Finally, Mr. Hodgdon requested that the Scarborough
Sanitary District investigate installation of a
treatment plant at Biggins Beach and apply for 208
funds to undertake planning.
Another citizen, Mr. Piper, said that many H.B. residents feel
the same as Mr. Hodgdon and would like to have the costs of such an
alternative considered. Much discussion relative to the above ideas
as well as the overall sewerage alternatives followed.
On a motion by Mr. Applebee, seconded by Mr. Allen, the Trustees
voted (6 yeas, 0 nays) to submit a letter to the Town Council and
Planning Board to include thte following points:
1. The Scarborough Sanitary District has a proposed sewer-
age system based on existing zoning.
?. If town boards plan to alter zoning and take concrete
to alter growth plans, then the Scarborough
Sanitary District must be so informed to enable develop-
ment of a sewerage system to meet the town's definite
needs and requirements.
3. Request that both Planning Board and Town Council place
this topic on their next agenda and officially respond
to the Scarborough Sanitary District in writing relative
to their plans for town growth. Only with such informa-
tion can the Scarborough Sanitary District efficiently
plan to provide the service required by the community.
Oji.) I'.i i:: J : ic:;:;
SLUDGE DISPOSAL: Mr. Kocne stated that the Scarborough Sanitary
District plar.s to use a combination of field spreading liquid sludge
and land disposal by Mr. Winslow in 1975. Mr. Winslow has verbally
agreed to maintain the price of $0.04 per gallon for sludge disposed
of at his site and JO.O0 per gallon for sludge that he might be called
upon to field spread. This subject, will be treated in more detail
w',u n t.ho 1973 bud'iet is discussed at the regular January meeting.
BUDGET COMMITTEE: A budget committee meeting was set for noon
on January 9, 1975.
- 4 -
148
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TOWN OF
Old OtchtJBead
THE FINEST. CLEANEST BEACH IN THE WORLD
OLD ORCHARD BEACH. MAINE
From the Office of: Acting Town Manager
January 27, 1976
Mr. Robert Steele, Town Manager
Oak Hill
Maine (14074
DearHBbb:
Kith the construction of our secondary treatment
plant imminent and allied water quality projects, it is only
proper for this office to begin thinking of the practical
water treatment for the 1980's. In addition, 1t appears
that the quality planning and implementation of the "208
program" so-called that arbitrary municipal boundaries could
conflict with cost effective regional solutions. Accordingly,
I would very much appreciate being kept apprised of any plans
which Scarborough might have for the Pine Point area (Ferry
Beach area, Saco} because it might he advantageous to all
participating communities when we separate our storm sewers
from sanitary sewers to take on additional units In order to
reduce our operational costs.
Very truly yoiurs
J5P:jg
Cc to: S. Zaitlin
G. ApplefiftG
149
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RUSSELL B. LONG, LA., CHAIRMAN
HERMAN E. TALMAOGE, GA.
VANCE HARTKE, IND.
ABRAHAM RLB1COFF, CONN.
HARRY F. BYRD, JR., VA.
OAYLORD NELSON, WIS.
WALTER F. MONDALE, MINN.
MIKE GRAVEL, ALASKA
LL0YO BENTSEN, TEX.
WILLIAM D. HATHAWAY, MAINE
FLOYD K. HASKELL, COLO.
CARL T. CURTIS, NEBR.
PAUL J. FANNIN, ARIZ.
CLIFFORD P. HANSEN, WYO.
ROBERT J. DOLE, KANS.
BOB PACKWOOD, OREG.
WILUAM V. ROTH, JR., DEL.
BILL BROCK, TE&N.
MICHAEL STERN, STAFF DIRECTOR
DONALD V. MOOREHEAD. CHIEF MINORITY COUNSEL
Heb	J&eriaie
COMMITTEE ON FINANCE
WASHINGTON, D.C. 20510
January 26, 1976
Mr. and Mrs. John Lee
6 Kirkwood Circle
Scarborough, Maine 04074
Dear Mr. and Mrs. Lee:
I have finally contacted Dr. Gerald Berg of the
Environmental Protection Agency. I read him the quote from
the Draft Environmental Impact Statement: Wastewater Collec-
tion and Treatment Facilities, Scarborough, Maine, p. V-15.
He said that the statement attributed to him was somewhat
misleading but he understood how his comments might have
been misconstrued.
He amended the quotation by defining more explicitly
his use of the word effluent. He states that in order for his
statement to be accurate that the "effluent must be well treated
and free of solids." If the effluent meets this criteria, and
"if 1 mg./l of hyposhlorous acid can be maintained for 30
minutes at ambiant temperatures, the fluid should be free of
viruses."
I hope this information will help clarify Dr. Berg's
statement for you.
Sincerely,
c.-r^Ki/iA^n
Shery^S. Feldman
Caseworker
SSF/dch
150
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NEWS RELEASE
e TELECOMMUNICATIONS INDUSTRIES, INC.
1375 AKRON STREET • COPIAGUE, NEW YORK 11726 • (516) 842-5000
For further information:
Contact: Fred Novak, V.P. Ecology
(516) 842-333^
or
Anthony Broy, P.R. Counsel
(212) 779-2259
TELECOMMUNICATIONS INDUSTRIES, INC. (Til) TO
DISTRIBUTE KERAG OZONE WATER PURIFICATION
CONTROL LINE IN WESTERN HEMISPHERE AND FAR EAST
OZONE SEEN AS KEY TO SAFER WATER
COPIAGUE, L.I., N.Y., December 93 197^- -- Telecommunications
Industries, Inc. (NASDAQ, Symbol TLCT) announced today it had
become exclusive distributor in the Western Hemisphere for the
line of drinking water purification and pollution control equip-
ment manufactured by Kerag Ecotec, a century-old Swiss firm.
Kerag is one of the world's largest and most respected manu-
facturers of ozonation equipment, with systems in use throughout
Europe.
Ozone, a superior method of water disinfection eliminates
the need for chlorine in wastewater treatment processes. Chlorinated
hydrocarbon compounds have recently been indicted as cancer pro-
ducing agents.
Under the terms of the agreement announced today, Tele-
151
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-2- Kerag
communications Industries, Inc. (Til) will enter the drinking
water purification industry by distributing the Kerag line of
ozonators and automated monitoring equipment in the Western
Hemisphere. Til is already in the wastewater control field
through its exclusive Sonozone (TM) process.
The Kerag line includes air drying systems, electronic
controls, ozone generators, diffusers, ECO PUR (scrubbing,
deodorizing, air treatment units and oxydizing systems), and
sewage aerators.
"The Kerag Company manufactures one of the finest and most
respected lines of water and air purification and sewage treat-
ment equipment in the world," said Mr. Roach.
"Its ozonators and other equipment are used throughout
Europe in the disinfection and purification of water," Mr.
Roach added. "Kerag equipment has an enviable reputation for
efficiency and effectiveness the world over and will complement
Telecommunications Industries' Sonozone wastewater treatment
system."
Kerag has built many water purification installations
throughout Europe and the plants are fully automated and re-
quire only minimal maintenance. A 50-million gallon a day
Kerag installation is now being constructed for the City of
Rotterdam which will draw water from the heavily polluted
Rhine River.
"The treatment of water by ozone is a process which has
been known for more than fifty years," said Edward Ploetz,
Wm
"* 152
-------
-3- Kerag
Managing Director of Kerag Ecotec. "Ozone has a much more
varied and extended efficacy than chlorine. Only air and
electricity are required for its manufacture".
"Ozone is the most powerful oxidizing agent and its
action is extremely rapid. In contrast to chlorine, ozone
decomposes after a short time and therefore does not reach
the water consumer.
"Ozone", said Mr. Ploetz, "eliminates offensive color,
odor and taste. Further, it increases the oxygen content
of the water and destroys all kinds of micro-organisms in-
cluding viruses.,T
Til's Sonozone system is a complete and technically
advanced wastewater treatment system utilizing either physical/
chemical or biological processes together with sonics and ozone
to produce an effluent so pure that it is suitable for reuse
in irrigation, industry and recreational activities.
Discussing research findings made at the University of
Notre Dame's Lobund Laboratory, Dr. Morris Pollard, Director,
declared:
"In analyzing the action of Sonozone on bacteria and
viruses, it is evident that the killing effect is complete
and rapid.
"It showed this effect on stable polio-like viruses
(EMC and GD VII strains), and on a virus of intermediate
resistance (VSV). I place great significance on this data
"because of a clear relationship to disease mechanisms."

