FINAL
ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER COLLECTION AND TREATMENT FACILITIES
NEW SHOREHAM, RHODE ISLAND
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United States
Environmental
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JOHN F. KENNEDY FEDERAL BUILDING - GOVERNMENT CENTER - BOSTON, MASSACHUSETTS 02203
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER COLLECTION AND TREATMENT FACILITIES
NEW SHOREHAM, RHODE ISLAND
Prepared By
U.S. Environmental Protection Agency
New England Region I
John F. Kennedy Federal Building
Boston, Massachusetts 0 220 3
J^lthvA.S. McGI
Regional Admi:
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This Environmenta1 Impact Statement (EIS) has been prepared
pursuant to P.L. 91-190, the National Environmental Policy Act
(NEPA) of 1969, and Executive Order 11511, "Protection and
Enhancement of Environmental Quality" dated March 5, 197 0. Both
NEPA and Executive Order 11514 require that all Federal Agencies
prepare such statements in connection with their proposals for
major Federal Actions significantly affecting the quality of the
human environment.
This EIS has been prepared in accordance with the
regulations and guidance set forth in the Presidents Council on
Environmental 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 Ennvironmental 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 appurtenances. 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 pollutants by 1985, and wherever attainable, an
interim water quality goal by July 1, 1983, which provides for
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the protection and propagation of fish, shellfish, and wildlife,
and provides for recreation in and on the water.
For the purposes of the 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, the Draft EIS
was circulated for a 45-day review as required by the CEQ, August
1, 197 3 Guidelines. In addition, a public hearing was held on
May 10, 1975. Subsequently, the comment period was extended an
additional 15 days. The official comment period ended on June 3,
1975.
No administrative action will be taken with regards to the
proposed action until 30 days after this final statement is
received by CEQ.
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TABLE OF CONTENTS
LIST OF TABLES
LIST OF I1APS
LIST OF APPENDICES
SUMMARY
REPORT
1.0 INTRODUCTION
1.1 Background
1.2 Other Proposed Actions
2.0 EXISTING ENVIRONMENT
2.1 Historical Background
2.2 Physical Inventory
Cliraate
Topography
Geology
Groundv/ater
Water Quality
Noise Levels
Air Quality
Fish and Wildlife
Environmentally Sensitive Areas
2.3 Utilities and Other Community Facilitie
Water
Sewer
Gas
Electricity
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CONTENTS (Cont.)
Telephone 15
Refuse Disposal 16
Other Facilities 16
2.4 Growth and Land Use Analysis 16
Populations and Socio-Economic Trends 16
Existing Land Use 18
State and Local Land Use Plans 19
Existing Zoning 22
Analysis of Existing Plans, Policies
and Zoning 23
Growth Assumptions 24
3.0 ALTERNATIVES 25
3.1 Alternative Treatment Plant Locations 25
3.2 Multiple Facility Alternatives 26
3.3 Treatment Process Alternatives 26
Extended Aeration 27
Modified Activated Sludge 28
Aerated Lagoon 28
Stabilization Pond 28
Physical Chemical Treatment 2 8
Land Disposal 29
Summary of Treatment Methods 30
3.4 Outfall Location Alternatives 30
3.5 Sludge Disposal Alternatives 31
3.6 Flow Reducing Alternatives 31
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CONTENTS (Cont.)
4.0 IMPACT OF ALTERNATIVE ACTIONS 33
Alternative Wastewater Flows 3 3
4.1 No Action Alternative 34
Description 34
Primary Impacts 3 4
Secondary Impacts 35
4.2 Alternative A - Fenton Keyes Proposed Project 35
Description 35
Social Impact 37
Technical 3 3
Environmental Impacts 40
Economic Impacts 44
Political and Legal/Institutional Impacts 45
Secondary Impacts 46
4.3 Alternative 3 - Proposed Project Minus
Stage II 51
Description 51
Primary Impacts 51
Secondary Impacts 51
4.4 Alternative C - Rehabilitation of Individual
Subsurface Disposal Systems 52
Description 52
Social Impacts 54
Technical 54
Environmental Impacts 54
Economic Impacts 55
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CONTENTS (Cont.)
Political and Legal/Institutional
Impacts 56
Secondary Impacts 57
4.5 Alternative D - Sewer System for Old Harbor 5 7
Description 57
Social Impacts 5 8
Technical 58
Environmental Impacts 59
Economic Impacts 59
Political and Legal/Institutional Impact 59
Secondary Impacts 59
5.0 PREFERRED ALTERNATIVES 6 2
6.0 PROBABLE ADVERSE IMPACTS WHICH CANNOT BE AVOIDED 6 4
6.1 Primary Impacts 6 4
Alternative B 64
6.2 Secondary Impacts 6 4
Alternative B 64
7.0 SHORT TERM VERSUS LONG TERM PRODUCTIVITY 65
8.0 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS
OF RESOURCES 66
9.0 COMMENTS ON DRAFT EIS 67
APPENDICES
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LIST OF TABLES AND CHARTS
Table
Page
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Water Quality Standards for Sea Water
Noise Levels on Block Island January 1975
19 70 Air Sampling Data, Block Island Airport
Comparison of National Primary and Secondary
Standards and Rhode Island Air Quality
Standards
Population
Labor Force
Housing Characteristics
Existing and Proposed Land Use
Growth Assumptions
Average Costs for 300,000 Gal/Day Treatment
Facilities in Southern New England
Comparative Equivalent Service Area Population
and Wastewater Flows
Actual Numbers of Units and Persons to be
Served Under Alternative A
Annual Costs of Alternative A
Comparison of Development Trends in Proposed
Sewer Service Area.
Estimated Annual Costs of Alternative B
Estimated Annual Costs of Alternative C
Estimated Annual Costs of Alternative D
10.1
12
13
12.1
16
17
18
21.1
24.1
27.1
34
34.1
45
47
52
56
61
Chart
A
Comparative Summary of Treatment Methods
30.1
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Map
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
LIST OF MAPS
Following
Page
Area of Influence 3
Proposed Sewer Service Area 3
History, Recreation, and Tourism 5
Topography 6
Soil Characteristics 7
Groundwater Availability 9
Water Quality Classification Closure Map 11
Environmentally Sensitive Areas 14
Water Service Areas 15
Community Facilities 16
Existing Land Use 18
Proposed Land Use Plan 21
A Proposed Zoning Map 22
Existing Zoning 22
Alternative A 3 3
Alternative D 5 7
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APPENDICES
Appendix Page
A Existing Water Quality A-l
B Watercraft Waste Regulations B-l
C Proposed Land Use Categories C-l
D Basis of Costs for Alternative Treatment
Systems D-l
E Flow Reduction Equipment E-l
F Design Flows F-l
G FMC Waste Treatment System G-l
II Ocean Current Studies, Pebbly Beach Outfall II-1
I Cost Basis for Alternative Actions 1-1
J Impact of Sewers on Specific Sectors of the
Island J-l
K Letter for U.S. Soil Conservation Service K-l
L Letter from State Historical Commission L-l
M State of Rhode Island Minimum Standards
Relating to Location, Design, Construction
and Maintenance of Individual Sewage Disposal
Systems M-l
H Environmental Effects of Subsurface Disposal
on Groundwater Quality N-l
0 Letters Received with Concern to Draft EIS 0-1
A. Federal Agencies
B. State Agencies
C. Environmental Groups
D. General Public
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SUMMARY
1. Type of Action
(x) Administrative ( ) Draft Environmental Impact Statement
{ ) Legislative (x) Final Environmental Impact Statement
2. Background of Project
In August 1973 the Town of New Shoreham (Block Island) ,
Rhode Island applied to Region I for financial assistance under
Title II of the Federal Water Pollution Control Act, as amended
(PL 92-500). The community requested a grant for construction
and reimbursement for planning and design of a wastewater
treatment facility, including sewering and construction of
pumping stations.
After preparing the environmental impact appraisal as part
of the review of the proposed project, EPA determined that the
project would not significantly affect the environment and issued
a negative declaration on May 6, 1974.
Before final approval of the project, Block Island residents
brought three key issues to the attention of the Regional
Administrator:
1. Possible accelerated growth induced by the project,
2. Possible adverse effects of the outfall pipe on
adjacent beaches, and
3. Possible adverse effects from locating the
wastewater treatment plant within a designated
national historical district.
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After carefully considering the potential impacts of the
proposed action in light of these locally controversial issues,
the Regional Administrator reversed his initial decision and
issued a notice of intent to prepare an environmental impact
statement on September 19, 1974.
3. Proposed Action
After completing the Environmental Impact Statement process,
EPA has determined that Block Island is a unique and fragile
community that has an immediate need for a sewage treatment and
collection system. This immediate need is evident in the Old
Harbor area vihere early development on the Island clustered very
close together. The early developers relyed on direct ocean
disposal for their sanitary sewage disposal needs. Now that
ocean disposal of raw wastewater is no longer an acceptable means
of sewage disposal and tightly knit housing precludes individual
subsurface disposal systems because of insufficient land area,
the community must rely on a municipal wastewater collection and
treatment system.
The people of New Shoreham depend on the summer tourist
season to maintain their economic independence. A major portion
of the tourist trade is supported by the marinas in the New
Harbor Area. The community feels, to provide sewerage for the
marinas is necessary to protect their fragile economic
independence. In addition, it is the opinion of EPA that a
sewerage system is needed for the New Harbor Area to alleviate
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potential health problems and to insure that the environmental
integrity of the New Harbor Area is maintained for future
generations.
The State of Rhode Island has also gone on record (letter
dated to John McGlennon)that the land area in the New Harbor area
is not suitable for subsurface sewage systems.
Therefore, EPA proposes to approve and fund Alternative B of
the draft impact statement. This Alternative includes the
original Fenton Keys Design, exluding Phase II of the Project.
In addition, EPA also proposes the following changes to the
original design:
1. Addition of a filtration unit for the final effluent
to assure a consistantly high quality effluent at
the outfall.
2. Odor control and noise attenuation to be included at
the plant.
3. Aethetic screening of the plant so that it will
blend into the setting of the Island.
4. Fencing to preclude easy access to the outfall.
EPA will amend the grant conditions to insure that public
toilet facilities will be. available in both the New and Old
Harbor Areas. In addition, EPA will also require the community
to enter into agreements with the marina operators to insure that
adequate pumpout and pretreatment facilities will be installed as
may be necessary to satisfy requirements for boat owners to
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comply with Public Law 92-500 Section 312 Marine Sanitation
Devices and subsequent Federal Regulations published by EPA and
the Department of Transportation on June 23, 1972 and January 30,
1975 respectively and any amendments or revisions thereto.
4. Summary of Impacts
The major direct impacts of EPA's proposed action are
related to construction and operation of the wastewater treatment
facility and include the aesthetic impact of locating the plant
at the Spring Street site, the temporary disruption of various
parts of Old Harbor by noise and other construction related
activities, the protection of Old Harbor's subsurface drinking
water supply, elimination of odor problems from malfunctioning
septic systems, and enhancement of water quality along the
recreation beaches on Block Island.
EPA recognizes that the capacity allocated to the treatment
facilities may allow certain amounts of limited induced growth.
However, there is no evidence that this growth can reasonably be
anticipated to contravene any environmental laws or regulations
nor would it contravene any environmental plans or standards.
The related potential impacts of capacity were set forth in
detail in the draft impact statement. All those concerned were
given the opportunity to become well aware of these possible
impacts. We recognize through comments made by the official
boards of the town that they are aware of this potential growth.
Further, we recognize that they have the authority to regulate
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this growth and the responsibility and intent to preserve the
character and environment of Block Island.
5. Other Alternatives Considered
Other major alternatives are discussed in detail in the
environmental impact statement, including the alternative of
taking no action.
The no action alternative was determined to be infeasible
because the failing subsurface disposal systems in Old Harbor and
New Harbor are a potential health hazard and are astheticly
unpleasant.
The alternative of rehabilitating the septic systems in the
densely populated area around Old Harbor was considered
impractical because there is not enough suitable land to support
these systems.
The draft statement also included an alternative of sewering
just the Old Harbor area. This alternative was not selected
because the town felt that it was not practical to exclude New
Harbor in light of their concern for the water quality of Great
Salt Pond. The State Board of Health has testified that the
soils in the New Harbor area are not suitable for subsurface
disposal systems. This unsuitability would result in a potential
water pollution and public health hazard and would be detrimental
to the tourist trade which is the economic life of the island.
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Sub-alternatives discussed include various outfall
locations, treatment plant sites, types of treatment and
possibilities cf flow reduction devices.
6. Distribution
Copies of the draft impact statement were sent to the
following Federal and State agencies.
FEDERAL
Council on Environmental Quality
~United States Department of the Interior
Bureau of Sports Fisheries and Wildlife
Bureau of Outdoor Recreation
Bureau of Land Management
Geoloqical Survey
National Park Survey
~United States Department of Agriculture
~Soil Conservation Service
~United States Department of the Army
Corps of Engineers
United States Department of Commerce
United States Department of Transportation
~ Federal Highway
~Coast Guard
National Oceanographic and Atmospheric Administration
~Department of Housing and Urban Development
~Department of Health, Eduction, and welfare
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Senator John C. Pastore
Senator Ciaifccrne Pell
Representative Fernand J. St. Germain
Representative Edward P. Beard
Stat e of Rhode Island
Department of Natural Resources
Department of water Resources
~Department of Health
Department of Administration, Budget Division
Office of the Attorney General
~Office of State Wide Planning
~Historical Preservation Commission
~ Comments were received from agencies so indicated.
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REPORT
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1.0 INTRODUCTION
1.1 Background
The Town of New shoreham (Block Island) is located in the
County of Washington, Rhode Island, approximately 10 miles
offshore from the south coast of the mainland of Rhode Island and
approximately 14 miles east of Montauk Point, Long Island. The
land area is approximately 11 square miles (see Map 1) . The
Island is a year-round residence to 500 people and a summer
residence to an additional 1,200 people. During the average day
of the summer tourist season, the Island is a refuge to
approximately 1,000 overnight guests and an equal number of day
visitors.
In the past few years, there has been an increase in summer
visitors and in construction cf summer residences. This growth,
coupled with forced abandonment of raw ocean discharges and the
lack of a municipal treatment system, has caused Islanders to
resort to subsurface disposal systems.
Because of improper construction due, in part, to
insufficient land area, these systems are not functioning
properly. The concentration of a number of failing systems in
the commercial area of New Shoreham has resulted in a situation
which is aesthetically displeasing to residents and visitors. In
addition, failing subsurface disposal systems are a potential
health hazard.
Because of the seriousness of the situation, the people of
New Shoreham enlisted the services cf the engineering consulting
firm of Fenton G. Keyes Associates to study the problem. In
February, 1972, the firm submitted a report to the Town entitled:
Preliminary Engineering Survey and Report on the control of Water
Pollution for the Town of New Shoreham, Rhode Island, February
1972.
On June 6, 1972, the Town Council filed a Notice of Intent
to apply for Federal aid for a municipal collection and treatment
system and on April 2, 1973, contracted with Fenton G. Keyes
Associates to design, supervise construction, and start operation
of the wastewater treatment system recommended in their report.
On August 17, 1973, the Environmental Protection Agency
(EPA) received an application for Federal aid from the Town of
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New Shore'nam. The application, based on engineering estimates,
was for a total project cost of $1.8 million.
Based on the application and the proposed design by Fenton
Keyes, EPA prepared an Environmental Impact Appraisal in
accordance with the National Environmental Policy Act (NEPA).
The project appraisal was for the construction of a secondary
wastewater treatment plant, interceptor sewers, two pumping
stations, associated force mains, and an outfall sewer located
approximately 900 linear feet to the South of the existing Old
Harbor breakwater and extending approximately 200 linear feet
from the shore line. The treatment facility proposed consisted
of an extended aeration-type treatment with a design capacity of
0.30 million qallons per day (mgd) . This system was to serve
both the Old and New Harbor areas, including marinas, and was to
be adequate for the design year of 1997. The locations of the
proposed treatment plant and service area are shown in Map 2.
Reviewing the proposal, EPA made the preliminary
determination that the funding of this project was not a major
action significantly affecting the environment and circulated a
negative declaration on May 6, 1974. Hearing no significant
comment or controversy in response to the negative declaration,
EPA, in accordance with Title II, Section 201 (g) (1) of the
Federal Water Pollution Control Act of 1972, made a grant offer
to the Town of New Shoreham on May 21, 1974. The offer was
accepted on June 7, 1974.
Final plans and specifications were approved June 14, 1974
and the job was opened to bid. On August 14, 1974, the low bid
was confirmed at $4.4 million, approximately $2.6 million higher
than the engineering estimates made a year earlier.
The higher cost of the treatment system sparked a new
citizen awareness causing considerable controversy about the
project. Issues raised were:
(1) possible accelerated growth due to a municipal
collection and treatment system;
(2) possible effects of the outfall on adjacent beaches;
(3) possible infringement of plant site on historical
landmarks.
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Finally, on September 17, 1974, a meeting was held in the
EPA Regional office so that proponents and opponents of the
project could air their views to the Agency. The next day, based
on the issues brought to the attention of EPA at this meeting, a
decision was made to reverse the initial determination and to
proceed with an environmental impact statement in accordance with
the National Environmental Policy Act (Section 102(2) (c)
1.2 Other Proposed Actions
The proposed wastewater collection and treatment system is
an independent action; that is, it was not proposed because of
another project. It is not anticipated that the sewage system
will be the cause of another Federal project, other than possible
Phase II extension of the proposed sewer.
However, pending EPA approval cf the project, the Farmers
Home Administration (FmHA) is prepared to grant additional
Federal aid for the project. On April 23, 197 3, a loan for
$1,015,00 0 was approved and later on October 21, 1974, funds were
obligated for an additional loan of $85,000 and a grant for
$220,000. The FmHA has stipulated that the preparation of the
environmental impact statement and subsequent decisions by EPA
are a condition of final approval of the grant.
The Rhode Island Department of Health has indicated that
State funds are available for this project and they will
authorize a grant amounting to fifteen (15) per cent of total
project cost deemed eligible for Federal Grant participation.
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Dates 1975 ,
040 COF *b eng #c COF *d OCL #d OCLCQ #d OCLCF *d OCLCQ *d OCLCO #d OCLCQ #d
EHA
043 n-us-ri
088 EPA 901-R-75-010
099 EPA 901-R-75-010
049 EHAD
110 1 United States. *b Environmental Protection Agency. *b Region I.
245 1 0 Wastewater collection and treatment facilities, New Shoreham, Rhode Island : *b final environmental
impact statement / #c prepared by U.S. Environmental Protection Agency, New England Region I.
260 Boston, Massachusetts : *b U.S. Environmental Protection Agency, New England Region I., #c
1975
300 approximately 400 pages in various pagings, 16 unnumbered leaves of plates : +b illustrations, maps
(some color); *c 28 cm
336 text *b txt #2 rdacontent
337 unmediated *b n +2 rdamedia
338 volume *b nc #2 rdacarrier
500 Includes errata.
504 Includes bibliographical references.
650 0 Sewage disposal plants #x Environmental aspects *z Rhode Island #z Block Island (Island)
650 0 Sewerage *z Rhode Island *z Block Island (Island)
650 7 Sewage disposal plants *x Environmental aspects. +2 fast #0 (OCoLC)fst01113958
650 7 Sewerage. +2 fast +0 (OCoLC)fstO1114083
651 7 Rhode Island *z Block Island (Island) *2 fast +0 (OCoLC)fstOI864783
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MAP I.
BOSTON
MASSACHUSETTS
BAY
MASS.
1
I
CONN.
> PROVIDENCE
CAPE COD
BAY
HARTFORD
FALL RIVER
NEW
NANTUCKET
) SOUND
NEW/LONDON
ESTERI
NEW HAVEN
BLOCK ISLAND
BRIDGEPORT
LONG ISLAND SOUND
i
SOURCE: ARMY MAP SERVICE
CORPS OF ENGINEERS, U.S. ARMY
WASHINGTON , D.C.
NEW SHOREHAM, BLOCK ISLAND
AREA OF INFLUENCE
URBAN LOCATIONS
FERRY ROUTES
AIR SERVICE
NO SCALE
NORTH
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MAP 2.
NEW SHOREHAM, BLOCK ISLAND
PROPOSED SEWER SERVICE AREA
NQRTH
"J STAGE H
STAGE I
SOURCE: FENTON G. KEYES ASSOCIATES , 1972
SLUDGE DISPOSAL AT
SANITARY LANDFILL-
PROPOSED SEWAGE
TREATMENT PLANT-
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2.0 EXISTING ENVIRONMENT
The history and existing environment of Block Island are
described to provide a background against which the impacts of
altnerative actions can be evaluated.
2.1 Historical Background
Originally, Block Island was called by its Indian
inhabitants, "Monisses," the "Isle of the Little God." Adrien
Block, in 1611, was the first white man to land on the Island,
but it was not until 1661 that the first white settlement
consisting of sixteen families arrived on the Island. In 1672,
it was incorporated as "New Shoreham, otherwise Block Island."*
During the next 100 years, the vulnerable island was
repeatedly beseiged by pirates. When the War of Independence
broke out, there were nearly eight hundred whites, fifty Indians,
and forty negroes living on the Island and the prosperours little
community was considered quite a temptation to the British fleet.
After the war and through much of the 19th century, the
Islanders supported themselves by fishing and piloting vessels
through the hazardous waters between the Island and the mainland.
In 1870, the construction of the first of two breakwaters was
started with Federal funds. It was the construction of the
harbors that signaled the growth of the Island as a vacation
resort. In 1879, New Shoreham's official name was changed to
Block Island, yet delighted visitors called it "The Bermuda of
the North." By the turn of the century, steamers arrived daily
from New York, Boston, Providence, Newport, New London and
Montauk.
The First World War, however, abruptly ended this prosperous
era. The Depression and subsequent Second World War further
curtailed the Island's tourist trade and many hotels closed.
Fortunately, the Island was still self-supporting through this
period by fishing and farming. In the postwar decades, Block
Island was rediscovered as a family resort. Private yachting and
flying grew more and more popular and a new generation of
tourists once again visited the Island. What they found was a
lovely, windswept place, with old fashioned inns and simple
cottages. Many bought abandoned farmlands overrun by shrubs and
bayberry, but dotted with ponds. They fixed up the old homes bit
by bit, doing most of the work themselves.
* Land Use Analysis, New Shoreham, Rhode Island
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Today, HNew Shoreham, otherwise Block Island," is governed
directly by a five member Town Council. In 1970, its people
defeated a bill to establish legalized gambling on the Island.
It is interesting that opposition to this bill was so intense
that even the possibility of secession from the State was
explored as an alternative to the Island becoming "The Las Vegas
of the East." It is now the concensus of those who visit or
reside on the Island that preservation of the existing rural
character and pristine environment is of utmost importance and
they are determined to achieve a sensible balance between
conservation and development before it is too late.
Map 3 displays general points cf interest on the Island.
2.2 Physical Inventory
Climate. Block Island's climate is typically maritime, but
can be affected by extreme conditicns. For example, temperatures
ranging from 10* to 95• have been recorded. Summers are usually
dry with maximum temperatures averaging 74« during July and
August. The Island is too small to build up cumulonimbus clouds,
therefore local thunderstorms are infrequent. Fog occurs on one
out of four days in early summer when the ocean temperatures are
relatively cold.
Winters are distinguished for their comparative mildness
with temperature maxima averaging to 10* above freezing and
minima averaging 25® in February. The surface winds are usually
from the east. When snow begins, it soon changes to rain or
melts rapidly if it does pile up.
The ocean has a dampening effect on hot winds in the summer
and, an accelerating effect on cold winds from the mainland in
the winter. Sea winds can reach 4 0 mph under certain conditions
in the winter with the average for that season about 20 mph.
Year round averages are also relatively high at 17 mph. In the
early fall, the Island is affected by most of the tropical storms
moving up the coast.
During these storms and other periods of high wind, flooding
occurs along the shores of the Island. The extent of this
flooding, the hurricane high water line is indicated on Map 4.
The efficiency of a wastewater treatment facility is
directly related to the ambient temperatures.
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MAP 3.
NEW SHOREHAM. BLOCK ISLAND
HISTORY - RECREATION - TOURISM
LIGHTHOUSE
NORTH
BIRD SANCTUARY
^ AREAS OF EARLY SETTLEMENT A BOAT LANDING .—FERRY
SOURCE COMPREHENSIVE COMMUNITY PLAN
NEW SHOREHAM. RHOOE ISLAND, 1970
GORTON FARM
0 CEMETERY / ^
SEARLEJ6 N
~ HBMlSfO
0N / MANSION
/ BEACH
CHARLESTON
BEACH
ST GUARD
5TATI0N
STATE
BEACH
A NEW /
HARBOR'
H HOUSE
BEACON HILL
HARBOR
DOCK
<-9<
A. PENN
GUARD
CEMETERY ¦-
FIRST SETTLEMENT
PALATINE GRAVES
MOHEGAN BLUFFS
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With relatively mild conditions prevailing through the year,
it is not expected that the operation of such a facility would be
inhibited. However, with the high winds experienced on the
Island, precautions must be taken to reduce the possibility of
flooding of structures built on the shoreline or in the sea
itself.
Topography. Block Island consists of two irregular, hilly
areas connected by a sandy lowland. It may be divided into three
topographic units which are illustrated on Map 4.
The first unit is a lowland covering about 3 square miles
which extends along the north and west sides of the northern half
of the Island and encloses Great Salt Pond on the east and west.
A manmade breach of the lowland on the pond's west shore forms a
channel into a protected harbor. The highest altitude in the
lowland is 40 feet above mean sea level (msl) and relief is
slight except in areas of sand dunes. Brackish ponds and marshes
are numerous.
The second unit is the plain, about 3/4 of a square mile in
area, in the extreme northeastern part of Block Island. Its
altitude increases northeastward to about 100 feel msl at the
eastern sea cliffs, the altitude of the highest point being 141
feet. About a dozen ponds, each covering roughly an acre, occupy
local depressions.
The third unit is the southern section of Block Island with
an area of about 5 square miles. Its altitude increases from
Great Salt Pond, reaching about 14 0 feet above msl at the
southern sea cliffs. The western portion of this section is very
irregular; local relief often exceeds 50 feet and the highest
point has an altitude of 211 feet above msl. Much of the eastern
portion of the southern section of the "island is nearly flat;
local relief is a few tens of feet. Its highest point has an
altitude of about 170 feet above msl. Of the approximately 50
ponds in the area, about 12 are larger than an acre. Many ponds
and swamps in the higher parts of Block Island go dry during the
summer and most of the streams on the Island are intermittent.
The Island is principally covered by low to medium height
shrubs such as bayberry, rusugo rose, sumac and chokeberry.
Presumably, early settlers had used all available forests for
fuel and lumber.
6
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MAP 4
NEW SHOREHAM. BLOCK ISLAND
TOPOGRAPHY
NORTH
HURRICANE HIGH WATER LINE
SOURCE LAND USE ANALYSIS, NEW SHOREHAM, R. I. , 1968
-------
The area of development proposed to be sewered encompasses
the eastern halves of the first and third topographical units
discussed above.
Geology, Block Island was affected by two or more periods
of Pleistocene glaciation. However, most of the superficial
glacial deposits were left by the most recent glaciation. Most
of the glacial deposits on Block Island are part of the terminal
moraine, consisting of till and sorted drift, that extends
northeastward from the Bonkonkoma moraine of Long Island to
Nantucket.
Till generally has low porosity and permeability because all
sizes of rock debris were dumped together by the melting ice so
that the smaller particles fill the pore spaces between the
larger rocks. Till particles range in size from clay to
boulders.
Although sorted drift has the same size range of rock
particles as till, the drift has been sorted and layered by
glacial meltwater streams so that individual layers generally
have a narrow range of particle size.
Since the Pleistocene glaciation, wave erosion of the
cretaceous and glacial deposits around the perimeter of the
Island has formed sea cliffs along large parts of the shoreline.
Pebbles and coarser materials have accumulated at the base of the
cliffs while sand and finer particles have been transported away
by ocean currents. Some of the sand has been redeposited as
beaches on the lee side of the Island, along the western shore of
the northern part of the Island, and around Great Salt Pond.
Till, sorted drift, and beach deposits are the materials
which would be encountered throughout the trench depths required
for sewer construction. Severe excavation techniques such as
blasting are not expected to be necessary.
The major portion of the Island is overlaid by two types of
fairly permeable soils, as shown on Map 5.
1. Narragansett Fine Sandy Loam, well drained non-stony
soil, which covers the northern and southeastern parts of
the Island, is formed on sorted drift and compact till.
This soil usually averages about 2 feet in thickness and
occupies gently rolling to rolling areas. The natural
drainage is good, but do to a relatively compact substratum.
7
-------
f
NEW SHOREHAM.BLOCK
ISLAND
SOIL CHARACTERISTICS
NORTH
o i n i
MILE
ROAD CLASSIFICATION
|\^\| WELL- DRAINED NON-STONY |'* *«£[
SWAMP OR MARSH
WELL-DRAINED STONY
BEACH OR DUNE SAND
lllllllllllllP00RLY °BAINE°
MAP 5
SOURCE- COMPREHENSIVE COMMUNITY PLAN,
NEW SHOREHAM, RHODE ISLAND 1968
-------
the downward movement of water is retarded to some extent
and the soil has a fairly high water holding capacity.
2. Gloucester Stoney Fine Sandy Loam, well drained stony
soil, which covers the southwestern part of the island, is
formed on sorted drift and relatively permeable loose sandy
till. This soil averages about 2 feet in thickness and has
developed in areas having steeply rolling relief. Natural
drainage is gccd to exbessive.
A third type of soil. Whitman Silty Clay Loam, is poorly
drained and occurs only in a few small bodies which occupy small
depressions or pot holes and are practically stone free. Natural
drainage is poor and water stands on the surface in wet seasons.
The Muck and Peat Areas are composed of deposits of organic
matter in varying degrees of decomposition. None of these areas
are drained and water stands on the surface of the ground most of
the year.
The Coastal Sand Areas, including beach and dune sand, have
value only for recreational purposes.
Evaluation of the above soils would indicate that only the
two well drained types, Narragansett Fine Sandy and Gloucester
Stoney Fine Sandy Loams, are satisfactory for onsite septic tank
disposal fields year round. The Gloucester type in the steep
phase is not satisfactory due to its erosive characteristics, and
a considerable area in the southwestern section of the Island has
slopes greater than 12 percent. However, this is only a general
analysis and individual onsite investigations are necessary prior
to approval of septic system locations.
An important factor of the geolcgy of Block Island is the
lack of the proper type of gravel and stone for septic tank
leaching field construction. Good "bank run gravel" for fill
purposes and 1/2-1 1/2 inch washed, crushed stone for leaching
field construction are not readily available.
Ground water. The source of all fresh water on Block Island
is precipitation. Since the water vapor for this precipitation
is derived by evaporation from the ocean, the precipitation
falling on Block Island contains more salt than that falling on
most mainland areas. Part of the Island's precipitation runs off
into the sea, part returns to the atmosphere by evaporation and
8
-------
the remainder seeps into the ground. Map 6 displays general
areas of ground water availability on Block Island.
Ground water on Block Island occurs principally within three
types of layers: The upper perched water bodies, the lower
perched water zone and the main zone of saturation, in order of
increasing depth below land surface.
The upper perched water bodies are not considered a
dependable source of supply. Many of the upper perched ponds and
wells tapping the perched water go dry during the summer. Only
domestic water supply systems utilize the upper perched water
with yields averaging about 5 to 10 gallons per minute (gpm).
The lower perched water zone is supported by aquicludes of
clay or compact till and underlies considerable areas of the
northern and southern sections of Block Island. Maximum well
yields from the lower perched zone may be as much as 80 gpm.
The main zone of saturation is continuous beneath all of
Block Island. The upper part of the main zone of saturation
consists of fresh ground water, the lower part is saline. The
water table of the main zone of saturation is only 1 or 2 feet
above sea level in the lowland and shore areas of Block Island.
The mid-southern section of the water table ranges from 3 to 18
feet above sea level.
The most important source of fresh ground water on Block
Island is the lower perched water zone in the southern section of
the Island. For several decades, it has been a reliable source
of water for public supply. Recharge to this perched water body
is roughly estimated to be 720 million gallons per year. The
yield obtainable by normal development methods is estimated to be
on the order of 1 million gallons per day (mgd). Most discharges
from the lower perched water zone are natural, only about 15
million gallons per year are discharged from wells on the Block
Island Water company.
The yield of fresh ground water from the main zone of
saturation depends primarily upon the height of the water table
above sea level. For each foot the water table stands above sea
level, a maximum of about 2 gpm can be pumped without saltwater
encroachment. Thus, the best potential area for development in
the main zone of saturation is the southern section of the Island
where the water table is highest.
9
-------
WATER COMPANY WELLS
NEW SHOREHAM.BLOCK ISLAND
GROUND WATER AVAILABILITY
ROAD CLASSIFICATION
MEDIUM-DUTY LIGHT-DUTY UMIMPHOVED WHT _
|j|'i|j|[|jjj|||[fl|| FAVORABLE GROUND WATER I I I I I I MINIMAL GROUND WATER
I DEVELOPMENT DEVELOPMENT
MODERATE GROUND WATER | NOT SUITABLE FOR GROUND
WATER DEVELOPMENT
MAP 6.
SOURCE: COMPREHENSIVE COMMUNITY PLAN,
NEW SHOREHAM, RHODE ISLAND 1970
BLOCK ISLAND
-------
Fresh and Sands Ponds in the southern section of Block
Island, when used together, would be a potential source of water
supply- Sands Pond is used seasonally by the Block Island Water
Comapny. Both ponds are a part of the lower perched water zone
and have a surface area of about 0.05 square mile, direct
recharge averages about 25,000 gpd.
Overland runoff and ground water discharge into the ponds
also contribute some recharge. Each pond is reported to average
about 10 feet in depth. About 10 million gallons of water is
stored for each fcot of their depth. It is assumed that at least
5 feet of the 10 feet pond depth is perennially available. Thus,
about 150,000 gpd can be withdrawn safely from the ponds.
Treatment, in accordance with State requirements for adequate
sanitary protection, would be necessary.
Water Quality. The State of Phode Island, Dept. of Health
has classified the relative quality of all the waters of the
State by means of a letter designation. The present and proposed
classification for most of the waters around Block Island is
S (A), the highest marine water quality designation. Two
exceptions are closures around the docking areas in Great Salt
Bay and Old Harbor (shown on Map 7). Both closures were given
the second highest marine water classification S(B). The uses
and standards of quality of waters under each of these
classifications are defined by the State and shown on Table 1.
Although the existing classifications indicate a relatively
clean water environment, apparently there are localized
conditions where the quality of water is in violation of the
standards set forth under each classification. Little data is
available on existing water quality levels for Block Island
except for a survey done in 1973 by the Rhode Island Department
of Health on Great Salt Bay (see Appendix A). However, officials
from the State Dept. of Health, Division of Food Protection and
Sanitation have attested to the severity of existing localized
conditions.
The cause of local violations of water quality standards is
directly attributable to untreated or partially treated
discharges of domestic wastewater. No public sewers exist within
the town. Waste disposal throughout the town is handled entirely
on an individual basis by means of septic tanks, cesspools or by
direct outfalls to ponds, harbors or the ocean. In the
Engineering Report developed by Fenton G. Keyes Associates, the
sources of pollution were identified as wastes from pleasure
10
-------
TABLE 1 - Rhode Island Water Quality Standards for Sea Water
CLASS SA: Suitable for all sea water uses including shellfish harvesting
for direct human consumption (approved shellfish areas), "bathing,
and other water contact sports.
Standards of Quality
Item
Water Quality Criteria
1. Dissolved oxygen
2. Sludge deposits—solid refuse
floating solids
oil
grease
scum
3. Color and turbidity
^. Coliform bacteria per 100 ml
Not less than 6.0 mg/l at any time.
None allowable
None in such concentrations that
will impair any usages specifically
assigned to this Class*
Not to exceed a median MPN of 70 and
not more than 10$ of the samples
shall ordinarily exceed an MPN o'f
230 for a 5-tube decimal dilution or
330 for a 3-tube decimal dilution
5. Odor
6. pH
7. Allowable temperature increase
8. Chemical constituents
None allowable
6.8 - 8.5
None except where the increase will
not exceed the recommended limits
for the most sensitive water use.
None in concentrations or combinations
which would be harmful to human, animal,
or aquatic life or which would make the
waters unsafe or unsuitable for fish
or shellfish or their propagation,
impair the palatability of same, or
impair the waters for any other uses.
9. Radioactivity
10.1
-------
TABLE 1 - Hhode Island Water Quality Standards for Sea Water (Continued)
CLASS SB: Suitable for "bathing, other recreational purposes, industrial
cooling and shellfish harvesting for human,consumption after
depuration (restricted shellfish area); excellent fish and
wildlife habitat; good aesthetic value.
Standards of Quality
Item Water Quality Criteria
1. Dissolved oxygen Rot less than 5-0 mg/l at any time
2. Sludge deposits Not allowable
solid refuse
floating solids
oils
grease
scum
3. Color and turbidity
1+. Coliform bacteria per 100 ml
Hone in such concentrations that
would impair any usages specifically
assigned to this class.
Not to exceed a median value of
TOO and not more than 2,300 in. more
than 10JS of the samples
5. Taste and odor None in such concentrations that would
impair any usages specifically assigned
to this class and none that would
cause taste and odor in edible fish
or shellfish
6. pH
7. Allowable temperature increase
6.8 - 8.5
None except where the increase will
not exceed the recommended limits on
the most sensitive water use assigned
to this class
8. Chemical constituents Hone in concentrations or combinations
which would be harmful to human,
animal or aquatic life or which would
make the waters unsafe or unsuitable
for fish or shellfish or their
propagations or impair the w&~er for
any other usage assigned to this class.
9. Radioactivity
10.2
-------
crafts, overflowing and inadequately drained septic systems and
direct outfalls. A generalized indication of the location of
these discharges is shown on Map 7. Their existence has created
a potential health hazard on the Island.
Specifically, in the New Harbor area (north of Beach
Avenue), there are several structures whose combined septic
effluent is collected in a pit cn the shore and subsequently
seeps into the harbor. In addition to many single direct
discharges, there is one discharge whose effluent flows very
close to a spring-fed water supply pumping station. Also, there
are several low-lying leaching fields whose operation is limited
by high water table conditions.
The Old Harbor Village is heavily developed with
characteristically small lots and large structures. This
condition results in septic systems with relatively small
leaching fields (or none at all) . These small fields, which
serve many of the hotels and commercial establishments, appear
sufficient for winter operation but are undersized for the great
demands put upon them by the large influx of summer population.
In both Harbor areas, pleasure craft dispose of their
sanitary wastes overboard, and until January 1975 there were no
Federal or State regulations controlling such disposal. (New
Federal regulations aimed at correcting this problem are
described in Appendix B.) In any event, no disposal facilities
such as pumpout stations are presently provided at marinas to
relieve the pleasure craft of these wastes. In addition, no
public toilet facilities are available on the Island to boaters,
thus increasing discharges from pleasure crafts.
Noise Levels. Ambient noise level measurements were
conducted by EPA in the proposed study area and more specifically
in the area adjacent to the proposed treatment plant site. A
summary of those results are given in Table 2.
11
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MAP 7
NEW SHOREHAM, BLOCK ISLAND
WATER QUALITY CLASSIFICATION
CLOSURE MAP
NQRTH
SEA WATER CLASSES
CLOSURE AREA
m GENERALIZE AREA OF FAILING SEPTIC SYSTEMS
SOURCE' STATE OF R.I.,DEPT. OF HEALTH, \ )\
DIVISION OF WATER POLLUTION CONTROL, )
"PROPOSED CLASSIFICATION OF WATER QUALITY MAP"l973f -
STATE OF R.I..OEPT. OF HEALTH, J q
DIVISION OF FOOD PROTECTION ON SANITATION. !
SA
SB
SA
SB
Ql~ a
-------
TABLE 2 Noise Levels on Block Island - January 1975
Location Time of Day L90 Leg
Location on High St. 10:15 to 10:30 29 dBA 34 dBA
(approx. 100 ft. from plant
12:12 to 12:27 27 34
14:50 to 15:05 26 47*
Ballard's Hotel 11:12 to 11:27 35 39
(approx. 250 ft. from plant)
esidence on Road "M"
(approx. 500 ft. froqi plant)
esidence on Spring St.
(approx. 300 ft. from plant)
14:11 to 14:26 33 38
Residence on Road "M" 10:48 to 11:03 34 50**
13:20 to 13:35 38 51**
Residence on Spring St. 16:04 to 16:19 25 44
* aircraft overflights dominate Leq value
** high Leq due to vehicle traffic on Road "M"
Source: EPA Measurements
These levels are indicative of a very quiet noise climate in
the vicinity of the proposed treatment plant. On the basis of
the above data, a crude estimate of the daytime equivalent sound
level (Leq) is 40 decibels (dBA) and it can be estimated that
nighttime Leq would be about 27 dBA. These values can be
combined to obtain an estimated day-night average sound .level
(Ldn) of 39 dBA.
This estimate is probably only valid during the winter
season and it can be expected that the noise levels will increase
somewhat during the summer months due to the seasonal increase in
population.
Air Quality. No major sources of air pollution presently
exist on the Island. From 1969 through 1972# the State of Rhode
Island Department of Health maintained an air quality monitoring
station at the New Shoreham Airport on Block Island
(approximately 1 mile west of the proposed wastewater treatment
plant). Data obtained from this station are shown in Table 3.
It can be seen frow Table 4 that none of the air quality data
12
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TABLE 4 - Comparison of National Primary and Secondary
Standards and Rhode Island Air Quality Standards
Pollutant
National Primary
Standard
National Secondary
Standard
State of R.I.
1973 Goal
State of R.I.
1975 Goal
Particulates
75 ug/M3 (annual
geometric mean)
60 ug/M3 (annual
geometric mean)
60 ug/M3* (annual
geometric mean)
50 ug/M3* (annual
geometric mean)
260 ug/M3 (24-hr
maximum)
150 ug/M3 (24rhr
maximum)
168 ug/M3* (24-hr
maximum)
130 ug/M3* (24-hr
maximum)
Sulfur Dioxide
80 ug/M3 (annual
arithmetic mean)
o
60 ug/M (annual
arithmetic mean)
72 ug/M3* (annual
geometric mean)
57 ug/M3* (annual
geometric mean)
1300 ug/M3 (3-hr
maximum)
858 ug/M3* (1-hr
maximum)
687 ug/M3* (1-hr
maximum)
365 ug/M3 (24-hr
maximum)
260 ug/M3 (24-hr
maximum)
358 ug/M3* (24-hr
maximum)
286 ug/M3* (24-hr
maximum)
Nitrogen Dioxide
100 ug/M3 (annual
arithmetic mean)
100 ug/M3 (annual
arithmetic mean)
NONE
NONE
Carbon Monoxide
10 mg/M3 (8-hr
max. average)
40 mg/M3 (1-hr
max. average)
10 mg/M3 (8-hr
max. average)
40 mg/M3 (1-hr
max. average)
9.2 mg/M3* (8-hr
max. average
NONE
Total Oxidants
160 ug/M3 (1-hr
max. average)
160 ug/M3 (1-hr
max. average)
118 ug/M3* (1-hr
max. average)
NONE
Hydrocarbons
160 ug/M3 (3-hr
max. average)
160 ug/M3 (3-hr
max. average)
118 ug/M3* (3-hr
max. average)
NONE
*Standard conditions for measurements are established at 25 °C, 1 atm pressure.
Source: State of Rhode Island, Department of Health
-------
measured during this period even approached violations of
National Ambient Air Quality Standards or Rhode Island Ambient
Air Standards; and therefore, the State discontinued the
operation of the site.
TABLE 3 1970 Air Sampling Data
Block Island Airport*
Pollutants
Particulates Sulfur-Dioxide Nitrogen-Dioxide
Number of Readings
13
12
12
Maximum 2 4-hours
66.7
15.7
86.5
Minimum 24-hours
19.2
7.9
5.6
Arithmetic Mean
36.8
8.7
12.4
Geometric Mean
34.2
-
-
Standard Deviation
1.45
1.23
2.20
~latest
complete
data available
Source: State of Rhode
Island Department of Health
Fish and Wildlife. The predominant fish species found in
the waters adjacent to Block Island are: yellow tail flounder,
ocean pout, little skate, winter flounder and spiny dog fish.
Commercial fishing on the Island is limited to the off-season, as
the primary occupation of fishermen on the Island is
shellfishing. Lobster harvesting is minimal but clams and
scallops are harvested in great quantities. Great Salt Pond,
which is protected from the ocean currents, contains at least
five species of shellfish commercially available to local
fishermen. A marine biologist from the Rhode Island State
Department of Natural Resources indicated that about 80S of the
shellfish (hard and soft clams, mussels and bay scallops) are
located in beds outside of the closure (shown on Map 6) in the
open classification of this natural saltwater pond.*
The hard clams and ocean quahogs are distributed around the
Island with concentrations of surf clams growing in beds close to
shore. The quahogs and hard clams are in waters about one to two
miles off-shore predominantly on the western side of the Island.
There are clams on the eastern side; however, the density and
* Memo from Edward Wong, Natural Resource Officer, Surveillance
and Analysis Division, EPA.
13
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yield is commercially less attractive and because of wire cables
extending out of Old Harbor, there are restrictions on the
dredging operations in that area. The fishing fleet is made up
of between four and six dredge beats operating simultaneously,
although not consistently, on a day-to-day basis.
The waters around Block Island have become increasingly
valuable during the past three years due to an increase in the
production of the ocean quahog and surf clams whose sources are
traceable to this area. In the listing of the Rhode Island
Landings, Summary of 1971, dredge boats harvested 1,650,000
pounds of clam meats, having a landed value of about $286,000.
This is a conservative figure because the largest operator
reported a landed value on ocean quahogs to his firm alone for
1973 in the order of $306,000. All of these clams were collected
from areas west of Block Island and parts of Rhode Island Sound.
Most of the extensive harvesting is on the western side of. the
Island. After processing by the food industry, the retail value
of the shellfish is several times the landed value.
Wildlife on Block Island includes birds and small mammals.
The Island serves as a migratory resting place for several
varieties of birds, many of which can be seen in the Wildlife
Refuge at Sandy Point. None of these birds are on the United
States List of Endangered Fauna. One mammal species of
significance is the Block Island Meadow Vole. This small rodent
is found in areas of beach grass and uncut fields on about 600
acres of the Island. The vole has been decreasing in numbers due
to alteration or elimination of its habitat caused by the
construction of buildings and roads on Block Island.* However,
it is not likely that this small creature will be included on the
United States List of Threatened Species which is currently being
prepared by the U.S. Fish and Wildlife Service.
Another species which uses the Island as a temporary home
during migratcry travels is the seal. Although neither State nor
Federal Fish and Wildlife agencies have recorded the seals1
presence, many of the Islanders have seen them. The seals are of
special concern because their resting area is on the eastern side
of the Island, in the vicinity of the proposed treatment plant
outfall sewer.
Environmentally Sensitive Areas. Map 8 is an identification
of environmentally sensitive areas on Block Island. A
fundamental definition of an environmentally sensitive area is
any area which is intolerant to major changes by man. It is,
* Clough, C.G., and Fulk, G., Current Status of the Block
Island Meadow Vole, Rhod^ Island, 1971.
14
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MAP 8
NEW SHOREHAM, BLOCK ISLAND
ENVIRONMENTALLY SENSITIVE
AREAS
NORTH
POORLY DRAINED SOIL
GROUND WATER
MARSH AREA
HIGH WATER LINE
SOURCE : EPA REGION 1
-------
therefore, implicit that exploitation of such regions could
result in irreparable and irretrievable damage. Specific land
types which fall under this category are; fresh and salt water
ponds, marshes and wetlands, coastal zones, areas with
impermeable soils, areas which have a slope greater than 15X,
areas with high ground water tables which generally includes any
area on Block Island which is belew the 10 ft. elevation, areas
favorable for ground water supply, and dunes and bluffs.
2.3 Otilities and Other Community Facilities
Water. A small water supply system, owned by the Block
Island Water Company serves about 250 winter and 2000 summer
customers in the Old Harbor and surrounding areas (see Map 9).
The water supply for this system includes two wells with a
reported capacity of 185 gpm and Sands Pond, which is used about
nine months of the year.
The remainder of the Island is serviced by private wells,
springs and in some cases, man-made impoundments. Recent
proposals, however, recommend the enlargement of this system to
service the majority of the southeastern portion of the Island,
including the proposed sewer services area. Such a system would
require a capacity of 650 gpm or 0.6 mgp by 2022.*
Sewers. At present, there is no sanitary sewer system on
the Island. As was discussed earlier, all wastewater is treated
on an individual basis by means of either septic tanks, cesspools
or direct discharges. No public tcilet facilities exist except
for rest rooms available in private establishments, and
facilities to collect wastewater from pleasure crafts are not
available at marinas.
Septage which must be pumped from septic tanks, from time to
time, is disposed of at the recently relocated landfill site.
Gas. Gas is provided by a private bottled gas company.
Electricity. Electricity is generated on the Island by the
Island Light and Power Company. Supply by overhead line is
generally available.
Telephone. A radar link between Pt. Judith and the Island
provides telephone connection to the mainland.
* Fenton G. Keyes Associates, Preliminary Engineering Survey
and Report on Water Supply and Distribution for the Town of
New Shoreham, Rhode Island, May 1972.
15
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MAP 9
NEW SHOREHAM, BLOCK ISLAND
WATER SERVICE AREA
NQRTH
ROAD CLASSIFtCATrQN
yrn.im.f»nTV LIOHT-OUTT UNIMPROVED DIRT _
II111 11 II EXISTING
I I PROPOSED-IMMEDIATE
PROPOSED-FUTURE
SOURCE FENTON G. KEYES, ASSOCIATES, 1972
: RHODE ISLAND DEPT. OF COMMUNITY AFFAIRS, 1968
-------
Refuse Disposal, In 1974, a new 23 acre sanitary landfill
started operation. This new facility is located off West Side
Road near Swede Hill (see Map 10). The site has been approved by
the State for septage disposal and during the summer several
truckloads are brought to the site each week. This site appears
to be adequate to serve the town's solid waste disposal needs,
including septage disposal, for the foreseeable future.*
Other Facilities. The locations of other important public
facilities are shown on Map 10.
2.4 Growth and Land Use Analysis
Population and Socio-economic Trends. The Island^s
population and economic activity reached its peak shortly after
the turn of the century. The Island supported a prosperous
summer trade with flourishing summer hotels, a fishing industry,
and 1,400 year-round residents until the 1920*3.
Subsequently, the 1938 hurricane destroyed the fishing fleet
and, giv^n the distance from land markets, the fishing industry
never recovered. The summer hotel trade began declining here, as
elsewhere with the increased use of the auto in vacations. As
shown in Table 5, the residential population steadily declined to
486 by 1960, and has remained stable since at between 450 to 500
year-round residents.
TABLE 5 - Population
Year
Population
1915
1,414
1930
1,029
1960
496
1970
501
2000
500
Source: U.S. Census of Population 1960 6 1970, Rhode Island;
Land Use Analysis. Rhode Island Dept. of Community
Affairs, 1968.
The population increases by approximately 1,200 summer
residents, 1,000 overnight visitors to the hotels, and 1,000 day
* EPA estimates of site capacity.
16
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MAP 10.
NEW SHOREHAM, BLOCK ISLAND
COMMUNITY FACILITIES
NQRTH
SOURCE-COMPREHENSIVE COMMUNITY PLAN,
NEW SHOREHAM, RHODE ISLAND, 1970.
COAST GUARD! STATION
FERRY DOCK
8ATH HOUSE
PROPOSED COMMUNITY C£f
FBRRY DOCK
AIRPORT
[SCHOOL
.WATER WORKS
» -Q--
-------
visitors on the average day during the 100 day summer season.
Estimates of peak holiday weekends have run as high as 3,000
visitors.
With few employment opportunities, the proportion of the
population in the productive age brackets has declined sharply.
The youth have been leaving the Island to seek educations,
employment, and cultural opportunities. Many who have come to
live there have been older retirees.
Since the first half of the century, the Island's resident
labor force has dwindled to approximately 180 persons. The
maiority are in professional, managerial, craft and service
occupations including construction and maintenance, as shown in
Table 6. Indicative of the highly seasonal economy, 85 percent
of the retail sales are made between May and October. The 1969
median family income of $8,289 was substantially below the Hhode
Island median of $9,733.
TABLE 6 - Labor Force*
Labor
Force
Occupation
1960
1970
Professional S Managerial
53
37
Craftsmen
33
44
Laborers
32
11
Operatives 6 Service Workers
23
34
Clerical
12
11
Sales
8
—
Not reported 6 Other
15
15
Total Employed
176
152
Unemployed
19
28
Total Labor Force
204
180
~Source: U.S. Census of Population, 1960, 1970.
Table 7 summarizes housing trends between 1960 and 1970.
Based on data from both the 1960 and 1970 census, it is
estimated that about forty-eight percent of the housing units
(365) were constructed prior to 1939. From 19 40 to 1960, only 74
new housing units were constructed on the Island, but between
1960 and 197 0, there was a net increase of 314 new dwelling
units. Of these, 301 were built by summer residents as seasonal
17
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homes, an average of 30 units per year. From 1970 to 1974, 125
building permits have been issued for new dwelling units. There
has been very little multiple unit construction on the Island
since 1960. Thus, following several decades of overall decline,
there is an upswing in the construction of new summer homes, but
not as yet in restoration of the former hotel capacity and
businesses serving tourists.
The number of hotel and other overnight tourist
accommodations has, in fact, declined in the past decade, despite
some rental cottage construction. For example, three hotels
totaling over 400 rooms closed. The existing over night capacity
of approximately 1,500-1,800 persons is not considered adequate
to sustain the Island's tourist economy.*
TABLE 7 - Housing Characteristics
Number of Un its
Occupancy I960 1967* 1970
Year-round 195 173 208
Owner-occupied 149 - 153
Renter-occupied 46 - 55
Seasonal (or vacant) 243 486 544
Total - all units 438 659 752
~Year-round and seasonal single family homes, single family
seasonal units in cluster colonies, and 7 housing units in mixed
use structures, but not seasonal rooms.
Source: U.S. Census of Housing, 1960 and 1970, and 1967
Inventory of Housing in Land Use Analysis, Rhode Island
Department of Community Affairs, 1968.
Existing Land Use. Development is concentrated in Old
Harbor, as shown on Map 11. Old hotels, inns, rooming houses,
restaurants and shops cluster along the harborfront. Homes and a
few scattered inns line the five streets radiating into the
countryside, especially to the south and to the southwest toward
the airport.
* Estimates by the Block Island Chamber of Commerce.
See: The Land Use Analysis.
18
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NEW SHOREHAM,BLOCK ISLAND
EXISTING LAND USE
NORTH
»OAO CLASSIFICATION
urmim.miTV LIGHT-DUTY UNIMPROVED DIHT
£ YEAR ROUNp RESIOENT Q COMMERCIAL
Q SEASONAL RESIOENT f HOTEL
¦ PUBLIC ANO SEMI-PUBLIC
MAP II.
SOURCE: LAND USE ANALYSIS, NEW SHOREHAM, RHODE ISLAND, 1968
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Over the last twenty-five years, much smaller scale
development has been taking place in New Harbor, 1.5 miles to the
northwest on Great Salt Pond: a ferryslip three marinas and two
hotels and restaurants. Along Ocean Avenue, leading to New
Harbor, are the Island's power Plant, State highway garage and
fire-police building, as well as wetlands and open land.
Within a couple of blocks of the old harborfront, the houses
become spaced farther and farther apart, with stonewalls
enclosing bayberry heath and abandoned pastureland. The
remainder of the Island is largely open heath, pasture, numerous
ponds and inland and coastal wetlands. The scene conveys a sense
of openness, dotted with an occasional white building. The
openness is illustrated in Map 11 and Column 1 of Table 8, which
summarizes existing land uses statistically. Of the Island's
nearly 7,000 acres, over 5,000 are in heath and open pasture
(including some fields and scrub forest) and another 1,000 acres
are in water and wetlands.
The newer homes are beginning, still almost imperceptibly,
to close in upon this sense of openness. This is becoming
evident in the vicinity of Old Harbor, especially on the uplands
overlooking the Harbor.
State and Local Land Use Plans. Public and privately
sponsored plans for the Island all emphasize the need to preserve
the Island's unique natural environment and chlarm in the face of
development pressures. At the same time, they recognize the need
to strengthen the economy. These plans do not explicitly
forecast population and economic activity, nor do they present
any optimum levels for designing future public facilities.
The Land Use Analysis (LUA) prepared for Block Island in
1968 by the Rhode Island Department of Community Affairs, assumes
500 year-round residents to be the minimum to sustain basic
economic life, and projects this minimum as the population
through the year 2000.
The New Shoreham Comprehensive Community Plan (CCP) attempts
to outline community objectives; tc plan for community
facilities, recreation, conservation and land use; and to
recommend implementation action. The CCP was prepared in
consultation with the Town Council and Planning Board by the
Rhode Island Department of Community Affairs, and was adopted by
the Town Council in April, 1972.
19
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A major stated goal of the CCP is "...to insure that
development will occur in an orderly fashion and will be in
keeping with the present character of the community...". To
protect the Island's ecology and character, the CCP states the
following goals as the Town's official policy:
1. Development shall be avoided on land subject to periodic
flooding.
2. Development utilizing septic tanks shall be confined to
lands having good subsurface drainage.
3. Lands which are difficult and expensive to develop
because of steep slopes, poor soil or other factors
shall be utilized as recreational open space.
4. Waterfront development shall follow the natural
undulations of shoreline and shall avoid long, straight
lines or abrupt curves and angles.
5. Natural areas of special value shall be acquired and
preserved by some public or quasi-public agency whenever
possible.
6. Freedom from air and water pollution is the right, of the
citizens of the community. Any substance added to the
air or water to a degree which damages property,
vegetation, natural resources or commerce shall be
considered a pollutant and shall not be permitted.
7. Local flora and fauna are important to the natural
environment and are a part of our heritage. The town
shall support and encourage programs to protect wildlife
and to maintain and supplement vegetation.
8. The appearance of the town is recognized to be of high
importance to the town's economy, its future
development, and to the pride and pleasure of its
residents. Improved community appearance shall be
encouraged whenever possible. The town government shall
cooperate with individuals and groups which engage in
constructive activities on behalf of community
appearance. A community's heritage should be reflected
in its appearance; therefore, the policy of New Shoreham
shall be to preserve the rural New England character.
This goal involves preservation of buildings or
20
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architectural importance, consideration of the design
relationship between new and existing structures,
preservation of stone walls, maintenance of open space
and so forth.
Recognizing the recent trends in construction of new homes
throughout the Island, the plan emphasizes that many types of
development would diminish the Island*s "unspoiled, rural
character," a strongly held value of the year-round residents and
a major attraction to tourists and seasonal residents.
"Therefore, (the CCP states) the major planning concern in New
Shoreham is to prevent indiscriminate, undesirable development."
At the same time, the CCP provides for additional
development to strengthen the hotel/tourist business base,
lengthening the season and attracting more visitors. Statements
in the CCP about the development potential of the Old and New
Harbor areas and the contiguous, presently sparsely settled areas
assume moderate growth. Also, proposals for a sewer and water
system, new town hall and civic center presume moderate
development.
Map 12 outlines future land uses proposed in the
Comprehensive Community Plans (CCP). These proposed uses take
into account both environmental and socioeconomic objectives,
present land use patterns, soils, flood areas, elevations, ground
water, public utilities, development trends and community goals.
A detailed description of the proposed uses is indicated in
Appendix C. Table 8, Column 2 gives acreage distributions of
these proposed uses.
The draft report. State Land Use Policies and Plan, sets
forth the State, environmental, social and economic goals;
development and conservation policies; and recommendations for
State-local implementation. These are similar to those which the
CCP outlined somewhat more specifically for the Island. The
State Plan also outlines essentially similar future land uses in
its generalized sketch of proposed State land uses in 1990.
These broad designations are summarized in Table 8, Column 3.
A major goal of the State Land Use Plan is to control urban
sprawl. Policies outlined in the Plan with specific regard to
utilities include:
21
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MAP 12
NEW SHOREHAM, BLOCK ISLAND
LAND USE PLAN
NORTH
RESIDENTIAL
OPEN SPACE
RECREATION
DEVELOPED
RECREATION
RESIDENTIAL
MIXED USES
SOURCE; COMPREHENSIVE COMMUNITY PLAN,
BLOCK ISLAND, RHODE ISLAND, 1970
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TABLE 8 - Existing & Proposed Land Uses
ACREAGE DISTRIBUTION
Land Uses* Existing (1970) Proposed (1990) Existing
(CCP) State Plan Zoning
(Col.1) (Col.2) (Col.3) (Col.A)
Mixed - commercial, industrial, 157 170 500
high density residential
Commercial-industrial 34
High density residential 4
Urban public 43
Airport 57
Spoil areas 19
Medium Density Residential - 1 acre lots 108
Medium residential 54
Light residential 54
500
1,100
"mixed"
& low
density"
700
Low Density Residential - 2 acre lots
Scattered residential
Heath
Pasture/abandoned field
Forest
Tilled
Developed Recreation
Open Space Recreation
(Should also include some of
heath/pasture W SE)
Conservation
Water & wet level marshes
ISLAND TOTAL
5,207 3,400 3,400 5,300
157 "woodland
3,169 &
1,577 openland"
239
65
11 30
370 1,000 400
1,090 1,800 1,800 400
6,943 6,900 6,800 6,?00
*Land Use categories combined to form a composite of existing and proposed land use
plans and zoning. Major categories follow the New Shoreham Comprehensive Plan (CCP),
subcategories follow William P. MacConnell, Univ. of Mass., mapping of 1970 land uses
for the Southeastern New England Study, New England River Basins Commission.
Subcategories are grouped into future land use categories in CCP.
Sources:
Col. 1: Compiled from Prof. William P. MacConnell, Univ. of Mass., Dept. of
Forestry and Wildlife Management., "Land Use and Vegetative Cover
Mapping for New England River Basins Commission, Southeastern New
England Study". Based on 1970 aerial photographs overlaid on U.S.
Geological Survey topographic quadrant of Block Island Quadrangle
Categories consolidated by EPA.
Col. 2: Acreage distributions estimated by EPA from Future Land Use Map,
New Shoreham Comprehensive Community Plan Rhode Island Dept. of
Community Affairs, 1970.
Col. 3: Summary of the Report on the State Land Use Policies and Plan, Rhode
Island Statewide Planning Program, Providence, R.I., April 1973.
Col. 4: Acres estimated by EPA from Zoning, Chapter 33 of the Revised
Ordinances of the Town of New Shoreham, enacted June 5, 1967 through
November 5, 1973.
21.1
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1. Policy #5: Locate public water and sewer facilities so
as to shape development in accordance with the State
Land Use Plan.
2. Policy #10: In developments which are of an intensity
to support public water and sewer facilities, coordinate
development with provision of facilities so as to assure
availability of these facilities at the time the area is
developed.
3. Policy #12: Minimize extensions of water and sewer
systems, consistent with gcals to reduce existing
pollution, in order to discourage urban sprawl.
As a major private effort, the Rhode Island School of Design
evaluated the environmental constraints and demand for
development and prepared a study entitled the Block Island
Report. This report has taken the position that development
pressures are fast upon the Island. The report also attempts to
outline environmental constraints and a proposed zoning, design
control, and action program to guide this development. Again no
estimates are made of the future population, but the detailed
suitability map provides a guide tc the location, density and
types of development, which can serve as a planning tool. The
most suitable development patterns are summarized in a proposed
zoning map (shown on Map 13) .
Existing Zoning. New Shoreham's zoning ordinance and map,
first enacted on June 5, 1967 and subsequently amended as
recently as November 5, 1973, essentially projects existing land
use and would permit extension of business and residential
development along and around the axis connecting Old and New
Harbor. The zoning classifications shown in Map 14 are as
follows:
1. Business — commercial establishments and residences,
with special exceptions for hotels and inns.
2. Residence C — single-family dwellings on 1/2 acre lots
with exceptions for two-family dwellings, hotels,
motels, boatels, on 1 acre lots.
3. Residence B — single-family dwelling units on 1 acre
lots, with exceptions for marinas, hotels, motels,
boatels on 3 acre lots.
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MAP 13.
NEW SHOREHAM,BLOCK ISLAND
A ZONING MAP
*0*0 CLASSIFICATION
LIGHT-DUTY
~
~
~
NO USE OR CROSSING
NO STRUCTURES
LOW RESIDENTIAL .OPEN
SPACE, PRESERVATION
UNIMPROVCO DIRT
I MEDIUM RESIDENTIAL
DENSE RESIDENTIAL
ES£$*i5j COMMERCIAL,
DENSE residential
SOURCE THE BLOCK ISLAND REPORT, R I SCHOOL OF DESIGN
\
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MAP 14.
NEW SHOREHAM, BLOCK ISLAND
EXISTING ZONING
NQRTH
BUSINESS
RESIDENCE A
SOURCE; CHAPTER 33 OF THE REVISED ORDINANCES OF THE
TOWN OF NEW SHOREHAM, 1972
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4. Residence A — single-family dwelling units on 2 acre
lots, with exceptions for hotels on 10 acre lots.
5. Beach — bathing, recreation or picnic areas, wildlife
refuges, with exceptions for beach clubs, bath houses
and marinas.
Table 8f Column 4 presents an estimated acreage distribution
of the zoning classifications.
The ordinance also includes the following provisions:
1. Development in residential clusters is permitted by the
Planning Board in Residential Zones A, B, & C, provided they
blend in with the general land use pattern established by the
Zoning Ordinance and stay within the overall maximum density set
for the Residential Zone in which the development would lie. The
Planning Board must review and approve a development plan for
each cluster.
2. Subsurface sewage disposal facilities shall be located
not less than 100 feet from the edge of any pond or stream. In
addition, the subdivision code does not permit any subdivision in
areas subject to periodic flooding; further, existing stream
channels and fresh water wetlands shall be preserved.
Analysis of Existing Plans. Policies and Zoning. No
estimates of future population or economic activity have been
developed that systematically take into account the Island»s
developmental limits necessary to preserve environmental quality
and community character. The Land Use Analysis presents a
maximum estimate of 2,500 additional dwellings if the 3,960 acres
of undeveloped land deemed suitable for development were fully
developed under the existing zoning.# But, the Analysis hastens
to emphasize that such maximum growth would drastically alter the
attractiveness of the Island as a resort.
The CCP cites the marked upturn in construction of new
summer homes as a warning to plan wisely to protect the Island*s
future environment and charm. In balancing environmental and
socioeconomic objectives, the CCP and, by implication, the State
Plan and Town zoning do not evaluate how much development and
what kinds of development the Island can take before development
infringes on the environmental and amenity values that residents
and visitors alike seek to preserve. Nor did the Islanders
debate these issues when they adopted the CCP at town meetings—
* These figures were based on the zoning map in effect in 1968.
Since that time, amendments have been made to the map which
would result in a lesser number of dwelling, units at maximum
development.
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the basic issues of future growth, land development and their
impact on the Island's environmental goals and community
amenities. The unanswered question, the, becomes, "What social
and economic values would the Island have to give up and be
willing to give up in order to retain the high quality
environment, and in particular, the rustic open character of the
Island as a whole, new present even in much of the Old Harbor
area?".
Growth Assumptions. Three major alternate assumptions,
about * the Island*s future growth are summarized below. The three
growth levels are quantified in Table 9.
Present level - Restore existing tourist accommodations
to full capacity, less than 15 percent increase in
summer visitors.
2. Moderate growth - 15 to 25 percent in summer residents
and visitors.
3. Substantial growth - Nearly doubling of summer residents
and visitors.
The Moderate Growth assumption would appear to support goals
of the CCP. It would support major rehabilitation of the old
hotels and inns and allow a modest increase in visitor
accommodations and residences. At the same time, with effective
planning and zoning, the values and character of the Island would
be maintained.
Fenton Keyes Associates design capacity (2,710 equivalent
persons) (Table 12) is in the order of magnitude of the Moderate
Growth assumption.
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TABLE 9 - Growth Assumptions
present - ldttie
Additional growth
Population
Characteristics
Moderate growth
Island Study Area Island Study Area
Persons Equiv. Pers. Persons Equiv. Pers.
Substatial .growth***
Island Study Area
Persons Equiv. Pers.
Basic year-round
residents
Sumner residents
Hotel visitors/
average sunnier day
500 400
1,200 500**
1,500* 1,400
Day visitors/average 1,000 1,000
sunnier day
400
500
700
250
500 450
450
1,500 900** 900
2,000 1,900** 950
1,200 1,200
300
600 550
2,500 1,500
3,000 3,000
2,000 2,000
TOTAL/ftverage
summer day
4,200 3,300
1,950
5,200 4,450 2,600
8,100 7,050
(1) Equivalent Persons computed as follows: a) year-round & summer residents = 1 equivalent person;
b) Hotel visitors - 0.5 equivalent persons; and
c) Day visitors - 0.25 equivalent persons
* Estimated capacity, assuming rehabilitation of existing hotels and inns.
** Forty-five percent of sunnier residents are within Study Area.
*** Assume approximate doubling of summer residences, hotel visitors, and day visitors.
550
1,500
1,500
500
4,050
Source: Estimates by EPA based on discussion with Town and State officials.
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3.0 ALTERNATIVES
The following section deals with the description and
evaluation of possible alternatives that Block Island could
pursue in its attempts to improve existing wastewater treatment
techniques. *fo effectively evaluate possible avenues of action;
and to do so in a manner that will result in the most cost
effective, environmentally sound alternative; the analysis
concentrates on what are considered the four most practical
alternatives. They are:
Alternative A. Construction of the project proposed by
Fenton Keyes Associates, which includes a treatment facility
and collection system to serve the Old and New Harbor
sections of the Island (Stage I) with provisions to serve
the area south of Old Harbor in the future (Stage II).
Alternative B. Construction of the project (Stage I)
without provisions for sewering the area south of Old Harbor
in the future.
Alternative C. No sewer construction, but a comprehensive
program for the rehabilitation of individual septic systems.
Alternative D. Construction of a treatment facility and
collection system for the Old Harbor area only, with
rehabilitation of individual septic systems in the New
Harbor area.
Also evaluated is the alternative of NO ACTION. Although the
least practical, it is presented to facilitate the reader's
understanding of the consequences of doing nothing.
Discussed below are common sub-alternatives which affect all
or some of the major alternatives to be addressed. An individual
analysis of each major alternative and its environmental^impact
is presented in Chapter
3.1 Alternative Treatment Plant Locations
For Alternatives A, B, and D above, a suitable site for a
treatment plant is required. In the proposed project
(Alternative A), a site was selected near Old Harbor on Spring
St. Alternative sites were evaluated, one near the Island*s
Power Plant and another further scuth on spring St. Neither site
displayed significant advantages over the proposed location and
25
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were not recommended. It should be assumed throughout this
impact statement that any reference to a treatment facility
location refers to the Spring St. site.
3.2 Multiple Facility Alternatives
For Alternatives A, B and D under discussion, theuse of
more than one treatment plant was studied. No multiple facility
arrangement was found to be practicable. The major deterring
factor was the requirement by the Rhode Island State Department
of Health, Division of Water Supply and Pollution Control that
there be only one discharge into the waters of Block Island.
Thus, any benefits of a two plant system would be negated by the
additional cost of pumping to one outfall location. Other
factors such as operating two facilities and utilizing two areas
for treatment plants also made the multiple facilities
alternative unattractive.
3.3 Treatment Process Alternatives
A variety of treatment processes were evaluated by EPA in
addition to the process recommended in the proposed project
(Alternative A). In the analysis which follows, two points must
be noted; first, the analysis was based on a .30 mgd facility
(Alternatives B and D would not require a facility that large),
and secondly, the cost shown for each treatment type reflect
average costs for New England are are not specifically
representative of costs on Block Island.
Certain treatment processes were eliminated immediately as a
preliminary analysis of the Block Island situation indicates that
they are not feasible. For instance, the conventional activated
sludge process and several of its modifications such as step
aeration and tapered aeration have been determined not feasible
for a plant of this small size. The trickling filter process was
not considered because of inadequate treatment and possible
nuisance problems. Primary treatment alone was not considered
due to the fact that secondary treatment is required by law.*
The following treatment systems were considered feasible for
a project such as Block Island and are evaluated in more detail:
1. Extended Aeration
a. Aeration tanks (proposed project)
b. Oxidation ditch
* Federal Water Pollution Control Act, Public Law 92-500.