-------
-4- Kerag
"The killing effect of the Sonozone process on bacteria
was very fast and impressive. The bacteria of public health
significance included Salmonella, Shigella, Pseudomonas,
Staphylococcus, Escherichia Colia and Vibria Cholerae."
The Sonozone system provides excellent solids removal,
BOD and COD reductions, almost instantaneous bacteria and
virus kill. Substantial economies in construction costs and
in land utilization are inherent in the system which requires
roughly one-fifth the land area required by convention systems.
The first operational, community-sized Sonozone system
dedicated in May 197at Indiantown, Florida, treats approxi-
mately 570,000 gallons of sewage per day for this town of
4,500 inhabitants. Other Sonozone installations are currently
being negotiated both in the United States, Europe, South
America and the Far East.
Telecommunications Industries, Inc., headquartered at
Copiague, New York, also designs and manufactures other
ecology systems including air deodorizing systems for industry.
In a separate division, Til manufactures a lines of electronic
devices designed to protect telephone and electronic equipment
from lightning and other electrical surges.
fu
154
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lOO N. Strong Ave. • Lindenhurst, N.Y. 11757
516/842-3334 Telex: 144631
% ECOLOGY DIVISION
Telecommunications Industries, Inc.
November 1, 1974
Mr. Alvin G. Keene
Gorham International Inc.
Gorham
Maine 04038
Dear Mr. Keene:
Thank you for your continued interest in the Sono-
zone Waste Water Treatment System.
In reference to your letter of October 25th con-
cerning BOD and Suspended Solids effluent quality, we have
been obtaining between 1 and 5 mg/1 Suspended Solids and
8-12 mg/1 BOD'at our Indiantown Flant.
Complete cost data for a domestic system varies with
the following items: excavating, construction cost material
at georgaphical location, amount of automation required to
mee£ customer's needs, sludge handling and housing require-
ments for the plant. However, a rough estimate for a 3 mgpd
domestic system would be under $1.00 per gallon - for the
75,000 gpd plant estimate would be between $2.25 - $2.50
per gallon.
Operating costs can also vary according to geographi-
cal location. Transportation costs of chemicals and bulk
purchasing will effect the chemical costs. Electrical costs
at the plant site are also effected by geographical location.
Our expected operating costs at Indiantown 1/2 mgpd plant
are 25c per I,UUU gallons.
f. 'i r ' i i
If any additional information is required, please
feel free to contact me.
t$ry truly y©urs,
Til Ecplagy M*»isi®^
Frejl N^vak
Tice President Operations
155
Air & Water Purification Systems
-------
p1™"™ m lOO N. Strong Ave. • Lindenhurst, N Y. 11757
Mjif 516/842 3334 Toiexr 144631
Bm ECOLOGY DIVISION, - •
of Telecommunications Industries, Inc.
November 1, 1974
Mr. Al vin G. Kccne
Gorham International Inc.
Gorharn
Maine 04,038
Dear Mr. Keene:
Thank you. for your continued interest in the Sono-
zone Waste Water Treatment System.
In reference to your letter of October 25th con-
cerning BOD and Suspended Solitis effluent qualitv, we have
been obtaining between 1 and 5 mg/1 Suspended Solids and
8-12 mg/1 ROD at our Indiantown Plant.
Complete cost data for a domestic system varies with
the following items: excavating, construction cost material
at georgaphical location, amount of automation required to
meet customer's needs, sludge handling and housing require-
ments for the plant. However, a rough estimate for a 3 mgpd
domestic system would be under $1.00 per, gallon - for the
7 5,000 gpd pLant estimate would be between $2.25 - £2.50
per gallon.
Operating costs can also vary according to geographi-
cal location. -Transportation costs of chemicals and bulk
purchasing will effect the chemical costs. Electrical costs
at the ill ant site are also effected by geographical location.
Our expected operating costs at Indiantown 1/2 mend plant
are 25c per I,000 gallons.
If any additional information is required, please
feel free to contact me.
V$ry tnaly v»urs,
Til F,cpl®gy Birisiav
Fred N&vak
yice President Operations
156
Air & Water Purification Systems
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it
lOO N. Strong Ave. • Lindenhurst. N.Y. 11757
516/842-3334 Telex: 144631
FC0LOGFDIVISIONTelecommunications Industries, Inc.
November 1, 1974
Mr. Al.vin G. Keene
Gorhcirri Tnternat i onal Inc.
Gorharn
Maine 04.038
Dear Mr. Keener
Thank you for your continued interest in the Sono-
zone Waste Water Treatment System.
In reference to your letter of October 25th con-
cerning BOD and Suspended Solids effluent quality, we have
been obtaining between 1 and 5 mg/1 Suspended Solids and
8-12 mg/1 BOD at our Indiantown Plant.
Complete cost data for a domestic system varies with
the following items: excavating, construction cost material
at georgaphical location, amount of automation required to
meet customer's needs, sludge handling and housing require-
ments for the plant. However, a rough estimate for a 3 mgpd
domestic system would be under $1.00 per gallon - for the
75,000 gpd plant estimate would be between $2.25 - $2.50 /
per gaLlon.	' "
Operating costs can also vary according to geographi-
cal location. Transportation costs of chemicals and bulk .
purchasing will effect the cheriiical costs. Electrical costs
at the1 plant, site are also effected by geographical location.
Our expected operating costs at Tmilantown 1/2 mgpd plant
are 2 S'c per I , U(i0 ga I. l ons.
If any additional information is required, please
feel free to contact, me.
~*ry trttly y®urs,
Til Ecplcgy Bivisi®^
Frejt Nfivak
Tice President Operations
157
Air & Water Purification Systems
-------
lOO N. Strong Ave. • Lindenhurst, N.Y. 11757
516/842 3334 Toiex: 144631
ECOLOGY DIVISION,
of Telecommunications Industries, Inc.
November 1, 1974
Mr. Alvirt G. Keene
Gorham International Inc.
Gorham
Maine 0&038
Dear Mr. Keene:
Thank you. for your continued interest in the Sono-
7.one Waste Water Treatment System.
In reference to your letter of October 25th con-
cerning BOD and Suspended Solius effluent quality, we have
been obtaining: between 1 and 5 mg/1 Suspended Solids and
8-12 mg/1 BOD at our Indiantown Plant.
Complete cost data for a domestic system varies with
the following items: excavating, construction cost material
at georgaphical location, amount of automation reoui rod to
meet ci i:". I. onio r's needs, sludge handling and housing requ i re—
menl lor the plant.. However, a rough est iinali: fo r a > uigpd
domestic syst em would be under $1.00 nor ga' Ion - 1 or the
7r),000 gpd plant. osL j'mate would he between $2. 2!3 - $ 2. .'.>0
per gallon.
Operating costs can also vary according to geographi-
cal location. Transportation costs of chemicals.and bulk
purchasing will effect the chemical costs. Electrical costs
at. the plant site are also effected by geographical location.
Our expected operating costs at: indiantown 1/2 mgpd plant
are 2'>c per I ,oOo ga I I ons.
If any additional. Information Is required, please
feel fret? to contact me.
~$ry tnl v veurs,
Til Ecplegy ©i'visi®^
Frejl Nf>vak
Tice President Operations
158
Air & Water Piirifieation Systems
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January 29, 1976
COMMENT CW THE COST ANALYSIS IN THE ENVIRONMENTAL IMPACT STATEMENT
DRAFT FOB WASTEWATER COLLECTION AND TREATMENT FACILITIES FOR SCAR-
BOROUGH, MAINE.
The following comments will demonstrate that in the process of
developing a cost per user breakdown, the total cost of the entire
project was ignored and a cost per user breakdown was provided £6r
Phase I only. This summary will also prove, by using the same for-
mulas used in the Phase I cost per user breakdown, that the final cost
per user, including Phase II and III will be $322. per year.
The project as defined on Page 1-7 of the report is intended
to "service the entire portion of Scarborough east of the Maine turn»
pike, calling for a 3 phase construction program, to be completed by
Dec. 1982.
-L&, Ptte
The cost breakdown provided on table k. k-2. is clearly captioned
for Phase I only and demonstrates that the annual cost per dwelling
will be £200 if a 5% F.H.A. loan is obtained or $237 if money is
borrowed on the bond market at 7.25%. The front page of the Portland
Evening Express on Jan. 28, 1976 carried a story by Mr. Brian Arsenault
of-
stating "the remaining $10.5 million of the 1$19»1 million cost^ con-
struction would be financed by the town itself." Another sentence
reads, " an annual charge would result to the residential users of
between $200 and 5237." Obviously, the annual cost of amortising fi10>T
rift\ gVTing Sr37erf	.	. ¦
iialliui; ilullax-^^has not been calculated or someone is disseminating
false information to the press intentionally.
160
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The following cost comparison is provided to highlight the in-
creased annual cost per dwelling from $237 to a more realistic cost of
$32.2 when Phase II and Phase III costs of $1.9 million and S3.5 million
respectively are added. These calculations ere based on the following
facts and formulas:
A. The same ratio of assessments per user was used for Phase II
and III as for Phase I in table if. i+-2 of the report.
£. Total dwellings to be sewered under Phase II and III will
be 800 units. Total dwellings sewered under Phase I, II and'
III will be 2600.
C.	Yearly operation and maintenance expense is estimated in the
report as $200f?,000 per year under Phase I. The addition of
Phases II and III would add another $50,000 expenses.
D.	A realistic and practical approach to amortization is through
a bond issue at 7.25% instead of a hope that F.H.A.' funds will
be available at %%, Though every effort should be made
such a. loan, the assumption cannot be made that it will
to obtain
161
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Phase I cost analysis
(Copied from page IV-4
of the report)
Total Pro.ject Cost Analysis
(Including Phases I,II & III)
5,193,000
1,600,000
(1800 dwellings)
3,593,000
277,452
200,000
477,452
51,000
426,452
1800
Local share of cost
Less sewer assessments
Local cost to be amortized
over 40 yrs. at 7.255
OL
10,593,000
Phase I 5,193,000
Phase II 1,900,000
Phase III 3,500,000
-2,314,000
(2600 dwellings)
= 8,279,000
Annual amortized cost (12.95%) 639,305
Add yearly operating costs +¦
Local annual cost
Less annjial fees from
Industrial users
Annual cost to dwellings
Total residential and
equivalent commercial
dwellings
¦250,000 (Includes $50,000
more per year for Phases II
and III.)
889,305
51,000
838,305
2600
$237
Annual cost per dwelling
- $322
162
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In summary the following questions must be resolved:
A. Why is a cost per dwelling analysis provided for Phase I
Only and not for the entire project?
3, Why is a F.H.A. loan at 5^' used in the calculation of e.
cost per user breakdown when the availability of such a loan
is doubtful?
C. .from a cost per user standpoint, why does phase 1 provide
sewerage for presently undeveloped property while populated
areas such as Blue Point, 'Villowdale, Pleasant Hills, Scottcy; Hill
and V/est Scarborough relegated to Phases II and 111?
A3 A CITIZEN MD TAXPAYER OF SCARBOROUGH, I BELIEVE THAT THE ANSWERS TO
THESE QUESTIONS MUST 3E MADE AND THE ESPGET SHOULD BE REVISED ACCORD-
INGLY. I WOULD ALSO ASK THAT THIS.REPORT NOT BE ACCEPTED UNTIL SUCK
TIME AS THE TRUE COST ANALYSES ARE MADE FOR THE 32TT11E PROJECT.
Respectfully submitted
' * 7f a-" "'
Robert G. Pelietier
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164
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Ar!--er carefully reviewing the draft environmental impact statement
[EIS] , Wastewa*er 0ollcction aud Treatment Facilities: Scarborough,
Maine, it is my conclusion that the study has presented inadequate
analysis and arrived at faulty conclusions concerning the environmental
impacts of the proposed action and alternatives. On the basis of
this study it is impossible to assess the environmental impacts and
to weigh the relative merits of the proposal and alternatives. In
addition, the draft has not complied with federal regulations
concerning the content of EIS's; most generally, it has not presented
"all the facts mecessary to permit independent evaluation and appraisal
of the beneficial and adverse environmental effects" of the alternative
actions and the proposed action as is required by EPA Final Regulations
CFR ltO-i 6 - 30J4.
More specifically T have the following criticisms:
A. THE DHAFT DOES NOT PRESENT AN ADEQUATE ANALYSIS OF ENVIRONMENTAL
IMPACTS AS IS REQUIRED BY CFR U0-§ 1500.8 [a] which states that,
A rigorous exploration and objective evaluation of the environmental
impacts cf all reasonable alternative actions ... is essential.
Examples of such alternatives include: ... alternatives requiring
actions of a significantly different nature	alternatives
related to different designs or details of the proposed action... .
The Draft does not present an adequate analysis of the environmental
impacts of alternatives because:
l.It has not presented a rigorous exploration of impacts associated
with alternatives requiring actions significantly different than
biological treatment. The Draft does not consider physical chemical
treatment plants which are less costly to construct, require less skill
to operate, are not subject to upset due to shock loadings, are not
upset by materials toxic to microorganis«s used in biological treatment.
In addition, these plants have higher removal of BOD, SS and nutrients
165
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2.
than "biological plants [Cooper, 1975 ; Ulmgren ,1976 ] . Due to their
reliability and. increased efficiency physical-chemical plants could
have less of an^impact on water quality than the proposed plant and,
therefore, should be considered.
2.	The Study prematurely eliminates transfer Alternatives II and
III on the basis that the delay resulting from the "necessary"
redesign of the South Portland and Old Orchard Beach plants vould not
be allowed by the DEP [EIS §3.1]. However, no documentation is
presented to substantiate the assumption that Scarborough's present
waste flows could not be handled by the plants. In fact, the plants
in both South Portland and Old Orchard Beach are probably designed
to service a 25 year projected population with a substantial safety-
margin capacity; therfore, it seems likely that transfer Alternatives
II and III are possible without a redesign of the plants. The truth
of this assumption must be investigated.
3.	The Draft does not present a rigorous analysis of environmental
impacts of alternatives relatedyto different designs or details of
the proposed action.
a. It does not assess the environmental effects of the apparant
over capacity of the proposed plant. Since the plant capacity is
based on a 100 gpcd flow from serviced population which is 10,000
above that which is projected in the FITS [p. VI-6, p.IV-5], the plant
is apparantly overdesigned by at least 1 mgd. Additional excess
capacity may have been designed into the system by assuming the 100 gpcd
flow, because it has been shown that this per capita flow estimate
may be excessive [ Urban Sys. Research & Eng.,Inc. 197U]. This excess
capacity could have undesirable effects on land use in the project area
and place an unecessary "excess" cost burden on the residents. These
166
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3.
effects resulting from excess capacity are well documented in a report
prepared for the Council on Environmental Quality and methods for
quantifying some of them were presented [Urban Systems Research &
Eng., Inc., 197^ ]• It is reasonable to assume,^hen,that the EIS
should include an assessment of both the kind and magnitude of
impacts resulting from different design capacities,because this is
well within the state of the art.
b.	Ozonation as an alternate method of disinfection was disregarded
on the basis that there may be a problem of monitoring its effectiveness
[EIS p. 111-21]. However, ozonation is now widely used in Europe and
Canada, and offers the advantage of more efficient viral kill. It
nne-it\6ci e>? di'S^tc+ioA
is also a desirable^because it adds oxygen to the effluent creating
a "negative BODv and has no adverse residual effects as does chlorination
f
[Monti and Silbermann, 197^]. Before this alternative can be rejected
these advantages must be weighed against the, as yet, undocumented
disadvantages.
c.	Alternative sites for the outfall have not been considered
and must be considered to comply with regulations. It is true that
the location of the outfall will have a substantial effect on the
amount of dilution the effluent will undergo and whether the effluent
will reach the beaches and clam areas in a concentrated slick.
As yet, no optimization studies have been done on the outfall location
[Stolzenbach, 1976]. Given the potential differences in impacts
on biota and risk to public health associated with different
locations of the ocean outfall, it is important that furthur
¦fo	ff> ,V>G,
analysis be carried out ^ the optimal location for the outfall.
167
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u.
B. THE DRAFT DOES NOT PRESENT AN ADEQUATE ANALYSIS OF PRIMARY IMPACTS
AS IS REQUIRED BY CFR U0-S6. 301+ which states that
The EIS shall describe primary and secondary environmental
impacts, "both "beneficial and adverse, anticipated from the action...
[and shall describe the] magnitudes of adverse impacts.
The EIS does not present an adequate analysis as is required
because:
1. It does not satisfactorily assess the possible impact of the
effluent on water quality and incorrectly states the failure
probability df the proposed plant and the associated risk to health.
a. It is stated that "the reliability of modern [biological]
treatment plants is high because of the requirements for standby
power, duplication of machinary, and fail safe provisions..."[EIS p.III-7'].
The report also contends that, "The probability of malfunctioning
of the entire treatment plant...is extremely small." [EIS p.V-15].
Both statments, however, are erroneous, and, therefore, probability
¦ft*-
of malfunction^biological plants has not been correctly evaluated.
It is well documented that biological plants are subject to
failures due to an inflow of toxic materials which are dumped down
the drains by users. Biological plants are also particularly sensitive
to shock loadings and temperature changes. Clearly the wonders of
modern science cannot prevent these upsets. In the event of
system failure, virtually untreated wastes will be flushed through
the system. Considering the infectivity of viruses, 1-2 particles;
the concentration of pathogenic viruses and bacteria in wastewater,
approx. lO^/gal.; and the initial dilution of the effluent, approx.
50x; the effluent is potentially very harmful [EIS pp. IV-7, V-17;
Foster and Enge}brecht,,197**]»
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5.
On the basis of data presented in the EIS and in the Whitman and
Howard study, Optimum location of the Proposed Prout's Week Ocean
Outfall, Scarborough, Maine, it is not possible to conclude that in
cases of system failure, due to the "high dilution effect and distance
to shore and beaches", the impact will be "minor and temporary" as
has been concluded in the Draft [EIS, p. III-7]. The distance to
the shore is much closer than is stated and implied. The southern
most tip of Scarborough beach is well short of a mile from the outfall,
and the shore is only 600' away. Given the worst possible conditions
of the effluent being washed to the shore and beaches, a significant
health hazard will exist unless the effluent undergoes a substantial
dilution after initial mixing. Dr. Keith Stolzenbach of The Massachusetts
Institute of Technology, however, has stated that he does not believe
"that the information provided [in the Outfall Study is] sufficient
to make an estimate of effluent dispersion beyond the initial jet
mixing region ...[and] without... additional studies shoreline values
of pollutant concentration cannot be measured " [Personal Communication].
It is evident that the EIS has not properly evaluated the
primary impact of the outfall, because failures are much more frequent
than is estimated and the effluent could reach the beaches in
harmful concentrations. In order to asses the risks to health the
study must estimate more carefully the probability of system failure
and gather additionalcurrent data to predict the shoreline concentrations
of pollutants. Only with this added assesraent will the EIS comply
with federal regulations for the evaluation of primary impacts.
b. The Draft does not properly predict the impacts associated
with the effluent which has undergone normal treatment fpecause
the report incorrectly infers that all but complete removal of viruses
169
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6.
will be accomplished by the treatment process and subsequent
chlorination;^thus, the risk to health from viruses isAminimal.
The statement made by Dr. Berg which is quoted does not necessarily
substantiate this claim as it is supposed to have done. Berg states
that "complete removal of viruses from the effluent is reasonably
assured if at least a 30 min. contact with hypochlorous acid with
1 mg/1 residual chlorine concentration is provided and all suspended
solids are removed" [EIS p. V-15]. It is important to note the
qualification that all suspended solids be removed to acheive the
desirable viral kill, because the effluent from the proposed plant
will contain 30 mg/1 SS. Thus the stated level of viral removal
cannot be acheived. It is well documented that chlorine will react
with materials in the wastewater rendering the disinfection dosage
lftss effective [Hunter and Kotalik, 197^1 • It followSj then^ that
to assess the possible health risk of viruses resulting from a well
functioning plant a better estimate of the number of surviving viruses
must be «r v'^ ry. And as has been previously explained, estimates of
dilution subsequent to initial jet mixing must be presented.
c. The effects of residual chlorine on the biota have not
been assessed. Since the outfall area is a lucrative fishing area
for commercial fishermen, adverse affects on the biota will in turn
mean that the livelihoods of the fishermen will be negatively affected.
Since the potential impact could be great, the effects of residual
chlorine must be carefully evaluated.
2. Environmental effects of blasting on the biota, especially
the lobster and shellfish populations , have not beer considered.
It is insufficient to state that the construction will "cause
170
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7.
temporary disruption of the aquatic life" without enumerating the
kinds of effects on the commercially harvested lobsters and clams
in the area and the magnitude o£ the possible effects.
C. THE DRAFT DOES NOT PRESENT AN ACCEPTABLE ANALYSIS OF SECONDARY
IMPACTS, ESPECIALLY IMPACTS ASSOCIATED WITH LAND USE AND GROWTH,
AS IS REQUIRED BY CFR U0-§ 6.30U which states that
The EIS shall describe primary and secondary environmental impacts,
both and adverse, anticipated from the action. ... the secondary
impacts would include environmental impacts related to:
i] induced changes in the pattern of land use, population
density and related effects on air and water quality or other
natural resources; ii] increased growth at a faster rate thsn
planned by the existing community...[and]... Land use patterns
and population trends in the project area and the assumptions
on which they are based shall be included.
Insufficient data has been presented to assess the secondary
environmental impacts of the proposal because:
1. No data is presented to establish the previous land use and
population trends, and the current land use and population in the
study area. All tables except table 2.2-13 report demographic
statistics for the whole town of Scarborough. These Scarborough statistics
can be visualized as an average between statistics for areas east
and west of the turnpike. It is important to note that the area
west of the pike encompasses approximately the same land area but
contains an insignificant portion of the population and is zoned
primarily R-F [EIS p.II-31*]. Whereas, the study area, or area east
of the pike, contains a very high percentage of the population and
is zoned quite differently. In addition, previous population
trends have been very different for the two areas; the study area
being less constrained has undergone much more rapid development.
Clearly, Scarborough demographic statistics and trends which are
the average of those for the two areas will not be representative
of the study area. For example, the population density for Scarborough
171
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8.
in 1970 was about 150 persons/sq mi, but the density in the study
area was about 250 persons/sq mi if it is assumed that approx. 70$
of the population is east of the pike in a buildable land area of
about 22 sq mi [EIS pp. II-U3 > 11-56].
Since statistics presented in the EIS do not represent the
demographic characteristics of the project area, additional data
must be given specifically for past land use and growth trends, present
population density,.number of acres available for building with and
without waste disposal provided by the project. It is only with
this baseline information that secondary impacts in the study area
can be assessed.
2.	The EIS has incorrectly assessed the secondary impacts of the
proposal; if the data presented in the EIS is used, it is not logical
to conclude that "Because the population attributed to the proposal
is small, the secondary effects of the proposed action on the
environment is very difficult to calculate but will probably will
be minimal." [EIS p. VI-10]. If we assume that the only difference
between the population projections for with and without the proposal
is that land in the project area that otherwise could not be developed
is developed, it follows that the projected 25# increase in population
with the proposal occurrs east of the pike [EIS VI-6]. This will
re suitvin'an increased density of about l67p/sq mi if we assume
that the land area IS approx. 22 sq mi and the inrease in population
f|S 3,680 persons. Thus, the secondary effect on population
density and land use seems to be significant. This increased
density could also have an adverse effect on water quality.
3.	No explanation T i;s "givgn :for ^fiy i:a~25#Sincrease In- populatibh
iS-^aasociatejl with the proposal. The reliability of this figure
cannot be assessed without documentation on how it was arrived at.
172
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9.
The Report also states that land use will be altered on less than
5% of the to^al drainage area with the proposal [EIS p.v]. Again
no substantiation for this assumption is presented in the text.
Furthur, after taking a closer look at the population predictions
in the EIS, one realizes that the accuracy of these estimates has
not been given. It is evident that no informed decision can be made
on the basis of projections which could be accurate to plus or
minus infinity for all the reader knows.
Before any decision can be made about the secondary effects of the
action on land use and growth, the Draft must substantiate the above
mentioned claims and also state %£§ accuracy of the ^o^mlation
estimates. This is not only required by federal regulations but
also is required by the 10 commandments for technical reports.
On the basis of the above review of the Draft, if is my
conclusion that the report does not present the accurate information
necessary to evaluate the environmental impacts of the proposal
and alternatives. More analysis must be carried out and revisions
must be made so that the EIS will comply with fedral regulations
and so that an informed decision can be made on the impacts of the
proposal and alternatives.
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BIBLIOGRAPHY
1.	Code of Federal Regulations, Title UO, Parts 6& 1500.
2.Cooper,	P., "Physical and Chemical Methods of Sewage Treatment,
Review of Present State of Technology", Water Pollution Control,
v. TU, no. 3, 1975-
3.Environmental	Impact Statement, Scarborough, Maine [Draft],
Wastewater Collection And Treatment Facilities, Booz-Allen&
Hamilton, Inc.
U.Foster, D.H.,Engelbrecht ,R.S. , "Microbial Hazards In Disposing
of Wastewater on Soil", paper, Conference on Recycling Treated
Municipal Wastewater Through Forest and Cropland, EPA-660/2-7U-003
March 1971*.
5.Hunter,	J.V., Kotalik, T.A., "Chemical and Biological Quality of
Treated Sewage Effluents", paper, Conference on Recycling Treated
Municipal Wastewater Through Forest and Cropland, EPA-660/2-7U-003
March 1971*.
6.Monti,	R.P., Silbermann, P.T., "Wastewater System: What Are They
...And What Cost?", Water and Wastes Engineering, v. 11, no.5
May, 197U.
7.Stolzenbach,K., personal communication, see attached letter.
8.Ulmgren,	L. , "Swedish experiences in Chemical Treatment of Wastewater
J. of Water Pollution Control Federation, v. U7, no. U,
April, 1975-
9.Urban	Systems Research & Engineering Inc., Interceptor Sewers and
Suburban Sprawl, prepared for the Conucil on Environmental Quality
September 10, 197^.
174
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RALPH M. PARSONS LABORATORY
FOR WATER RESOURCES AND HYDRODYNAMICS
Department of Civil Engineering. Blog. 48 — 321
Massachusetts Institute of Technology
Cambridge. Massachusetts 02139
Miss Valerie Ann Lee
Kirkwood Road
Scarborough, Maine
Dear Miss Lee:
At your request I have reviewed the report entitled "Optimum Location of
the Proposed Prout's Neck Ocean Outfall" which was prepared by Whitman and
Howard, Inc. in March, 1974.
My review has focussed on the assessment of pollutant concentration levels
resulting from the construction and operation of the proposed outfall structure.
I have the following comments in this regard:
1.	Although I have not repeated the detailed calculations of the dilution
induced by the discharge structure (defined as D in the report) it
appears that the analysis presented in the report is adequate for de-
termining this mixing and its "dependence on the depth of water in which
the outfall is located and on the discharge port diameter. However,
the report does not present any true "optimization" of the outfall
depth or port diameter with respect to cost or potential environmental
impact.
2.	I was not able to evaluate the technique used to estimate the subsequent
dilution due to dispersion (defined as D^) because of the lack of detail
in the report. However, I do not believe that the information provided
by the drogue, drift bottle, and current meter studies are sufficient
to make an estimate of effluent dispersion beyond the initial jet mixing
region, regardless of what technique is used. In particular, the spatial
and temporal variation in the current regime over a much larger area
would be required for such an assessment. Alternatively an analog
field measurement technique such as a dye release could be used to
actually observe the transport and dilution of an effluent released at
the proposed outfall site. Without such additional studies shoreline
values of pollutant concentration can not be estimated. I believe that
the report recognizes this limitation implicitly in as much as the
calculated values of Dg are not used in the final evaluation of the pro-
posed design.
Please let me know if I can be of further assistance in this regard.
PHONE: (617) 253- 6761
28 January 1976
Very truly yours
Keith D..^8"£olzenbach
Assistant Professor
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HIGGINS BEACH ASSOCIATION
SCARBOROUGH, MAINE 04074
Marck 1976
Mr. Gerald Applebee, Ckairaan
Searborougk Sanitary District
Scarborough., litiie 04074
Gentlemen:
Regardless of wkat may ©r may not appear in prist, tke
Higgins Beaek Association kas act allied itself in amy way
wkatsoever witk amy ©tker ©rganTzation, most particularly mot
witk tke Searborougk Taxpayers' Association, to "figkt tke T®wa"
agaiast Sewage Plan A, or for amy ©tker reason, mor will it do so.
Furtkernore, apparemtly tke gentlemen wko respomded to tke
Environmental Impaet Statement regarding Waste Water Golleetiom
& Treatment Facilities in Searborougk Maine at tke Public Hearing an
January 29, 1976 gave tke impression tkat tkey were presenting a
unanamous, or at least, majority opinion from tke memberskip of
tke Higgins Beaek Association. Tkey were not autkorized to do so.
Tkis may or may not kave been a misunderstanding on tkeir part.
However, I skould like to make it clear, tkat neitker tke Board
of Directors of tke Association, tke Environmental Committee of
tke Association, nor tke total Association memberskip, kas taken an
official stand on Sewage Plan A in, at least, tke last two years.
Individual members kave done so, as was tkeir privilige, and
will probably continue to do so, but tkey are not speaking for tke
Association as a wkole. Indeed, tkat is usually an impossibilityJ
Tke Higgins Beaek Association includes in its memberskip all
tke residents and taxpayers of Higgins Beaek wko pay tkeir dues.
It was net formed "to grind any speeial ax"! One of its purposes,
as stated in tke by-laws, is to "protect and improve Higgins Beaek
property". As is true of most suck groups, tkere is almost never
total agreement as to kow tkis skould be done. Tke Board of
Directors try to speak fairly on bekalf of tke memberskip, and
try to"please most of tke people most of tke time"! And to tkat end,
it is tke policy of tke current Beard of Directors to try to
worilinieably witk "Tke Town" for tke greatest good for all.
' Witk tke above comments in mind, I skould like to present tke
following tkougkts representative of tke Higgins Beaek Association
memberskip. It is impossible to say wkick migkt be tke majority
or minority opinions. Tke fact is, some even contradict tkemselves.
But all tkese opinions are very muck in evidence.
1)	It is probably safe to say tkat tke memberskip as a wkole
dees want seme kind of sewage disposal!
2)	A petition, in favor of Plan A, was signed by approximately
175 Higgins Beaek Taxpayers, most of wkom are members of tke
Higgins Beaek Association, was included in tke Public Hearing keld
in July 1974. Tkis was net submitted as a stand by tke Higgins
Beaek Association, but simply as a petition signed by individual
taxpayers.
5) lou kave keard loudly, if maybe not clearly, from individuals
of our memberskip wko do not favor Plan A and speak in terms of
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"our ©wn treatment plant at Higgins Beaek", witk varying suggestions
and no specific plans as yet.
4)	Statements are made tkat tkere can be very little more
building at Higgias Beack and tkerefore, we are a "contained
community" aad tkus caa kave "our own plant" and it will always
take care of us and never aeed to be enlarged.
5)	yet, at a planning Board Workskop (February 19, 1976),
attended by two Higgias Beaek Association Directors and a resident
of Higgias Beaek, it was deteraiaed tkat "pessimistically" tkere
aigkt be as maay as 125-150 available building sites still left
at Higgias Beack.
6; It is suggested tkat tke existingsewer piping caa be used
as a nucleus aad added oato to build "our own system" tkus saving
tke environmental destruction tkat blasting will occasion.
7)	Some ask, if tke above is so, wky wouldn't it work witkin
tke larger system of Flaa A?
8)	Tke opinion is keld by still otkers tkat tke existing
system, beiag nearly 50 years old, if aot past tkat, is doubtful
at best. Locating aad/or traciag it is agreed by most to be difficult.
Curreatly a large part of it runs under "otker people's kouses".
9)Water	quality and tke preservation of tke Spurwink Marsk
seem to bo prime ceneeras of many, altkougk tkero are differeaces
as to tke optimum aad tke "kow to"s.
10)	Cost is, of courstr, a concern of everyone, more or less.
11)	Of great imterest is "kow soon?" and tkis breaks down iato
faotioas also, tkoso ia favor of delay, aad tkose tired of "diddliag
arouad"•
So, ia coaclusioa, tke memberskip of tke Higgias Beack Associatioa
is Just like tke rest of tke Towa. Some for, some agaiast, aad
aot at all uaaaamous. We kave our "experts" oa eitker side, some
mere vocal tkaa otkers. I do believe it is safe to say tkat
we are ia favor of sewage disposal, witk as good water quality aad
preservatioa of our aatural resources as is possible, at a
feasible cost. Aad tkat is wkat tke argument is all about, isa't
it?
Had Booz, Alloa, & Hamiltoa, Inc. followed up tkeir initial
eoataet witk me last summer as premised, tkis all migkt kave beoa
muck clearer muek sooaer.
If tkis letter arrives ia time to become part of tke latest
Public Hearing keld oa January 29, 1976 please see tkat it is
included. (I uaderstaad tke cutoff dat« to be Marek 7tk but siace
tkat falls oa a Sunday perkaps tkere is aaiexteasioa uatil tke 8tk?
Anyway tke postmark will read Marck 6, 1976.) If it does aot
arrive by tke deadliae, at least you will be iaformed.
Tkanking you, I am
Very sincerely yours, | (
Dr.(jjbaa Mortoa Kelly (Mrarf7 A.L. )
President Higgias Beack A{§ociatioa
Summer Address: Coraer of Bayview & Pearl St.
Higgias Beaek, Scarborougk, Maine
Winter Address: 109 Locksley Bead
until May 1st Lynnfield, Mass. 01940
Copies to: Linwood Higgins, Town Council
Tkomas Kuozkowski, Planning Board
Dick Piper, HBA Vice President
Dave MacDonald, HBA Environmental Committee
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March 4, 1976
Mr. Bob Mendoza
Environmental Impact Office
Environmental Protection Agency
Room 2203
John F. Kennedy Federal Building
Boston, MA 02203
Re: Draft EIS for Scarborough Sanitary District, Scarborough,
Ma ine
Dear Mr. Mendoza:
After reviewing the Draft EIS and discussing the contents as
well as the recent public hearing input, the Scarborough Sanitary
District Trustees voted unanimously to submit this letter to
summarize their feelings on the proposed wastewater collection
and treatment facilities for Scarborough.
First, the Trustees want to reconfirm their support of the
one plant concept to serve the wastewater treatment needs of the
Town of Scarborough. This confirmation is based upon the Trustees'
January 22, 1975 and February 26, 1975 votes (see attached excerpts
from SSD minutes) that contained several conditions to be used by
the design engineers, Whitman & Howard, as design input.
With regard to specific items discussed in the deaft EIS, the
Trustees have long been aware of the areas which still require
additional investigation. As you will recall, the current project
status is basically that of a completed preliminary design. Much
additional effort is required before the project can be considered
ready for construction.
As with all new treatment facilities, the sludge disposal
requirements will require careful planning and design to enable
implementation of the most cost effective methods. The Trustees
are hopeful that at least a portion of the sludge can be utilized
MAR 5 1976
178
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for its soil conditioning/fertilizer value. This desire is based
on the fact that land spreading applications from the existing
treatment facility have been carried out successfully in accordance
with Maine DEP guidelines for several years. Obviously, the total
sludge quantities to be generated, availability of acceptable
land spreading sites, economic comparison of alternative disposal
methods, etc. will be considered as part of the final system
design. The Trustees goal is to dispose of all sludge in an
environmentally acceptable manner while incurring the smallest
possible cost on behalf of the system's users.
With regard to the ultimate user fee, the Trustees have con-
tinually expressed their intentions to attempt to keep the fee as
close as possible to the existing user fee of $13 7 per year.
While many factors, including overall economic trends, will influence
the ultimate figure, the current projection of $146 per year with
federal, state and Farmers Home Administration funding is certainly
much more acceptable than some of the previously quoted user fee
projections.
With regard to user fees in future construction phases, any
projections at this time seem premature. This statement is based
on the fact that while the general areas to be sewered are known;
no definite priorities have been established, no actual facility
requirements have been estimated and future financial assistance
programs are not known at this time. Before any new construction
is undertaken, the Trustees will very carefully project total costs
and "determine the project's economic feasibility relative to the
community's needs and resulting benefits.
While other specific points in the draft EIS could be dis-
cussed, the Trustees overall feeling is that all the substantive
items addressed are subjects that will be resolved in the final
design period. The Trustees intend to work very closely with the
engineers to insure that the final design provides the best possible
system to satisfactorily meet the community's requirements as
well as all federal and state environmental regulations.
In addition to the above comments, the Trustees want to include
their November 20, 19 75 "Open Letter" (copy enclosed) as evidence
of their status and feelings on the sewerage collection and treat-
ment facilities proposed for Scarborough.
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The Trustees appreciate the effort expended by EPA in preparing
the EIS and are hopeful that the above comments will be useful.
If you desire additional information or elaboration on any specific
items, please feel free to call.
We look forward to receiving the completed EIS and to working
with EPA to provide the best possible pollution abatement program
for the residents of Scarborough.
Very truly yours,
SCARBOROUGH SANITARY DISTRICT
Gerald F. Applebee
Chairman
GFA/j
CC: F. Paul Frinsko, Esq.
Dennis Purington, Maine DEP
D. Dargie, Whitman & Howard
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Scarborough Sanitary District
P. O. BOX 302
Scarborough. Maine 0407/,
November 20, 1975
SUMMARY OF SCARBOROUGH SANITARY DISTRICT
POLLUTION ABATEMENT PROGRAM
For the past several years the Scarborough Sanitary District
Board of Trustees has been working to develop the best possible
pollution abatement program for the Town of Scarborough. Through-
out these several years, there has been much discussion and
controversy over public sewer alternatives for Scarborough. At
this point in time, the Trustees want to summarize the current
pollution abatement program and their intentions for the future.
The Scarborough Sanitary District was originally formed by a
vote of the Town of Scarborough to accept the responsibility for
sewerage collection and treatment facilities. The Scarborough
Sanitary District operates separately from the municipal government
and all costs of existing and proposed sewerage collection and
treatment facilities will be paid for by District revenues gener-
ated from users of the system. No municipal tax dollars will be
used to pay for construction, operation or maintenance of sewerage
facilities.
In October, 1972, the Scarborough Sanitary District, Town of
Scarborough, Maine Attorney General's Office and Maine Department
of Environmental Protection entered into a Consent Order. This
agreement stated:
"That the District provide for the construction and
operation of sewage collection and treatment facili-
ties to serve specified areas of certain sections of
the Town known as: (i) Higgins Beach; (ii) Willowdale,
(iii) Oak Hill; (iv) Pine Point; (v) Blue Point, and
(vi) West Scarborough, all as more particularly set
forth in the proposed pollution abatement program and
accompanying map, dated March, 1972, prepared by
Whitman & Howard, Boston, Massachusetts, which pro-
posed pollution abatement program and accompanying
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map are attached hereto as Exhibit "A" and made a part
hereof. The District shall provide for the facilities
contemplated by said program and map in accordance with
the schedule contained therein, provided, however, that
said facilities and schedule shall be subject to Federal
and/or State financial assistance being available in
the amount to which the District is or will be legally
entitled, and further subject to such assistance being
made available within such period of time as will enable
the District to complete the construction of the afore-
mentioned sewage collection and treatment facilities
within the time contemplated in the said schedule."
The original timetable which called for construction to start
in 1973 was not met as a result of impounded Federal funds and
various delays in the planning process. During the planning
process, the Trustees have reviewed inputs from all interested
parties concerning collection and treatment alternatives. To
date over $175,000 has been expended for overall system planning,
ocean outfall study, and design of collection sewers for the
Higgins Beach area. In addition to the above inputs, the Trustees
have held two public hearings on the proposed facilities and have
reviewed the results of the Town's Comprehensive Plan Committee.
At their regular meetings in January and February, 1975, the
Board of Trustees voted unanimously .to proceed with a one treat-
ment plant concept to satisfy the consent order and to abate
pollution in Scarborough. However, this vote to proceed was
subject to the following conditions to be used as design input:
1.	The annual user fee shall not exceed $13 7.
2.	The initial front foot assessment shall not
exceed $10 per front foot (Note: no final
determination has been made as to how this
assessment will be billed to the abutters.
Some alternatives that exist are:
A.	One time assessment per front foot.
B.	One time assessment based on lot size
or other zoning criteria.
C.	One time charge such as a or b financed
over 10 years.
D.	An assessment charge added to the annual
user fee. )
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3.	The charge for the District's readiness to serve
on vacant lots shall not exceed 40% of the annual
user fee.
4.	Final plant site location may be altered depending
upon comparative site development costs for the
existing District owned site versus purchase of a
different site with improved soil conditions.
5.	Snow Food Products and Bayley's Seafood Process-
ing's wastewaters will be included in the new
treatment plant flow.
The above decision was based upon the Trustees unanimous
agreement that the concept of a single treatment plant with an
ocean outfall is the most cost effective method to provide
collection sewers and proper wastewater treatment to Scarborough's
existing population centers and to provide proper pollution abate-
ment service required for a slow to moderate community growth.
While small localized treatment facilities may appear to be a
desirable alternative, the increased operation and maintenance
costs for multiple treatment plants; the construction and main-
tenance cost of additional outfalls in the marsh and estuarine
areas; the increased capital and operating costs resulting from
the higher degree of treatment that would be required by the
Department of Environmental Protection for estuarine discharges;
and the cost of several individual projects would actually increase
total overall costs. Additionally, these individual plants
would require the same overall twenty year population design
capacities as the proposed one plant concept to qualify for
Federal and state grants. Also, small localized treatment
facilities would tend to limit the Town's future growth options
whereas the one plant concept provides maximum flexibility for
an advantageous mix of residential, commercial and industrial
growth at whatever pace is desired by the Planning Board, Council
and other organizations that are responsible for planning
Scarborough's growth pattern and economic future.
Undertaking this multi-million dollar project will certainly
abate pollution, and will be the most cost effective approach for
the Scarborough Sanitary District's users. The initial construc-
tion phase (including Higgins Beach, connection of existing
treatment plant to new plant via Black Point Road area, Willowdale,
Pine Point and parts of Prouts Neck) is estimated to cost nearly
$14,000,000. With the local share of this cost estimated at
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approximately $4,600,000, the users would be left with an annual
user fee of about $164 plus a $10 per front foot assessment for
all new abutters. However, the Scarborough Sanitary District
Trustees feel that their previously voted financial criteria of
$13 7 per year must be met by outside funds so as not to increase
an already major financial burden on Scarborough residents.
However, in March, the Maine Board of Environmental Protection
voted to seek a court order to force the Scarborough Sanitary
District to begin implementation of the above program without
resolving the question of additional financial aid necessary to
prevent an excessive burden on the system's users. While they
have taken no further action to date, it is expected that legal
action may be forthcoming.
Also, the U. S. Environmental Protection Agency has required
an Environmental Impact Statement (EIS) on the proposed new
system before further planning or design can be funded. The
four major objectives stated in EPA's scope of work are:
1.	To identify, explain, and where possible quantify both
adverse and beneficial environment impacts which may result from
the implementation of the proposed projecto
2.	To identify and evaluate secondary effects, such as social,
physical, and economic impacts resulting from the implementation
of the proposed plan.
3.	To identify and evaluate long-term population projections
and distributions within the community and their effect upon land
use plans and zoning. An evaluation should be given to development
pressures in relation to adequate land use controls.
4.	An evaluation of water quality impacts and potential
health hazard that could occur as a result of the dispersion of
the effluent from the Prout's Neck Treatment Plant outfall. This
evaluation must consider the aesthetic quality of the water at the
beach areas within proximity to the outfall location. The contractor
will, as part of his environmental inventory, gather existing data
on human health hazards and viral diseases and apply such data as
necessary to text of the environmental impact statement.
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EPA has selected Booz Allen & Hamilton, Inc. of Bethesda,
Maryland to conduct this study and completion is scheduled in
early February, 1976. During the course of the EIS preparation,
the contractor will be in contact with parties showing prior
involvement and interest (both pro and con) in the proposed
project. The draft EIS will be subject to at least a 45-day
review period prior to completion of the final EIS, and a
public hearing will be held by EPA. The preliminary draft EIS
has been received by EPA and the final draft should be publicly
available by the end of November. The preliminary draft EIS
generally concurs that the proposed one plant concept is the
most sensible pollution abatement alternative for Scarborough.
It is expected that no further design efforts can be commenced
until the final EIS is completed and has been accepted by EPA.
Meanwhile, the Trustees are attempting to obtain additional
financial support from all possible sources. An application for
a final eligibility determination was filed with the Maine DEP
and their concurrence was received in September. Also, the
Farmers Home Administration (FmHA) has expressed their willingness
to entertain the District's application for grant and loan funds
for this project. A request for a review of possible funding
alternatives has been recently filed with the FmHA. The Trustees
are hopeful that funds from these sources will enable their
financial criteria to be met.
The Trustees have also taken positive action to utilize the
remaining capacity at the existing Oak Hill Treatment Plant to
provide service to an area cited in the consent order. A Farmers
Home Administration grant-loan award for a project to sewer about
fifty homes in the Oak Hill area has been received, and construction
is completed. This project had been planned for 1974, but the
bids received made the project financially impossible without grant
funds. This project will correct one of Scarborough's serious
problem areas named in the DEP's consent order. This sewer con-
struction project has been completed in an orderly manner and has
resulted in major overall improvement in the Oak Hill area. Also,
the total project costs were significantly less than estimated at
the time of construction bids.
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With regard to impact on the town's growth pattern and rate,
all the preliminary design calculations have been based on existing
zoning regulations and past trends. These calculations have been
carried out using information supplied by the Scarborough Planning
Board and with their full knowledge. At the Scarborough Sanitary
District's December, 1974 meeting, the Trustees requested information
concerning zoning and growth plans from the Town Council and
Planning Board. On January 16, 1975 the Trustees met in a workshop
session with the Town Council and Planning Board, at which time
the town officials stated they did not plan to change the present
zoning plan or regulations under which development could occur.
Based on the town's current plans for maintaining existing zoning
and development procedures, the Scarborough Sanitary District cannot
justify altering the basis upon which existing flow estimates have
been developed.
Starting with the current summer population in the area to
be served by the proposed treatment plant and using the proposed
slow growth rate of 80 residential units per year coupled with
commercial/industrial development to maintain the current balance
between commercial/industrial and residential development, the
design flow figures do not change substantially from previous
design estimates.
In summary, the Trustees have evaluated all the available
information relative to the alternative solutions to Scarborough's
pollution problems and are convinced that the recommended approach
is the most cost effective and practical solution.
Realizing that this program is a major step for the community,
the Trustees want to receive public input relative to the planned
system, financial planning and other aspects of the pollution
abatement program. Interested citizens are invited to attend the
District's regular monthly meetings and to submit written sugges-
tions and comments to the Scarborough Sanitary District, Board
of Trustees, P. 0. Box 302, Scarborough, Maine 04074.
Also, the Trustees urge the public to provide input to the
contractors preparing the EIS and to make their feelings known at
the EIS public hearing so that EPA will receive an overall view
of Scarborough's citizens' desires. Many decisions concerning the
final system and its implementation remain to be made. Only by
maintaining open communication channels can the Scarborough Sanitary
District Trustees best serve the interests of Scarborough citizens.
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We look forward to serving you in this important aspect of Scar-
borough's future and invite your comments and suggestions relative
to all District activities.
Very truly yours,
SCARBOROUGH SANITARY DISTRICT
BOARD OF TRUSTEES
Gerald Applebee, Chairman
Neal Jannelle, Vice Chairman
Richard Hesslein, Treasurer
Nan Jackson, Clerk
Anthony Attardo
Calvin Austin
Dana MacDonald
SSD/j
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SCARBOROUGH SANITARY DISTRICT
REGULAR FEBRUARY MONTHLY MEETING
February 26, 1975
Call to Order:
The meeting was called to order by Chairman Applebee at
7:30 p.m.
Roll Call:
Gerald Applebee, Chairman	-
Anthony Attardo
Calvin Austin	-
Richard Hesslein, Treasurer	-
Nan Jackson, Clerk	-
Neal Jannelle, Vice Chairman	-
Dana MacDonald	-
Others present were:
Raymond Field, Chief Treatment Plant Operator
John Hart, Treatment Plant Operator
Alvin Keene, Gorham International Inc. & S.S.D. Superintendent
Robert Hickman, Whitman & Howard, Inc.
Approximately six interested citizens
Minutes of January 22. 1975 Meeting:
On a motion by Mr. Austin, seconded by Mr. Attardo, the Trustees
voted (7 yeas - 0 nays) to accept the minutes as submitted.
Correspondence:
EXCELSIOR LABS: Correspondence concerning Excelsior's revoked
permits was summarized. The lien notice has been filed and Biddeford
Savings Bank, who has initiated foreclosure proceedings, has been
notified of the S.S.D.*s outstanding account relative to the property.
(OVER)
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are acceptable to the Sanitary District and to the Town, there is
no need to restudy the issue. It is true that accepting the plan
will perhaps limit the number of possible land use alternatives
and consideration of potential combinations of facilities and
controls to meet water quality, but that is not to say that Scar-
borough is not participating and will not get full benefit, especial-
ly on the other water quality issues, from 208 planning.
Mr. Keene stated that he had discussed the above letter-with
Mr. Hubbell and that COG's management plan would result from the
overall two year study and that it was a management plan, not an
engineering plan for specific projects.
Old Business:
NEW TREATMENT FACILITIES AND SEWER SYSTEM EXPANSION: Chairman
Applebee summarized the correspondence relative to this topic that
has occurred since the January meeting.
Mr. Applebee's January 28, 1975 letter to Mr. Adams, DEP. con-
veying the vote accepting the one-plant concept as presented in the
January 22, 1975 minutes. The letter also stated that Whitman &
Hoyard would forward additional technical information to the DEP.
Mr. Gormley's (DEP) January 30, 1975 letter to Mr. Applebee
acknowledged his January 28, 1975 letter and advised that the DEP
would be particularly interested in receiving an implementation
schedule including all areas cited in the consent order. He stated
the DEP's intention to have Scarborough*s plans taken up at the
Board's February 12, 1975 meeting.
Whitman & Howard's February 11, 1975 letter to the Trustees
with copies to the DEP presented a proposed implementation schedule
and an economic breakdown requested by the Trustees. By reference
that letter and attachments are made part of these minutes.
Mr. Gormley's (DEP) February 19, 1975 letter to the Trustees
stated that the Board of Environmental Protection had voted to delay
any action on the Scarborough project until the February 26, 1975
meeting. The two major reasons were:
1. To allow time for the DEP staff, Board members and S.S.D.
to review the information submitted in Whitman & Howard's February
11, 1975 letter.
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2. To enable the Board and DEP staff to review information
submitted by other interested parties in Scarborough. (Copies of
the information was submitted to the S.S.D. with Mr. Gormley's
letter. It consisted of letters from Mr. John Lee and Mrs. Lillian
Lee with attachments previously submitted to the S.S.D. and DEP.
Mr. Keene's February 20, 1975 letter to Mr. Gormley requesting
that the Board withhold any action on the S.S.D.*s plans until their
first meeting in March. The letter stated that at a February 18,
1975 workshop meeting, "all Trustees were in general agreement with
the implementation schedule as presented and with the one plant
concept as previously voted." However, no official vote would be
taken until the February 26, 1975 public meeting, to allow public
input prior to any vote. The Trustees also expressed their willing-
ness to appear at the Board's first March meeting to answer any ques-
tions from the Board or DEP staff.
The Trustees discussed the proposed new system and possible
funding alternatives at length. Mr. Hickman recommended that the
S.S.D. ask the DEP for a new eligibility determination to increase
the amount of EPA and DEP grant funds available for the project and
to apply to FmHA for grant and loan money to assist on the project.
It appears that only by receiving additional aid can the financial
criteria voted on at the January 22, 1975 meeting be met.
On a motion by Mr. Hesslein, seconded by Mr. Jannelle, the
Trustees voted (-7 yeas - 0 nays) to reaffirm their January 22, 1975
vote accepting the one plant concept with the following conditions:
1.	Annual user fee shall be no more than $137
2.	Initial front foot assessment shall not exceed $10
per front foot.
3* A readiness to serve charge for vacant lots shall
not exceed 40% of the annual user fee.
4.	Final plant site location may be altered depending
on comparative site development costs for existing
Scarborough Sanitary District - Owned site versus
purchase of a different site with improved soil con-
ditions.
5.	Snow Food Product's and Bayley Seafood Processing's
wastewaters shall be included in the flow to the new
treatment plant.
(OVER)
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6.	The implenation schedule presented in Whitman &
Howard's February 11, 1975 letter is adopted
subject to DEP and Board of Environmental
Protection approval.
7.	A financial committment or eligibility determina-
tion to enable compliance with conditions 1,2 & 3
above must be received from the DEP prior to
initiating any further design. (Any delays in re-
ceiving such financial committment to insure
meeting the above user charge criteria will
cause a similar set back of the implementation
schedule.)
On a motion by Mr. Austin, seconded by Mr. Attardo, the Trustees
voted (7 yeas - 0 nays) tc send a letter to the Farmers Home
Administration requesting financial assistance on the S.S.D.'s over-
all sewerage project.
The Treatment Plant Site Committee reported that they are still
investigating the possibility of procuring a better site in the
general area of the S.S.D.'s currently owned land.
OAK HILL PROJECT: Mr. Keene reported that Mr. Sewall, FmHA
said the S.S.D.'s loan-grant approval has been forwarded to Congres-
sional liason for an announcement and that barring unforeseen
difficulties, the grant offer would be forthcoming soon. Mr. Sewall
recommended that the S.S.D. go forward and finalize arrangements
with the Town Council for the proposed joint project.
On a motion by Mr. Attardo, seconded by Mr. Austin, the Trustees
voted (7 yeas - 0 nays) to send a letter to the Town Council requesting
a workshop meeting to discuss this project on March 11, 1975.
PERMIT ALLOCATION: On a motion by Mr. Hesslein, seconded by
Mr. Attardo, the Trustees voted (6 yeas - 1 abstention) to allow Nedia
Development to transfer sufficient permits (not to exceed 29) from
those now held in a readiness to serve status for use in their proposed
housing for the elderly project on a parcel of land on the south side
of Route 114. This transfer is contingent upon final Scarborough
Planning Board approval of the overall project and is subject to the
final sewer system plans receiving S.S.D. approval prior to permit
issuance and to meeting all S.S.D. rules and regulations.
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SCARBOROUGH SANITARY DISTRICT
REGULAR JANUARY MONTHLY MEETING
January 22, 1975
Call To Order:
The meeting was called to order by Treasurer Gerald Applebee
at 7:35 p.m.
Election Of Officers:
On a motion by Mr. Attardo,
Trustees elected (6 yeas, 0 nays,
Chairman for 1975.
On a motion by Mr. Attardo,
Trustees elected (6 yeas, 0 nays,
Vice Chairman for 1975.
On a motion by Mr. Attardo,
Trustees elected (6 yeas, 0 nays,
Treasurer for 1975.
On a motion by Mr. Attardo,
Trustees elected (6 yeas, 0 nays,
Clerk for 1975.
seconded by Mr. Jannelle, the
1 abstention) Mr. Applebee as
seconded by Mr. Hesslein, the
1 abstention) Mr. Jannelle as
seconded by Mrs. Jackson, the
1 abstention) Mr. Hesslein as
seconded by Mr. Hesslein, the
1 abstention) Mrs. Jackson as
Roll Call:
Gerald Applebee, Chairman
Anthony Attardo
Calvin Austin
Richard Hesslein, Treasurer	-
Nan Jackson, Clerk	-
Neal Jannelle, Vice Chairman	-
Dana MacDonald	-
Others present were:
Raymond Field, Chief Treatment Plant Operator
John Hart, Treatment Plant Operator
Alvin Keene, Gorham International Inc and Sanitary District
Superintendent
^Robert Hickman, Whitman & Howard, Inc.
Approximately 35 interested citizens
(OVER)
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Thus, the MWWCA is sponsoring legislation to deregulate all sewer
and sanitary districts from PUC review.
This affects the Scarborough Sanitary District in that the
Trustees voted in December to request the PUC's opinion relative to
interest rates for overdue accounts.
Old Business:
PLANS FOR SEWER SYSTEMS EXPANSION AND NEW TREATMENT FACILITIES:
Mr. Applebee had correspondence read that had been submitted relative
to the Scarborough Sanitary District future plans.
1.	A paper developed to add to the continuing discussion of
Scarborough *s future which was submitted by Mr. Richard Harvey was read.
Because of its length it is incorporated by reference as a part of
these minutes.
2.	A January 6, 1975 letter from Robert Hodgdon in support of
the proposal that he presented at the December 18, 1974 meeting. The
letter conveyed the following petition with 42 signatures:
The following Scarborough residents have indicated a willingness
to consider, reasonable, higher than usual sewer fees provided that
(1) a small treatment plant is considered for Higgins Beach, (2)
that this plant be a part of the overall sewerage treatment program,
for the.Town of Scarborough, and (3) that federal and state aid be
used where acceptable.
Mr. Applebee presented a summary of information relative to
the Scarborough Sanitary District's decision making process. The
following presents many of his major points:
1. From a Scarborough Sanitary District workshop session, the
following points were made:
a.	Town growth has been and should continue to be con-
trolled by the Town Manager, Council and Planning
Board.
b.	The first obligations of the Scarborough Sanitary
District are to solve existing problems and to
maintain reasonable user costs and fees. From
the Scarborough Sanitary District's engineering
and planning studies, it seems that this can best
be done by a one plant concept.
(OVER)
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c.	Reasonable user costs should be defined as $137
per year for existing and new residential users
and a maximum assessment of $10 per front foot
for new users. While not necessarily determing
the method of assessment, these figures should
be used in determining total project feasibility.
d.	Higgins Beach, Pine Point, Oak Hill, Black Point
and Willowdale should be considered in the first
phase. Also, Snow Food Products and Bayley Pro-
cessing should be included in the first phase.
2.	From the joint workshop session of the Scarborough Sanitary
District, Council and Planning Board held January 16, 1975, the
following points were presented.
a.	The Scarborough Sanitary District stated the four
points from Item 1.
b.	Council indicated that they had made plans to
answer DEP relative to the consent order. (Mr.
Steele's January 20, 1975 letter was read and
generally stated that the town was enforcing the
State Plumbing Code and that the Scarborough
Sanitary District must address the construction
of public sewerage facilities.)
c.	Council and Planning Board are not considering
rezoning as a method of growth control at this
time.
d.	Most Council and Planning Board members felt
that the Scarborough Sanitary District should
move ahead with the one plant concept.
3.	Mr. Applebee then explained the Scarborough Sanitary Dis-
trict's alternative approaches (one plant concept vs. decentralized
plants); the information imputs (Public hearings, Scarborough Sanitary
District meetings, Town Goals Committee, DEP, Scarborough Sanitary
District's engineers, Hunter and Ballew report, Town government,
other engineer's proposals, and other miscellaneous inputs); some
of the major points of consideration in selecting a plan; projected
numbers of users and estimated flows; advantages and disadvantages
of alternatives; potential phase construction process; and the fol-
lowing general conclusions:
a. The one plant system's advantages far outweigh
the decentralized system (except on the issue
of rapid growth).
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b.	The Scarborough Sanitary District has stated
that the Town government has and should have
the responsibility for control of growth.
c.	The DEP stated in a December 11, 1974 letter
to Mrs. Lee that, "the town should meet ordi-
nances to promote the amount of growth that is
desired by the town and not allow the sewer
system to dictate growth".
Mr. Applebee and other Trustees then expressed their personal feel-
ings relative to reaching a decision on a plan to satisfy the consent
order. Then, the audience commented on the topic.
Mrs. Mary Perry presented the following petition with 312
signatures:
"We, the residents of Scarborough are opposed to Plan A or System
C as presented by Whitman & Howard with lines through undeveloped
Rural Farm areas, Resource Protection and Flood Plains, which we feel
will bring undue pressure for development along the lines and resulting
uncontrolled rapid growth to pay for the system. Especially true
since neither the Council nor Planning Board have come up with, well-
defined controls, as mandated by the people.
Realizing the February 1 deadline we petition the Sanitary Dis-
trict to apply for 208 funds for further planning of "another viable
alternative" as suggested by Mr. Dennis Purrington at the November
Goals Committee meeting. We ask the Sanitary District to advise the
DEP of their intention and ask for a reasonable extension of limited
time in order to qualify for the next available sewage grants."
Dr. George Lord submitted an article entitled, "Sewage: Our
Most Neglected Resource", by Stuart Udall and Jeff Stanburg that was
published in the December 1974 issue (Volume 81, No. 6) of Annals of
Internal Medicine. The article discusses the use of land disposal
of treated wastewater effluents to reclaim its nutritional value and
obtain other potential benefits. Dr. Lord asked that the Scarborough
Sanitary District review the process as opposed to the ocean outfall
proposed.
After receiving other input from members of the audience, the
Trustees voted (7 yeas, 0 nays) on a motion by Mr. Hesslein, seconded
by Mr. Jannelle, to approve the following motion:
The Scarborough Sanitary District accepts the one plant concept
with the following conditions to be used as design input to the Scar-
borough Sanitary District's engineers:
(OVER)
195
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1.	Annual user fee shall be no more than $137.
2.	Initial front foot assessment shall not exceed $10
per front foot.
3.	A readiness to serve charge for vacant lots shall
not exceed 40% of the annual user fee.
4.	Final plant site location may be altered depending
on comparitive site development costs for existing
Scarborough Sanitary District - Owned site versus
purchase of a different site with improved soil con-
ditions.
5.	Snow Food Product's and Bayley Seafood Processing's
wastewaters shall be included in the flow to the new
treatment plant.
6.	Oak Hill and Willowdale will be incorporated into the
new facility either in the initial phase or at a later
date depending on the economic feasibility.
The above information was to be submitted to the DEP by the
Scarborough Sanitary District, and Whitman & Howard will provide addi-
tional technical input to the Scarborough Sanitary District and DEP
by the February 1, 1975 deadline.
New Business:
BUDGET: On a motion by Mr. Attardo, seconded by Mrs. Jackson,
the Trustees voted (7 yeas, 0 nays) to accept the 1975 budget as pre-
sented by Mr. Keene on behalf of the Budget Committee with the follow-
ing change:
Interest account increased from $1100 to $1750. The approved
budget is included by reference as part of these minutes.
PERMIT ALLOCATION: Mr. Keene presented the following applica-
tions for permit allocation:
Discussion pointed out that (1) the conditions of the sewage
systems at the existing houses of Mr. Libby and Mr. Hall are not
Webber Farms
Anthony Attardo
Dwight Libby
Earl Hall. 3rd
5	permits
2	permits
1	permit
1	permit
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TOWN OF SCARBOROUGH
Planning Board
SCARBOROUGH, MAINE
Open Letter From The Scarborough Planning Board Regarding The "Draft Environmental
Impact Statement, Waste Collection and Treatment Facilities, Scarborough, Maine".
January 29, 197&
The Scarborough Planning Board wishes to express its concern regarding the
construction of a sewage treatment plant in Scarborough. The Board is cognizant
of the growth pressures that may result from such an undertaking, as well as
those which will continue to be exerted without such construction. The intent
of the Planning Board is to arrive at a determination of its ability to cope
with the demands that materialize with either eventuality, and to assess the
benefits and oosts of each. Furthermore the Board will assess the relative
effeots associated with providing a system that serves only the areas designated
in the consent order and more widespread service to the majority of the Town
east of the Turnpike. This assessment will be quantitative if possible and
qualitative if necessary.
It is with disappointment and regret that the Board is unable to officially
state its position this evening. The members were not informed of the distribu-
tion until Monday, January 26, 1976, and since that time sufficient copies have
not been available to enable a detailed review. Copies have been obtained from
EPA (received 1/29/76), and the Planning Board will submit a written statement
by the February 12, 1976 deadline.
Very truly yours,
Thomas A. Kuczkowski
Chairman
TAK/pb
Planning — Key to the Future
197
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town of Scarborough
WAR8
P. O. BOX 327
SCARBOROUGH, MAINE 04074
CODE ENFORCEMENT
March U, 1976
Environmental Protection Agency
Attn: Environmental Impact Office
Room 2203
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Gentlemen:
At the public hearing held January 29, 1976 on the "Draft
Environmental Impact Statement, Wastewater Collection and Treatment
Facilities, Scarborough, Maine" the Scarborough Planning Board
committed itself to a stand, on the issue of a sewage treatment
facility for the town. Enclosed please find a copy of that state-
ment. Also enclosed is a list of editorial comments.
Your attention to the items discussed will do much to alleviate
much of the concern demonstrated by the citizens of Scarborough, and
will enable the final decision on a treatment system to be more
readily implemented.
If you have any questions or comments do not hesitate to
contact me.
J.
Charles J. Andreson
Town Planner/Engineer
Encs
CJA/pb
Greater Portland's Oldest Organized Community
198
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Editorial Comments
11-13 There are U sandy beaches. Fine Point has been
omitted.
11-22 and 11-23 Sampling stations and figure do not have
comparable identification.
11-53 Review of subdivisions is for the creation of 3 or
more parcels out of one not 4 + units.
II-60 is missing.
IY-5 The figure of 27,000 people is not explained in the
text. Where does it come from.
17-8 1st paragraph - the word dewatered should be deleted.
V-15 Is the "lack of medical data" due to state of the art
or lack of investigation on this project?
199
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Statement of Position
Scarborough Planning Board
Be: 'Draft Eaviroraaontal Impact Statement;
Wastewater Collection and Treatment
Facilities, Scarborough, Mains"
She Scarborough Planning Board feels that it is obligated to take a
position on -$ie issue of a sewage treatment system for the Town. The
Board believes that there is a demonstrated need for a sewage treatment
plant, and that the system that is implemented should be the one that
provides the most benefit at a reasonable cost* The Board is of the opinion
that further e^diausiivs research will probably not make the final decision
aay easier to reach, nor Hill it make that decision any mora reliable. The
decision must be made and mads soon.
Opponents to the proposed system seem to be pleading for more effective
treatment, rather than arguing against the need for a system. Also they axe
seeking the most economical system that can be provided* The E I S has
portrayed the centralised single plant concept as the most feasible. It has
not presented enough substantial material to allow a comparison by laymen to
conclusively arrive at that decision. The Planning Board would like to see
the following itents discussed farther so that a conclusive decision can be
made:
X. Growth ° A comparison of induced growth steaming from both single and
zmsltiple plant concepts.
2- Sludgge Disposal - The final sludge disposal method should be deter-
mined, and the environmental and financial consequences assessed.
Capital costs and annual operational and maintenance costs should be
clearly stated.
3* Multiple Trea-feaent Plant Concent - Due to the concern for a multiple
treatment plant concept, a more detailed evaluation of the associated
impacts is warranted. Such a statement should include quantified
enviroxaaental effects due tc effluent discharge into receiving water
bodies, and the impact upon costs. Such discussion should reflect
the erailability of federal funds for a mlti-plant system, and
requirements for additional treatment (and costs) associated with
effluent discharge to estuaries.
if. Tertisgy Treatment - Tertiary treatment as an available modification
to Hie proposed systems should be distressed. The maintenance of
hi{$i quality effluent could necessitate such treatment should actual
plant performance be less -than expected. Supporters of tertiary
treatment should be made aware of its practicality. Associated costs
should be discussed in detail.
200
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(2)
5. Coats - Costs of any system are "Has most crucial factor affecting
fee economic euceeas of the system. All costs as reflected by the
use? fees must be shorn clearly. If the annual user fed is to be
outrageously hlgjb it shotdd be mada knovm. Such an occurrence
could mks -the entire project economically unfeasible, mho
financial resources cf the general citizezrzy who will pay for tbe
system cannot be interpreted to be unlimited. Such a stand will
surely bring about a financial crisis as the sewage treatment
system becomes operational. It should be clearly stated where the
responsibility will lie and feimt the consequences will be should a
financial crisis occur.
Bug to the existing concern for user fees it is essential
tetat a detailed breakdown be presented as to uhat factors contribute
to the user fee (capital costs, anmal 0 & M, interest} eto.), and
how noa-aiigible costs (for federal and state funding), such as
construction of laterals, will be paid. A home owner should be able
to accurately figure his annual costs for sewage treatment based
upon material presented in the E I S. Failing this tho Scarborou^i
Sanitary Mstriot should publish such a document.
Generally speaking user fees should be discussed in terms of
constant dollars* A schedule or model of anticipated user fees
should be presented to estimate the user costs associated with the
various phases of construction and operation. Discussion of costs
should also reflect the costs associated with the sludge disposal
technique that is used (as discussed previously) • User fees should
be presented for the contra! versus the multiple plant system,
reflecting all associated costs. Ths iapaet of tertiaxy treatment
on user fees should also be presented. Alternative methods for
assessing user fees should be explored, especially basing the user
fee upon water consumption.
The most important issue at this point is to accurately predict the
user fees, front foot assassneat, and any other costs ¦feat will clearly
establish the total animal cost for sewage traats&nt that an individual
jssust pay.
Cusare&tly the Planning Board feels that the central system concept is
the most practical and economic.. Ihe Beard recognizes that the multiple
plant concept is said to provide additional benefits due to distributing
•file effluent to aore than one location, and in savings on the capital costs
of installing interceptors through expanses of unbuildable areas. Adequate
treatment of the coHKents contained in this papsr will permit a final
decision to be xea&o by the Planning Bcaxd.
201
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In the course of its review -fee Planning Board sougit
to TOX&fy Oi&t the population and growth projections vera
seasonable. The attached summary indicates that saturation
development of all buildable areas in B - 10 and R - U Zones
(those that will moot significantly affect the growth) would
result in a population increase of 12p212. This figure
constitutes ultimate population under existing zoning, which
compares favorably with the 8,300 ± person increase predicted
for 1995 on Page II-U3*
Whether residential zoning will remain as is, the
assumption isade for the saturation and the 1995 population
estimates ? is of course uncertain. Tovm policy regarding
the maintemme of zoning at its current status and adopting
other land use control methods, must be identified in a
eosapreihensive plan to demonstrate the town's committment to
control growth consistent with its adopted goals and objec-
tives. The Board is working actively to develop goals and
objectives for the town's adoption to ascertain and illus-
trate the town's coranittment to controlled growth.
202
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SOMMAHT OP POTENTIAL GROWTH IN SCARBOBOPCT
IH R-ii & R-10 ZONES WITH 3EWEBS
Zone & Location	AoreB
R-10 Oak mi	337*5
R-10 Pine Point	125
R-ll Dunatan Comer	350
R-ij Higgins Beach	300
R-k Oak Hill, West Side of Route 1	275
R-l* Oak Hill $ East Side of Routs 1	lf£0
(1)
Net Development AoreB
225
5.5
67
30
78.75
202
(2)
Population Increase
7200
176
858
381*
1008
2586
12,212
1. Bemovsd from gross acreage available
a)	Shoreland Zoned s
b)	Unbuildable soils and slopes
c)	Acreage needed for roads
cU	Existing developed land
e) Not expected to ever be developed
©. g. Sown or State owned land
2. 3.2 persons per new household
Coapiled by
Soarboxou{$i Planning Board
2/19/76
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a
Greater Portland m 1 1976
Council of Governments
President
EDWARD I. BERNSTEIN
Executive Director
OSMOND C. BONSEY
Director Of Planning
JOSEPH F. ZIEPNIEWSKI
February 27, 1976
Environmental Protection Agency
Room 2203
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Attention: Mr. Wallace Stickney
Dear Sir:
This letter is to review and comment upon the Draft Environmental Impact
Statement (EIS) by Booz, Allen, & Hamilton, Inc., for the proposed Scar-
borough Wastewater Treatment System.
The Greater Portland Council of Governments (GPCOG) finds this EIS to be
acceptable except as noted in the comments section of this letter. We
feel that when the deficiencies noted are addressed, the information nec-
essary to assess the proposed Scarborough wastewater treatment system
will be sufficient. We urge all concerned to proceed expeditiously be-
cause the existing situation should not be allowed to continue.
Specific portions of the EIS which did not provide the information neces-
sary to resolve the issues raised by Whitman and Howard's proposed Scar-
borough sewerage system are as follows:
1.	Sludge Disposal
Insufficient detail was developed by the consultant to permit the estima-
tion of cost for and feasibility of land disposal of sludge within the
Scarborough corporate limits. While it is true that Scarborough presently
disposes of 12,000 gallons of sludge weekly through land application, the
success of a land disposal system for 302,995 gallons weekly cannot be
assumed. Further, the cost for land disposal of sludge should be compared
with other disposal methods to assure cost-effectiveness.
2.	Effluent Disposal
The selection of an ocean outfall for effluent disposal should be supported
with, a) specific information on the impacts on the estuary of the existing
and proposed estuarine outfalls and b) a study of the feasibility of land
application of secondary effluent within Scarborough. Quantative analysis
of both alternatives needs to be undertaken.
204
169A Ocean Street • South Portland, Maine 04106 *207-799-8523
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Greater Portland Council of Governments
3.	Population
A discrepancy of approximately 4,500 people exists between the population
projection used in the EIS and the design population projection used by
Whitman and Howard. (Whitman and Howard assumed a seasonal population of
4,000 people and, therefore, projected a permanent population of 23,000
people). The financial implications of this discrepancy should be thor-
oughly explored.
4.	Non-Point Source Impacts
With the growth in Scarborough contemplated by either set of population
projections (see 3), the rise in storm related contaminate yields is ex-
pected to be significant. The proposed sewerage is widely believed to be
designed to protect the marsh ecosystem from degradation and restore the
clam flats to commercial productivity. Since non-point source contami-
nates, particularly bacteria, heavy metals, and conservative toxins po-
tentially threaten this goal, a detailed discussion of their expected
magnitude and effects is necessary.
If you have any questions or comments regarding this letter, please con-
tact Eric Root or John McGrail at (207) 799-8523.
Vp.tv—trulv vours.	)
Executive Director
T
OSB/md
205
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W&H
Robert T. Jones, President
Paul C. Bucknam, Jr., Treasurer
C. R. Wickerson, Chairman
C. Roger Pearson, Chm. Emeritus
Anthony Chiaravelotti
Elias A. Cooney
Brewster W. Fuller
Myles F. Howard
Frederick D. A. King, Jr.
James T. McDonough
Howard R. Perkins, Manager
James A. S. Walker, Arch. Ofiicer
Arthur T. Lucchini, Controller
Whitman & Howard, Inc.
Engineers and Architects
89 BROAD STREET, BOSTON, MASS. 02110 • TEL. (617) 426-6400
February 24, 1976
EST. 1869 — INC. 1924
ASSOCIATES
Gerald T. Carey
T. T. Chiang Ph.D.
Robert E. Crawford
Donald F. Dargie
Charles G. Ellis
Ernest H. Fagerstrom
Robert E. Hickman
George A. Howland II
Arthur Liatsos
James A. Little
Edward R. Mayer
Steven J. Medlar
James F. Murphy
Joseph A. Murphy
Environmental Impact Office
Environmental Protection Agency
Room 2203
John F. Kennedy Federal Building
Boston, MA 02203
Re:
Draft Environmental Impact Statement
Wastewater Collection and
Treatment Facilities
Scarborough, Maine
Gentlemen:
We are herein commenting on several statements given at
the January 29, 1976, public hearing for the above-named
project. Where possible, our responses have been coordinated
with the individual's comments, as follows:
1. Dr. Levy - There was a considerable presentation
by Dr. Levy, and others, concerning viruses and
accusations made as to the health hazards the
treatment facility would present through its
discharge of secondarily treated and disinfected
effluent off of Prout's Neck. Mr. Gallant appeared
to be the only person to recognize the fact that
raw sewage is presently being discharged into the
ocean and this practice will continue until such
time as a treatment facility is in operation. The
study and eventual control of viruses is extremely
important, but as Mr. Gallant correctly pointed
out, this is a new field, and it will be many
years before the practical control or elimination
of viruses will be available. To our knowledge
there have not been any adverse health conditions
created by the discharge of secondarily treated
effluent into the ocean. On the contrary, the
liklihood of such an occurance is immeasurably
reduced through the elimination of raw discharges.
206
Out /OS tL I jeax C^&ntinu&ui etvice
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We do agree with Dr. Levy that ozone is a
better disinfectant than chlorine, and we recommended
its use; however, the DEP insisted upon the use of
chlorine.
The Sonozone process about which Dr. Levy
spoke is a relatively new utilization of ozone and
one which we feel is entirely unnecessary. It is
claimed that in combining ozone with ultra-high
frequency sound, the effluent will be completely
disinfected in about one (1) minute. If ozone
were used the disinfection process would take
about two (2) minutes, but since a 30 minute
contact time is required for disinfection, the
additional equipment required for the Sonozone
process is totally unnecessary.
Another claim by Dr. Levy was that the existing
Higgins Beach sewerage system would be "... broken
into and will not function..." for a year while
the new sewers are being constructed. This is not
true. The existing system will obviously be
utilized until flow can be transferred to the new
system and treated. Sewer use to the residents
will not be interrupted.
Mr. Robert Pelleter - Mr. Pelleter was concerned
about the total cost of the project to the users
including Phases 2 and 3; however, we feel that it
is too premature to discuss the later phases.
Phases 2 and 3 were included in our 1972 report
merely as a guide for the future development of
the sewerage system. The development of the Town
and its resultant needs will set the priorities
upon which the future phases will be based. Thus,
the future phases must remain flexible if they are
to be realistic.
Once the District is able to accurately
assess its needs in the future, Phase 2 may be
formulated and its eligibility for federal and
state aid determined. Then it would be logical to
estimate the costs and evaluate them versus the
needs.
We, therefore, feel that a determination of
the user fees based upon Phases 2 and 3 presents
an unrealistic picture to the residents.
207
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-3-
The user fees for Phase 1 were determined
based upon the anticipated grant and loan from
FHA, and as may be seen from our January 27th
submittal, the estimated user fee is $146.
3.	Mrs. Lee - Contrary to Mrs. Lee's statement, the
plans for the Higgins Beach sewerage system were
completed several years ago, and submitted to the
District. The remaining design of Phase 1, however,
was suspended upon requests by the DEP.
4.	Ms. Lee - Ms. Lee stated "...biological systems
are subject to failure and they are frequent and
uncontrolable." Although it is true that biological
systems can be upset, this is also true of all
treatment processes if foreign or incompatible
substances are discharged into the system. However,
it is not true that the "failures", or more correctly
the upsets, are frequent and uncontrolable. To
our knowledge the Oak Hill plant has only been
upset once in its 10 years of existence. This was
caused by the unexpected loading from the Humpty
Dumpty Potato Chip Co. which overwhelmed the small
plant. Once the loadings were established and
adjustments made, the problems ceased. The proposed
facility with its more sophisticated design and
flexibility and increased monitoring will eliminate
problems such as the aforementioned.
In our opinion the biological treatment
process is the most advantageous for the Town of
Scarborough. It limits, to as great a degree as
possible, the amount of sludge that is produced
and also presents the most economical form of
treatment.
5.	Mr. John Lee - Mr. Lee made several erroneous
claims and left many wrong impressions, intended
or otherwise, in his statements. Generally, he
was incorrect in all of his statements concerning
the many treatment facilities we have designed in
Maine. The South Paris facility which recently
received awards in Engineering Excellance from
Water and Waste Magazine and the Consulting Engineers
Council of New England is operating very well. It
208
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-4-
was claimed that the "sludge problem" was not
addressed until after the plant was built; however,
this is totally untrue. A landfill site was
approved during the design phase, but the State
revised its criteria at the end of the design and
withdrew its approval of the site. Thus, public
hearings were held on a new site in an effort to
get public participation and select the most
desirable site for the District.
Mr. Lee answered his own comment about the
Kittery plant by stating that the reduction of the
Navy Yard was the reason for the decrease in flows
at the plant. Mr. Lee was badly informed about
the two plants in Kennebunk. The plants are not
3 MGD and .75 MGD, but 0.62 MGD and 0.126 MGD.
The smaller plant surves the resort areas in Town,
and it should be obvious that during the winter
months, the flow would be greatly reduced. Both
plants have been operating well for approximately
18 years.
There were several problems at the Biddeford
plant and these were investigated by both the
State and the EPA. It was found that the problems
were caused by Mayor Boucher. The Mayor made an
illegal connection of his sanitary sewer into the
storm drain. This caused raw sewage to be discharged
into a playground and eventually the river. The
Mayor also ordered the power to all pumping stations
in Town to be shut off. This obviously caused the
pumping stations to overflow and pollute the
river.
Mr. Lee never said what the "problems" were
concerning the other plants, but the design of all
plants is reviewed and approved by the State and
EPA and to our knowledge these plants are operating
well. However, it should be pointed out that good
design does not necessarily insure good operation.
The efficient operation of a treatment facility
also requires highly trained and competent personnel.
It was ^Aso wondered by Mr. Lee as to why the
exact locations for the outfall and the treatment
plant are not known. It is the function of a
preliminary report to determine the general location
of these facilities, the exact location can only
be determined during the final design stage after
a considerable amount of survey has been completed.
209
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-5-
The final location will be very close to that
determined in the preliminary report and will not
substantially affect the preliminary costs presented.
We would also like to make a few general comments
concerning several aspects of the project. The preliminary
engineering report prepared in 1972 determined the plant to
be a 3 MGD facility, however, it should be pointed out that
the design presented was a preliminary design. The parameters
are flexible and will be revised to reflect the most up to
date findings. Thus, it is and always has been fully expected
that the final design parameters will be formulated only
after the final design phase has begun and all of the desired
in-put from the District, Town and the various federal and
state agencies has been evaluated. As is usual, the final
design parameters will be submitted to the DEP for their
review and approval.
In all probability the design population will be reduced
from 27,000 to 25,000 which would decrease the average daily
design flow by 200,000 gallons, but this may be offset by a
possible increase in the industrial flow from Snow's Food
Products.
It has been suggested that the treatment facility be
constructed in phases; however, this would prove to be a
false economy and not the most cost-effective approach. The
initial flow to the proposed facility will be about 1 MGD.
Thus, the minimum plant which could be constructed would be
1.5 MGD, and in all probability, the additional 1.5 MGD
would have to be added in about 5 years. In the last five
years the construction cost index has risen 57%. Assuming
this rate to continue, and coupling this with the already
increased costs of phased construction could possibly bring
the total increase up to 70% over the original cost. It is
also a possibility that within this period the federal
funding program would be reduced or even eliminated, thereby,
causing the project to be economically unfeasible.
There has also been a considerable controversy over the
ocean outfall. Scarborough has two possible alternatives
for effluent discharge, land or ocean. Based upon what is
presently known about the Town and the fact that its soils
cannot handle the existing individual septic systems, it
should be obvious that land disposal of the effluent is totally
unrealistic. The only reasonable alternative is ocean
discharge since discharge into an estuary would only compound
any real or imagined problems.
210
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-6-
In our study of the proposed ocean outfall, it was
never claimed that the discharge would be carried out to
sea. The only conclusion that could be drawn was that the
effluent would be well mixed and its direction of travel
unpredictable, however, the travel tendency was parallel to
the shore in an eastward direction. But even on the days
that the effluent traveled toward the shore, it could not be
considered a health hazard because of its high degree of
treatment and substantial dilution.
We strongly agree that sludge is one of the most serious
problems associated with any treatment facility, but we also
believe that Scarborough has more sludge disposal options
available than most other communities. In the past the
District has had great success in landspreading its sludge
and this is certainly a viable alternative for the future.
Sludge disposal may also be accomplished via land filling,
or a combination of the two. A third alternative would be
incineration; however, this is a very costly precedure and
would greatly increase the operation cost for the facility,
and, therefore, cause a significantly higher user fee.
It is obvious that more investigation must be done on
sludge disposal, and we feel that it should be done during
the final design phase where it can be coordinated with the
actual final design of the treatment facility.
If there are any questions in any of the aforementioned
comments, please do not hesitate to contact us.
Very truly yours,
WHITMAN & HOWARD, INC.
Donald F. Dargie, P.E.
Associate
DFD/jml
cc: Scarborough Sanitary District
211
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United States Department of the Interior
OFFICE OF THE SECRETARY
NORTHEAST REGION
JOHN F. KENNEDY FEDERAL BUILDING
ROOM 2003 M & N
BOSTON, MASSACHUSETTS 02203
March 8, 1976
In Reply Refer To:
EGS-ER-76/24-MS 760
Dear Mr. McGlennon:
We offer the following comments on the draft environmental impact statement
on wastewater collection and treatment facilities for Scarborough, Maine.
Cultural resource protection considerations are not fully satisfactory.
The discussion of these aspects under section 2.2.7 adequately covers
sites currently on the National Register of Historic Places and those
which are for nomination to the National Register which should be considered.
We suggest the Environmental Protection Agency consult with the State
Historic Preservation Officer (Mr. H. Sawin Millett, Jr., Director, Maine
Historical Preservation Commission, 31 Western Avenue, Augusta, Maine
04330) and display and discuss the results in the final environmental
statement.
The general discussion of human history and occupancy in the area
(sec. 2.2.7) evokes a concern for the protection of archaeological resources
that may be present. We find no substantiation in this document for the
outlook in section 5.2.3 (concerning the project impacts) that archaeological
resources will not be disrupted or disturbed.
The information in the section on geology and soils (p. II-2) is either
insufficient or so unclearly presented that we cannot judge the soil
strata wherein archaeological sites might occur. Therefore, we cannot
agree with the notion that because the project work will not require
deep excavations, it is unlikely that archaeological values will be
found. We urgently recommend that a qualified archaeologist such as
Mr. Steven Perlman, Geography and Anthropology, University of Maine,
Gorham, Maine 04038, be consulted regarding the potential for archaeo-
logical resources in the project area and that his comments be displayed
and discussed in the final environmental statement.
We agree that contractors should be seriously impressed with the urgency
to immediately report any archaeological finds. In fact, their work
operations should be systematically conditioned to provide for such events.
,vlo\-UT'0/v
'•^6-191* @
212
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Page 2
As a key precaution to any inadvertent resource damage and to avoid upset
to construction schedules and/or progress, an advance determination of
resource potential and probable site locations is the only real solution.
The archaeological consultation mentioned above could provide this or can
certainly be a guide toward an adequate determination.
The statement should include a more accurate indication of the location
of parks and recreation areas. It should explicitly indicate whether
or not the proposed project facilities will directly impact any park or
recreation area.
Also, a question arises as to whether it is possible that the project
will induce a major increase of vacationers which in turn would disrupt
treatment operations due to periodic overloading. If such operational
failure is possible, safeguards which would be taken to forewarn and
protect the swimmers should be described in the environmental impact
statement.
In regard to surface water resources, we note that water quality near
the proposed ocean outfall off Prout's Neck is within state standards
(p. 11-21, par. 2.1.5(3)). We suggest that monitoring measures should
be considered for this offshore area in order to maintain the water
quality integrity. Further, in view of the number of septic tank
sanitary waste disposal facilities that will be abandoned in the service
area, the environmental statement should include discussion of measures
for treatment of abandoned septic tank systems.
In general, the environmental statement indicates proper consideration
of ground water resources in relation to most aspects of the proposed
project and its alternatives. However, we do not find any evaluation
of beneficial or adverse impacts from exfiltration or infiltration in
the proposed system, or of export of ground water or of water that is
potential recharge to ground water through the proposed ocean outfall.
These aspects should be discussed; furthermore, the ground water impacts
of the proposed alternative, land application of effluents and use of
holding lagoons (p. 111-17) should be evaluated.
Mr. John A. S. McGlennon
Regional Administrator, Region I
Environmental Protection Agency
John F. Kennedy Federal Building, Room 2203
Government Center
Boston, Massachusetts 02203
Sincerely your;
the Secretary
213
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
MANCHESTER AREA OFFICE
DAVISON BUILDING, 1230 ELM STREET
MANCHESTER, NEW HAMPSHIRE 03101
REGION I
Room 800
John F. Kennedy Federal Building
Boston,-Massachusetts 02203
February 27, 1976
IN REPLY REFER TO:
1.3SS
Environmental Protection Agency
Attention: Environmental Impact Office
Room 2203
John F* Kennedy Federal Building
Boston, Massachusetts 02203
Gentlemen:
We have reviewed the Draft Environmental Impact Statement for the
Wastewater Collection and Treatment Facilities proposed for con-
struction in Scarborough, Maine.
We believe that many areas of discussion in the draft have been
adequately treated, and agree that the proposal represents a good
alternative to solving water quality problems.
However, it is noted that the substantial differences in popula-
tion projections of 27,000 by Whitman and Howard and 18,500 by
Booz, Allen and Hamilton are not adequately treated in the draft.
This subject should be more fully addressed in the final state-
ment, with particular emphasis on resultant land use considerations.
For example, the draft should specifically compare total land area
currently considered not suitable for development with the area
which could be developed as a result of construction of the system
and logical extensions from the system to the collection service
area.
We have no other comments regarding the proposal find have no ob-
jections to your proceeding.
Thank you for the opportunity to review the proposal.
Buchanan
214
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O^jjv
U. S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
REGION ONE

Room 614, Federal Building
Augusta, Maine 04330
January 28, 1976
IN REPLY REFER TO:
01-23
Environmental Protection Agency
Attn: Environmental Impact Office
Room 2203, J. F. Kennedy Federal Bldg.
Boston, Massachusetts 02203
Gentlemen:
This Division has reviewed the Draft Environmental Impact Statement
for the Scarborough, Maine, Wastewater Disposal System. With regard
to the installation of interceptor and collector sewers within the
right-of-way of State highways, it will be necessary to comply with
the policies and regulations of the Maine Department of Transportation.
We find that the proposed wastewater system will have little impact
on highway transportation. It will have no impact on the Federal-
aid highway program.
This response is made on behalf of Mr. Robert E. Kirby, Regional
Federal Highway Administrator, Region I.
Sincerely yours