26
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2. Modified activated sludge (contact stabilization)
3. Aerated lagoons
4. Stabilization
5. Physical-chemical
6. Land disposal
A cost breakdown for each of the above systems is displayed
in Table 10.
Although the tabulation of basic average annual costs
indicates that certain alternatives appear more cost-effective
than others, evaluation of special considerations will tend to
show that the alternatives are really more equal than might
appear.
Extended Aeration. The alternative chosen by Fenton Keyes
Associates, that of the extended aeration process with aeration
tanks has the highest initial construction cost and average
operating costs. It is, however, the system which is in greatest
use for the size project proposed and is probably the best
overall method for treating the large flow variation between
winter and summer. A minimum of operational manpower and skill
are required to produce a good effluent and will result in the
production of a relatively small volume of stabilized sludge
which can be easily disposed of.
The use of oxidation ditches as a method of extended
aeration treatment is a very similar process to the above system
and appears to be far less costly to construct. However, the
basic oxidation ditch system is not able to handle the extreme
variations in flow of the Block Island system and would have to
be modified by construction of an additional small ditch to
accommodate winter flows only. This may increase the initial
construction cost to an amount near the amount estimated for an
aeration tank system. The oxidation ditch system would require
only slightly more land area. However, this would be sufficient
to preclude use of the presently proposed site. If a new site
were found for this system, it may not be centrally located and
would result in adding to the cost of the collection system and
outfall sewer. The oxidation ditch is generally more susceptible
to adverse weather conditions which could cause operational
problems.
27
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TABLE10- Average Costs for 300,000 Gal/day Treatment Facilities
Southern New England
Type Treatment System
Construction
Costs*
Ave. Annual
Bond Payment**
Annual Opera-
ting Costs
Total Ave.
Annual Costs
Extended Aeration:
a) Aeration tanks $ 750,000
b) Oxidation ditch 525,000
Modified Act. Sludge
(Contact Stabilization)
Aerated Lagoons
Stabilization Ponds
Physical-chemical
Land Disposal
640,000
635,000
585,000
450,000
$ 65,400
45,700
55,700
55,400
51,000
39,200
$ 22,500
13,000
35,000
22,500
8,500
40,000
$ 87,900
58,700
90,700
77,900
59,500
79,200
*Based on a 20-year bond issue @ 6% with .08718 - Capital Recovery Factor
**ENR 2100
Source: See Appendix B
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Modified Activated Sludge. The modified activated sludge
process known as a contact stabiliation is slightly less costly
to construct than the proposed system; however, it has the major
disadvantage in being a costly and more complex system to
operate. The major reason for the increased operating cost is
the larger volumes of sludge produced and the necessity to
condition the sludge prior to disposal.
Aerated lagoon. The basic aerated lagoon system is
moderately costly to construct and operate; however, it requires
substantially more land than the proposed system and a new site
would be required. This again would probably result in an
increased cost for the collection system and outfall sewer. It
has been found that these systems generally develop problems with
formation of algae which would cause odor problems and
necessitate additional treatment to correct.
Stabilization Pond. Stabilization ponds have a decided
advantage in construction costs and are quite simple to operate.
However, the extremely large amount of land necessary for this
process could increase the initial cost well above that of other
alternatives, unless most of the land were available to the town
at little or no cost. The cost of the collection system would be
increased appreciably as there is nc centrally located site of
sufficient land area for this system. In addition, the cost to
construct an outfall from this system would be prohibitive as
there are no adequate sites in close proximity to any shore area.
Effluent would, therefore, have to be discharged through
intermittent sand filter beds in a form of land disposal. The
possible environmental effects of this method of treatment would
probably preclude this alternative. Land disposal is disucssed
in detail in a later paragraph.
Physical-Chemical Treatment. The physical-chemical system
has the advantage of being the least costly to construct,
requiring the smallest area, being least susceptible to toxic
wastes (such as boat wastes), being able to handle flow
fluctuation very well and being able to be completely enclosed.
However, this system is the most ccstly to operate and requires
skilled operation. Physical-chemical treatment is generally used
where a high degree of treatment and the removal of phosphorus is
necessary.
Although the use of the physical-chemical treatment
alternative appears to have several technological advantages as
well as an economic advantage over the proposed alternative, a
28
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note of caution must be made. At present, there is no definitive
cost data for municipal physical-chemical treatment plants as
there are few, if any, which have been in operation for any
length of time. The capital and operating costs for physical-
chemical treatment presented in Table 10 are based upon estimates
from pilot plant and demonstration studies upon manufacturers
costs of equipment and upon experience with costs of these
processes in other industries. How the actual capital cost will
be affected by bidding of general contractors is relatively
unknown. Competition may be limited. In some areas, such as
Block Island, it is doubtful that contractors bidding on the work
will be familiar with this type of construction and the resulting
bids are likely to be higher than anticipated.
The annual operating costs presently being estimated for
physical-chemical treatment are even less reliable than the
capital cost estimates. There is little or no data on full-scale
operations of physical-chemical plants for wastewater treatment.
The costs of the chemicals and media used in the processes may
increase rapidly due to increasing demand. Associated with this
increasing demand are uncertainties concerning the long-term
availability of these chemicals and media. For a small user,
such as Block Island, the availability and cost of.such supplies
could become critical in the future as witnessed by recent
experiences with shortages of chlorine. The long-term
maintenance requirements of physical-chemical wastewater
treatment facilities are unknown at this time and can only be
estimated from experience in other industries.
Land Disposal. Land application of the treated effluent and
sludge, at first glance, seemed attractive due to the abundant
presence of soils with characteristics favorable to land disposal
of treated wastewater and the high costs associated with a
submerged ocean outfall. In addition, there appeared to be
sufficient depth to groundwater beneath the acceptable soils even
during the wet season.
The U.S. Department of Agriculture, Soil Conservation
Service advised EPA that the sites tentatively proposed as land
application areas are generally well suited for the intended
uses. One possible conflict noted was the proximity of one area
to the municipal water supply wells at Sands Pond. (See Appendix
K)
By combining the yearly base flow and the seasonal high
wastewater flow a determination of the amount of land necessary
29
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was made. The application period was assumed to be limited to
six months per year due to climate. Using the adjusted flows, it
was determined that approximately 30 acres were required for
spray irrigation and approximately 5 acres were needed for rapid
infiltration.
Analysis of the areas with the best physical characteristics
revealed that without exception there are competing interests for
the sites. The soil type and topographical characteristics most
suitable for land application of wastes also are the best suited
for water supply development, construction purposes and
agriculture. It is not possible, within one to one-and-a-half
miles of the municipal center, to locate an adequately sized
parcel of land a sufficient distance from a public or private
water supply well.
Summary of Treatment Methods. Chart A, which follows,
summarizes the relative merits of each of the treatment processes
discussed above.
While seme of these methods may appear more attractive than
others, in the final analysis several of them could be
successfully employed to treat Block Island*s wastewater. Fenton
Keyes Associates chose the extended aeration process because of
its cost effectiveness and its reliability for small treatment
plants. For the purposes of this report, extended aeration has
been assumed to be the method of treatment to be employed for
Alternatives A, B and D. The following process modifications are
recommended to be made to the plant as presently designed:
1. Provide a method for filtering the final effluent for
use during start up and peak periods in the summer to
ensure removal of excess sclids.
2. Provide a method of supplying air to the sludge storage
tanks to insure complete aerobic stabilization of
sludge, thus preventing odcr problems.
3. Provide a method for controlling odors at the treatment
plant such as introduction of an odor reducing chemical.
3.4 Outfall Location Alternatives
The outfall location chosen for the proposed project is off
Pebbly Beach. A detailed evaluation of that outfall site is
presented under Alternative A. Alternative locations were
30
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CHART A - Comparative Summary of Treatment Methods
Alternative
Technical
Environmental
Economic
1.
Extended Aeration
A. Aeration Tanks
a. Biological system which may
be upset by watercraft wastes.
b. Has ability to operate under
variations in flow.
a. Will meet secondary
effluent requirements.
b. Minimal land requirements.
a. Annual
cost -
$87,90Q
B. Oxidation Ditches
c. Requires minimum of skilled
operators.
d. Minimum amount of sludge to
te handled.
a. Same as above except efficiency
may be more susceptible to
variations in weather.
c. Minimum amounts of odors
and noise.
a. Same as above except
greater requirement for
land.
a. Annual
cost -
$58,70Q
2.
Modified Activated
Sludge
a. Same as for Extended Aeration,
Aeration Tanks, except will
require greater operational
controls and will produce more
sludge to be handled.
a. Same as for Extended
Aeration Tanks.
a. Annual
cost -
$90,70Q
3.
Aerated Lagoons
a. Biological system which may be
affected by watercraft wastes.
b. Less amenable to variations in
flow than Extended Aeration.
c. Sludge handling difficult.
d. Susceptible to adverse
weather conditions.
e. Minimum of skilled operators
required.
a. Will meet secondary
effluent requirements
but generally requires
additional treatment for
algae formation.
b. Considerably more land
required than for
Extended Aeration.
a. Annual
cost -
$77,90Q
4.
Stabilization Ponds
a. Although a biological system,
less susceptible to toxic wastes
from watercraft.
b. Amenable to flow variations.
c. Little or no sludge produced.
d. Least amount of operational
controls required.
a. Generally will not meet
secondary effluent re-
quirements.
b. Minimal noises but re-
quires controls of odors.
c. Large amounts of land
necessary.
a. Annual
cost -
$59,50Q
5.
Physical-Chemical
a. Not a biological system. Not
susceptible to toxic wastes
from watercraft.
b. Best system to deal with
variations in flows.
c. Produces great amounts of
sludge.
d. Requires greatest amount of highly
skilled operators.
e. Requires greatest amount cf
importation of chemicals.
a. Will meet better than
secondary effluent
requirements.
b. Minimum amount of land
required.
a. Annual
cost
$79,20Q
6.
Land Disposal.
a. Not susceptible to toxic wastes
from watercraft.
b. Amenable to flow variations.
c. No sludge produced.
d. Requires great amount of
operational controls.
e. Limited by weather conditions.
a. Essentially produces
no discharge.
b. Largest .land requirements.
c. Aesthetics a major problem.
d. Possible contamination of
groundwater supplies.
f. Requires constant monitoring of
groundwater supplies.
30.1
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investigated but none were considered better than the proposed
site. Because of the State requirement prohibiting a discharge
into Class SA waters, the only possible alternative sites are in
the closures around Old Harbor and Great Salt Pond (refer to Map
7) . A discharge in the Great Salt Pond closure is unacceptable
due to the pond's characteristic lack of sufficient flushing
action. A discharge into the Old Harbor closure, other than at
the proposed site, would be closer to Crescent Beach, the
Island's only public beach and prime tourist attraction. This
also was unacceptable. Thus, in each case, the location of the
ocean outfall required for Alternatives A, B and D is at the
proposed site off Pebbly Beach.
3.5 Sludge Disposal Alternatives
For Alternatives A, B and D, the recommended sludge disposal
technique is by landfill at the Town landfill site. The ability
of that site to handle these residual wastes is discussed under
Alternative A. Alternative and more costly techniques, such as
incineration and dewatering or digestion, were not considered
practicable based upon the small amount of sludge produced by the
recommended extended aeration treatment process.
The disposal of septic tank pumpouts (septage), is also by
land application at the landfill site. Because the present site
is more than adequate, alternative techniques or sites were not
investigated.
3.6 Flow Reducing Alternatives
New technology has made available flow reducing equipment
which when installed in single or multiple unit homes, can reduce
wastewater flows by 15-2 0 percent. The types and costs of the
various equipment on the market are found in Appendix E. On the
average, an initial investment of $500 and an annual cost of $50
would be required to achieve a 15% reduction per single home.
The use of this equipment is not recommended for homes or
establishments that will tie intc a sewer system since it would
have little impact on a treatment plant operation. For homes
that will remain on subsurface systems, especially in the
developed Old and New Harbor areas, installation of this
equipment could have significant benefits. Research has been
done which indicates that installation of these or similar
systems will increase the efficiency of septic systems and
consequently mitigate against their failure.
31
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For Alternatives C or D which would require homes in the Old
and New Harbor areas of the town to remain on septic systems,
installation of the above equipment is recommended to reduce
system failures. As neither Federal or State authorities can
require use of such equipment, it vtculd be the responsibility of
the community to requlate and control its installation and
operation.
32
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4.0 IMPACT OF ALTERNATIVE ACTIONS
This Chapter presents a detailed description of the four
major alternatives outlined in Chapter 3, along with a discussion
of the primary and secondary environmental impacts of these
alternatives and of the NO ACTION Alternative.
Alternative Wastewater Flows
Wastewater flows are based on existing and future projected
populations for the area to be served. The three levels of
population growth discussed in Chapter 2 reflect the total Island
and, therefore, must be modified tc reflect just the proposed
sewered area. The general area under consideration for a
wastewater treatment system is shown on Map 2, and more
specifically, on Map 15 as the area encompassing Stages I and II.
Table 11 presents service area design populations and wastewater
flow for the three alternatives requiring a sewerage system. The
figures for Alternative A were taken directly from the
engineering report for the proposed project. Figures for
Alternatives B and D were estimated from detailed data from the
engineering report. The wastewater flows were based on the total
amoiait of equivalent persons contributing to the system. The
number of equivalent persons at 100 gallons per capita per day
(gpcd) were calculated combining the estimated number of persons
in single family dwellings at (100 gpcd) with persons in multiple
dwellings at 45 gpcd, and the number of persons coming to the
Island on boats at 25 gpcd*.
* The estimate of 25 gpcd for boaters is based on the assumption
that each person visiting the Island by boat will spend a
majority of time on land. Therefore, the estimate represents
22.5 gpcd on land and 2.5 gpcd of 8,000 gal/day, from the boat
holding tanks, and implementation of Federal regulations
concerning holding tanks will have minimal impact on the
capacity of the sewerage system.
33
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MAP 15.
NEW SHOREHAM. BLOCK ISLAND
ALTERNATIVE A
•/.» . ^ •// ~
OCEAN .OUTFAL.
STAGE ONE
STAGE TWO
|STP|w^» f
CONTINENTAL "H ¦
POND
' t%P*rNE y
yr pond
& r
VC\ rT~\
-Jo. ^!a_ ^a, [ I
POND
TOWN WELD®
-------
TABLE 11 - Comparative Equivalent: Service Area
Population and Wastewater Flows
Alternative
EES I G N YEA R
1973
Summer
Winter
1998
Summer
Winter
Population*
A
B
C
2032
1447
901
383
159
90
3000
2415
1271
538
258
150
Wastewater Flow«*
A 203,200
B 144,700
D 90,100
* Equivalent persons
~* Gallons per day
38,300
15,900
9,000
300,000
241,500
127,100
53,800
25,800
15,000
Source: Fenton G. Keyes and Associates and Estimated by EPA
based on data from Fenton G. Keyes Associates.
Actual population projections for the proposed project in
terms of single and multiple units and boats are presented in
Table 12.
4.1 NO ACTION Alternative
Description. The alternative of NO ACTION implies a
continuation of existing conditions and practices of wastewater
disposal on Block Island.
Primary Impacts. As was presented previously, existing
water quality conditions within the Old Harbor and New Harbor
areas of the Island are tenuous. Direct discharges and failing
septic systems would continue, and associated public health,
aesthetic and environmental programs would persist. Pumping and
hauling of septage from overflowing septic systems would go on
with the regularity of the past. For many of the commercial
establishments, it is necessary to pump as often as once a week
during the busy tourist season. Fortunately, the disposal site
for the final dumping of the septage is adequate to handle such
loads, {a further discussion of the septage disposal areas is
34
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TABLE 12 - Actual Numbers of Units, Persons and
Equivalent Persons^ to Be Served
Description
of Units
Type
Unit
No. No. Equivalent
Units Persons Pers./Unit
Equivalent
Persons
1. Old Harbor & Ad j. Area
1972
2.
3.
Single
Multiple & Carcn.v '
Private Boats
Ferry Passengers
No. Dwellings
No. Roans
No. Boats
No. Passengers
166
772
150
1035
581
1545
600
1035
3761
3 5(2)
1 0(3)
1 (4)
581
772
150
104
1607
1997
Single (6)
Multiple & Ccrrni.X l
Private Boats
Ferry Passengers
II
II
II
II
211
822
150
1200
739
1645
600
1200
4184
3 5^
1 0(3)
1 (4>
739
822
150
120
1831
New Harbor & Adj. Area
1972
Single
Multiple & Ccmm.K >
Private Boats
Ferry Passengers
II
II
II
II
17
78
340
695
60
156
1360
695
2271
3 5^
1 0(3)
l (4)
60
78
340
69
547
1997
Single
Multiple & Catim.l >
Private Boats
Ferry Passengers
II
II
It
II
26
308
400
800
91
616
1600
800
3107
3 5^)
1,0 5
0.l(5>
91
308
400
80
879
Phase II Area
1972
single
Multiple & Ccmm.v ;
Private Boats
Ferry Passengers
II
11
II
II
43
28
150
55
3.5^
1.0(3)
150
28
205
178
1997
Single
Multiple & Carni. ^
II
II
75
28
262
55
3.5(2)
i.o(3>
262
28
34.1
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TABLE 12 - Actual Numbers of Units, Persons and
Equivalent Persons^ to Be Served
Description Type No. No. Equivalent Equivalent
of Units Unit Units Persons Pers./Unit Persons
Total Old Harbor & New Harbor (not including Phase II)
1972
Single No. Dwellings 183 641 3.5^ 641
Multiple & Ccnm. No. Roans 850 1701 1.0 (3) 850
Private Boats No. Boats 490 1960 1.0^) 490
Ferry Passengers No. Passengers 1730 1730 0.1^ 173
6032 2154
1997
Single " 237 830 3.5j2J 830
Multiple & Ccnm. (6) " 1130 2261 1.0 1130
Private Boats " 550 2200 1.0 ^ 550
Ferry Passengers " 2000 2000 0.1 (5) 200
7291 2710
Footnotes
(1)
(2)
(3)
(4)
(5)
(6)
(7)
100 gallons per day flow (gpd) contribution = 1 equivalent person for design
of wastewater treatment facilities.
3.5 persons per single family dwelling at 100 gpd/person =3.5 equivalent
person/unit.
2.0 persons per multiple dwelling roan at 50 gpd/person *1.0 equivalent
persons/unit.
4.0 persons per private boat at 25 gpd/person = 1.0 equivalent persons/
unit.
No. Passengers at 10 gpd/person =0.1 equivalent persons/unit.
Allowance for Existing and Future Caimercial Flow included as equivalent
multiple dwelling units.
Source: Final design computations by Fenton G. Keyes Associates.
34.2
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included wider Alternative A), but there are negative aesthetic
affects associated with the transportation of these wastes.
Since the major water supply is or will be taken from ground
water aquifers in the southern section of the Island, discharges
from the Old and New Harbor areas will not affect that supply.
However, seepage from direct outfalls and failing septic systems
into Great Salt Bay, Old Harbor and Crescent Beach could
eventually affect the quality of fishing, shellfishing and water
contact recreation in those areas. The discharge of watercraft
wastes would also continue to contribute a great pollution load
to Great Salt Bay and the Harbor areas, at least until Federal
regulations go into effect.
The State Department of Health has indicated that many
warnings have been issued to establishments on Block Island which
are in violation of the State Sanitary Code. However, sources
from that Department say that they have been hesitant to close
establishments because the Town has exhibited, in good faith,
their intentions to improve conditions with proposals to build
waste water collection and treatment facilities. However, if no
affirmative action is taken, the State will have no course but to
condemn these establishments which continually violate sanitary
regulations.
Secondary Impacts. Under the Alternative of NO ACTION, it
is obvious that growth rates will not increase (see present level
trends in Chapter 2). Yet, it is likely that there will be a
significant change in present land use. Inasmuch as growth
within the established Island cores (Old Harbor and New Harbor)
cannot be assimilated because of inadequate land available for
subsurface disposal systems, it is conceivable the resultant
effect will be the eventual disintegration of the social,
environmental, and economic viability of these town centers.
Further, future developments, if any, will spread outward from
these cores and possibly infringe upon the openness of the
southerly and northerly sections of the Island.
4.2 Alternative A - Fenton Keves Proposed Project
Description. The alternative described and evaluated in
this section is the proposed project submitted by Block Island to
the EPA for funding. This project consists of pumping stations,
interceptor sewers, lateral sewers and a wastewater treatment
plant. The total project is designed to be constructed in two
stages. The first and second stages are shown on Map 15. The
35
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dashed lines ( —) indicate the extent of Stage 2. The design
of the treatment systems was based on the projected waste flows
displayed at the beginning of this chapter, the design capacity
is 0.3 MGD for expected flow through the year 1998.
The treatment plant is to be located on the high land south
of Old Harbor, east of Spring Street (refer to Map 15). The
method of treatment is the extended aeration modification of the
conventional activated sludge process. Properly operated, this
system will remove at least 85% of the suspended solids and 90X
of the BOD contained in the incoming wastes. The units in the
treatment plant consist of grit removal, comminution, six
aeration tanks, two secondary sedimentation tanks, and dual
chlorine contact chambers.
/
Power to operate the system will be generated at the plant
site. This self-sustaining feature was recommended by the
engineers as a result of a cost evaluation of alternative power
supplied. Dual 1200 cubic inch diesel generators are proposed to
supply every-day and emergency power. The multiplicity of units
in the treatment plant mitigates against total equipment failure.
Should such failure occur, however, the storage capacity of the
plant is sufficient to remove virtually all of the settleable and
floating solids.
The effluent from a plant of this type is essentially
colorless and low in suspended solids and turbidity. The
suspended solids (10 to 15 percent remaining) are light and
flocculent, will not form sludge banks, and are relatively
stable.
The effluent is to be discharged into the ocean off-Pebbly
Beach via an outfall sewer (refer to Map 15). Due to the severe
weather conditions that are experienced in the area, it will be
necessary to completely enclose the submerged portion of the
outfall in a concrete case.
Although the extended aeration process normally does not
produce a sludge by-product, at times an excess will build up in
the system. When this situation occurs, excess sludge can be
pumped from the system to a waste sludge holding tank for
ultimate disposal at the landfill located in the southwestern
part of the Island. It is estimated that once every 30 days in
the summer and once every 60 days in the winter, the sludge must
be hauled from the treatment site to the landfill for final
disposal.
36
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Social Impact. The most significant social impact of this
alternative is that it will clean up the pollution problems in
Old and New Harbors and the resulting health and asthetic
effects.
At present, the land on which the treatment plant will be
constructed is zoned for business. However, this site is located
within the Old Harbor area which was designated by the Rhode
Island Historical Preservation Commission as an historic district
and was placed on the National Historic Register in May 1974.
The Commission indicated that it was unfortunate that the site
was to be located in an historical district, but further
indicated that in the future the whole Island may be designated
as an historical area. In that event, the relative effect of a
treatment plant site in that area would be minimal. {See
Appendix 6).
Of greater concern to the Commission was the close proximity
of the treatment facility to the Ocean View Hotel ruins, "The
Shamrock Inn," which is being restored, and the nearby church.
Although the actual site will be in a depression thus affording
some natural cover, a sufficient buffer zone does not exist
between the three structures and the faiclity. Fences and
shrubbery will be required to screen the facility from the
structures- The Commission indicated it will assist in the
design of fences and landscaping that will effectively reduce any
negative aesthetic impacts.
The route of the outfall sewer, from the point it departs
from the roadway and continues through the beach area and
eventually to the ocean, will have aesthetic and psychological
effects. The concrete encased outfall will rise above mean sea
level and will be in effect a groin or pier extending from the
shore out approximately 200 feet. From a visual sense, the groin
will undoubtedly change the natural setting of the area. From a
psychological sense, just the presence of a wastewater outfall
may impart a negative attitude or atmosphere to the area. Health
aspects of this outfall are discussed in the environmental
section.
It can be seen from Map 15 that the sewer routes are in most
cases along existing roadways. It is not anticipated that these
routes will be affected negatively by the interceptor. However,
the impact or short term effects during construction of the
sewers, as well as the treatment plant and outfall sewer, depend
on the time of year the construction takes place. As was
37
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established earlier in this report, the Island's major asset is
its attractiveness as a recreational area. If construction
occurs during the tourist season, the associated disruptions will
have an unfavorable effect on the Island's tourist strade. For
this reason, the condition that there be no construction
activities during the tourist season was included in the design
of the proposed system.
Technical. From a technical standpoint, there is no
indication of problems in construction of either the sewer system
or the treatment facility. The site of the treatment facility is
high enough above sea level to be protected against floods and
the soil characteristics are amenable to construction of such a
unit. Construction of that portion of the outfall that is in the
water, will be difficult, as is reflected in estimated costs;
however, no overwhelming constraints are foreseen.
Because many of the soils in the total project area are
erosive and the topography is steep and undulating, the Soil
Conservation Service indicated that a plan for control of erosion
is required. Such a plan should include provisions to reduce
erosion from excavation areas, stock piled soil material,
construction sites and final revegetation after construction.
Practices that will probably be needed in the control plan
include: temporary and permanent seeding of critical areas,
sediment basins, diversion interceptor dikes, mulching, drainage
log or bailed hay erosion checks, and tree planting in heavy use
areas. In addition, revegetation plans should include only those
plants that are tolerant and adapted to "salt spray" such as,
Japanese Black Pine, Russion Olive, Tatarian Honeysuckle, and
Scotch Broom. The Soil Conservation Service is willing to assist
in the development of such a control plan.
Operation and maintenance of the proposed treatment
facilities could present some problems. Specifically, the
drastic changes in flow due to seasonal changes in population may
upset the biological action in the treatment plant. This will
necessitate additional monitoring and operational activities
during the periods when flows change, at the beginning and end of
the tourist season and possibly cn weekends.
Another problem may be the inclusion of salts and chemicals
in the system from the boat dumping facilities.
The magnitude of saline and chemically treated wastes
emanating from watercraft, that will affect a biological
38
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treatment plant has been determined by various research programs.
A report developed by Ludzork 6 Noran in the October, 1975 issue
of the Journal of the Water Pollution Control Federation
indicated total concentrations of chlorides at the treatment
plant up to 3,000 parts per million (ppm), assuming a reasonably
constant concentration, will not inhibit biological action. For
the treatment system described in this alternative, 2.5 gpcd for
each of the 3,600 boaters contributing, resulting in a chloride
concentration of 645 ppm at the treatment plant. It is not
probable that levels of this nature will impair treatment
efficiency, but during periods of seasonal changes in flow, the
shock loads of high salinity wastewater may cause temporary
disruptions in treatment efficiency.
Additional chemical ingredients which are found in
watercraft wastes, and can be harmful to the treatment system are
zinc and formaldehyde. A research report prepared by FMC
Corporation, San Jose, California for EPA (1974) indicated zinc
concentrations above 20 mg/1 or formaldehyde concentrations
greater than 120 mg/1 cause adverse effects in biological
systems. Based on the projected rate of 2.5 gpcd times 3,600
persons and the reported concentrations for zinc (4,500 mg/1) and
formaldehyde (4,500 mg/1) in watercraft wastes, the resultant
concentrations at the treatment plant will be: 135 mg/1 zinc and
135 mg/1 formaldehyde. Considering the reliability of these
estimates to be within 50%, it is probable that zinc
concentrations, and to a lesser extent, formaldehyde
concentrations will upset the biological treatment efficiency of
the extended aeration facility.
The problem of salts and chemicals in the treatment system
is directly related to EPA, Coast Guard and State regulations
concerning watercraft wastes. The present EPA standard of no
discharge by 1981 will require holding facilities on boats and
pumpout facilities at marinas in the future. Under these
requirements, pretreatment of chemically laded boat wastes will
be required for this alternative and Alternatives B and D, which
also utilize a biological treatment facility. It is possible
that Federal or State authorities will prohibit the use of these
toxic chemicals in which case pretreatment would not be
necessary. However, such action does not appear likely at this
time. It is also possible that the no discharge standard may be
totally abandoned in favor of flow through devices, in which case
no facilities would be required at the marinas. (See Appendix
B).
39
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An example of the type of treatment systems necessary at
each marina under the present law is included in Appendix G. The
exact type of system to suit the situation on Block Island should
be investigated and determined by the design engineer. The
disposal technique of the residual toxic wastes from the
pretreatment process should also be investigated by the engineer.
Because of their expected toxicity, special landfilling
procedures may be required.
The materials to be used in the construction and operation
of the proposed project include concrete, fill material, piping
and machinery, which for the most part will have to be shipped
from the mainland since little or no supplies are available on
the Island. Neither the consumption nor the transportation of
these materials is considered to have a significant environmental
impact.
As stated previously, power will be generated at the
treatment plant. Thus, there will be no consumption of the
Island's municipal energy supply.
Although this type of treatment system, extended aeration,
is known for its reliability and simplicity of operation, under
non-seasonal conditions, the operational difficulties that will
be experienced because of seasonal flows will require skilled
technicians. Finding personnel capable of operating this
facility may require relocating them from the mainland as the
present work force on the Island is limited. This in itself may
be a problem.
Environmental Impact. Discharging over 300,000 gallons of
treated wastes in four feet of water only some 200 feet from
shore presents environmental questions that must be addressed in
details. For this purpose a mathematical model, verified by on-
site investigations was used by EPA to simulate the conditions
that can be expected if a discharge occurs.
The complete analysis is included in Appendix H, however, a
summary of the conclusions are as follows:
1. Drogue studies indicated it is highly improbable that
the wastewater effluent will encroach upon the nearest
bathing area, Ballard's Beach, and at no time will it
reach Crescent Beach.
40
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2. Dispersion models predicted the proposed outfall design
would meet water quality standards most of the time, but
that with an improved diffuser design, water quality
standards could be met all of the time.
The above conclusions were based on secondary treatment
wastewaters with an effluent coliform count of 1000/100 ml. and
the required water quality standards (SB) of 700/100 ml. It was
considered that the treatment plant should at least chlorinate
the wastewater at all times.
Another important question concerning the outfall is its
accessibility to swimmers, strollers, or curious youngsters.
Because the depth of water at the end of the outfall is only four
feet, it is conceivable that could walk out to that point.
Furthermore, the concrete encasement for the outfall, which will
be above water, will afford an even more direct route to the
discharge point. For this reason, it is recommended that the
outfall be extended to a depth which would preclude easy
accessibility (the 10 feet depth would require extending the
outfall some 500 feet) or, some arrangements to limit
accessibility to the discharge point such as fences or warning
signs be employed.
EPA and the State will assist in the design of the improved
diffuser, and the extension of the outfall or the confinement of
the discharge point.
As indicated in the project description, the sludge will be
disposed of no more than 20 times per year at the Town's landfill
site shown on Map 10. The United States Department of
Agriculture Soil Conservation Service was consulted and commented
that the disposal site has well drained, deep, course textured
soils and a water table between 30 and 40 feet deep. Thus, the
site is suitable for the proposed use. Both the State Department
of Health and the local Conservation Commission have approved the
site for sludge disposal.
Since tfce majority of septic tanks now requiring frequent
pumping would be replaced by sewers, the septage load, under this
alternative, coming to the landfill would be greatly reduced.
The present treatment plant design does not contain
provisions for odor control and odors emanating from the
treatment plant may be present. With proper operating practices,
these can be minimized; however, we recommend that odor control
41
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provisions be made. Haulage of the sludge may present some odor
problems as the trucks must pass relatively near the populated
Old Harbor area. However, by collecting the sludge at times such
as early in the morning, when it will least affect the
neighboring populace, the potential problem can be minimized.
A preliminary inspection of the drawings of the treatment
plant indicate that the noise emitted from the plant may bfe
considerably higher than the measured ambient levels (indicated
in Chapter 2), such that a significant noise impact may be
geerated by the plant. The main source of emitted noise can be
identified as:
1. Radiator and radiator fan noise, 75 dBA at 50 ft. These
radiators are located on the outside of the proposed
plant and evidently will not be located behind acoustic
barriers.
2. Exhaust noise, 75 dBA at 50 ft. The engine exhausts
vent directly to the exterior of the building. This
assumes the use of a standard exhaust muffler.
3. Engine noise, 70 dBA at 50 ft. while the engines are
located inside the building in an acoustically treated
engine room, there is a 10 ft. by 5 ft. opening from the
room to the outside for engine inlet air and it is
reasonable to expect about 70 dBA at 50 feet emitted
through this opening.
All three sources are related to the two diesel generators
(approximately 150 KW capacity each) and the dBA levels have been
estimated based on the data given for truck diesel engines in
EPA550/974018, BACKGROUND DOCUMENT FOR PROPOSED MEDIUM AND HEAVY
TRUCK NOISE REGULATIONS, OCT. 1974.
All three sources are visible from the boundary line of the
proposed site and all three sources are located on the inland
side of the proposed building and, therefore, visible to the
adjacent receptors. All three sources together give a single
equivalent source of:
75 + 75 + 70 = 78.6 dBA at 50 ft.
Assuming 6 dB per doubling-of the distance gives 72.6 dBA at 100
ft., 66.6 dBA at 200 ft., 60.6 dBA at 400 ft., and 54.6 dBA at
800 ft. Furthermore, the emitted noise over a continuous 24-hour
42
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period will result in Ldn values of 79 dBA at 100 ft., 73 dBA at
200 ft., 67 dBA at 400 ft.„ 61 dBA at 800 ft., and 55 dBA at 1600
ft. These Ldn values should be compared to the Ldn of 39 dBA
estimated for the existing winter level. During the winter
period, the plant will be audible at distances up to about 1.2
miles with no additional attenuation.
In view of the possible noise impact indicated above, EPA
would require that measures be taken to include noise attenuation
features sufficient to reduce the Ldn at all receptors to a
maximum of 55 dBA. (An Ldn of 55 dBA is identified in the EPA
document, "Information on Levels of Environmental Noise Requisite
to Protect Public Health and Welfare with an Adequate Margin of
Safety11, as adequate to protect against outdoor activity
interference and annoyance). As the noise impact would be the
same for Alternatives B and D, this requirement would apply to
those alternatives as well.
In view of the low ambient levels, an Ldn of 45 dBA should
be set as a design goal to be achieved if economically feasible.
The following are possible solutions to the problem:
1. Use acoustically insulated louvers.
2. Construct an acoustical baffle between generators and
louver opening.
3. Construct acoustical barrier wall around radiator fan
area.
4. Construct earth berra barrier between plant and
receptors.
5. Use improved exhaust silencer.
6. Relocate generators to less sensitive area, if
available.
The proceeding are standard noise-control procedures. The
effects of such procedures on engine efficiency and plant working
conditions must be taken into account by the design engineer.
The Region I Noise Program will provide technical assistance to
engineers to the extent possible.
The only effect of the treatment plant on the ambient air
quality other than the odors from the sewage itself will be
emissions of the diesel generators. Operation of the two diesel
engines, one at a time, will be continuous, burning approximately
57,000 gallons of diesel fuel per year. Using emissions factors
in the EPA publication, "Compilation of Air Pollutant Emission
43
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Factors", Second Edition, AP-42, p.3.1.5-2 (emission factors for
heavy-duty, diesel-powered vehicles), the following annual
emissions are predicted from the diesel engines:
Particulates 741#/year
SCx (as SO* ) 1540 #/year
(Based on ave. sulfur content of 0.2%)
CO
HC
NOx (as NO« )
Aldehydes
12820 #/year
2120 #/year
21200 #/year
171 #/year
(as RCHO)
Organic Acids
171 #/year
No background CO levels are estimated due to the absence of
CO monitoring on Block island. However, as stated in the section
on air guality, no major sources of air pollution (including CO)
exist on Block Island.
Due to the relatively low background levels of SO and
particulates and the relatively insignificant amounts of air
pollutants estimated for this facility, the emissions from the
diesel engine will not cause a violation of any applicable
ambient air standards.
To determine the effect of the treatment system on the
Island's wildlife, various authorities were consulted. According
to the Department of the Interior, U.S. Fish and Wildlife
Service, neither the wildlife refuge area in Sandy Point nor the
"Block Island Vole" will be disturbed by the proposed system. In
addition, Dr. Howard Winn, a marine mammalian expert from the
University of Rhode Island, who has been studying the seals
indicated it was unlikely that the effluent from the proposed
treatment plant would adversely affect the reported seals.