JAN 3 0 1976
215
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''4IIS 0»
U. S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
REGION ONE
Room 614, Federal Building
Augusta, Maine 04330
KB 17 !3/s
February 12, 1976
IN REPLY REFER TO:
01-23
Environmental Protection Agency
Attn: Environmental Impact Office
Room 2203, J. F. Kennedy Federal Bldg.
Boston, Massachusetts 02203
Gentlemen:
Transmitted herewith is a copy of a letter dated February 4, 1976
from the Maine Department of Transportation to this office. The
State's letter includes comments regarding the DEIS for the pro-
posed Scarborough, Maine, Wastewater Collection and Treatment
Facilities.
This letter supplements our response of January 8, 1976 on behalf
of Mr. Robert E. Kirby, Regional Federal Highway Administrator,
Region I.
Sincerely yours
Ja
Division Administrator
Enclosure
216
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Pslvuavjr kt 1976
Mr* J* J« Barakos
Division Administrator
fodsni Hi^asser AdKtaiaftraAJUM
Btym At/t[| ^gfamd
Augustae Mains Qfc&Q
Subleti Se&xfeaarougbWastewater GoUsetlo&aKl ftwtoirt Pssllitiss
Bsear Mr* Borates#
Ifo boss mlwdi emsspte of the above ftasffc BwAffoaassHfeal Sqpast Statsasnt
end off«r ths foll«#ing soaenats for possible inclusion in say response yea aaor
casks to the awdUranaeafcal Fvotastlon Agmqr*
1« P# U - 109 2Xi Hmts and leoattnna of traffls figures should b©
bettsr defined in order to verify.
2« P0 II-78t She year of traffic is probably 1974* not 1973* there U
a year-found intorehsnga tdblia ths torn. Units of SsavWoa^ (Hon
ftunplks XBtershanga with 1*295)•
3* P* H-88* Propoesd ata&o Protests la Scarborough laeludb iteai 63 (if
the 1976-77 Hitfwp end Bridge Zsprevsanafc Psogpsa tdiieh proidss for
tjraffis flpmUgMi i^vmnfei (inoladin®
nodsxaiSaEtlon and rseoBStsoetAan) «t ths ifiktmcUn of &.S* A and
Bortss 114 and 207 la Oak 81I1U
4» P« I2-91t Ths HDOT unit sited should be the Bureau of Flaming, net
th« Division of fraffts &*gine*ftiig«
5* P* V-3« fhs traffle volume aim is for the Spuratak Boad, not ths
Blssk Point Boed*
60 P*	His I069 unit sitsd rinnld be ths Bureau at ftaariaa not
the Qtoiaiao of trsfff&s &qginaer4qg»
Wwy twfly yours.
mass mfBioi op fiuwosmisii
t- tfain ag»- flown* cua4w»n
-------
UNITED STATES DEPARTMENT OF COMMERCE
The Assistant Secretary for Science and Technology
Washington, D.C. 20230
February 17, 1976
Mr. John A. S. McGlennon
Regional Administrator
Environmental Protection Agency
Attn.: Environmental Impact Office
Room 2203
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
This is in reference to your draft environmental impact
statement entitled "Wastewater Collection and Treatment
Facilities Scarborough, Maine." The enclosed comments from
the National Oceanic and Atmospheric Administration are
forwarded for your consideration.
Thank you for giving us an opportunity to provide these
comments, which we hope will be of assistance to you. We
would appreciate receiving six (6) copies of the final
statement.
Sincerely,
(k?
Sidney R. (feller fj
Deputy Assistant Secretary

Sidney R. Sailer f J
Deputy Assistant itercretary
for Environmental Affairs
Enclosure - Memo from: N0AA (2-4-76)
FEB 24 1976
-------
U.S. DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
Rockville, Md. 20852
February 4, 1976	Replyt0 Attn of.
William Aron
EE
	
Robert Kifer
OCZM
7601.06 - Wastewater Collection and Treatment Facilities
Scarborough, Maine
The Office of Coastal Zone Management finds that the proposers
did not discuss Maine's participation in the CZMA, nor inves-
tigate conformity of the action with any stated CZM goals.
The Maine CZM agency, however, will provide commentary through
the A-95 clearinghouse.
219
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Advisory Council
On Historic Preservation
I 522 K Street N.W.
Washington, D.C. 20005
February 26, 1976
Mr. John A.S. McGlennon
Regional Administrator
U. S. Environmental Protection Agency-
John F. Kennedy Federal Building-Rrn 2203
Boston, Massachusettes 02203
Dear Mr. McGlennon:
Thank you for your request for comments on the environmental statement
for the proposed Wastewater Collection and Treatment Facilities in
Scarborough, Maine. Pursuant to our responsibilities under Section
102 (2) (c) of the National Environmental Policy Act of 19^9 and the
Council's "Procedures for the Protection of Historic and Cultural
Properties" (36 C.F.R. Part 800), we have determined that your draft
environmental impact statement mentions properties of cultural and
historical significance; however, we need more information in order to
evaluate the effects of the undertaking on these resources. Please furnish
additional data indicating:
(a)	Compliance with Executive Order 11593 of May 13. 1971 (l6 U.S.C.
V70). The environmental statement must demonstrate that either
of the following conditions exists:
1.	A property eligible for inclusion in the National Register
of Historic Places is not located within the area of the
environmental impact of the undertaking, and the undertaking
will not affect any such property. In making this determin-
ation, the Council requires evidence of consultation with
the appropriate State Historic Preservation Officer and
evidence of an effort to ensure the identification of such
properties. The Council recommends that comments of the
State Historic Preservation Officer be included in the final
environmental statement.
2.	A property eligible for inclusion in the National Register
is located within the area of environemtnal impact, and the
undertaking will or will not affect any such property. In
cases where there will be an effect, the final environmental
statement should contain evidence of compliance with the Exec-
utive Order through the Council's "Procedures for the Protection
of Cultural and Historic Properties" (36 C.F.R. Part 800).
(b)	To ensure a comprehensive review of cultural and historical prop-
erties, the Advisory Council recommends that the environmental
220
The Council is an independent unit of the Executive Branch of the Federal Government charged by the Act of
October 15, 1966 to advise the President and Congress in the field of Historic Preservation.
-------
Advisory Council
On Historic Preservation
1522 K Street N.W.
Washington, D.C. 20005
statement contain evidence of contact with the appropriate State
Historic Preservation Officer. A copy of his comments concerning
the effects of the undertaking upon these resources should be in-
cluded in the environmental statement. The State Historic Preservation
Officer for Maine is Mr. Sawin Millet, Jr., Director Maine Historic
Preservation Commission, 31 Western Avenue, Augusta, Maine 0^330.
Should you have any questions on these comments or require any additional
assistance, please contact Jordan Tanneribaum of the Advisory Council staff
at (202) 254-3380.
Sincerely yours,
John D. McDermott
Director, Office of Review and
Compliance
221
The Council is an independent unit of the Executive Branch of the Federal Government charged by the Act of
October 15, 1966 to advise the President and Congress in the field of Historic Preservation.
-------
DEPARTMENT OF THE ARMY
NEW ENGLAND DIVISION, CORPS OF ENGINEERS
424 TRAPELO ROAD
WALTHAM, MASSACHUSETTS 02154
reply to
ATTENTION OF:
NEDPL-R
9 February 1976
Mr. John A.Si McGlennon
Regional Administrator
Region I
U.S. Environmental Protection Agency
J.F.K. Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
A review has been made of the Draft Environmental Impact Statement,
Wastewater Collection and Treatment Facilities, Scarborough, Maine.
Below, please find our comments concerning this DEIS.
1.	It is noted that a Department of the Army permit will be
required for the construction of the discharge structure and for any
pipeline crossings of the Scarboro River, Nonesuch River, Libby River
and Jones Creek, as described in the alternatives.
2.	It should also be noted that if sewer lines cross any navi-
gable water, and any wetlands which are adjacent or contiguous to
navigable waters, a Corps of Engineers permit will be required.
3.	The final statement should address itself to the actual
extent of the dredging which will be required for the work. It
should also address the extent of discharge of dredged or fill
material in the waters and adjacent wetlands. These factors should
be covered in detail in the final statement.
4.	The impacted areas of navigable waters and adjacent or con-
tiguous wetlands should be adequately displayed. It is difficult to
determine where construction takes place through wetlands or waterways
as provided on the site plans in alternatives one through four (pages
III-5, 111-9, and 111-12), and in the proposed action, (page V-10).
5.	It appears that the treatment plant, and perhaps one or more
pumping stations will be constructed in a wetland and, therefore, would
require a Corps of Engineers permit for the fill.
5-

FEB 11 1978
^6-191*
222
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NEDPL-R
Mr. John A.S. McGlennon
9 February 1976
6.	More information should be provided to detail the present
environmental setting of the proposed treatment plant in order to
assess its difference from the environmental setting of the alter-
native site, (pages II1-18 and II1-20).
7.	The construction of an ocean outfall should be addressed further
to provide adequate information to assess the impact on aquatic organ-
isms of the affected area (page 111-6, V-2). We suggest that alter-
native ocean sites for the outfall be presented, should the proposed
construction route prove unacceptable (pages 111-17, 18).
8.	The outfall location should be shown on figure 4.1-1.
9.	We would favor minimizing any negative environmental impact
through timely scheduling of construction phases, (page V-10).
Please include any further information detailing the environmental
impacts of the proposed action, and any alternatives, on navigable
waters and wetlands. Review of this information and its inclusion
into an Environmental Impact Statement is necessary prior to any
action on a Corps of Engineers permit application.
Please contact Mr. William McCarthy of ny staff so that the Final
Environmental Impact Statement includes all the necessary information
required for Corps of Engineers actions on the entire project. Other-
wise, it may be necessary for us to prepare a separate Environmental
Impact Statement for the omitted portions, and this is not in accordance
with CEQ guidelines.
Sincerely yours,

f'JOSEPH L. IGNAZIO
Chief, Planning Division
223
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PETITIONS RECEIVED BY EPA
REGARDING POPULATION
AND GROWTH MANAGEMENT IN
SCARBOROUGH
224
-------
J
We, the undersigned taxpayers and residents of Scarborough oppose the present massive
sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the majority of Scarborough citizens.	K /X /
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We, vie undersigned taxpayers ana residents 01 scarDorougn oppose one present, raa^axve
sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an aooropriate alternative sewer plan be developed by the District.
Ke petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najority of Scarborough citizens.
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We, the undersigned taxpayers and residents of Scarborough oppose the present massive
sewer plan which would go through undeveloped rural farn zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth, and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
Ke petition the Sanitary District, Town Council, Planning Board, EPA, and DSP
to respect the wishes of the aajority of Scarborough citizens.
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We, the undersigned taxpayers and residents of Scarborough oppose the present massive
sewer plan whi;h would go through undeveloped rural farm zones because it would force
too rapid gro»~ h and overburdening increased costs, and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted b7 the Council should reflect the wishes of the people for slow orderly growth
ar.d that an appropriate alternative sewer plan be developed by the District.
Ve petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the majority of Scarborough citizens.	fly



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-------
We, the undersigned taxpayers and residents of Scarborough oppose the present massive
sewer plan which would go through undeveloped rural farm zones because it vould force
too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Haster Plan prepared by the Planning Board and
accepted b7 the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najority of Scarborough citizens.

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Ve, the undersigned taxpayers and residents of Scarborough oppose the present massive^ j
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Ve want slow growth and feel a Master Plan prepared by the Planning Board and
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prrf that an appropriate alternative sewer plan be developed by the District.
Ve petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najority of Scarborough citizens.
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We, the undersigned taxpayers and residents of Scarborough oppose the present massive
sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the majority of Scarborough citizens.
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sewer plan which v>o'x-d go through undeveloped rural farm zones because it would force
too rapid growth arid overburdening increased costs and taxes.
We want slow growth asd feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
He petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the majority of Scarborough citizens.


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We, the undersigned taxpayers ana resxaeuwj cu oumuuiuu6n	- — r—	
sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
. and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the majority of Scarborough citizens.

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sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najority of Scarborough citizens.

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sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and o~erturdecing increased costs and taxes•
We want slow growth tnd feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najority of Scarborough citizens.
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We, the undersigned taxpayers and residents of Scarborough oppose the present massive
sewer plan which would £3 through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth ana feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the majority of Scarborough citizens.

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We, the undersized -taxpayers and residents of ScarDorougn oppose w.c i-".		
sewer plan which would go through-undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth sad feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najority of Scarborough citizens.

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We, the undersigned ta_xpayer3 and residents of Scarborough oppose the present massive t
sewer' plan which would go through undeveloped rural farm zones because it .would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth ana feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the n&jority of Scarborough citizens.	'"L/* ~
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We, the undersigned taxpayers and residents of Scarborough oppose the present massive
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too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the raajority of Scarborough citizens.
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We, the undersigned taxpayers and residents or ScarDorougn	u.c			
sewer plan which would go through 'undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District•
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najorlty of Scarborough citizens.
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we, tne Uiiuei aJ-^ueu	c^u»~ *			 -**
sewer plan vhich would, go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
He want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najority of Scarborough citizens.
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We, the undersigned taxpayers and residents of Scarborough oppose xne present
sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want clow growth and feel a Master Plan prepared by the Planning Board and
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accepted by the Council should reflect the wishes of/the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
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We, the undersigned taxpayers and residents of Scarborough oppose the present massive
sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
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Ve, the undersigned t^ipavers and residents of Scarborough oppose the present massive
sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth asd feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najority of Scarborough citizens.

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244
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We, the undersigned taxpayers and residents of Scarborough oppose the present massive
sever plan vhich would £o through undeveloped rural farm zones because it would force
too rapid growth ar.d overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
Ke petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the aajority of Scarborough citizens.

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Ke, the undersigned taxpayers and residents of Scarborough oppose the present massive,
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Ke want slow growth and feel a Master Plan prepared by the Planning Board and
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and that an appropriate alternative sewer plan be developed by the District.
Ve petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
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Ve, the undersigned taxpayers and residents of Scarborough oppose th® present massive
sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
Ve want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by tie Council should reflect the wishes of the people for slow orderly growth
and that an £parot>riate alternative sewer plan be developed by the District.
Ve petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the majority of Scarborough citizens.

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We, the undersigned taxpayers and residents 01 scarDorouga oppose urn pic
sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
Ke want slow growth and feel a Master Plan prepared by the Planning Board and
accepted tsy the Council should reflect the wishes of the people for slow orderly growth
pud that an appropriate alternative sewer plan be developed by the District.
Ve petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najority of Scarborough citizens.
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We, the undersigned taxpayers and residents of Scarborough oppose the present massive"
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too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the majority of Scarborough citizens.






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We, the undersigned taxpayers and residents of Scarborough oppose the present massive'
sewer plan which vould go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth and reel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the aajority of Scarborough citizens.
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sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow'growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the majority of Scarborough citizens.
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fewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth ana feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
He petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najority of Scarborough citizens.
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Ve, the undersigned taxpayers ar.d residents of Scarborough oppose the present massive
Sever plan which would go through undeveloped rural fana zones because it would force
too rapid growth and overburdening increased costs and taxes.
Ve want slow growth and feel a Master Plan prepared by the Planning Board and
accepted fc7 the Council should reflect the wishes of the people for slow orderly growth
end that an appropriate alternative sewer plan be developed by the District,
Ve petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najority of Scarborough citizens.



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Ve, the undersigned taxpayers and residents of Scarborough oppose the present massive
sewer plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
ne want slow grovth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the najority of Scarborough citizens.
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We, the undersigned taxpayers and residents of Scarborough oppose the present massive
sever plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes*
We want slow growth and feel a Haster Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
nnrf that an aporooriate alternative sewer plan be developed by the District.
ri'e petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the majority of Scarborough citizens.
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We, the undersigned taxpayers and residents of Scarborough oppose the present massive"
seusr plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people, for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect,the wishes of the majority of Scarborough citizens.



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We, the undersigned taxpayers and residents of Scarborough oppose the present massive
sower plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
' and that an appropriate alternative sewer plan be developed by the District.
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect the wishes of the majority of Scarborough citizens.
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We, the undersigned taxpayers'a^d residents of Scarborough oppose xne presenv nuwaivc
r.ewt-r plan which would go through undeveloped rural farm zones because it would force
too rapid growth and overburdening increased costs and taxes.
We want slow growth and feel a Master Plan prepared by the Planning Board and
accepted by the Council should reflect the wishes of the people for slow orderly growth
and that an appropriate alternative sewer plan be developed by the District*
We petition the Sanitary District, Town Council, Planning Board, EPA, and DEP
to respect.the wishes of the majority of Scarborough citizens.