The environmentally sensitive areas indicated in Map 8 were
evaluated with respect to the physical system proposed by this
alternative. There do net appear to be any major conflicts.
Economic Impact. The costs associated with Alternative A
are shown on Table 13. The costs for Stage I are based on bid
prices of August 1974. All other costs are based on best
estimates.
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TABLE 13 - Annual Costs of Alternative A
Construction Ave. Annual Annual Oper- Total Ave.
Cost* Bond Payment ating Cost Annual Cost
Phase I $ 4,383,000 382,000 51,000 409,000
Phase II** 500,000 44,000 0 44,000
Individual
House
Connections 150,000 13.000 0 13,000
TOTAL $5,033,000 439,000 51,000 466,000
* A detailed cost breakdown is included in Appendix I.
** When constructed.
Source: Construction Bids - August 1974 and Estimates by EPA
The Town's share of the construction cost will be borne by a
minor increase in the total tax rate and by betterment
assessments on the properties within the service area. The
operating costs will be covered by service charges based on
extent of user facilities.
In addition to the annual costs of this alternative, there
are other ramifications to the economic base of the Island. It
is a fact that many of the Town's commercial establishments are
suffering economically from a lack of sanitary systems. For
instance, some establishments are limited in the number of people
they can serve, and in some cases establishments have been
closed. Since the Island's economy is based on the ability of
its commercial industries to provide services to tourists, the
improvements provided by this alternative will significantly
benefit the economy of the established Town center.
Political and Legal/Institutional Impact. Many of the legal
and institutional arrangements required to maintain and regulate
a sewer system have already been established by the Town in
anticipation of the construction of this system, including the
Block Island Sewer Commission and subsequent sewer cost
assessments. Some strengthening of these arrangements may be
necessary to better reflect the needs and desires of the
townspeople since the preparation of this impact statement would
45
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indicate that the diologue between local regulatory authorities
and the general public is less than complete.
In addition, the arrangements recommended by the designing
engineer concerning subsurface disposal systems for areas outside
the sewer system are excellent and should be implemented.*
Secondary Impact. Based on the development pressures on the
Island's coastline serving the Northeast*s recreation demand
centers, construction of sewer lines and waste treatment capacity
could be expected to stimulate and accelerate growth on Block
Island.
The design capacity of the proposed project is based on the
assumption that both single and multiple housing units will
double in the study area by 1997. (See Table 12).
The significance of this fact is dependent to a great extent
on two factors: (1) How much development could occur without the
sewer systems, and (2) How that new development is distributed
within the study area.
Based on existing zoning allowances and recent demand for
building permits, doubling of the single housing units will
likely occur within the study area whether or not the area is
sewered. Sewering this area could cause an acceleration of
single family development (see Table 14). However, there has
been almost no recent demand for building permits for multple
units, probably due primarily to the lack of adequate sewage
disposal. Thus, without the new sewers, it is probable that few
multiple unit structures would be built.
It is possible that as a result of sewering this area, the
emphasis will be placed on multiple unit development. A portion
of this multiple development will probably include hotels and
possibly condominiums along with commercial establishments.
These will generally be located in either New or Old Harbor. As
Old Harbor is presently the most densely developed area on the .
island, additional development would likely have the effect on
enlarging the core of the Old Harbor area, possibly causing more
intensive land use without substantial change to its character.
If, on the other hand, the greater portion of the multiple unit
and commercial development occurs in New Harbor, there will be a
noticeable change in the character of New Harbor, simply because
present development in this area is minimal.
* Preliminary Engineering Survey and Report on Control of Water
Pollution for the Town of New Shoreham, R.I., Fenton G. Keyes
Associates, Providence, R.I., Feb. 1972, pp. 20-26.
46
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TABLE 14 - Comparison of Development Trends
in Proposed sewer service area
N E
WON
ITS
0 N
ITS/
YEAR
Total
Single
Multiple
Total
Single
Multiple
Estimated
1960-1970
175
125
50
17
13
5
Projected
for Desicrn
1972-1997
543
188
350
22
8
14
1997-2022
187
42
145
10
2
7
Source: 1) Estimates from U.S. Census and U.S.G.S. maps.
2) Fenton G. Keyes Associates.
3) This estimate includes 36 units in Ballards.
In either case, there will be an eventual demand for an
extension of other public utilities and services such as water
supply, electricity and solid waste disposal.*
A large portion of the area proposed to be sewered by Phase
II is wetlands, and cannot be developed using subsurface disposal
methods. If sewers were made available there is a strong
possibility that development would encroach upon these areas,
despite State wetlands regulations.** Intensive commercial resort
development would be especially likely in the extensive
undeveloped areas in the vicinity of New Harbor, accessible to
Great Salt Pond, marinas and a ferry-slip. New summer home
developments would likely occur both in the vicinity of New
Harbor and in the heights to the south of Old Harbor. There is
even a possibility that, with the extension sewers and other
utility services, a pattern of new condominiums, motels and
summer home developments in presently undeveloped areas could
take place at the expense of revitalization of the old hotels,
homes, and businesses of Old Harbor.
A substantial impact on the character of the residential
areas outside of Old and New Harbors would result from the sewers
only if there were sufficient demand for development to cause
* In 1972, Fenton G. Keyes Associates, prepared a "Preliminary
Engineering Survey $ Report On Water Supply & Distribution
for the Town of New Shoreham".
**R.I.G.L. 2-1-18, 1971 c.213
2-1-13, 1965 c.140
2-1-1
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either zoning changes to smaller lot sizes within the sewered
area or zoning variances to the same end. Such development is
theoretically limited by the design capacity of the sewer system*
but once the system reaches capacity, demand for additional
development could result in pressure for expansion of the system
and the costly expansion of treatment facilities. Then the cycle
could begin again, resulting in denser development of outlying
areas.
Substantial changes in character of these types would be in
direct contrast to one of the Town's prime goals: maintaining
its rural New England character.
It must be recognized that although the design capacity is
based on certain development assumptions, once the capacity is
provided development may proceed in many different ways and at
differing rates, unless the town makes a conscious effort to
control each development through zcning or other planning
techniques.*
On other northeast resort islands, the demand for recreation
facilities and summer homes has resulted in intensive development
and proliferation of resort complexes, condominiums, motels,
shopping centers and well-equipped modern summer residences.
With sewers and other improvements, such development would be
made possible in the vicinity of proposed sewer lines on Block
Island.
It is not probable that an extreme growth situation will
occur on Block island either directly or simultaneously as a
result of the proposed project. But such growth will occur
little by little if the sewer system is permitted to expand with
complementary changes in the zoning densities either by variance
and special permit or bylaw amendment. Based on the experience
of these other places and depending on the strength of
development demand to force zoning changes and further expansion
of sewer and treatment capacity, an extreme growth situation
could result in the following impacts;
1. Impose resort complexes and residences on wetland and
shoreland ecosystems and cn flood hazard areas.
Especially adverse would be encroachment upon the salt
water marshes of the Great Salt Pond embayments as well
as fresh water marshes abutting the Ocean Avenue and
Beach Avenue sewer lines; also, the south shoreline of
Great Salt Pond accessible to the West Side Road sewer
* One such mechanism which could be used to check unwanted
growth attributable to sewer construction is through the
National Pollutant Discharge Elimination System permit.
Effluent quantity limitations at different points in the
design life of the treatment facility, over development of
the sewered area could be controlled.
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line and extensive areas in the south central sector
tentatively proposed for "conservation" or "open space
recreation" in the CCP and for "low residential, open
space preservation", "no structures", or wetlands in the
Block Island Report prepared by the Rhode Island School
of Design.
2. Facilitate condominium and medium density residential
development in the extensive open moors, dotted with
small lakes, to the southwest of New Harbor. Intrude
upon open space character, marsh and upland vegetation
and general sense of openness of the Great Salt Pond
area and view of Great Salt Pond and Block Island Sound.
3. Stimulate medium density residential development (1 acre
lots) on the extensive "lew density residential" and
"conservation" areas southeast and south of Old Harbor
proposed in the CCP. These areas embrace perched fresh
water marshes, ponds, water supply recharge areas, and
the picturesque pasture-bayberry moor vistas of Old
Harbor and the ocean from the Upland Plateau. Proposed
for "low density residential" (2 acre lots) and some
"open space recreation" in the CCP and "low density,
open space preservation" in the URI report (zoning in
conflict with both).
4. Facilitate resort and beach house development northward
along Corn Neck Road toward North Neck, through the
potential for sewer connections. Thus closing in upon
the beaches, salt water marshes and open vistas of the
ocean, Great Salt Pond and North Neck Highlands. Much
of this area presents flood hazards and lies below the
hurricane highwater line.
5. A higher level of development, public services,
commercial activity, tax assessments and overall
publicity about the Island would encourage land sales
and greater numbers of people to build summer homes on
the Island even in areas beyond the influence of the
sewers and treatment plant, thus impairing surface and
ground water and further encroaching upon the open
countryside of the Island hinterland.
6. Greater numbers, densities, and range of activities on
the Island would have an overall adverse impact on the
high quality environment:
49
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°n water quality through runoff from additional
paved and impervious surfaces, through some erosion
and sedimentation cf fragile ponds and wetlands
associated with construction and continuing earch
disturbance, and through additional solid waste-
septage disposal and septic system operation - all
associated with a higher level of development;
- on noise levels through additional vehicles,
lawnmowers, and human activities;
- on air quality through additional motor vehicles and
powered boats;
on visual appeal of sweeping vistas of sea, sand,
and sky; cf rolling moors, pastures, ponds, and
vegetation;
on fragile ecosystems: salt and fresh water marsh
associations, dunes associations, and upland plant
and animal associations.
7- Greater numbers, densities, range of activities, and
standardized outside architectural styles could
overwhelm or clash with the character of the Island
countryside, with the relative open scale of the Old
Harbor community itself, with the indigenous
architecture, and with historic preservation.
On the other hand, a sewer system would help to maintain
the historic hotels, shops, and houses of Old Harbor as
a community cluster.
8. Greater numbers of residents and visitors and diversity
of outside interest could weaken the cohesiveness and
close personal relationsips of a small tightly-knit
Island community. Yet, at the same time, some
additional residents, economic activities, and services
would sustain, enrich, and round out the social fabric
of the community.
9. Additional numbers, economic activity, and services
would provide a base for a sustained year-round economy
and raise the monetary level-of-living. At the same
time, this could lend to greater dependence on values
associated with a cash economy as opposed to a way-of-
50
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life that features a quality environment, indigenous
community charm, and opportunities for solitude.
A section by section analysis of the town under extreme
conditions of induced growth is included in Appendix J.
4.3 Alternative J3 - Proposed Project minus Stage II
Description. It is apparent from an examination of the
Septic System Failure, Map 7 and the Soil Characteristics, Map 5
that septic systems are, at present, working properly in the
Stage II area (refer to Map 15), and by all indications could
continue to work with a reasonable degree of reliability for the
future. Therefore, Alternative B includes a wastewater system
similar to the proposed project which would include Stage I
sewers but not future Stage II sewers. The treatment facility
design under Alternative A includes an additional capacity of
58,500 gallons per day for Stage II. That capacity would not be
required under this Alternative. No other changes from the
system described in Alternative A are suggested.
Primary Impacts. Because of the similarity between
Alternative B and Alternative A, the primary Social, Technical,
Political and Legal/Institutional Impacts will be the same. The
environmental impacts differ only in that the expected discharge
under this alternative will be less than under Alternative A by
58,500 gpd at design conditions. This amount, however, is not
significant enough to consider a redesign of the outfall system
or the treatment process itself. This decrease in capacity
should be handled by a simple restriction on the NPDES permit.
Table 15 lists the estimated costs of Alternative B and
reveals a slight savings over Alternative A. The economic
advantages, however, may be deceiving. While Alternative B would
not require an expenditure of $500,000 for Stage II sewer
construction, growth within the Stage II area will require
construction of new septic systems. Based on moderate growth
projections, individual expenditures for septic system
construction in the Stage II area could total up to $225,000 in
the next 25 years. Further, while the sewer system costs are
partially funded by State and Federal grants, the cost for the
construction of individual septic systems must be entirely borne
by the individual.
Secondary Imcacts. Secondary impacts of this alternative
would be similar to those of the proposed project (Alternative
51
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A), except that there would be nc real pressure for smaller
zoning lot sizes or for multiple unit structures in the Stage XI
area. This would eliminate the potential adverse effects of .such
development on the open space and ground water availability areas
to the south of Old Harbor. Elimination of stage II could result
in directing development to sewered areas in New Harbor. Such
development might eventually encroach on environmentally
sensitive areas adjacent to Great Salt Pond.
TABLE 15 - Estimate Costs for Alternative B
COSTS
Item
Capital
Average
Annual
Operation &
Maintenance
Total
Annual
Treatment Plant
S Sewer System
$4,083,000
355,000
25,000
380,000
House Connection
100,000
9,000
0
9,000
Future Stage II
Septic System
Construction
225.000
20.000
500
20.500
TOTAL
$4,408,000
384,000
25,500
409,500
Source: See Detailed Cost Breakdown in Appendix I.
4.4 Alternative C - Rehabilitation of Individual Subsurface
Disposal Systems
Description. This alternative for dealing with the water
pollution problems of Block Island is based on the continued
utilization of individual subsurface disposal systems.
Subsurface disposal or septic tanks have been demonstrated to be
an effective, reliable, economic and environmentally satisfactory
method for the disposal of wastewater for individual homes at low
development densities and with appropriate soil conditions.
Subsurface disposal systems have served all of the commercial and
residential dwellings on Block Island with many dwellings using
the subsurface systems originally constructed with the building.
However, in the more densely developed commercial areas of Old
Harbor and New Harbor, subsurface systems have failed because of
either poor construction, inadequate soil conditions or
52
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insufficient area for drainage fields. As was stated previously,
the proper backfill (Bank Run Gravel) and trench material (1/2 to
1 1/2 crushed stone) are not readily available on the Island and
were probably not used in many cases.
As was discussed under Alternative B, septic systems in the
Stage II area are working properly and by all indications will
continue to work adequately for the future. Existing systems
which have failed would be reconstructed in accordance with the
State of Rhode Island's standards for construction and
maintenance of individual sewage disposal systems included in
Appendix M. A major assumption of this alternative is that all
subsurface systems in the areas, defined by Stage I of
Alternatives A 6 B, would need to be rebuilt within the next five
years. The life of a reconstructed system is assumed to be
twenty years with annual inspections and pumpout of the septic
tank solids as necessary perhaps once every three years. In
situations where sufficient land is not available to construct
systems to meet State regulations, such land would have to be
acquired. Future developments would also require more stringent
construction practices. Septage from septic tanks would be
trucked and disposed of at the existing landfill site.
The Federal requirements for disposal of watercraft wastes
as discussed in Appendix B may necessitate holding tank pumpout
facilities at each marina similar to those provided in
Alternatives A and B. Under this alternative, wastes pumped out
of the boats will have to be trucked to the landfill site for
disposal along with the septage wastes. Although there is ample
room at the landfill site to accept these wastes, recent research
has indicated that the highly toxic chemicals added to holding
tank wastes as a conditioner could eventually seep into ground
water supplies. Consequently, costly pretreatment to eliminate
such chemicals will be required prior to disposal in a sanitary
landfill.
In order for Alternative C to be considered viable. State
regulations on subsurface disposal must be rigidly enforced in
the future to minimize the possibility of additional water
pollution problems resulting from failing systems. It should be
recognized that design and construction of subsurface disposal
systems is not an exact science, but that careful design and
construction coupled with favorable soil conditions minimize
possible septic tank failure. Seasonal use of these systems
further enhances the prospects for their successful use. An
additional mitigating factor would be the utilization of in-house
53
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flow reducing equipment discussed in Chapter 3 for the critical
New Harbor and Old Harbor areas.
Under this alternative, development would be constrained to
present levels and would be limited, prohibited, or uneconomical
in the law lying areas, generally below elevation of 10 feet.
Environmentally sensitive areas below elevation 10 feet were
presented on Map 15.
Social Impacts. A primary social impact will be general
disruption of services from construction activity during
rehabilitation of the septic systems. Construction impacts can
be minimized, however, by scheduling such activities during
nontourism months. Additional social impact may result from
public health and aesthetic problems of systems which may fail in
the future.
The aesthetic impacts of odors associated with transport and
land disposal of septage and watercraft wastes are expected to be
minimal.
Technical. The continued use of individual subsurface
disposal systems provides a number of technical advantages in
that such systems are simple, and maintained properly. However,
this alternative poses significant problems particularly with
regard to existing buildings which have failing systems. The
failure of these systems may generally be attributed to high
ground water conditions, inadequately sized or constructed
leaching fields, or inappropriate soil conditions. In'the more
densely developed areas of the Island, lot sizes and geographical
locations may physically preclude the construction of
satisfactory subsurface disposal systems. In those cases,
reconstruction of the systems may only provide an adequate
functioning system for several months or less and pumping of the
septic tank on a regular daily or weekly basis may be necessary.
The only possible scluticn for these failing systems is to convey
the wastes to adjoining properties or other locations where
satisfactory systems ecuId be built.
Use of properly constructed subsurface disposal systems will
require the continuation of pumping, hauling and landfilling
septage, but on a less frequent basis than at present-
Environmenta1 Impacts. An advantage of subsurface disposal
is that it serves to recharge the ground water and thereby serves
to sustain the fresh water supply. The long term effects on
54
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water quality of continued discharge to the ground water are
uncertain. However, experience with subsurface disposal systems
at the densit ies proposed on the Island indicate that the effects
would be minimal. In areas served by the community water sysiem,
these impacts would be further reduced (See Appendix N).
The possibility of continuing failure of subsurface disposal
systems always exists. Odors and public health problems which
might arise from sewage seepage would pose a significant
environmental problem.
The magnitude of septage to be disposed of will probably be
less under this alternative than under present conditions. The
possibility of odors and ground water contaminants at the
disposal site are considered to be minimal.
Economic Impacts. The costs cf continued use of subsurface
disposal systems are based on reconstruction of the existing
systems and construction of new systems in accordance with State
of Rhode Island regulations. Reconstruction of existing systems
within the proposed sewered area and new construction of systems
to accommodate new development through 1998 is estimated at
$2,000,000.
As previously noted, several cf the existing systems cannot
be adequately reconstructed because of physical site limitations.
The cost of conveying this wastewater to adjoining properties
where adequate subsurface disposal systems could be constructed
is not included.
Total Capital and Annual Costs of Alternative C, including
costs for handling watercraft wastes are shown in Table 16.
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TABLE 16 - Estimated Costs for Alternative C
COSTS
Item
Capital
Average Operation & Total
Annual Maintenance Annual
Rehabilitation on
future construction
of Septic Systems
in Phase I areas $1,801,000 157,000
4,500
101,500
Future construction
of Septic Systems
in Phase II areas 225,000 19,000
500
19.500
TOTAL
$2,026,000 176,000
5,000
121,000
Source: See Detailed Cost Breakdown in Appendix I.
The continued use of subsurface disposal systems would
require that the costs of necessary system reconstruction and
annual maintenance be financed by private owners. Where
additional land area is required for the construction of existing
systems, private land owners would have to acquire or maike
arrangements for the use of adjoining land. Because of the high
cost of septic system construction on Block Island, the total
costs to be borne by an individual property owner in the proposed
sewer service area would generally be higher under Alternative C
than the total assessments to be made on his property over the
design life of the sewer system. On the other hand, the cost of
this alternative to property owners outside the proposed service
area would be zero as compared with the sewer assessment in the
general tax rate under Alternatives A, B and D.
Political and Legal/Institution Impacts. The continued use
of subsurface disposal systems on Block Island poses special
legal and institutional considerations.
In order for individual systems to be considered a realistic
possibility for dealing with current and future wastewater
management, existing laws and regulations must be rigidly
enforced including the use of stone for leaching fields. While
this may increase the costs of system construction, these actions
are necessary to. reasonably ensure system reliability. Also, the
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minimum distance to ground water from the leaching field should
probably be maintained at 4 feet for all new development on the
Island.
All percolation tests and leaching field construction should
be observed and inspected by regulatory agency personnel,
preferably by a well qualified engineer.
In some instances, these requirements may place the Town and
State regulatory agencies in a politically difficult enforcement
role, particularly relative to existing systems. However, the
adequacy of rehabilitated subsurface disposal systems rests
heavily on the achievement of this regulatory capability.
Secondary Impacts. Similar to the secondary impacts of the
NO ACTION Alternative, this alternative could perpetuate the
deterioration of the Old Harbor town center. Extremely high
costs for the construction or reconstruction of septic systems in
that area could channel development to other areas, instead of
channeling investment in the restoration and clustering
development of the Old Harbor core.
Growth resulting from this alternative would be at or near
"present levels" such that the magnitude of the influx of people
and associated development would not infringe upon the
environmental amenities of the Island. However, the existing
development patterns could be affected with a possible adverse
change in the Island's unique character and its ability to
attract tourists.
A solution would be the adoption and strict enforcement of a
refined zoning plan, with emphasis on environmental suitability,
land capability and community goals. This solution is always
subject to development pressures, but such pressures should be
less intense than those likely to result from construction of a
sewer system.
4.5 Alternative D - Sewer System for Old Harbor
Description. Under Alternative D, only the immediate Old
Harbor area would be served by a sewer system and treatment
facility. Map 16 indicates the extent of this system. In New
Harbor, or the portion of Stage I net served by this system,
inadequate subsurface disposal systems would be ameliorated
through rehabilitation as was discussed iri Alternative C. For
the area south of Old Harbor, Stage II, existing individual
57
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MAP 16
NEW SHOREHAM, BLOCK ISLAND
ALTERNATIVE D
OCEAN OUTFAL
SEWER SYSTEM
^1/'^ c?
~°qt
AREA REQUIRING SEPTIC
SYSTEM REHABILITATION
PAYNE
-------
septic systems can generally continue to be used without
rehabilitation.
The justification for consideration of this alternative is
premised on the general availability of amenable soils and
sufficient land in New Harbor to facilitate subsurface disposal
techniques. Septic System Failures Map 7 indicates many systems#
at present, are failing in the New Harbor area, rehabilitation of
these systems and coupled with the utilization of in-house flow
reducing apparatus, would make individual subsurface systems an
acceptable disposal technique for that area.
The treatment facility for the Old Harbor sewer system under
this alternative would be reduced in capacity to approximately
130,000 gallons per day. This would require a major redesign of
the plant and sewer system possibly involving changes in the
treatment process or sewer routes. For purposes of discussion of
this alternative, it is generally assumed that these things will
not change. Watercraft wastes from marinas in the New Harbor
area would have to be hauled to the Town landfill site.
Pretreatment may be required as discussed in the technical
section of Alternative A.
Social Impacts. The major social impact of this alternative
is that it will provide a municipal service to clean up the
pollution problems in Old Harbor. However, the remainder of the
Island and particularly the New Harbor area will not have the
advantage of municipal responsibility for sewage collection and
treatment. Those areas outside of Old Harbor will have to rely
upon the effectiveness of code enforcement to insure that there
will be no repetition of current problems. While the chance of
failure of proper septic systems is minimal, such failure could
result in adverse public health and aesthetic conditions.
Technical. In order to reduce the capacity of the proposed
treatment plant to 130,000 gal/day, a major redesign would be
required by the engineer. Although the extended aeration
treatment process would be viable under this alternative, during
the redesign process some other treatment method might be found
to be more suitable or more cost effective, in addition, during
the design process, sewer pipes may have to be re-sized and
possibly relocated. This whole process would take a few months,
thus further delaying solution to Old Harbor's problems.
Reconstruction of subsurface disposal systems in the New
Harbor area could begin immediately. Septic tanks will still
58
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have to be pumped out although on a less frequent basis than at
present. Septage from these pumpings and boat wastes from the
New Harbor marinas will have to be trucked to the landfill.
Reduction of the plant capacity would not necessarily
preclude expansion of the plant and system to service New Harbor
at some future time.
Environmenta1 Impacts. The discharge from the treatment
facility in this alternative will be significantly reduced from
that expected in Alternative A. The resultant effect on the
receiving water will consequently be reduced. However, the
reduction in flow is not so great that the outfall sewer
dimensions should be decreased or that the recommendations made
for the outfall sewer in Alternative A be disregarded.
Again* the possibility of septic system failure in the New
Harbor area remains. However, proper code enforcement action
should prevent multiple failure, thus preventing serious
environmental problems in that area^
Economic Impacts. The costs associated with Alternative D
are considerably reduced from those estimated for Alternatives A
and B, as shown in Table 16. Again, however, expenditures for
reconstruction of individual septic systems are not fundable by
either State or Federal grants and must be borned by the
landowner. Therefore, the costs shown on Table 17 represents
overall reduction in costs to the Island and cannot be
interpreted to indicate a concomitant reduction to the costs of
each individual.
Further, the costs to New Harbor properties will likely be
slightly greater under this alternative than under Alternatives A
and B because of the general tax increase necessary to build the
municipal facilities.
Political and Legal/Institutional Impact. The reduction in
the size and extent of the wastewater system in this alternative
will reduce, somewhat, the necessary administrative arrangement
that would be required for a larger system. However, the demand
for regulatory and enforcement controls to oversee construction
or rehabilitation of septic systems will be nearly as significant
as those discussed under Alternative C.
Secondary Impact. The secondary impacts of this alternative
will be a concentration cf growth in the Old Harbor area.
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Overall growth and particularly development of multiple unit
structures will be much less than predicted for the proposed
system without the stimulus of an extensive sewer system.
Therefore, the New Harbor and Stage II areas will essentially
continue to develop at a rate equal to or less than past trends.
Thus, the potential for associated adverse environmental effects
to the wetlands and shoreline adjacent to Great Salt Pond and the
open space and scenic vistas to the south of Old and New Harbors
will be practically eliminated.
It is also clear that without a sewer system, expansion of
the economic base of the New Harbor area may be restricted. This
is, large structures such as condominiums or hotels may be
prevented from building there due to the extremely high costs to
construct large septic systems. Similarly, the large land
requirements for these systems would prohibit dense development.
On the other hand, the economic base in Old Harbor would
benefit, both in terms of rehabilitation of old properties which
have been closed or have reduced operations due to failing septic
systems and from the potential for new economic development.
Such development, if not too extensive, would be in keeping
with the development goals of the Island.
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TABLE 17 - Estimated Costs for Alternative D
COSTS
Item Capital
Average
Annual
Operation S
Maintenance
Total
Annual
Treatment Plant 6
sewer system $2,820,000
225,000
20,000
245,000
House Connections 75,000
6,000
0
6,000
Present 6 future
Septic System con-
struction, Stage I 700,000
61,000
2,500
63,500
Future Septic System
Construction,
Staae II 225.000
20.000
500
20,500
TOTAL $3,820,000
1
312,000
23,000
335,000
Source: See Detailed Cost Breakdown in Appendix I.
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5.0 PREFERRED ALTERNATIVES
Of the five alternatives studied in the previous chapter it
is the opinion of EPA that Alternative B represents the most
environmentally acceptable solution to the existing wastewater
disposal problems on Block Island. Alternative B includes the
sewage collection and treatment system as proposed by Fenton
Keyes minus Phase II. Other changes in the Keyes* design
include:
1. Addition cf a filteration unit for the final effluent to
assure a consistantly high quality effluent at the
outfall.
2. Odor control and noise attenuation to be included at the
plant.
3. Aethetic screening of the plant so that it will blend
into the setting of the Island.
4. Fencing to preclude easy access to the outfall.
This alternative was selected because EPA determined that
there was an immediate need for a sewage treatment and collection
system. This immediate need is evident in the Old Harbor area
where early development on the Island clustered very close
together. The early developers relyed on direct ocean disposal
for their sanitary sewage disposal needs. Now that ocean
disposal of raw wastewater is no longer an acceptable means of
sewage disposal and tightly knit housing precludes individual
subsurface disposal systems because of insufficient land area,
the community must rely on a municipal wastewater collection and
treatment system.
The people of New Shoreham depend on the summer tourist
season to maintain their economic independence. A major portion
of the tourist trade is supported by the marinas in the New
Harbor Area. The community feels, to provide sewerage for the
marinas is necessary to protect their fragile economic
independence. In addition, it is the opinion of EPA that a
sewerage system is needed for the New Harbor Area to alleviate
potential health problems and to insure that the environmental
integrity of the New Harbor Area is maintained for future
generations.
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The State of Rhode Island has also gone on record (letter
dated to John McGlennon) that the land area in the New Harbor
area is not suitable for subsurface sewage systems.
In an effort to mitigate against any possible negative
impacts, EPA further proposes to ammend the grant- EPA will
amend the grant conditions to insure that public toilet
facilities will be available in both the New and Old Harbor
Areas. In addition, EPA will also require the community to enter
into agreements with the marina operators to insure that adequate
pumpout and pretreatment facilities will be installed as may be
necessary to satisfy requirements for boat owners to comply with
Public Law 92-500 Section 312 Marine Sanitation Devices and
subsequent Federal Regulations published by EPA and the
Department of Transportation on June 23, 1972 and January 30,
1975 respectively and any amendments or revisions thereto.
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6.0 PROBABLE ADVERSE IMPACTS WHICH CANNOT BE AVOIDED
In this Chapter, the impacts which cannot be avoided for the
proposed alternative are discussed.
6.1 Primary Impacts
Alternative B. Unavoidable impacts will probably be
greatest for this alternative since it involves the most
construction activities. Erosion will be minimized through
following an erosion control plan (described in Chapter 4) to be
developed with assistance from the Department of Agriculture,
Soil Conservation Service. A revegetation plan, also developed
in coordination with the SCS, will aid in restoring construction
areas as closely as possible to original conditions.
Noises and odors emanating from the treatment plant are
unavoidable but will be minimized as much as possible. Visual
impacts of the above-ground facilities, such as the treatment
plant and pumping stations, can be minimized with proper design
and screening. The Rhode Island Historical Society will assist
in the design of fences and shrubbery around these facilities.
The visual impact of the concrete outfall, however, cannot be
reduced.
6.2 Secondary Impacts
Alternative B. Moderate growth rates, coupled with
significant multi-unit development, particularly in the New
Harbor area, can be expected with the implementation of this
alternative. Commensurate with this growth may be unavoidable
adverse impacts on water quality, air quality, and public
services through encroachment into environmentally sensitive
areas, increased use of recreational facilities, greater number
of cars, and, in general, increased activities on the Island.
However, with revised zoning and strict enforcement of such
regulations, the above affects can be minimized. In addition,
through the National Pollutant Discharge Elimination System,
Waste Discharge Permits, effluent quantity limitations can be
included for different points in the design life of the facility.
This is a mechanism that may be available to insure that the
capacity of the treatment facility is not reached in the early
stages of its design life, and therefore, can control growth in
the service area.
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7.0 LOCAL SHORT-TERM VERSUS LONG-TERM PRODUCTIVITY
This chapter will consider the tradeoffs between the
immediate local benefits of the proposed alternative and its
effect on future options available to the Island. For example,
the proposed alternative has the short-term benefit of abating
existing pollutional sources. However, it will have different
affects on the long-term productivity or future courses of action
the Island can take.
Alternative B can commit the Island to a pattern or course
of action that may be acceptable now but not acceptable and
unchangeable in the future. For instance, permanent municipal
structures can limit road changes, development patterns, or other
community goals that may require change in the future. In
addition, growth rates can be stimulated which will result in
population and development densities beyond optimum capacities
for the Island, and once the development is there, it will stay
whether the population does or not.
The future of the Island is not to be determined by a sewer
system al*ong. The availability of ether public services such as
water supplies and fire protection also play a significant role
in a town*s future development. However, an initial step is
necessary before any action can be taken and construction of a
sewer system and treatment facility can provide that step.
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8.0 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES
Under the proposed plan considered in this statement, the
materials and energy used in construction will be an
irretrievably commitment of resources. Where the alternative
plan requires land that cannot be used for purposes other than
intended, such commitment of land is considered irretrievable, at
least for the design life of the structure on it. Loss in
property values due to the nature of the project, such as the
treatment plant and visable outfall sewer, are also likely to be
irretrievable and irreversible for the life of the structures.
Necessary changes in the natural topography and unavoidable
loss of vegetation through construction are considered
irretrievable. Further, to the extent that the plan will induce
growth resulting in a loss of open space, such a loss is
irreversible.
On one hand, the State and Federal funds committed to this
project will be an irreversible and irretrievable commitment of
financial resources in that such funds will be unavailable for
other projects or needs. On the ether hand, such a substantial
investment is not irretrievable since it will be manifested in an
improvement in the quality of life on Block Island.
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9.0 COMMENTS ON DRAFT EIS
Approximately 77 letters were received by the Environmental
Protection Agency, Region I, Boston, Massachusetts concerning the
Draft EIS for New Shoreham, Rhode Island. All letters have been
reproduced in Appendix 0. Those letters which had a substantive
comment and/or indicated a preference for either Alternative B,
D, or another Alternative are summarized in Table .
Because many of the questions cr comments in the letters
were reiterated, it was not possible to address each individual
letter directly. However, in a survey of all letters we found
there were 52 specific comments that required a response. Those
comments are listed below with each accompanied by an official
EPA reply.
1. COMMENT: The "Comprehensive Community Plan" is at
present being revised and therefore, it was improper to
cite it in the impact statement.
1. REPLY; EPA recognizes that the "Comprehensive Community
Plan" is undergoing revision. The plan was cited in the
Draft EIS as evidence of the devise of Block Islanders
to preserve the rural low density character of the
Island. Since the Planning Board has repeatedly assured
EPA and other concerned parties that it intends to use
its zoning and other regulatory powers to control
development on the Island, EPA assumes that the revised
Comprehensive Community Plan will be in keeping with the
spirit of the old.
2. COMMENT; Hauling crushed rock to the Island to build or
rehabilitate septic systems is prohibitively expensive.
2- REPLY: A revised cost estimate (see reply 39) revealed
that the cost of crushed rock on the Island would be
approximately $20/ton. For an average septic system on
Block Island, it would cost $1,200.00 for fill material
and another $1,000.00 for construction resulting in a
total cost of approximately $2,200.00 per system.
3. COMMENTi Some elements of the town desire growth to
support necessary services.
3. REPLY: The issue of growth needed to support necessary
services presently not available on the Island, such as
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barber shops and pharmacies - or to support small
industry to stimulate a year-round economy, has been
addressed in the Draft EIS and is recognized by EPA as a
secondary benefit of a sewer system. Whether such
growth will result in a disbenefit to the Island*s
environment is directly related to the Town's ability to
regulate growth such that it proceeds in an
environmentally sound manner.
4. COMMENT: Contrary to the EIS, there is a height
restriction on buildings over 35 ft.
REPLY: The Draft EIS was in error and the text has been
changed.
5. COMMENT: On page 50 of the Draft EIS, remarks on the
dangers of development on Corn Neck Road. However, that
area is all beach zone and restricted from building.
5. REPLY: The growth possibilities outlined on pages 49,
50 and 51 are identified as the extreme situation which
could occur if pressure for development becomes great
enough to force further expansion of the sewer system
and changes in zoning to allow development at higher
densities^ This section was intended to indicate what
could happen on Block Island if strict control was not
exercised on zoning changes and sewer extensions.
*>• COMMENT: The landfill site mentioned on pages 17 and
53 of the EIS is not owned by the Town but is used
through a rental arrangement with a private contractor.
REPLY: The draft EIS was in error concerning the
ownership of the landfill site and all mention of the
landfill site in the statement have been changed
accordingly.
7. COMMENT: Disposal of boat wastes at the landfill which
would require costly pretreatment seems to be
impractical.
7. REPLY: Existing EPA regulations require holding tanks
on boats and pumpout facilities at marina*s by 1980,
(refer to Appendix B). Because of the chemicals being
used at present as additives to the boat holding tanks,
pretreatment to eliminate such toxic chemicals will be
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necessary. Pretreatment will be required for either
land disposal or inclusion into the treatment system.
8. COMMENT: The beaches which could potentially be
affected by the ocean outfall discharge are undesireable
for swimming anyway.
8. REPLY; EPA recognizes that Pebbly Beach has an
extremely rough topography and is, therefore, not ideal
for swimming. However, swimming is not entirely
precluded by the roughness of the terrain.
9. COMMENT: What will be the effect on the Island's water
supply if the closed cycle of returning wastewater to
the ground through septic systems is broken by
discharging wastewater into the ocean?