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258
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SECTION III
TRANSCRIPT OF PUBLIC HEARING ON
DRAFT EIS
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1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
PUBLIC HEARING
on
DRAFT ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER COLLECTION AND TREATMENT FACILITIES
SCARBOROUGH, MAINE
Scarborough Junior High School
Scarborough, Maine
7:00 o'clock p.m.
Thursday, January 29, 1976
PANEL MEMBERS:
WALLACE STICKNEY, Director, Environmental Impact
Office, Environmental Protection Agency, John F.
Kennedy Building, Boston, Mass. 02203
ALAN FARKUS, Booz,.Allen and Hamilton, 1 Bulfinch
Place, Boston, Mass.
:>
SATISH SURYAWANSHI, Booz, Allen and Hamilton,
1 Bulfinch Place, Boston, Mass.
LaMONT CURT-IS, Jr., Havens and Emerson
DENNIS PURINGTON, Chief, Division of Municipal Ser-
vices, State of Maine Department of Environmental
Protection
DAVE ACHORN, Chief Engineer, Division of Municipal
Services, State of Maine Department of Environ-
mental Protection
B. P. A. REPORTING ASSOCIATES, INC.
STENOTYPE REPORTERS
294 WASHINGTON ST. (SUITE 401)
BOSTON. MASSACHUSETTS 02108
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SPEAKERS
Alan Farkus
LaMont Curtis, Jr.
Harvey Warren
Thomas Sitzkowsky
Dr. Richard Levy
William Brooks
William Hillock
Valerie Lee
Robert Pelletier
Rebecca Warren
John Lee
Mr. John Lee
Linda Fuller
Dr. Robert Richie
William Gallant
William K. Bayley
Robert Hodgdon
Dr. James Maier
Donald Googan
David Jordan
Linwood Higgins
Sidney Woodcock
INDEX
PAGE
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46
55
59, 12{
64
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102
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123
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SPEAKERS	PAGE
Larry Wilworth	127
Clarke Libbey	133
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PROCEEDINGS
MR. WALLACE STICKNEY: Good evening, ladies
and gentlemen. If I could have your attention,
we will begin.
I have been asked to announce by the
Management that there is no smoking in the hall,
which is of course only fitting for an EPA hearing
anyway. We appreciate that and we appreciate
your cooperation.
My name is Wallace Stickney. I am Director
of the Environmental Impact Office, the Boston
Regional Office of the Environmental Protection
Agency. With me this evening on the hearing
panel are Mr. Alan Farkus of the firm of Booz,
Allen, Incorporated, which has acted as the prime
consultant to EPA for the Impact Statement;
Mr. Satish Suryawanshi of Booz, Allen; next
Mr. LaMont Curtis, Jr. of the firm of Havens and
Emerson who also assisted in the preparation of
the Statement; Mr. Dennis Purington, Chief of
the Division of Municipal Services, State of
Maine, Department of Environmental Protection;
and Mr. Dave Achorn, Assistant Engineer, Division
of Municipal Services, State of Maine, Department
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of Environmental Protection.
The hearing has been convened to receive
public comments on the draft Environmental Impact
Statement for the proposed wastewater collection
and treatment facilities in Scarborough, Maine,
for which the EPA anticipates that an application
for Federal funding will be submitted in the
future. This draft Environmental Impact Statemen :
has been prepared, as required by the National
Environmental Policy Act of 1969, and pursuant
to the Environmental Protection Agency regulation'!
promulgated as required by that Act, which appear
in the Code of Federal Regulations 40, Part VI,
The National Environmental Policy Act of 1969
requires that, prior to/ commencing any major
Federal action having a significant affect on the
environment, the responsible Federal agency must
prepare an environmental impact statement which
analyzes the potential environmental impacts of
various solutions to the problem; in this case,
existing and piy&dicted water quality problems.
By the way, I would like to point out at this tim«
and emphasize that the decision to prepare this
Environmental Impact Statement does not evolve
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from a lack of confidence in the work which has
been done before. It is not meant to accuse any-
one of not doing their best work in the past or
does not question the intentions of anyone
associated with the project in the past. It is
a step in the Federal funding process which we
must complete in order to fund the projects where
there are serious environmental questions, and in
particular, there is a serious controversy on
environmental grounds.
The Environmental Impact Statement was made
public early in January. Many of you got your
copies about that time, I would hope, and received
an effective date of January 7 from the Council
on Environmental Quality. The comment period
required for an impact statement is 45 days and,
therefore, the comment period for this statement
would close, I believe, on February 21st. The
record of this hearing will remain open, of course
until that date and, if you feel you would like
to submit further comments in writing directly to
the EPA after the hearing.
I ought to also make two comments relative to
this document and the testimony and comments that
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we expect to receive tonight. First of all,
the documents is a draft and considerable flexi-
bility remains in the process. However, we did
indicate that preliminary conclusions which have
been drawn in some case, to avoid misleading any-
one and to give you a bench-mark from which to
begin your response; secondly, the Federal regula-
tions governing the process clearly require that
all responsible comments be properly addressed
and considered in the final statement, and I can
assure you that that will be done. I would like
to suggest that the format for this evening woulc
be as follows:
We would like to begin with a presentation
which will take 20 to 30 minutes which will
summarize the EIS as a refresher for those who
are not familiar with the document at this point.
And after that we would g® 4ir©ctly to your
testimony if you wish to speak. By the way, we
have been requested, and I think it would be best
for you to use the microphones up front in order
that everyone can year and the stenographer can
hear as well. As you might expect, this is being
stenographically recorded for the record and a
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hearing transcript of this session will be
available. If you have prepared testimony, I
would encourage you to present the summary and
submit the complete document for the record.
However, if you wish to do it though, we will try
to accommodate your wishes and provide a forum
in which you do have full opportunity to express
your opinions.
With those preliminary remarks, then I should
like to right now turn to Mr. Alan Farkus who is
Project Director for this Environmental Impact
Statement and he will summarize the statement as
it exists now.
MR. ALAN FARKUS: As Wallace Stickney indicate
the primary purpose of this session is to hear
from you. So, we will try to keep our comments
very brief. I would like to tell you who we are,
what the objective of the Impact Statement is. One
of my colleagues, Mr. Curtis, will review the
alternatives and describe the proposed action to
you, and then I will take the floor again and
briefly highlight the significant affects that
we see from the proposed action. Booz, Allen and
Hamilton is a multi-service consulting firm with
b. p. a. reportim; associates, im:.
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offices throughout the country. The Environmental
i
Consulting Group is located in Bethesda, Maryland!.
We have teamed with the sanitary engineering firm
of Havens and Emerson, Limited on many such state-
ments. Havens and Emerson specializes in waste-
water, water supply and water quality analysis.
The objective of this Environmental Impact
Statement is to carefully assess the affects,
positive and negative, of the proposed facility
on the Scarborough community. The analysis is to
serve as a basis for U.S. EPA and state and local
officials in deciding whether or not the project
should go forward as designed, and if a decision
is made that the project should be undertaken, the|n
the statement also provides a basis for taking
certain measures to lessen any adverse impact whic
we identify. This is really the sole objective
of this statement, but we hope, as well, that a
consequence of our efforts will be to provide at
least useful information to local and regional
planners concerning the Scarborough area.
With that, I would like to now turn the micro
phone over to Mr. Bud Curtis, who will briefly
summarize the alternatives, analyses and describe
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the proposed action.
MR. LaMONT CURTIS, JR: Thank you, Alan.
We want to briefly review the alternatives that
we looked at during the preparation of this EIS.
Many of you will be familiar with these since the)'
have been discussed at prior public hearings and
meetings.
The first alternative was for a single plant
at Scarborough located near Prouts Neck. Effluent
from this plant would be discharged about 600 feel
offshore through an outfall and about 40 feet of
water. This alternative was recommended by
Whitman and Howard in their report and later by
Hunter-Ballew.
The second alternative that we looked at
was an expanded plant at South Portland. All of
the wastewater generated in Scarborough would be
pumped or conveyed to the South Portland plant.
That plant would then be enlarged from 5.5 to 8.5
million gallons per day. Effluent from this plant
is discharged into the Fore River.
Alternative three is an expansion of both
the Old Orchard plant and the South Portland plant.
The wastewater generated in the southern side of
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Scarborough would be conveyed to the Old Orchard
plant which would be expanded and the wastewater
generated in the northern section of Scarborough
would go to South Portland and that also would be
enlarged. The split in flow is about even; about
1.5 million gallons a day for both plants. The
Old Orchard plant discharges into Goosefare Brook.
This alternative was studied and reported on by
Hunter-Ballew.
Alternative four will be two plants in
Scarborough. The existing Oak Hill plant will be e
larged as one facility, and the second plant would
be constructed at the same site as the alternative
one plant; that is, the single plant near Prouts
Neck. This alternative was also presented by
Whitman and Howard.
The fifth alternative was called "No Action"
in the EIS. Now, this is not a totally descrip-
tive term, because some action does result except
that it is not as centralized as the other alterna-
tives are. The existing plant at Oak Hill would
remain and septic tanks and other small package
tanks would be used to solve local water pollution
and water quality problems.
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All five of these alternatives now have an
associated collection system to convey the waste
to their respective given plants. These systems
are all similar and serve basically the same
areas for the purposes of this alternative compati
son. The alternatives were compared using three
main criteria, rationale, cost, environmental
effect and feasibility.
I would like to summarize these alternatives
using these criteria. First, cost. We reviewed a
the cost data presented in other reports and
compared them with other averaged developed data.
Operation and maintenance cost data were based on
our own data. At the time these costs for these
alternatives were compared, the South Portland
plant was not under construction and modifications
would still have been moderately easy. Our cost
today would be a little higher, probably, since
construction has started. We found the regional
cost, as well as the cost to Scarborough users,
to be substantially equal for alternatives one, tw
and three. Again, one is a single plant; two is
transfer to South Portland; and three would be the
split transfers to South Portland and to Old Orcha
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That includes both capital cost of recovery and
operation and maintenance costs. These costs
were within 15 percent, which is about the esti-
mating accuracy. Alternative four and alternative
five were higher.
Environmental effects, alternative five had
many points of discharge but would not alleviate
the problems that close recreational, shellfish
and harvesting areas. Alternative four's discharj:
point on the Nonesuch River which would prohibit
shellfish harvesting in that area. Alternative
three has a negative impact in that the effluent
discharges into Goosefare Brook in the proximity
of Old Orchard Beach. And most likely in the
event of that alternative being selected, an out-
fall would have to be constructed at Old Orchard
Beach.
Alternatives one and two are considered
merely within the environmental effects. There ij
no difference in the social and economic effects
among the first four alternatives. There is nega-
tive impact in alternative five because of some
financial reasons in Federal funding.
With regard to feasibility, alternative one
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and alternative four are the most feasible becaus
they are -- they require not .outside communities
for contracting. The State does not favor
alternative four with the two plants in Scar-
borough because of the discharge. Alternative
two, the transfer to South Portland would be
difficult at this time because that plant --until
that plant is designed and is under construction.
Alternatives two and three both have inherent
problems of contracting between two or more
communities. Further, the State of Maine has
stated that they would not delay either the South
Portland or Old Orchard Beach projects unless a
significant benefit could be shown. Alternative
five would not be eligible for Federal funding.
We have considered these criteria constraint
and have ruled out alternatives four and five on
the basis of cost» feasibility and the primary
effects. We find alternative three, the split
transfer, to be not particularly feasible or
environmentally attractive. Alternatives one and
two, single plant and a transfer to South Portland
remain, and we feel that alternative two would be
unavailable because of difficulties of obtaining
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both State and local approvals. The time delay-
would unquestionably increase the construction
cost.
Mr. Farkus will go into the discussion of
these actions or the proposed actions and its
effects. Thank you.
MR. FARKUS: In presenting the significant
effects of the proposed actions, first I would 1i]:
to discuss the primary effects of the proposed
system. Those effects stem directly from the
construction and operation of the proposed seweraj;
system. The most significant effect of the pro-
posed project is the improvement on water quality.
There are two assumptions that we are making that
I want to make explicit now with respect to the
affect of the action on water quality. One is
that the Scarborough sanitary district will
exercise its authority to require tap-ins into the
system of those package plants and septic systems
that are currently discharging inadequately
treated effluent. The second assumption has to do
with the dispersion of the effluent. Although the
Whitman and Howard data and analysis were not
conclusive, we believe that based on their
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presentation, it is reasonable to presume that
at least occasionally effluent would be dispersed
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to Scarborough and its beaches. Making these
assumptions, we find that the action would have
significant beneficial impact on water quality.
Specifically, we believe that water quality stan-
dards would be met in areas presently degraded.
The Higgins Beach area, which is now fortunately
closed -- aside from the weather -- closed during
the summer because of public health reasons,
should be opened. We think likewise that the
water quality in the estuarine areas would be
considerably improved and the likelihood of
recreational planning taking place would be en-
hanced.
In analyzing the water quality effects, we
studied very carefully the question of viral
pollution because this was an issue, as you know,
that was raised in previous public hearings. In
addition to reviewing the literature on this
subject, we consulted with a number of recognized
experts in the field. These include Dr. Gerald
Berg of the U.S. EPA Laboratories in Cincinnati;
Professor T. G. Metcalf of the University of New
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Hampshire, Microbiology Department; and Professor
Ralph Mitchell of Harvard University. The only
definitive statement that we can make on the
subject of viruses in the effluent is that the
concentration of viruses currently in tiiese water-
ways will be reduced by the proposed action. No
other scientifically balanced conclusion can be
made regarding the affect of the effluent.
There are some facts, though, that do sub-
stantiate a qualitative or a non-scientific con-
clusion. These facts are the following: First,
there is no correlation that has been reported to
date which linked the outbreak of infectious
disease with the discharge of secondary treated
effluent. Secondly, the current design should
enable approximately 99 percent removal of all
viruses in the effluent. Thirdly, of the live
viruses which remain in the effluent, many will
be inactivated by the sea water. This is not to
say that all virus particles will be removed even
making those assumptions. Nevertheless, we think
that the effluent does not pose an unreasonable
public health risk with respect to recreational
use of the surrounding waters.
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With respect to the harvesting of shellfish,
because shellfish concentrate accumulated viruses
over a time, harvesting in an area may have to be
prohibited. As you may know, the Federal Food
and Drug Administration currently prohibits shell
fishing in an area of 1 ,000 feet from a discharge
plant. The only way to determine whether or not
further limitation would have to be placed would
be after the plant were in actual operation.
To summarize, then, we believe that a major
beneficial effect of the action would be to im-
prove water quality in the area. In terms of
other environmental effects, there will be some
effects from construction in terms of noise, dust
and disruption of the -- of aquatic life. These
effects will be minor and short-term.
With respect to the location of the treatment
plant on a flood plain, we believe that given
the current plans to raise the level of the site
above 100 year floor level, that this fact would
not pose a problem.
These are the primary effects on the natural
environment. The significant effects on the man-
made environment of the plant would be the
¦ } ¦ ")
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following: First, in terms of the clamming, we
believe that the pollution control facility would
open up areas to recreational clamming that are
currently closed and would remove the necessity
of cleansing clams that are currently commerciall)
harvested. We have made some rough estimates as
to the increase of income, resulting from this
event, and we estimated that we are currently --
the clamming industryigenerates 1.5 million dollar
per year; that if the clam does not have to be
cleansed, that the income generated would be
approximately two to three million dollars a year.
Another significant effect would be the expansion
of suitable beach area and at least a continuatior
of income related to summer residents and tourism.
That concludes our discussion of the primary
effects. The secondary effects of the treatment
plant deal with the affects on the natural and so
called man-made environment that result from the
population growth that is solely attributable to
the installation of the central sewerage system.
In order to estimate these effects, we must first
project what the population of the area would be,
assuming this system, a central system, is built.
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Secondly, we must try to estimate growth, assuming
there is no centralized system, and finally, we
analyzed the effects of the additions, assuming
there is some aiddition to the population,
attributable to the plant on the natural and man-
made environment.
First, the projection of population. We
based our population projection for the Town of
Scarborough on sl report published in the February
of 1975 of the Public Affairs Research Center at
Bowdoin College. The report was developed, I
understand, in consultation with the State and
regional planners. We took the population esti-
mates for the State of Maine and for Cumberland
County from this report. We calculated the
Scarborough population by assuming that Scarbo-
rough's increasing share of the Cumberland County
population would continue at the same rate as in
the last 15 years. Using this methodology, we
projected that in 1995, the year-round population
here in Scarborough would be approximately 18,500.
There is no systematic way to estimate the seasona
population. We have assumed a 20 percent increase
in seasonal population over a 25 yeaT period. Thi
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brings a total peak population in the Town of
Scarborough, as a whole, to approximately 25,000
in 1995.
Now, the calculation of the growth that would
result if there were no central sewerage system
is substantially more difficult. As we indicated
in the statement, our calculation here has to be
regarded as speculative. The calculation depends
on the regulatory policies of the Federal, State
and local government. We assume that these
policies wouldn't slow residential growth in the
area and we project a population in 1995 of 20 ,00(1
We have also indicated that the climate for in-
dustrial and commercial development would not be
as attractive, and that development would be
somewhat reduced if the action were not undertaker
Now, in terms of the effects of this on the
man-made and natural environment, the effect on
the man-made environment of the proposed action
is to increase the tax base of the community.
There is no basis for objectively assessing whethe
the effect of the additional population is positiM
or negative. We believe there are no significant
effects of this population on the natural environn
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Nor, in fact, do we feel that there is any signifi
cant environmental effects associated with the
entire population growth that this area expects.
I have tried to give you a sense of who we
are, identify what the object of the Impact State-
ment is. Curtis and I have tried to summarize
very briefly what the statement represents. Now
we look forward to hearing your comments.
MR. STICKNEY: Thank you very much, Alan.
The normal protocol for hearings of this type is
to recognize the various levels of governmental
representatives who wish to speak, and then go on
to the people who really know what they are talkir
about, I suppose you might say. I didn't check
before, Dennis. Was the State going to make a
statement at this time?
MR. PURINGTON: No. We have no statement.
MR. STICKNEY: There won't be a statement frc
the State. I have not noted a card here indica-
ting that anyone from the local government agenci«
which wishes to speak at this time, except some
of those who are included in a group which as beer
put together by the Scarborough ad hoc EIS
Committee, which has prepared a presentation whicf
c-
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I believe, with your permission, ought to be
taken in order and probably would put their points
across most effectively that way. So, I would
like to recognize as the first respondant this
evening, Mr. Harvey Warren, who will indicate
precisely what this testimony represents and, I
imagine, why it is presented.
MR. HARVEY WARREN: Mr. Stickney, first of a!
since the EIS draft has been available for only a
short time to the general public and in very
limited quantities, we would like to request a
15 day extension of the time allowed for filing
to allow others to study the available copies and
research data from other sources. In an effoTt
to coordinate these studies and presentation of
various concerned citizens and groups, we have
formed the ad hoc committee. In our opinion, our
various presentations will show the deficiencies
in five areas.
The engineering data compiled for the EIS was
obtained for the specific purpose of supporting
the outdated technology of Plan A. Not only was
there a failure to vigorously examine alternative
treatment systems, but there was a flat refusal
% Is J
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to apply for 208 funds to search for and examine
other proposed alternative systems. The data
compiled for the EIS paid lip service to the
study guidelines but falls far short of the guide-
lines. In short, it is superficial and without
depth.
Many of the claims made in the EIS dataare
misleading, erroneous and highly suspect. The
data supplied for the EIS exhibits a very super-
ficial and callous disregard for the secondary
environmental effects. Thank you.
MR. STICKNEY: Thank you, Mr. Warren. The
regulations provide for a 15 day extension upon
request, and we understand that one of the Federal
agencies commenting on the draft will also make a
similar request. In any event, I believe, if I
have calculated properly, the 15 days would leave
the record open until March 7. I hope I get the
<¦
order right. I believe the next person wishing to
speak is Mrs. Lillian Fig.
FROM THE FLOOR: She had a car failure and we
are a half an hour behind
MR. STICKNEY: All right. Yes, sir?
MR. THOMAS SITZKOWSKY: I am the Chairman of
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the Scarborough Planning Board and I would like
to make a statement at this point. I did not
realize that I should have registered with you
in order to make a statement. I would like to
make a statement.
MR. STICKNEY: I believe that would be in
order, sir.
MR. SITZKOWSKY: For you who don't know me,
I am Tom Sitzkowsfey, Chairman of the Scarborough
Planning Board and I would like to issue a state-
ment at this point in time just to identify the
current situation of the Planning Board review
of the Impact Statement.
The Scarborough Planning Board wishes to
express its concern regarding construction of the
sewerage treatment plant in Scarborough. The
Board is cognizant of the growth pressures that
may result from such an undertaking, as well as
those that will continue to be exerted without
such construction. The intent of the Planning
Board is to arrive at a determination of its
ability to cope with the demands that materialize
with either eventuality and to assess the benefits
and cost of each. Furthermore, the Board will
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assess the relative affects associated with
providing a system that would serve only the
areas designated in the consent order and more
wide-spread service to the majority of the town
east of the Turnpike. This assessment will be
quantitative if possible, and qualitative if
necessary. It is with disappointment and regret
the Board is unable to officially state its
position this evening. The members were not
informed of the distribution until Monday, Januar
26, 1976, and since that time, sufficient copies
have not been available to enable a detailed
review. Copies have been obtained from EPA today
and the Planning Board will submit a written stat^
raent by February 12, 1976.
MR. STICKNEY: Thank you, sir. We are sorry
that you did not have adequate numbers of the
report earlier and we are looking forward to your
comments.
Dr. Richard Levy, please.
RICHARD LEVY, M.D: The physicians who have
prepared the following statement are all resident
of Scarborough and practice medicine in the
Greater Portland area. They are Dr. George Lord,
		'	
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Dr. Robert Ritchie, Dr. George Higgins, Dr. James
Mayer and myself. These physicians have a combine<
medical experience involving more than 60 years,
not including their years in medical school, and
represent a very cross - section of medicine includi
medical research, public health, mental health,
pulmonary disease and family practice. Dr. Lord
is a graduate engineering, having received his
degree from the Coast Guard Academy and practiced
engineering prior to his subsequent medical
education and medical career. In addition, he is
a trained diver. He is a member of the Sea-Lab
team in the U.S. Navy and is personally familiar
with the waters both over and under off this coast
of Maine.
Dr. Ritchie is a Director of a large medical
research laboratory, the Maine Medical Center, is
a member of the Federal Drug Administration and
has many years of experience in investigation and
collection of data.
Dr. Levy has had several years' experience in
medical research, public health and in the design,
organization and carrying out of community medical
programs.
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Drs, Higgins and Mayer are daily involved in
delivery health services to families and indi-
viduals and have special concern for the issues
of infectious disease in relation to children in
the community.
All of these physicians have spent considera)
time studying the health aspects of the proposed
treatment systems. They have at their disposal
the Health Sciences Library at the Maine Medical
Center and the Medlar Computer Facility hooked
up to the Harvard School of Medicine providing
a copy of any scientific paper written about any
subject anywhere in the world. They have given
considerable thought and concern to the issues and
have based the following statement on facts and
their experienced medical judgment.
I would like to say that we into technical
problems and, unfortunately, we will have to
occasionally use technical language and I shall d(
my best to clarify those technical terms.
The undersigned physicians believe that the
sewerage treatment facility proposed by Whitman
and Howard, known as Plan7A, constitutes a
potential health hazard to the community and its
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visitors. We believe that the method by which
data was obtained for the purpose of determining
the relative safety and hazards of both the treat-
ment process proposed and the location of the
outfall would be scientifically and medically
unsound. We would like to address ourselves firsi:
to the question of disinfection of the effluent
and the actual hazard to health of viruses dis-
charged into sea water. The following material
to be discussed relates to the Environmental
Impact Statement, Section III, Item 3.2; Section
IV, Item 4.1; Section V, Item 5.1.5. We will
assume that no secondary treatment plant is
100 percent effective and that a reasonable per-
cent of effectiveness is somewhere between 85 and
90 percent. This essentially means that about
10 percent or more of sewerage is not effectively
treated and that, therefore, a certain quantity
of solid material, bacteria and viruses
will be released directly into the ocean. These
viruses are known to cause infectious hepatitis;
multiple sclerosis; myocarditis* an inflammation c
the heart; poliomyelitis; collagen disease, such
as lupus erythematosus -- excuse the fancy languag
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but it's a fact -- and certain other diseases we
will not list. They are too long.
Dr. Gerald Berg, Chief of Virology at the
EPA Water Quality Office stated in a paper
entitled "Removal of Viruses from Wastewater"
that, "It is a common experience that the
efficiency of treatment systems is much greater
under lab conditions than under the difficult to
regulate conditions that exist in the field.
Activated sludge treatment is no exception. When
samples were taken from primary and activated
sludge effluents in the same plant, secondary
effluents contained only 53 and 71 percent fewer
viruses than the settled primary effluent."
Dr. Berg stated in the same paper that "Safe
water requires terminal disinfection. Chlorine,
universally applied to many needs for decades,
suffers many shortcomings. Since most effluents
contain ammonia, sometimes at levels that exceed
20mg per liter, chlorination is likely to produce
only chloramine. Chloramines are toxic to fish
and life that serves as fish food and are slow
disinfectants."
In the 1973 Annual Report of the Environmenta
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Research published by the U.S. Environmental
Protection Agency, the National Environmental
Research Center in Cincinnati, it stated on
page 19 that "Evidence indicates the proof of
destruction of coliform organisms does not
necessarily insure all viruses are killed. In
addition, there is growing concern regarding the
low viricidal potency of chloramine." Chlorine
upon entering the effluent of sea water would
partially be bound to ammonia and form chloramine,
as I mentioned before. "Toxicity of chlorine and
the possibility of producing undesirable organic
chlorine reaction products. Chlorinated hydro-
carbons are currently being investigated as
potential cancer-producing agent." In the same
report it is stated that, "More than 100 viruses
are excreted by man and may be discharged into
waterways. Since the importance of viruses reside
not in number but in their infectivity, a high
degree of virus removal is desirable." And I
think we have to emphasize that point. It is
extremely important. The fact that this system
might decrease the total number of viruses enter-
ing the water is really not significant. The
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question is, what is the nature and the infectious
capacity or potency of those viruses that are
being discharged.
There is no reliable or available research
at this time to indicate what happens to a viral
sample when it enters sea water. That is to say,
whether the virus dies, remains virulent, has its
potency diminished or is still capable of pro-
ducing disease in humans. We do know from our
studies and recent research that coliform counts
do not indicate what viruses are present in
effluent, in what quantity, whether or not they
might cause disease, or to sum it up, whether or
not the water that has been sampled for the coli-
form test is actually safe.
There is a controversy regrarding the
affect of sea water on vrisuses, as mentioned,
which has not yet been solved. We were unable
to find a reliable research project which validatei
or invalidated the opinion that viruses are killed
in sea water. Viruses, it has been demonstrated,
are recovered from shellfish living in sea water
and, therefore, we could assume therefore that
viruses do survive in sea water. That is an
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assumption and, as I said, there is really no
good research to date yet.
During the course of our research we have
come across the very disturbing fact; that is, tha£
viruses are now being linked to cancer. We are
talking about the very kinds of viruses that would
be discharged into sea water in an enteric
effluent from a wastewater system. Viruses are
now known to remain latent in people, causing
their diseases weeks, months and even years after
the original infection. This subject was discuss^
in some detail by Dr. Ritchie at a public hearing
held in June, 1974 in relation to this proposed
sewer system. Secondary treatment systems have
been designed in the past with no knowledge of
the viral relationship to cancer. Certainly, this
new knowledge indicates that systems must be
designed to take into account this very important
potentially lifewthreatening effect. The proposec
system does not so do and will admittedly dump a
certain number of untreated viruses into the
ocean and environment.
In a scientific paper published ia 1973,
Professor Otis J. Sproul, S-P-R-O-U-L, Department
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of Civil Engineering, University of Maine,
entitled "Quality of Recycled Water, Fatal In-
fectious Agents," stated that"the numbers of
viruses in wastewater are always small, but the
number required to produce an infection in man is
also very small. We must be concerned," he says,
'fetbout the presence of only one virus particle in
water." Dr. Sproul goes on to report that
"in activated sludge treatment processes that
field reports show that removal of 90 percent and
less are obtained in actual plant operation."
What this means in reality is that residents and
visitors swimming in our oceanwaters will be
exposed to 10 percent or more of, meaning up to
300,000 gallons per day or more, inadequately or
non-treated effluent containing an unknown quantity
of virus. Also in that paper Dr. Sproul goes on
to say when discussing this infection that chlorine
reacts with ammonia, and I won't go into those
details again -- but also produces chloral proteins
and that these have "a considerably reduced poten-
tial to virus inactivation." This, of course,
reinforces the statement made by Dr. Berg mentione3
above, as well as many other researchers in the
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area. Dr. Sproul goes on to say in other works
by himself and another researcher shows that only
50 percent or less of polio virus, Type I, were
inactivated at lmg. per liter of combined
chlorine residual with a 30 minute contact period
By the way, this is the recommended period of
holding and disinfection in the proposed treatment
process. Contrary to the figures given in a
statement prepared by Booz-Allen, 90 percent or
more of disinfection does not take place when the
effluent is held for 30 minutes with a combined
chlorine residual of lmg per liter. This whole
standard is no longer applicable with the knowledj
we now have of virus resistance to disinfection.
A series of papers read at the University of
Illinois College of Engineering, the 13th Water
Quality Conference in February of 1971 provides
abundant data and new research findings indicating
the very complex problem of adequately disinfectin
viral samples.
Dr. Sproul also states in his paper, he says,
"High chlorine residuals required to inactivate
viruses in wastewater cause persisting active
chlorine compounds in receiving water." These
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compounds have been reported to kill fish and
other organisms at low concentrations, and to
taint shellfish and fish flesh at lower concentra
tions. Dr. Sproul also states in his paper that
"research has shown consistently that solid
materials in effluent protect viruses from expo-
sure to disinfection."
In order that adequate disinfection take
place, total removal of solids is necessary. This
is certainly not provided by the secondary treat
ment plant proposed in Plan A.
In many papers presented at the Water Qualitj
Conference held at the University of Illinois,
mentioned above, it is stated repeatedly that
disinfection is the key to killing viruses in
wastewater effluent and that at present inadequate
viral kills are obtained by standard disinfection
systems utilizing chlorine. The new approach
utilizing ultrasound, which breaks up solid mattei
into small particles, provides greater opportunity
for contact with the disinfectant. The most
effective disinfectant is regarded to be ozone.
A combined system using both ultrasound and ozone,
as reported in a paper published in Applied
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Microbiology, March 1975 by researchers at the
University of Notre Dame and has been tested in
the fields of Indian Town, Florida and in
municipal treatment plant for over one year. Thi^
process is commercially available.
Section 111 - 21 of the Environmental Impact
Statement, 3.2 number 3 states that "Because of tlj
concern of the problem of monitoring the effective!
ness of ozonation, the design engineer was en-
couraged to select chlorination as a means of dis-|
infection." In view of the research mentioned
above, it does not make logical or common sense th|
we continue to use chlorine in the disinfection
process. The problem of ozone monitoring existed
at one time but is no longer the case. Automated,
reliable, commercially available feed-back system
is incorporated into the ozone generator and
constantly monitors the ozone level, keying in
more or less the production as is necessary. This
is known as the ITT-Therax System. It is manu-
factured in Switzerland. The manufacturer claims
it has been utilized for 20 years successfully.
It was stated two years ago at the public hearing
regarding the proposed system that viruses could
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not be isolated from sea water and adequately
studied. We have discovered in our research that
it was not true then and it certainly is not true
now. Various filter systems have been designed
and are in operation which isolate virus samples
from quantities as much as 300,000 gallons per
minute andboth artificial and tissue mediums have
been developed on which viral cultures can be
reliably grown. The latter technique results what
is known in the trade as platforming units and
tissue culture infective dose.
Scientific measuring of viruses in sea water
effluents can be accomplished and we can no longer
say it is not so. There is a side issue relating
to the difference in viral kill qualities between
chlorine and ozone not mentioned in the EIS, which
has a profound effect on the environment to which
the disinfectant is discharged. It is known that
the chlorine dangers and toxic compound remain
after its use in a treatment process. Ozone
rapidly converts into oxygen and provides no
after-disinfection> chemical or compound, whatso-
ever.
To proceed with a treatment system as propose
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by Whitman and Howard, would insure that a certain
number of Scarborough townspeople, and in particu!a
their children, utilizing the recreational waters,
as well as visitors, will be exposed to infectioui
disease. It is also likely that the risk of
contracting cancer would be increased due to the
presence of chloral proteins, chlorinated hydro-
carbons, nitrosamines, and most importantly, the
link between the virus particles and certain forms
of cancer. We are very concerned with the
apparent fact that no thorough, carefully investi-
gated alternative method of treatment as opposed
to transfer, has been considered in any of the
proposals made by Whitman and Howard or subsequent
studies. It is our understanding that this is
required by the Federal Water Control Act.
We will briefly comment on fractional plants
for the town with multiple sources of outfalls fro
the viewpoint of public health. It is certainly
more desirable to not concentrate the effluent but
to have more than one ocean outfall. It is de-
sirable to control the Higgins Beach pollution
problem as rapidly as possible and it is likely
that that would happen much faster if the plant
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were to be built at Higgins Beach to handle the
effluent now running freely both by point and non-
point sources into those highly utilized recrea-
tional waters. In our research into this ozone
process, we did note that their plants are con-
structed in six to eight months at an approximate
cost of $1.35 per gallon per day, which would
appear to be quicker and cheaper than the plant
proposed by Whitman and Howard. We will go into
no further details on that.
Also, in relation to Higgins Beach we are
concerned with the total lack of provisions in an>
of the proposals made by Whitman and Howard or
subsequent reports for sanitary facilities or
their cost during the approximately anticipated
12 months between the beginning of construction
and the function of the new sewer system. No
provision is made for the disposition of human
waste, nor other effluents during the interval whe
the old system will be broken into and, admittedly
will not function. Another disturbing medical
fact has come to light during our investigation of
this problem. Sludge removed from biological
treatment plants is crawling with live viruses.
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There is no way that this mass of material can
be adequately disinfected. It is likely that it
constitutes as worrisome a public health problem
as the effluent entering the water directly. It
is stated in the EIS that the sanitary district
has made arrangements to experimentally spread
sludge from the proposed plant on local golf couri;
and farm fields. It is known that sludge leaches
into ground water and can be carried into streams
as well as open waters, not only contaminating
water supplies, but endangering people utilizing
waters for recreational purposes. There is no
research available of what the hazard is of walkin
over a golf course or living down-wind of a golf
course that has been fertilized by a concentrated
dose of virus surrounded by sewerage residue, kno\
as sludge. As far as farm land fertilized by
this manner, it would be very important to set up
a carefully controlled, systematic research study
involving culture or produce from that farm land,
as well as a public health study of the incidents
of infectious disease of people eating that food
produce, if anyone be foolish enough to so do.
Personally, after I read about sludge, I wouldn't
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want to live anywhere near a so-called sanitary
landfill or even drive by a golf course recently
fertilized, and I think anyone who would volunteer
to eat the produce, enjoys high-risk activities.
In recent discussions of the disposition of
handling of human waste, the composting toilet
was frequently raised. It is not mentioned in thi
EIS and, of course, it is not related to the pro-
posed sewerage system. However, it has an ally
of public health implication that we will very
briefly touch on. The ideal method of handling
human waste with minimal health hazard would be
a system which put out not effluent. Viral diseai
could be eliminated as a health hazard problem if
there was no effluent. For new construction pur-
poses, a composting toilet seems to provide this
effluent - free system.
Next, we will address ourselves to the seconc
major problem of the proposed treatement system.
We believe that the method by which the data was
obtained for the purpose of determining the rela-
tive safety or hazards in both treatment processes
proposed and the location of the outfall to be
scientifically and medically unsound. Much of the
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data and information on which opinions have been
based regarding the safety of the system were
collected from studies done by Whitman and Howard.
It's a basic rule of thumb in medical and scientii
investigation and research that data be collected
by an independent investigator who in no ways
stands to profit by the eventual outcome of the
study under consideration. An excellent example
of how such conflict of interest can influence
the collection and interpretation of data is both
the drift bottle study and the drug buoy experi-
ment carried out by Whitman and Howard in relatior
to the location of an outfall. The results of the
drift bottle study were unfavorable to the pro-
posed location of the outfall, with the large
majority of the bottles found on local beaches,
indicating quite clearly the strong influence of
prevailing winds in the area. The results of this
study were discounted by Whitman and Howard be-
cause "the bottles were improperly ballasted."
The fundamental rule of research was ignored and
an experiment in an experimental study they
repeated it, the investigator doubt the reliabili
of the initial result. Logically, the ballasting
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of the bottles has little to do with the fact
that they were pushed in by prevailing winds to
the beaches, regardless of how deep they sit in
the water. The fact is, they were blown into
the beaches, as would any other mass floating on
the surface. the published Environmental Impact
Statement comments on the likelihood that the
effluent rising from the outfall would rise to tho
surface and be subject to prevailing winds.
In a similar fashion, the investigators
chose to interpret the results of the drug buoy
study as indicating the current did not flow in a
direction which would bring effluent into recrea-
tional and beach areas. To the contrary, it is
very clear that the basic data obtained from these
studies show currents to go in every which direc-
tion and materials are likely to be carried both
in the Scarborough and Higgins Beach, as well as
towards Old Orchard Beach, as well as out to sea.
Local fishermen and boatmen have known for many
years that the currents off the coast of Maine and
in this area in particular are quite erratic and
unpredictable and vary from season to season and
time to time and weather condition to weather con-
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dition. Certainly, there is no opportunity, as
described in the original drug buoy experiment,
to monitor the effects of currents by this method
at varying seasons and times of the year. It is
logical to conclude that a large quantity of
effluent would be carried by the current towards
shore and the beaches on one day, while on another
day, it may go in another direction. What is
important to know i$ that there is no dependabili :
in terms of drift or current and, therefore, the
community is placed at risk. The drug buoy
studies are not definitive and the study of
currents in relation to the dispersion of a liquir
and/or semi-solid material, a dye study in which
a known quantity of liquid dye dispersed in a
known unit of time, would have given a much more
accurate and reliable indication of what actually
happens in relation to effluent. Therefore, the
basic investigative technique utilized by the
engineers studying "where will the effluent go"
is incomplete and unreliable. We are further
concerned with the issue of conflict of interest
in relation to choice of the treatment process or
system. Research and field operations indicating '
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swing or biological treatment plants, physical-
chemical treatment plants.
In summary, the physicians preparing this
report believe this sewerage treatment proposed,
Plan A, constitutes a health hazard to the
community. Based on information and research data
available, it is our opinion that, if the proposed
system is put in operation, the residents of
Scarborough and visitors would be exposed to
viruses, also infectious diseases and then cancer
More adequate and commercially effective dis-
infection systems are available. In our opinion,
the disposal of sludge has been poorly researched
and the plan in the proposal constitutes a severe
health hazard. We believe the original tests
carried out by Whitman and Howard in relation to
the location of an outfall to be incomplete and
the data unreliable. Further, the present loca-
tion of the outfall will be exactly where it
carries effluent to where people are using the
recreational waters off the Scarborough coast.
We are especially concerned with the lack of
provision of sanitary health measures at Higgins
Beach during the proposed construction phase. I
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thank you very much for your patience.
MR. STICKNEY: Thank you very much for that
comprehensive, Dr. Levy. Does anyone on the
panel have questions, technical questions, re-
garding the points made by Dr. Levy?
Did Dr. Lord wish to speak also?
DR. LORD: I think the points were covered
well by Dr. Levy already.
MR. STICKNEY: Okay. Mr. William Brooks?
MR. WILLIAM BROOKS: Ladies and gentlemen,
I am a naturalist, a generalist and I have made
a general statement, as well as some specifics, bu :
I intend to make a written statement as soon as I
finish this. But we didn't get out books for
quite some time. I had a very difficult time
getting them and we have tried hard to study this ,
but it's been difficult. I will say more about
that towards the end, but really we are in the
seventh inning or something. I'm going to tell
you a funny Maine story.
A Maine farmer who invited a Texan to his
house up in Aroostook County to his potato farm,
they sat down for Sunday dinner. That afternoon,
of course, they began talking, they began discussi
3 ci
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their spreads, you know. The Texan said, "What's
your spread?" The Maine farmer said, "Well, that
tree, that tree and that tree and back to the
house," and so he very courteously said, "What's
your spread like?" And the Texan said, "Well,
if I got in my car after dinner like this and rodis
around my spread on Sunday afternoon, I couldn't
get back by suppertime." The Maine man said,
"Yes, I understand. I had a car like that once,
too."
Now, this applies to the sewer system. We
I
don't want a sewer system like that too. The key
to the Scarborough sewer problem is this, the
Town Council wants massive, rapid growth. This
requires a large sewer system. A large sewer
system requires high taxes. To keep the taxes
down somewhat, it makes it necessary to have the
most cost effective system rather than the one
that will fulfill the Federal requirements of no
pollution in the waters by 1985. A system to meet
the Federal requirements requires the most advance
treatment available and not a centralized secondar
treatment plant. The most advanced treatment is
the most expensive. In order to keep taxes within
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bounds, Scarborough must build its sewers to tak
care of only the consent order areas with advanced
treatment plants. Advanced treatment plants
could be built at Higgins Beach for Southeastern
Scarborough, Pine Point for Southwestern and
Western Scarborough with a possibility that is
now surfacing that Old Orchard wants to add the
Pine Point sewerage to the Old Orchard plant whic l
would be upgraded to advanced treatment in order
to make the 1985 Federal standards. If this is
done, the rest of Western Scarborough,those areas
in the consent order, could be treated at an up-
graded to an advanced treatment Oak Hill plant,
and the sewerage from the Western areas could be
pumped in pipes along the old railroad right-of-
way to the Oak Hill plant and the pure effluent
from all of these plants could go to the estuaries
if it is advanced treatment, to almost pure water.
This plant in my opinion is what Whitman and
Howard should have dreamed up in the first place.
It is the plant ttet Booz, Allen and Hamilton
should have dreamed up and the EPA, if Whitman and
Howard won't do it or Booz-Allen, it is plain that
the EPA should have suggested in this EIS that pla
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Any delays that have been encountered by the
necessary opposition to alternate one plan are
not the fault of the people opposed to it. The
Scarborough Sanitary Sewer District and the Town
Council have been importuned for years by various
knowledgeable people to prepare a similar plan.
The EIS draft has a further fault of modifying
all conclusions to the thesis of the Town Council
that the town is going to have a population growth
whether the town's people like it or not, as
indicated by the fact that they don't want -- I'm
sorry -- whether the town's people like it or not,
or whether the town's waters can stand the effects
of a secondary treatment plant that will not ful-
fill the 1985 requirements. Neither this town
nor any town must have population growth if condi-
tions are not right for it. Such a thesis has
been upheld in the courts. The conditions are not
right for much population growth in Scarborough.
Sewers are not good enough, the cesspools, and the
taxes would be too high for the kind of water
treatment that Scarborough needs to meet the 1985
Federal standards for population growth. Therefor
developers should move out of Scarborough and go
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inland. They must not destroy our marshes, the
largest in Maine, by improper development near
them, as is being done right now; nor our beaches
and scenic walks enclosed by inadequate water
treatment from homes and street runoff. We must
take care of present pollution only by advanced
treatment plants, and that is all.
There is a very important of water treatment
which has just surfaced and I have not been hearin
much of anybody speak about it; that is, a treat-
ment of a storm drainage runoff so as to clean it
up. The EPA is fully aware of this because the
Water Pollution Control Act arranged for designa-
tion of billions of dollars for it. I have heard
about it on Long Island, New York, where I live
for half the year, where I am a member of the
Environmental Caucus for the citizens1 advisory
committee of the 208 study being done by the
Nassau-Suffolk County Regional Planning Board.
But it did not hit me as applied to Scarborough
until an article, a column long, in the New York
Times of January 22, brought it to the surface.
It seems that since Vice President Rockefeller's
Commission on Water Quality report to President
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Ford, the President is said to be planning to
send two amendments to the Congress that could
drastically alter the prospects for Federal fund-
ing for Scarborough sewers. It would require
cutting to a minimum the monies already allocated
for cleaning up waters resulting from storm
drainage from streets. Storm drains, containing
dog manure, have all kinds of bacteria and
viruses, plus car oil and rubber dust, and all
other matters of pollutants in storm runoffs are
polluting our waters -- that is, human sewerage -
in some places that are urbanized. What is the
message for Scarborough? It is that the growth
plan for Scarborough must not take place unless
the storm waters are cleaned up as well as the
other sewerage. I don't know how this is to be
accomplished, but the Federal government has been
aware and EPA has been aware of this for a long
time and, as I have said, billions have been allo-
cated for cleaning up of such waters so that the
1985 Federal standards of no pollution can be met.
Why, knowing this, did Whitman and Howard and
Booz,Allen and Hamilton and the EPA Region 1 not
take it into consideration?
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Furthermore, President Ford expects to offer
amendments to the Water Pollution Control Act
to grant no Federal funds for sewerage being
planned to allow for population growth; only
present pollution is to be taken care of. Now,
I submit this is a bombshell for Scarborough, but
I think it makes sense. Please look into it and
make recommendations.
I was going to comment about the virus, but
Dr. Levy covered that pretty well, but I want to
say that the sludge, the 15 percent of suspended
solids still in the secondary treatment will have
an effect upon our coast. So, I want to get rid
of that 15 percent suspended solids because, al-
though it is not decided just where the outfall
would go, it will go somewhere near the south
point of the Prouts Neck Cliffs no doubt. TVhere-
ever it goes, the effect will be the same. The
rocks will accumulate a daily residue of grease
and other suspended solids and, if the population
builds up, the 15 percent becomes actually a
larger and larger quantity of accumulated suspende
solids ending up in an area in which no negative
impact is permitted by Federal law, namely the
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Winslow Homer Home and Studio, which is on the
National Register as a national monument. It
will make the rocks ugly. I will go into this
more in length in my written statement.
There is another area in which the EIS is
quite deficient. Discussing the geology of the
area, and I have been an earth science teacher
and have studied this area carefully, the statemen
on page II-2, Section 2.1-2 states that "Rela-
tively little is known about the geology of
Scarborough and its neighboring communities." As
a matter of fact, a very detailed report on the
geology of the area was published in 1971 by
the Department of Economic Development, Maine
Geological Survey, Augusta, Robert G. Doyle,
State Geologist, geologic map series GM-1,
geologic map of the Portland province of Maine
by Dr. Arthur Hussey of Bowdoin. It is not listec
in your references nor is it mentioned in the
text. This report contains a detailed geologic
map, and explanation of the rocks of the area.
I won't go into details except to say that the
Prouts Neck area is very complicated and engineers
would have to blast through about 40 feet deep
f 'f
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at the ocean front of seven different kinds of
hard, tough rock to run an approximately sea kvel
pipe to Sou-tii Point, which is the farthest point
from people, and this farthest point is the goal
Whitman and Howard planned to put it there. Well,
what they run into trying to anchor that pipe
600 feet out, 40 feet deep is another question.
I will say more about other errors in the EIS
but I will stop here for the summary*
I do want to protest the short time given
us to write answers to such a complicated EIS
with so many errors. If public participation
is really wanted and is supposed to be wanted
and is supposed to be taken care of, the EPA
Region 1 should hold, in my opinion, a second
hearing a month from now, a day long, preferably
on a Saturday so people can really hear what we
have to say. Even that time -- now that it has
been extended to March 7, that's good, but still
it isn't time for people to pay attention so they
can know what is going on. Our time was cut shori
by unreasonable delays caused by our inability
to get this first draft of the EIS even though mar
others had access to it; though we had even great<
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inability to get the second draft. It frankly
almost seems like a conspiracy to avoid public
participation, and here you see our Planning Board
just got their copies of this blue book. I submi-:
there should be another hearing about a month fron
now and give us time. We haven't had time enough
to really do a good job on this. Thank you.
MR. STICKNEY: Thank you, Mr. Brooks. I
can assure you that we are interested in public
participation and that, apparently, we have done
something to encourage it it appears. Are there
any questions from the panel of Mr. Brooks?
(No Response)
MR. STICKNEY: Fine. I would like to move
on to Mr. William Hillock, if I have the pronun-
ciation right, who has indicated his desire to
speak next.
MR. WILLIAM HILLOCK: Ladies and gentlemen,
members of the Board, if you will give me just a
few minutes of your time, I would like to drive
home one of the most important segments of this
sewerage treatment process, and that is, the
dispersement of sludge judged by the standards
set by the regulatory agencies of the environmenta
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system incorporated in this plan is inadequate.
The proposed sludge disposal plan is based on the
often-tried land spreading or landfill method.
The history of sludge disposal landfills in this
area is a horrible story of water pollution and
unbearable •dors. In adjacent York County, a
Pollution Control Agency is awarding a $50,000
contract to determine why Saco's landfill is
polluting ground water and filling the air with
odors. The Greater Portland Council of Governors
says it is in need of a three million dollar
expenditure that will be necessary to insure that
new sludge, solid waste land fill sites proposed
for Scarborough will not pollute the water table
or the air. The environmental regulations for th<
proposed sludge landfill would eventually cause
this part of the project to cost the sewer user
more than the actual treatment process. The
molecules of gas that is given off by these land-
fills are a hundred times smaller than the soil
cores in the proposed clean linings of disposal
sites. The methane and carbondioxide gases pro-
duced can travel up to 600 feet through clay. The
gases replace the root system oxygen of plants,
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grasses and trees, causing them to die. Escaping
carbondioxide, which is soluble in water, producer
a hardness which renders the water unuseful with-
out treatment. The proposed alternative disposal
of sludge by spreading it on golf courses and
median strips runs headlong into the disposal
methods of the cities in our area which also will
be producing truck-loads of sludge. We can only
absorb so much of it. Just how much sludge can
this whole area take? Land spread, at the best,
is done at certain times of the year. This sludge
will go on month after month, year round. The
sludge from our present plant is being land-spread
The testing used to determine metal concentrations
are selective rather than spectographic in nature
and the analysis in effect finds only evidence
of these metals for which these tests are made.
The daily build-up of concentrated metallic com-
pounds in the soil and water must be taken into
consideration.
Some other methods of disposal have been
considered in our general area. Vangar is trying
composting. Saco is considering recycling sludge
for the production of a soil conditioner^ methane
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gas. In other areas, the sludge is incinerated
to produce activated carbons to use in advanced
treatment filter beds. These are just a few
alternatives, with no more imagination than has
been shown in the proposed sludge disposal. We
can see that there are absolutely no long-range
plans for the disposal of sludge; just short-rangr
plans. The casual dismissal of sludge disposal
by suggested land absorption is not only naive,
but it also avoids the regulations that are de-
manded. Detailed plans must be formulated. The
environmental assessment in the proposed plan is
inadequate. The engineering that substitutes one
problem for another as a solution is neither valic
nor acceptable.
Somewhere in the report you mentioned, or
someone mentioned, that there were very few wells
on the westerly side of the Turnpike. Well,
90 percent of the population in that area are on
wells and these are shallow wells with a very high
water table. In the area, most of it is sand and
this is where Scarborough will be looking for At
their sludge disposal sites, and I am sure the
people wouldn't welcome them. There isn't too
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much else I can say other than I understand this
water will be 99 percent pure. I am wondering if
the town officials might run a water main down
there and hook this so-called pure water in the
water main and send it up to North Scarborough.
We could use it.
MR. STICKNEY: Thank you Mr. Hillock. I
should have mentioned at the end of Mr. Brooks'
presentation, you are beseiged not only by this
planning process but of course by another area-
wide planning process now going on -- the so-call
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Regulations, Preparation of Environmental Impact
Statement, states "Factors that must be considerec
in determining if induced changes are significant
include, but are not limited to, the land area
subject to increased development as a result of
the treatment works; the relative increase in
population which may be induced; the potential
over-loading sewerage — the potential for over-
loading sewerage facilities, the extent of which
land owners may benefit from the area subject to
increased development; the nature of land use
regulations in the affected area; and the potentia
affects on the development."
A critical factor in determining the impact
of water treatment facilities on the community's
natural and man-made environment is the numerical
increase and physical location of population
caused by the facilities. The Environmental
Impact Study has made population projections both
with and without the proposed treatment facilities
They have drawn conclusions about the impact of
the proposed facilities on the natural and man-mad
environment. The Environmental Impact Statement,
paragraph 2.2.1, Population Profiles, states,
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"Projecting population for any one area can
involve a variety of factors and components
analyzed. However, the margin for error is wide
and given the vagaries of consumer trends and
practices, this margin increased with each
succeeding decade included within the span of
the projection."
The study bases its impact conclusion on
one population projection, recognizing the very
wide margin of error in population projections
and, yet, does not address this sensitivity of
conclusion to various -- to varying population
levels. The conclusion concerning the proposed
wastewater facility's environmental impact could
substantially change if the population trends
were higher than assumed. No confidence level
is established for the population projections.
Therefore, how realistic are the conclusions
drawn from this imprecise data? One purpose of
the Environmental Impact Study is assessment of
the impact wastewater facility on the natural and
man-made environment. EPA Rules and Regulations,
Sub-part (e), paragraph 6.5(7) (b) states, "The
impact statement section entitled "Environmental
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Impact on the Proposed Project or Plan" shall
contain a description of the environmental impact
that the proposed treatment works or plants might
have on the surrounding area. Both adverse and
beneficial effects need to be discussed." The
EIS study concludes in paragraph 5.1.5(2), "Thus,
the proposed actions would eliminate all the
discharges of untreated sewage into the estuaries
of Scarborough and in the Higgins Beach area.
The water quality in these waters would, therefore
be improved."
This conclusion is reached without considera-
tion of the effects of runoff from adjacent land
on the estuary water quality.
The majority of the population growth pro-
jected by the study won't settle on land around
the Scarborough estuary. The map of Figure 2.2-4,
the zoning map of Scarborough, shows the estuary
surrounded by the land zones R-2, R-4, R-10 and
B"l. All these zones allow for substantial high-
density development. In addition, the map of
Figure 4.1-1, the location of the proposed key
facilities and general areas to be sewered,
indicates sewers will serve all areas surrounding
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the estuary. The present Scarborough Zoning
Ordinance allows land serviced by sanitary
sewers to be developed to the maximum density
allowed in that zone. These facts indicate a
significal number of dwelling units could be
built surrounding the estuary. The map of
Figure 2.-1 (sic) shows all land east of the
Turnpike drains into the estuary.
The concentrated development of dwellings
around the estuary will lead to a substantial
increase in runoff. A conclusion reached in the
Hunter-Ballew report was, and I quote : "Runoffs
from developed lands surrounding the marsh could
offset any improvements in water quality achieved
by installing sanitary sewers."
No consideration has been given in the
Environmental Impact Study to the affect of in-
creased runoff from developing lands on the estuar
water quality. The effect of the proposed plan
allowing development of land adjacent to the
estuary, the increase in runoff from the developec
lands and the impact of runoff on the estuary
water quality has not been investigated. This
oversight violates the EPA Rules and Regulations,
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Sub-part (e), paragraph 6.5(4). This study must
investigate the secondary effects of the proposed
water quality management strategy. Thank you.
MR. STICKNEY: Thank you, Miss Lee. Mr. Robe
Pelletier?
MR. ROBERT PELLETIER: Thank you, Mr. Chair-
man and good evening concerned citizens of
Scarborough. The following is a summary of commen
on a cost analysis in the EIS statement for waste-
water collection and treatment facilities for the
Town of Scarborough. The following comments will
demonstrate that in the process of developing a
cost per user breakdown, the total cost of the
entire project was ignored and the cost per user
breakdown was provided only for Phase 1. This
summary will also prove by using the same formulas
as in the Phase 1 cost analyst and using the same
methodology that the final cost per user, includin
Phases 2 and 3, will not be $237.00 a year. It wi
be $322.00 a year.
The project as defined in Section I, page sev
of the report, and I quote: "This project is
intended to service the entire portion of Scarbo-
rough east of the Maine Turnpike. The plans call
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for a three-phase construction program to be
completed by December, 1982." Yet, the cost
breakdown provided in Section IV, page 14, is
clearly captioned as being for Phase 1 only.
This breakdown demonstrates that the annual cost
per dwelling or per user will be $200.00 a year if,
and this is contentioned on a five percent avail-
ability -- or the availability of a five percent
Federal Home Administration loan; or the annual
cost will be $237.00 a year if the monies have to
be borrowed on the municipal bond market at
7-1/4 percent. Last evening on the front page of
the Press Herald a story was printed stating that
the 10.5 million portion of a 19.1 million cost
would be financed by the town itself. Another
sentence in the same article reads, "An annual
charge would result to the residential users of
between $200.00 and $237.00." Obviously, the
annual cost of the entire system has yet to be
calculated, or somebody is disseminating false
information to the press.
I am providing the Chairman -- and I would al»
like to give a copy of this to the Scarborough
Planning Board -- a cost comparison which will
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indicate the increased annual cost per dwelling
from $237.00 to a more realistic cost of $322.00
when Phase 2 and Phase 3 are added. These calcu-
lations are based on the following facts:
We used the same ratio of assessments per
user for Phases 2 and 3 as what was used for
Phase 1 in the report.
The total dwellings to be sewered under
Phases 2 and 3 will be an additional 800 units.
The yearly operation and maintenance cost
is estimated to be increased another $50,000 a
year when Phase 2 and Phase 3 are added.
The report does not state that. It says that
the total annual operational cost will be $200 ,00C
a year for Phase 1. Also a realistic and practice
approach to amortization is through a bond issue
at 7-1/4 percent. The report admits that the
financing through the Federal Home Administration
is doubtful at this time and, yet, the calculation
are based on the 5 percent loan.
In summary, ladies and gentlemen, I feel that
the following questions must be resolved:
Why is the cost per dwelling analyst provided
for Phase 1 only and not for the entire project?
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Number two, why is the FHA loan at 5 percent
used in the calculation of the cost per user
breakdown when the availability of such a loan is
in doubt?
Number three, from a cost per user stand-
point, why does Phase 1 provide sewers for presently
undeveloped property while populated areas, such
as Blue Point, Willowdale, Pleasant Hills, Scottov
Hill and West Scarborough are relegated to Phase 2
and Phase 3?
Thank you for listening to me.
MR. STICKNEY: Thank you very much, Mr. Pelle-
tier. Questions or comments? None? Next, if
you please, is Sandra Bradford;she wishes to speak.
Miss Rebecca Warren instead.
MS. REBECCA WARREN: I'll be reading a state-
ment that has been prepared by myself and Sandra
and Charles Bradford as members of the Conservatioi
Commission here in Scarborough.
As members of the Scarborough Conservation
Commission, we realize that there is a serious
pollution problem within the Town of Scarborough
and that there is a graye need for sewage treatmen :
but for treatment that is cost effective in terms
3 1*$	
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of social, economic and environmental criteria.
The Booz, Allen and Hamilton, Incorporated
Environmental Impact Statement for the treatment
facility as designed by Whitman and Howard is an
inadequate analysis in many respects. We would
like to address ourselves to a few of the deficien-
cies of that study.
Point one, the Environmental Impact Statement
has given insufficient consideration to the
increased volume of traffic and to the noise
pollution generated by this traffic in a primarily
residential and recreational area. We find the
study to be lacking in terms of the increase in
heavy traffic on Ferry Road and the Black Point
Road. These roads are basically residential and
are already experiencing congestion during many
months of the year as access roads to town and
state-owned beaches. Trucks will also be operating
in areas where there is substantial pedestrian
traffic on the road to the beach, passing in close
proximity to the beach parking lot and passing
through golfers' crossings.
Point two, the Environmental Impact Statement
gives insufficient consideration to the effects of
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the blasting necessary to lay an ocean outfall
at Prouts Neck. We find the study to state only
that blasting will be necessary to lay an outfall
pipe. There is no detailed information regarding
possible effects of this blasting on the animal
and plant life of the surrounding area.
Point three, the Environmental Impact State-
ment gives insufficient consideration to the
long-range effects of destroying dunes within the
area of the proposed plant, the possible damage to
the state-owned salt marsh directly adjacent to
the plant site, to the general damage to the
esthetic quality of the area and to the hazards of
building in an area highly susceptible to flooding
The Scarborough Conversation Commission is pre-
sently working with the Threshold to Main Re-
sources and Conversation Development Project of
the Soil Conversation Service, U.S. Department of
Agriculture to preserve and restore the sand dunes
at Ferry Beach. Any disruption of dunes in that
area would be counter-productive to these efforts.
The location proposed for the building of this
plant is in an extreme flood hazard zone. In
light of the problems encountered by other plants
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constructed in flood point areas, such as in Saco,
this seems to be an undesirable site.
We will conclude that, as members of the
Scarborough Conservation Commission, we feel there
are many serious questions in regard to the
environmental impact of the proposed secondary
treatment facility which remain unanswered in the
Booz, Allen and Hamilton report. Further, we
realize that Federal law requires municipal
sewage treatment to be of an advanced nature by
1983. In view of the fact that the final phase
of the proposed secondary plant will not be com-
pleted until 1982 at the earliest, we feel that
the funds required for construction would be more
wisely spent on a plant using advanced treatment
rather than to convert the Whitman and Howard
secondary treatment plant at a later date. In
addition, advanced treatment would be a,more effec-
tive means of reducing the pollution content of
the effluent which will be produced. We, therefoi
feel that the study is deficient in its failure
to consider alternate means of treatment and for
the other reasons previously discussed. We would
ask that these deficiencies be corrected before a
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final decision on the Whitman and Howard proposal
is made.
MR. STICKNEY: Thank you very much. Mr. John
Lee?
MR. JOHN LEE: Mr. Chairman, members of Booz,
Allen and Hamilton, members of EPA and friends of
Scarborough. After a careful"examination and
study of the Environmental Impact Statement, we
find that there are many discrepancies which
should prevent fast action to approve Phase 1 of
the proposed sewer system for the Town of Scarbo-
rough. We shall try to enumerate many of what
we term deficiencies, not paying any particular
attention to their order in the Environmental
Impact Statement.
The statement includes a great deal of informa
tion about the disposal of sludge that is
accumulated at the treatment plant, but how is it
to be treated; where is it to be placed and how
much it is going to cost has not been included in
the report. This additional cost is important to
taxpayers and where it is to be dumped is a most
important decision. Whitman and Howard should hav:
learned their lesson in South Paris about where
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to dump sludge, yet there is nothing definite
in the statement. After this South Paris treat-
ment plant was built, the sludge problem came to
light. I believe there were five hearings before
the DEP and I am not certain if it has been
settled yet. I have here a brief regarding the
incident and I am sure the EPA knows quite well
that this sludge removal phase should be properly
defined, and hex!» i$ a brief relative to that.
They have one hell of a time down there.
Now, the statement has much to say about the
outfall at Prouts Neck, but exactly where it is
to be placed has not been pinpointed. A change of
position could be increases in cost and further-
more could affect the waters more in one position
than in another. The treatment plant is the
first major construction, but as to where it will
go does not seem to be definitely decided. Why
wasn't an option obtained on the necessary land
that seems most desirable. This delay in such a
decision could mean another increase in cost to
the taxpayers and could be embarrassing to settle.
Why hasn't the whole story been told on this
sewering of Scarborough? Facts and figures
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concerning Phases 2 and 3 have been omitted from
the statement. Yet, this is an essential part
of the complete picture. It is important to the
people in Blue Point and West Scarborough that
they know the answers. The EPA should be con-
cerned with an incomplete financial and environ
mental review.
Yes, we know that decision is on Phase 1
relevant to the grant, but you should get the
full story. Why hasn't the statement included
the plan of Thomas Griffin Associates that was
submitted to the Sanitary District and the DEP
sometime ago. This plan was considerably less in
cost than any of the ones described in the state
ment. If it could be decided on cost effectiveness!,
then the Griffin plan is a greet deal more cost
effective. Why was it that only one person from
the opposition was interviewed when many names of
prominent persons with expertise were given to
the consultants? Why was it that Whitman and
Howard were called in after the primary draft was
out to help make changes for the final draft with
out asking others to sit in?' Since we are trying
to control pollution, consideration should have
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been given to the balefill relative to the
leachate. The mere one reviews the Environmental
Impact Statement, the more one questions the
reliability of it.
On page 11-30, Table 2,2-2, 1975 population
estimate of Scarborough, the figure 754 family
units is very much in egHS-. The total of
individual family units should be 1018, or a.
difference of 265 units. This affects other es-
timates in the chart. The town annual report wii:.
verify the difference.
Let us look at the user fee. Originally, th<
user fee was $137.00 until a decision had to be
made to the DEP and the engineers said it had to
be at least $188.00. The total annual user fee
in the preliminary report was $153.00. Then the
final statement appears and it is $200.00 or
$237.06, The user fee for Phases 2 and 3 was not
involved, but if it were, using the information
in the statement and combining it with Phase 1,
it would be approximately ai^ Mr. Pelletier said,
$322.00. Shouldn't the b^A'know these answers
and how about the taxpayers? It is only a small
point, but it has to do with the consistency, on
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page 11-82 relative to "There are a few
privately-owned ground water wells in Scarborough
and I think Bill Hiller hit on that. The Buildinj;
Inspector told me there are hundreds, maybe even
thousands. It JttSt goes to show you how thorough
on what they were doing.
Okay, the consultants in reverse. Figuring
from the projected population in 1995 back to
the estimated population in 1975, arrived at an
annual figure of dwelling units construction of
139 per year, saying it was high and perhaps 100
would be more reliable. But with a close look
at the years 1970, *71 and '72, there were 814
units, family units* built and an average of 271
per year with 511 being built in 1971, believe it
or not. This building was taking place with
very little sewering. Did our consultants inves-
tigate the R-10 area from Black Point Road to
Route 1? What do you suppose will happen with
a large *»Ver ii^jthe ground and over 250 acres
zoned for R-10? #5$&ere is capability for 8,000
people in that area alone.
Now, the draft states we will get our ellif
back and that we will be able to do recreational
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digging, Yet, one of those state officials said
a while ago that with the secondary effluent going
out at the Neck, it would be doubtful if we ever
got the clams back be.cause of storm water runoff.
Now, I ask you in 1946 there were 118,000 bushels
of claras dug, plus all the recreational digging,
and our present production is for 10,000 bushels
per year. We are told vltk the building of the
sewer we may inc$iMi$|> our production to maybe
15,000 or 20,000 bushels per year. That is
getting our clams back -- 118,000 bushels and now
20,000 bushels? Far from it, and nothing has been
said about aqua culture. Scarborough has already
done a great deal in cleaning up its pollution
sources. Humpty-Dumpty, Scarborough Downs, Prouts
Neck, Oak Hill have made good headway and there
is no need to saddle the taxpayers with this new
sewer that will burden the town. It can be done
better and much easier if other engineers were
given a chance to compete, but it has been a close-
out with Whitman and Howard.
Because of the many inconsistencies of the
statement and Whitman and Howard, our taxpayers
are concerned about the reliability of both the
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statement and the engineers. The greatest bulk
of the material in the statement is from the
engineers who hawe the most to gain. Reference
has been made to Hunter-Baliew, but their work
was a rehash of Whitman and Howard's writing.
There has been no real technical research by the
authors or Hunter-Baliew to verify facts and
figures given by Whitman and Howard; just an
appraisal of the material furnished by the en-
gineers, Even the size of the plant can be
questioned. This past week we visited the
Kittery treatment plant built by Whitman and
Howard and it was only operating at one-third
capacity. The attendant blamed it on the reduc-
tion at the navy Yard. Kittery is a three million
gallon per day treatment plant, such as is propose
in Scarborough. A visit to Kennebunk where
Whitman and Howard built two primary plants?-one
a three million gallons per day and the second
750 gallons per day--we learned that it, too, was
operating at about one-third capacity. Do we
really need a three million gallon per day treat-
ment plant?
Now, during our fisit to many sewer plants
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last week, we got the feeling that our engineers
were up te their necks in problem* with a one of
tho towns, Ogunquit, Kennebunk, Old Orchard,
Biddeford, Saco end South Peris* Sene officials
had a lot to sey *nd w®?of#rr®d to the nany tine:
relative to tho Saco situation at Factor/ Islafcd«n
sure the EPA is well awiift..'c-S ihis problem.
I would like to read tfi'llii quote by Mayor Zaglaad
(phonetic) of Saco relative to the Saco River
Tannery has been discharging its effluent into
the river. "The pollution problem at Factory
Island stems from faulty design and construction.
It was designed by Whitman and Howard of Boston,
which also designed treatment facilities at
Biddeford and Old Orchard Beach. Those two towns
have experienced considerable problems also. I
don't think the firm is reputable." Here is an
article from the Biddeford Journal, an article
from the Biddeford Journal here in which Mayor
Boucher (phonetic) blames it all on Whitman and
Howard which designed Bi&djpford' s treatment system
Now, because of the man* jUconsistencies in the
statement, the appraisals of all Whitman and Howar
material, no other engineer's input, the lack of
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technical research to prove the accuracy of
the engineer's recommendations, the excessive
user fees that will be charged, the omission of
Phases 2 and 3 facts both monetarily and environ-
mentally, the assured increase in growth that
would take place affecting all town services so
as to steadily increase the taxes, we |»el that
the EPA should delay any action and give the
people in the town who want gradual growth a
chance to produce a better plan with 208 funds.
Furthermore, we recommend them not to rush
hastily in operation with Whitman and Howard be-
cause of the many problems they have encountered
in the various towns mentioned above. Thank you
very much.
MR. STICKNEY: Thank you, Mr. Lee, I atktt
say that there is one thing that came to mind,
the .'btlcfill is mentioned on page V-24. I must
admit that that could be elaborated upon somewhat,
but it is there. Secondly, although our primary
mission here	listen and we are listening
quietly, % hope that as we go through this, that
the aere fact that we are listening and not re-
sponding is net misconstrued. We don*t necessaril
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agree with every point that is being made, but
we are listening and we will respond to each one
as we go further into the development of the
Environmental Impact Statement. I believe
Mrs. Lee wishes to speak.
MRS, JOHN LEE; I have carefully reviewed
the draft Environmental Statement on Wastewater
Collection and Treatment Facilities for Scarboroun
I would like to point out a few inaccuracies in
the report, and in addition, I would like to
mention the state of omissions of the options
which are required by law and recommended by
Federal guidelines. The Environmental Protection
Agency's final regulations concerning EIS states:
"The EIS will develop, describe and objectively
weigh feasible alternatives,including the
options of taking no action or postponing action.
The analysis should be detailed enough to show
EPA comparative evaluations of the environmental
impact, commission# of resources, costs and risks
of the proposed action and each feasible alterna-
tive." In addition, the Council of Environmental
Quality Rules and Regulations, Title 40, states
that, "The alternatives of taking no action or
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of postponing actions can embrace studies,
alternatives requiring action to be significantly
different in nature which will provide similar
benefits with different ^vironmental impacts,
alternatives related to different designs or de-
tails of the proposed action which would present
different environmental impacts." In this regard
the EIS has inadequately and erroneously raised
feasible alternatives and has not complied with
the above law.
The plans presented by Thomas Griffin of
Thomas Griffin Associates, Company were not con-
sidered. These were given at a Board meeting prio
to November 15, 1974 to the Scarborough Sanitary
District. Briefly, the plan calls for the en-
largement of the Oak Hill plant to 124 million
gallons per day, converting the existing plant
from extended	oxygen. It will
safeguard the quality oft til* waters in the estuary
by going to advanced treatment using sand fill as
a backwashing to remove particles, making disin-
fection with ozone to insure the removal of bacterlL
and viruse.s possible.
At this point I would like to point out
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asse&fRtnts in the BIS statement where they
qweteDr.Berg as stating that the effluent would
be 99 percent pure, I believe the way it is
stated there is that "provided there it a clean
effluent, it is free ef 3olids," The local news-
papers have picked this up and they are under the
impression that the eff<pnt will be generally
99 percent pure, and ai'.vflr. Levy pointed out, in
order for ozonation to be effective, you must not
have any suspended particles and with secondary
treatment, you will have --well, it is allowable
to have 30m£. per liter of suspended solids. So,
this does make a difference. I do have a letter
from Hathaway's office where they called Dr. Berg
to clarify this statement.
Now, the above alternatives -- talking about
doctors, Mr. Griffin mentioned that.
The above should include Higgins Beach using
a different routing for the interceptor line,
thereby cutting down on the length of the line
through R-F areas. He ala$ said you could con-
sider a separate plant B'e set up at Higgins
Beach, which was a proposal that was made by
Mr. Hodgkins at the December '75 meeting of the
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Sanitary District, one on which no action was
taken. In reference to this, I would like to
say that in 1971the Sanitary District signed a
contract for planning for the Higgins Beach -
Prouts Neck plahs and we are still waiting for
that Higgins Beach plan because we have been
planning for the rest of the town because we coulc
take care of Higgins Beaxh.
Mr. Griffin's plan, as proposed, was -- woult
cost significantly less and is more favorable to
the environment than the proposed Plan A. This is
especially true since it installs the interceptor
along the abandoned railroad line and removes the
line from the precarious position of being under
the Scarborough River.
The alternatives which proposed the transfer
of waste to South Portland and Old Orchard were
disregarded on the basis of erroneous and inade-
quate analyses. It is stated that "Transferring
Scarborough's w»f*0 to South Portland will require
changes in treatttfcut plant design and the Maine
Department of Environmental Protection would not
allow any dolay in the construction of the South
Portland project*" A consulting engineer pointed
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pointed out that the South Portland plant is
based on a 25 year design and could accept waste
from Scarborough without delay in construction of
the plant. The EIS does not present specific
information in this regard.
Again, the EIS has eliminated the Old Orcharc
Beach plan with the same arguments that were
presented for South Portland. With respect to
Old Orchard Beach, the EIS again does not careful!
present information to show that Scarborough cannc
tie without delay of the project. In fact, I have
recently read a letter addressed to Mr. Appleby,
the Chairman of the Sanitary District, stating
that it might be advantageous;to>all participating
communities to take on additional units from
Scarborough.
A reference at this point was made to the
208. Therefore, the two alternatives which call
for the transferring of waste were not adequately
I
considered, as required by law and must be re-
assessed. The EIS does not consider alternatives
of a significantly different nature as is required
Action alternatives reviewed were biological
treatment plants. The EIS did not review possible
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physical-chemical systems for the town. After a
brief review of the literature and conferences
with experts in the field, it is clear that P-C
plants could cost less than biological systems
in some instances and in any case, are of com-
parable cost. I have references to water pollutio
control conversation with Walter Webber of the
University of Michigan, a conversation with
Otis Sproul at the University of Maine, water
and waste engineering and so forth, which I have
in the paper.
More specifically, the Superintendent of the
Scarborough Sanitary District received a letter
from Telecommunication Industries, Incorporated,
which stated that "sonar-zone" treatment system
produced an effluent of much higher quality than
by biologically treated effluent and construction
cost for a typical facility of the size needed in
Scarborough would be equal to or less than the
cost for Plan A.
Might I say at this time, we were interested
in finding out whether this might be a suitable
plant for Higgins Beach.
This alternative and others "of a significant
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different nature" must be considered before a
decision can be reached. With this treatment
system, it maybe possible to clean up the polluted
areas stated in the consent order by constructing
more than one treatment plant and the higher quality
effluent could be discharged into the estuaries.
It is clear that th# BIS has not considered
these alternatives of a significantly different
nature and a review is necessary before a decision
can be reached.
"Alternatives related to different designs or
details of the proposed action" have not been
considered. For example, the pure oxygen actived
sludge system, different size plant, different
lengths of the outfall pipe. Other alternatives
inadequately considered are ozonation versus dis-
infection. Ozonation can be monitored. Therefore,
it cannot be disregarded prematurely without
adequate analysis, as was done in the draft.
From the above section it is clear that feasible
alternatives have not been sufficiently explored,
as is required by law.
Two, the Environmental Protection Agency's
final regulations states that the EIS shall descril
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primary and secondary environmental impacts, both
beneficial and adverse, anticipated from the action
The draft does not comply with the section of the
law for the following reasons:
(a) The Environmental Impact Statement has
insufficiently dealt with environmental effects of
consttuction of the proposed facilities on water
quality. For example, it isn't sufficient to say
that construction of the proposed facilities would
have "temporary minor adverse effects," without
substantiation. What effect will blasting the
trench for the outfall have on the fish, lobsters
and shellfish of the area, which are harvested
commercially? At this point I don't know whether
it was known that there are shellfish in the area
where the outfall is going. I forgot my bag of
clams, but I took a walk on the beach today and
in five minutes I collected one big bucket of huge
hen-clams, which periodically are washed on shore
on all of our bsftches -- Higgins Beach, Scarborougi
Beach and Pine Point. So, referring to the impact
by the construction of the facility, this possible
impact could be of such magnitude so that it cannot
be neglected.
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(b)	There is a lack of baseline studies
on the marine biota in this pristine area as a
point of reference for monitoring. I get a little
emotional here when I think of this beautiful
area of a pristine nature, one of the few left
up and down our coast, without any outfall, is
going to be contaminated and I don't think we do
have a proper baseline study to know the diversity
of organisms we have;, in this area. And what are
the possible effects of residual chlorine on the
biota? I don't believe this has been considered.
Now, we do know from studies in Narraganset that
these can be considerable. Flounder eggs, for
instance, were killed by something like 4/10the
parts per million of chlorine.
(c)	The EIS has not properly evaluated the
consequences of a treatment plant failure and the
probability that a failure will occur. It is
stated that the reliability of modern plants is
high because of the requirement for stand-by power,
duplication of machinery and pumping capacity and
failsafe provisions. There are numerous authenti-
cated references which state that the treatment
plants are subject to upsets in the biological
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treatment phase. There are no failsafe mechanism
to prevent users from flushing a plethora of
toxic chemicals, drugs down the drains, which are
toxic to the microorganisms essential to the
treatment. Further, whin, 'this failure occurs,
there could be a significant hazard to health due
to viral and bacterial pollution because of a
46 times dilution of the effluent, which is pre-
dicted as insufficient dilution to protect health
and damage to the marine biota and economical
consequences.to a tourist area.
Excuse me, what I am trying to say is that
there is not enough evidence to show what this
failure, which will result in the astronomical
numbers of organisms, many of the pathogenes,
washing on the shore, what they will do to the
health of the bathers , the damage to the marine
biota or the consequences that would result to
the tourist trade. I h*ve in mind here what
happened at Old Orchard several years ago when
they had a sewage problem at the height of the
Labor Day weekend. The town was a ghost town
within hours as soon as the news hit the papers.
(d) The analysis regarding the secondary
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effect of growth and cost is questionable. This
has been covered before and I should add that it
is most probable from past experience that sewer
lines would generate growth in the undeveloped
areas and the ecological sensitive areas and it
was pointed out that this might result in the loss
of our clams rather than saving them from the
pollution that is caused from the tremendous
storm water runoff. I would like this point to
be investigated a little further. I know the
208 is interested in this. In addition, the plant
is oversized for the population projection of
18,460 presented in the Impact Statement. There-
fore, if we accept this projection, the plant will
place an unnecessarily high financial burden on
the users or residents. Should we accept the
original population projections of Whitman and
Howard 25 year projection of 27,000 and designed
for three million gallons per day, there is a
greater undesirable population impact east of the
Turnpike than is accounted for in the draft.
Thank you.
MR. STICKNEY: I have several other cards of
people who wish to speak. Miss Linda Fuller?
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MS. LINDA FULLER: From West Scarborough
to the other side of the Turnpike, we don't have
water up there and where you get the idea that we
didn't have too many wells. Every one on the
other side of the Turnpike has a well and there aie
a lot of houses over there. Water stops on this
side of the Turnpike, the same as the sewers. I
fully realize that an adequate sewer systems is
desparately needed in this town. As a resident
of West Scarborough, which means I would never
receive a sewer system, I feel and object to any
extension of being forced help pay for the sewer
system. I do feel that a paragraph completely
and accurately stipulating that North and West
Scarborough will not and never will be taxed, finei
burdened, or forced to pay the user fee, a part
thereof whatsoever until the sewer system runs
at least 500 feet from our property. The reason
for this stipulation paragraph is the town has no
intention, desire ©r will to bring the sewer systeu
across the Turnpike, We feel that our taxes
are over-burdeniiig now for the few benefits that we
receive. We do not have good police protection.
The only time we do is when we have to call after
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we have been robbed. We don't have a water
system,which I just said. We all have wells,
and the sludge might ruin our wells. We do not
want to pay for this benefit for the users. Also,
if the proposed sewer system is handled anything
at all like the sludge disposal system in this
town, then we are in desparate need of help way
beyond anybody here. I will give you one example ,
because I know physically of a site on the Broad
Turn Road. This is a letter from the Scarborough
Planning Board to the Scarborough Field Board.
"Special Section Appeal by B. H. Henchel, sewage
treatment facility, November 13, 1974. To the
Scarborough Zoning Board of Appeals:
The Planning Board to review the B. H. Hench*
appei at our November 12th meeting. We offer the
following observations and opinions for your
information:
(1) A septic tank sludge disposal area is
the immediate facility and appears appropriate
in the R-F zone. However, we are completely
forgetting that we all have wells. Nonetheless,
such a proposal must be just as acceptable on its
merits and impact on a local neighborhood and
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environment." Not once was there anybody that
did not complain. We complained, we rallied,
we petitioned, we still got it. ,vThe EP has
issued a license for the subject facility." This
is in the letter. "Apparently, the facility meets
the main guidlines for septic sludge disposal
on land requirements, but substantial proof of
that fact should be obtained. The licensing pro-
cedure should be scrutinized for completeness
and accuracy." Was that ever done" Never in this
town. Nobody cares. Town officials do not care.
"Water qu&lity monitoring provisions to determine
impact of such a facility on the environment have
not been proposed. Monitoring of water quality
should be a part of any proposed disposal on land.'
That also was never done, nor has it been done
since, even though it is running right into the
Nonesuch. Nobody cares. The town doesn't care.
"A very close look should be taken on the impact
of such a facility on a local neighborhood before
you take any actions." Again, lawyers and
petitions have gone through, still --- "If you
judge that the appeal is appropriate and have
satisfied yourselves that the impact of such a
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facility is justified, precedent has been set
for the detailed proposal to be reviewed by the
Planning Board under a non-statutory subdivision
Ordinance number 6. The Planning Board does not
offer an opinion of approval or disapproval be-
cause the appeal is a complicated one and our
first-hand information is limited. We suggest
you accept our opinions on their merits and waive
the impact on the environment of the neighborhood
to get substantial means for such a facility."
May I ask what did they o^inionate? Nothing.
They don't Offer approval or disapproval. They
are just passing the buck. Why didn't someone
or some department in the office of the town take
initiative and find out more information instead
of passing the buck? This letter for the third
time mentioned impact on local neighborhood
should be considered. The neighborhood complainec
It is just my opinion that if this sewer system
is handled on the same idea as the sludge dispo-
sal site and if it happens«? and it sure seems to
be that way, we are going to be in trouble, not
just in dollars but in land, air and water
quality control and abuse. This hurry-up, non-
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caring attitude by the town officials seems to me
to be a disgrace and they should look into this
more thoroughly and look into an alternate site,
an alternate way of taking care of the sewage
disposal. Thank you.
MR. STICKNEY: Thank you, Mrs. Fuller. By
the way, I should mention that, of course, in
addition to the Federal and state approvals that
are required for any portions of the systems,
nothing preempts local approvals and local
deliberations and whatever variances or zoning
changes have to be made would have to go through
your normal channels.
The next card I have is Dr. Robert Richie, I
believe.
DR. ROBERT RICHIE: Gentlemen at the head
table, ladies and gentlemen, since this ground has
had so much sludge tilled on it in the last hour
or two and has been told sourt of thoroughly, I
am going to restrict my comments to an area that
has only been touched on tangentially and that is
why I will talk about virus.
I think most of you who read the newspapers
must be aware that there are other governmental
Tint"
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agencies that are extremely active and perhaps
overboard in the attempts to protect us as
individuals from having other health threatening
items placed in our environment, namely into our
food and our working environments. These agencie;
seem to be working quite different from what we
see in operation today.
The subject which I think makes most of us
who are cognizant and have some involvement with
the decision making process which is to protect
us as individuals are somewhat haunted by some
of the things which happened a few years ago, and
I will briefly mention one because I think it is
worth reminding the members of the head table.
Perhaps you remember the thalidomide program that
occurred in 1959 through 1962. It was a drug that|
was released in the European countries without
the appropriate field trials, which we in this
country require. There were no means by which the|
adequate testing in a human population could be
carried out. Fortunately, some people did publish|
and more than that, fortunately in this country
people read what was written in Europe, and one of
our people here was aware of the fact that while
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there was no effect of this drug --and I am using
this as an analogy -- this drug caused no effects
on the animals themselves and was given a clean
bill of health by the industry controlled experi-
ments. But one member said that there were Severn
cases of abnormal babies being born in these mice
and because of that studies were carried out in
this country and because of that the drug was held
up here and it was never released. There were
3800 babies born with most unpleasant deformities
in the Western European countries. The estimate
in this hemisphere would have been close to
18,000 and it was only stopped because somebody
was sensitive to what was happening.
Now, I think the gentlemen at the head table
must take into account the great concern of the
scientific community that there is a hazard in
our environment that we are currently ignoring,
and that is the virus. There is a very ubiquitous
bugaboo and we bring it up all the time, and you
have heard it repeatedly, but two years ago when
we first threw it up, there was only just the
faintest Tumblings on the horizon of what the
virus implication was in the human environment,
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and in those two years we now have well-documente
evidence that viruses cause all ii the diseases
that we fear in humans, in animals, in our domestL
animals and our wild animals. We have some solid
evidence of virus -- that viruses are related to
many human diseases. The points that were made
earlier that sewage effluents do not adequately
dense the effluent of virus must be remembered
and the infectivity of these effluents has to be
remembered very carefully, and I think that the
gentlemen at the head table while they are listen
ing tonight must remember that the trend of affair
in the United States at the present time could
place them who approve of an inadequate project,
such as we think we are hearing about tonight,
in the position to be in a hearing before the
people who are out there.
MR. STICKNEY: Dr. Richie, if I might, one
question comes to mind and it has been in my mind
most of the evening. If, provided complete removal
does take place of the virus instead of 99.9 per-
cent whatever or 100 percent, I think we would al]
agree that that removal merely transfers the
virus, should it occur, into a sludge product
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which we all recognize has to be put somewhere
in the environment or reused, and my question is,
in your research and in the research that you are
aware of here, is there any judgment that can be
made as to your opinion as to where the least
damaging final resting place for this thing is?
DR. RICHIE: The use of pyrolysis, which is
incineration in excess of 3,000 degrees,which is
not a difficult process to accomplish. There are
many incinerators -- municipal incinerators which
do just that. It must be carried Out in that
fashion because virus infected -- infected human
virus will withstand incredible mishandling. For
example, the hepatitis virus, which we have right
here tonight, it will stand boiling for 30 minutes
Several of the other viruses will withstand very
high levels of various toxications and still be
effective. Even if the effluent were 100 percent
clean, you bring up the point, it has to go some-
where, and it is in that sludge and if that sludge
is not destroyed', and the thought of putting it
on the environment where we can have access to it,
is absolutely horrifying to me. We go to enormous
lengths within the hospital setting to isolate
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the individual who is potentially a carrier of
an infective virus and to think of taking those
bedpans out and putting them on a golf course, is
just beyond me, and that is essentially what you
are suggesting be done here, because the effluent
has infected virus and I think I have one more
comment concerning a statement that was made
earlier that there is no scientically valid
information to say t^iat the effluent is infected
is misleading. There is no data, period, one way
or the other. I think that EPA and whatever
agencies are involved in this must support and
force this kind of work. Otherwise, we are going
to be in the soup but it is going to be too late
a little later on.
MR. STICKNEY: Are there any other questions
from the panel?
(No response.)
MR. STICKNEY: Dr. Richie? Thank you.
MR. FARKUS: Dr. Richie, do you have any
sense of the concentration of viruses in your
average public swimming pool?
DR. RICHIE: I would be afraid to look, but
that doesn't protect me from not wanting it dumpec
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into the ocean. I think that is a specious state-
ment, really, because we recognize that our
environment is latent with virus. What we don't
understand at the moment is by taking a treatment
plant which gathers material from all of the homes
in the community and then makes it available in a
fairly tight, concentration to a young population-: -
I think the point was made earlier that the young
population is the worrisome part, the young
population at the beach. The young population is
probably the one at risk and we have many examples
of that in human disease, exposure of -- being a
child is the time in which -- that's the dangerous
period. As adults, perhaps it is too late, or
many df us, the incubation time for these viruses
is just not there. But when you are a youngster,
you perhaps are highly susceptible and I use that
trite case of leprosy. You never see an adult
• • '>	i
catching it. It is always contracted as a young
individual, and there are many viral diseases that
are exactly the same situation. Several neurologic
diseases that are just that. They cannot be
transmitted to the adult, but they are transmitted
to the child, but the adult carries the virus and
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sheds the virus, but the child catches it and
the adult gets the disease. So, by putting it
into a common location such as a single plant,
maltreating the effluent or spreading the sludge
about and then putting it into a situation where
young people are in contact with it, I think is
unconscionable. There is enough evidence today
to document that.
MR. STICKNEY: I have one other question, sir
and that is, that regards the occurrence of virus
in the ambient -- in the environment, is there
any evidence to indicate that the numbers of virus
or virus levels are increasing or changing from
what they might have been from the past?
DR. RICHIE: No, there is no information. It
is a young science.
MR. STICKNEY: Thank you very much. Mr. Willi
Gallant, please.
MR. WILLIAM GALLANT: I would like to address
the Board as representative of the Borden Company
and its local affiliate, Snow Food Products, We
have been actively involved in participation of
the Scarborough Sanitary District for over two
years in negotiating a feasible way for the Town
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of Scarborough to collect and treat the effluent
of Snow Food Products. As a matter of public
record, a contract has been executed with the
Town of Scarborough contingent on the building of
a treatment plant within a reasonable period of
time.
Now, one of the greatest factors here, and
many of you people will agree, is the removal
of effluent from the estuarial system. Unless we
go to some type of centralized system, there are
going to be point source outfalls in the estuari
system and one of the largest would be someone in
the nature of Snow Food Products. We stated many
time at many public hearings, at many Sanitary
District meetings, at many meetings with the DEP
and the EPA that Snow Food Products is not in the
waste treatment business. We are in the business
of producing a saleable, reputable food product
for the consumption of the American people. That
would conclude my comments as representative of
the Borden Company.
I would like to make a small side comment as
a microbiologist and not as a member of the resi-
dent scientific community but as a trained
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microbiologist to the effect that, admittedly,
as pointed out by Dr. Richie, virology is a very
young science. Scarborough cannot afford to sit
on its heels and wait for the development of a
science that could be five, ten or 15, 20 years
down the road. It is a long way off and these
gentlemen who have come up through the scientific
community realize, and I'm sure are fully aware,
of the length of timjB involved from the beginning
of basic research to the development of applied
virological or any scientific data. To wait and
sit on our heels for the development of virologicsi
techniques is going to be a long-time coming and
I think the citizens of Scarborough should be
aware of that and should be cognizant of the fact
that in all of that time, it's going to be raw
effluent going to those beaches instead of treatec
Thank you.
MR. STICKNEY: Thank .you, Mr. Gallant. Next
I have a card from Mr. William K. Bayley, I belie\
the pronunciation is. B-A-Y-L-E-Y.
MR. WILLIAM K. BAYLEY: I have a few rematks
regarding the clams, Their production on the
Environmental Impact Study quoted 118,000 bushels
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in 1946, This has got to be a misprint or a
mistake. So, I would throw that out. In 1957
there were 4,000 bushels harvested, according to
the records and 10,000 bushels now. According to
my records and the records that I have had avail-
able, the past year, the three declaration plants
in Scarborough processed approximately 10,000
bushels in the year, but only 40 percent of these
clams came from the Scarborough River. So, in
actuality, the Scarborough River system is pro-
ducing approximately 4,000 bushels a year. I
believe this has been true for the last four or
five years. The only way that we could increase
the production of clams in this river would be-
with predator control, conservation and cultivatio
Certainly, putting in a sewer plant, in my esti-
mation anyway, is not going to increase production
If anything, it will decrease it because of the
larger number of people that will be harvesting
the clams.
The other point that I would like to bring
out is that, if this plant is to be built, I would
hope that some consideration will be given to the
Pine Point area in the construction phase, that
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this thing would be done in the months when we
don't have the tourist trade, as the loss of
business would be terrific.
MR. STICKNEY: Thank you for that -- can you
tell me what a hen-clam is?
MR. BAYLEY: A hen-clam is a hardshelled clan
similar to an ocean quahog. It does not grown, as
a rule, in the estuary, but it is along the
beaches. That particular beach where the outfall
would go is a big producing area of these clams.
At the moment; though, I would let Mrs. Lee know
that the hen-clams in this area are toxic and she
cannot take them because of the red tide.
MR. STICKNEY: Thank you very much.
Mr. Robert Hodgdon.
MR. ROBERT HODGDON: Members of the head
table, I am here representing the feelings and
position of the Higgins Beach Association, which
has been referred to tonight several times. Our
organization, numbering over 170 people, has for
a number of years been directly involved and
concerned as to all proposals which are designed
to relieve residents of contributing to sewage
pollution. Our organization has made it clear to
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the town over these past years that the present
1,000 gallon septic tank located in the marsh
maintained by the town is totally and legally
unsuitable to continue to serve over 100 dwelling:;
and two hotels on Higgins Beach. After reviewing
the EIS, the Environmental Impact Statement, our
organization can conclude the following:
That under Plan A the problem of waste dis-
charge at Higgins Beach would be abated but only
at an unreasonable and exhausting cost to the
resident landowners of Higgins Beach; that because
of the need to reduce and eliminate sewage pollu-
tion from 234 dwellings at Higgins Beach it will
be necessary to lay a pipe, sewerage pipe, througl
rural farm land, to run three miles to pick up
53 homes at Prouts Neck and that the environmental
impact created by construction has not been
treated nor analyzed in any form in the EIS State-
ment for Higgins Beach, particularly as it affects
sewage discharge and protection of the frontal
dune areas from blasting; that there is no plan
to control or divert the daily average of 3300
to 4,000 cars which go in on and off Higgins Beach
during the average summer day; that if Higgins
		