9. REPLY: The main source of recharge to the underground
water supply on Block Island is precipitation. Further,
since the portion of the town proposed to be sewered is
in an area unsuited for groundwater development (refer
to map 6), it would not appear that elimination of
recharge via septic systems, with the construction of
sewer systems, will affect goundwater availability.
10. COMMENT: The potential for growth on Block Island is
limited by lack of a good water supply system and lack
of access.
10. REPLY: While the lack of a good water supply system and
the inaccessibility of the Island are limiting factors
in the growth of Block Island, with the application of
developmental pressures, they cannot be considered
controlling. For example, there are existing proposals
for a new enlarged water supply system to serve the
majority of the Island. Furhter, with respect to
inaccessibility, at the turn of the century, the
Island's population was 1,400 year-round residents
compared to 500 today.
The draft impact statement intended to display all
possible secondary impacts of the construction of a
wastewater treatment facility. The potential for growth
stimulation is real, however after public input, it
appears that the Town is aWare of uncontrolled growth
and will take every precaution to guard against it.
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11.
COMMENT: In reference to the section on Refuse Disposal
on page 17 of the Draft EIS, homeowners in the area have
never heard of the plan mentioned.
11. REPLY; The section entitled Refuse Disposal discusses
an existing facility rather than a proposed one. The
landfill area is, therefore, not a "possible plan" which
EPA could influence, but rather an existing facility
owned by the Rice Construction Co., approved by the
State Department of Health and the local Conservation
Commission and already in use by the town.
The New Shoreham Planning Board, in their letter of
comments dated May 8, 1975, discusses the landfill site
and indicates that the location described in the Draft
EIS is correct. The Planning Board did indicate that
the landfill is privately owned rather than a town
facility as had been improperly stated in the EIS.
12. COMMENT; Will effluent be chlorinated and for what
time?
12. REPLY: Chlorination of the effluent for a minimum 15
minute contact period will be afforded by the treatment
facility.
13. COMMENT; Discuss the size of the area around the
outfall which will have to be closed to shellfishing.
13. REPLY: From discussions with Charleton Maine of the
Dept. of Health, Div. of Water Supply and Pollution
Control, it appears that the area around the proposed
outfall, that will be closed to shellfishing will
probably extend from the end of the Old Harbor
Breakwater to a point cn the shore south of the outfall
where the existing Class SB closure terminates (see Map
7). After the treatment facility is; in operation,
officials from the Dept. of Health will sample the
closure area to ascertain if it is of appropriate
dimensions..
14. COMMENT: What is the number of boats using New Harbor?
11. REPLY: Based on the information presented by Mr.
Whitman in his letter of June 2, 1975, EPA is accepting
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the estimate of 500 as the average number of boats usifii&
New Harbor on average weekend days.
15. COMMENT: If the outfall is extended, the Corps of
Engineers will require a new Federal permit.
15. REPLY: EPA will require that all Federal, State and
local regulations are complied with by the applicant.
16. COMMENT: The estimate of summer population on Block
Island used in the Draft EIS was inadequate.
16. REPLY: The summer population estimates used in the
draft statement were taken from the Fenton G. Keyes
report. The Keyes report estimated summer populations
by making a house-to-house count of rooms available for
both existing and future proposed accommodations, and by
estimating the number of boats and ferry tourists.
Projecting population totals is not an exact science,
however, EPA feels that the Keyes estimates are
adequate.
17. COMMENT: What are the updated construction and
operation and maintenance costs for the treatment
system?
17. REPLY: As of our latest inquiry, the contractor for the
sewer contract is holding to the original bid price.
Minor design changes and escalation of equipment costs
will necessitate renegotiation or rebidding of the
wastewater treatment plant contract. Therefore, the
final cost estimates may be changed.
Operation and maintenance costs apparently were
underestimated, (see reply to comment 34) with revised
estimates now approximately $40,000/year.
18. COMMENT: Insufficient emphasis was placed on the fact
that subsurface septic systems failed because of
improper construction.
18. REPLY: The Draft EIS indicated that poor construction
techniques of septic systems may have contributed to
their failure, however, it is the State's opinion that
inadequate soil conditions is the major factor in the
inoperability of subsurface systems.
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19. COMMENT: The outfall off of Pebbly Beach is impractical
because it will be very subject to storm damage.
19. REPLY; The problem of heavy seas in the outfall area
has been well considered by the design engineers, Fenton
G. Keyes. Their design of a concrete encased outfall
with steel sheet piling attempts to circumvent the storm
problem, however, by their own admission, continuous
maintenance of this structure will be necessary.
EPA is also aware of potential outfall damage and for
this reason has required final polishing filters at the
treatment facility. The addition of filters will also
provide for a higher degree of reliability for the
treatment plant effluent.
20. COMMENT: It is not true, as the Draft EIS indicates,
that no thunderstorms occur on Block Island.
20. REPLY: The Draft EIS was in error and the text has been
changed.
21. COMMENT: The Block Island Report referred to in the EIS
was prepared by the R.I. School of Design, not the
University of Rhode Island.
21. REPLY: The Draft EIS was in error and the text has been
changed.
22. COMMENT: The EIS gives the impression that only
retirees reside on Block Island, which is not true as
many young people are presently moving in.
22. REPLY: Apparently this section of the Draft EIS was
misleading and has therefore been revised.
23. COMMENT: Has an archeological survey been performed by
the R.I. Historical Preservation Commission on the
Island and will their results be included in the final
EIS?
23. REPLY: A preliminary archeological survey was conducted
by the R.I. Historical Preservation Commission. We have
determined from their results that there are no specific
archeologically significant sites that will be
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distrubed. Therefore, EPA is not prepared to fund a
complete archeological survey at this time.
24. COMMENT; Have new percolation tests been done in the
New Harbor area and what are their results?
24. REPLY; Percolation studies were performed by the Dept.
of Health, Div. of Water Pollution Control in early May,
1975, which concluded that sub-surface soil conditions
in New Harbor, for the most part, were not amenable to
subsurface disposal of wastewater. However, because of
the limited amount of time available when making these
tests, the results could not be considered
representative. Therefore, as recently as August 6,
1975, staff of the Dept. of Health, Div. of Food
Protection and Sanitation surveyed New Harbor again and
confirmed that disposal of sewage by the subsurface
method is not a viable alternative.
25. COMMENT; Page 4 of the Draft E1S misleadingly describes
the Island's past golf course as plush.
2 5. REPLY; The text has been changed.
26. COMMENT; The map opposite page 24 of the Draft EIS
shows as dense residential an area where only 1 house
exists.
26. REPLY; The map opposite page 24 in the Draft EIS is
drawn from the R.I. School of Design's "Block Island
Report". The area in guestion is indeed currently being
used in a low-density fashion as indicated on the map of
existing land use on page 57 of the "Block Island
Report". The map in the EIS, however, depicts suggested
zoning rather than current use and is drawn from page 81
of the "Block Island Report". Despite its current use,
the area in question is zoned for commercial and dense
residential. The distinction between zoned use and
current use is extremely important in assessing the
potential for induced growth on Block Island.
27. COMMENT; Has the alternative of package plants to serve
the built-up portions of the Island been investigated?
27- REPLY; EPA did examine the possibility of using package
sewage systems on Block Island. However, it was felt
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that given the unique conditions present on Block Island
(i.e., extreme flow variations between winter-summer and
weekday-weekend), a custom designed plant would be more
reliable and efficient than a standardized, pre-
fabricated package system. Also, with package plants,
it would be more difficult to adapt to changing needs in
the volume of sewage to be treated or the degree of
treatment necessary.
28. COMMENT: Will the dumping of toxic wastes at the
landfill site affect the water supply?
28. REPLY; The disposal of septage by land application is
an acceptable practice if the underlying soil conditions
and depth to groundwater are appropriate. The
conditions at the present landfill site are adequate to
preclude any contamination of groundwater aquifiers.
(Refer to Dept. of Agriculture, Soil Conservation
Service analysis. Appendix K). The disposal of toxic
wastes such as those as may be included in boat holding
tanks, however, could have a deleterious effect on
underground water supplies and therefore, will be
required to pretreat prior to land disposal. (Refer to
pages 53 and 57 of the EIS.)
29. COMMENT; Development in New Harbor will take place even
without sewers and this will lead to the same problems
now occuring in Old Harbor.
29. REPLY; It is the general cpinion of the townspeople of
Block Island, that the economic viability of New Harbor
is directly related to the availability of sewers.
Without sewers, development of this area will be limited
by the high cost of subsurface septic system
construction or rehabilitation.
30. COMMENT: It is obvious from watching the sea that the
discharge from the proposed outfall will wash onto the
fceach, further there will undoubtably be erosion of te
outfall.
30. REPLY; It is EPA's opinion, based on mathematical
models and drouge studies, that the outfall will not
present a health problem to users of the ^Island's
beaches. EPA*s requirements to increase treatment
efficiency (addition of final filters) will further
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preclude against beach contamination. As for an erosion
of the outfall area, this is a phenomena that will occur
regardless of the outfall.
31. COMMENT: Growth cannot be channelled in Old Harbor
because there are only limited vacant land available.
31. REPLY: The Draft EIS indicated that growth in Old
Harbor could be accommodated by renovation of existing
structures as well as new building on vacant lots.
32. COMMENT; There is a supposed agreement with the town
council to extend the outfall as far as necessary if any
effluent washes back on the beach, however, no mention
of this was made in the EIS.
32. REPLY: In the original grant offer of May 21, 1975, a
three-party agreement was included which required
sampling of the outfall area after the treatment
facility had been in operation. The 'purpose for this
agreement was to insure that the ocean discharge would
not have any effect on the adjacent beach area.
However, with the decision to prepare an impact
statement, it was also decided to intensively study the
affects of the outfall through sampling and modeling
(See Appendix H). Based upon these subsequent
investigations and their results, the necessity for a
three-party agreement is now questionable. EPA will
pursue this matter with the cosigners of the agreement,
(i.e., EPA, Rhode Island Dept. of Health and the Town of
New Shoreham), to possibly affect its termination.
33. COMMENT: Rehabilitation in Old Harbor is impractical
and will not take place.
33. REPLY: If commercial growth is channeled into Old
Harbor, rehabilitation will of necessity be one of the
main ways of accommodating new businesses given the
amount of land available fcr new construction. In any
event, the amount of rehabilitation vs. new construction
which occurs will be strongly influenced by decisions
made by the town.
34. COMMENT: Do operating costs of STP include the cost of
diesel fuel for the generators?
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3<*. REPLY; A section from the Fenton G. Keyes Assoc.
preliminary engineering report dealing with the
operating costs of the SIP neglected to include a
$28,000/yr. final cost for the diesel generator fuel.
This added cost is considerable since it increases
previous fuel cost estimates by $24,000/yr. The New
Shoreham Planning Board has been made aware of this
change.
35. COMMENT: The assumption by Fenton G. Keyes Assoc. that
boaters will spend a majority of their time on land is
not founded on any ascertainable facts.
35. REPLY: Although the assumptions made by the towns*
engineer were not based cn an actual survey of boaters
activities when harbored in Block Island, they were
based on available information supplied by the Islands*
town officials.
36. COMMENT: How difficult will repairs and emergency
breakdowns be to cope with on a remote island such as
this one?
36. REPLY: The treatment plant has been designed to include
backup systems in the event that any equipment failure
should occur. Any breakdown could most likely be
repaired quite quickly and both primary treatment and
chlorination could be provided during repair.
37. COMMENT: The O.S. Coast Guard requires that the outfall
be marked.
37. REPLY: EPA will ensure that all Federal Regulations are
complied with by the applicant.
38. COMMENT: The Coast Guard is withholding approval of the
outfall until it ascertains the effects of it upon
navigation by requesting further information.
38. REPLY: The consultant and applicants have been made
aware of the requirements of the U.S.c.G. concerning the
outfall structure and will comply with same.
39. COMMENT: The estimated costs of construction of septic
systems in the EIS are high.
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39« REPLY: A cost estimate cf septic system revitalization
on the island was conducted and the findings are as
follows: Using minimum sq. footage regulations set by
the State of R.I., it was estimated that approximately
40 yds. of 1 1/2" gravel was necessary for the average
dwelling unit (particular to the Island) septic system.
Since there is no crushed rock naturally available on
the Island, it would have to be barged from the
mainland. The cost of the material and transportation
from origin to individual site on the Island would be
approximately $20/ton. Therefore, the cost of gravel
alone for each individual septic system would be $1,200.
This does not include construction costs, probably
another $1,000 for a total cost of $2,200 per system.
40. COMMENT: Given the general economic situation, it is
irresponsible to commit Block Island to long term
financing for the STP.
10. REPLY: Bonding to finance needed municipal improvements
can provide long-term benefits in an inflationary
situaiton since bonds are paid off with inflated
currency.
41. COMMENT: From regional shellfish maps available for the
Block Island area it appears that major sea scallop beds
exist off the east coast of the Island and in the area
of the proposed outfall.
41. REPLY: Sea scallop beds do exist off the eastern side
of Block Island, however, they will be outside of the
expected closure area (refer to comment 15) and in no
way will be affected by the proposed outfall discharge.
42. COMMENT: should ozone be used instead of chlorine for
final effluent purification?
42. REPLY: EPA is also very interested in the use of ozone
as a substitute for chlorine, and is following a number
of projects in which this approach is being tried.
However, in the Block Island case, given the small size
of the proposed plant, and the fact that ozone is still
not in widespread use as a substitute for chlorine, it
was felt that it would not be appropriate to require a
detailed study of this alternative.
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43.
COMMENT: Discuss the project and alternative impact
upon recreation.
REPLY: The impact of the project upon recreation can be
examined in three aspects. The first is the
construction impact upon local surroundings, the second
is the loss of recreational use of the facilities site
and the third is the affect of the outfall upon water
recreation.
A minimum amount of disruption from construction
activities will result but these will be short-term and
are now unavoidable.
Recreational use of the land has never been very great.
There are no parks or playgrounds to be disrupted and
the site has been rather inconsequencial as far as
recreation is concerned.
Ocean and beach oriented uses will not be affected in
any great amount because the outfall site lies off of a
very rocky beach near the entrance to Old Harbor. The
use of this beach or its surrounding waters for
swimming, fishing, or boating is extremely minimal.
In summation, the adverse impact of this project upon
recreation is very slight.
44. COMMENT: DOI stated that a review by the Advisory
Council on Historic Preservation may be necessary
because the effected area is on a National Register.
Also, greater consideration of archelogical resources
may be necessary.
44. REPLY: (Refer to Reply 25)
45. COMMENT: We are in disagreement with the paragraph
stating that enlarging the historic area will change the
impact, on page 39.
15* REPLY: This paragraph has been attached to better
communicate its original idea - given that a sewage
treatment plant must be constructed somewhere, if the
entire Island is designated an historic district, then
such designation ceases to be limiting input to the
decision of which site is chosen.
78
-------
COMMENT: Use of water saving devices should be
encouraged.
46. REPLY: EPA agrees that greater use of water saving
devices could substantially reduce the amount of
wastewater produced by businesses and residences.
However, as indicated on page 35 of the Draft EIS, these
water saving systems will have little impact on sewage
treatment plants because the amount of waste to be
processed will still be the same — it will simply be
more concentrated. EPA does feel, however, that water-
saving devices could substantially improve the
efficiency of septic systems. EPA does not have the
authority to require the installation of these devices,
however, and any action on this issue must therefore
take place at the local level. (See Appendix E of the
EIS for a discussion and evaluation of various flow
reducing devices.)
Even if water saving devices were able to reduce the
size of the sewage treatment plant, the primary issue
would remain the size of the area to be serviced,
regardless of the size of the treatment plant necessary
to do so.
47. COMMENT: Use septic systems instead of a sewer system
for eld Harbor.
47. REPLY: After studying Block Island extensively, EPA is
convinced that septic systems are not a viable solution
for Old Harbor's problems. (Refer to Summary )
48. COMMENT: What is the status of laws governing boat
wastes.
48. REPLY: Federal regulations regarding boat wastes were
detailed in Appendix B of the Draft EIS. Briefly, the
regulations as they now stand require the installation
of holding tanks, with certain exemptions.
49. COMMENT: How will the assessment for the sewers be
determined?
49. REPLY: Issues relating to the financing of the local
share of the sewage treatment plant construction costs
79
-------
are beyond EPA's authority, and should be discussed at
the town level with municipal officials.
50. COMMENT; Should tertiary treatment be considered?
50. REPLY; Tertiary treatment techniques {such as physical
chemical treatment and land disposal (refer to Section
4.0)) were analyzed in the draft statement, but because
of the large expenditures necessary for such treatment
types they were not considered the best alternatives.
However, because of the possibility of damage to the
outfall sewer some additional treatment was considered
exigent. For this reason, final polishing filters will
be required to insure a higher degree of reliability for
the treatment plant effluent.
51. COMMENT: Will the STP generate any noticeable noise or
odor?
51. REPLY: The sewage treatment plant as designed by Fenton
Keyes does not include provisions for controlling noise
and odors. However, such control techniques are
available and are being recommended. They are discussed
in the EIS on page 34 and pages 43-45.
52. COMMENT: what effect will subsurface disposal have upon
groundwater supply. No study has yet been made that
gives the EPA authority tc say there will be no effect.
52. REPLY: Page N-2 states that, based on available
information, subsurface disposal systems have not to
date affected groundwater used for water supply, and
that, if density remains low, no future impact is
expected, particularly given the seasonal nature of the
population.
80
-------
APPENDICES
-------
APPENDIX A - EXISTING WATER QUALITY
BLOCK ISLAND SURVEY
August 26, 1971
A. Water Quality High Tide 12:05 pm (EDT)
Coliform MPN/100 ml
Station* Total Fecal
1
3-
3-
2
4
4
3
230
11
4
93
21
5
9
4
6
3-
3-
7
4
4
8
3-
3-
*See chart
Source: Rhode Island Department of Health, Division of Water Supply
and Pollution Control.
A-l
-------
P:}'BALLS
POINT
Mr- ".v "
7M-' w"h *** "VtyA. Ci> a
'?¦ sX/
£•' WEST PEACH *0 '/"-V ^
MMI-JO* ~—U>
GREAT
SALT POND
CORMORANT
POINT
NEW
HARBOR
. cMrA4y/./?-m*s\
WWk
^,\kTi^oi6.$i
corns
170.000' COKC;
' \ V""-
BLOCK ISLAND
AIRPOR
(STATE)
.• <*f»p£c '»¦ -/f^"j\: »•¦
OLD HAftS
'//, POtNT
3h .7 ^
ROAO
OtCKENS
( POFteLl
BLOCK
fo"d
SOUTHEAST
POINT
SOUTHEAST
LIGHT NOU
h»ueht"
SOUTHWEST-
7t*46'4r
BLACK ROCK
A*-2
-------
APPENDIX B - REGULATIONS GOVERNING WASTE DISCHARGES FROM WATERCRAFT
The State of Rhode Island has 110 existing law regarding the dis-
charge of sanitary waste from watercraft. Vessel pollution control
will be covered, however, under Section 312 of the Federal Water
Pollution Control Act Amendment of 1972. Under the Act, EPA is
authorized to promulgate effluent standards for marine sanitation
devices, and the Coast Guard is authorized to promulgate criteria
on the design, construction and certification. Furthermore, the
Federal law will preempt any State laws regarding the design,
manufacture, installation or use of any marine sanitation devices.
Such preemption will not take place, however, until the effective
date which is 2 years and 5 years from the date of final promulgations
for the new and existing vessels, respectively. Section 312 also
provides two waivers for the States to apply for no discharge zones,
one based on water quality protection and the other based on the
availability of pump-out facilities, but no guidelines have yet
promulgated for the application of no discharge zones.
The Coast Guard promulgated its design criteria and certifi-
cation procedures on January 30, 1975 and EPA has promulgated its
standards on June 23, 1972. Therefore, Section 312 of the Act will
come into effect on January 30, 1977 for new vessels and on January 30,
1980 for existing vessels. In brief, the EPA standards requires zero
discharge after the effective date. However, as an incentive for
existing boaters to install marine sanitation devices before the
effective date, the following provisions are included: (1) any
existing vessel, equipped with a Coast Guard certified flow-through
device that will reduce fecal coliform bacteria to no more than
1000/100 ml, with no floating solid and is installed with 3 years
after the time of promulgation, the vessel shall be deemed in
compliance. (2) If the above device is installed after 3 years from
the time of promulgation but before the effective date, the vessel
shall be deemed in compliance for only 3 more years following the
effective date. In addition, the Coast Guard promulation further
allows one year incentive period (ending January 30, 1976) for new
vessels to install certified flow through devices and still be
deemed in compliance.
Reference:
1. Section 312, Public Law 92-500, Federal Water Pollution
Control Act Amendment of 1972.
2. Federal Register, Volume 37, Number 122. Title AO -
Protection of Environment, Chapter 1, Part 140.
3-1
-------
APPENDIX C - COMPREHENSIVE COMMUNITY PLAN PROPOSED LAND USE CATEGORIES
Mixed Uses. Commercial and intensive residential development.
Suitable areas are Old Harbor, the center of the present hotels and
commercial establishments, and New Harbor, the location of the three
marinas on Great Salt Pond. Ferries from the mainland serve both areas,
The Comprehensive Community Plan notes that further development could
take place on vacant land in the Old Harbor area, and that the vacant
land along West Road in New Harbor is suitable for the same kind of
mixed commercial and residential development that characterizes
Old Harbor.
Medium Density Residential. Tourist cottages, boarding houses,
summer homes and year-round residence, averaging one dwelling unit per
acre. These areas border the two mixed use areas, contiguous to
proposed sewer and water systems, and the Comprehensive Community Plan
envisions tying into these proposed systems in the future.
Low Density Residential. Year-round and summer homes, averaging
one dwelling unit per 2-acres. These are the areas now rural in
character embracing much of the remainder of the Island beyond the
development centers. Here, according to the Comprehensive Community
Plan, low density will conserve ground water supplies and the open
space character. The soils are generally well-drained and suitable
for properly installed and operated septic sys.tems.
Developed Recreation. Areas designated for facilities to
support intensive recreation such as marinas, restaurants, and movie
theatres. Mixed use areas are suitable for such development, but in
addition, such development could occur in the shoreline areas at the
piers at Old and New Harbor, with buildings on stilts to avoid the
flood water (potential conflict with conservation objectives).
Open Space Recreation. Areas maintained in open space free of
intensive recreation facilities and homes to maintain the Island's scenic
qualities and ecological balance. Areas include the erodable and highly
scenic southwestern cliffs, the ground water recharge zone in the south
portion and the low-lying beach land separating Great Salt Pond from
the ocean.
Conservation. Relatively undisturbed shoreline ecology to be
preserved in its natural state. These areas include the salt marshes
around Great Salt Pond, fish spawning grounds; western coastline north
of Great Salt Pond, lying below the hurricane high water line and in-
cluding a bird sanctuary; narrow strips along the northwestern and
southwestern shores, where the cliffs are subject to erosions, not
suitable for development yet highly scenic; and also Rodman Hollow in
the southwest, an unusual land form linking the southwest sector to
the ocean.
C-l
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APPENDIX D - BASIS OF COSTS ALTERNATIVE TREATMENT SYSTEMS
The cost data for this report was compiled in the following manner:
a) Construction Costs - EPA, Region I prepared graphs of con-
struction costs vs. design capacity for various treatment plants located
in Southern New England (Conn., Mass., and R.I.) in the Summer of 1973.
The costs for these graphs were taken from the low bid quotes for the
recent construction of Municipal Wastewater Treatment in those states.
A least mean regression computer analysis was made which resulted in
equations for a log/log plot in the form:
loglQ (cost) = a log10 (Q) + b
a = slope of line of best fit
b = y intercept
Q = design average flow
For this Report, these costs have been updated to present conditions
based on an ENR Construction Cost Index of 2100. These costs represent
the complete treatment facilities including preliminary treatment, if
any; effluent disposal and sludge handling. As they are a composite of
many diverse projects, they should be used as a guide with consideration
for any special conditions which may affect the individual project.
b) Operation & Maintenance Costs - The records of the Operation
and Maintenance Section of EPA, Region I were analyzed to compute
average yearly costs of operations and maintenance of wastewater
treatment facilities. These are based on actual reported costs by a
large number of municipalities throughout New England over the last
several years. It should be noted that these costs generally represent
treatment of a more or less constant flow throughout the year. Projects,
such as Block Island, which will treat a greatly varying seasonal flow
must be analyzed with this fact in mind.
c) Exception - The capital and operating costs for physical-
chemical treatment alternative are based upon pilot-plant and demon-
stration studies, upon manufacturers costs of equipment and upon
experience with the cost of those processes in other industries.
There are no functioning physical-chemical treatment facilities in
New England (or in the U.S.) at present. Therefore, there is no
actual capital and operating cost data to be presented.
d) Land Costs - The cost of land has been estimated as $10,000/
acre based on correspondence with local officials in New Shoreham.
D-l
-------
e) Summary - The use of the above cost data is intended to
show the relative costs of alternative treatment systems and the
costs presented are not meant to imply the actual cost to construct
any of the systems on Block Island. The cost data reflects capital
and operating cost for a treatment facility with a design average
flow of 300,000 gal/day, unless indicated otherwise.
D-2
-------
TABLE A - Average Costs for 300,000 Gallon^Per Day Treatment Facilities
Southern New England
Type Treatment System
Construction
Cost
Avg. Annual
Bond Payment*
Annual
Operating
Cost
Total Avg.
Annual
Cost
Extended Aeration:
0
1
U)
a) Aeration Tanks
b) Oxidation Ditch
Modified Act. Sludge (Contact
Stabilization)
Aerated Lagoons
Stabilization Ponds
Physical-Chemical
Package Treatment Plants
(60,000 MGD)
750,000
525,000
640,000
635,000
585,000
450,000
100,000
65,400
45,700
55,700
55,400
51,000
39,200
8,700
22,500
13,000
35,000
22,500
8,500
40,000
6,000
87,900
58,700
90,700
77,900
59,500
79,200
14,700
* Assuming 20-year bond issue @ 6%.
.08718 - Capital Recovery Factor
-------
TABLE B - Land Area Required for Various Treatment Alternatives
Type Treatment System Land Area Cost of
(Acres) Land *
Extended Aeration:
a) Aeration Tanks 2.0 20,000
b) Oxidation Ditch 3.0 30,000
Modified Activated Sludge
(Contact Stabilization) 2.0 20,000
Aerated Lagoons 6.0 60,000
Stabilization Ponds 30.0** 300,000
Physical-Chemical 0.25 2,500
* Assuming $10,000/acre.
**Including land for intermittent sand filters.
D-4
-------
EVALUATION OF ALTERNATIVE TREATMENT SYSTEMS
References:
1. Preliminary Engineering Survey & Report for the
Town of New Shoreham - Fenton G. Keyes Associates,
Feburary, 1972.
2. Environmental Impact Appraisal - EPA, Region, May, 1974.
3. "Wastewater Treatment for Small Communities" -
George Tchobanoglous, University of California,
September 28, 1973.
4. Construction Cost Curves, EPA,Region I, January, 1974.
5. Personal communications.
D-5
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APPENDIX E - FLOW REDUCTION EQUIPMENT
The following In-house flow reduction equipment has been tested
by EPA and are available or will shortly be available on the open
market. The information shown below was adopted from the EPA
publication, "Demonstration of Waste Flow Reduction from Households",
EPA-670/2-74-071, Sept., 1974.
Description of Units Tested
Wash Water Recycle System = Laundry and bath water are collected in
a suitably sized vented storage tank, provided with an overflow pipe, side
bottom outlet, and a low-level control system for supplemental feed water.
The stored wash water is either continuously or intermittently (when the
pressurization pump operated) disinfected prior to filtration. The treated
water is pressurized by a 1/3 HP shallow well jet pump mounted on either a
45 or 115 liter pressure tank, controlled by a pressure switch over the
range of 105 to 210 cm HG. When the pump is activated, wash water is
pulled through a cartridge or diatomite filter and pressurized. The
treated water is then carried through copper tube lines to the flush
toilet and lawn sprinkler.
Shallow Trap Toilet = One of the approaches involved the use of a
water saving toilet designed to use approximately one-third less water
than ordinary toilets. The specific model selected for testing was the
American Standard Water Saving Elongated Cadet. It is similar in
appearance and cost to the standard model except for a noticeably smaller
tank. Less water is required for flushing due to the special design of
the bowl (shallower trap).
Dual Flush Toilet Devices = The second approach utilized devices which
converted a conventional water closet to dual cycle operation, i.e., a
short flush for liquids and a normal flush for solids. Two different
devices were examined during the program.
1) Econo-Flush = This toilet device consists of two interconnected
plastic tanks open at the bottom which are positioned inside the toilet
tank, and a handle/lever assembly incorporating a unique valve arrangement.
The Econo-flush operates in the following manner:
(a) Light flush - this is activated by pushing the handle
up. The handle assembly, through a unique linkage arrange-
ment, simultaneously opens the toilet flush valve and
closes a plastic valve which seals both plastic tanks from
the atmosphere. The contents of both tanks (approximately
one gallon) are thereby trapped by the vacuum created and
a reduced flush results.
-------
(b) Normal flush - this is activated by pushing the
handle down in the usual manner. The plastic valve now
opens in conjunction with the toilet flush valve, breaks
the vacuum seal and thereby allows a full flush to occur.
A label is included for posting on or near the toilet
in order to remind the household occupant of the new
flushing procedure.
2) Sink-Bob = This dual flush device consists of a polystyrene
float and lead sinker connected to the float stem by a split brass
ring. As with the Econo-flush device, most standard toilet models
will accomodate the Sink-Bob. The Sink-Bob attaches to both rod and
flapper-type seals at a point just above the flush valve. The device
operates in the following manner:
(a) Light flush - the Toilet handle is tripped in the normal
manner, opening the flush valve and allowing the water in
the closet tank to drain into the bowl. When the level
inside the tank has decreased by approximately 50%, the Sink-'
Bob attains sufficient negative buoyancy to prematurely
seat the flush valve.
(b) Normal flush - for full flush, the handle must be held
down during the entire flushing operation to prevent premature
closing of the flush valve.
Flow Limiting Shower Heads = Shower heads with built-in flow limiting
orifices are available which can reduce water consumption rates from the
typical 19 to 38 liter per minute (1pm) (5 to 10 gpm) to 9.5 or 13.3 1pm
(2.5 to 3.5 gpm). The actual amount of water saved will depend primarily
on the system water pressure and the personal habits of the bather. Two
different Speakman flow limiting shower heads were selected for testing.
The first of these, "Auto-flo" flow is equipped with a 13.3 1pm integral
limiting orifice. This shower head has a fully-adjustable spray, integral
ball joint and a 5 cm face. The second shower head is equipped with a
9.5 1pm integral "Auto-flo" limiting orifice. It is also of the adjustable
spray, ball joint type but has a much narrower shape. Both shower heads
have standard 1.27 cm (1/2") I.P.S. female inlets which are compatible with
standard shower arms.
The following Tables summarize waste flow reduction from households:
E-2
-------
TABLE A - Water Savings Summary
Unit
Tested
Water
Savings
lpcda
% Reduction
of water
usage
% Reduction
in total
water usage
Benefit to Homeowner
Adverse Effects
Wash water
recylce
system
fd Shallow
\ Trap water
U) , r
closet
Dual Flush
Devices:
Sink-Bob
Econo-Flush
Flow limiting
shower head
44.0 (11.6)
14.8 (3.9)
20.5 (5.4)
12.4 (3.3)
2.7 (.7)
25.6
28.6
16.6
7.1
- lpcd = liters per capita-day.
- gallons per capita-day.
26.0
6.9
8.6
3.3
1.0
The recylce system minimize . the surge
in outflow to the septic system.
It reduced total waste flow & allowed
the septic tank and soil absorption
system to operate more effectively.
Little maintenance required.
Achieve good reduction in water use.
Temporary stains in toilet
bowls.
Tie-up of essential metals
needed for plant growth due to
high phosphate detergents.
Possible reduction in soil
moisture content.
None
Achieve good reduction in water use. None
Achieve adequate reduction in water use. None
Significant savings in hot water. The flow None
limiting shower heads have good reduction
for high frequency users.
-------
TABLE B - Cost Summary - Bathroon Water Saving Devices
Water
aavlng
device
Material
Cost-$
Labor
Coat-$
Installed
Cost-$
Operating
Ccst-$
Expected
Life.yrs.
Total"
Annual
Coat -$/yr,
Shallow-trap
flush toilet
60
15
75
0
20
3.75
Dual flush
devices
Sink-Bob
4
0b
0b
4
0
10
0.40
Econo-Pluoh
14
14
0
10
1.40
Savelt
6
0b
6
0
10
0.60
Plow limiting
shower heads
13.3 lpm
6
0b
6
0
15
0.40
9.5 lpm
8
ob
8
0
15
0.53
- The Total Annual Cost was based on amortization of the installed
cost over the expected life of the device.
- Assume homeowner installs unit himself.
-------
TABLE C - Cost Summary - Wash Water Recycle Systems
Prototype
Recycle Systems ,
Diatomlte Cartridge 1
filter filter
Projection for
mass produced
recycle system
(Diatomite filter)
A.
Initial cost
$175
$70
Storage sys»-
—$175
Filter sys.--
— 135
60
100
Pressuriza-
85
tion sys.
— 115
115
Disinfectant
feeder-
— 20
20
20
Valves, pipe,
80
fittings
---25.
JE5.
Total Mat '1
Cost
— 540
450
350
Labor Cost
100
_20
_^o
Total Installed
Cost
- $640
$540
$400
B. Annual opera-
ting cost
Filter media--- $3*50 $38.80
Electric power—12.00 1,20
Disinfectant 5.50 5.50
$21.00 $45.50
$3.50
7.00
„ 5.^0
$lo.00
Total annual cost2
Expected life
years— 15 15
Total cost per
yr $63.50 $81.50
15
$43.00
1 - Fram filter selected for cost analysis.
2 - The Total Annual Costs were determined by amortizing the initial
costs over the expected life and adding the respective operating
costs.
-------
TABLE D - Cost Comparison
1
Flow reduction device
Cost per unit
vol. of flow
reduction
$/lOOO liters
Typicalc
water rates
&/1000 liters
Typicald
sewer rates
.t/1000 liters
Septic tank
system -
poor soil
$/1000 liters
Net
Savings
$/year
Shallow trap water closet
0.15
0.16 - 0.42
0 - 0.13
$.25 to
9.80
Dual
flush
devices
Sinkbob
0.02
0.16 - 0.42
0 - 0.13
$4.10 to
15.60
Econoflush
0.07
0.16 - 0.42
0 - 0.13
$1.72 to
9.20
Saveit
0.04
0.16 - 0.42
0 - 0.13
$2.40 to
10.20
Flow
limiting
shower
heads
13.3 1pm
0.08
0.16 - 0.1*2
0 - 0.13
$1.10 to
5.32
9.5 lpm
0.22
0.16 - 0.42
0-0.13
$.52 to
3.53
Wash
water
recycle
system
Prototype
0.57
0.16 - 0.42
0 - 0.13
0.40
$-45.70
to -2.30®
$-1.30
to 27.60
Mass-produced
0.39
0.16 - 0.42
0 - 0.13
O.UO
$-25.20
to 18.20®
$19.20
to 48.10
- Net savings per year based on water and sewer rates.
- Net savings per year based on water rate and septic system cost.
^ - Domestic water rates throughout the State of Connecticut.
- Typical sewerage use rates in the Connecticut area.
-------
(see following pages)
F-l
-------
FENTON G. KF.YF.S ASSOCIATES
CONSULTING
ARCHITECT — ENGINEERS
ProTidf-nce, R. 1.02903 Waltiiam, Umi. 021S4 P«Ze
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F-2
-------
FENTON G. KEYES ASSOCIATES
CONSULTING
ARCHrTECT — ENGINEERS
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F-3
-------
FENTON G. KEYES ASSOCIATES
CONSULTING
ARCHITECT — ENGINEERS y
ProridsDca, R. I. 02903 Waltham, Mau. 02164 Page
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-------
APPENDIX G - FMC WASTE TREATMENT SYSTEM*. AN EXAMPLE OF A PHYSICAL/CHEMICAL
TREATMENT SYSTEM FOR MARINAS.
The FMC Waste Treatment System employs a physical/chemical process to
treat sanitary sewage and other wastes. Chemicals are added to con-
dition the sewage, which is then filtered to remove suspended solids.
The system operates automatically on demand, with instantaneous on-
off treatment capability. Influent sewage flow may be constant or
variable, with no loss in degree of treatment.
During the process, chemicals are added automatically in proportion to
the influent sewage flow rate. The type and function of each chemical
is as follows:
1. Bactericidal Agent. A bactericidal agent, chlorine, is used
to destroy bacteria and inactivate viruses present in sewage so
that the effluent water and solid filter cake are free of live
pathogenic organisms.
2. Activated Carbon. Powdered activated carbon is used to adsorb
certain soluble organic compounds in sewage that could not be
removed by filtration. Once adsorbed, they are readily re-
moved by filtering out the spent carbon particles.
3. Flocculating Agent. A flocculating agent, aluminum sulfate,
is used to destabilize the colloidal particles of sewage. The
result is the coagulation of many small colloidal particles
into large floes, which are removed by filtration.
Filter Aid. A filter aid, diatomaceous earth, is used to
assist the filtration process. Diatomaceous earth is a finely
divided, insoluble, rigid material that will not compact or
channel when forming a mat during filtration. This maintains
the filtration rate by preventing fine gelatinous solids from
blinding the filter surface.
The basic process, shown schematically in Figure 10, involves four
operations: (1) comminution, (2) disinfection, (3) flocculation, and
(4) vacuum filtration.
* "Development of On-Shore Treatment System for Sewage from Watercraft
Waste Retention System", EPA-670/2-74-056, July, 1974.
-------
MACERATOR-
STRAINER
SANITARY
RATER
DISCHARGE
FILTER
ySSEZEES
' REACTION—¦
COIL
~ -«- ¦ i*»•» •»
flWcViant
FILTER
CAKE
ICHLORINE
SURGE
TANK
Figure 10. Schematic drawing of FMC waste treatment system
Influent wastes are coarsely screened and comminuted to reduce solid
particle size. A bactericidal agent (aqueous chlorine) is added auto-
matically with a metering pump. This treated mixture flows to an
agitated surge tank designed to handle anticipated load fluctuations.
A dry chemical mixture of activated carbon and filter aid is added
automatically to the surge tank by a vibrating feed mechanism supplied
from a hopper above the tank. At a set level, sewage in the surge
tank is moved by a low-volume pump into a reactor coil wound around
the surge tank. Before entering the coil, chemical flocculant is
added automatically to the sewage/chemical mixture by a metering pump.
The coagulated sewage mixture then flows to a rotary vacuum filter,
which separates solids from the liquid. Sewage solids, filter aid,
and carbon retained on the drum filter fabric are removed with a "wire
doctor blade." The clear effluent passes through an air separator
tank before being discharged. The solid filter cake is accumulated
and disposed as sanitary landfill.
Complete automatic operation is accomplished with a magnetic flow metet,
electrical timers, relays, and liquid-level sensors. Fail-safe in-
telligence systems prevent the unit from operating if any component
fails. An alarm system sounds a warning of low chemical level and, if
not replenished, the system automatically shuts off.
G-2
-------
umm<—
^rT^" --, J
""^-r macp.ator./
STRAINER
> DRY CHEMICAL HOP°ER
* i iiwi Him i n i i '• i i
DRY CHEMICAL FEEDER .&>>•
VACUUM FILTER
SURGE TANK
FLOCCULENT TANK
i vv
VACUUM •.
PUMP V.
¦s) f
REACTION COIL
PROCESS PUMP
Figure 11. Photograph identifying major components of the FMC
waste treatment system, model 50-2000
Figure 11 is a photograph of the FMC Waste Treatment System Model 50-
2000, with major components identified. An aluminum frame houses
copper-nickel plumbing and shielded electric motors. Overall dimen-
sions are 239 cm long, 122 cm high, and 203 cm wide, with a total
empty weight of 1135 kg (2500 pounds). Maximum electrical demand is
12 kva, using three-phase 220- or 440-volt current. The design
flow capacity for processing domestic sewage is 15 kl/day (4000 gal/
day) at an average flow rate of 9.5 1/min (2.5 gal/min).
Operating costs for wastes having approximately 2000 mg/1 ss and BOD^
were //602/KI ($23.5/1000 gal). Auxiliary treatment cost for zinc
removal and postchlorination was $1.5/KI ($5.7/1000 gal.).
Capital costs for unit not given.
G-3
-------
APPENDIX II - OCr-AN CURRENT STUDIES - PEBBLY BEACH OUTFALL LOCATION AND BLOCK
ISLAND OUTFALL ANALYSIS
(see following pages)
H-l
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SUBJECT: Proposed Ocean Outfall, New Shoreham, Rhode Island DATE: January 7, 1975
FROM: ¦ IAS
Environmental Impact Statment Office
Enclosed is our final report prepared for the ocean current studies
conducted near Pebbly Beach, New Shoreham, Rhode Island, during
October 22 - 24, 1974. Most of the report presents the conditions
which existed and occurred during the study. The discussion portion
presents our interpretation of the data collected.
This report is presented as part of our support effort to the
environmental impact statement being prepared for the proposed
wastewater treatment system at New Shoreham-and, at the discretion
of the editor, may be used in its entirety or without the discussion
portion included.
TO:
Wallace E. Stickney, Chief
Myron 0. Knudson, Chief
Surveillance Branch
'Attachment
JAAliO 1975
H-2
EPA Form 1320-6 (Rev. 6-72)
-------
OCEAN CURRENT STUDIES
PEBBLY BEACH OUTFALL LOCATION
NEW SHOREHAM (BLOCK ISLAND), RHODE ISLAND
OCTOBER, 1974
H-3
-------
TABLE OF CONTENTS
PAGE NUMEER
INTRODUCTION 1
STUDY DESIGN 2
STUDY OBSERVATIONS 4
Monday, October 21 4
Tuesday, October 22 5
Wednesday, October 23 7
'1
Thursday, October 24 >3
!
DISCUSSION 111
/rr<£i/g£l
I
/! pO < H s*
-------
LIST OF TABLES
TABLE NUMBER TITLE PAGE NUMBER
1 WIND DIRECTIONS AND VELOCITIES 6
H-5
-------
List of Appended Figures
Ocean Current Studies
Pebbly Beach Outfall Location
New Shoreham (Block Island), Rhode Island
October, 1974
Figure No. Title
1 Location Map
2 Drogue Detail
3 Station Displacement
4-8 Current Studies
Proposed Outfall at Pebbly Beach
New Shoreham, Rhode Island
October 22, 1974
9-16 Current Studies
Proposed Outfall at Pebbly Beach
New Shoreham, Rhode Island
October 23, 1974
16 - 21 Current Studies
Proposed Outfall at Pebbly Beach
New Shoreham, Rhode Island
October 24, 1974
pi-6
-------
OCEAN CURRENT STUDIES
PEBBLY BEACH OUTFALL LOCATION
NEW SHOREHAM (BLOCK ISLAND).RHODE ISLAND
INTRODUCTION
During October 21 - 25, the Environmental Protection Agency,
Region I's Surveillance & Analysis Division engaged in near shore current
studies off the east shore of Block Island (see Figure 1). The studies
were precipitated as part of a data collection program prior to preparing
an environmental impact statement for a proposed municipal wastewater
treatment plant at New Shoreham, Rhode Island.
The Environmental Protection Agency mathematically modeled the
drift and dispersion of the sewage plume from a proposed sewer outfall
at Pebbly Beach, New Shoreham, Rhode Island. The preliminary model
used available modeling techniques.
Two data sources were immediately available with which to compare
current .velocity assumptions used in developing the model. These were
a report prepared for Fenton Keyes Associates and Department of Commerce
Tidal Current Charts for Block Island Sound. The Fenton Keyes current
study had used drogues deposited 60 meters (200 feet) east of the end
of the Old Harbor breakwater. This point is some 1070 meters (3500
feet) north of the currently proposed outfall which will be submerged
in 1.3 meters (4.3 feet) of water^- approximately 70 meters (230 feet)
from Pebbly Beach.
^¦at mean low tide
H-T
-------
2
The currents shown in the Department of Commerce Tidal Current
Charts are based upon data collected approximately 1600 meters (one
mile) offshore and did not necessarily represent local current patterns.
The charts showed that offshore from the proposed outfall the near shore
current patterns are southeast on ebb tide, but on flood tide the current
splits. North of the Old Harbor breakwater the current drift is north-
vest while at Southeast Point the drift is southwest. The proposed
outfall lay in the nebulous area where the current splits.
The Environmental Protection Agency needed to collect local current
data which would demonstrate the reasonableness of the assumptions used
in developing the model. In addition, currents at locations more distant
from shore needed examination in case the proposed outfall terminus is
unsuitable.
STUDY DESIGN
Since the mathematical model used critical time-displacement vector
assumptions, the Environmental Protection Agency conducted shallow
water drogue and surface float studies to determine the tide and wind
induced current patterns in the vicinity of the proposed outfall. The
drogue details are shown in Figure 2. The floats were constructed of
15.2 cm X 15.2 cm X 1.3 cm (6" X 6" X 1/2") squares of plywood and
painted orange.
The field crew deposited drogues approximately 75 meters (250 feet),
150 meters (500 feet), and 230 meters (750 feet) from shore. Because
of concerns about a current split, two stations were selected which
were 750 meters (250 feet) perpendicular to the proposed outfall pipe
H-8
-------
3
extended. See Figure 3 for the displacement pattern. Because of the
shallow depth at the outfall location, the validity of the drogue data
from this location might be doubtful. Therefore, the crew used floats
at the 75 meters and 150 meters locations to plot surface currents.
On bluffs overlooking the outfall location, the field crew operated.1,
two transits for triangulating the drogue and float drift positions.
Critical .observations were made at two minute intervals for the first ten
minutes on floats. If the drogues were moving laterally along the shore-
line, sightings were recorded at fifteen minute intervals. If the drogues
were moving out from shore, they were withdrawn. In the event that the
drogues and/or floats reach shore, the contact time and locations were
noted and that test series terminated.
The Environmental Protection Agency felt that flood tide and north
to east winds would create the critical transport currents. Three days
were allotted to tracking current patterns. Because of time constraints
for completing the study, October 22 - 26 was the only time envelope
which was favorable (i.e. when light would be available) for tracking
the drogues. This time frame allowed for sightings through the entire
flood tide and a major portion of ebb tide. If inclement weather had
prevented conducting the study on one or two days, tides and light still
would have been favorable for observing most of the flood tide.
In conversations with personnel at the National Oceanic and
Atmospheric Administration's weather station at the Block Island State
Airport, it was learned that winds during the late spring and summer
are usually from the'south - southwest quadrant. As fall progresses,
the winds shift toward the northwest and in December and January are
H-9
-------
prevailent from the north - northeast. The wind then begins its counter-
clockwise movement toward becoming a south - southwesterly wind in the
late spring.
STUDY OBSERVATIONS
Monday, October 21
Weather: Overcast Winds: North
Tides: low - 0545 hours^ high - 1230 hours
On Monday, October 21, the winds were from the north and arriving
on the island at 1100 hours the crew had its first encounter with the
type of surf north or east winds create. A steady line of white capped
waves were rolling in on Crescent Beach. The waves were 1.2 to 1.8
meters (4 to 6 feet) in height and began breaking approximately 240
meters (800 feet) from the shoreline. In the Pebbly Beach area, the
vicinity of the proposed outfall, ground swells were rolling in at
approximately the same height and crashing into the rocks. The waves
in this area were breaking 60 to 150 meters (200 to 500 feet) from
shore.
On Monday, the crew established stations for setting up transit.
One station was located at the northeast end of Spring Street, overlooking
Pebbly Beach; the other was located 134 meters (438 feet) northeast of
the first point on the edge of the bluff overlooking Pebbly Beach. On
the next day the crew had to abandon this point because of sun reflections
in the early morning. It was replaced with a new transit point at the
^All times in this report are Eastern Daylight Time.
H-10
-------
5
edge of Spring Street 117 meters (383 feet) southeast of the first
transit point.
Tuesday, October, 22
Weather: Clear Winds: West—southwest 10-14 knots^
Tides: low - 0635 hours high - 1328 hours
In the vicinity of the outfall rocks 0.3 to 0.6 meters (1 to 2 feet)
in diameter littered the beach, and boulders 1 to 2 meters (4 to 6 feet)
In diameter are visible In the water or lying slightly submerged up to
60 meters (200 feet) from shore. The winds were blowing directly off-
shore, and the seas were lapping gently against the shoreline. Wave
heights were less than 0.5 meters (1 1/2 feet) high.
At approximately 0800 hours the first drogue was Installed at
Station 4 and shortly thereafter at Stations 2 and 3. Surface floats
were Installed at Station 1. It was not long until the crew determined
that the north transit location was unsuitable. At approximately 1000
hours, the transit was moved to the southerly location on Spring Street.
Later, when drogues were released at Station 1, their paths were erratic
seeming to indicate that the drogues would get hung up on rocks and
bounce among them. The velocities of the drogues Installed at Station 1
are suspect. Drogues installed at Stations 2, 3, and 4 moved south-
easterly on a flood tide. This same general drift continued throughout
the day and into ebb tide. (See Figures 4-8.)
Surface currents rapidly moved floats placed at Station 1 from
shore in an east - northeast direction. (See Figures 6 and 8.)
^-Hourly wind readings are available In Table 1.
H-ll
-------
TABLE
WIND DIRECTIONS1 AND VELOCITIES2
OCEAN CURRENT STUDIES
NEW
PEBBLY
SHOREHAM
BEACH OUTFALL
(BLOCK ISLAND)
LOCATION
, RHODE
ISLAND
DATE
10/22/74
10/23/74
10/24/74
Time
Clours)
(EDT)
Direction
Knots
Direction
Knots
Direction
Knots
0600
270
10
280
10
350
07
0700
300
11
260
11
360
133
0800
240
10
280
11
350
14 3
^00
260
11
310
10
340
14 3
1000
240
12
300
12
020
10 3
1100
240
13
330
19
010
10 3
1200
220
13
300
15
040
06
1300
220
12
310
15
070
06
1400
220
13
290
16
070
06
1500
210
14
290
15
160
08
1600
240
14
250
14
170
09
1700
230
12
230
11
170
07
1800
230
14
320
12
180
07
NOTE: Wind directions and velocities were supplied by the National Oceanic and
Aeronautic Administration's Weather Station at the Block Island State
Airport.
^Direction indicates the azimuth from which the wind blows. The azimuth is read
clockwise with zero and 360° denoting north.
^Five knot correction factor has been added to reported readings.
^Station was manned; no correction factor applied.
H-12
-------
7
Surface velocities were 0,97 knots at 1145 hours and 0.31 knots at 1440
hours. Other floats were not recorded because the slight wave action
coupled with the narrow fleld-of—view of the transits prevented
observers from locating and tracking the floats. Using binoculars, the
floats were observed moving out from shore.
The drogues, although all moved southeastward, gradually shifted
to a more easterly direction as high tide approached and on Into ebb
tide. Drogues released from 0800 - 0900 hours travelled from 0.05 to
0.09 knots with those farther from shore having greater velocities.
During the next two hours, the velocities in the vicinity of 230 meter
stations remained relatively constant. However, when the drogues were
northeast of the near point (see Figure 1), velocities increased to
more than 0.12 knots. Throughout the tidal cycle little velocity change
was noted in the cove .area, but the velocities of the offshore drogues
and those which passed the near point increased markedly at the approach
of high tide and into ebb tide. The farther the drogue was from shore
the more rapid its movement. One and one-half hours after high tide,
velocities greater than 0.30 knots were recorded.
Wednesday, October 23
Weather: Clear Wind: West - northwest 10-19 knots
Tides: low - 0736 hours high - 1427 hours
Wednesday the sea and weather conditions were similar to those on
Tuesday.^ The wind, however, had shifted northward. This shift had an
apparent effect upon the current patterns in the cove area. The drogue drift
was more to the south with a gentle sweep eastward as they approached
the near and far points of land, (See Figures 9 - 16.) As had occurred
H-13
-------
8
on the previous day, the drift moved more eastward near the time of high
tide and into ebb tide. The drogues on this day tended to run aground
among submerged rocks lying off the points.
Because the drift continued to be in one direction with no indication
of a current split northward, Stations 2 and 3 were abandoned as drogue
release points. A Station 5 lying midway between Stations 1 and 4 was
established.
Drogue velocities were similar to those encountered on 10/22/74r
Those placed at Station"4 moved more rapidly than those deposited at
Station 5. Velocities of the Station 5 drogues sometimes doubled as
the drogues passed the near point. Velocities in the cove area (Station
5 drogue) ranged from 0.06 to 0.16 knots with most being 0..07 to 0.08
knots. Off the near point, these drogue velocities ranged from 0.07
to 0.18 knots but generally held about 0.11 knots. At Station 4 drogue
velocities ranged from 0.08 to 0.24 knots with most being near 0.12 knots.
Floats placed at Staion 1 moved parallel to the shoreline at
velocities ranging from 0.20 to 0.27 knots. All were washed onto the
north shore of the near point,
Thursday, October 24
Weather: Overcast changing to broken clouds
Wind: North - northwest changing to east 6-14 knots with
gusts to 25 knots
Tide: low - 0855 hours high - 1520 hours
Thursday morning the weather was blustery, similar to that encountered
upon the crew's arrival on the island. North winds existed from 0600
to 1100 hours. White capped swells 1.5 to 2.5 meters (5 to 8 feet) high
H-lfc
-------
were rumbling Into shore from the northeast. The waves were rolling,
cresting, and breaking nearly 150 meters (500 feet) from shore. Those
thundering against the Old Harbor breakwater would toss water high above
and at times over the breakwater. The waters within Old Harbor were
more violent than the boat crew had encountered at the outfall location
on Tuesday and Wednesday. Throughout the day seas continued to run from
the east-northeast quadrant, but their intensity diminished in the late
morning to rythmic ground swells 1.2 to 1.8 meters (4 to 6 feet) high.
By early afternoon the surf line had moved to within 60 meters (200 feet)
offshote. Residents on the island disclosed that during stronger wind
conditions or storms at sea the surf line could extend more than 300
meters (1000 feet) out from shore.
Because of the turbulent conditions, the boat crew could not approach
Station 1 so they released no drogues there. In addition, a Station 6
was established to determine current velocity and direction farther from
shore. Station 6. lay on a line with Stations 1, 4, and 5 approximately
300 meters (1000 feet) from shore.
From 0830 - 1000 hours the drogues moved as on the other days—
southeastward. From 0830 - 0915 the current drift was approximately
0.20 knots. During the next hour, the drogue velocities decreased rapidly
and at 1030 hours current reversal was detected. During this same period
winds had shifted from north-northwest to north-northeast. Continued
drogue releases showed that the offshore current movement was southward,
but a clockwise eddy was being generated. Drogues released at Station 6
moved south but gradually turned westward as they approached the near
point. Once entering the cove area the drogues moved northward parallel
H-15
-------
Co the shoreline. Drogues placed at Station 5 moved northwest and
started to parallel the shoreline. At 1400 hours, winds were shifting
rapidly from east northeast to south - southeast, and currents were
moving onshore (southwest) but the velocity decreased rapidly near
shore. Drogues placed at Station 6 moved approximately 140 meters
(450 feet) in twenty-one minutes while the drogue near Station 5 moved
about 35 meters (120 feet) in nineteen minutes. From 1430 hours to
1520 hours (high tide), the drogue movements were relatively stagnant,
and thep the drogues began moving off to the southeast at 0.03 knots
although the winds had shifted to south -southeast at 8 knots. (See
Figure 21.)
Groups of floats were placed at Station 5. Floats deposited
at 0900 hours were on shore within nine minutes. Those dropped at
1020 hours were at Station 1 in six minutes and on shore two minutes
later. Others placed at 1200 hours were on shore in nine minutes.
At 1500 hours floats were tossed from shore in the vicinity of
Station 1. The floats that landed just beyond the surf line drifted
southeastward. Those which landed within the surf line were on Pebbly
Beach within one minute.
11—16
-------
11
DISCUSSION
Pebbly Beach Is aptly named. Rocks and boulders litter the proposed
outfall area. Drogues released at Station 1 appear to ground or get
hung up on rocks. Their paths were erratic and drogue velocities in
this area were not reliable indicators of current movements.
The near shore ocean currents in the vicinity of Pebbly Beach appear
to be wind influenced. The predominent drift on both flood and ebb
tides was southeast. A north - northeast wind can induce clockwise
currents near Old Harbor Landing and Pebbly Beach. While the wind effect
seems to have counteracted the southeast movement during flood tide,
it did not overcome the southeast flow during ebb tide. On Thursday,
October 24, 1974, the wind had shifted to south - southeast but had not
been from that quadrant long enough to determine the effect of a sustained^
southeast wind.
The surf is of major concern. While the wind direction is critical
for surf development, the surf produced the most rapid on shore move-
ment. On Thursday the crews recorded on shore float velocities of 1
to 2 knots in the surf. Residents said that Thursday's surf was not
unusual with the northeast wind. Since the surf line remained at, or
beyond, the proposed outfall location, one can expect that anything
discharged at that location under such conditions would be on the beach
in 1 to 2 minutes. Residents* comments that the surf line can occur
more than 300 meters from shore means that an extended outfall will be
at times subject to the same phenomenon. However, since winds are
reportedly from the south and west during the late spring, summer, and
H-17
-------
12
early fall months, sewage wash, nay be an Infrequent problem during the
months of high recreation use.
The nearest recognized bathing area Is Ballard*s Beach, located
on the south side of the Old Harbor breakwater (see Figure 1), This
beach Is approximately 550 meters (1800 feet) north - northeast of
the proposed outfall. At no time did a float or drogue get within
300 meters (1000 feet) of Ballard's Beach.
H-18
-------
/£
ie
irtitch
Georgian
=Summp
Hams
i
Xt. \Harbor
5oJ
House
N *Np— fOAn ^ *• t \«
J- fiew Meadow Hilly ¦: \ r\ Si
f *¦ Swamp ;V vr
J -•' ro^ >¦;• 'v • V+# »j
a roor
<- Bd Hard's
Beach
Lantern
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r_. L~. .'•*& ^Vc?v
STUDY AREA
^ '^V^A *0-
ntinental' | , ^/pebbly, Ne<"" Wi
-. {.' 'Pojid ¦. ° V"\ ^T^Beach^Old Harbor
/¦?',*'/• " v* ¦ i/'* *"* •* »\ \ V-iX^ Landing
Greats-- _• / « \ XX* +++*
Swamp . I' . • *"•
• Old Harbor
Pt
High: i4 mbrose
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^•HS.orI
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Cove
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Swamp.
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• JX '
(Sanda _ "
fold Whale
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til Ruck
Cove*
John E
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^ / II • y An ^ Pnn^ /
Southeast
~ * pt
Ski no*&i nk
Cove
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Block Island
SE Lighthouse °
Blufts
M0HfO4w
it— *e*"h ..
Great
/.
/
s
<05
"9
LOCATION MAP
"Cow z*Lighthouse Ocean Current Studies
Cove Jn Pebbly Beach Outfall Location
New Shoreham (Block Island), Rhode Island
Figure 1
H-19
-------
15 - 30 cm <6" - 12")
Surveyor's Flagging
Straightened Coathanger
m
H
PVC Threaded Plug
PVC Female Adapter
m
PVC Pipe
00
2" PVC Connectors
1/8" x 1* x 2' Plexiglass
-------
A/eJr
, Point
^ Ocean Current Studies
\ Pebbly Beach Outfall Location
New Shoreham (Block Island), Rhode Island
Statlpn Displacement
O •* Proposed Sidl'icHS
•Q" Stations
( Noi io Scttte)
FIGURE 3
H-21
-------
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
Hours)
a—
1 inch = 250 feet
(Hours)
® Drogues •
Floats
DATE: October 22,1974 TIDES: Low 0635 hrs. High 1328 hrs.
WIND DIRECTION: 240°-260° VELOCITY: 10 - 12 knots
23
0840
0900
"¦;v'
0845
0855
10
1020
¦%
•¦-mvT
fiiSig
m&i
23
%$«
Old Harbor Ptlir
iff
mm
FIGURE 4
-------
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
STUDY
AREA
LEGEND
NEW
SHOREHAM
1 inch = 250 feet
(Hours)
(Hours)
Drogues
-• Floats
DATE: October 22,1974 TIDES: Low 0635 hrs. High 1328 hrs.
WIND DIRECTION: 2609-220° VELOCITY: 11-13 knots
LOCATION MAP
23
23
.0910
0919
0903
k0948
.0917
0945
1028
1125
1151
1025
Old
* y
"4 dr
V/
FIGURE 5
-------
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
STUDY
AREA
LEGEND
NEW
SHOREHAM
1 inch = 250 feet
(Hours)
(Hours)
• Drogues
Floats
DATE: October 22,1974 TIDES: Low 0635 hrs. High 1328 hrs.
WIND DIRECTION: 220° VELOCITY: 13 knots
LOCATION MAP
23
1226
23
1223
1310
1141
1314
1140
,1149
1145
H5Q
1131
1316
1334
1358
1415
m
Old Harbor Pt.
FIGURE 6
-------
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
(Hours)
•—
1 inch = 250 feet
(Hours)
9 Drogues •
Floats
DATE: October 22,1974 TIDES: Low 0635 hrs. High 1328 hrs.
WIND DIRECTION: 210°-240° VELOCITY: 13*14 knots
23
1330
"S3
1328
23
I I >111
• • •
i&o.
VN»
. *
*v> < i&feW
Old Harbor Ptli
m
m*-
Mm.
FIGURE 7
-------
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
1 inch = 250 feet
(Hours) (Hours)
•— • Drogues • • Floats
DATE: October 22,1974 TIDES: Low 0635 hrs. High 1328 hrs.
WIND DIRECTION: 210°-220° VELOCITY: 13-14 knots
16
7
Old Harbor Pt.
FIGURE 8
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
-------
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
(Hours)
•—
1 inch = 250 feet
(Hours)
• Drogues °
Floats
DATE: October 23, 1974 TIDES: Low 0736 hrs. High 1427 hrs.
WIND DIRECTION: 280°-3IO° VELOCITY: 10-12 knots
.0801
7 \ .0800
23
^>811
\08I6
P!> • ^-0819
» • ">.0824
0900
0835
0853
I0I5\ ii
-
0908
* -i
$3
Old Harbor Pt.1
Sil
£11
.uVj
FIGURE 9
-------
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
STUDY
AREA
LEGEND
NEW
SHOREHAM
1 inch = 250 feet
'Hours)
(Hours)
¦* Drogues
Floats
DATE: October 23,1974 TIDES: Low 0736 hrs. High 1427 hrs.
WIND DIRECTION: 300°-3l0° VELOCITY: 10-12 knots
LOCATION MAP
23
23
0901
,0903
. 0904
0915
,0923
.0920
0954
0954
• 1021
.0950
1027
MWMIi
Old Harbor Pt.t§§
pm
FIGURE 10
-------
NEW
SHOREHAM
LOCATION MAP
STUDY
AREA
J
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
(Hours)
•—
1 inch = 250 feet
(Hours)
0 Drogues 8
Floats
DATE: October 23,1974 TIDES: Low 0736 hrs. High 1427 hrs.
WIND DIRECTION: 300°-330° VELOCITY: 15-19 knots
23
J045
'¦-A:
v.
1204
*ip so' »
"yfc » J
,&5/wra
FIGURE II
-------
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
I Hours)
1 inch =250 feet
(Hours)
° Drogues •
Floats
DATE: October 23,1974 TIDES: Low 0736 hrs. High 1427 hrs.
WIND DIRECTION: 290°-310° VELOCITY: 15*16 knots
23
1230
•J240
1348
IS
13
'5>.i£&$
fl.
was
Old Harbor Pt. WM
Mm
¦'-ihf.
FIGURE 12
-------
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
1 inch = 250 feet
(Hours)
(Hours)
• Drogues
Floats
DATE: October 23,1974 TIDES: Low 0736 hrs. High 1427 hrs.
WIND DIRECTION: 250°-3l0° VELOCITY: 14-16 knots
*
*
14
23
i
Harbor
FIGURE 13
-------
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
(Hours)
e—
1 inch = 250 feet
(Hours)
8 Drogues °
Floats
DATE: October 23,1974 TIDES: Low 0736 hrs. High 1427 hrs.
WIND DIRECTION: 250° - 290° VELOCITY : 14 -15 knots
23
17
1444
Old Harbor Pt. m
.m
FIGURE 14
-------
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
(Hours)
e—
1 inch = 250 feet
(Hours)
• Drogues •
Floats
DATE: October 23,1974 TIDES: Low 0736 hrs. High 1427 hrs.
WIND DIRECTION: 230°-250° VELOCITY: 11-14 knots
23
14
1530
23
i
Harbor
FIGURE 15
-------
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
1 inch = 250 feet
(Hours)
o—
(Hours)
Drogues
Floats
DATE: October 23,1974 TIDES: Low 0736 hrs. High 1427 hrs.
WIND DIRECTION: 230°-250° VELOCITY: II-14 knots
14
23
23
l60l 1607
1636
613
1717
'••Hs
llltiilM
. *
'W
Old Harbor Pt1j§|
m
*'-W.
0
FIGURE 16
-------
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
' Hours)
o—
1 inch = 250 feet
(Hours)
• Drogues •
Floats
DATE: October 24,1974 TIDES: Low 0855 hrs. High 1520 hrs.
WIND DIRECTION; 010*- 350° VELOCITY: 10*14 knots
23
0857
0854
0937
15
1013
. *
up
Old Harbor Ptttflf
K
My
A ,V
gm
•jsya
FIGURE 17
-------
NEW
SHOREHAM
STUDY
\ AREA
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
1 inch =250 feet
(Hours)
o—
(Hours)
Drogues
Floats
DATE: October 24,1974 TIDES: Low 0855 hrs. High 1520 hrs.
WIND DIRECTION: 010°* 020° VELOCITY: 10 knots
17
23
23
.1017
*
Old Harbor Pt.f|
FIGURE 18
-------
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
1 inch = 250 feet
(Hours)
(Hours)
Drogues
Floats
DATE:October 24,1974 TIDES:Low 0855 hrs. High 1520 hrs.
WIND DIRECTION: 010°-070° VELOCITY: 06 knots
14
23
23
.1139
Old Harbor PtW
i
¦Sfeis
88m.
FIGURE 19
-------
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
(Hours)
LEGEND
1 inch = 250 feet
(Hours)
• Drogues 8
Floats
DATE: October 24,1974 TIDES: Low 0855 hrs. High 1520 hrs.
WIND DIRECTION: 040°-160° VELOCITY: OS -08 knots
1443
71324
•&SESB»3»$b8
wmtmsss®1*-*'"
Old Harbor Pt
FIGURE 20
-------
STUDY
AREA
NEW
SHOREHAM
LOCATION MAP
CURRENT STUDIES
PROPOSED OUTFALL AT PEBBLY BEACH
NEW SHOREHAM, RHODE ISLAND
LEGEND
(Hours)
¦—
1 inch = 250 feet
(Hours)
• Drogues ®
Floats
DATE: October 24,1974 TIDES: Low 0855 hrs. High 1520 hrs.
WIND DIRECTION: 070°-170° VELOCITY: 06*09 knots
14
1407
1604
1639* 1450
1603 t
1618
23
15
15
ISipllv
'life
MHS
^!
Old Harbor Ptmf
W
FIGURE 21
-------
INTRODUCTION;
We have conducted analyses of two aspects of dilution of wastewater
from the proposed New Shoreham Wastewater treatment facility. These
are dilution due to diffuser design and depth of water over the
diffuser; and dilution due to dispersion of surface plume of waste-
water under two conditions;constrained by a seawall parallel to the
path of flow and unconstrained in the horizontal plane.
RESULTS:
We found that it would be desirable to relocate the outfall in
deeper water to increase dilution. Certain specific modifications of .
the diffuser design would also increase dilution.
The following sections detail the analyses of the diffuser problem
and allow for the investigation of a large number of design options
by means of generalized tables and charts.
H-UO
-------
-2-
BLOCK ISLAND OUTFALL ANALYSIS
A. Diffuser analysis
The dilution of sewage effluent by means of a diffuser system is a
function of jet velocity, jet diameter, discharge angle, sewage density,
and water depth. Work by Fan & Brooks (1), as presented by Norman Brooks
at Manhattan College, May, 1973, analyzes sewage dispersion by use of the
densimetric Froude Number, and the depth/diameter ratio of the diffuser,
for peak flows of 0.3 MGD (0.45 cfs) each port of the 8 port present -
design would have a Froude Number of 2.3 and would, ifacting independently,
ii
(1) Van, Loh-Nien and Brooks, N.H., "Numerical Solutions of Turbulent
Bouyant Jet Problems" W. M. Keck Laboratory of Hydraulics and
Water Resources Report No. KH-R-18, California Institute of
Technology, Pasadena, January, 1969, 54 pp.
0- velocity
v. f
H-ltl
-------
produce dilution ratios somewhere between 6 and 9. However, the close proximity
of the eight individual ports, as shown below, make the likelihood of plume
interaction very high, although impossible to determine(because of the very
low velocity, and very shallow, changing depth).
Interaction of G & F and B & C to a high degree is certain because low jet
velocities mean there will be very little horizontal movement before density-
differences cause vertical rise. Interaction between jets E & H and A & D
are also very likely, although the resulting loss of dilution would
probably not be as great as in the case of G & H and B & C. There is
also a likelihood of plume interaction between adjacent ports in the
horizontal plane, such that ports F & E, E & D, H & A, G & H, A & B,
and C & D would not be likely to have sufficient spacing to allow
unrestrained dilution.
Besides the problem of actual plume interaction, there could be a problem
of restraint of dilution water flow. Plume analysis theory requires
sufficient access to the plume by clean dilution water. With this scheme,
! I
H-l+2
-------
-4-
as the individual plumes expand, the availability of clean dilution water
could be severely limited, thereby decreasing dilution.
Additionally, dilution expected during periods of considerably lower
flow (lower than 0.45 cfs), would be drastically lower still, because of
decreased velocity and therefore a lower Froude Number, so that the
sewage field would not be likely to act as a jet, but as a weakly buoyant
flow, with little mixing likelihood. As a result of the above analytical
difficulties, no dilution of the sewage could be ascribed to the present
design.
Several other possible diffuser arrangements were analyzed for their
possible environmental effects. Three designs were analyzed for six
one-inch diameter ports at plant flows of 0.45 cfs, 0.225 cfs, and
0.112 cfs, along with three designs for six two-inch ports at the same
flows. In each case, ports were assumed to be spaced such that they
would not interact (spacings of several feet, discharging horizontally).
Froude Numbers of: 9.3, 4.6, and 2.3 resulted from the two-inch ports
at the specified flows, while the one-inch ports at these flows resulted
in Froude Numbers of: 54.7, 27.8, and 13.9, respectively.
The following chart shows the dilutions that could be expected from
a given depth and Froude Number.
H-U3
-------
120
80
100
80
60 w
50-52-
AO;
30
29
20
30
40
' F * FROUOE No. * „ Z
td'Wd
PIG. 7.-DII.UTI0N AS A FUNCTION OF y0/D AND F FOR HORIZONTAL DISCHARGE
diffusers for disposal of sewage in sea water
By A.M. Rawn, F.R. Bowerman, and Norman H. Brooks
H-M
-------
BLOCK ISLAND OUTFALL ANALYSIS
B. Surface Plume Analysis
Once the bouyant jet from the diffuser reaches the surface, the sewage
field Is carried In local ocean currents, and undergoes further reductions
in concentration of pollutants by far field dispersion and by decay of
non-conservative substances such as coliforms and biochemical oxygen
demand, (BOD). The following equation is used to describe the changes in
concentration due to lateral dispersion, advection and decay:
6. - diffusion coefficient
C = Concentration
U ¦=. Velocity in "x" direction
K - decay rate
y u r spatial coordinate system
•1
The equation was solved numerically by the Systems Analysis Branch, EPA,
Region I, (3) for two cases, herein referred to as the unconstrained case
and the constrained case. The unconstrained case is open to dispersion in
(2) Brooks, N.H. "Waste Water Disposal in the Marine Environment" Pearson,
U. California, Berkely, 1959, Pergamon
(3) Internal Memos, October - November, 1974, Systems Analysis Branch, EPA, Region ]
li-1+5
-------
-6-
both directions perpendicular to the center-line velocity. The constrained
case has a berm or seawall along one side, preventing dispersion in that
direction. Figure 1 below illustrates the two cases studied.