¦iP
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Beach did not exist, there would be in our
opinion absolutely no economical or environmental
justification to extend the sewer line down
Spurwink Avenue to the extent that it is designed
under Plan A, Finally, when isolated at Higgins
Beach, residents in this area are seemingly going
to have to pay an overbearing initial outlay and
an unaffordable monthly rate, particularly since
most residents are hfre less than one-third of
the year.
Our organization has found it difficult to
comprehend most of this report. However, since
no representation of the Federal agency doing this
study interviewed any of our residents, we feel
obliged to tell you now what we have told the
town before. Our organization supports completely
the proposal to establish a small, local treatment
plant at Higgins Beach to remedy a severe pollutic
problem, without ever having to expand this plant
because we have a built-in population which cannot
increase to any great degree, which would allow
or cause an increase in plant size. Our organiza-
tion opposes providing sewer lines through areas
of the town that can be sewered by septic tank
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systems, either above or below the ground. The
cost of the Higgins Beach sewer to both Higgins
Beach residents and to the future developer of
the Town of Scarborough will be far, far less,
according to figures available to us, and that an
immediate study and a special study be undertaken
to determine the feasibility of the development
of a small treatment plant at Higgins Beach and
to relate these findings to the present EIS
study. I think that if this is done, this will
once and for all put this cat to bed, as far as
whether or not treatment abatement of a small plar
at Higgins Beach is desirable, feasible, economics
and will do the things that many of us say it will
do.
From a personal point of view, this sewer
program as outlined in Plan A vifch its>*aaimous
capital outlay and operational cost would seem to
be up front, could really easily, if it were
constructed, if we were in those years of 1980,
could easily act as a six voting member on the
Planning Board and as a silent partner on any
Town Council to come.
MR. STICKNEY: Thank you very much, sir.
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The next card I have is for Dr. James Maier,
M-A-I-E-R.
DR. JAMES MAIER: I don't wish to make any
separate statement. I worked jointly on the
statement with Dr. Richie.
MR. STICKNEY: We have other cards which
indicate that people migitt wish to speak, depending
upon what they have heard so far, I presume, and
I would like to poll that group, if I may.
MR. DONALD GO0GAN: I'm not speaking for
the clamdiggers, I am speaking for myself as a
life-long resident of Scarborough and I make my
living from clamming and lobstering in the Pine
Point area, I feel it is time that the people
of Scarborough, in order to live and hold on to
what we have got here in Scarborough, we have got
to start thinking of lowering taxes and not in-
creasing them by building these multi-million dolljt
sewage plants of which we have two already. This
report here tonight leads us to believe that the
new plants will clean our rivers so that our clam
industry will come back te the point where it was
years ago. Well, in regards to this, I will give
you a brief history of our attempts and why I feel
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this is not true.
Throughout the forties and early fifties
we managed our own flats. Amongst the clamdiggeri
here in Scarborough, the only interest the state
had in our affair^ was that we had a $3.00 license
and that we dug a two inch clam. But as populatic
grew and the number of microscopes increased and
the development of marine resources, the word
pollution began to creep into Scarborough. We
formed clam committees and took strong actions
against polluters to our river, and in the early
sixties, a sewage plant was built which we
opposed because they were going to use our river
as the sewer pipe to the ocean. In *66, as
Chairman of the Scarborough Clam Committee, I
made the following report to the citizens of
Scarborough: It has been a record year in the
clam management program with three managed areas,
producing approximately 11,000 bushels of clams
in five months ta the sum of $88,000. Add to this
the claras taken from other parts of the river
over the next seven months, and you have a total
well over $150 ,000.
Now, if this sounds like a family outing to
V ") ^
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get clams to eat, as stated in this report that
some of you read, I don't know, but from '66 on
i&oi this report was given to the Town of Scarborough
we had approximately four years of fairly decent
clamming here in Scarborough. But it seemed to
me, and I think it is the feeling of every clam-
digger in Scarborough, which are quite a few now,
that the more we cleaned our river, the more we
went and done things^the way the state told us to
do them, the more areas we lost. So, I feel that
-- and then, of course, in 1971, as you all know,
our river was completely closed. We had a good
conservation program going as we kept losing these
areas. Finally in '71 we lost our river completely
It was closed to the digging of clams in the
regular manner as we used to do it. So, I believe,
regardless of how many sewer plants are built,
as long as the state controls the clam industry,
it will never be as it was. This is my own persona
opinion on this.
In conclusion, I recommend that the town by
the fastest and cheapest means sewer the Higgins
Beach area, which everybody in the town knows needs
it, but as far as sewering the whole town -- but
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instead of sewering the whole town with a multi-
million dollar plant and the rest of the town
that doesn't need it, I think it is foolish. Thar
you.
MR. STICKNEY: Thank you, Mr. Googan for
that very direct statement. Mr. David Jordan?
MR. DAVID JORDAN: I don't have too much to
say. I just have a few questions I would like to
direct at you people. Mainly, what is going to
happen when you blast 600 feest out there to the
lobster industry in that area, which is a pretty
proficient area for lobsters, and I don't know whe
when you go out there 600 feet, you're going to
find 40 feet of water, because there is considerab
more than that out there at 600 feet. That is
just about the extent of what I have to say except
I don't know what effect this virus and this stuff
is going to have on the lobstering industry, which
I am mainly concerned in. That's all I've got to
say. Thank you.
MR. STICKNEY: Before you go, I would like to
ask two questions. First, about the lobstering
that takes place out there, is that an active area
where people are lobstering?
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MR. JORDAN: Very active. I dare say there
are around 1,000 traps in that area anyway.
MR. STICKNEY: So that the point I'm getting
at is that you would be concerned not only about
the presence of the discharge, but the constructic
activity that would take place?
MR. JORDAN: I would think that if you blaste
in that area, I don't know how much it's going to
consist of, what directly you're going to blast,
but you're going to drive those lobsters out of
there and I wouldn't say they are going to be baci
for a few years. It's a known fact that if a
dragger comes into a certain area and drags the
bottom of the ocean, it takes probably five to
seven years for these lobsters to come back in
any amount. You're just going to ruin that busine
in a very, very popular place in the summertime.
As a matter of fact, it's not just for us commerci
fishermen. You have a lot of summer people that
go from Swanee Point and that's one of the main
areas they fish because it ^s very close to shore.
MR. STICKNEY: My next question is on the
depth, relative to the 40 foot depth and your
comment. Can you indicate an average depth?
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MR. JORDAN: I would say when you get out
there 600 feet, you're going to be running into
anywhere from 70 to 80 feet of water.
MR. STICKNEY: Is that consistent with the
chart?
MR. JORDAN: I don't pay too much attention
to charts because it's mainly -- there are quite
a few errors in the chart.
MR. STICKNEY: Are there any other questions?
(No response} Margaret Sweat? Did Mr. Linwood
Higgins wish to make a statement?
MR. LINWOOD HIGGINS: Ladies and gentlemen,
my name is Linwood Higgins. I have served on the
Town Council for three years and I am presently
its Chairman. Tonight I do not wish to speak to
you in any official capacity, however, which is
why I waited until the end instead of the beginnir
to speak. However, given the appropriate time,
I speak to you only as an individual who has been
involved in this matter for some time. Until this
time, however, the Town Council -- and it still is
I am not making an official statement -- has
purposely stayed out of the controversy. They hav
never taken a public stand as a body on the questi
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of sewers for the town, because we felt it was
not within our jurisdiction, bur rather a matter
between the Sanitary District, Whitman and Howard
the Maine Department of Environmental Protection
and now EPA. We may, however, take some action
at a later date.
Within the past three months there have been
some misleading facts and implications being
spread throughout this town which have caused somn
unnecessary concern for its residents, some of
whom will not even be served by the proposed
system. First, the Town Council and Sanitary
District are two completely distinct organizations
and I can assure you that neither one of them
has any plans whatsoever to charge those people
not served directly by the system any fee at all;
no user fee, no readiness to serve fee and no
front foot assessment or percentage thereof, whicJ
is quite very well implied in this handout as
you came in. It says various things, but at the
bottom it says, "For those properties which are
outside the 100 foot limit and have properly
functioning septic systems in the district may, at
the option of trustees, assess up to 40 percent
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of the normal user charge," which leads people
to believe, I assume, that if they lived in North
Scarborough, they might have to pay the 40 percent
fee, which is not true. If it is in the report,
the report is in error. The intended legislation,
as I understand it, is that if you live with front
footage on the sewer, that if you do live beyond
the 100 foot line, then you can and you have a
system that works,-you do not have to hook in, but
then you may be subject to the 40 percent; not if
you live in North Scarborough, 2,000 feet away fro
where the sewer is -- only if you have front
footage on where the sewer will be.
Secondly, there will be no increases in taxes
directly related to the system being installed.
Opponents have led some people to believe that
the minute the sewer is in the ground, property
taxes will -- for Scarborough will go sky-high.
This is certainly speculation at best and the
opposite may well be true. Given the fact that
our industrial potential is severely hampered
until we have the capacity to serve these new
industries, as well as some of the existing
industries such as Borden's and Humpty-Dumpty,
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which will provide a more broad base tax support
for all citizens, I'm sure you will hear and have
heard many arguments against Plan A tonight, and
I am sure aspersions will be cast upon the
character and quality of work done, not only by
Whitman and Howard and the Scarborough Sanitary
District, but also Booz, Allen and Hamilton. Well
I cannot be in complete agreement with everything
that has been said by all of these people, I
suspect - - I do think they have done an admirable
job in the past, at least, in starting along the
way and hopefully, they will continue. I suspect
that most of the public comments you hear and hav<
heard will be negative ones. Those who are againj
something always turn out in greater numbers chan
those who are in favor. I suggest to you that
this is the same vocal minority that has appeared
at every public meeting in the past three years
and their sole purpose is to stymie any further
progress. These are the same people, however,
that a few years ago were preaching that Scarborou
was a desparately polluted town and we must do
something about it immediately or our beaches
will be unsafe for swimming, the marshes would be
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polluted and people would be dying in the streets
from all the viruses that were floating around.
Now, these people are saying that theeffluent from
the plant will do the same thing. To me you can't
have it both ways. In fact, the EIS states the
coliform count is almost 15 times greater at
Higgins Beach alone than would be discharged if
the plant were built, not even considering the
diffusion that would take place 600 feet from
shore. I don't believe there are any more potent
viruses or potent sludge than there is at Higgins
Beach.
There are many areas of concern surrounding
this project, but the two expressed most often
are the location of the plant or plants and the
effect it will have on Scarborough's growth patterfr
First, the location of the plant has been explored
from every angle. South Portland does not want
our sewage. Odl Orchard does not want our sewage.
Consequently, we must then treat it ourselves and
rightfully so, I might add. Now, given that
assumption, the question of single versus multiple
plant construction seems asinine for the present
and potential users of the system. A multi-plant
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system would most definitely make the user fee
so high that it would be prohibitive, since
maintenance costs must be paid by the users are
not subject to Federal monies. Perhaps that's
what the opponents want. Not only that, but where
will these plants be located and just where would
they discharge treated effluent? Into the marshes
or into the clam flats? Perhaps the Nonesuch
River. That can reaJLly stand no more. I think
the decision is simple -- the single plant is the
most effective and economical alternative.
Second, the effect on a potential population
growth of the town has been exploited by many,
even to the extent of saying that should this
plant be built, Scarborough would turn into a
thriving metropolis of 60,000 people. This is
absurd. Where would these people work and wouldn'
the Planning Board and Town Council most certainly
takes steps to avoid this rapid growth? I think
most definitely so. The people of this town woulc
not stand for it nor would thtir public officials.
Also, opponents fail to mention that the bulk of
this 60,000 people would be occurring in areas
which are west of the Turnpike or not even plannec
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to be serviced by the sewer. I have lived in this
town all of my life and I have seen its popula-
tion go from 5,000 to its present estimated level
of ten to 10,000. I have seen these people come
from out of town with their dreams about what shou
be and should not be and then see them leave for
bigger houses, better jobs elsewhere, but believe
me, I do share the same concerns about Scarborough
because I intend to live here the rest of my
life and I want my children to grow up in the same
great town as I did. However, I do not get
extremely concerned when I read the projected
population figures for the next 20 years, if they
are right, because they represent about a two
percent compounded growth rate which I consider
a moderate pattern, and everyone, at least to my
knowledge, has agreed that we do want moderate
growth.
As I said before, I am not addressing you in
any official capacity or for any specifically
designed group of people in this town; only to
express my thoughts and concerns on the matter
and perhaps present a different perspective than
will be and has been given by others. I would,
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however, like to take the liberty of saying that
I think I speak for a good many of the people who
for one reason or another might not be present
or might not choose to speak tonight. They are
not doctors or lawyers or businessmen, they are
not owners of ocean front property and they do
not live in one particular area. They are, howevo
the people of this town that work for a living
and enjoy our beautiful beaches when they can and
enjoy living here as much as anyone who is in this
hall tonight. Chances are they live on one-half
acre or full acre lots that have received about
all the sub-surface sewage it can and every time
these people must reconstruct their system, it
costs them another $2 , 000 or $3, 000 and they don't
like it. These people are not looking to become
a part of any special interest group. They only
want a fair shake. They deserve better than what
we are offering them now. There are these hundred
of people who are not here tonight that I feel
somewhat obligated to. They were promised sewers
many years ago and, as yet, have not received
them. Please give us a chance to help them now.
Thank you.
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MR. STICKNEY: Thank you very much,
Mr. Higgins. Mr. Sidney Woodcock.
MR. SIDNEY WOODCOCK: Mr. Chairman, ladies
and gentlemen, after hearing the last two or thre«
speakers who have lived here all their lives, it
is with some trepidation that I address you this
evening because I have only been here for one
month. However, I will try. It was rather a
surprise at the last speaker because I got the
impression from him that many people in the town
are opposed to the sewer system. I only received
a copy of the report tonight, which I haven't
read obviously, because it is too long, but I have
been listening with some interest to most of the
speakers and the impression I get is that people
are in favor in general of a sewer system. In
fact, most people are so much in favor of it that
they want something better than is being proposed
in the plan here. In fact, when I read this thing
just on Figure 4.1-2 in here, it shows the pro-
posed system and it is fairly rudimentary. As I
listened to the various speakers I heard such
things as -- people saying they want a more advance
technology. We heard about the tertiary treatment
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system. We heard about the use of breaking down
the final suspended matter by ultrasonic techniques
the use of ozone to do the final disinfection.
We heard about the possibility of using the
activated sludge process,instead of using air,
using oxygen. We even had one guy who was, I think
a naturalist here, suggesting that we. should even
treat surface water. Now, that is quite a good
thing, too, but of course you have to remember
if you're going to put surface water through a
sewage treatment plant, then the excess capacity
of that plant is fantastic and the cost would go
way up, or else you would have to have some sort
of a large holding arrangement to catch the storm
water and then treat it.
I think, really, the upshot of all this is
that it comes down to cost. I get the impression
and looking at the report, such as I have seen of
it, and the various other cost figures that have bee
bandied about tonight, that this project has been
cut down to a cost, and of course now we come back
to a typical problem of a town the size of
Scarborough and that, in fact, any of these schemes
such as sewage or municipal garbage collection or
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any of these services that are provided by a
municipality, there is a scale problem. Scarbo-
rough is typical of many towns in this country
where there are a lot of little developments all
over the place. The collection of sewage from
th«»i piping through a central system costs a lot
of money because of the miles and miles and miles
of piping and pumping for the system involved,
plus the fact that when you have collected it all
together, you have nothing to treat anyway, not
when you compare a city like Chicago or New York
City or Atlanta, or something of^that type, where
you could really have a decent collection system
aid a large, economic treatment plant with sludge
digestion, fuel engines and all that sort of stuff
But I must admit that this project here worries
me in one particular area, or two areas. I don't
like the fact it's on a secondary system and I
would much prefer some tertiary treatment to this
thing that's been addressed on the viral area.
But the treatment of the sludge in this report I
think is appalling. I am going to. take one
sentence, in fact, out of context, which I read
on page IV-8, after they describe the project and
r. !
J.
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how it works and so on and so forth, it says,
"The decision of sludge disposal has not been mad<
Now, there are in other parts all sorts of
proposals as to how it might have done. We have
heard of pyrolysis. I guess, sludge digestion,
generates the methane using it to drive fuel
engines. So, again, I think it is only economical
on a large scale. I would like to ask the panel
to look at things like that, but I know one thing
darn well, and we all know, that I think the
disposal of such waste, spreading it out on land
even to a layman it is just non-acceptable. We
want something better in the sludge disposal
area. Thank you very much, gentlemen.
MR. STICKNEY: Dr. George Higgins?
DR. HIGGINS: I have nothing to add to
Dr. Richie's comments. I think I want to add one
thing. It is sort of an exciting era for
Scarborough in that I think, as a product of your
concern and sensitive consideration and investiga-
tion, Scarborough might become a positive model
for other cities, coastal cities in Maine to
model themselves after, and I think we should stri
to that.
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MR. STICKNEY: Thank you. I would like to
go through the list of speakers first. Mr. Earl
Bennett? Is there anyone else who has not spoke
who wishes to speak at this point?
MR. LARRY WILWORTH: My name is Larry Wil-
worth and I moved to Scarborough about two years
ago. I wasn't planning to speak tonight, but when
the concern about treating the virus, I thought
I might add something and some of the experiences
that I ran into in the last year. Presently I
am involved in a construction project with the
Carell (phonetic) Company to treat 15,000 gallons
of water a minute in a fish hatchery by ultra-
violet light and since there seems to be extreme
concern about virus, I wonder if you fellows have
considered -- I don't know if it's going to have
an impact on this particular project, but have
considered treatment of effluent by ultraviolet
sources. The development of the new process that
came out -- I believe Mr. Sidney Ulner (phonetic)
of Ultraviolet Purification Systems in Scarsdale,
New York has developed a system where municipal
sewage can be processed by an ultraviolet light
and thus eliminate the virus infection which a lot
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of us are concerned about. I am presently in
volved in a project where we are completely
treating the water for the Green Light Fish
Hatchery up in Ellsworth. I thought I would brinj
this to your attention so maybe it would help
you give better treatment for all of us.
MR. STICKNEY: Thank you very much. Miss Lee,
do you wish to speak?
MS. VALERIE LEE: I think after the discussicjn
this evening we have all become quite aware of the
potential hazards that viruses could be in the
effluents and I also think what has been pointed
out is the fact that biological plants are subject
to failures and one thing that struck me when I
read the Environmental Impact Statement is the
fact that it did not consider the probability that
failure would happen; how many times it would
happen; after it did happen, what would the effect
be of dispersing untreated effluent in the waters.
Would it be a health hazard to the beaches; what
economic consequences would occur? All of that
hadn't been considered. I think in light of these
facts, it is essential that we are able to predict
where the effluent goes and in what concentration
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the effluent is when it reaches, for instance,
say the beaches or other important points on the
shore. I am a grad student in Civil Engineering,
Division of Water Resources at M.I.T., and I gave
to a Professor of mine the proposed outfall study
presented by Whitman and Howard and asked him to
review the study, and he sent me this letter with
his comments and I will read it:
"At your request I reviewed the report
entitled "Optimum Location of Proposed Prouts Nee*
Ocean Outfall," which was prepared by Whitman and
Howard, Incorporated, March 1974. My review is fo
cused on the assessment of pollutant concentration
levels resulting from the construction and opera-
tion of the proposed outfall structure. I have th
following comments in this regard:
1. Although I have not repeated the detailed
calculations of the dilution adduced by the
discharge, the Finding D-l in the report, it
appears that the analysis presented in the report
is adequate for determining this fixing and is
dependent on the depth of water in which the out-
fall is located than on the discharge port diamete
However, the report does not present any true
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optimization of the outfall depth or port diameter
with respect to cost or potential environmental
impact.
2. I was not able to evaluate the technique
used to estimate the subsequent dilution due to
dispersion, the Finding D-2, because of the lack
of detail in the report. However, I do not believe
that the information provided by the troll drift
bottle and current meter studies are sufficient
to make an estimate of effluent dispersion beyond
the initial jet mixture range, regardless of what
technique is used. In particular, the spatial and
temporal variations in the current regime over a.
much larger area will be required for such an
assessment. Alternatively, an analog field measurs
ment technique, such as a dye release, could be
used to actually observe the transport and dilutioi
of an effluent released at the proposed outfall
site. Without such additional studies, shore line
values of pullutant concentrations cannot be
estimated. I believe that the report recognizes
this limitation implicitly inasmuch as the calcu-
lated values of D-2 are not used in the final
evaluation of the proposed design.
B. P. A. REPORTING ASSOCIATES. INC.
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Please let me know if I can be of any further
assistance in this regard."
I would like to mention that Dr. Keith
Stolsenbachwas the person who wrote this letter
to me and he is a specialist in current studies
and dispersion and dilution of effluent. I think
it is clear from the comments that Dr. Stolsenbach
has made that we do have to do further studies to
find out where the effluent is going and this is
really important because, first of all, there
might be a plant failure. We don't know what the
probability of that is going to be, and just re-
viewing the literature, I went to the library last
night and read a number of engineering journals,
and it was apparent that biological systems are
subject to failure and they are frequent and
uncontrolable. There are no failsafe mechanisms
from stopping somebody pouring toxic materials dow
the drain.
Thirdly, Federal guidelines state that
technical alternatives related to different de-
signs of the proposed action must be considered
in the Environmental Impact Statement, and I think
the Environmental Impact Statement before you
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doesn't do this. We have to weigh the different
positions of outfall. We have to consider how
long we want the outfall to be and we have to
weigh the different environmental, impacts of
these permutations and this hasn't been presented
in the outfall study, and in the Environmental
Impact Study as well.
In addition, I would just like to say that
I don't believe the Environmental Impact State-
ment really evaluates the potential hazards to
the biota and I think the lobsterman pretty well
summarized what I think about the issue, and also
what happens when we have residual chlorine in
the water. That really hasn't been considered.
And just on another vein, I think that Mr. Higgins
brought up an interesting point and another lady
who got up and talked about West Scarborough and
the possibility of being taxed or assessed for
the sewer, and it is a question in the report be-
cause it does state for those properties which are
outside the 100 foot limit and have properly
functioning septic systems, the District may at \
the option of the Board of Trustees, assess up
to 40 percent of the normal user charges. So,
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whether this is incorrect or correct at this
point, I don't know, but it certainly must be
clarified. Thank you.
MR. STICKNEY: Thank you. Any questions?
Comments? Is there anybody else who hasn't spokei
MR. CLARKE LIBBEY: My name is Clarke Libbey ,
I won't need the microphone for what I've got to
ask. Is there anything in your plan that is goin ;
to tell how much electric power is going to be in
this plant that is proposed for Prouts Neck?
MR. STICKNEY: Yes, sir. We do have the
power figures, a range of power figures, I believo
MR. LIBBEY: Is there a plan for an auxiliary
generator to take care of it in case of a power
failure?
MR. STICKNEY: Yes, sir. A plant must be
able to perform, I believe, at the level of
primary treatment at all times with or without.
MR. LIBBEY: That's included in the cost of
those plants?
MR. STICKNEY: It would be inherent in the
design, yes, sir.
Anyone else who hasn't spoken who would like
to speak? Okay, Mr, Higgins, if you have somethin
	'	
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new to add, fine. I hope you recognize that
we are going to objectively weigh this as best
we can, everything that has been presented and we
recognize that there are degrees of agreement or
disagreement on each, so I hope you will be addinj;
new information.
MR. HIGGINS: I want to thank you for being
here and I think you have done an admirable job
sitting here for three and a half hours. The only
thing I want to say is the point was brought up
that maybe I am not in favor of the best treatment
possible, and that is not true and I don't think
it is true of anybody in this hall tonight. Every
body wants the best practical treatment, but on
the one hand testimony brought in that the figures
that have been presented are not accurate, they
are excessive, they are too high; and on the other
hand, there are those who say, you know, we are
not providing the best practical treatment and
it will cost more, I assume, to get tertiary
treatment, or it always ha* anyway, than secondary
treatment. So, you have to balance one against
the other, and if we can get tertiary treatment
for the same price, or cheaper, or maybe just a
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little bit more, I would be more in favor of it
than anybody else here, and I'm sure the members
of the Sanitary District would be more in favor
of it than anybody here. I just want to make than
clear, that there isn't anybody here who doesn't
want -- that stuff that's coming out, the effluenl:
does not want good materials. Thank you.
MR. STICKNEY: Mr. Googans?
MR. GOOGANS: I don't wish to speak, but we
have three members here from the Department of
Marine; Resources and they are the gentlemen who
dictate the opening and closing of our rivers,
especially Mr. Hearst here, and I think we should
hear a statement from him, one way or the other,
of the State's opinion, being at the hearing. They
are the ones who close our rivers and so^forth.
MR. STICKNEY: I would leave that to
Mr. Hearst. I assure you that we do work very
closely with his division -- the state and the
Federal sectors do before our plants are approved.
Do you wish to make a statement?
MR. HEARST: I really can't comment.
MR. STICKNEY: Okay. I believe that, A1, you
wished to make a comment at this point?
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MR. FARKUS: I would just like to express
on behalf of the contractor our appreciation for
your testimony; much of it was thoughtful and
a lot of new information. We will do our best
to respond to the issues that have been raised
here. I am confident that, while some of you may
not feel the Impact Statement in the end will be
good, that it will have been improved by virtue
of your participation. Thank you.
MR. STICICNEY: Thank you very much. We do
have some copies of the EIS still available at
the back of the room, if you haven't had a chance
to get your own. The hearing is closed.
(Whereupon, the hearing closed at 10:10 p.m.,
January 29, 1976.)
*****************
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CERTIFICATE
I, MELVIN T. PHIPPIN, Stenomask Reporter, do
hereby certify that the foregoing transcript,
pages 1 through 136 inclusive, was taken by me
by Stenomask and thereafter under my direction
reduced to typewriting and is a true record of the
testimony of the proceedings to the best of my
ability.
Dated at Boston, Massachusetts, this
day of February, 1976.
MELVIN T. PHIPPIN
Stenomask Reporter

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SECTION IV
EPA's RESPONSE TO COMMENTS ON
THE SUPPLEMENT TO THE DRAFT EIS
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o
COMMENTATOR
RESIDENTS
ALTERNATIVES |
DISINFECTION |
3
73
O
Pm
CO
H
3
3
P
b
P
A
USER COST J
CONSTRUCTION
IMPACTS
FOP. GROWTH & I
MANAGEMENT I
NON-POINT SOURCE1
1 POLLUTION 1
ARCHEOLOGICAL
1 IMPACT
IMPACT ON CLAM
RESOURCES
GEOHYDROLOGY J
INFILTRATION
TREATMENT
PLANT RELIABILITY
IMPACT ON
MARSHES
OTHER
Mrs. L. Lee
•




a








Mr. J. Lee
*


•

«








Mr. C. Carver








0





Mr. H. Warren
•













Mr. J. Tarbell
0













Ms. R. Warren
•


0




0



0

Mr. W. Brooks
«




e
»

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f

Mr. C. Goodall














Mr. B. Gray
6


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Mr. H. Wintersteen














Local Gov't














_Platin in Board
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Town nminr_-n
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RPnna













RELATIONSHIP TO CZM. PLANS
1ta±e. Gmf'.t.














Mar-ino RpsnnrfPS
a





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.Maine Historic Comm.













NO COMMENT
Federal Gov't





























TVopt- nf rrnmoi-cp













RELATIONSHIP TO CDM PLANS
Dept. of Interior













PBD7IEE ASSISTANCE TO EPA
Coastal Env. Assoc.
«
#


«



0



9

Whitman & Howard
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1. Alternatives
One of the major comments with respect to the alternatives
evaluation was the vocal support for Alternative F, the full trans-
fer of Scarborough's wastewater to South Portland. EPA's response
to comments in Section I discusses the alternatives evaluated in
the Draft and Supplemental Draft EIS. This criteria utilized to
select alternatives are included in Chapter III of the Final EIS.
3.	User Costs
EPA received several comments in regard to project costs,
user charges, etc. Most comments criticized the Draft EIS and
Supplement Report for not providing sufficient information on user
costs. The Final EIS provides a detail breakdown of individual
costs in Chapter Fbur- At this stage of the project design, these
cost estimates represent the most up-to-date projections available.
The Final EIS states that these user cost projections could
vary depending on the number of users and the cost of financing
the non-eligible portions of the projects.
4.	Construction Impacts
EPA received comments on the potential adverse impacts due to
construction with respect to Alternative A, the Prout's Neck altern-
ative. The concern was over constructing the ocean outfall and
the treatment plant in a coastal area.
Since the supplement report was distributed EPA has recommended
Alternative G. This alternative represents a reduction of possible
coastal impacts from Alternative A. The primary and secondary im-
pacts of the proposed action are discussed in Chapter Five of the
Final EIS.
5.	Population and Growth Management
Throughout this EIS process many citizens were concerned over
the inadequate growth management plan for the Town of Scarborough.
Many individuals have commented that the Town does not have a
unified growth strategy. Therefore, a sewer facility could not
be designed if a design population has not been determined.
Subsequent to the release of the supplement report EPA re-
quested the Town to develop a growth scenario which best repre-
sented the long-term goals for the community.
Letters have been included in the Final EIS which reflect the
Town's decision as to a growth scenario. The proposed facilities
have been sized to adequately serve the needs of the moderate
403
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growth scenario discussed in the Final EIS. It will be the re-
sponsibility of the Town to implement the planning recommendations
in the Final EIS. It has not been the policy of EPA to require
adoption of growth management plans only where it appears that
the proposed project will violate or degradate an environmental
statute. In the case of Scarborough, it will be important not
only to revise and update the comprehensive plan but also to en-
force existing and future ordinances.
6.	Non»-Point Sources of Pollution
EPA's response to the comments on non-point sources of pol-
lution is contained in the section on responses to the Draft EIS.
7.	Impacts on Clam Resources
EPA received comments from several individuals and the Maine
Department of Marine Resources. EPA concurs with these comments
and the need to improve the water quality of the estuary. The
anticipated benefits of improved water quality are discussed in
the Final EIS.
8.	Impacts on the Marshes
Several individuals expressed concern with the project's im-
pact on the environmentally sensitive areas in Scarborough.
EPA has met with both the Dept. of Marine Resources and the
U.S. Fish and Wildlife Service to determine the possibility of
impacting on these natural areas. The Final EIS discusses the
importance of these sensitive areas and recommends measures to
the Town to reduce or avoid possible adverse impacts on the marsh-
lands. It is not anticipated that the proposed project will ad-
versely effect existing natural resource areas. In an effort to
avoid construction impacts, mitigating measures are presented and
long-term land use controls are discussed to afford long range
preservation of these natural areas.
404
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SECTION V
COMMENTS SUBMITTED TO EPA ON
THE SUPPLEMENT TO THE DRAFT EIS
405
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Sfaum d)te#tv\ 0^ice
ScaiSaraucffo, 97laute 04074
Scarborough, Maine
November 29,1976
U.S. Environmental
Protection Agency-
Region 1
Boston, Mass 02203
Gentlemen:
I am enclosing for your recoras a copy oi an
environmental impact statement which was
approved and adopted by the Scarborough Town Council
at its regular meeting of November 17,1976.
Yours very truly,

(j><
Norman E. Morse
Town Clerk
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To: U. S. Environmental Protection Agency
From: Scarborough Town Council
Date: November 17, 1976
He; Environmental Impact Statement
The Scarborough Town Council wishes to go on record as
favoring a low to moderate growth rate, based on 80-125
units per year or approx. 3# growth in valuation.
The Council also feels that the Planning Board is making
adequade progress with its Comprehensive Plan at this time.
Realizing that growth is a primary concern of most citizens,
it is the belief of the Town Council that with the co-opera-
tion of all Town departments, low to moderate' growth can
be maintained, regardless qf which sew©r alternative is
finally selected.
As presented, Alt. P (full*transfer to South Portland)
appears to be the most 4estateable solution; however,, there
are many practical matters^uch as; time. delays, admini-
strative control, infiltra$^n,%and Tiser-rate structure
which the Council feels would put the Scarborough Sanitary
District in a most ilifion.
If these conoerns can be properly dealt with and resolved
within a reasonable time span Alt • F is felt to be a
desireable e<)lurtio|.. ^f/vhj&wey^
insurmountable, then the; Sc&rboroughTown Council endorses
Alt. A as the most feasible solution.to service those areas
indicated in the State's"consent order?
408
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FEB 24 B
TO
Planner/Engineer
February 22, 1977
Mrs. Karen Kelly-
United States Environmental Protection Agency
Region I
John F. Kennedy Federal Building
Government Center
Boston, Mass. 02203
Sear Karen,
Enclosed please find a copy of the community
goals, adopted by the Scarborough Planning Board
and the Scarborough Town Council, as you requested
per our telephone conversation this morning.
If I can be of further assistance do not
hesitate to call.
Very truly yours
Town Planner/Engineer
CJA/pb
Enc.
Greater Portland's Oldest Organized Community
409
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town or 'Scarborough
"• «'f»»e
SCARBOROUGH MAIN# 64074
Planner/Engineer
Janeery 3#1977
Soaxfeoroaeh Town Council
Munisipal Office Building
Soarterau^ Maine 0U0?2*
Ceeneillorai
Fonrarded fox jowr oooaideration an goals that the 8oa*boreagi
Planning Board ha© adeptod* Sh» Board is Mtinly engaged An the update
«f the 196b Coapzahoasivo Tien, and it is Intended to itowUw that
deeusamt jja MA a vay that the goals ny realistically to attained*
Sutetential effort has teea expended in formulating this etateasent
of goals* An attemptwas mada to draw qpon all available sosovffoes (seo
fable A) in order to draft a statement Kspreaentativs of the vanta and
needs of th® wmmmity m a vhale. Saphaaia vas placed upon oittssn
participation® resulting in th* "neighborhood fix© Baaa* testings oendosted
in dttgpst* sod tha amotion of tho AA Hoe PlanningCosaoittee, whieh has
sateittsd its reona—irfatlona to tho Pinning Board and will shortly
bo dissolved, Xn additian9 tho result of tho CoHsunity Attitudes ausvsy
and tha Conaasaity AmlojtBSUt Study Conaitts* Report vsss relied vpm aa
velaatle statements af jmblio needs sad wants* Snpafe frsa gnftlie and
private sasnittsss and organisations» Kmieipal officials and department®
eaaplotsd tha prooodur® of gsal founlatian*
$he goals foanalatod safloot in tesad tasaa tho variety of problems
pososived by tha Publis^ tha ASainiat»atl
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?ag® 2%
A* Capital Xapxorapa&t frco&em
B» ffistwih Hanageaaat
Th« growth noatflesniKft eoBpoaaat will psa&afcly t» the «oot ttf&Uralt
aapoot of tho plan to atwaaaafnny lavtOMmt# awl wiU lifc&ly fea a
aajo* faotos in Attaining tbo detained pwth ratOo Ttaa Planning Soaxd
has ooodttBtaft intartiawa with sanieipal 
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n» miwiag to wwi m m wwftt—ffiU
f© inflmaoa fh» «arit»*&jr fafflalagmt «f *&» eesanity 1tam&
tfa® ttylvamtoMm «P $Uas «bA $»p&B8f th» mSmmmeA aarit mib>
timMm of grirlgfttag w&Samm*i w& ffae £«aa&etieft sx& aAopUea «ff
asw assnlailflBs, j&ajss, anfi	la wies M mrtirtitln end satanoa
tfca «aa&ity «? Xiffl svatttfftft ia lite Vta» «? Saasfcewo#*
fU f*U&mg am swepaaM as
1» 9»88«m «h* pvesttsl ofeaimafas o$ the eosmityf:
2* Bfatwfaitn a wfca«l» gwwtt »l» (80*48$ jwiimm w&te
P9»tM*h
3« Woamamp emuonUik an* intaetsial Aewslepsisa* ft teeafea
«bt wtaMt
b«	pmmftn, im& afent© f®U*M£
fisoal m«oaf3»a®ats ead
It® fsoaets a «tiv3*% of &0iU$i«a*
412
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TABLE A
Hoaourcea for Input tc thf Comprehensive Plan
Resource
Contact
Made
Response
Received
Scarborough Sanitary District
Scarborough Public Library
Board of Trustees
Permanent School Building Committee
Scarborough Conservation Commission
Recreation Advisory Committee
Economic Advisory Committee
Historical Society
Scarborough Board of Trade
School Board
Town Council
Department of Publie Works
Fire Department
Police Department
Higgins Beach Association
Scarborough Concerned Citiaens
Rotary Club
Lions Cltib
Jay Cees
Prouts Association
Seaiborough Tax payers Association
x
X
X
X
'¦ *
X
X
X
*
X
X
X
X
;Xr:
*
x
X
X
X
X
X
¦<%'
X
X
413
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Community Attitudes Survey
Community Development Study Committee
Meetings
Neighborhood Fire Barn Meetings
Planning Board Meetings & Hearings
414
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SOUTH PORTLAND
AU AMERICA CITY
City of South Portland\ Maine
All America City

January 5, 1977
Mr. Alvin G. Keene, Superintendent
Scarborough Sanitary District
P. 0. Box 302
Scarborough, Maine 04074
Dear Al:
In response to your letter of November requesting acceptance of Scarborough's
sewage, and treatment through our Waterman Drive facility, I have reviewed your
proposal with the Council at a workshop held on December 27.
The Council at their regular scheduled meeting on January 3, 1977 voted to
advise the Scarborough Sanitary District that we are unable to consider acceptance
of your sewage at this time.
Their decision was based on an opinion provided by our engineers, Fay, Spofford
§ Thorndike, Boston. The prevailing rates of infiltration/inflow will exceed the
initial design capacity of the treatment plant. The rehabilitation of our system
is essential to reducing the infiltration inflow rate immediately by 63 per cent.
However, the plant will not be on line until early 1978, and our engineers
recommend a full year of operation before any consideration be given to expanding
the sewer system.
Based on this analysis, your request for immediate consideration must be
denied.
RES:pvj
cc: Paul Frinsko, Esquire
Henry Steinfeld, Corporation Counsel
William G. Dyer, Fay, Spofford § Thorndike, Inc.
Roy Spugnardi, City Engineer
Ronald £7 Stewart'
City Manager
415
RONALD E. STEWART, CITY MANAGER • 25 COTTAGE ROAD, SOUTH PORTLAND • 04106
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COMMENTS OF
William J. Brookes
Higgins Beach
Scarborough, Maine
by his Attorney
Clifford H. Goodall
Lund and Goodall
15 Western Avenue
Augusta, Maine 04330
Regarding
AN ANALYSIS OF THE ALTERNATIVE SYSTEMS FOR WASTEWATER COLLECTION
AND TREATMENT IN SCARBOROUGH, MAINE ON OCTOBER 30, 1976.
SUPPLEMENT TO THE DRAFT
ENVIRONMENTAL IMPACT STATEMENT OF
DECEMBER 1975
Submitted to the
ENVIRONMENTAL PROTECTION AGENCY, REGION I
BOSTON, MASSACHUSETTS
November 19, 1976
416
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The basic conclusion of these comments are as follows:
1.	Both the October, 1976 Supplement and the December,
1975 Environmental Impact Statement fail to recognize and
properly value the national, regional and statewide environmental
importances of the saltwater marshes in the Town of Scarborough;
2.	Both the original E.I.S. and its Supplement fail to
adequately consider the economic importances of the marshes;
3.	Both fail to adequately consider the potential
destruction of the marshes that will occur if the secondary
impact of population growth and distribution is not regulated;
4.	Both fail to adequately consider the land use
regulations that are available to the Federal, State and local
governments;
5.	The discussion of alternatives in the October, 1976
Supplement is not exhaustive or based on adequate data; and
6.	The Environmental Protection Agency, Region I (E.P.A.),
the Maine Department of Environmental Protection (D.E.P.), the
Scarborough Sanitary District and Scarborough Municipal Government
must severally and independently exercise their discretionary
statutory powers if the national, state and local interests are
to be adequately protected.
417
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I
NATIONAL, REGIONAL/ STATE AND LOCAL INTEREST
To date the discussions, reports and plans for the
Scarborough treatment system has been couched in provincial
terms in that the major concerns have been the effect this
necessary project will have on the residents of Scarborough,
its government and its costs to the users. These discussions
and the E.I.S. and it Supplement have also failed to seriously
consider the national, regional and state implications, heeds
and policies. The localized orientation is the root cause of
the major weaknesses of the E.I.S. and the planning which has
occurred to date. It is a shortcoming of the Sanitary District
and many of the local residents. Both the D.E.P. and the E.P.A.
appear to be taking a more expansive view of the importance of the
marshes.
The State of Maine has only 16,000 acres of saltwater marshes.
This relatively limited amount of marsh land is in dramatic
contrast to the fisheries habitat that exists in the fragile
environment of Maine1s coastal waters and the George's Bank and
Continental Shelf. When one considers the limited amount of
remaining productive salt marshes in New England and the importance
of the oceans for the supply of food to present and future
generations, the importance of the Scarborough marshes are clearly
understood.
418
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Scarborough has within its boundaries 2,700 acres of
marsh lands which equals sixteen and eight tenths percent (16.8%)
of the salt marshes in Maine. More importantly it is the largest
and most important saltwater marsh on the entire Maine coast.
These saltwater marshes are so important nationally that
they are included in and are a major part of the Rachel Carson
National Wildlife Refuge.
Within the State of Maine they have been recognized by the
Department of Fish and Wildlife as an important wildlife habitat,
a feeding and resting area for waterfowl on the Atlantic Flyway
because they offer an excellent habitat and opportunity for the
management of Canadian Geese, Snow Geese, Black Ducks and other
waterfowl and shore birds.
In short, the Scarborough marshes are an important State
and national asset. Because of this, the National Wildlife
Federation, Environmental Defense Fund and others have requested
the opportunity to comment on the E.I.S.
The national and state interest must not be ignored and
they create an obligation on the E.P.A. and D.E.P. to actively
protect them. The fact that the E.P.A. has required an E.I.S.
and that the D.E.P. has forced the town to act through the threat
of enforcement actions is encouraging. In order to be adequate
the E.I.S. must place these interests and the supporting data in
a priority position in the decision-making process.
419
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Because of these shortcomings, the E.I.S. with Supplement
fails to satisfy the requirements of guidelines of the Council
on Environmental Quality Guidelines for the Protection of
Environmental Impact Statements, 40 CFR Part 1500 (Aug. 1, 1973),
and in particular the purpose and authority sections (§1500.1),
the policy section (§1500.2) and specifically Section 1500.8(3)(i):
"This requires agencies to assess the positive
and negative affects of both the national and
international environment."
and Section 1500.8(6):
"The relationship between local short-term
uses of man's environment and the maintenance
and enhancement of long-term productivity."
A careful review of both the E.I.S. and Supplement suggests
that the writers of these documents were not cognizant of the
requirements of specific and clearly stated criteria of
40 CFR Part 6, 40FR 16814 (Apr. 14, 1975) E.P.A., Preparation
of Environmental Impact Statements in that the preliminary
commentary for these regulations by Russell E. Train stresses
the importance of protecting wildlife habitat, food production
and commercial harvesting of fish for future generations. In
particular, the E.I.S. and Supplement fail to adequately consider
the criteria of §6.214 (b)(2) relating to direct or induced
impacts on floodplains which clearly includes the Scarborough
marshes and they also fail to deal with the criteria of §6.304 (e)
dealing with the "relationship between local short-term uses of
420
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man's environment and the maintenance and enhancement of long-
term productivity", (emphasis added)
II
ECONOMIC IMPACT
The E.I.S. all but ignored the direct economic value and
primary impact of the saltwater marsh resrouces except for a
footnote on page 11-49 and the Supplement completely ignores it
when evaluating the alternatives. This is a major inadequacy
because it ignores a multimillion dollar resource. The information
could have been easily obtained and is outlined below.
Both the E.I.S. and Supplement are orientated to middle
to upper middle class residential uses at the expense of protecting
and enhancing the natural and economic resources of the area. This
is clearly in contrast to both E.P.A. and C.E.Q. guidelines and
policies.
The Department of Marine Resources is concerned about the
potential economic importance of the clam flats that are contained
in these wetlands. According to John W. Hurst, Jr. of that
Department's Research Station in Boothbay Harbor, these clam flats
have the capacity of being managed to produce an average yearly
sustained yield of 10,000 bushels of clams. Each bushel currently
has about a $20.00 per bushel landed value which, therefore,
would provide a $200,000.00 annual value to clams dug in these
flats at current landed value rates. This potential sustained
421
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yield is sufficient to support three or four commercial handlers
and 25 to 50 people harvesting the clams depending on the season.
The important economic point is that these Scarborough clam flats
are able to produce steamers which are worth thirty times the
landed value or $6,000,000.00. These flats also produce fryers
which are worth ten to fifteen times the landed value or
$3,000,000.00. According to Hurst, the value of this industry
to the area would be approximately fifteen times the landed value
of the harvest or $3,000,000.00.
None of these values are now being realized because the
clam flats and depuration plants are closed because of the
extensive and massive pollution that exists in the Scarborough
marshes. During this summer the Department of Marine Resources'
test showed clams containing a count of 160,000+ of total coliforms
M.P.N, and the same for fecal coliforms M.P.N. These same tests
show that the water in these areas have a total coliform count
of over 11,000 M.P.N, which is the limit of their testing equipment
and fecal coliform bacteria count of up to 430 M.P.N. State law
(38 M.R.S.A. §364) established a water classification standard
for these waters that states "the median numbers of coliform
bacteria in any series of samples representative of water in the
shellfish growing area shall not be in excess of 700 per 100
milliliters, nor shall more than 10% of the samples exceed 2,300
coliform bacteria per 100 milliliters. The median numbers of
fecal coliform bacteria in any series of samples representative
of waters in the shellfish growing area shall not be in excess of
422
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150 per 100 milliliters	This is clear evidence of the
extent of pollution in the shellfish or clam flat areas. These
standards are currently being reviewed by the D.E.P. and the E.P.A.
proposes that they be changed to a median of 14/100 ml and 10%
of the sample be L 43/100 ml in shellfish harvesting waters in
order to meet the 1983 swimmable-fishable goal. Other areas in
the marshes have waters that have fecal coliform counts of up to
4600 M.P.N. The results are from nonpoint source studies begun
in March 1976 and the high readings were found in samples collected
August 12, September 27 and November 4, 1976.
These polluted waters flow by three of the four public
beaches in Scarborough (Pine Point, Prouts Neck and Higgins
Beach) but there are no tests to show definite pollution of these
recreational waters, but their pollution and threat to health is
obvious.
Not only are the pollution criteria of Maine's statutes
violated, but also all other objective and measurable standards
are exceeded especially in the case of shellfish harvesting
waters and recreation areas. These constitute a clear public
health threat. See for example:
Coastal Zone Pollution Management, Proceedings of
the Symposium, sponsored by Southeast Region
Environmental Protection Agency and College of
Engineering, Clemson University, Charleston,
South Carolina, February 21-22, 1972. p. 282
423
LUND AND GOODALL - ATTORNEYS AT LAW ¦ 15 WESTERN AVENUE - AUGUSTA, MAINE 04330
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Quality Criteria for Water, U.S. Environmental
Protection Agency, Washington, D.C. 20460.,
"Fecal Coliform Bacteria", 79-100.
Technical Bulletin EPA 430/9-74-010, Protection
of Shellfish Waters, July 1974, 19 p. U.S.
Environmental Protection Agency, Office of
Water Program Operations, Washington, D.C. 20460.
See also the comments submitted by Doctors Lord, et al
at the public hearing on the original draft E.I.S. in this matter.
The economic impact is not limited just to shellfish and
tourist industries. The pollution also has an economic impact on
property values especially in the Higgins Beach and Prouts Neck
area. The E.I.S. and Supplement does not consider this impact.
The failure of the E.I.S. and Supplement clearly cause them
to not meet the criteria of 40 CRF Part 6 (Apr. 14, 1975)
§6.302(4)(e) and 40 CFR Part 1500 (Aug. 1, 1973) §1500.8(a)(6).
Ill
SECONDARY IMPACT
Both the E.P.A. and C.E.Q. guidelines require serious
consideration of the secondary impact of projects in all E.I.S.'s.
40 CFR Part 1500 (Aug. 1, 1973) states at §1500.8 (3) (ii):
424
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"(ii) Secondary or indirect, as well as primary
or direct, consequences for the environment should
be included in the analysis. Many major Federal
actions, in particular those that involve the con-
struction or licensing of infrastructure investments
(e.g., highways, airports, sewer systems, water
resource projects, etc.), stimulate or induce
secondary effects in the form of associated invest-
ments and changed patterns of social and economic
activities. Such secondary effects, through their
impacts on existing community facilities and
activities, through inducing new facilities and
activities, or through changes in natural conditions,
may often be even more substantial than the primary
effects of the original action itself. For example,
the effects of the proposed action on population
and growth may be among the more significant secondary
effects. Such population and growth impacts should be
estimated if expected to be significant (using data
identified as indicated in §1500.8(a)(1) and an
assessment made of the effect of any possible change
in population patterns or growth upon the resource
base, including land use, water and public services,
of the area in question." (emphasis added)
More specific E.P.A. criteria are found in 40 CFR Part 6
(Apr. 14, 1975) at §6.304 (c) (3).
E.P.A.'s own publications specifically address this problem
in technical bulletin E.P.A.-600/5-75-002, January 1975 "Secondary
Impacts of Transportation and Wastewater Investments: Review
and Bibliography".
This bulletin at page 22 contains the following summary:
C. General Land Use Effects
General land use secondary effects of sewer
investments identified in the literature are
summarized below.
The increased attractiveness of sewered
areas encourages land speculation and increased
real estate values (111-06). Although it is
425
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difficult to isolate sewer-related increases,
a doubling in value seems common, while three-,
four-, and five-fold increases in value are
not exceptional (13).
Sewer-inspired development is often of the
dispersed sprawl type with deleterious effects
on available level of public services to
residents of the newly developed areas, on
per capita public services in the region as
a whole, and/or on tax burdens to residents
of other areas in the region (111-10).
A potential physical effect of sewerage
investments is decreased water quality through
storm water runoff in newly developed areas (14).
Specific mechanisms which provide strong
encouragement for development of newly sewered
areas include:
Interceptor sewers servicing undeveloped or
partially developed land areas subsidize
developers by providing relatively low cost
sewer treatment (111-10). The subsidy encourages
moderately-priced housing, as opposed to higher
priced housing in unsewered areas (15).
New sewers increase the density of possible
development and thus the potential economic "rent"
(and development profit) per unit of land to the
owner or developer (III-09).
New sewerage is often partially financed by
revenue bonds to be repaid through tap-in and
service charges. Local authorities tend to
encourage tap-ins through easy rezoning in order
to stimulate revenues while the market is strong
(111-10). This provides another stimulus for
development at high densities.
Two other external factors help cause sewer
impacts. The availability of federal funds for
capital costs makes over-capacity sewers and
regional sewerage systems more attractive to
local decision-makers. In the case of over-
capacity, local planners again tend to encourage
tap-ins in order to quickly repay their share of
capital costs. And because regional systems with
a central waste treatment plant often require
426
LUND AND GOODALL - ATTORNEYS AT LAW . 15 WESTERN AVENUE ¦ AUGUSTA, MAINE 04330
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long interceptor lines through undeveloped
areas, they encourage development of open
space (111-03).
An important qualification is that lack
of public sewer investments does not
necessarily stop further development. If
developmental pressures are intense, private
sewerage systems are financially feasible,
not only in the form of individual septic
tanks, but also as package treatment plants.
Thus development can continue unchecked
without public investment in sewer facilities.
But the form, intensity, and rate of develop-
ment may be significantly altered.
The E.I.S. and Supplement ignore this document, its
conclusions, and modeling techniques for measuring the impacts.
This oversight is unbelievable considering the requirements of
the legal criteria and the fact that the E.P.A. published the
document and paid Booz, Allen and Hamilton to prepare the E.I.S.
and Supplement.
We request that the E.I.S. and Supplement again be rejected
until they require evaluations done for each of the viable
alternatives.
The above quoted summary qualifies itself in the last
paragraph by saying that growth may still come with septic tanks,
etc. In Scarborough almost all of the land is not suitable for
septic tanks and package plants. Most of the land to be sewered
are peninsulars projecting into the marshes and ocean and are
not much more than an upland interface between sections of the
marsh, the confluence of river systems and the ocean. Also the
town is located well within the Greater Portland Urban Area and
427
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has experienced a recent explosive growth.
A new sewer system will trigger a land development explosion
that will destroy the marshes permanently if land uses are not
seriously and conclusively controlled. This threat is obvious
and inevitable no matter which alternative system is chosen.
The E.I.S., all E.P.A. and D.E.P. grants and licenses must address
this issue separately otherwise the new sewer system will destroy
the very environment it is designed to protect. We cannot stress
this point strongly enough in these comments. The present E.I.S.
and Supplement is a farce in terms of this crucial issue.
IV
LAND USE PLANS, POLICIES AND CONTROLS
Both the E.I.S. and Supplement are required to consider
"the goals and objectives of approved or proposed Federal,
regional, State and local land use plans, policies and controls
for the project area should be included in the E.I.S." 40 CFR
Part 6 (Apr. 14, 1975) at §6.304 (c) (3).
The E.I.S. fails to consider State policy as contained in
statutes and administrative agency policy and goals particularly
as they relate to shellfish and the Department of Marine Resources
and wildlife and the Department of Fish and Game.
The E.I.S. and Supplement ignore the Greater Portland Council
of Governments' regional 208 planning which is currently taking
place.
There is in addition Federal policy as it relates to the
Rachel Carson National Wildlife Refuge.
428
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Maine also has land use controls including the Site
Location Act, 30 M.R.S.A. §481 et seq.
The E.I.S. and Supplement does not discuss the explicit
and implicit controls that are available to both State and
Federal agencies. For example, Region I, E.P.A. conditional
201 grant for New Shoreham, Rhode Island (E.P.A. Project
No. C 440074-01) with the following special conditions:
7. Wetlands
The Town shall not permit any person to
discharge wastewater into any collection line,
lateral sewer, interceptor or other means of
conveying wastewater to the treatment plant if
such wastewater originates from any building,
facility or other manner of construction which
is hereafter erected or otherwise placed, in
whole in part, upon land which is a wetland
area within the means of G.L.R.I. Tit. 2,
§2-1-13 and §2-1-14 (Supp. 1974). This
condition is deemed to be for the protection
of wetland areas and shall constitute a
bilateral agreement between EPA and the Town
which may be enforced by any person who has
an interest in the protection of such wetland
areas, including year-round and part-time
residents of Block Island.
That condition in effect protects wetlands by prohibiting
construction within one hundred and fifty feet (150') of any
high or low mark in the project area. See Appendix A for a
copy of this related section of the Rhode Island law.
Both the E.P.A. and D.E.P. should consider creating such
a buffer zone in Scarborough in order to protect the marshes
from the inevitable secondary impact of this project.
429
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V
ALTERNATIVES OUTLINED IN E.I.S. SUPPLEMENT
Any direct discharge into the marshes is unacceptable.
In this we concur with the comments of John Hurst of the Maine
Department of Marine Resources and the concerns of the D.E.P.
Hence, Alternative C should be eliminated given the real value
of the marshes discussed in these comments.
Alternative A has impacts that are also unacceptable regarding
the beaches and clam flats and secondary growth.
Alternative F, of those presented, is the most acceptable
and now appears to be administratively acceptable, more so than
suggested in the E.I.S. Supplement. See Appendix B. It is our
understanding that both the South Portland City Council and the
Scarborough Sanitary District see this as a favorable arrangement.
The E.I.S. Supplement suggests that F could cause delay.
However, both Alternative A and C could stimulate litigation and
delay that would exceed any administrative delay of F.
The infiltration problems with the South Portland plant could
cause delay, but the E.I.S. must consider the "feasible alternatives
to any proposed action, including taking no action or postponing
action" (emphasis added) 40 CFR Part 6 (Apr. 14, 1975) at §6.304(b).
In addition it must consider "trade-offs between short-term
environmental gains at the expense of long-term gains..." at
§6.304(e). Clearly the Supplement must reconsider both postponement
along with long-term gains of Alternative F and the protection of
430
LUND AND GOODALL - ATTORNEYS AT LAW - 15 WESTERN AVENUE - AUGUSTA, MAINE 04S30
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the marshes, wetlands and secondary impact.
In addition, there is a Federal policy that favors regional
wastewater treatment systems as found in the 1972 Water Pollution
Control Act Amendments.
Another alternative which needs to be consider is the
expansion and upgrading of the Oak Hill Plant with a discharge
in the Fore River in South Portland.
However, no matter which alternative is implemented, secondary
growth must be controlled.
VI
FEDERAL, STATE AND LOCAL PROTECTION
Who will be the protector?
There is a general reluctance in government administrative
agencies to accept the responsibility (sometimes controversial)
to adopt and enforce the needed controls. In this case it cannot
be ignored by either the Federal, State or local agencies.
There are national interests involved (see section one of
these comments) that need to be protected by a strong enforcement
of the E.I.S. criteria and the conditioning of 201 grants with a
condition similar to the one discussed heretofore regarding Block
Island. There must also be strong controls placed on the type of
equipment to be used, the treatment performance standards, etc.
The D.E.P. must continue its tradition of strong protection
of coastal wetlands'.
431
LUND AND GOODALL i ATTORNEYS AT LAW - IB WESTERN AVENUE - AUGUSTA, MAINE 04330
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The local government needs to implement strong land use
plans and controls.
In short, there needs to be a balance of power and control.
Both State and Federal government must not rely on the local
government to protect the environment and control secondary growth.
Local government has a disappointing history of amending, not
enforcing, and granting variances and exceptions to already weak
land use controls. See: Stansbury, Jeffrey, "Suburban Growth:
A Case Study," Population Bulletin, Vol. 28, April 1972; and
Administration of Zoning in Maine, 20 Maine Law Review, 207 (1968)
and E.P.A. Technical Bulletin: "Secondary Impacts of Transportation
and Wastewater Investments: Review and Bibliography, infra."
CONCLUSION AND ACTIONS
The E.P.A. should take the following steps:
1.	Reject the E.I.S. and Supplement as inadequate;
2.	Provide for an evaluation of the shellfish resources
of the Scarborough marshes and relate them to all the viable
alternatives and E.I.S. guidelines;
3.	Evaluate short-term uses against long-term productivity
of the marshes;
4.	Evaluate with models and more studies the sources of
current pollution in the marshes;
5.	Evaluate the economic impact of the marsh resources;
6.	Evaluate the potential secondary impact of growth on
the marshes with models and reliable data;
432
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7.	Evaluate all alternatives for no discharges into the
marshes or ocean waters off Scarborough;
8.	Postpone decisions until the viability of Alternative F
is fully determined; and
9.	Amend the E.I.S. with a Supplement to reflect the
findings in these new studies.
Dated: November 19, 1976	Respectfully submitted,
Clifford ft."Coodall,Esq
Attorney for
WilViam J. Brookes
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TO:	Members of the City Council
FROM:	Ronald E. Stewart, City Manager
SUBJECT: Scarborough's Sanitary Sewer District
On November 1, A1 Keene, Superintendent of the Scarborough Sewer District, along
with Ray Field, Treatment Plant Operator, Jerry Appleby, Chairman of the District,
and Donald Dargie, P.E., Whitman and Howard,requested a meeting, which explored
the possibilities of their District connecting with South Portland's system, in
accord with recommendations of Dooz-Allen and Hamilton, consultants to Scarborough.
This was the first knowledge officially that I had of their interest, other than
seeing it offered as an alternative in Booz-Allen and Hamilton's impact statement
to the EPA.
They suggested that the recommendation of treatment included those six specific
areas mentioned in the State's Consent Order, all areas located east of the Turnpike,
but projected to amount (high growth scenario) to 2 million g.p.d. It would include
the industrial accounts of Humpty Dumpty and Snow's Canning.
Since Bill Dyer was scheduled to be in South Portland on November 3, we agreed to
meet again.
Following the meeting of November 3, the only benefits to South Portland, as we can
see than, are:
1.	It would open up the Highland Avenue area with a sewer facility,
thus creating a substantial growth area for the City of South Portland.
2.	It could be conditional that Scarborough provide a dumping site for
sludge wastes, in that this potential is greater in Scarborough
than South Portland.
However, it is the feeling of our engineers, Fay, Spofford £ Thorndike, that we should
not consider any additional proposals for increased sewerage, beyond our jurisdiction,
until the plant has been operating for at least a year.
Our capacity, as you know, is 5.5 m.p.g. The inflow-infiltration flows, however, are
greater than originally estimated, as determined by the Interim Study recently
completed by Fay, Spofford § Thorndike.
Our capacity to expand on present site location, without further expansion into the
Fore River, is approximately 50 per cent or to 8.2 m.p.g.
The City in its discussions with developers on November 4, 1976 is looking at approx-
imately 200 acres of new development potential.
434
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It woulJ be my recoro*:..uation that we reply to Scarborough's letter of November 4
(See attached.) that we cannot consider any positive response to their suggestion
before June 1, 1978.
However, members of the Council may feel otherwise; and I would like to place this
subject matter before the next City Council Workshop.
RES: pv j
Attachment
cc: Robert B. Ganley
435
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KAiwiORqvU*! Sanitary District
(	*}'" » O. 4»,OI» »0*
|feAljaoMU»H. J%vn« 044**
November 4, 1976
Mr. Ronald E. Stewart
Ci ty Manager
South Portland City Hall
South Portland, Maine 04106
Dear Mr. Stewart:
As we discussed at our meetings with you on November 1 and 3,
1976, the Scarborough Sanitary District Trustees will greatly
appreciate your cooperation in reviewing with the South Portland
City Council possibilities for joint treatment of sewage from
South Portland and Scarborough.
As you know, one of the more cost efficient alternative treat-
ment schemes for Scarborough that has been studied by Booz-Allen &
Hamilton as part of their EPA funded Environmental Inspect Study
is complete transfer of Scarborough's sewage to the South Portland
treatment plant.
To enable the District's Trustees to make the best possible
decision for the Town of Scarborough, they will appreciate the
South Portland City Council's opinion relative to the possibility
of South Portland's acceptance of Scarborough's sewage. Specifically,
the Trustees wish to know if South Portland feels they are currently
in a position to establish serious negotiations for a joint treatment
-ilternative. If not, what condition? or timing would be required
before they could decide if the joint treatment alternative has any
merit?
If you have any questions on Scarborough's situation, timing or
other details, please feel free to call me (892-6761) or Don Dargie
(617-237-5000).
We look forward to your response.
Very truly yours,
SCARBOROUGH SANITARY DISTRICT
Alvin G. Keene
Superintendent
A3K/p
ccs F. Paul Frinsko, Esq.
G. Applebee, Chairman,
SSD Trustees
436
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rtun,ii.in.TUKE AND FOEESTRY
86
APPENDIX A	». L.
260,
. L.
Compiler's Note.
The words "bureau of markets" In
now construed to mean "department of
natural resources." See § 42-17.1-8.
2-1-10. Inspection powers.
Compiler's Note.	of natural resources) where such duties
Provisions of this section shall apply have been transferred. See P. L. 1962,
to the department of health in the same ch. 80, 8 12, as amended by P. L. 1968,
manner as to the department of agricul- ch. 74, § 1.	*
tore and conservation (now department
2-1-11. Administration of oaths—Subpoena of witnesses and papers.
Compiler's Note.	ment of natural resources) where such
Provisions of this section shall apply	duties have been transferred. See P. L.
to the department of health in the same	1962, ch. 80, 8 12, as amended by P. L.
manner as to the department of agri-	196S, ch. 74, 81*
culture and conservation (now depart-
2-1-12. Enforcement of provisions—Prosecutions.
Compiler's Note.	ment of natural resources) where such
Provisions of this section shall apply	duties have been transferred. See P. L.
to the department of health in the same	1962, ch. 80, § 12, aa amended by P. L.
manner as to the department of agri-	1968, ch. 74, 81-
cultnre and conservation (now depart-
2-1-13. Public policy on coastal wetlands.—Whereas, article I,
§ 17 of the constitution of the state of Ehode Island and Providence
Plantations guarantees to the people the free right of fishery, and
Whereas, The free right of fishery cannot be enjoyed unless both
finfish and shellfish are in abundance to be caught, and
Whereas, The metabolism and katabolism of plants and animals
which constitutes the estuarine complex found in salt marshes fur-
nishes the nitrates, phosphates, sugars, plankton and organic chem-
icals necessary for the. nurture of finfish and shellfish throughout
the Narragansett bay area and its environs, and
Whereas, The capacity of the salt marsh peat and muck sub-
strate to absorb tidal flooding helps to obviate the hydraulics of
severe flood conditions, and
Whereas, All the salt marshes of this state are in jeopardy of
despoliation by persons unmindful of the economic and aesthetic
consequences of such spoliation, therefore,
It is the public policy of this state to preserve the purity and
integrity of the coastal wetlands of this state. The health, welfare
and protection of persons r and property require that the state re-
87
DEPARTMENT OP NATURAL RESOURCES
2-1-15
strict the uses of coastal wetlands and, therefore, in the exercise
of the police power such wetlands aro to be regulated hereunder.
History of Section.
As enacted by P. L. 1965, eh. 140, 81-
2-1-14. Definitions.—A coastal wetland shall mean any salt marsh
bordering on the tidal waters of this state, whether or not the tide
waters reach the littoral areas through natural or artificial water
courses, and such uplands contiguous thereto, but extending no
more than fifty (50) yards inland therefrom, as the director shall
deem reasonably necessary to protect such salt marshes for the
purposes set forth in § 2-1-13. Salt marshes shall include those
areas upon which grow some, but not necessarily all of the follow-
ing: Salt meadow grass (Spartina patens), spike grass (Distichlie
spicata), black grass (Juncus gerardi), saltmarsh grass (Spartina
altemiflora), saltworts (Salicornia europaea, and Salicornia bige-
levil), sea lavender (Iinonium carolinanus), saltmarsh bulrushes
(Scirpus robustus, and Scirpus paludosus var. atlanticus), sand
spurrey (Spergularia marina), switch grass (Panicns virgatum), tall
cordgrass (Spartina pectinata), high-tide bush (Iva frutescens var.
oraria), cattails (Typha angustifolia, and Typha latifolia), spike
rush (Eleocharis rostellata), chairmaker's rush (Seirpus americana),
bent grass (Argostis palustria), and sweet grass (Hierochlee
odorats). The occurrence and extent of saltmarsh peat at the un-
disturbed surface shall be construed to be true evidence of the
extent of a salt marsh or a part thereof.
History of Section.
As enacted by P. L. 1965, ch. 140, § 1.	't
2-1-15. Program for coastal wetlands.—The department is hereby
authorized to establish a program for the protection of the coastal
wetlands of the state. After public hearing the director may, by
written order signed by the director and recorded in the registry
of deeds in each city or town where the land is situated, designate
coastal wetlands or parts thereof, the ecology of which shall not
be disturbed and the use of which shallbe restricted to those uses
compatible with the public policy of this state as set forth in such
order. Notice of such public hearing shall be given by certified mail,
return receipt requested, mailed at least two (2) weeks prior to such
hearing to all owners of record of the land concerned listed in the
most recent records in the city or town in which the land lies, and
upon recording of an order signed by the director a copy thereof
shall be sent by certified mail, return receipt requested, to said
-------
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NOV 22 1876
Kirkwood Road
Scarborough, Me.
Nov. 19, 1976
EPA
c/o Mr. John McGlennon
J ohn Kennedy Bltlg.,
Boston, Mass.
Dear Sirs;
Unfortunately I was unable to attend the open session on sewers
at Scarborough due to my being hospitalized.with a very serious illness,
but I have talked with members of my committee and this letter is to serve
/¦A*
as a reaction to the 3ooz, Allen, 4 Hamilton report.
Our committee was not impressed and somehow we seem to have doubt
as to the sincerity of the whole study. As you recall the original EIS and
the study done by Booz, Allen, & Hamilton revealed many inconsistencies and
errors and the report of Whitman & Howard was pretty well botched.
Now the Supplement to the Draft EIS raises a question of reliability.
In the original EIS there were four schemes for sewering the Town of Scarborough
yet in' the Supplement to the Draft EIS one section is headed "reevaluation
of six schemes presented in the initial draft". This is in error since only
three of the original schemes are being reevaluated and three others are new
and being evaluated, Tl^Ls seems inconsistent.
There is still reference to the works of whitman & Howard of
which there were many inconsistencies, Why have'nt other engineering firms
been brought into the situation? The recent study by the EPA auditors on
national costs for sewage treatment ^ants revealed millions of dollars of
waste and overcharges. Yet, here we are in Scarborough continuing to rely
on only one firm which has been involved in many shortcomings in the work#
It makes us wonder whether the Boston EPA is acting in the best interest for
our people.
439
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Treatment plants seem to have a life of approximately 20 years yet
nowhere in the estimates are budgeting costs for the replacement of the traato
ment plants in the future.
At no time has user fees been brought into the report. This is an
important factor to the taxpayers of the town to know what their annual costs
would be.
As to the determination of growth figures, what expertise does the
members of CCG have for determining these figures? And who determined lew,
medium, and high?
The clarn industry and aqua-culture have beer, ignored in all the
studies when this is important to the commercial development of the town and
a future source of food for the people.
A i?reat deal of stress has beer, put cm what the town Committees
think yet all of them , S*om the town manager down, have members with what
seems to be definite conflicts and would benefit by the development of Flan A,
How can you put much weight on what these committees think under such circum-
stances? Polls have show^that the people wish slow growth yet the people have
never been asked to express themselves in a referendum.
It is with regret that we should have to say that the EPA has not
really helped the situation since at no time have they invited other engineering
firms to present their views.
We hope that you may reach a sensible solution so as to avoid any
legal action by the various groups opposing Flan A.
t' very idftily
man Concerned Citizens Comm.
Sen. Edmund K skie
Sen. '•¦'illiam "-lath-way
Con. William Cohen
Cong. David Hmery
440
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Kirkwood Road
Scarborough, lie,
Oct. 8, 1976
Mr, John I-IcGlenron
EPA Administrator
Regional Office of SPA
Kennedy Blag.,
Boston, ss,
Dear 2-ir, ilcGlennon:
V.'e had hoped to give you a little rest but an article
appearing in the Portland Evening Express on Tuesday, Sept. £8, written
by reporter, Lorraine -.lien, has irked, many -people in the Town of Scarborough.
Although we do not have much confidence in the additional
stu^y by 3ooz, Allen f; Hamilton Inc. we have been v.aiting it out, but, the
letter of Gerald Applabee, Chairman of the Scarborough Sanitary District,
to you brings us back into the picture.
The reporter, quoting from Applebee's letter to you,
stated, "but it seems that the outcry of a sm^ll group has received mors
than sufficient attention for a period of two years," This statement by
Applebee and the Trustees of the Sanitary District is far from accurate
since it is not a s.iiall group crying emit in the To«n of Scarborough, but,
most of the town.
Citizens for a Sensible Sewer is a group of. approximately
fifty enfluential people, the Scarborough Taxpayer's Association Inc. has
a membership of over 100 members from all parts of the town, and the Concerned
Citizens Committee is another fair size group. The Environmental Coram# of
the lag "ins Beach Association voted unanimously to oppose Plan A, Also,the
people should knew that filed in your office is a petition with several
hundred names opposing the large sewer and asking for slow growth. Furthermore
on Wednesday Sight, Oct. 6 a petition with several hundred names was filed
with the Scarborough Tcwn Council to reduce an RIO area to E4. These prople
realize the danger that lies ahead with a large sewer. So you can see tbfet
it is not a small group opposing the large sewer but most of the citizens in
the tewn.
The Sanitary District Timstees are blinded by the fact
thst they are being opposed and they are reacting with poor reasoning, The$,
what does one expect when four of their members , attending a meeting for the
first tins voted j_n favor of Plan A "which called for many millions of dollars
in construction, Yery little study and research had been done by any of the
new members.
The opponents of Plan A are numerous and the various groups
are being represented by three lawyers. They are prepared to go all the way
if the project is not treated fairly under the provisions and proceedures
for an Impact Study,
In the present situation the SPA was to do alternate
studies, yet, no new engineering firms have been brought into the picture,
Whitman & Howard has had it all to themselves with no new ideas or statistical
information brought in from other sources. Competitors have been kept out.
The consultants are still working with Whitman & Howard's figures which have
been unreliable in several instances,
1 5
441
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In the meantime the Sanitary District is issuing permits for
sever entries which seem to exceed the limits of the Oak Hill plant and
the tcwn is still permitting building in what seems to be most undesirable
areas.
The Federal Government under the guidance of Senator Luskie has
been scrutinizing the expenditure of Federal Funds, The EPA has published
material which showed excessive waste in treatment plant constructions and
it is certain the government would like things done efficiently in Scarborough.
Yet, nothing has been said about run-off water and the preservation of the
marshes for aqua-culture development. There could be a great future for the
to-n in aqua=culture. At present the whole area is closed to clamming ana has
been worsened by continuing building such that depurati0n is banned. The
consultants have failed to recognize these important phases of the Scarborough
problem. Greenville and South Paris have had their problems because of the
inefficiency of the engineers. Go up and down the Maine Coast and you'll find
plants built for far over capacity needed and you'll find engineering firms
making costly mistakes at the people1:; expense. So slow dcWi in making a
hasty decision. *v*ait for the Comprehensive study to see the townspeoples
wishes^ The4( bring in engineering firms with fresh or new ideas with competitive
objectives.
Thy is the Sanitary District resisting intelligent citizen input?
Could some of the Trustees have selfish interests? The chairman represents
one of the largest real estate firms doing business in the area and another
•trustee b?.s a sub-diorision recorded in the Portland Begistry. Their interests
may be blinding their reasoning.
You'll find scattered throughout many committees in the town mebbers
who have building interests, own large tracts of land, or have some affiliation
in fields associated with building. It's only natural for them to support
the building of a large sewer.
It is hoped that your consultants ana your employees involved in the
Scarborough Impact Study are not taken in by untrue statements otherwise it
could turn the Impact Study into a long legal battle* which the opponents of
the large sewer are prepared to risk.
Trusting that you get other engineers into the field for a sincere
study of ths problem.
cc:
Senator Edmund Huskie
Senator 'William Hat!'away
Cong. David Emery
Cong. William Cohen
Russell Train
William Adams
Evening Express
American Journal
Lorraine Allen
dofeffl Lee ^J
Chairman Concerned Citizens Corn
442
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Nov. 20, 1976
Mr. Wallace Stickney
U. S. Environmental Policy Coordination Office
Bear Mr. Stickney:
I have carefully revised the "Analysis of the Alternative Systems
for Wastewater 	There still exists inaccuracies
and emissions of analyses in this draft, which are required by law and
recommended by federal guidelines.
In the estimation of waste loads it was necessary to "identify the
service areas and project the population to be served. In 11.1 the
following statement is made - because of septic tank malfunctions 		"
How many septic tanks are involved? Where are they located? When was this
fact established? How many have been remedied over the past five years? It
is stated, "Black Point/Prouts Neck areas, although not under the consent
order, also need sewerage service." Without answering the above questions,
some of which have not been explored, how has the need for these two areas
been established? As a result of a personal survey of people on both sides
of the Black Point Rd., two out of approximately 30 homes indicated that they
had malfunctioning septic tanks. So the majority of this sampling ( at
random) had satisfactory septic tanks. One of the malfunctions was due to
an undersized tank for a family of eight and there was room in the backyard
for expansion. Most of these homes have long flat back
Looking at Prouts Neck - Most of the residents have spent thousands of
dollars to combine and install efficient septic systems. This was
engineered by a local firm. This project at PN should have been considered
in the draft. By what criteria was it established that Prouts Neck needs
service?
With reference to population growth projections from GPCOG. These
projections were supposed to have been prepared in conjunction with the
443
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-2.
Citizen1s Advisory Committee,'when in fact it was prepared by Erie Root
under the direction cf the Chairman of the planning Board, with little input
from the Citizens' Committee as indicated by Mr. Lee in a letter to the
EPA, July 20 *76. I am told by the individual who conducted the study
that it was not done in detail and could be used when planning the design
for the designated areas. In light of these facts, some of these projections
could be far less than accurate. The report hasn't adequately dealt with
what the growth is or adequately predicted what the grcwth will be.
Furthermore, as a result of two recent petitions, townspeople have
indicated a desire for slow growth. Presently well over 1000 residents
have prepared initiative legislation for a referendum vote in Dec. for the
purpose of eliminating the fast growing R-10 district.
In the absence of a deciding referendum on growth, it would seem likely to
plan for slow rather than moderate to high growth, which would eliminate
the need for severing Black Point and Prouts Neck, at this time, which are
not in the consent areas.
Looking at the alternatives, Plan F is the logical answer. But
since there was a last minute announcement of a problem in So. PORTLAND
with infiltration and inflow, it would be expedient to take a second
look at other alternatives rather than the highly objectionable plan A
for reasons cited by Levy, Lees, Cashman, Pelletier Warren et al, at the
EIS hearing of jan.29, I976, which involved Public Health, Economic,
Demographic, Environmental and Aesthetic reasons.
When Plan F is eliminated that leaves us without a viable alternative
unless additional engineering studies are made.
Briefly in considering alternatives, another look should be given to
Old Orchard with the split transfer a little differently. Drainage from
the East side of the standpipe at Blue Point, and Pine Point could go to
0.0., or Dunstan could also be included with a piping station.
444
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-3-
The flow could be controlled by the installation of relatively inexpensive
holding tanks which could be pumped to 0.0. in periods of low flow. This
would improve .the process and cut costs. The present O.H. plant could be
maintained. If Dunstan is not taken, it could be pumped across the old
railroad bed. Higgins Beach could be sent to So. Portland. This would
be much less flow for So. Portland to receive and possibly this small
increase could be handled. Assuming administrative and political pro-
blems is not a sufficient reason for throwing out an alternative as was
dohe with 0.0. Also the recently submitted Ta rbe 11 -Wa rr e n plan is the
only plan which made a serious attempt to address administrative,
political and environmental objections.
With reference to plan C, this was not investigated thoroughly.
Mr. Griffin did not propose a line down the Black Point Road nor the
Spurwink Road, The line from H.B. was propped for two possible routes _
one was over Pleasant Hill to the pumping station , back to the plant
across the RR tracks., the other was by Chamberlin Road. However, these
plans shculd have been obtained from engineer Griffin for an accurate
report. A preliminary contact was made with Mr. Griffin who was told
that Mr. Farkas would be contacting him later which never did happen.
Mr. Griffin presented plans for little money arid he could not present
detailed plans without compensation. This is the chief difficulty with
all of these studies and hearings i.e. lack of engineering studies,
The above lack of follow_up, together with the recent findings of the
So. Portland infiltration shows that the Booz Allen report is incomplete.
They did not fully explore F.
so that opponents really did not have a f&ir chance of a rebuttal in this
other than Whitman and Howardj

With this last minute revelation of F, the whole picture was changed
limited time.
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6 Vesper Street
Scarborough, Maine 04074
November 16, 1976
Mr. Wallace Stickney
EPA Region 1
J.F.K. Federal Building
Government Center
Boston, Massachusetts 02203
Dear Mr. Stickney:
I found the public hearing on the supplement to the Draft EIS of Dec. 1975 held in
Scarborough on Nov. 9, 1976to be most informative. Some good thoughts were
expounded on both sides of the table.
I was, of course, disappointed to hear of South Portland's infiltration problem
just as it seemed that a viable alternative to Plan A had been found, which had the
support of nearly everyone comprising the "political opposition" to Plan A. However,
I believe Mr. C. Harvey Warren and Mr. John Tarbell have an idea which includes the
bebefits of both Plans A and F.
You should have received detailed descriptions of these plans from them, but I shall
summarize:
Expand the Oak Hill plant, or build a new plant in the vicinity of the old
Port 0' Maine airport with an outfall to the Fore River. This plan has the
following advantages:
1.	Does not depend on capacity problems at the South Portland plant.
Would not incur additional delays.
2.	Proposed plant would be under Scarborough Sewer District controls.
3.	Has all the advantages in the areas of public health, primary and
secondary environmental effects, and public support of the modified
Plan F brought forth in my presentation at the hearing Nov. 9th.
4.	Places the plant (either location) in a more desirable location than
Plan A for that type of activity.
A possible' disadvantage is the cost of the longer outfall (when compared to Plan A)
but as indicated by some at the public bearing, there may be a willingness to
support a slightly more expensive system that is environmentally and socially "cost
effective". Besides, the installation of the plant and piping is part of the 90%
funded cost, and is a "one-time" cost. In the long run, the residents of
Scarborough are going to be more interested in the user costs and benefits of having
a sewer system.
NOV 19
446
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Mr. Wallace Stickney
-2-
November 16, 1976
I hope you will consider this alternative in preparing the final edition of the
Environmental Impact Statement, and find this a favorable system over the pro-
posed Plan A.
Thank you for your attention in this matter.
Sincerely,
a(\
Bruce C. Gray
For the Higgins Beach
Environmental Committee
447
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Lund and Goodall
ATTORNEYS AT LAW
13 WBSTEKN AVENUE
AUGUSTA, MAINB 043 3 0
JON A. LUND
CLIFFORD H. GOODALL
TBLBPHONB
207-623 1186
October 22, 1976
John A. S. McGlennon
Regional Administrator
U.S. Environmental Protection Agency
Room 2203
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
It is my understanding that at a meeting held in
Augusta, Maine on October 20, 1976, which you attended,
representatives of the Scarborough, Maine Sanitary District
complained about what they claim to be unnecessary delays
in the funding and construction of the sewerage treatment
system for that town.
Our firm represents a group of Scarborough residents
that are sincerely concerned about the primary and secondary
effects of any proposed system. It is our position that the
Scarborough Sanitary District and some town officials have
failed to understand the complexity, importance and implications
of the decisions that must be made in this matter.
The residents of Scarborough, Maine; the Maine Department
of Environmental Protection (D.E.P.) and the Federal Environmental
Protection Agency (E.P.A.) are currently in the process of making
decisions, that will have a substantial impact on local, areawide,
state, regional and national issues. These decisions can have
a major impact on the economy of Scarborough and the surrounding
areas. If properly handled, new economic resources can be
developed as outlined in this letter.
The basic issue concerns the choice of a sewerage treatment
system for the Town of Scarborough, but other important environ-
mental, wildlife, economic, population growth and employment issues
are involved and overshadow the basic issue of selecting among
various alternatives of sewerage treatment systems.
448
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John A. S. McGlennon
October 22, 1976
Page two
The State of Maine, as you may know, has only 16,000 acres
of saltwater marshes which play a direct and major role in the
support of our State's important fisheries industry. Scarborough
has within its boundaries 2,700 acres of this marsh land and it is
the largest and most important saltwater marsh on the entire Maine
coast. It is a part of the Rachel Carson National Wildlife Refuge
and is^important as a wildlife habitat, a feeding and resting area
for waterfowl on the Atlantic Flyway, a commercially productive
shellfish area, and is a major contributor to the marine food web
for this section of the Maine coast. These saltwater marshes
offer an excellent habitat and opportunity for the management
of Canadian Snow Geese, as well as Black Ducks, other waterfowl
and shore birds.
The Town of Scarborough is located ten miles south of
Portland and consists of a system of peninsulars which project
out into the salt marshes and into the Atlantic Ocean. It is
a town which has experienced a recent explosive growth in
population. In addition to the marshes, it also has several
fine sandy beaches and a State Park which serves as an increasingly
important recreational function for the greater Portland area.
Please see the enclosed photocopy of a topo map of the area.
The Department of Marine Resources is concerned about the
potential economic importance of the clam flats that are contained
in these wetlands. According to John W. Hurst, Jr. of that
Department's Research Station in Boothbay Harbor, these clam flats
have the capacity of being managed to produce an average yearly
sustained yield of 10,000 bushels of clams. Each bushel currently
has about a $20.00 per bushel landed value which, therefore,
would provide a $200,000.00 annual value to clams dug in these
flats at current landed value rates. This potential sustained
yield is sufficient to support three or four commercial handlers
and 25 to 50 people harvesting the clams depending on the season.
./The important economic point is that these Scarborough clam flats
are able to produce steamers which are worth thirty times the
landed value or $6,000,000.00. These flats also produce fryers
which are worth ten to fifteen times the landed value or
$3,000,000.00. According to Hurst, the value of this industry
to the area would be approximately fifteen times the landed value
of the harvest or $3,000,000.00.
449
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John A. S. McGlennon
October 22, 1976
Page three
None of these values are now being realized because the
clam flats and depuration plants are closed because of the
extensive and massive pollution that exists in the Scarborough
marshes. During this summer the Department of Marine Resources'
test showed clams containing a count of 160,000+ of total coliforms
M.P.N, and the same for fecal coliforms M.P.N. These same tests
show that the water in these areas have a total coliform count
of 11,000 M.P.N, and fecal coliform bacteria count of up to
430 M.P.N. State law (38 M.R.S.A. §364) established a water
classification standard for these waters that states "the
median numbers of coliform bacteria in any series of samples
representative of water in the shellfish growing area shall not
be in excess of 700 per 100 milliliters, nor shall more than 10%
of the samples exceed 2,300 coliform bacteria per 100 milliliters.
The median numbers of fecal coliform bacteria in any series of
samples representative of waters in the shellfish growing area
shall not be in excess of 150 per 100 milliliters	This is
clear evidence of the extent of pollution in the shellfish or
clam flat areas. These standards are currently being reviewed
by the D.E.P. and the E.P.A. proposes that they be changed to a
median of 14/100 ml and 10% of the sample be L 43/100 ml in
shellfish harvesting waters in order to meet the 1983 swimmable-
fishable goal. Other areas in the marshes have waters that have
fecal coliform counts of up to 4600 M.P.N. The results are from
nonpoint source studies begun in March 1976 and the high readings
were found in samples collected August 12 and September 27, 1976.
Mr. Hurst said that this magnitude of pollution is what one
would expect to find in Portland Harbor. He also said the
pollution is so extensive through the marshes that the sources
cannot be easily determined.
These polluted waters flow by'three of the four public
beaches in Scarborough (Pine Point, Prouts Neck and Higgins
Beach) but there are no tests to show definite pollution of
these recreational waters, but their pollution and threat to
health is obvious.
Much of the existing pollution comes from the residential
development in the town, including the extensive recent
residential development that has occurred around the marshes.
The proposed sewerage treatment system will help to reduce some
of this current pollution, but may replace it and add to it with
a similar as well as a different type of pollution and threat
to the marshes. The construction of a large treatment system
would act as a catalyst to encourage unnatural growth and
development within the town and around the marshes. If the
450
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John A. S. McGlennon
October 22, 1976
Page four
system is not properly planned and controlled, it can stimulate
substantial growth because the town is close to the metropolitan
Portland area. Any growth in the area of the marshes is a threat
to the marshes and substantial growth, stimulated by the treatment
system, would destroy the marsh and its economic and environmental
potential because of the secondary nonpoint source pollution that
results from all residential development. Therefore, if the
marshes are to be saved, improved, protected and their economic
potential used, the sewerage treatment plant must be one that
treats existing pollution instead of one that encourages growth.
A Step I Planning Grant has been awarded the Scarborough
Sanitary District, but because of the importance of these marshes
and their fragile characteristics, Region I of E.P.A. is requiring
that an Environmental Impact Statement (E.I.S.) be completed
prior to the funding of any Step II or III construction grants.
One E.I.S. has already been drafted and rejected for this project.
A new draft E.I.S. is now being written and will be released soon
for comment.
It is also important to note that Scarborough is
within a §208 Water Quality Planning District that is actively
fulfilling its planning functions for the town while the
§201, Step 1 planning is also taking place. In addition, the
town does not have a current and adequate comprehensive plan
and this has and will continue to contribute to the delays,.
The source of delay is caused by some of the very town officials
that are complaining of the length of time it takes to fully
implement a §201 project. Town officials and Sanitary District
members should not expect to be able to drag their heels for a
long period of time before they actively become involved in water
pollution cleanup and then expect everything to happen overnight
after they are forced into action by the D.E.P. and E.P.A.
I hope this information will assist you in evaluating
the circumstances of this case. Please feel free to ask any
questions that may arise regarding these matters.
Best re
XMT/ORD H. GOODALL
CHG/lt
Enclosure
451
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John G. Tarbell
127 Spurwink Rd.
Scarborough, Maine QkOTii.
November 17, 1976
Gentlemen:
Having attended both the Monday November 8, 1976 workshop, and
the Tuesday November 9, 1976 public hearing I wish to write to
express my thoughts on the proposed alternatives for sewering
Scarborough.
I,like many citizens in Scarborough felt prior to the Tuesday
eveni: g meeting that we had a feasible alternative to support
in alternative F; however, it now appears as though alternative
F will become less favorable in view of the serious I/I pro-
blems recently discovered in South Portland's older sections of
its sewer system. Therefore, although alternative P probably
will not be totally eliminated in the final EIS, it will never-
theless not be feasible from the standpoint of solving Scarboro-
ugh's need for a sewer system and treatment in the very near fu-
ture (1 to 2 years). The SPA, and Maine's DEP, are the govern-
mental agencies which will now decide whether or not Scarborough
can be permitted to delay action until the extent of the South
Portland problem is determined and a time frame for allowing
Scarborough to connect into the South Portland system can be res-
olved. I for one feel this is still the best and most economical
system for all the citizens of Scarborough and for that reason
deserves the total support of you at the EPA and the appropriate
officials with the Maine DEP.
Two possible alternatives may exist if it is decided that Scar-
borough can not connect into South Portland's system because of
the time involved in solving their I/I problem. First, as was
briefly mentioned at the Tuesday evening meeting, pumping Scar-
borough's treated effluent to the Pore River. I have worked out
two possible methods which could be used. One involves construct-
ion of a new treatment facility near the old airport site off
Pleasant Hill road and pumping from there along the railroad bed
area to a point in the Pore River near the Veteran's Bridge where
it would discharge(refer to method 1 plan enclosed). The number
of pipqp .station's initially are the same for this method as the
total for Plan A, however, two additional stations would be re-
quired in the future. The outfall is approximately 17,000 feet
to the Pore River, while the Whitman and Howard outfall is ahout
8,000 feet. However, it should be noted W.&H.'s force main out-
fall would require rock excavation, while the Pore River route
does not appear to be in rock.
»0VH
%
453
-------
Therefore, the cost difference should be greatly reduced. As can
be seen on the Method 1 plan the Prout's Neck and Bl-ack Point
areas (not in the consent order) are to be sewered in the future
which should further decease the coat of this method. I feel this
system should be analyzed closely to determine it's feasibility.
The second method is shown on the Method 2 plan enclosed. It in-
volves expanding the Oak Hill facility (secondary treatment only)
and pumping to the Pore River. I showed only one pump station to
accomplish this because the added cost of an additional pump
station somewhere along the outfall route would probably make this
plan too-expensive for consideration. The only advantage of this
second method over the first would be that the facility at Oak
Hill would be less in capital cost because of the existing plant's
capacity already available.
The second alternative mentioned earlier would be to transport sCll
waste to Old Orchard Beach, expand the treatment plant at the
Goosefare Brook, and provide an ocean outfall so that the facility
need not be advanced treatment. Old Orchard Beach may be receptive
to this plan because of the problems they are going to continue to
have discharging into the Goosefare Brook.
I thank you for your time and consideration. Should you have
any questions I may be reached at telephone number 207-799-3666
after 5:00 P.M. any weekday.
Very truly yours, ^
Sfl & 7^5--
JOHN C. TARBSLL
enclosures
454
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102 Fogg Road
Scarborough, Maine 04074
November 18, 1976
Mr. Wallace Stickney
EPA Region 1
J.F.K. Federal Building
Government Center
Boston, Massachusetts 02203
Dear Mr. Stickney:
The Scarborough Conservation Commission would like to go on record-
as supporting the concept of Plan F as a solution to Scarborough's
waste treatment and effluent dispersement problems. We were of course
disturbed by the information revealed at the public workshop on the 9th
of November regarding South Portland's infiltration dilemma; however, we
would urge the Environmental Protection Agency to do all in its power
to help overcome the technical problems which now pose an obstacle to
South Portland's acceptance of any waste from Scarborough.
It was obvious from statements made by municipal officials at both
the private and public workshops on November 8th and 9th that, with certain
reservations. Plan F is the most cost-effective and environmentally sound
of the proposed alternatives. If, however, the Environmental Protection
Agency and the Scarborough Sanitary District should find further negotia-
tions with South Portland to be either impossible or fruitless, the
Conservation Commission would urge implementation of the proposal submitted
by C. Harvey Warren and John Tarbell, calling for an outfall pipe running
from a treatment plant in Scarborough (located either at the present site
or at Pleasant Hill) to the Fore River. The Warren-Tarbell concept com-
bines the environmental benefits of Plan F with the autonomy of Plan A
to provide a solution that is both administratively feasible and politically
uncontroversial. The cost should not be appreciably different from that
** and therefore has their support.
459
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2
estimated for other alternatives, especially when comparing the proposed
outfalls under Plan A and the Warren-Tarbell alternative; a pipeline
along the railroad bed to the Fore River will avoid many of the monetary
and environmental problems that would be involved with the blasting for
the ocean outfall at Prouts Neck.
Please give the Warren-Tarbell plan serious and complete considera-
tion in the final draft of the Scarborough EIS. Should Plan F be aban-
doned, the Warren-Tarbell proposal would be the perfect substitute.
We would also urge that the Environmental Protection Agency make
some serious recommendations for treatment of run-off and sludge, bearing
in mind their importance to the quality of both the Scarborough marsh
and the water supply for Nbrth and West Scarborough.
Thank you for your consideration of this and any other citizen input
you may receive by the November 22nd deadline.