SfoarC.
r\
I6 J /C £
f
u = current velocity
FIGURE 1
The plume analysis computed lateral dispersion perpendicular to the
center-line of the sewage plume. The plume need not be heading toward shore
to be valid, although this would seem to pose the most environmentally
important case, as other paths require additional lengths of travel, and
result in higher dilutions. Figures 2 through 10 summarize the computer
runs of the plume model. All sewage concentrations refer to the ratio C/Co
or the fraction of the original surface concentration remaining.
Figure 2 shows a schematic drawing of the system being analyzed, with
the peak concentration declining as the plume spreads, i.e. as the plume
width increases. Figure 2 shows only half of the plume for the symmetric
unconstrained case, and shows the whole plume for the constrained case
because there is no dispersion through the seawall. i.j .*
H-i+6
-------
Ay
M
PLUME
CENTERLINE^ X
1- PLUME WIDTH
I1*
ORIGINAL )
PLUME WIDTH
% 2
-------
Ay = .25'
b = Plume Width (2.5')
ii.= Velocity (0.3 fps}
0 = .00339 ft.2/sec.
X - Distance along center line (ft.) from source
50'= x
1/2 OF UNCONSTRAINED SYMETRICAL PLUME
M
I
¦t-
cx>
.6
200' = X
Co
500' - X
50
60
80
30
DISTANCE PERPENDICULAR TO CENTER LINE (ft.)
40
20
-------
UNCONSTRAINED
Ay = 0.25*
b = 2.5'
D = 0.00339 ft2/sec.
X 5 Distance along center line
0.8-
0.6-
0.4-
u = 0.5
u = 0.3 fps
0.2-
u = 0.1 fps
100'
200
300
400
500
700
600
800
X (ft.)
CENTER LINE CONCENTRATIONS
-------
1.0
UNCONSTRAINED
u = 0.3 fps
0.8"
Co
\n
o
100
200
300
400
500
600
700
800
DISTANCE FROM SOURCE (ft.)
EFFECT OF SOURCE WIDTH ON CENTER LINE CONCENTRATION
-------
I.0-,
UNCONSTRAINED
X - 200* Along center line
u = 0.3 fps
0.8-
0.6
3.5'
C_
Co
b= 2.5
h 0.4-
0.2-
80
70
30
50
60
20
40
10
DISTANCE FROM CENTER LINE (ft.)
EFFECT OF SOURCE WIDTH ON CONCENTRATION PROFILE PERPENDICULAR TO CENTER LINE
-------
1.0
CONSTRAINED
Ay = 0.25'
0.8-
D = 0.00339 ftVsec.
X = Distance from source
0.6-
u = 0.5 fps
C_
Co
u = 0.3 fps
0.4-
VI
ro
u = 0.1 fps
0.2-
200
300
100
400
500
600
700
800
X (ft.)
LINE OF HIGHEST CONCENTRATION (ALONG SEAWALL)
-------
CONSTRAINED
X = 100'
0.8-
u s 0.3 fps
0.6-
b = 2.5'
C_
Co
0.4-
0.2-
20
30
50
60
70
80
40
y (DISTANCE FROM BARRIER-ft.)
EFFECT OF SOURCE WIDTH ON CONCENTRATIONS PERPENDICULAR TO CENTER LINE
-------
CONSTRAINEO
Xs 200* (Distance from source)
u = 0.3 fps
0.8-
0.6-
JC
Co
b=2.5
0.2-
50
60
80
30 40
y ( DISTANCE FROM BARRIER - ft.)
20
EFFECT OF SOURCE WIDTH ON CONCENTRATION PERPENDICULAR TO CENTER LINE
-------
/o ¦
I.O-i
CONSTRAINED
X = 500* (Distance from source)
u = 0.3 fps
0.8-
0.6-
0.4-
0.2-
60
80
70
50
10
20
30
40
y (Distance from barrier -ft.)
EFFECT OF SOURCE WIDTH ON CONCENTRATION PERPENDICULAR TO CENTER LINE
-------
Figure 3 shows the concentrations perpendicular to the plume center-line
at various distances from the sewage source, for the unconstrained case.
These curves show the peak decreasing, and the plume width increasing
with distance from the source.
Figure 4 shows the effect of various current velocities on the dispersion
of the sewage. It can be seen that higher velocities restilt in lower dilution
of the sewage.
The reasons for this become apparent when the solution of the differential
equation (2) is examined in finite difference form for the case where there
is no decay:
+ C
Where: - Concentration at i, j
r Concentration art i + 1, j
L, \ r Are grid coordinates in the x and y
directions respectively
t z Diffusion Coeficients
U r Velocity in the x direction
b - Original source width
r Grid spacing in x direction
4^ s Grid spacing in y direction
The whole first term on the right side shows the change in concentration from
one grid point to the next in the x direction. This is seen to become smaller with
increasing velocity u.
H-56
-------
-8-
Figure 5 shows the effect of source width on plume centerline
concentrations for a constant velocity, and the unconstrained case.
This is important because various diffuser alternatives would result in
different dilutions and different surface boil sizes.
Figure 6 shows the effect of source width on plume profile concentrations
at a distance of 200 feet from the source.
Figures 7, 8, 9, and 10 show similar analyses for the case of a
constrained plume.
Using the above generalized curves, almost any expected current
strength or outfall location can be evaluated.
C. Special Surf Conditions
If an outfall is subject to surf conditions, the results of any diffuser and
surface plume analysis must be evaluated in a different light. Breaking
surf usually occurs when sea depths become shallow. A diffuser system
that is located inside the surf line is subject to widely varying hydro-
dynamic forces, most of which are adverse. Swell action causes significant
depth changes when compared to total depth, and local velocities near the
diffusers could interfere with jet dispersion. The surface plume, when
caught in a surf would experience high velocity which would be guaranteed
to be shoreward in direction, and dilution would be significantly reduced.
The curves for plume dilution as found in Section B would be invalid. The
following is quoted from Brooks (2) pp. 262:
H-57
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"The prediction of the coliform count in the surf
zone presents an added difficulty because of the
littoral drift, upwelling of bottom water, and
the less rapid flushing in the shallow region
very close to shore. Because of these effects'
the shore count of a given magnitude may be as
much as two or three times as frequent as
predicted by the above analysis. The experience
of the Los Angeles County District indicates
that the frequency of counts greater than 10 per
ml is greater at the shore than it is offshore."
Therefore, a diffuser located in only 3 to 4 feet of water, at only two
hundred feet offshore, and known to be within the surf line in some current
conditions, would not be likely to produce significant sewage dilution
with a high degree of confidence. Any site for an outfall which falls
within the surf line should be considered a poor site.
D. Diffuser/Plume Analysis Applied to Survey Results
The EPA study of October, 1974, utilized floats and drogues in the
vicinity of the proposed outfall, 225 offshore of Pebbly Beach. The study
was designed to test the reasonableness of computations and assumptions
made in the plume analysis. Current studies were conducted on three days.
TVo days during the study found almost no surf, with one day showing a
predominantly south west wind (9 - 13 knots) and the other day with a
north west wind (9-18 knots). The third day showed heavy surf
H-58
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-10-
200 to 400 feet offshore in the morning with a North to North-East wind
(6 - 14 knots gusting to 25 knots). The wind dropped to 5 - 8 knots from
a southerly direction in the afternoon.
Drogues and floats were released periodically starting one hour
after low tide, and their velocities and paths were recorded. On the
second day, with a southwest wind, all drogues moved in a southeasterly
direction with a velocity range of .07 fps to .4 fps with a large grouping
at about .15 to .20 fps. These are within the range of velocities used
to develop the curves in Section B.
The third day's work encountered winds roughly parallel to shore
to almost directly on shore, NNE to SE. Heavy surf prevailed about 200 feet
to 400 feet off the beach. Floats released in the surf line came up on the
shore, and had an approximate velocity of 6 fps. The analysis of Sections A and B
would not be valid for this condition. However, drogues released beyond the
surf exhibited a definite shoreward motion soon after flood tide began, with
velocities ranging from .1 fps to .6 fps. The curves derived from the analysis
in Section B are valid for this situation up to the point the plume enters
the surf line. The diffuser analysis of Section A applies tor locations beyond
the surf.
E. Example Dispersion Analysis
1. An outfall is located 225 feet offshore, with wind from the North-
west 9-13 knots.
The effluent coliform count is 2300/l00ml.
The present outfall design, with seawall depth =3.5 feet at low water
produces a source width of 2.5 feet.
Dilution due to diffuser is unknown (=1).
The path of plume is 565 feet towards Old Harbor Point.
H-59
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-11-
The average current velocity is 0.13 fps in that direction.
The centerline dilution is 5.8 to 1 (from Figure 4).
The centerline concentration at Old Harbor Point is 2300/5.8 = 396/100 ml
2. Same conditions as Example 1, except a diffuser with 3" ports and
a Froude Number of 4.67 is used.
The dilution due to the diffuser is 7:1 (Table 1).
The dilution due to the surface plume is 5.8:1 (Figure 4).
The total dilution at Old Harbor Point is 7 x 5.8 = 40.6:1
The coliform concentration at Old Harbor Point is 2300/40.6 = 56/100ml
3. Northeast wind 6-14 knots.
Present outfall location and design.
The surf line is at 225 feet and the outfall dilution due to the diffuser
is 1:1.
The dilution due to dispersion in the surface plume (velocity = 6 fps) is
1.33:1 (likely to be lower).
The coliform concentration on Pebbly Beach is 2300/1.33 = 1725/100 ml.
4. Outfall 600' offshore, northeast wind surf at 400' offshore.
The diffuser is composed of 2" ports.
The plume source width is 2.5 feet.
The depth is about 10'.
The current velocity is 0.2 fps to surf line.
The densimetric Froude Number is 13.9.
The dilution due to diffuser is found to be 30:1 (Table 1).
The dilution due to a 200 foot plume traveling to the surf line is
ii-6o
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-12-
The total dilution is 2.5 x 30.1:1 =75:1 at the surf line.
The coliform concentration at surf line = 2300/75 = 30./100 ml.
Any combination of possible situations can be analyzed in this manner, and
the above 4 examples only illustrate possible situations.
H-6l
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APPENDIX I
- COST BASIS FOR ALTERNATIVE ACTIONS
Alternative A: Collection and Treatment.
Cost basis: The costs for the treatment plant and sewer system are taken
from the bid prices of the selected contractor.
Costs for Phase II sewers which were not included in original
bid are based on Block Island estimated costs per foot of
sewer installed.
House connections costs were estimated by EPA, Region I,
at $500/unit.
Total Costs:
Capital
Ave. Annual
0 & M
Treatment Plant
$ 2,2lU,000
__
—
Sewer System
1,505,000
—
Tech. Services
338,000
—
Legal
16,000
—
Admini strative
16,000
—
Contingency
181*, ooo
—
Inspection
100,000
—
Site
10,000
—
Subtotal
$ U,383,000
$ 382,000
$ 27,000
Phase II sewers
500,000
UU,000
House Connections
150,000
13,000
Total
$ 5,033,000
$ 1+39,000
$ 27,000
Total Annual
$ U09,000
kk,000
13,000
$ 1+66,000
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Alternative B: Collection and Treatment minus Phase II sewers.
Cost basis: Future sewer constructions costs for Phase II eliminated.
Existing septic systems in Phase II areas adequate. Future
septic tank construction estimated at $225,000.
Design of treatment facility reduced by amount of flow
estimated for Phase II or approximately 60,000 gpd.
Reduction in cost of treatment facility interpolated from
EPA, Region I cost curves. Therefore, a 21*0,000 gpd
treatment facility would cost $2,000,000 (this does not
include any redesign costs).
Total Costs:
Treatment Plant
Sewer System
Tech. Services
Legal
Administrative
Contingency
Inspection
Site
Subtotal
Future Phase II
septic system
construction
House Connections
Total
Capital Ave. Annual
$ 2,000,000
1,505,000
300,000
1U,000
lit,poo
11*0,000
100,000
10,000 —
$ U,083,000
225,000
100,000 —
$ 1+,1*08,000 $ 381*,000
0 & M Total Annual
$ 25,000
1,000 —
$ 26,000 $ 1*10,000
1-2
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Alternative C: Rehabilitation of Individual Subsurface Disposal Systems.
Cost basis*: Construction or reconstruction of single
home septic system = $ It,000.
Construction or reconstruction of multiple
unit S.S. with average daily flow less
than 2,000 gallons = 10,000.
Construction or reconstruction of multiple
unit S.S. with average daily flow
between 2,000-5,000 gallons = 25,000.
Construction or reconstruction of multiple
unit S.S. with average daily flow over
5,000 gallons = 50,000.
Annual Cost Basis:
Assumed each septic tank must be pumped
once every three years § = $6o/pumping
Therefore, 207 units (Phase I only) at a
design life of 20 years will require
l,lt00 pumpings @ $60/per = $81t,000 4 20 years
= It,200 or $lt,500/yr.
Estimated units from Fenton G. Keyes Associates projections
Appendix F, less Phase II.
Total Costs:
Capital Ave. Annual 0 & M Total Annual
Construction of
Septic Systems in
Phase I areas $ 1,801,000 .$ 157,000 $ U,500 $ 161,500
Hew Construction
of septic systems
in Phase II areas 225,000 19,000 500 19,500
$ 2,026,000 $ 176,000 $ 5,000 $ 181,000
*S0URCE: Tony Lafasio, Rhode Island Department of Health
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Alternative D: Collection and treatment of Old Harbor only. Rehabilitation
of individual septic systems for remainder of Phase I area.
Cost basis: Sewer construction of Phase II eliminated.
Sewer construction for "Old Harbor Only" taken from bid
costs - $1,505,000 - 1+05,000 = $1,100,000.
Treatment plant design average flow reduced by 50,000 gpd
(Phase II) and llU,U00 gpd (New Harbor area). Reduction
in cost of treatment facility interpolated from EPA
curves. Therefore,
300,000 - (60,000 + lilt,000)
= 126,000 gpd or $1,300,000
Reconstruction or new construction of septic systems in
New Harbor estimated at $700,000. Future construction of
septic systems in Phase II areas estimated at $225,500.
Total Costs
Capital Ave. Annual 0 & M Total Annual
Treatment Plant
$ 1,300,000
—
—
—
Sewer System
1,100,000
—
—
—
Tech. Services
2lt0,000
—
—
—
Legal
10,000
—
—
—
Administrative
10,000
—
—
—
Contingency
100,000
—
—
—
Inspection
50,000
—
—
—
Site
10,000
—
¦—
—
Subtotal
$ 2,820,000
$ 20,000
House Connections
75,000
—
—
—
Individual Septic
systems in Phase I
700,000
—
2,500
—
Future septic systems
in Phase II
225,000
—
—
—
Total
$ 3,820,000
$ 312,000
$ 22,500
$ 335,000
I-It
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APPENDIX J - IMPACT OF SEWERS ON SPECIFIC SECTORS OF THE ISLAND
Following is an analysis of the growth and environmental impact of Phase I
and Phase II sewer lines, or the potential for connecting to these sewer lines,
in the various sectors of the Island. Refer to Maps, Alternative A superimposed
on environmental sensitive areas and cultural features.
New Harbor
A sewer to the New Harbor marinas would extend from Old Harbor for 1.5 miles
along Ocean Ave and West Side Road, plus a Beach Ave loop, through extensive
vacant land, highly attractive for development, yet largely environmental-
critical marshland, shoreland, and scenic uplands. This line, and the potential
for connections, would, based on all experience elsewhere, open up for resort
and summer house development the mid portion of the Island, adversely altering
the environment of Great Salt Pond, its shoreline, marshes, and moor-pasture
uplands rising to the south.
Specifically, the West Side Road sewer to Champlins marina could encourage
condominium and resort development along West Side Road and, in addition, the
opportunities for connections to this sewer could spur condominiums and medium
density residential subdivisions to the west along West Side Road and Center
Road and to the south toward Beach Hill Road. This would press upon salt water
marshes, fresh water marshes, ponds and shorelands and bring strong pressures
for intensive resort development within the storm inundation areas adjacent to
Great Salt Pond and the extensive lowlands below the hurricane high waterline.
If such developments were to occur and suffer flood and hurricane damage,
pressures could, in turn, mount for flood protection projects, which would be
costly and damaging to the wetland ecosystems and scenery. These development
pressures could defeat CCP proposals to preserve as a conservation area Cormorant
Point and Cove Northwest to Champlins marina and the Charlestown Beach Peninsula.
Southwest to West End Road, it would crowd open bayberry heath, up land pasture,
vegetative cover, and scenic vistas of the Great Salt Pond.
Northern Section
With a basic sewer system in Old Harbor, the potential for extension
northward along Corn Neck Road would stimulate beach condominiums and houses
between the road and the southeast embayments of Great Salt Pond (especially
Harbor Pond). Unless this development were carefully confined to the higher
ground (as proposed in Bradford), it would encroach upon the salt marshes.
Some of the area is subject to storm inundation and lies within the hurricane
high water line. Dense development would diminish views of Old Harbor, the
ocean, Great Salt Pond and the North Neck uplands.
Old Harbor
Development associated with the basic sewer system might bring pressures
to fill in a portion of the marshy area at the foot of High St. - near the
commercial center. More intense development would fill in the "vacant" open
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spaces and vegetation and might stimulate construction that would diminish the
area's essential openness and charm. Construction of new architectural styles
might clash with the older styles and historic character. Development of the
opeVi spaces surrounding the Old Harbor care would further diminish this appeal.
On the other hand, construction of a sewer system would permit concentrations
oi people and buildings and encourage restoration and additions to strengthen
a compact town center, without the density limits set by individual subsurface
disposal systems. But proliferation of the system into the hinterland, particularly
to New Harbor, might actually turn additional investment and development away
from restoration of Old Harbor.
Southeast Sewer Extensions - Phase I and II
Pressures for summer home development have already been demonstrated in
the construction of approximately 60 new homes in this section since 1957-
The Pilot Hill Road sewer extension southward and upward from the school
would support growth in the lower perched ground water zone, on which much of
the Island's population depends for water supply. The area embraces Sands Pond
and a number of other ponds. Lacking outlets and small in size, these ponds
have little capacity for self-cleansing: they are extremely sensitive to
pollutants from construction activity and from runoff from build up areas.
The area embraces approximately 20 percent of the Island's taller, heavier
coastal shrub cover and approximately 20 percent of its agricultural land.
The entire area is recommended for "low residential, open space preservation"
in Bradford. That portion west of Pilot Road embraces a proposed park for
extensive recreation - water supply - conservation uses, and that portion east
of Pilot Road for "low density residential" in CCP.
The Southeast Road extension, together with lateral interceptors, would
cumulatively crowd the breathtaking open vistas of, moor, farmland, stone-walled
pastures and ocean. There would be a lesser impact on water supply. The area
west of the road, as Bradford suggests, is generally best suited to "low
residential, open space preservation", but the area east of the road may
accommodate, if desired, a ring of "medium" to "dense residential" development.
The Conn. Ave. extension could encourage connections of development
impinging upon Great Swamp. On the other hand, the high ground immediately to
the east of the Connecticut Ave. terminus appears suitable for development and
offers vistas of Old Harbor. It is proposed for "commercial" and "dense
residential" in Bradford, and for "medium" and "low" residential in CCP.
Dense development here would enclose some of Old Harbor's open, vegetative
backdrop. This closing in upon open space would become more pronounced as
development were extended as a belt along the hillsides to the south of
Old Harbor.
South-Southwest
The Old Town Road-Center Road extension would also traverse upland moor and
wooded areas southwesterly from Old Harbor. Large sections would traverse a
strip deemed suitable for "dense residential" in Bradford and for "medium density
J-2
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residential" in CCP. But, this extension could also induce development of
intermingled wetlands to the south of Old Town Road. In addition, the
associated development would diminish the backdrop to Old Harbor of some of
the Island's taller coastal shrub and moors. Sedimentation and other pollutants
associated with the increased land runoff from construction and denser settlement
would wash into the fragile wetlands and ponds, which have little flushing
action.
J-3
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APPENDIX K
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
222 Quaker Lane, West Warwick, Rhode Island 02893
November 12, 1974
Mr. Mark Possidento
Sanitary Engineer
US Environmental Protection Agency
Region I
J. F. Kennedy Building
Boston, Mass. 02203
Re: New Shoreham, Rhode Island
Impact Statement
Dear Mr. Possidento:
As requested, our Agency has completed a review of the "Preliminary
Engineering Survey and Report on Control of Water Pollution for the
Town of New Shoreham". This review has been separated into two
sections: The first being of erosion and sediment control during
construction and the second section dealing with an evaluation of the
soils of the land disposal and sludge disposal sites.
SECTION #7 - GEOLOGY:
The majority of the soils on New Shoreham are underlain either
by stratified sands and gravels or coarse textured glacial till.
This fact is going to make it important that provisions are made
to control erosion and sediments of this erosive soil material
during excavation and construction. There is also growing concern
that these permeable soils may lead to contamination of ground waters
because effluent may pass through them to rapidly to be adequately
filtered if ground waters are relatively close to the surface.
SECTION #11 - DESIGN OF SEWAGE SYSTEM:
Because many of the soils found on the Island are erosive and the
topography of the "Area of Study Concentration" is steep and
undulating, it is our opinion that a plan for the control of erosion
and sediment needs to be included in the design of the sewage
system. Such a plan should include provisions to reduce erosion
from excavation areas, stock-piled soil material, construction sites
and final revegetation after construction.
Probable practices that may be required in an erosion and sediment
control plan include: temporary and permanent seeding of critical
areas, sediment basins, diversions, interceptor dikes, mulching,
drainage, log or baled hay erosion checks, heavy use area protection
and tree planting.
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2.
11/12/74
Mr. Mark Possidento
Our Agency is willing to cooperate with the firm awarded the
design contract for this project to develop an erosion and
sediment control plan once this proposal has reached that stage.
SECTION #13 - SEWAGE TREATMENT PLANT SITE:
The last paragraph in this section discusses the "landscaping
of the plant site in a pleasing fashion". We would like to caution
that this landscape plan include only those plant materials that
are tolerant and adapted to "salt spray" such as: Japanese Black
Pine, Russian Olive, Tatarian Honeysuckle and Scotch Broom. We
would recommend Dr. Robert Wakefield, Professor - Plant and Soil
Science, College of Resource Development, University of Rhode Island,
in regards to salt tolerant plant materials.
SECTION #15 - COST ESTIMATES:
Cost estimates should be developed to include necessary expenditures
for erosion and sediment control measures.
The second part of this report deals with an evaluation of the soils of
the land disposal and sludge disposal sites. To complete this part of
the report we had our soil scientist update and re-map the soil survey of
those sites that you had indicated on the topo map. The results of the
soil survey is enclosed on the attached photo copies. The areas we were
asked to investigate are shaded in "red".
The following is a list of the soils found on these properties and a brief
description of them:
16A - - BRIDGEHAMPTON SILT LOAM: This is a deep silty soil on 0-3%
slopes underlain by stratified sands and gravels. Depth to bedrock
is generally greater than 10 feet and depth to seasonal high water
table is greater than 4 feet. Surface drainage is slow to rapid
depending on the slope and soil cover. Internal drainage and
permeability are moderate in the upper sequim. The lower sequim may
be water-logged in winter, early spring and after heavy rains
because of the strongly contrasting textures in the lower solum and
the substratum. The permeability range of this soil is between 0.6
and 2.0 inches per hour. The available water holding capacity of this
soil is 0.18 to 0.30 inches per inches of soil.
16B - - BRIDGEHAMPTON SILT LOAM: This is the same soil as 16A except
that the slopes will range from 3-8%.
K-2
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3.
11/12/74
Mr. Ma-k Possidento
27A HINCKLEY GRAVELLY SANDY LOAM: This is an excessively
drained sandy soil underlain by stratified sands and gravels
on 0-3% slopes. Depth to bedrock is generally greater than
10 feet and depth to seasonal high water table is greater than
4 feet. This soil has been developed from deep outwash deposits
of sand and gravel. The permeability range of this soil will be
something greater than 6.0 inches per hour and the available water
holding capacity of this soil is between 0.06 and 0.14 inches per inch
of soil.
27C - - HINCKLEY GRAVELLY SANDY LOAM: This is the same as 27A except
that the slopes will range from 3-15%.
27D - - HINCKLEY GRAVELLY SANDY LOAM: This is the same soil as 27A
except that the slopes will range from 15-25%.'
28C - - HINCKLEY-ENFIELD COMPLEX: The soils in this unit occur in
such an intricate and complex pattern that it is not practical to
separate them with the scale used. This complex includes both well
drained sandy and silty soils underlain by stratified sands and
gravels on slopes ranging from 0-15%. The permeability range of this
soil is between 0.60 and 6.0 inches per hour. The available water
holding capacity of this soil is between 0.06 and 0.30 inches per inch
of soil.
50A - - ENFIELD SILT LOAM: This is a well drained silty soil on 0-3%
slopes underlain by stratified sands and gravels. These soils are
on terraces and outwash plains formed by glacial melt waters. Depth to
bedrock is generally greater than 10 feet and depth to seasonal high
water table is greater than 4 feet. The upper 2 feet of this soil
has a permeability range from 0.60 to 2.0 inches per hour. The
permeability range in the substratum will be greater than 6.0 inches
per hour. The available water holding capacity in the upper 2 feet
will be between 0.16 and 0.30 inches per inch, below 2 feet it will
be between 0.01 and 0.08 inches per inch.
51B - - WINDSOR LOAMY SAND: This is an excessively drained sandy soil
on 3-8% slopes underlain by sands. Depth to bedrock is generally
greater than 10 feet and depth to seasonal high water table is greater
than 4 feet. The permeability of this soil will be something greater
than 6.0 inches per hour. The available water holding capacity of this
soil is between 0.01 and 0.12 inches per inch of soil.
K-3
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4.
11/12/74
Mr. Mark Possidento
53 - - RAYNHAM SILT LOAM: This is a poorly drained silty soil on
slopes of 0-3% underlain by stratified sands and gravels. Depth
to bedrock is generally greater than 10 feet and depth to seasonal
high water table is commonly between 0.5 and 1.5 feet of the surface.
Internal drainage is slow because of the high water table that occurs
in the winter and spring. The permeability of this soil will range
from 0.60 to 2.0 when the water table is down and the available
water holding capacity of this soil is between 0.17 and 0.30 inches
per inch of soil. The high water table condition of this soil
restricts its uses.
54 - - BELGRADE SILT LOAM: This is a moderately well drained deep
silty soil on 0-3% slopes underlain with stratified sands and gravels.
Depth to bedrock in this soil is generally greater than 10 feet and
the water table is usually within 2 feet of the surface from late fall
to early spring. During the summer and early fall the water table
recedes to below 4 feet. The permeability range of this soil is
between 0.60 and 2.0 inches per hour when not being restricted by the
high water table. The available water holding capacity of this
soil ranges between 0.17 and 0.24 inches per inch of soil.
61 - - TISBURY SILT LOAM: This is a moderately well drained soil on
0-3% slopes underlain with stratified sands and gravels. Depth to
bedrock in this soil is generally greater than 10 feet and the water
table is usually within 2 feet of the surface from late fall to early
spring. During the summer and early fall the water table recedes to
below 4 feet. The permeability range of this soil in the upper two
feet is between 0.60 and 2.0 inches per hour; when not restricted by
high water tables, the substratum in this soil will have a permeability
rate greater than 6 inches per hour. The available water holding
capacity of this soil ranges between 0.01 and 0.30 inches per inch of
soil.
68B - - BROADBROOK SILT LOAM: This is a well drained soil on 3-8%
slopes underlain by glacial till. In Rhode Island these soils have
an impervious fragipan at a depth of 30 inches or more. Depth to
bedrock in this soil is generally greater than 10 feet and depth to
seasonal high water table is greater than 4 feet. The permeability
range in the upper 3 feet of this soil will be between 0.60 to 2.0 inches
per hour; below this depth the fragipan will restrict to permeability
to less than 0.20 inches per hour. The available water holding capacity
of the upper 3 feet of this soil is between 0.15 to 0.30 inches per
inch; below 3 feet the range will be between 0.08 to 0.16 inches per
inch.
K-it
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5.
11/12/74
Mr. Mark Possidento
117B - - AGAWAM FINE SANDY LOAM: This is a deep well drained
soil on 3-8% slopes underlain by coarse textured outwash materials.
Depth to bedrock in this soil is generally greater than 10 feet and
depth to seasonal high water table is generally greater than 4 feet.
The permeability range in this soil will be between 2.0 to greater than
6.0 inches per hour. The available water holding capacity of this
soil in the upper 2 feet will range from 0.11 to 0.25 inches per
inch, below 2 feet the range will be from 0.01 to 0.09 inches per
inch.
The above brief descriptions of the soils found on the lands tentatively
proposed as possible land disposal sites (irrigation of liquid effluent)
and sludge disposal sites leads to the conclusion that the sites picked are
generally well suited for the intended uses. The exception to this general
statement would be Raynham, Belgrade and Tisbury Silt Loam which have a
high seasonal water table condition that may restrict their use during periods
of the year.
Both the existing sludge disposal site and the proposed sludge disposal
site are suited for land fill and disposal areas because they are well
drained, deep coarse textured soils that we estimate from topographic
maps that the water table will be between 30 to 40 feet deep.
Another important consideration is that the Towns' wells are located on
the property indicated just north of Sands Pond as a possible land
disposal area. Detailed investigation would be recommended to determine
that the ground water supply would not become contaminated.
In this review we have attempted to point out some items we feel need
further consideration in the areas in which our Agency has expertise. It
is hoped that our suggestions and recommendations will be useful in
strengthening this already fine "Preliminary Engineering Survey and Report".
If we can be of further assistance please contact our office.
Austin
Austin L. Patrick, Jr
State Conservationist
Attachments
K-5
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APPENDIX L
STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS
HISTORICAL PRESERVATION COMMISSION
John Brown House
52 Power Street
Providence, R.I. 02906
(401) 277-2678
September 16, 197^
Mr. John McGlennon, Regional Administrator
Environmental Protection Agency
John F. Kennedy Federal Bldg.
Boston, Mass. 02203
Dear Mr. McGlennon:
At the request of your office, we have reviewed the plans for
the proposed sewage treatment facility at Block Island. We under-
stand that considerable discussion of alternative sites has already
taken place.
The fact that the location chosen falls within the National
Register Historic District is unfortunate. However, preliminary
survey by our Commission indicates that several other districts
could be identified as eligible for the Register, and possibly the
whole island could be considered as a district, as has been done at
Nantucket. This means that any location could possibly affect historic
sites, and therefore an attempt to minimize impact should be the goal.
In its presently planned location, we are concerned with the
sewage facility's proximity to the Shamrock Inn, recently purchased
and slated for restoration. We feel it is essential that improvements
be made in the design of the fence surrounding the aerating tanks,
and provision made for plantings which could provide a more effective
screen between the facility, the hotel, and the nearby church.
We feel that the construction of the sewage treatment facility
at Block Island is in the best interests of historic preservation
there. We would be happy to advise^lhe design of a suitable fence
and landscape planning which could effectively accomplish the screening
which we propose. We certainly want to review final plans for improve-
ments in this area, but see no reason why this could not be done as
construction progresses.
S i ncerely
Richard Alan Dow
Executive Director
RAD/dn
cc Mr. Hfthnrt 5. Wliihnnn
L-l
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APPENDIX M - .STATE OF RHODE ISLAND MINIMUM STANDARDS RELATING TO LOCATION,
DESIGN, CONSTRUCTION, AND MAINTENANCE OF INDIVIDUAL SEWAGE
DISPOSAL SYSTEMS
(see following pages)
M-l
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R23-1-SD
RULES AND REGULATIONS ESTABLISHING MINIMUM STANDARDS
RELATING TO LOCATION, DESIGN, CONSTRUCTION AND
MAINTENANCE OF INDIVIDUAL SEWAGE DISPOSAL SYSTEMS
STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS
DEPARTMENT OF HEALTH
AUTHORITY: Chapter 23-1-17 and 23-1-18 (S)
of the General Lavs of 1956, as
amended
NEW AMENDMENTS EFFECTIVE 30 AUGUST 1974
AS AMENDED JULY 1973
M-2
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TABLE OF CONTENTS
Page
PART A - DEFINITION OF TERMS
R23-I-SD 1.00 Definitions
SD 1.01 through SD 1.28 !-3
PART B-1 APPLICATION AND -CONDIT 1 QMS FOR APPROVAL
R23-I-SD 2.00 Disposal of Sewage
SD 2.01 Approval of an Individual Sewage
Disposal System
SD 2.02 Application for Approval of a New
Sewage Disposal System
SD 2.03 Repair and Alteration
SD 2.04 Use
SD 2.05 Certification of Conformance ......
SD 2.06 Inspection
SB 2.07 Discharge to a Watercourse .
SD 2.08 Disciiarge on or to the Surface of Ground
SD 2.09 Dwelling or Building
SD 2.10 Connection to a Public Sanitary Sewer . .
SD 2.I I Maintenance
SD 2.13 Prof
JJse of Acid in Septic Tanks
PART B-2 CONDITIONS FOR APPROVAL IN RELATION TO WELLS
SD 2.14 Construction in Areas Served by
Pri vate We I Is
SD 2.15 Location of Wells
SD 2.16 Protection of Wells on Adjoining property
PART C. STANDARDS FOR CONSTRUCTION AND DESIGN
R23-I-SD 3.00 Standards of Flow and Minimum Distances
SD 3.01 Determination of Sewage Flow 7-8
SD 3.02 Separate Systems 9
SD 3.03 Type of System Required 9
SD 3.04 Surface Water Drainage 9
SD 3.05 Location 9-10
SD 3.06 Subsurface Drains 10
SD 3.07 Subsurface Drain Discharges iU
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R23-I-SD 4.00 Building Sewers
SD 4.01 Size
SD 4.02 Material . . .
SD 4.03 Joints . . . .
SD 4.04 Slope or Grade
SD 4.05 Alignment . .
SD 4.06 Manholes . . .
SD 4.07 Ventilation .
SD 4.08 Grease Traps .