Sincerely,
Rebecca I. Warren
Chairperson
Scarborough Conservation Comm
460
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H. JEREMY WINTERSTEEN
243 EAST 4Bth STREET
NEW YDRK CITY 10D17
i i*U V
E.P.A., Region 1
Environmental Policy Coordination
JFK Federal Building
Boston Mass 02203
12 November 1976
Dear Sir;
I write to state my serious concern about Alternative A
in your September 30, 1976, Supplemental Environmental Impact
Statement for Scarborough's (Maine) proposed wastewater and
treatment systems.
I am a taxpayer of Scarborough, and have been a summer
resident there for 41 years.
Alternative A's proposed outfall off Prout's Neck would,
in your own words (EIS p.IV-7) engender a "degree of health risk
from such effluent discharge (that) cannot be determined." The
bathing beaches of Scarborough are perhaps its primary summer
attraction and source of tourist revenue. Scarborough Beach is
in line for direct receipt of effluent flow from the Prouts
Neck outfall. If there were no alternative to this outfall place-
ment, still it would be an inhuman concept. Once that outfall is
in place, the mistake becomes irretrievable given the economics
of construction.
There does exist, however, a sound alternative both in terms
of environment and economics. That is Alternative F, full transfer
to South Portland. From the beginning, Scarborough has resisted
full analysis and pursuit of this idea solely to massage its local
ego by proposing full control of sanitation systems - a parochial
concept that flies in the face of your own oft-stated support for
regional facilities.
Scarborough's key argument now for Alternative A stems around
the question of time. I ask: is it better to do the wrong thing
now ... or the right thing a little later?
Sincerely yours
I 11)	. <1.
H\yeremy Winters teen
461
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o
Greater Portland
Council of Governments
0 DEC 1976
President
LOUIS P. BLANCHETTE
Executive Director
OSMOND C. BONSEY
Director Of Planning
JOSEPH F. ZIEPNIEWSKI
TO: Bob Mendoza

FROM: Eric Root
DATE: December 9, 1976
RE: Comments on the Draft EIS for Scarborough's STP
Comments:
1.	The information currently available to local decisionmakers,
with the latest supplements to the draft EIS, should be suf-
ficient to permit them to make a final decision on the al-
ternative sewerage system configuration.
2.	The principal uncertainty which local decisionmakers face is
the possibility of an agreement with South,Portland on the
treatment of Scarborough's wastewater in South Portland.
This possibility should be examined and a decision should be
rendered on the local level.
3.	Regional and local plans do not conflict with any of the proposed
alternatives. The CZM program is not approved and is therefore
not a factor in this review. However, Maine has state laws
governing land use in areas adjacent to water bodies which will
form the basis for CZM plans and other plans for preservation
and management of coastal areas. The implementation of local
and state laws and plans for water pollution control under each
alternative sewerage configuration will require considerable
effort and diligence on the part of local elected and appointed
officials. I think that Scarborough's officials perceive this
need.
This EIS has significantly affected the decisionmaking process in
Scarborough and has therefore served its purpose. Further time for
preliminary planning and analysis of alternatives will probably not
serve any useful purpose.
331 Veranda Street• Portlanc^J^aine 04103-207-774-9891
-------
Comments of
John W. Hurst-, Jr.
Laboratory Director
Department of Marine Resources
Boothbay Harbor, Maine
November 9, 19.'
to
AN ANALYSIS OF THE
ALTERNATIVE SYSTEMS FOR WASTEWATER
COLLECTION AND TREATMENT IN SCARBOROUGH, MAINE
SUPPLEMENT TO THE DRAFT
ENVIRONMENTAL IMPACT STATEMENT
OF DECEMBER 1975
Prepared for
Environmental Protection Agency, Region I
Boston, Massachusetts
463
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If we assume that the citizens of Scarboro want clean shellfish
growing water and clean bathing beaches, they must remove most if not
all sources of pollution from the area. For practical purposes most of
Scarboro is not suitable for subsurface sewage disposal. Therefore, a-
sewage treatment plant is the only answer.
Booz-Allen and Hamilton give three alternatives for the treatment of
the sewage from Scarboro: A1ternate A, treatment plant with an outfall off
Prout's Neck; Alternate C, upgrading the Oak Hill Sewer Plant; Alternative F,
complete transfer of all sewage to the South Portland Sewage Treatment Plant.
Commenting first on Alternative A -
Ocean outfalls from sewage treatment plants, when properly located and
maintained, are the best kind of sewage treatment. Literature references
indicate that the dilution factor from a properly located ocean outfall gives
a comparable rate of treatment, with only primary treatment, as a more sophis-
ticated sewage treatment plant which provides even tertiary treatment. This
sewage treatment plant is a secondary plant, thus in this situation the plant
is achieving the ultimate in sewage treatment. This sewage treatment plant
is the only acceptable sewage treatment plant completely under the control of
the citizens of Scarboro.
The two options for the route of the outfall pipe in Alternative A have
been adequately discussed by Booz-Allen and Hamilton. The suggested advanced
treatment of the effluent for this option does not adequately discuss the probable
toxic effects of the effluent. It is doubtful whether this added treatment will
be worth its added cost.
Under the National Shellfish Sanitat ion Program it is necessary to have
464
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a closed shellfish area around an effluent pipe of a sewage treatment plant.
The purpose of this closed area is to protect the public from possible patho-
gens present in the shellfish growing waters which the shellfish might be
expected to accumulate. The size of the closed area is determined after a
detailed hydrographic and bacteriological study of the area. The details of
these studies are discussed in Technological Builetin EPA 430/9-7^-010 Pro-
tection of Shel1fish Waters.
Although no studies as such have been conducted for Alternative A
at Prout's Neck, it has been estimated that with a complete failure of
chlorination of the Scarboro effluent that it would take an area approxi-
mately 2500 feet in diameter to dilute the effluent to less than 70 Mf*N.
In this area al1" shell fishing would be prohibited. The permanent closed
area in Scarboro which is as yet undetermined may be expected to be consider-
ably less than 2500 feet.
Predicting in advance whether and when the shellfish growing areas may
be reopened is difficult because reopening of shellfish growing waters is
dependent upon acceptable water quality levels. Complete removal of pollution
from the estuary should achieve this. Until pollution abatement is achieved,
the shellfish areas will remain closed.
If the water quality is such that it is suitable for open area shell-
fishing, bathing waters are more than adequately protected.
The proposed Alternative C will enlarge the sewage treatment facility
at Oak Hill to treat al1 (except Pleasant Hill) of the sewage from Scarboro.
There is no reliable way to evaluate in advance the impact of this sewage
treatment facility on the estuary. We can assume that there will be viruses
and other pathogens in the sewage treatment plant discharge at Oak Hill and
that the shellfish downstream from the outfall will accumulate any viruses
465
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and other pathogens present in the growing waters. These shel1fish will
present a definite public health risk which will be difficult to evaluate.
We can assume that Alternative C will also present a water contact risk of
a somewhat greater magnitude than the Prout's Neck outfall due to much less
dilution water being available.
Advanced treatment of some sort will undoubtedly be required for
Alternative C. What form of advanced treatment which would be required is
not discussed adequately. It should be assumed that the more complicated
a sewage treatment system is the more chance there is for a possible breakdown.
To predict, at this time, what the impact of the sewage treatment plant
outfall on the reopening of the Scarboro shellfish growing area will be is
speculative at best. It may be expected, due to the unreliability of sewage
treatment plants, that a large portion, if not all, of the area will remain
closed. The only reliable method of sewage treatment as far as shellfish
protection is concerned is the complete removal of any sewage discharges,
either point or nonpoint, from the estuary. The Department of Marine Resources
is opposed to Alternative C due to the expected impact of this outfall on the
estuary.
Alternative F will achieve the same degree of pollution removal as
Alternative A. The fact that Pleasant Hill may be easily added to the sewage
treatment system under this alternative makes it more acceptable than Alter-
native A. Pollution abatement-wise this option would appear to be more accept-
able than Alternative A. The adequacy of this alternative is obviously depend-
ent upon the removal of all pollution from the estuary. How acceptable this
alternative is to the citizens of Scarboro does not appear to be any concern
of the Department of Marine Resources.
466
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References:
Coastal Zone Pollution Management, Proceedings of the Symposium,
sponsored by Southeast Region Environmental Protection Agency
and College of Engineering, Clemson University, Charleston,
South Carolina, February 21-22, 1972. 282 p.
Quality Criteria for Water, U.S. Environmental Protection Agency,
Washington, D.C. 20460., "Fecal Coliform Bacteria", 79~lOO.
Technical Bulletin EPA 430/9-74-010, Protection of Shel1 fish Waters,
July 1974, 19 P> U.S. Environmental Protection Agency, Office
of Water Program Operations, Washington, D.C. 20460.
467
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Open Coast
Estuary
City
[w?
Figure I. Idealized Estuarine-Coastal Disposal Alternatives
1
DISCHARGE LOCATION
A
B
c
2
Initial Waste Dilution, So
(Min. River Flow)
10
30
150
3
Pollutant Concentration
Near Source (at Diffusor)
(No Treatment)
.Co
To
.Co
30
.Co
150'
4
Treatment (Assume)
Percent Removal
Secondary
(0.9)
. Intermediate
(0.75)
Primary
(0.33)
'j
Pollutant Concentration
Near Source
.Co
Too
,Co.
120
.Co
225
6
Treatment {% Removal)
Required for Equal
Pollutant Concentrations
dt all Three LocaLions
C = Cq/1!>0
93.3
so.o
None
(oj:)
1
DISCHARGE LOCATION
A
B
C
2
Initial Dilution
(At Source)
5 - 20
(10)
60 •• 80
(70)
100 - 200
(150)
3
Pollutant Concentration
(At Source) Conservative
Ho Decay
_Co
10
.Co
10
.Co
10
4
Treatment - Percent Removal
90
75
50
5
Assumed Transport Time to
Shore in Hours
0
12
24
6
1
Pollutant Concentration on
Beach Conservative
No Decay
.Co
100
_Co
335
.Co
750
7
Pollutant Concentration on
Beach Non Conservative,
Decay Rate



7a
Tg0 f 4 hrs k = .58 hrs"1
C0/100
CQ/3.35x10s
Cq/4.5x109
7b
T°° = 1 hrs k = 2.3 hrs"1
Co/100
C /3.9xl0.1'
C /I.6x10-^
0
7c
Tjo » 12 hrs k s .19 hrs*1
Co/100
Cn/3.36x10'
C /4-5x'l 0''
0
7d
T<,o = 240 hrs k ¦ .23 day"1
Co/100
C0/398x10
C0/557
Figure 2. Idealised Open Coast Disposal Alternatives
-------
FECAL COLIFOP.M BACTERIA
CRITERION;
Bathing Waters
Based cn a riuxuioan of riot less than five sairples taken over
a 30-day period/ the fecal coliform bacterial level should not exceed
a log mean of 200 per 100 ml, nor should irore than 10 percent of the
total sarples taken during any 30 day period exceed 400 per 100 ml.
Shellfish Harvesting Waters
Not to exceed a median fecal coliform bacterial concentration
of 14 MPN per 100 ml with not more than 10 percent of
samples exceeding 43 MPN per 100 ml for the taking of
shellfish.
INTRODUCTION;
It was recognized e^vsn before the microbial etiology of
disease was known# that water can serve as a medium for the
transfpr of disease. The cause-effect relationship of disease
transmission and specific fecally-assoclated microbes was
initially defined by Von Fritsch in 1880, when he identified
Klebsiella spp*. in human feces. ' Further confirmation of the
469
-------
relationship between fecal ly-assoc1ated microbes and potential
disease was developed by EscharicA whan he described BaciUua .coli
(Escherichia coll) as an Indicator of pollution (Wolf, 19725
Guarrala, 1972). Since these early observations, the role of
biological Indicator organisms in defining water quality has
become essential and addresses three categories generally: to
-identify environmental changes; to quantify pollution levels; or
to be used 1n laboratories to study under controlled conditions
phenomena which could be extrapolated to the environment (Butler,
ejt aV., 1972).
Microbiological indicators have been used to determine or
indicate the safety of water for drinking, swimming and shellfish
*
harvesting. As our knowledge concerning microbiology has
increased, so has our understanding of the complex
interrelationship of the various organisms with disease. Viruses
causing a number of diseases and non-fecally associated bacteria
causing infections of the ear,", eye, nose and throat all hava been
isolated from water (Bonde, 1974j Scarplno, 1974). The
relationship between numbers of specific disease causing
organisms in water and the potential for transmission of disease
remains elusive since the number of organisms^naquired to causa
disease varies depending upon the organise, th» fcosto sod
the manner in which the bacteria and host Int-araet. For enaraple,
in soma instances a single cell of Salmonella,, or a single plaque-
forming unit (PFU) may bs all that is necessary to cause a
470
-------
disease; however, in other instances the numbers of bacteria
6	7'
necessary to cause an illness nay be up to 10 to 10 or evsn more
viable organists. The use to "which water is put (i.e., swiirroing
or drinking) the type of water, (marine or fresh), and the geographical
location atfa all factors to be weighed in determining micro-
hifilngical criteria.
Ideally, a microbiological Indicator organism should fulfill
all of the following criteria: (1) It should be applicable to all
types of water, *(2) 1t should be present whenever pathogens are
present with a survival time equal to that of the hardiest
enteric pathogen, and (3) tha Indicator should not reproduce In
contaminated waters thus resulting 1n Inflated values (Scarpino,
1974). Unfortunately, no such indicator organisms are known.
Use has been made of coliform or fecal ooliforra bacteria as indicators
of pollution.
Bacteria of the col 1 form group are considered the primary
Indicators of fecal contamination and are one of the most
frequently applied Indicators of water quality. The conform
group 1s made up of a numSer of bacteria Including the genera
Klebsiella, Escherichia, Serratla, Erwinia and Enterobacteria.
Total conform bacteria are all gram negative asporogenous rods
and have baen associated with feces o? wanrblcodsd aniirals.
471
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and with soil. The fecal coliform bacteria, which comprise
a portion of the total coliform group, are able to grow
at 44.5° C and ferment lactose producing acid and gas. Use
of fecal coliform bacteria has proven to be of more sanitary
significance than the use of total coliform bacteria because
they are restricted to the intestinal tract of warm-blooded
animals and are now used to define water quality for swimming.
Arguments have been advanced for the use of Escherichia coli
as the indicator of choice for fresh fecal pollution (Bonde,
1966). However, the methods for its identification require
time* complex biochemical reactions, and experienced micro-
biologists, and the information gained by the additional work
and expense involved in its identification may not provide
sufficient additional information above the elevated temperatura
test (for fecal coliform bacteria) to warj-ant its use.
Errterooocci were recognized as early as 1890 as being indicators
of recant facal pollution from wazm-blccdsd animals (Geldreich and
Kennar, 1969). The enterocecci possess many characteristics which iraka
them an ideal indicator system since they do not multiply in
the aquatic environment and are serologically characteristic.
However, there are numerous biotypes, and no good standard-
ized method is available for biochemical testing. Such
methodology is essential since identification is based primarily
upon biochemical characterization.
472
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Additional microbial systems have also been proposed as
potential Indicators of fecal pollution. Clostridium
perfr1nqens, an anaerobic spore former, has been associated
frequently with sewage pollution. However, 1n a suspension of
fecal material the ratio of £]_. perfrlnqens to £. col 1 may differ
from that 1n the effluent from a sewage treatment plant, 1n
seawater or in sludge. Also the spores of Cl_. perfrlnqens are
resistant and will vegetate upon culturing, hence It would be
difficult to associate their presence with recent pollution.
Presence of microorganisms other than fecal coHform bacteria may
also be indicative of water quality; however, the strict
correlation between a pollutant problem other than fecal
pollution and the numbers of the indicator organism 1s not always
clear. The pseudomonads that are comprised of numerous free
living saprophytes found in both fresh and marine waters have
only one of its members as a known pathogen, Pseudoinonas
aeruginosa» which may be an Indicator of pol lution from the
presence of warm-blooded animals jRlngem and Drake, 1952; Taylor,
1968; Reitier and Seligaman, 1957). While the number of P.
aerugi nosa in sewage usually is quite low and occurs too
sporadically to be of value as an indicator organism for fecal
pollution (Bonde, 1974), this organism may be an indicator of
human pollution other than fecal.
473
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Bacterial pathogens, which occur in bathing waters
and may cause disease even when not Ingested are K1ebsiel 1 a
pneumoniae and Pseudomonas aeruginosa.
RATIONALE:
Bathing Waters
Pollution of aquatic systems by the excreta of warnfeLcodsd
animals creates public health problems for man and animals and
potential disease problems for aquatic Hfe. It 1s known that
enteric microbial pathogens may Inhabit the gut of most
warmblooded aninsals and are shed in feces. The presence of
bacterial , viral, protozoan, and possibly fungal species which
are either pathogens for or possess the potential to infect man
and other organisms 1s Indicated by the presence of the fecal
coHform group of bacteria. Thus, the number of fecal conforms
present is indicative of the degree of health risk associated
with using the water for drlrtklng, swimming, or shellfish
harvesting.
Arguments against the use of fecal collform bacteria to
define swimming quality in waters have noted tha paucity of
epidemiological evidence'1 Inking fecal col 1 form 1 avals In bathing
waters and the incidence of disease (Moore, 1959s 197!)•
474
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A problem of potential medical significance Is the transfer
of characteristlcs which will alter the resistance of pathogenic
bacteria, i.e. the R-factor {RTF - resistance transfer factor),
to certain antibiotics, heavy metals and ultraviolet light. The
significance of this, while not fully known, suggests that human
pathogens In water nay become resistant to common antibiotic
therapy once the bacteria infect man or animals. One example of
this problem has been already reported. Recently an outbreak of
typhoid fever was found to be caused by Salmonella typhi
containing the chloramphenical and amphicillin resistant factor
(Datta and OleartB/ 1974; Olearte and Galindo, 1973).
Disease transmission via the aquatic route including drinking
water, recreational water, and seafood fran polluted water, has been
and continues to be a problem. Presently, the indicator systems
considered to be the most practical are the colifom and the fecal
colifoxm groups. Additional microbiological problems, which can be
anticipated by the presence of specific bacteria or viruses,
are recognized. Correlation between human pollution sources
and the numbers and significance of the microbial system in question remain elusive.
Nevertheless* as the relationships become clear additional criteria for water
quality will evolve. Berg (1974) has shown that Polio Virus I. at a concentration
of 2 plaque forming units (PFU), a standard means for measuring virus concentrations
i.n tissue culture, will cause disease in 67 percent of the uninnoculatad. population.
475
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However, the lack of epidemiological correlation between fecal
conform levels 1n coastal swimming watars and tha incldanes of
disease may not have validity 1n fresh waters and it does not
take into account non-reported diseases which may
develop as an unrecognized result of swimming in polluted waters*
Epidemiological evidence 1s but one consideration 1n setting
microbiological criteria. The presence of fecal collform
bacteria indicates degradation of water quality and a.relative
risk of disease transmission.
In studies conducted In Lake Michigan at Chicago, Illinois
(Smith, e_t al_., 1951.), In an Inland river (Smith and Woolsey,
1952) and in tidal waters at Long Island, New York (Smith and
Woolsey, 1961), a statistically significant increase 1n the
incidence of illness was observed among swimmers who used the
Lake Michigan beaches on selected daj/s and the Ohio River beach
of poorest Wuier quality. The mean total collform bacteria
content of fresh waters was 2,300 per 100 ml and 2,700 per 100 ml/
respectively. No relationship between the total collform levels
and swimming-related diseases was found at the ocean beach.
These studies demonstrated that an appreciably higher overall
Illness incidence may be expected among swiinrers when carpared to
non-swimmers, but tha data are inconclusive* The data provide a
positive correlation between total conform numbers and the
increased risk of disease associated with swimming 1n these
waters. The diseases found wars infections of the eyep ea'r»
476
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nose, and throat, as well as Intestinal ailments (Stevenson,
1953).
Outbreaks of typhoid fever (Salmonella typhi) have been
associated with swimmers 1n "heavily" polluted beaches in western
Australia (Kovacs, 1959; Snow, 1959). In this case, a sewer
outfall pipe was located one mile from the bathing beach where
the typhoid outbreaks occurred and the sewer was overloaded
because of rapid population growth. Use of a log mean of 200
fecal coliform bacteria per 100 ml, with the provision that 10
percent of the total samples during a thirty-day period not
exceed 400 fecal collforms per 100.ml.', allows for variations 1n
environmental conditions such as shifts 1n wind direction,
current flow, and tidal fluctuations. At levels above the 200
fecal collforms per 100 ml the risk of exposure to pathogenic
microbes increases. Correlation between the fecal coliform level
and microbial pathogen levels is the Important relationship,
since the fecal collforms themselves serve as an indicator of the
quality of water in relation tQ^ fecally associated microbial
pathogens. Direct demonstration of the microbial pathogens is
not always feasible.
Detection of Salmonel1 a has shown that 1n fecally polluted
marine waters the level may vary between 1 and 1,000 per liter
(McCoy, 1964). Occurrences of viruses in ocean waters at levels
of 60 plaque-forming units (PFU) per liter have been found
477
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(Shuval, et al., 1971). It Is estimated that these values may
represent only 10 to 50 percent of the total viral pathogens
present because of the limited recovery efficiency of the
methods used. Also, other viruses associated with feces m^y be
present but may not grow in the tissue culture systems used.
Another Important consideration 1n determining the safe
microbiological criterion Is the minimum dosage necessary to
Infect a bather. As few as 3 to 5 organisms of.S,. typhosa have
been reported to cause Infection, whereas, 1 x 10^ to 1 x 107 cells
for other Salmonella serotypes may .be required to produce
disease. Similarly, massive concentrations of cells of
enteropathogenfc E. coli have been reported necessary to produce
infections in adult volunteers. Alteration of gastric function
either by raising the pH 1n the stomach or by facilitating
gastric emptying can reduce this dosage several orders of raaqnituds.
Kecent data fran experiments with adult volunteers indicate that the
infectious dose for Shigella flexaeri 2a 1s less than 200 calls
(Geldrelch, 1974). Although enteric viruses are found 1n
relatively small numbers 1n polluted waters, their occurrence
could be hazardous since the minimum Infective dbse for humans
has not been firmly established. For children, the minimum
infective dose may be 1 or 2 PFU (Plotkin and Katz, 1967), while
for adults the minimum infective dose may be the sane or higher.
478
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Howevar, less is known concerning the rninirral infective dosa for
pathogenic bacteria that cause ear/ eye, nose/ and throat aiiinents
(Geldreich, 2974).
Use of fecal coliform bacteria as a single parameter for
monitoring recreational water quality must ultimately relate to
the probable occurrence of watexborns pathogens. Currently, the
only relationship which has been developed between the fecal
col if or m indicator and waterborne pathogens is that of
Salroonella to fecal coliform density Data which have been
developed indicate a sharp increase in the frequency of
Salmonella detection when fecal coliform densities are above 200
organisms per 100 ml of freshwater. When there are over 200
fecal coliforms per 100 ml, Salmonella isolation should approach
100 percent frequency. Data from estuarlne waters were grouped
to include the level of 1 to 70 fecal coliforms that is of
interest to investigators of shellfish waters. For this range,
below 70 fecal cdliforms per 100 ml, only 6.7 percent of the 184
Salmonella examinations w-ere positive. At the 200 fecal coliform
level, the 28.4 percent occurrence of Salmonella in estuarlne
waters was essentially identical with data compiled from
freshwater environments. In polluted estuarlne waters containing
fecal coliforms ranging fro;n 201 to above 2,000, a recoyary of
479
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Salmonella was seen 60 percent of the time. The recovery rate of
Salmonella in estuarine waters is lower than that in fresh waters.
In fresh water, Salmonella were recovered 85 to 98 Dercent of the
time, in the range of from 201 to 2,000 fecal conforms. The
lower value for isolation of Salmonella from estuarine waters may
be related to limitations of Salmonella methodology (Geldreich,
1972). It must be noted that any projection of the qualitative
recoveries of Salmonella into a comparison with fecal coliform
quantification has recognized limitations. Such projections do
nevertheless suggest that the 200 fecal coliform per 100 ml limit
for recreational waters is a useful water quality value.
Evaluation of the microbiological suitability for- marine and
fresh waters should be based upon the fecal coliform
levels. As determined by either the multiple-tube fermentation
for marine water or the membrane filter method for fresh water,
and based upon a minimum of not less than five samples taken
over not more than a 30-day period, the fecal coliform bacterial
level should not exceed a log m-ean of 200 per 100 ml, nor
should more than 10 percent of total samples during any 30-day
period exceed[ 400 per 100 ml.
Shellfish
Shellfish, being filter feeders, require a high quality of
water in order to be micrcbiologically safe for human consumption
480
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as either raw or partially cooked. Fecal coliform bacteria,
other bacterial pathogens, and viruses found in water and
sediments are concentrated by shellfish, depending upon
temperature, density of pathogens, currents, depth, water
chemistry, and shellfish feeding activity (Van Donsel and
Geldre1Ach, 1971; Metcalf and Stiles, 1968). Once concentration
of pathogens occurs, flushing of microorganisms will not
necessarily occur at the sane rate (Janssen, 1974; Kelly and
Arcisy, 1954). Because of the established relationship between
coliform levels and enteric pathogens, shellfish waters
historically have been classified on the basis of total coliforTn
levels.
An attempt by the National Shellfish Program 'has bean mada to
correlate fecal coliform bacteria to enteric pathogens. Idsal1y9
any specific fecal coliform bacterial limit for shellfish should
be based on a correlation with pathogenic occurrences 1n the
aquatic environment and with epidemiological evidence of
increased health risk among shellfish consumers. However, thesa
data are not available and calculations have been based on health
risks incurred through increased pathogen occurrence in waters of
differing levels of fecal contamination. Recent data in
shellfish growing waters have shown that Salmons!1 a occurred 1n
4.7 percent of water samples having fecal coliform densities of 1
to 29 per 100 ml (Slanetz et al.9 1974). Oysters growing In
these v/aters accumulated from 33 to 2200 fecal coliform bacteria
481
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per 100 grains of shellfish meat, with Salmonella occurrence at
6.1 percent,
She! If 1sh contamination is intensified furtiter by ths noural
accumulation of watarbome organisms in bottom sediments through
the action of sedimentation. Investigation of both the overlying
water and bottom sediments from lakes and streams'has indicated
a 100- to 1000-fold increase 1n fecal coliform densities at the
water-sediment interface (Van Donsel and Geldrelch# 1971).
Enteric viruses (Coxsackle B3) in the bottom sediment of
shellfish-growing waters along the New Hampshire estuary have
been found when the fecal coliform densities were as low as 10
organises par 100 ml in tha overlying waters (Slanstz et al., 1955)
Indicators of fecal pollution more specific than the total
coliforms 1n shellfish waters have been sought. Candidate
organisms or groups of organisms include £. coli and the fecal
coliform group. The fecal co>.iforms have a higher positive
correlation with fecal contamination from all warm blocdad
animals than does E. co*l i (GeldreicTi* 1974) . -Usually cojj,, ,s
the most numerous bacterium of the fecal coliform gfjup; however,
under some conditions other..fecal conforms may predominate
(Sears et ajk» 1950). Analysis of data comparing tha correlation
of fecal cbllforns	and E. col 1 to fecal
coliform sourcas confirms tha fact that tha fecal coliforms.
482
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reflect sanitary quality of water. In comparing results of th«=> fecal
col 1 form test to thosa of the E. coli procedure in shellfish -waters, E.
col 1 was reported to range from 75 to 90 percent of the fecal
collform population with the fecal coll form bacteria giving a
95.6 percent correlation (Presncll, 1974). Therefore, the use of
the fecal coliform test avoids the undesirable risk of excluding
some fecal contamination.
The microbiological criterion for shellfish water quality has
been accepted by international agreement to be 70 total col 1 forms
per 100 ml, using a median MPM, with no more than 10 percent of
the values exceeding 230 total conforms. No evidence of
epidemiological outbreak from consumption of raw shellfish which
were grown in waters meeting this bacterid!ogical criterion has
been demonstrated. This standard has proven to be a practical
limit when supported by sanitary surveys of the growing waters#
acceptable quality in shellfish meats and good
epidemiological evidence. However, evidence from field
investigations suggests that not all total coliform occurrences
can be associated with fecal pollution (Gallagher, et al., 1959),
Thus, attention has been directed toward the adoption of the
fecal coliform test to measure more precisely the occurrence and
magnitude of fecal pollution in shellfish growing waters.
A series of studies was initiated by the National Shellfish
Sanitation Program and data relating the occurrence of total
483
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conforms to numbers of fecal col 1 forms were compiled.
Information was received from 15 States and 2 Canadian provinces
and was arbitrarily divided into 4 geographical areas:
northwest, southern states,-mid-Atlantic, and northeast. A total
of 3,695 coliform values and 3,574 fecal coliform values were
included 1n the tabulations. The prime objective was to
determine the correlation between the two indicator groups and
secondarily,to determine whether .or not coliform data could be
used as a basis for evaluation of a potential fecal coliform standard.
The data show that a 70 col 1 form MPN per 100 ml at the 50th
percentile was equivalent to a fecal•coliform MPN of 14 per 100 ml.
The data, therefore, indicate that a median value for a fecal
coliform stanaard is 14 and the 90th percentile shoulS not exceed 43
for a 5 tube^ 3 dilution method (Hunt and Springer, 1973).
Evaluation of the microbioloflical suitability of waters
for recreational taking of shellfish should be based upon the
fecal coliform bacterial	levels. When possible,
samples should be collected under those conditions of tide and
reasonable rainfall when pollution is. most likely to be maximum
in the area to be classified. The median fecal coliform value
should not exceed an MPN of 14 per 100 ml and not more than 10
percent of the samples should exceed an MPN of 43.
484
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REFERENCES CITED
Berg, G. 1574. Reassessment of the virus problem In sewage and
In surface and renovated waters. Sixth International Water
Poll. Res. California. Pergamon Press.
Bonde, G.J.,1966. Bacteriological methods for the estimation of
water pollution. Hlth. Lab. Sci. 3:124.
Bonde, G.J., 1974. Bacterial indicators of sewage pollution.
International Symposium on Discharge of Sswage froa Sea
Outfalls. Pergamon Press.
Butler» P., e£ aK , 1972. Test, monitoring and indicator
organisms. In: A Guide to Marine Pol lution, e.d. Goldberg, ed.
Gordon and Beach, N.Y.
Datta, N. and J. Olearte, 1974. R-Factors 1n strains of
Salmonella typhi and Shigella dysenteri I isolated during
epidemics 1n Mexico: Classificatlon by compatibil1ty.
Antimicrobial Agents and'Chemotherapy 5: 310.
Gallagher, T. P., et_ al_., 1969. Pollution affecting shellfish
harvesting in Mobile Bay, Alabama, Tech. Servs, F.H.P.C.A.
Southeast Water Lab., Athens, Georgia.
485
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Celdrelch, E.C., et al., lf^n. Fecal-coliforp-organism medium
for the membrane filter technique. Amer. Water Works Assn.,
51:208.
Geldreich, E.E. and B.A. Kenner, . 196*3. Concepts of fecal
streptococci in strean pollt'tion. t'our. Water Poll. Contr.
Fed. 41: R 33F.
Geldreich, E.F., 1^72. Fuffalo Laboratory recreational water
quality: A study in bacteriological data interpretation.
'Water Res. P:912.
.Geldreich, E.E., 1374. Microbiological criteria concepts for
coastal bathing v/aters. ncoar> '-Int. (In !>ress»)..
fieldreich, E.E., 1974. ''Honitori r*» marine waters for
microbiological quality. WPO Conference - Scientific Aspects
of Marine Pollution. Heneva Swi tzerland.
G =»ia, L. «1. 1972. Brief literature review of Klebsiella as
pathogens. In seninar on the ginni^icance of Efecal coliforns
in I ndtistrial Waste. E.P.r. T. P.. 3, ''atioaal P1eld
Investigations Center, Denver, Colo. n. "4.
Hunt, n.A. and «].. Springer, 1P74. Trelininary report on "A
comparison of total coliforri and fecal coliforn values 1n
486
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shellfish growing areas and a proposed fecal col 1 form growing
area standard. Presented at 8th National Shellfish
Sanitation Workshop. {FDA. Wash. 0*C•
Janssen, W.A., 1974. Oysters; Retention and excretion of three
types of human water-borne disease bacteria. Health Lab.
Scl. 11:20.
Kelly, C.B. and W. Arclsy, 1954. Survival of enteric organisms
in shellfish. Pub. Health Repts. 69:1205.
Kovacs, H., 1959. Enteric fever in connection with pollution of
seawater. Western Australia. Report of the Commissioner of
Public Health for the year 1958.
Metcalf, T.6. and W.C. Stiles, 1968. Viral pollution of
shellfish 1n estuary waters. Jour. San. Eng. D1v. Proc. Amer.
Soc. Civ. Eng. 94:595.
McCoy, J.H., 1964. Salmonella. 1n crude sewage, sewage effluent
and sewage polluted natural waters. Abs. In Water Poll. Res.
pp 205.
Moore,'B. 1959. Sewage contamination of coastal bathing waters
in England and Wales. Jour. Hyg., 57:435.
487
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Moore, B.» 1971. The Health hazards of pollution 1n microbial
aspects of pollution. Sykes and Skinner, Eds., Academ. Press.
London: pp 11-32.
Olearte, «J, and E. GaUndo, 1973. Salmonella typhi resistance to
chloramphenlcal, amphicllUn and other antimicrobial agents:
Strains isolated during an extensive typhoid fever epidemic
1n Mexico. Antimicrobial Agents and Chemotherapy 4:597.
Plotkln, S.A. and H. Katz, 1957. Minimal Infective dosas "of
viruses for wan'by the oral route, In: Transmission of Viruses
by the Water Routa.. g. Berg, Ed.,	John Wiley Intersclanca,
N..Y. p. 155.
Presnell, N„ 1974. Discussion of fecal coliforas for shallflsh
growing waters. Proc. 7th National Shellfish Sanitation Workshop
Oct. 21 - 22, 1971. Ratcliff and Wilt, Eds., FDA. Wash., D.C.
Reltler, P.. and R. Sel igaman, 1937. Pseudbmonas aeruqi nosa in
%
drinking water. Jour. Appl. Bact. 20:145.
Rlngero, L.H. and C.H. Drake, 1952. A study of the incidence of
Pseudomonas aerug.inosa fron various national sources. Jour.
Bact. 64:841.
488
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Scarp-!no, D., 1974. Human enteric viruses and bacteriophages as
indicators of sewage pollution. International Symposium from
Sea Outfalls. Pergamon Press.
Sears, H.J. ejt al_., 1950. Persistence of Individual strains of
Escherchla coll in the Intestinal tract of man. Jour. Bact.
59:293.
Shuval, H.J., et al .*, 1971. Natural 1nact1vation processes
of viruses in seawater. Proc. Natural Specialty
Conf. on Disinfection. Amer. Soc. of Civil Engineers, N.Y.
Slanetz, L.W., et al., 1965. Correlation of coliform and fecal
streptococci indices with the presence of Salmonella and
enteric viruses in sea water and shellfish. Adv. in Water
Pollution P>es. 2nd International Confr., Tokyo. 3:17.
Smith, R.S., et al., 1951. Bathing water quality and health. I.
Great Lakes (U.S. Public Health Service, Cincinnati, Ohio).
Smith, R.S. and T.D. Woolsey, 1952. Bathing water quality and
health. II. Inland river and pool. {U.S.,Public Health
*
Service, Cincinnati, Ohio).
489
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Smith, R.S. and T.D. Woolsey, 1951, Bathing water quality and
Public Health. III. Coastal Waters (U. S. Public Health
Service, Cincinnati, Ohio).
Snow, D.J.R., 1959. Typhoid and City Beach. Western Australia.
Report of the Commissioner of Public Health for the Year
1959, p. 52.
Stevenson, A.H., 1953. Studies of bathing water quality and
health. Amer. Jour. Public Health 43:529*
m ¦
Taylor, E.W., 196S. Forty-second-report of Director of Water
Examination, 1965-66," Metropolitan Wa'ter Board, London., p.
117.
Van Donsel, D.J. and E.E. Geldreich, 1971. Relationships of
Salmonel lae to fecal coliforms in bottom sediments. Water
Res. 5:1079.
Wolf, H.W., 1972. The col 1 form count as a measure of water
quality. In Water Pollution Microbiology. R. Mitchell, Eds.>
Wiley-Interscience.
490
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E?A 430/3-74-010
TECHNICAL BULLETIN	

% Pn0«°
JULY 1974
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Water Program Operations
Washington, D.C. 20450
491
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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER PROGRAM OPERATIONS
TECHNICAL BULLETIN
PROTECTION OF SHELLFISH WATERS
The Federal Water Pollution Control Act Amendments of 1972
establish an extensive program to upgrade the quality of our Nation's
waters. The program of Federal grants for construction of munici-
pal wastewater treatment plants will have significant benefits in
reducing pollution and improving water quality. The effluents from
many municipal plants could impact on shellfish waters, with serious
potential for public health and local shell-fishing industries. As these
plants are upgraded through the EPA construction grants program,
it is essential that project designs include provisions for protection
of shellfish waters.
This Technical Bulletin, which supplements the "Federal Guide-
lines: Design, Operation, and Maintenance of Wastewater Treatment
Facilities", is a compilation of information to provide a high degree
of reliability in the protection of shellfish waters. Much of the Bulletin
is based on existing information from publications of the Environmental
Protection Agency and the Food and Drug Administration. .
EPA Regional Administrators will work closely with the Food and
Drug Administration to reasonably determine if completed project
designs provide a level of protection which meets the objectives of
this bulletin. In some cases the need for construction of additional
reliability features may be identified and appropriately accomplished
in a project subsequent to the one being reviewed. By July 1975 it
is anticipated that designs will be in accordance with the bulletin and
routine project review by the Food and Drug Administration would
not be necessary.
The Bulletin will be revised from time to time as additional
information becomes available. All users are encouraged to submit
suggested revisions and information to the Director, Municipal
Construction Division (WH-447), Office of Water Program Operations,
Environmental Protection Agency. Washington. D.C. 20460.
James L. Agee
Assistant Administrator
for Water and Hazardous Materials
492
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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER PROGRAM OPERATIONS
TECHNICAL BULLETIN
PROTECTION OF SHELLFISH WATERS
Purpose:
The purpose of this bulletin is to ensure that maximum protection
is provided for shellfish waters receiving effluent discharged from
municipal wastewater treatment works proposed for an EPA construction
grant.
Applicability:
This bulletin applies to projects which could affect shellfish waters.
Relationship to National Shellfish Sanitation Program:
The National Shellfish Sanitation Px'ogram (NSSP) is a voluntary
cooperative program conducted by the Food and Drug Administration (FDA)
of the U.S. Department of Health, Education, and Welfare and 23 coastal
States and the shellfish industry. NSSP requirements are contained in
the National Shellfish Sanitation Program Manual of Operations, Part I,
Sanitation of Shellfish Growing Areas (1955). This bulletin provides
guidelines for design of publicly owned treatment works to meet the
objectives of the Manual of Operations.
Definitions:
The following definitions apply to the terms used in this bulletin:
Shellfish: Molluscan shellfish species of oysters, clams, and
mussels. 3s used in this bulletin, the term does not include other
species, such as crabs, lobsters, shrimp, or scallops.
Shellfish Waters: Any waters which are classified by the State
as either shellfish growing waters or potential shellfish growing
waters.
Shellfish Growing Waters: Waters classified by the State as ac-
ceptable for commercial or recreational harvesting of shellfish. In
the manual of operations these are classified as either Approved or
Conditionally Approved growing areas.
493
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Potential Shellfish Growing Waters:1 Waters classified by the State
as not presently acceptable for coxrimercial or recreational harvesting
of shellfish, but which the State plans to make acceptable in the future
by improving certain conditions. In the NSSP Manual of Operations
these would be presently classified as either Restricted or Prohibited
growing areas. To be in this category, the waters must have been
formally classified by the State as potentially meeting the approved
shellfish growing water quality requirements for the production of
shellfish.
Background;
These guidelines are necessary because of the public health hazards
resulting from the harvesting of edible moluscan shellfish from waters
subject to discharge of pollutants. Shellfish are known to concentrate
pollutants from the aquatic environment. The quality of the shellfish
is directly related to the quality of the overlying waters. In the past
there have been numerous typhoid fever and infectious hepatitis out-
breaks associated with the consumption of sewage contaminated
shellfish. Since shellfish are frequently eaten uncooked or partially
cooked, their habitat must be protected to preclude contamination
and the resultant health hazard.
Action to be taken by the grant applicant:
1.	Determine if the proposed project could affect shellfish waters. ,
Some projects clearly could never affect shellfish waters, and this
bulletin does not apply to such projects. Assistance in making this
determination is available from the State water pollution control agency
and the EPA Regional Administrator.
2.	Assess the impact of the proposed project on the shellfish
waters. This is accomplished during the facility planning phase (see
Section 35. 917, 40 CFR 35). Coordination with environmental
protection authorities, shellfish regulatory agencies (Appendices 1
and 2), and local interests must be initiated early in the project
planning. The assessment of total impact, and screening of alterna-
tives for cost-effectiveness analysis (40 CFR 35, Appendix A) will
include, but is not limited to, the determination of the following:
a.	Location of the effluent discharge in relation to the
shellfish waters.
b.	Volumes of wastewater.
c.	Effluent quality expected under normal and adverse
conditions. Includes bacterial quality, substances
2
494
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2
that could be toxic (such as heavy metals or pesticides),
or other materials which could adversely affect public
health.
d.	Estimates of the effect on the shellfish waters of combined
sewer overflows or other uncontrolled discharges from the
treatment works. Provide information on rainfall frequency,
duration, and intensity, or other conditions, which cause
overflows, bypasses, or significant reductions in treatment
efficiency, and the locations in the project system where
these conditions will occur.
e.	A summary of NPDES municipal permit information on
wastewaters introduced into the municipal system by
industrial users.
f.	The reliability of the processes and equipment included in
the project, including an estimate of the frequency of
adverse conditons affecting the shellfish waters and
measures included in the project to increase reliability
of wastewater treatment works performance or provide
containment of potentially adverse discharges.
g.	An evaluation of dilution, dispersion, mixing, thermal
effects, and seasonal variations affecting the shellfish
waters as a result of the proposed project.
h.	Relate the present shellfish water conditions to those
conditions expected during and after construction of the
project. Information on the existing shellfish water
conditions is available from environmental protection
authorities, shellfish regulatory agencies, and public
health departments.
3. Estimate the size of a closed safety zone around the outfall
site. The closed safety zone is a designated portion of the shellfish
waters adjacent to a source of contamination (such as an outfall) in
which harvesting of shellfish would be prohibited. The closed
safety zone is required by the NSSP Manual of Operations between
conditionally approved growing areas and the source of pollution,
and is subject to review and approval by environmental protection
authorities and shellfish regulatory agencies. There is a two-fold
objective in designating the closed safety zone. Both objectives are
related to the time required for pollutants to travel from the source
of pollution, through the closed safety zone, to the shellfish growing
areas. One objective is to ensure public health is protected by
495
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preventing pathogen contamination of shellfish waters from normally
operating treatment works. Mixing, dilution, and natural pathogen
die off occur as the pathogens trariverse the closed safety zone and
the pathogen concentrations are decreased accordingly. The objective
is achieved by defining the closed safety zone so that the pathogen
concentrations beyond the zone are at acceptable levels under normal
operating conditions. The second objective is to provide the time
necessary for notification to cease harvesting in the shellfish growing
waters following a malfunction in the wastewater treatment works.
Define a closed safety zone to provide the required safety factor
for both objectives. The factors to be considered in determining
the boundaries for a closed safety zone are:
a.	For normally operating wastewater treatment works:
(1)	The maximum concentration of contaminants (usually
coliform bacteria) expected in the effluent before an
emergency response plan is activated.
(2)	Time and distance from the discharge point for the
effluent containing the maximum expected concentration
of contaminants to be reduced to permissable levels,
considering dilution expected under adverse conditions
in the receiving waters (e.g., high stream flows and
spring tides which result in minimum time of flow
to the boundary and reduced salinity).
b.	For a malfunction in wastewater treatment works:
(1) The total time it would take for the wastewater treat-
ment works operator to detect a malfunction, notify the
shellfish regulatory agency, and for the agency to
stop shellfish harvesting. Due consideration should be
given to adverse conditions such as time of occurrence
(weekend, holiday, or at night), the areas to be covered,
and the methods of communication. In some cases
instrumentation and alarms beyond the level established
in this Technical Bulletin can be provided to reduce
the time required to notify the shellfish regulatory agency
of a malfunction.
4
496
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(2)	The reliability of wastewater treatment works. See
paragraph 4b of this bulletin.
(3)	The travel time for flow from the points of discharge
to the Conditionally Appoved growing areas. Adverse
conditions which will reduce travel time, such as
river stage or tides, will be considered. Allowance
must also be made for the expected degree of mixing.
(4)	The safety factor to be provided. Normally the travel
time through the closed safety zone should be twice
the time required for the notification process to become
effective. Where this is not feasible, provide in-
creased reliability or storage.
c. Each of the above factors has some variability. Analyze
these factors and determine the optimum combination to
ensure protection of public health, preserve valuable
shellfish growing waters, and provide for cost-effective
wastewater treatment works.
4. Base the wastewater treatment works design on the following
guidelines:
a.	Federal Guidelines: Design, Operation, and Maintenance
of Wastewater Treatment Plants.
b.	Technical Bulletin "Design Criteria for Mechanical, Electric,
and Fluid System and Component Reliability, " .EPA-430-99-
74-001. Shellfish waters will be Reliability Class I. When
conditions warrant (e. g., proximity of shellfish beds,
unusual chlorine demand variations, excessive wet
weather flows) a degree of reliability higher than described
in EPA-430-99-74-001 may be needed. This could include
increased disinfection contact time, larger holding basins,
or equipment redundancy.
c.	Discharges in close proximity to shellfish harvesting areas
should be avoided. Where such dischargers are unavoidable,, .
the applicant should contact environmental protection authori-
ties and shellfish regulatory agencies for guidance.
d.	Where the effluent discharge will be to waters designated
by the State as potential shellfish growing waters, the
5
497
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criteria will either be incorporated in the design or
provision will be made to incorporate them by future
modifications to the -wastewater treatment works. The
course of action to be followed will be based on the
timing of planned actions to upgrade the shellfish waters.
e. Disinfection System. Effluent disinfection performance
requirements are contained in the municipal NPDES
permit. The permit is based on the EPA secondary
treatment information (40 CFR 133), but more stringent
requirements may be imposed for other conditions, such
as water quality related to shellfish waters. Shellfish safety
is closely related to reduction of pathogenic micro-organisms.
Thus, the disinfection system must be designed to achieve
high effectiveness and reliability. The following requirements
apply where chlorine is used as the disinfectant. Other
disinfectants are acceptable provided a level of performance
and reliability comparable to chlorination is attained.
(1) The sanitation requirements for approved shellfish
growing areas are given in the following quotation from
the NSPP Manual of Operation:
"Growing areas may be designated as approved when:
(a) the sanitary survey indicates that pathogenic micro-
organisms, radionuclides, and/or harmful industrial
wastes do not reach the area in dangerous concentration,
and (b) this is verified by laboratory findings whenever
the sanitary survey indicates the need. Shellfish may
be taken from such areas for direct marketing.
"Satisfactory compliance. -- This item will be satis-
fied when the three following criteria are met:
(a)	The area is not so contaminated with fecal material
that consumption of the shellfish might be hazardous,
and
(b)	the area is not so contaminated with radionuclides
or industrial wastes that consumption of the shell-
fish might be hazardous (see section c item 7 in the
Manual of Operation, regarding toxins in shellfish
growing areas), and
(c) the coliform median MPN of the water does riot
exceed 70 per 100 mil., and not more than 10
percent of the samples ordinarily exceed an
6
498
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MPN of 230 per 100 ml. for a 5-tube decimal dilution
test (or 330 per 100 ml., where the 3-tube decimal
dilution test is used) in those portions of the area most
probably exposed to fecal contamination during the most
unfavorable hydrographic and pollution conditions.
(Note: This concentration might be exceeded if less
than.8 million cubic feet of a coliform-free dilution
water are available for each population equivalent
(coliform) of sewage reaching the area). The fore-
going limits need not be applied if it can be shown,
by detailed study that the coliforms are not of direct
fecal origin and do not indicate a public health hazard.
This MPN value is based on a typical ratio of coliforms
to pathogens and would not be applicable to any situation
in which an abnormally large number of pathogens might
be present. Consideration must also be given to the
possible presence of industrial or agricultural wastes
in which there is an atypical coliform to pathogen ratio."
(2)	Maintain an adequate chlorine residual in the chlorine
contact chamber to ensure that the bacteriological
requirements are not exceeded in the effluent or shellfish
waters. Because of insufficient data available to relate
effluent bacteriological quality and chlorine residual
and variatons in types and strengths of wastewater, no
specific chlorine residual is recommended.
(3)	Provide sufficient chlorinator capacity to continuously
maintain adequate disinfection with the largest unit
out of service. Disinfection must be continuous during
container and/or chlorinator changeover.
(4)	Chlorine Contact Tank
(a)	Premixing - Rapidly and thoroughly mix the chlorine
with the wastewater before entering the chlorine
contact chamber.
(b)	Contact chamber - Design the chlorine contact
chamber for a contact time of at least 30 minutes
at the peak hourly flow rate. Additional contact
chamber capacity or flow equalization may be
necessary where there are unusually high peak
flow rates.
7
499
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Design the chlorine contact chambers in accordance
with Paragraph 212.1. 9 of Technical Bulletin "Design
Criteria for Mechanical, Electric, and Fluid System
and Component Reliability, " EPA 430-99-74-001.
Chambers should be designed to produce, as nearly
as possible, a plug flow condition (plug flow occurs
when each increment of flow is in the chamber for a
time equal to the theoretical detention time). The
design will include adequate measures to minimize
short circuiting, stratification, and stagnation
zones. Velocity variations within the chamber will
be minimized.
(c) Outfalls - conduits conveying effluent will not normally
be considered as part of the required chlorine contact
chamber. One exception could be where the chlorine
residual is continuously monitored at the end of the
portion of conduit used for contact chamber.
(5)	The chlorine residual in the effluent after detention in
the chlorine contact chamber (or other conduit) will
be continously monitored and recorded.
(6)	Provide an alarm for low chlorine residual in the
effluent. Additionally, depending on the size of the
plant, proximity to the shellfish beds, and other
safety factors, alarms may be required as indicated
in Paragraph 243 of Technical. Bulletin "Design Criteria
for Mechanical, Electric, and Fluid System and Component
Reliability," EPA 430-99-74-001. Examples of such
alarms are:
(a)	Disinfectant container depletion.
(b)	Low chlorine water pressure.
(c)	Automatic changeover.
(7)	Design alarm circuits to indicate circuit malfunctions.
5. Include the following in the operation and maintenance manual for
a facility which could affect shellfish waters:
8
500
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a.	Definition of the types of incidents or malfunctions to be
reported to the shellfish regulatory agency and the maximum
acceptable time for accomplishing this report,
b.	An emergency response plan, including procedures to be used
to make reports to the shellfish regulatory agency.
c.	Recommended frequency of laboratory check tests to verify
performance of analyzers such as chlorine residual
indicator and recorder.
d.	Recommended frequency and types of laboratory tests re-
quired for monitoring coliform bacteria.
References:
1.	"National Shellfish Sanitation Program Manual of Operations,
Part I, Sanitation of Shellfish Growing Areas", 1965 Revision,
U.S. Department of Health, Education and Welfare, Public
Health Service.
2.	EPA-430-99-74-001, Design Criteria for Mechanical, Electric,
and Fluid System and Component Reliability, 1973. , Office of
Water Program Operations, EPA.
Technical Assistance:
Criteria and technical assistance for specific problems may be
obtained from local or State environmental protection authorities or
agencies concerned with the protection of shellfish wates. Additionally,
assistance if available from the following offices:
1.	Environmental Protection Agency Regional Offices
2.	Shellfish Regulatory Agencies: (Appendix A)
3.	Food and Drug Administration: (Appendix B)
501
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m 1977
MAINE HISTORIC PRESERVATION COMMISSION
31 WESTERN AVENUE
AUGUSTA, MAINE 04330
Earle G. Shettleworth, J a.
Director
Arsa Code 207
289-2133
January 19, 1977
Mr. Wallace E. Stickney, Director
Environmental Policy Coordination Office
United States Environmental Protection Agency, Region I
J.F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. Stickney:
In response to your recent request, I have reviewed your
agency's new alternative action plan for the sewage treatment in
Scarborough. I find that this proposal will have no effect upon
any structure or site of historic, architectural, or archeolog-
ical significance as defined by the National Preservation Act of 1966
If I can be of further assistance concerning this matter, please
do not hesitate to let me know.
Sincerely
Earle G. Shettleworth, Jr
State Historic Breservation Officer
502
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"V
~

MAINE HISTORIC PRESERVATION COMMISSION
31 WESTERN AVENUE
AUGUSTA, MAINE 04330
Earle G. Shettlewobth, Jr.
Director
Area Code
289-2133
% DEC 1976
December 2, 1976
Mr. John A. S. McGlennon, Regional Administrator
U.S. Environmental Protection Agency, Region I
Environmental Policy Coordination Office
John F. Kennedy Building, Room 2203
Boston, Massachusetts 02203
Dear Mr. McGlennon:
In reply to the "Analysis of Alternative Systems
for Wastewater Collection and Treatment in Scaroborough,
Maine: Supplement to the Draft Environmental Impact State-
ment of January 1976, I have reviewed the proposals from
the standpafat of Historic, Architectural, and Archeological
resources. I find that these proposals will have no effect
on the above resources.
Sincerely
State Historic Preservation
Officer
503
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MAILING ADDRESS:
COMMANDER
FIRST COAST GUARD DISTRICT
150 CAUSEWAY STREET
BOSTON. MASS. 02114
Tel: (617) 223-6915
4 November 1976
'United States Environmental Protection Agency
Region I
J. F. Kennedy Federal Building
Boston, Massachusetts 02203
Re: Draft Environmental Impact
Statement for the Cranston,
Rhode Island Wastewater
Treatment and Collection
Facility
Gentlemen:
DEPARTMENT OF TRANSPORTATION
UNITED STATES COAST GUARD
$ JilOV 19/::
After having reviewed the above referenced statement, the United
States Coast Guard does not have any comment to make concerning the
project.
This office does request to remain fully informed'the future
status of the project.	/
Sincerely,
W. FOLGER
Captain', U. S. Coast Guard
Chief, Uapiiie Safety Division
By direction of the Commander,
First Coast Guard District
504
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UNITED STATES DEPARTMENT OF COMMERCE
The Assistant Secretary for Science and Technology
Washington. D.C. 20230
November 12, 1976
Mr. John A. S. McClennon
Regional Administrator
U. S. Environmental Protection Agency
Region I
Environmental Policy Coordination Office
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
Dear Mr. McClennon:
This is in reference to your supplement to your draft
environmental impact statement entitled "Wastewater
Collection and Treatment, Scarborough, Maine." The
enclosed comments from the National Oceanic and
Atmospheric Administration are forwarded for your
consideration.
Thank you for giving us an opportunity to provide these
comments, which we hope will be of assistance to you. We
would appreciate receiving six (6) copies of the final
statement.
Sincerely,
uepucy Assxscanc secretary
for Environmental Affairs
Enclosure - Memo, Office of Coastal Zone Management,
November 3, 1976

-------
U.S. DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
Rockville, Md. 20852
~ate
November 3, 1976
Reply to Attn, of:
To
William Aron
EE
From
Robert Kifer
OCZM
-fiA-
j/C.
Subject: Supplement to DEIS - 7601.06— WASTEWATER COLLECTION & TREATMENT
SCARBOROUGH, MAINE
The Office of Coastal Zone Management again finds the proposers
did not discuss Maine's participation in the Coastal Zone Management
Act, nor investigate conformity of the action with any stated CZM
goals. However,the Maine CZM lead agency will provide comments
through the A-95 review process.
506
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UNITED STATES
DEPARTMENT OF THE INTERIOR
FISH AND WILDLIFE SERVICE
Post Office and Courthouse Building
BOSTON, MASSACHUSETTS 02109
Mr. Clifford H. Goodall
NOV 5 1976
15 Western Avenue
Augusta, ME 04330
Dear Mr. Goodall
Thank you for your letter of October 7, 1976 detailing the Scarborough
Sewerage Treatment Plant situation and the potential impact of the facility
on the Rachel Carson National Wildlife Refuge.
I appreciate your interest and concern in this matter. The Fish and
Wildlife Service will review and comment on this Environmental Impact
Statement. In addition, because of our vested interest in the Refuge, we
have offered our assistance to the Environmental Protection Agency in
preparing this EIS. A copy of our letter is enclosed.
If you have any further input regarding this matter, please contact
Mr. Mel Evans of our Concord, NH office. Thank you.
Sincerely yours
C
&CTINci Regional Director
^T'O/v

l- ~ < w •>
% (¦ ^

508
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COASTAL ENVIRONMENT ASSOCIATION, INC.
TWO SANCTUARY LANE
SCARBOROUGH, MAINE 04074
Comment on September 30, 1976
Supplemental Environmental Impact Statement
for Scarborough, Maine Wastewater Treatment System
Coastal Environment Association, Inc. is a non-profit corpora-
tion devoted to intelligent land use decisions in the coastal
Mainejand Scarborough regions and the prevention of adverse envi-
ronmental effects on the coast of Maine. jsThe Association has
carefully examined the September 30, 1976 Supplemental Environmental
Impact Statement for Scarborough's proposed wastewater collection
and treatment systems and wholeheartedly supports Alternative FjJ
full transfer to South Portland, as the best possible method, from
an environmental, as well as economic standpoint, of treating
Scarborough1s sanitary waste. [The selection of any other alternative,
including Alternative A, would penalize the citizens of Scarborough
and coastal Maine by promoting a waste treatment system which raises
serious public health questions and jeopardizes the safety of some
of Maine's finest bathing beaches without any corresponding economic
benefit?^
The following detailed comments are submitted for inclusion in
the record of comments on the Supplemental Environmental. Report
prior to the November 22, 1976 deadline.
ENVIRONMENTAL IMPACT. Of the three principal alternatives
which the Environmental Impact Statement (EIS) considers feasible,
Alternatives A, C, and F, only Alternative F avoids a discharge
into waters of the cleanest classification as established by the
Maine Department of Environmental Protection and Legislature of the
509
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-2-
State of Maine. Most of Scarborough's beaches and shorefront areas
are in Classes SA, SB-1 or SB-2. These waters, according to 38 M.R.S.A.
§364:
"Shall be suitable for all clean water usages,
including water contact recreation, and fishing.
Such waters shall be suitable for the harvesting
and propagation of shellfish and for a fish and
wildlife habitat."
The Fore River in South Portland, where the discharge would take
place under Alternative F, is classified in Class SC, which is the
next-to-lowest water classification in the State of Maine, a classi-
fication which does not require that the water be safe for "water
contact" nor that the waters shall be suitable for the harvesting
and propagation of shellfish.
j^With respect to discharge into the Fore River, the EIS states
at p. V-15 that recreational opportunities in the Fore River"are
limited because of the existence of commercial facilities such as
oil storage and transfer terminals." The bathing beaches, clam flats
and productive shellfish areas of Scarborough are sharply contrasted
with the "oil storage and transfer terminals"of the Fore River. It
does not make sense to allow a discharge into the high classification
waters of Scarborough when the sensible alternative of transfer to
South Portland exists.^
^It makes even less sense to tolerate discharge into the waters
of Scarborough when the EIS recognizes a potential for
the effluent to reach Scarborough's beaches and public concern about
live viruses remaining in the effluent and creating a health hazard
at the beaches, (p. IV-6; 7)^
The Coastal Environment Association does not believe that any
chances can be taken with the health of man and his ecosystem. In
510
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-3-
the case of any discharge other than into the Fore River under
Alternative F, insufficient data exists to determine the degree
of health risk; and, therefore, such risk must be considered very
real and present, jjhe EIS clearly and convincingly states:
"Because of the lack epidemiological data,
the degree of health risk from such effluent
discharge cannot be determined." (p. IV-7)
"Potential threat to public health results
from the viruses remaining in the treated
effluent and reaching public bathing areas.
Because of the lack of flow data, the
ultimate destination of the viruses from
the effluent discharge location is uncertain."
(p. V-20£3
Because the ultimate destination of the viruses from the effluent
discharge locations would be uncertain, the tequirement that
the water of Scarborough's bathing beaches be satisfactory for
primary water contact would be endangered.^In the well known
Water Quality Criteria, authored by a Subcommittee of the National
Technical Advisory Committee to the Secretary of the Interior (1968),
the Subcommittee defined "primary contact recreation" as:
"Activities in which there is prolonged and
intimate contact with the water involving
considerable risk of ingesting water in
quantities sufficient to pose a significant
health hazard."
If, in fact, the EIS is correct and the destination of viruses is
uncertain, then everything possible must be done to prevent those
viruses from contaminating Scarborough's beaches, which the Legislature
of the State of Maine have mandated should be safe for primary water
contact recreation.
In addition to the effects on man, viruses and bacteria from the
discharge could damage the highly productive wetland areas on
Scarborough's coast. According to the Maine Department of
511
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-4-
Environmental Protection:
"Research has shown that the value of wetlands
for food production is tremendous; that, in
fact, they are among the most naturally pro-
ductive areas in the world. Nearly two-thirds
of all fish caught on the continental shelf
have spent some portion of their lives in
wetland areas. These fish represent 90% of
the total U.S. offshore catch." (Protecting
Your Coastal Wetlands, Maine Department of
Environmental Protection)
All the risks outlined above to man and his environment can be
avoided through Alternative F; all of these risks continue,
impossible of precise evaluation and determination if any other
alternative is selected.
It should also be noted that the selection of Alternative A
or any other alternative which would allow even treated viruses to
exist in the waters of Scarborough presents an enormous health
hazard in the event of a breakdown or malfunction in the treatment
system. In the event of such a malfunction or breakdown, untreated
sanitary waste, the most significant potential source of waterborae
pathogens capable of infecting man, would exist in Scarborough's
waters. Sanitary waste from warm blooded animals, including man,
have led to cholera, typhoid, leptospirosis and other diseases.
(Water Quality Criteria, p. 12) Thus, even if an indeterminate
health risk exists with a perfectly operating treatment system,
a clear and present risk exists if any malfunction whatsoever occurs.
OTIIP.R""ENVIRONMENTAL EFFECTS. _The Selection of Alternative F,
as opposed to other alternatives, would eliminate many other primary
and Secondary environmental hazards as outlined by the EIS.
A -discharge off the Scarborough coast would involve potential
outfalls at Higgins Beach, Prout's Neck or Grand Beach (p. II-5).
512
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-5-
These outfalls would have to extend far enough into the ocean to
insure possible dispersal of pollutants and protection of bathing
areas. A distance of 600 feet has been suggested (p. III-2)
which would require dredging of the ocean bottom to lay the outfall,
as well as rocks and ledge excavation and blasting, especially in
the Prout's Neck area. Selection of Alternative F would avoid the
adverse environmental impact of blasting and dredging to create an
outfall line by using the alredy existing outfall in the Fore River.
Although the EIS indicates that some detrimental effects of blasting
and excavation could be avoided by undertaking those activities
during certain seasons, no analysis whatsoever is given to the
problems caused by blasting on water fowl, fish habitats, spawning
grounds and benthic species.
Selection of Alternative F would allow, at no extra cost,
addition of wastewater from the Pleasant Hill area to the collection
system as it approaches Highland Avenue in South Portland. No other
alternative determined feasible by the EIS would allow the addition
of the Pleasant Hill wastewater at no further cost0
Selection of an alternative which does not involve a discharge
into Scarborough's waters would avoid the necessity of disinfection
by chlorine or other method in order to treat viruses. Recent
studies have indicated that disinfection itself can lead to health
problems both to man and aquatic life. See Disinfection of
Wastewater, EPA Task Force Report, March 1976.
Alternative F is the sole alternative which would have only a minor
secondary environmental impact from growth induction because all
other alternatives involve a greater extent of gravity sewers through
undeveloped areas, thus promoting development potential as a result of
513
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-6-
the greater economies involved in connection to a gravity sewer,
(p. V-16)
The selection of Alternative F, the only alternative which
does not involve, construction of a waste treatment facility in
Scarborough, will avoid numerous adverse environmental impacts
associated directly with the construction and existence of a
physical plant:
1.	During construction of a waste treatment facility, vehicles,
noise, dust and other construction activities would be avoided.
2.	The location of a treatment plant will involve some continuing
odor in areas of raw sewage pumping stations, sludge de-watering areas
and truck loading areas.
3.	Some continuing noise impact caused by hydraulic pumps and
electric motors will be continually present during operation of a
treatment system.
ECONOMIC CONSIDERATIONS. Given the clear conclusion that Alternative F
presents virtually no possibility of adverse environmental effect
in comparison with the potentially great environmental impact of the
other alternatives, the only conceivable justification for some
alternative other than F would be if such other alternative was
overwhelmingly more attractive on a cost-benefit analysis. A review
of the EIS reveals, however, that Alternative F is also the least
expensive alternative of those considered.
Since the Greater Portland Council of Governments concluded from
its "Scarborough Community Attitudes Survey Results" that most persons
"would like Scarborough to experience a slow rate of growth in the
future" Ariy comparison of economic advantages or disadvantages of
a given alternative should necessarily focus on the "low growth"
514
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-7-
scenario. The table set forth on p. IV-3 of the EIS indicates a
lower capital outlay for Scarborough, as well as lower total capital
artK>vir.ization and operation and maintenance costs. These costs, when
translated into a per capita cost for Scarborough residents, obviously
reveal lower per year, per capita cost for AlternativeF than any
other alternative.
In addition to the clear fact that Alternative F is less
expensive than any other alternative by use of the figures that are
presented on p. IV-3, it is also important to consider that the
environmental risks raised and undetermined with respect to virus
transport and bacteriological health hazards, should mandate advanced
waste treatment as discussed on pp. V-2 - V-6. Advanced waste
treatment would only be necessary in the event of a discharge near
Scarborough's beaches and if an alternative is selected which would
involve such discharges would add a capital cost of $1, 649,000,
$236,000 per year to treatment plant operation and maintenance and
a resultant annual added per capita cost of $6.70. Since some
question is raised as to the effectiveness of the proposed disinfec-
tion methods, the suggested alternative disinfection techniques of
increased chlorine dosage and additional detention time would add a
capital cost of $325,000 and operation and maintenance costs of $144,000
per year, "for a total yearly cost in addition to standard chlorine
disinfection of $151,000. Use of ozone instead of chlorine for
maximum virus reduction would similarly add $35,000 per year.
All of the costs associated with alternative wastewater disinfec-
tion methods and advanced wastewater treatment would seem necessary if
maximum reduction of health risks is sought. It is estimated that
per capita costs for these alternative and advanced treatment methods,
515
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-8-
necessary with every alternative other than F would cause a per
capita cost for Alternative A of approximately twice that of
Alternative F.«
Finally, it is essential to realize that costs provided for
serving the communities of Scarborough, Old Orchard and South
Portland are only certain in one respect—the cost of the South
Portland plant which is already built. Assuming that a plant in
Scarborough could not be built for several years, and assuming an
inflation rate of 10% per year (which is common in the construction
industry) an extra $1,500,000 should be added to the cost of treat-
ment by Scarborough alone, which would not be incurred by using an
already constructed plant in South Portland.
A great deal of time could be devoted to many of the uncertain
economic conclusions and factual bases in the EIS. Because the
concerns of the Coastal Environment Association, Inc. are principally
environmental, it should be sufficient from those comments already
made to conclude that no significant cost benefit outweighs the
environmental harm which any alternative, other than Alternative F,
would inflict upon Scarborough.
* With respect to "per capita" cost figures, such figures in the
EIS were apparently arrived at by dividing the total of "combined
amortized capital and O&M" costs by the projected year 2000
low growth population for Scarborough consent areas. This is not a
particularly revealing concept. In order to accurately gauge the
economic impact on Scarborough residents, the opportunity to know
the approximate cost per household must be afforded. Additionally,
the per capita cost, since it excludes construction, capital cost and
operation and maintenance of the collection system, does not cover all
the cost elements which would make up the charge per family. An
examination of the original Draft EIS demonstrates that use of collec-
tion system figures would nearly double the cost per household.
516
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-9-
POLITICAL AND ADMINISTRATIVE FEASIBILITY, In only one area does the
EIS indicate some disadvantage to Alternative F over a plant built
and maintained in Scarborough alone. In terms of political and
adminstrative feasibility, the EIS seems to indicate that the
question of negotiations between Scarborough and South Portland could
delay implementation of Scarborough's treatment plant and cause
political disadvantages as a result of relinquishing control over
sewerage management. In light of the extreme risk to human and
animal life and health caused by alternatives other than Alternative F,
it would seem that questions of political control and expediency
should be considered of virtually no consequence. Politics cannot
be given paramount concern over environmental well-being and putfllic
health and safety.
The EIS, however, does not mention one very important fact
which would seem to negate any inference of delay caused by the
need for negotiations between South Portland and Scarborough. The
Scarborough treatment system is several years away and South
Portland's system is now available. It would take years of negotiating
delay to compensate for the fact that when those negotiations are
finally concluded, the South Portland system would be ready, willing
and able to receive Scarborough's waste, as opposed to the Scarborough
system which is not even under construction at the present time.
Thus, it seems clear that no realistic time delay should be used
as an argument against Alternative F.
Additionally, there are many reasons why it would be to the
mutual benefit of Scarborough and South Portland to join forces in
waste treatment. Some of these reasons are set forth on P. V-18 and
they should be considered in connection with the overriding value of
517
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-10-
regional treatment - economies of scale, operation and maintenance
efficiencies and avoidance of duplicate services. All of these
factors should lead reasonable men from both communities to conclude
that joint treatment is far more feasible than separate facilities;
and, therefore, expedite initiation and conclusion of negotiations.
Despite the intimation in the EIS that there may be some
local concern over giving up control of the treatment system,
it should be emphasized that the Maine Legislature has long
recognized that cooperation between municipalities for the
treatment and disposal of sewage should be encouraged.
38 M.R.S.A. §1157 states as follows:
"Any sanitary district formed under this
chapter is authorized to contract with persons,
corporations,, districts and other municipalitiesj
both inside and outside the boundaries of the
district, and with the State of Maine and the
United States Government or any agency of either,
to provide for disposal of sewage and commercial
and industrial waste and storm and surface water
through the district's system and through the
system of any such person, corporation, district
or other municipality; and every other district
and municipality of the State of Maine is author-
ized to contact with such sanitary district for
the collection, distribution, treatment and 1
disposal of sewage and commercial and industrial
waste and storm and surface water, and for said
purposes any such municipality may raise money
as for other municipal charges."
Finally, and perhaps most important with respect i:o the
role of the Environmental Protection Agency in determining
the most satisfactory environmental alternative is the clear
intention of Congress as stated in the 1972 amendments to the
Federal Water Pollution Control Act, 1201(c);
"To the extent practicable, waste treatment
management shall be on an areawide basis
and provide control or treatment of all point
and non-point sources of pollution, including
in place or accumulated pollution sources."
COASTAL ENVIRONMENT ASSOCIATION, INC.
. 518
-------
WfiiH
EST. - 1869 INC. 1924
Robert T. Jones, President
Paul C. Bucknam, jr., Treasurer
C. R. Wickerson, Oia/rman
C. Roger Pearson, Chm. Emeritus
Anthony Chiaravelotti
Elias A. Cooney
Brewster W. Fuller
Myles F. Howard
Frederick D. A. King, Jr.
James T. McDonough
Howard R. Perkins, M^nager
James A. S. Walker, Arch. Officer
Arthur T. Lucchini, Controller
Whitman & Howard, Inc.
Engineers and Architects
45 WILLIAM STREET, WELLESLEY. MASS. 02181 • TEL: 617-237-5000
November 15, 1976
ASSOCIATES
Gerald T. Carey
T. T. Chiang Ph.D.
Robert E. Crawford
Donald F. Dargie
Charles G. Ellis
Ernest H. Fagerstrom
Robert E. Hickman
Arthur Liatsos
James A. Little
Edward R. Mayer
Steven J. Medlar
James F. Murphy
Joseph A. Murphy
U.S. Environmental Protection Agency,
Region 1
Environmental Policy Coordination Office
J.F.K. Federal Building, Room 2203
Boston, MA 02203
RE: Environmental Impact Statement
Scarborough, ME
Gentlemen:
The following comments are relative to the supplemental
report entitled "An Analysis of the Alternative Systems for
Wastewater Collection and Treatment in Scarborough, Maine".
Specifically, these comments will be limited to the conclu-
sions drawn in Section V-2,Comparison of Alternatives.
1. Costs Comparison
Although it is stated in the Supplement that there
are no significant cost differences between Alternatives
"A", "C" and "F", there appear to be enough inaccuracies
in the Comparative Cost Table, Table IV-3, to negate
this claim.
All pumping stations are undersized, sometimes
by as much as a factor of two, according to
TR-16 "Guides for the Design of Wastewater
Treatment Works" (New England Interstate
Water Pollution Control Commission)
The costs shown for the pumping stations
(Attachments #1, #2, and #3) are well below
recent bid prices for similar sized stations
(Attachment #4). From the bid prices, a graph
was formulated (Attachment #5) and the costs of
the stations determined. A comparison of the
costs is shown in Attachment #6.
(a)
(b)
1

519
-------
- 2 -
(c)	The 24-inch sewer from West Scarborough in
Alternative "A" should be 15 inches instead
of 24 inches, thereby, reducing the costs by
$169,000.
(d)	The cost for the sewer from Pine Point to
Prouts Neck is $155/ft. in Alt. "A" but only
$60/ft. in Alt. "F". If this route is to be
abandoned in favor of the route along the
railroad bed, then it should be the same in
both Alternatives.
(e)	Advanced waste treatment (AWT) is needed in
Alternative "C", but has not been included
in the costs. As a minimum, sand filters would
be required, and as shown on page V-3 of the
Supplement, this additional cost would be
$1,200,000.
There is not sufficient information presented in the
Supplement to adequately check the cost figures, especially
the 0 & M costs; however, based upon the aforementioned, but
ignoring the undersizing of the pumping stations, the capital
costs for Alternatives "A, "C" and "F" should be increased
by $475,000, $1,623,000, and $1,594,000, respectively. We
have, therefore, partially revised Table IV-3 (Attachment #7),
and carrying these figures over to Table V-l (Attachment #8),
Alternatives "C" and "F" are, respectively 42% and 18% more
costly than Alternative "A".
Thus, even with the limited cost information presented
in the Supplement, there appears to be a substantial cost
differential between the Alternatives. Based upon this
information, and the fact that the collection system costs
would be the same for all Alternatives, Alternative "A" is the
most cost effective.
Another factor which should be considered is the apparent
need to expand the South Portland facility immediately, if
Scarborough is to utilize the plant. In discussions with the
City's engineer, the existing wastewater flow, exclusive of
infiltration, is approximately 3.5 MGD and with an acceptable
level of infiltration, according to the DEP, of 1.5 MGD, the
South Portland flow would be about 5.0 MGD. According to a
contract between Cape Elizabeth and South Portland, the annual
average flow from Cape Elizabeth can be 0.5 MGD; however,
this flow is allowed to reach 1.25 MGD, probably during the
spring and summer months.
520
-------
- 3 -
Thus, it appears that irregardless of which growth
scenario Scarborough may choose, the South Portland facility
will have to be expanded before it can accept flows from
Scarborough. These costs should, therefore, be included
in Alternative "F".
It is also possible that under the medium or high
growth scenarios (1.65 MGD and 1.9 MGD, respectively),
industrial flows generated from the "opening up" of the
Highland Ave. area in South Portland and/or expansion of
the South Portland sewerage system may cause the ultimate
capacity of the South Portland facility, 8.25 MGD, to be
exceeded.
2. Comparison of Environmental Effects
(a)	It is claimed that Alternative "F" will cause
the least environmental disruption during
construction and operation because there is
adequate filled area for future expansion of
the plant; however, this may not be true.
According to South Portland's engineers, the
available site will allow for only 50% ex-
pansion, or an ultimate plant capacity of
8.25 MGD. Depending upon the amount of
industrial development which would occur from
the opening of the Highland Ave. area, the
expansion of the South Portland sewerage system,
and the amount of excessive infiltration which
can be eliminated from the South Portland system,
it is very possible that Scarborough's flow could
necessitate expanding the site.
(b)	The minor environmental effects of constructing
the ocean outfall in Alternative "A" are only
temporary, and the construction of the outfall
in the roadways of Prouts Neck would be no more
disruptive than constructing the lateral sewers
in that area which must be installed under all
Alternatives.
(c)	In considering the secondary environmental effects,
it is stated that the most adverse condition
would be caused by the gravity sewer along Black
Point Road in Alternative "A". This condition
could be eliminated by extending the force mains
from Oak Hill and Higgins Beach to the treatment
facility at Prouts Neck.
521
-------
(d) Based upon the aforementioned, all secondary
environmental effects are equivalent.
Comparision of Political and Administrative Feasibility
(a)	In discussions with South Portland's City Manager
and consulting engineer, it was stated that the
City would probably not consider accepting wastes
from Scarborough until its facility had been
"on line" for at least one year. Thus, negotia-
tions on a regional agreement could not begin
until the spring of 1978 at the very earliest.
This is especially true considering the extreme
amount of infiltration, estimated to be 6 MGD,
which is entering South Portland's system. If
this is the case, it may take years before the
infiltration is reduced to an acceptable level,
especially if South Portland must pay all of
the rehabilitation costs.
(b)	Scarborough would have no control over the
South Portland facility and its operation,
according to its City Manager.
(c)	In all probability, the maximum size of the
South Portland facility will be determined by
the available site. This lack of flexibility
may adversely effect any industry that may desire
to locate in Scarborough. Without the capability
of expanding the facility and, thereby, increasing
the allotted flow from Scarborough, the Town
would probably not be able to offer sewerage
facilities to prospective industries.
(d)	Because of the size and number of pumping
stations, and the probability that South
Portland would have to enlarge its treatment
plant immediately, there would be no significant
difference between the design and construction
times of Alternatives "A", "C", and wf"; however,
if negotiations for a regional agreement in
Alternative "F" must await the evaluation of the
operation of the South Portland facility and/or
the reduction of the excessive infiltration,
Alternative "F" would require a minimum of one
(1) year more to complete than Alternatives
"A" and "C".
522
-------
- 5 -
(e) In terms of administrative feasibility
Alternative "C" would be more difficult
than "A" because of the advanced treatment
required. This would increase the opera-
tional costs and manpower needs of the
facility, thereby, increasing the adminis-
trative piroblems.
Based upon the aforementioned, Table V-2 has been
revised to better reflect these conclusions.
TABLE V-2
RANKING OF ALTERNATIVE SYSTEMS IN TERMS OP ACCEPTABILITY
Costs Primary Secondary Public Administrative Political
Environmt'l Environmt'l Health Feasibility Opposition
Effects	Effects	Risk
A	F*	A,C,F	F	A	F
FA	A	C	C
C	C	C	F	A
~Depending upon the flows to the South Portland facility and
industrial development in the Highland Ave. area, the site
may have to be enlarged, thereby, causing "F" to have the
most adverse primary environmental effects.
If there are any questions on the presented matter,
please do not hesitate to contact us.
Very truly yours,
WHITMAN & HOWARD, INC.
\ )/i ,--j. / / y
Donald F. Dargie, P.E.
Associate
DFD/ds
523
-------
47?A£//M£AJT
Vhitkan-Kowaro Proposed Action and Their OuifALL and *0gden Ross" Outfall
K.
Scarborough
1)
.096 KGD
2)
.125 MGD
3)
.139 MGD
$
Willowdale

Oak Hill

Oak Hill North
1) .OH KGO

1) .172 MGD

1) -
2) .153 MGD

2) .108 MGD

2) .230 KGD
3) .197 MGD

3) .199 KGD

3) .279 kgd
Blue Poiht
1)	.072 hgd
2)	.032 hod
3)	.105 KGO
PUMPING STATION
1)	133 GPK
2)	171 cph iif6
3)	m GPft $23,9T>
Huhpty-Dumpty
I Other Future
Ind.
.215 KGO
0
Pumping Station
1)	149 gpm
2)	1213 gpm
3)	JSOTgpm 595,000\
6" force main (3300') 562.700	1
1)	6*	1
2)	12* force main (13500*) $3*I,<'00
f
I
I
A
|.*V 1
¦J! V
hoV
'f\)	3) 12-
-21*"SEWER (10400') $501,800
Snow I Eayley Foods
.085 KGD
Pike Point
1)	.116 ksd
2)	.113 MGD
3)	.121 KGD
\0
V
\
Pumping Station
1)	397 gpm
2)	153 gpm
3)	sea,gpm sis.oto
-B" FORCE1main (2700') *51.300
Black Pt./Prouts (I
1)	-
2)	.115 mgd'
3)	.133 KGD
1
Higgihs P.eacn
1)	.105 KGD
2)	.116 KGD
3)	.123 KGD
Pumping Station
1) 177 gpk
V 2) 535 gpm
\ 3) m gpm $35,000
V
8* FORCE RAIN (3900')
$601,500-
/Si/,
/
routs'Neck
wtr
¦ HAIN-S. \_y
6* FORCE*
(5500') *13'i.5T3
Pumping Station
1)	292 gpk
2)	161 6PH	„
3)gpm	$23,000 tkl
"1) 12' gravity
2)	18' gravity (5500')
3)	18* gravity $25'i.100
I.W
u
o $
1)	.905 MGD
2)	1.617 KGD
3)	1.897 kgd $1.95^,000
Outfall through Prouts Neck (7000') $670,000
'Ogsek Ross" Outfall around Prouts Neck (9000')
$1,395,000
5) ¦% iti	&Ljji\r; US
A. I	S & jwlj iiL'A

£
" itUloo *\zli -^S$Zho ZoiSoo- 332 fw-
*/1m. ']t$J £ 'tsuJL.	ju-LL'fc
(9 uau	d. jut***tC /^Jf /{»
G-{£, j'MAV Wj j$jL.ix ICIaJL— JlXA>	\t t( & (L !o^\ / i-
'A r
pr-
524
-------
Thokas Griffin Alternative
4TTACHM&J TT-*Z.
<• Scarborough
1) '.096 mo
?) .125 MGD
3) .139 hod
5
O
Blue Point
1)	.072 MGD
2)	.032 kgo
3)	'.106 r.GD
6' Force JUin (2200')
541,800

Pine Point
1)	.116 KGO
2)	.118 nso
3)	.121 MGD
C.C-cn JWrt I* 1&4Cl 3
Iiggins Beach
1)	.105 kgd
2)	.116 hgd
I) .173 wn
Pumping Station
1)	133 GPU
2)	171 gpm	,
3)	>81 gpm $23,000



Pumping Station
1)	146 GPM
2)	161 GPM - ri
3)	iWGPH - 3* /
$23,000 '
6" Force Main
(5500')
$104,500
-6* Force Main (3300*) $£2,700
Prouts (I./Black P
1)	-
2)	.115 KGD
3)	.133 kgd
Pumping Station
Snow ! Bayley
.085 MGD
1)	177 GPM
2)	535 gpm
DJOi gph *35,000
|lDO
-6* Force Main (3300')
$62,700
Pumping Station
1)	294 gpm
2)	304 gph
3)	JS5 c?n $35,030
(r °b
Pumping Station
1)	161 GPH
2)	161 GPM
3)J6S	gph $23,000
oT7
8* Force Main
• (11000') $250,000
Pumping Station
1)	146 gph
2)	321 gph rt
3)35$	gpm - 7' I
$35,000
6" Force Kaiw (4300*)
$91,000
iUMPTY-D'JMPTY i
)tker Ikd.
¦'IS"»
HlLLOWDALE

3ak Hill

Oak Hill Korth
1) .044 MGD

1) .172 MGD

IV-
2) .153 MGD

2) .408 MGD

2) .230 mgd
3) .197 mod

3) .499 mod

3) .279 mod
/
D-
Oak Hill MffP
1)	.905 mgo (y-0
2)	1.647 mgo
3)	1.897 mgo $1,950,000
f 5 ^

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>bi>xt Ovf
S7P (.017 > /.^J"O
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(t)
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525
-------
, jtMSMOUGH to Expanded South Portland Plant
- 4TJACt/MZAjr *3
H. Scarborough
1)	.096 KGD
2)	.125 mod
3)	.139 kgd
Humpty-Dumpty
I Other Ino.
.215 *r,p
Jlue Point
I) .072 KGD
V) .CS2 kgd
3) .105 kgc
Bayle*
i£2i£SE
Pimping Station
1)	133 GPH
2)	171 sph
3)	1» 6pm 423,000
¦6* Force Rain (3300')
$62,700
Pumping Station
1)	183 GPH
2)	231 gph
J)^r 435,000
-6' Force (Uim (2000') $3?,0?)
Oak Hill
1)	.172 KGD
2)	.108 KGD
5) .499 KGD
South Portland KWTP
5.5 ~ 1) .505 kgd
2) 1.617 two
P3) 1.E97 kgd
2b) 1.755 kgd
3b) 2.023 kgd
$2,109,000
I
l~«- Force Kaih (6600')
Hillohdale
1)	.011 kgd
2)	.153 KGD
3)	.197 kgd
Uak Hill North
1)	-
2)	.230 kgo
3)	.279 K5D
1
0
Pumping Station
1)	316 gph
2)	371 gph
3)	J&M «ph $35,0-00
<{oo
6* Force Cain (1800')
$34,200
5
Force fam
1)	6* (12100)
2)	12' «70Q)—H
3)	12* (WOO) i
Pumping Station
1)	119 gph
2)	1218 gph
3) 1585- gph
£60
$133,000
$95,000
Gravity (7700
Q
$20f.2=O
Pumping Station
1)	1072 gph
2)	2101 gph
3)	2151 gph
2b) 2251 gph Gjr,
3b) 2636 gph ^ J
$160,000
•Gravity (17100')
1)	15*	f)
2)	21* , v
3)21'
2b)21* " 1 -*
3b) 21" ^22,000
Force Hain (1300')
1)	10*
2)	11* }
ft
Pike Point
1)	.116 KGD
2)	.113 KGD
3)	.121 KGD
1)	-
2)	21"
3)	21"
<0
3) 16*
2b) 16"
3s) 16*
>• 'j
*1^,000
$364,000
A
\
\
Pumping Station
1)	477 gph
2)	535 gph
3)	.585 gph $35,000
\lco
\
\ H.
\
V
A
4-'?
J*
 0/Jf.
\
\
\
\
I
^Jrh'i
Prouts N./Black P
1)	-
2)	.115 HGO
3)	.133 hgo
\
l-*-10" F.M. (10100*)
$270,000
Pumping Station
1)	622 gph
2)	856 gph
3)	J#5f gph *73,000
i5$ 5
15" 6ravity (5S0Q*)
b-V
t LAaa
VUa.	^
j tf
1)	12*
2)	15"
3)	15"
$134,050
1IGGIK5 BEAC>i
_ 1) .105 HGO
2) .116 hgo
» .123 KGD
*-*>	iL(: <~L\ iA !*. ii k.i t
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•8 BROAD STREET BOSTON MASS
EN8INEERS and ARCHITECTS
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Table V-'l
Comparison of Combined Amortized Capital and O&M
Costs for Alternatives A, C, and F
Alternatives
Total Cost
$/Capita/yr.
Actual Cost-
Gov't Grants *
$/Capita/yr.
ilo ,
'TdMju
IV-3

A - Single Plant
at Prouts
Neck
Low
Medium
High
58.40
37.30
/31.40

17.70
14.20
v ll.lOv

V
C - Expanded and
Upgraded Oak
Hill Plant
Low
Medium
High

\ 58.80
\38.40
t«33.10

1 \ 20.50 /
/ J 15.90 / I
+^%J 12.80W»j
¦*¦2.
M2J
F - Full Transfer
to South Portland
Low
Medium
High
^m
\ 44.20
\ 33.00
?/>29.80
44>7
/ 15.60 /
/ 13.40 /
Jifl, 12.4o4izyo

I
+\&/«
* Federal and State grants amount to 90 percent of the capital
costs.
I
tkfiju. 5 ) (o	IM0	' ' I 7* C4-0 - H-74
V CLjjt I/*Ll - M<00- (Z.fo* (*>Z*	~ t6.fi>?
s	= t3-7d- iz.+o - '-so
vl
V-14
531
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY jp?p.
SUBJECT: Environmental Impact Statement
DATE- Fe'3ruary 6, 1976

FROM:
Edward F. M. Wong, Natural Resource Officer
TO:
Wallace E. Stickney, Chief
Office of Environmental and Economic Impact
Of the many impact statements crossing my path, I think this is
one of the better reports. I have made comments on certain question-
able points in the margin of the pageJP and you may want to consider
them. Most of these notations are minor and should not detract from
the general thesis of the report.
The consultants found, however, that the selection of alternate
one (1), among the five (5) alternates, offered reasonable arguments
that would enhance the shellfisheries and provide an economic benefit
to the community, as well as reclaiming a valuable resource (page V).
It appeared that considerable emphasis was enumerated on this basis
and that this was a strong point in their selection. To me and mem-
bers of the Department of Marine Resources, this is not exactly the
case. The firm based their assumptions on records of past clam pro-
duction and made projections on landed values and added market values
using my own shellfish multiplier method. This can be done but, in
this case, the projections were inaccurate because of insufficient
current field data to support their case. Density surveys of the clam
flats disclosed an acute predation of green crabs. This was confirmed
by field trips conducted last year by Wallace and Welch of the Depart-
ment of Marine Resources. In fact, the destruction of the flats here
are such that spat and juvenile clams have been devastated to the
point that expectation of a mature marketable crop within the next
three years is not feasible. This does not, of course, apply to the
entire Scarborough estuary.
On page 11-49, reference is made to clam production back in 1957,
listing the number of diggers and bushels obtained. Somehow, the fi-
gures are impossible to accept because my calculations show that in
1946, 250 diggers producing 118,286 bushels in 118 days, as reported,
would yield over 1,000 bushels per day, at a rate of about four bushels
per digger. It is unlikely that you would ever have all the diggers
out on each single digging day, not to mention the likelihood of over
a period of 118 days. A four bushel per day digger is not an unusually
high figure in an area that was good— an area with a density of 100
bushels/acre or more. I -£iad it difficult to accept that in 1946, the
rate of 1,000 bushels per day was a reasonable market demand. We be-
lieve that these figures were gross estimates of clam production and
harvesters from Cumberland County and not a matter of record, wher
ever the data originated. Records at the Department of Marine Resour-
ces show 307 diggers in all of Cumberland County, with a yield of
158,000 bushels of clams during the year 1946.
EPA Farm 1320-6 (Rev. 6-72)
532
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Reference was made that a 1,000 ft. conditional shellfish closure
would be imposed adjacent to the outfall. Although I have seen the
1,000 ft. figure in other reports also, there is no basis for its use.
True, a closure will automatically be imposed around an outfall, but
the distance and area is determined only through surveys conducted by
the Department of Marine Resources.
A chlorine residual of 1 mg/1 was recommended as the requirement
that would meet the water classification of the receiving waters. In
practice, 1 mg/1 may be too much and unnecessary to meet SA water
standards for direct harvesting of shellfish. Usually, depending on
the quality and maintenance of the plant operations, the chlorine re-
sidual is that amount necessary to provide for a 15 fecal coliform per
100/ml at the point of discharge following a 30-minute contact time to
accommodate class SA waters suitable for direct harvesting. Aside
from major harbors like New Haven and Norwalk in Connecticut, a residu-
al of less than 1 mg/1 at this plant may reasonably do the job for
Maine waters.
533
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UNITED STATES
DEPARTMENT OF THE INTERIOR
FISH AND WILDLIFE SERVICE
New England Field Office
F. 0. Box 1518
55 Pleasant Street
Concord, NH 03301
February 1, 1977
Regional Administrator
Environmental Protection Agency
Region 1
J. F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Sir:
This planning aid report is submitted to assist you in completing the Environ-
mental Impact Statement for the Wastewater Collection and Treatment Facilities
at Scarboro, Maine. It was generated as a result of a meeting on January 26,
1977, and offers several mitigation recommendations and/or conditions which
should be included in the environmental statement.
Recommendations
(1) Establishment of Green Belts: Wetlands represent an ecosystem of unique
and major importance to citizens of this Nation. The establishment of
green belts around the floodplain (including a buffer zone) would protect
and preserve these areas for use by all residents.
Conditions
Grant approval should be subject to compliance with the following:
(1) No future floodplain development: Executive Order 11296, dated
January 1969 (copy attached), makes it very clear that "All execu-
tive agencies responsible for the administration of Federal grant,
loan...shall evaluate flood hazards...and the need for future ex-
penditures for flood protection and flood disaster relief...shall,
..., preclude the uneconomic, hazardous, or unnecessary use of
floodplains...".
Although more along the line of siting facilities, we feel that any
Federal action which facilitates floodplain development is also
subject to this order.
.0^T'0/u
'<^6-19*1*
534
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(2)	Restoration of wetland areas which are disturbed during construction:
It is not anticipated that many wetland areas will be disturbed
during construction. However, any areas which are disturbed should
be subject to complete restoration conditions. Specific measures
to be taken vary with each situation, and we would request that the
contractor notify this agency and the Maine Department of Marine
Resources for consultation before project construction.
(3)	Removal of old sewer outfalls, or making them inoperable: It is
anticipated that the installation of this treatment plant will faci-
litate overall water quality improvement, and subsequent cleansing
of shellfish areas which are currently closed. We feel it extremely
important that all outfalls, lines, etc., which will hopefully
become "non-functional", be removed or made inoperative. This action
will remove the potential hazard from overflow or bypass of sewage
into old lines in case of plant malfunction, flooding, etc.
We appreciate the opportunity to review and comment on this project and are
available for further consultation.
Sincerely yours,
Melvin R. Evans
Field Supervisor, NEFO
Attachment
535
~ U.S. GOVERNMENT PRINTING OFFICE: 1977-A-0828/10
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