R23-I-SD 5.00 Septic Tanks
SD 5.01 Capacity . 12
SD 5.02 Length ........ 12
SD 5.03 Diameter of Circular Tanks ......... 12
SD 5.04 Depth ¦ 12
SD 5.05 Multiple Compartments 12
SD 5.06 Construction 12
SD 5.07 Inlet and Outlet 12
SD 5.08 Inlet and Outlet Elevations 13
SD 5.09 Foundation 13
SD 5.10 Materials 13
SD 5.11 Access Manholes 13
SD 5.12 Accessibility 13
SD 5.13 Backf i II . . 13
SD 5.14 Holding tanks 13
SD 5.15 Pumping to Septic Tanks Prohibited ..... 13
R23-I-SD 6.00 Dosing Tank
SD 6.01 General 14
SD 6.02 Capacity • 14
SD 6.03 Construction 14
SD 6.04 Foundation 14
SD-6.05 Ventilation 14
SD 6.06 Inlet 14
SD 6.07 Access 14
R23-I-SD 7.00 Distribution Box
SD 7.01 General 15
SD 7.02 Iniet 15
SD 7.03 Outlet Elevations 15
SD 7.04 Distribution Pipes 1 15
SD 7.05 Construction 15
SD 7.06 Number of Outlets 15
SD 7.07 Foundation 15
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R23-I-SD 8.00 Sewage Seepage Systems - General
SO 8.01 Minimum Leaching Area 16
SD 8.02 Ground Water 16
SD 8.03 Impervious Material 16
SD 8.04 Excavation 16
SD.8.05 Location 16
SD 8.06 Minimum Leaching Area for an
Individual Dwelling ... 16-17
SD 8.07 Minimum Leaching Area for Places Other
Than Individual Dwellings 17
R23-I-SD 9.00 Specifications for Disposal Trenches and Disposal Beds
SD 9.01 Effective Leaching Area 18
SD 9.02 Construction of Disposal Trenches
and Beds . 18
SD 9.03 Distribution Lines 18
SD 9.04 Stone 19
SD 9.05 Construction In Fill 19
SD 9.06 Backfi II 19
SD 9.07 Parking Area Location 19
SD 9.08 Finished Grade 19
R23-I-SD 10.00 Seepage Pits
SD 10.01 Acceptability 20
SD 10.02 Leaching Area 20
SD 10.03 Spacing 20
SD 10.04 Access 20
SD 10.05 Construction 20
R23-I-SD 11.00 Cesspools
SD 11.01 Acceptability 21
SD 11.02 Leaching Area 21
SD 11.03 Construction 21
SD 11.04 Access 21
R23-I-SD 12.00 Privies, Chemical Toilets and Incinerator Type
SD 12.01 Acceptability 22
SD 12.02 Location 22
SD 12.03 Construction 22
SD 12.04 Maintenance 22
PART D. SOIL STUDIES AND PERCOLATION TESTING
R23-I-SD 13.00 Subsoi I Exploration
SD 13.01 General 23
SD 13.02 Site Suitability . 23
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SD 13.03 Percolation Test 23
SD 13.04 Exploration holes 23
SD 13.05 Persons Qualified to Test 23-24
SD 13.06 Recording Results 24
R23-I-SD 14.00 Percolation Test Procedure
SD 14.01 and 14.02 25
R23-I-SD 15.00 Procedures For Ground Water Table Elevation Determinations
SD 15.01 and 15.02 26
PART E. SUBDIVISIONS
SD 16.01 Subdivisions - Individual Sewage
Disposal Systems 27
SD 16.02 Topographic Map 27
SD 16.03 Location Map 27
SD 16.04 Percolation Tests 27
SD 16.05 Ground Water Table 28
SD 16.06 Certification 28
SD 16.07 28
APPENDIX
Minimum Design Criteria and Typical LayouT Illustrations
i. Lot Layout 29
i I. Septic Tank 30
III. Dos i rig Tank 31
IV. Distribution Box 32
V. Trench Type Field 33
V I. Bed Type Field 34
VII. Soil Percolation Hole 35
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I
1 STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS
2 DEPARTMENT OF HEALTH
3 RULES AND REGULATIONS ESTABLISHING MINIMUM STANDARDS
4 RELATING TO LOCATION, DESIGN, CONSTRUCTION, AND
5 MAINTENANCE OF INDIVIDUAL SEWAGE DISPOSAL SYSTEMS
6 PART A. DEFINITION OF TERMS
7 R23-1-SP 1.00 Definitions
8 As used in these rules and regulations, the following terms
9 shall, where the context permits, be construed as follows:
10 SD 1.01 Alteration - Alteration shall be held to mean any change in
11 size or type of system or installation of a replacement system.
12 SD 1.02 Bui Idlnq Sewer - The buiIding sewer shalI be held to mean
13 the pipe which begins three feet outside the building wall and extends to
14 a public sewer, septic tank, or other place of sewage disposal.
15 SD 1.03 Cesspool - The term cesspool shall be held to mean a covered
16 pit with open-jointed sidewall lining and an earth bottom into which raw
17 Sewage Is discharged.
18 SD 1.04 Pi rector - The term director shalI mean the director of
19 health of the state of Rhode Island or his duly authorized agent.
20 SD 1.05 Disposal Bed - A disposal bed for sewage shall be held to
21 mean a shallow excavation in the ground, backfilled with stone in which
22 open-jointed or perforated distribution lines are laid-and over which a
23 cover of earth is placed.
24 SD 1.06 Disposal Trench - A disposal trench shall be held to mean
25 a shalfow ditch with vertical sides, filled with stone, in which a single
26 distribution line is laid and over which a cover of earth is placed.
27 SD 1.07 Pi stri but ion Box - A distribution box shall be held to mean
28 a water-tight structure which receives septic tank effluent and distributes
29 It In substantially equal portions to two or more pipe lines leading to
30 some type of seepage system.
31 SD 1.08 Distribution Line - A distribution Iine shal I be held to
32 mean an open-jointed or perforated pipe used to disperse septic tank
33 effluent.
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1 SO 1.09 Dosing Tank - A dosing tank shall be held to mean a
2 watertight structure placed between a settling or septic tank and a
3 distribution box and equipped with one or more siphons or pumps designed
4 to discharge sewage intermittently into a seepage system.
*5 SO 1.10 Impervious - For the purposes of these regulations, any soil
6 wlth^a percolation rate in excess of 40 minutes per Inch, or any ledge or
7 shale are considered impervious and unsuitable for individual spwage
8 disposal systems.
9 SD 1.11 Individual Sewage Disposal System - An individual sewage
10 disposal system shall be held to mean one installed to provide sanitary
11 sewage disposal by leaching into the ground where no public sewer system
12 Is available or accessible.
13 SD 1.12 Invert - The Invert shall be held to mean the lowest portion
14 of the Interior of a pipe or fitting placed horizontally.
15 SD 1.13 Leaching Area - The leaching area, when applied to a disposal
16 trench or disposal bed shall be held to mean the bottom area of the trench
17 or bed; when applied to a seepage pit, the combined bottom area and sidewall
18 area below the inlet pipe; when applied to a cesspool, the sidewall area
19 below the Inlet pipe, only.
20 SD 1.14 Maximum Ground Water Table Elevation - The maximum ground
21 water table elevation shall be held to mean that observed when the ground
22 water is at its highest level during the year or the highest level observed
23 In past years when such Inforamtion is available.
24 SD 1.15 Owner - Owner shall be held to mean any person .who alone, or
25 Jointly, or severally with others (a) has a legal title to any premises, or
26 (b) has control of any premises as agent, executor, executrix, administrator,
27 administratrix, trustee, lessee, or guardian of the estate of a holder of a
28 legal title. Each such person is bound to comply with the provisions of
29 these rules and regulations.
30 SD 1.16 Person - The term person shall Include apy individual, group
31 of individuals, firm, corporation, association, partnership or private
32 entity, Including a district, county, city, town, or other governmental unit
33 or agent thereof, and in the case of a corporation, any individual having
34 active and general supervision of the properties of such corporation.
35 SD 1.17 Privy - A privy shall be held to mean a structure used for a
36 toilet lacking the flushing aid of water. It consists of a shelter built
37 above a pit or vault in the ground into which the waste matter falls.
38 SD 1.18 Repalr - Repair shalI be held to mean replacement of septic
39 tank, distribution box, leach field, or pipes connecting same with no
40 change in type of material, location, or area of system.
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SO 1.19 Sanitary Sewage - Sanitary sewage shall be held to mean any
human or animal excrementaI liquid or substance, any putrescible animator
vegetable matter., garbage and filth, including the discharge of water
closets, laundry tubs, washing machines, sinks, dishwashers, and the contents
of septic tanks, cesspools, or privies.
SD 1.20 Seepage Pit - A seepage pit shall be held to mean a covered
pit with open jointed sidewalls and bottom, from which septic tank effluent
Is leached into the soil.
SD 1.21 Septic Tank - A septic tank shall be held to mean a watei—tight
receptacle which receives the discharge of sewage from a building sewer,
and Is designed and constructed to permit the deposition of settled solids,
the digestion of the matter deposited, and the discharge of the liquid portion
into a leaching system.
SD 1.22 Siphon - A siphon shall be held to mean a hydraulic device
designed to discharge the contents of a dosing tank rapidly when a predeter-
mined level is reached.
SD 1.23 Slope or Grade - Slope or grade shal I be held to mean the rate
of fall or drop of a pipe line or of the ground surface in reference to a
horizontal plane. It is commonly expressed as fall or drop in inches per 100
feet, inches per foot, or feet per 100 feet.
SD 1.24 SubdIvidinq - Subdividing for the purposes of these regulations
shall be held to mean the division of a lot, tract or parcel of land into
three (3) or more lots, sites or other division of land for the purpose,
whether immediate or future, of building development.
SD 1.25 Subsurface Drains - A subsurface drain shall be held to mean
a deep trench intended to lower the water table of an area where an
individual sewage disposal system is to be located. It shall consist of not
less than 6 inches of washed stone i inch to 2 inches in diameter, over which
is laid a perforated or open jointed pipe. The stone shall extend above the
pipe to within 2 feet of the ground surface, and then be covered with at
least a 2 inch layer of washed pea stone or a 2 inch layer of straw or hay,
or by a layer of untreated building paper. The size of the pipe used shall
be at least 4 inches in diameter when less than 3 lots are being drained;
otherwise the pipe must be at least 8 inches in diameter.
SDI.26 Test Pit - A test pit shaII be he Id to mean an open pit dug to
permit an examination of the soil profile, and a determination of the elevation
of the ground water table.
SD 1.27 Watercourse - The term watercourse shall be held to mean any
tidewater, or any river, stream, brook, pond, lake, swamp, or any other
standing or flowing body of water.
SD 1.28 Wei I - A we I I shall be held to mean an opening into the ground
or bedrock located safely in respect to sources of pollution, encased,
covered and equipped in a sanitary manner, and yielding supply of potable
water safe for human consumption sufficient to meet the needs of the
property on which it is located and ordinarily used as a drinking water supply.
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PART B-1 APPLICATION AND CONDITIONS FOR APPROVAL
2 R23-1-SD 2.00 Disposal of Sewace
3 SD 2.01 Approval of an Individual Sewage Disposal System - No person
4 shall install, construct, alter, or repair or cause to be installed,
5 constructed, altered, or repaired any individual sewage disposal system,
6 nor shall he begin construction of any improvement to his property from
7 which sewage will have to be disposed of by means of an individual sewage
8 disposal system until he has obtained the written approval of the director
9 of the plans and specifications for such work. Repairs or alterations
10 shall, insofar as possible, comply in every respect with the standards set
11 forth in these regulations.
12 Note: A municipality may only grant a building permit according to
13 the provisions of Chapter 23-27-6 of the General Laus of the State of
14 Rhode Island as amended.
15 SD 2.02 Application for Approval of a New Sewage Disposal System -
16 (a) The application for approval of plans and specifications for a new
17 sewage disposal system shall be made on forms provided by the director.
18 (b) It shall be accompanied by basic design data, and a plan, to scale,
19 of the property or pertinent portion thereof showing the size and
20 location of the sewage disposal system, also monholes, cleanout plugs,
21 essential invert elevations, and a fixed bench mark that can be readily
22 referenced and that will not be disturbed during construction.
23 (c) Other information to be provided includes: I. present, and-proposed
24 finished grades. 2. the location of test pits. 3. the results of
25 percolation tests. 4. a description of the type of soil. 5. the
26 maximum "elevation of the ground water table in the location of the
27 proposed seepage system, and 6. size and location of building(s).
28 (d) The location of any drinking water line within 25 feet, and any well,
29 watercourse or drain within 200 feet of the proposed disposal system
30 must be shown.
31 (e) Approval granted an applicant shall expire two years from the date of
32 its issuance i fOfrCtryfc^ion^had WW>egu* iff*- itMr /¦»' t maY be
33 renewed if the A' I
34 requi red-design criteria shall be included.
35 (f) The location of existing individual sewage disposal systems within 100
36 feet of any well to be installed on subject property must also be shown.
37 (g) nothing in the foregoing shall prevent the director from requiring cony
38 additional information he deems necessary to carry out his obligations
39 for approving an application.
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SD 2.03 Repair and Alteration - Application must be made for repair
or alteration of a system. Requirements for repair or alteration under
these regulations may be waived at the discretion of the director.
SD 2.04 Use - The use of an individual sewage disposal system shall
conform to the terms of the approval; its designed capacity must not be
exceeded.
SD 2.05 Certification of Conformance - A newly constructed, altered
or rebuilt individual sewage disposal system, shall not be covered with
earth until the director shall have inspected it and certified in writing
that it conforms with the terms ofthe approval granted under the provisions
of these regulations. Said system shall be covered within 48 hours after
Inspection and approval. No dwellings, buildings, or additions thereto, to
be served by such a system, shall be sold or occupied until the entire system
Is completed, including'the covering of the system and the necessary grading
to divert surface water from the area of the leaching field.
SD 2.06 Inspection - The director may inspect the installation of an
Individual sewage disposal system at any stage of its construction, and may
require its modification if unanticipated conditions are disclosed which make
It necessary. If changes from the approved plans and specifications are
found necessary, revised plans must be submitted for review and approval.
SD 2.07 Discharge to a Watercourse - No person shall discharge or
permit the entrance of sanitary sewage, treated or untreated,/into any
watercourse, nor shall he discharge or permit the entrance of such sewage
Into any open or covered drain tributary to such waters, without having
obtained an order from the director approving the same.
SD 2.08 Discharge on or to the Surface of Ground - No person shall
discharge or permit the overflow or spillage of any sanitary sewage on or to
the surface of the ground, provided, however, this shall not interfere with
the spreading of animal manure on the surface of the ground in an amount not
In excess of that essential to meet agricultural requirements, and that will
not cause water pollution.
SD 2.09 Dwe11inq or BuiIdinq - Each dwe11ing or other buiIding having
plumbing fixtures, or on which sanitary sewage is produced, in a location where
no public sanitary sewage system is available or accessible, shall be provided
with an individual sewage disposal system of type and design approved by
the director.
SD 2.10 Connection to a Public Sanitary Sewer - An individual sewage
disposal system shall not be approved for use on any premises if a public
sanitary sewer is accessible to such premises, and permission to enter it can
be obtained from the authority having jurisdiction. When problems are encoun-
tered in the operation of an individual sewage disposal system and public sewage
service is accessible and available to the property on which it is located
and where permission to enter such a sewer can be obtained from the authority
having jurisdiction over it, the director may require the owner or occupant of
an existing building or buildings to be connected thereto within a period of
time as specified by him.
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SD 2.11 Maintenance - All building sewers and individual sewage
disposal systems shall be maintained in good repair by the owner. The
director may order the owner to clean or repair such sewers or systems within
a reasonable time if he finds them to be in need of the same.
SD 2.12 Septic Tank Cleaners - No person shall engage in the removal or
transportation of the contents of privies, cesspools, or septic tanks without
first having obtained the approval of the director for the site, and the means
of disposal of such contents that he proposes to use.
Such approval may be withdrawn by the director if he finds, that with
use, the site or means of disposal has become insanitary or offensive.
Note: See Chapter 23-49 Rhode Island General Laus 1956 as amended
Entitled: Cesspool, and Sanitary Tank Cleaners
SD 2.13 Prohibition^in-Certain Filled Areas - No sewage disposal
system may be constructed^)^-pf i t^\ ] "Sliced PP'A sw^"Pj marsh, bog, or
other area where water is at" weQJrlcML/ifo(Tljg wen' I I
is placed on an Impervious formatiopVil ¦t'llfltiV I 5
Use cf Acid in Sepcic Tanks
PART B-2 CONDITIONS FOR APPROVAL IN RELATION TO WELLS
sb 2.14 Construction in Areas Served by Private Wells - Before an
approval can be granted to construct a building being served by a private
well, sufficient additional area must be available for the replacement
of the disposal field, in case of failure. This area must be on the property
of the individual seeking approval and meet all the minimum distance
requirements set forth in these regulations.
SD 2.15 Locat i on of We I Is - No person shal I locate or cause to be
located, any wel*l within 100 feet of an individual sewage disposal leaching
area. The director may grant an exception for the replacement of a well on
property with an existing, owner occupied, private single family dwelling
when no other water supply is available.
SD 2.16 Protection of Wells on Adjoining Property - An applicatlon
for the installation of, a sewage disposal system shall not be denied on
the grounds that the system cannot meet the required minimum distance from
a well if the well is on adjoining property and a public water supply is
readily available to such property.
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PART C. STANDARDS FOR CONSTRUCTION AND DESIGN
R23-1-SD 3.00 Standards of Flow and Minimum Distances
SD 3.01 Determination of Sewage Flow - A sewage disposal system
must be designed to dispose of the estimated maximum days' flow from
the building it serves. The maximum days' flow .is estimated by'muItipIying
flow (according to the following table) by the maximum design capacity of
the building. Consideration will be given to sewage flow estimates derived
from actual records of water consumption kept at comparable establishments.
MINIMUM DESIGN REQUIREMENTS FOR SEWAGE FLOW
TYPE OF ESTABLISHMENT GALLONS PER PERSON PER DAY
Single Residence (2 persons per bedroom) 75
Multiple family dwelling units (2 persons per bedroom) 100
Roomi ng House 40
Hotel or boarding house 50
Nursing home 100
Rest home 75
School without cafeteria, gymnasium, or showers 10
School with caieterla, but no gymnasium or showers 15
School with cafeteria, gymnasium, and showers 20
Boarding school or college 80
Mote I 40
Motel - efficiency units 50
Pub I Ic'institution other than a hospital 100
Public picnic park-toilet wastes only 5
Public park with bathhouse, showers and flush toilets 15
Swimming pool or other bathing place 15
Camp (day) - toilets (add 3 gallons per capita per
meal if any served) 15
Camp (overnight) 35
Restaurant (per table seat or counter seat) 70
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TYPE OF ESTABLISHMENT GALLONS PER PERSON PER DAY
Restaurant, toilet and kitchen wastes (per patron) 10
Restaurant, throughway service area (per table seat or
counter seat) 350
Factory or industrial plant without cafeteria - (per person) 15
Factory or industrial plant with cafeteria - (per person) 20
Office BuiIding 15
Drive-in-theater - (per stall) 5
Theater - (per person) 3
Auditorium or hall - (per person) 3
Gymnasium - (per spectator) 3
Gymnasium - (per participant) 15
Service, station (minimum) 500
CocktaiI lounge, bar (per seat) 20
Bowling alley - (per alley) 200
Hospital - (per bed) 200
Country c"lub - (per person at maximum usage)
(Exclusive of Food Service and Bar) 25
Fellowship Hall (per seat) 6
Barber shop (per chair) 100
Beauty Parlor (per booth) 200
Dental^Office (minimum 3 persons per chair) 500
Mobile Home (exceeding 8 feet wide and 32 feet long) 75
(using individual toilets) (minimum 450)
Trailers (not exceeding 8 feet wide and 32 feet long) 200
(and recreational vehicles using individual toilets) (per day per space)
Central Service Building (Toilet-Shower-Lavatories) 140
Serving recreational vehicles/trailers (per day per spaca)
Dumping Station (for recreational vehicle/trailer park 50
without individual water and sewer connections) (per day per space)
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1 SD 3.02 Separate Systems - Where separate treatment systems are to
2 be Installed, the following proportions should be used unless there is
3 definite data available as to the exact distribution of flow. Toilet and
4 bath facilities - 60% of total flow, kitchen wastes - 40? of total flow,
5 laundry wastes - 40? of total flow.
"N
6 SD 3.03 Type of System Required - Except as provided in Sections I I
7 and 12, an individual sewage disposal system shall consist of a' septic
8 tank followed by a subsurface seepage system or other sewage disposal method
9 approved by the director.
10 SD 3.04 Surface Water Drainage - Provision shall be made to prevent the
11 flow of surface water from the surrounding area onto the area of the seepage
12 system.
13 SD 3.05 Location - The horizontal distances between the parts of an
14 Individual sewage disposal system and Trie items listed in the following table
15 shall not be less than those shown.
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MINIMUM
DISTANCES
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18
19
20
Septic
Tank
D i sposa1
Trench or
Disposa1
Bed
Seepage
Pit or
Cesspool
Bu i1di ng
Sewer
Pri vy
21
(ft)
(ft)
(ft)
(ft)
(ft)
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23
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Wei 1 or suction
1i ne (f)
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100
(c)
50 (a)
50
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25
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Water supply
1ine (pressure)
10 (b)
25 (b)
25 (b)
10 (b)
25 (b)
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Property line
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20
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27
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Dwel1ing
5
15 (d)
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30
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Surface drinking
water supplies or
tributaries in-
cluding open and
subsurface drains,
thereto
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100
150
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50
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Watercourses
25
50
50
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35
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Subsurface drains
25
25
25
25
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37
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Edge of any bank 10 (e)
sloping tc a level
lower than the invert
of the distribution line
25 (e)
25 (e)
10 (e)
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(a) Distance may be reduced if extra heavy cast Iron pipe or equal
with tight joints is installed.
(b) Disposal facilities shall be installed as far away as possible
from water supply lines. Where sewer lines must cross water supply lines,
they should be constructed of durable, corrosion-resistant material with
water-tight joints. Whenever possible, however, sewer lines should be
laid below water supply lines at crossings.
(c) Installation of a seepage pit or cesspool is unacceptable If
drinking water is obtained from wells within 200 feet.
(d) Distance may be reduced to 8 feet with no cellar.
(e) Where fill is required and where it is necessary to fill beyond
the boundary of the subject property to meet the requirements of these
regulations, no approval will be granted unless the adjoining property
owner(s) have given a permanent legal release (easement, etc.) granting
such right to the owner of the applicant property. A copy of| such right
of access and use shall be attached to the application.
(f) See Section SD2.1C
SD 3.06 Subsurface Drains - The effectiveness of subsurface drains
used to lower the water table to meet the limitation.* of these regulations
must be demonstrated through one complete wet season, January I, through
April 30, before consideration can be given to an application for an
individual sewage disposal permit.
SD 3.07 Subsurface Psaifrjisfharcies - Subsurface drains which discharge
ground water to a watercojari'^l shsljj Siee^+ffe cffSfl'gWse requirements in
Section SD 3.05 pertainin^Wcj^wareroSlirs
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R23-1-SD 4.00 BUILDING SEWERS
SD 4.01 Size - The building sewer shall be designed with a capacity,
when running full, of not less than twice the peak rate of flow from the
connected fixtures. In no case shall the building sewer be less than four
inches in diameter.
SD 4.02 Material - The building sewer shall be constructed of cast
Iron, vitrified ti le, concrete, asbestos cement, or other material acceptable
to the director, provided, however, cast iron or equal shall be used where
the building sewer may be subjected to heavy loads.
SD 4.03 Joi nts - All pi pe joi nts for the buiIdi ng sewer shaI I be made
water-tight and protected against damage by roots. Poured type joints
shall be properly wiped on the Inside to prevent obstruction of flow.
SD 4.04 Slope or Grade- The grade of the building sewer should be
at least I?, I foot fall per 100 feet, or 1/8 inch per foot.
SD 4.05 Alignment - The bui Iding sewer should be laid as nearly as
possible in a straight line. Horizontal bends, where unavoidable, shall
not be greated than 45 degrees. Any greater bend requires a manhole at the
change in alignment.
SD 4.06 Manholes - A manhole with a removable cover of concrete, cast
Iron, or other durable material shall be provided at the junction of two or
more pipes, at all sharp changes in direction or grade of pipes, and at
intervals not greater than 300 feet.
SD 4.07 VentiI at ion - The bui iding sewer shall be vented through the
stack or main vent of the building it serves. No trap shall be installed
in the building sewer.
SD 4.08 Grease Traps - A grease trap may be required at premises from
which large quantities of grease can be expected to be discharged and where
there is reasonable assurance that it will be cleaned frequently. A separate
line shall be installed to serve the fixture from which the grease is discharged
and the grease trap inserted in this line. The trap shall be so located
and constructed that the temperature of the sewage will be reduced to promote
congealing or separation of grease. It shall be located and constructed in a
manner'that will permit easy access for cleaning.
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R23-1-SD 5.00 SEPTIC TANKS
SD 5.01 Capacity - For Individual dwellings, the required capacity
of a septic tank, below the flow line, shall be at least that shown in
the following table:
Number of bedrooms
Capacity below flow line in gallons
2
750
3
900
4 (I)
I ,000
(I) For each additional bedroom, add 250 gallons.
For other than individual dwellings, the
capacity of the septic tank for sewage flows
up to 500 gal ions per day shall be at least
750 gallons-. For flows between 500 and 1,500
gallons per day, the capacity of the tank shall
be equal to at least one and one-half of a days'
flow. For flows greater than 1,500 gallons per
day, the capacity of the tank shall equal 1,125
gallons plus 75it of the daily flow.
SD 5.02 Length - In rectangular tanks, the distance between the inlet
and outlet should be at least equal to the liquid depti¦ of the tank and at
least one and one-half times the width.
SD 5.03 Diameter of Circular Tanks - Circular tanks shall have a
diameter of. at least 52 inches.
SD 5.04,Depth - The depth of the tank below the flow line should be
not less than 4 feet or more than 8 feet.
SD 5.05 Multiple Compartments - Multiple compartment tanks, including
two individual septic Tanks placed in series, will be approved, provided
the totai capacity (below the flow line) is not less than 5,000 gallons and
the capacity of the first compartment or tank is at least one-half of the
capacity required.
SD 5.06 Construction - Septic tanks shall be water-tight. They Shall
be constructed of sound and durable materials not subject to excessive
corrosion, decay, or frost damage, or to cracking or buckling due to settlement
or soil pressures. Tanks and covers shall be constructed so as to withstand
any load that may be expected to be placed upon them.
SD 5.07 Inlet and Outlet - The tops of inlet and outlet tees or the tops
of the baffies shall extend a minimum of 6 inches above the flow line. Tops
of the inlet and outlet tees or baffles shall be left open to provide ventilation.
There shall be an air space of at least 3 inches between the tops of the tees or
baffles and the top of the tank. The outlet tee or baffle should extend downward
one-third of the depth below the flow line. The inlet tee or baffle should
extend downward at least I foot below the flow line but not below the outlet
tee or baffle. Multiple outlets shall be provided on tanks wider than 7 feet.
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SD 5.08 Inlet and Outlet Elevations - The invert elevation of the
outlet shall be at least 2 inches below the invert elevation of the inlet.
SD 5.09 Foundation - The septic tank shall be installed on a level
base that will not settle.
SD 5.10 Materials - Septic tanks may be constructed of poured in
place reinforced concrete, pre-cast reinforced concrete, coated'steel,
or other material approved by the director. Steel tanks designed in
accordance with the provisions of these regulations shall meet Commercial
Standard 177 of the U. S. Department of Commerce.
SD 5.11 Access Manholes - At least one manhole with a removable
cover of concrete, iron, or other durable material shall be provided
each septic tank compartment. Inlets and outlets shall be made accessible
'for cleaning by placing manholes or clean-out plugs over the tees or
baffles. Manholes on tanks of under 2,000 gallons capacity should be
brought up to within 12 inches of finished grade; and properly marked for
location. Manholes on tanks of 2,000 gallons capacity or over shall be
brought up to finished grade.
SD 5.12 AccessibiIity - Septic tanks shall be so located on the lot
as to be accessible for servicing and cleaning. They should be placed
between^ the building and the street wherever practicable, to facilitate
connection to a public sanitary sewer when it becomes available.
SD 5.13 Backfi I I - Backfill shall be placed around the septic tank
In such a manner as to avoid damage to it. All backfill placed around
the septic tank shall be free of large stones, stumps, waste construction
material and rubbish.
SD 5.14 Holding tanks - Holding tanks are not acceptable as a means
of an Individual Sewage Disposal System for new installations.
SD 5.15 Pumping to Septic Tanks Prohibited - Sewage shalI not be
pumped into septic tanks unless approved by the director.
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R23-I-SD 6.00 DOSING TANK
SD 6.01 General - A dosing tank equipped with a sip"hon or two
pumps shall be provided where the total length of the distribution
lines exceeds 500 feet. The dosing tank shall be provided with at least
two alternating siphons or two pumps delivering to separate fields or beds,
if the total length o.f the distribution lines exceeds 1,000 feet. When
pumps are installed, the pump discharge lines shall be inter-connected and
properly valved or gated so as to permit dosage to both fields or beds with
one pump when the other is being repaired. The pumps installed must be
capable of passing 2.5 inch diameter solids. System head curves must be
submitted for each installation.
SD 6.02 Capacity - Dosing tanks shall discharge a volume of sewage
which is between 60 and 75^ of the interior capacity of the distribution
lines of the disposal trenches to be dosed, and not more than the full
capacity of the distribution lines in the case of a disposal bed.
SD 6.03 Construction - Dosing tanks shall be water-tight. They
shall be constructed of sound, durable materials not subject to excessive
corrosion or decay and be able to withstand any load which may be placed
upon them.
SO 6.04 Foundation - Dosing tanks shalI be conrtructed on a level
base that will not settle.
SD 6.05 Ventilation - Dosing tanks and similar appurtenances shall
be adequately ventilated.
SD 6.06 Inlet - The invert elevation of the inlet pipe to the
dosing tank shall be located above the maximum water elevation in the dosing
tank, and at least one foot above the maximum elevation of the ground
water table.
SD 6.07 Access - Each dosing tank or compartment thereof shall be
provided with an access located so as to facilitate repair or adjustment
of the siphons or pumps.
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R23-I-SD 7.00 DISTRIBUTION BOX
SD 7.01 General - A distribution box shall be installed between
the septic tank and the seepage system.
SD 7.02 Inlet - The distribution box shall be provided with an
inlet tee or a suitable baffle. The invert of the inlet pipe shall be
not less than 2 inches above the invert of the outlet pipe.
SD 7.03 Outlet Elevations - The invert of all the outlet pipes
shall be a minimum of 4 inches above the floor of the distribution
box. All outlet inverts shall be at the same elevation.
SD 7.04 Distribution Pipes - All dlstri but ion pi pes for mi nimum
of 2 feet from the distribution box to the first section in the laterals
shall be level and unperforated and shall be laid with tight joints. Any
sections of such pipe laid with tight joints shall not be considered in
determining the leaching area.
SD 7.05 Construction - The distribution box shall be constructed
water-tight of concrete or other durable material; it shall be designed
to accommodate the necessary distribution lines.
St) 7.06 Number o' Outlets - If there is no dosing tank, there shall
be a separate outlet for each distribution line. Where a dosing tank or
pump chamber is installed, there should be either a separate outlet for
each distribution line, or a separate outlet of at least six (6) inches
In diameter for every two distribution lines. In all cases following a
dosing tank or pump chamber, the outlet shall be of sufficient size to
accept the sewage flow at the rate sewage is delivered to the distribution
box.
SD 7.07 Foundation - The distribution box shall be installed between
the septic tank and seepage system on a solid and level base that will
not settle.
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1 R23-I-SD 8.00 SEWAGE SEEPAGE SYSTEMS - GENERAL
2 SD 8.01 Minimum Leaching Area - The minimum leaching area of a disposal
3 ' system will be dictated by the number of bedrooms in the case of individual
4 dwellings, or the maximum daily sewage flow for places other than
5 individual dwellings, and the results of percolation tests performed in
6 accordance with Section SD 14.00.
7 SD 8.02 Ground Water - The bottom of the seepage system shalI be at
8 least 3 feet above the maximum elevation of the ground water table.
9 SD 8.03 Impervious Material - The bottom of the seepage system shall
10 be at least 5 feet above impervious formations. Excavating into impervious
11 material is prohibited unless otherwise approved by the director.
12 SD 8.04 Excavation - The excavation for the seepage system may be made
13 by mechanical means, however, if such means are used, care must be taken
14 to assure that the soil at the bottom of the excavation is not compacted or
15 smeared, the bottom of the excavation shall be level and scarified.
16 SD 8.05 Location - The minimum distance the sewage seepage system
17 must be from items it might effect is found in Section SD 3.05.
18 SD 8.06 Minimum reaching Area for an Individual Dwelling - The minimum
19 leaching area required per bedroom shall be determined from the following
20 table:
21 Percolation Rate Disposal Trenches Disposal Beds, Seepage
22 (minutes per inch) (leaching area, Pits, Cesspools, (leach-
23 sq. ft. per bedroom) ing area, sq. feet per
24 - (I) (3) bedroom (2) (3)
25
2
85
125
26
3
100
145
27
4
115
165
28
5
125
180
29
to
{65
235
30
15
190
270
31
20
220
315
32
25
240
33
30
250
34
40
290
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(1) Soil with a percolation rate of over 40 minutes per inch is
unsuitable for disposal of sewage by any means of sub-surface leaching.
(2) Soil with a percolation rate of over 20 minutes per inch is
unsuitable for these means of subsurface leaching.
(3) To determine effective leaching area, see Section SD 9.00, 10.00,
and 11.00.
SD 8.07 Minimum Leaching Area for Places Other Than Individual Dwellings
The minimum leaching area required shall be determined from the following
table using-the estimated daily sewage flow as determined by means given in
Section SD 3.01.
Percolation Rate Disposal Trenches Disposal Beds, Seepage
(minutes per inch) (maximum rate of Pits, Cesspools (maxi-
sewage application mum rate of sewage
gallons per sq. ft. application) - (gals,
per day ) (I) (3) Per sq. ft. per day)
(2) (3)
2
3.5
2.5
3
2.9
2.0
4
2.5
1.8
5
2.2
1.6
10
1.6
<•>
15
1.3
0.9
20
I.I
0.8
25
1.0
30
0.9
40
0.8
(1) Soil with a percolation rate of over 40 minutes per inch is
unsuitable for^^s£psa| of sewage by any means of subsurface leach|ng.
(2) Soil with J~pJrc^~T~r-i)te of over 20 minutes per inch is
unsuitable for these means of^£dtisj_/fa^ey1 teaching.
(3) To determine effective leaching area^«^/sj§/5t<>Hs SD 9.00.
10.00 and 11.00.
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R23-I-SD 9.00 SPECIFICATIONS FOR DISPOSAL TRENCHES AND DISPOSAL BEDS
SD 9.01 Effective Leaching Area - The effective leaching area shall be
held to mean the total bottom area of the disposal trenches or the entire
bottom area of the disposal bed. The leaching area required shall be
determined in accordance with the provisions of Section SD 8.00. In no event
shall the total effective leaching area be less than 170 square feet in the
case of disposal trenches or 250 square feet in the case of disposal beds.
SD 9.02 Construction of Disposal Trenches and Beds - Disposal trenches
and beds shall follow the construction details listed in the table below:
Minimum lines per field or bed 2
Maximum length per line 100 feet
Minimum diameter of distribution lines 4 inches
Grade of distribution lines 2 to 4 inches per 100 feet
(No gradient needed if dosed by siphon or pumps)
Maximum width of disposal trench bottom 3 feet
M'ini mum distance between walls of adjacent trenches 5 feet
Minimum cover over distribution lines 12 inches
Maximum distance between distribution lines 6 feet
in disposal beds
Maximum depl'h of invert of distribution pipe 2.5 feet
below finished grade
Minimum distance between adjacent beds 10 feet
Length of bell and spigot clay pipe lines 2 feet
Openings at joints of bell and spigot 0.5 inches
c I ay p i pe I i nes
Distance between distribution lines and 2 feet
edge of bed shalI not be less than
Termination of distribution lines 2 feet
from end of trench
SD 9.03 Distribution Lines - The distribution lines may consist of clay
or tile,bell and spigot pipes, perforated asbestos cement pipe, or other
suitable pipe approved by the director. The ends of all distribution lines
shall be interconnected, unless otherwise approved by the director.
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SD 9.04 Stone - The stone used in the leaching system to surround the
distribution lines shall consist of washed stone ranging from not less than
1/2 inch to not more than 2 inches in size and free from iron, fines and
dust. It shall cover the full width of the trench or bed and shall be
placed to a depth not less than 6 inches below the bottom of the distribution
lines in a disposal trench and not less than 12 inches below the
bottom of the distribution lines in a disposal bed. The stone shall extend
at least 2 inches above the top of the distribution pipes. The- stone shall
be covered with at least a 2 inch layer of washed pea stone or a 2 inch layer
of straw or hay, or by a layer of untreated building paper.
SD 9.05 Construction in Fill - When a sewage leaching system can be
approved in filled land, the leaching area, extending at least 10 feet on
all sides, must be stripped of trees, brush, stumps, topsoi I, and soil
containing fines and the bottom of the excavation scarified and backfilled
with a coarse grained soil containing little or no fines. The leaching
system shall not be constructed when the original soil was stripped to, or
Into, the ground water table unless approved by the director. Distribution
lines shall be supported by grade boards attached to stakes driven into
undisturbed soil whenever required.
SD 9.06 Backf ill- All backfill placed over a seepage system shall
be free of large stones, frozen clumps of earth, rubbish, masonry, stumps
or waste construction materials. Backfill shall be placed carefully in
disposal trenches or beds so as to avoid displacement and damage to piping.
Heavy machinery shall not be permitted to pass over the leaching area.
SD 9.07 Parking Area Location - The area of the seepage system shalI
not be paved or used for vehicular parking or vehicular traffic. Systems
serving other than individual dwellings shall be adequately curbed or
fenced so as to exclude all vehicular traffic. Parking areas adjacent to
seepage systems shall be graded or curbed to divert runoff from the seepage
area.
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R23-I-SD 10.00 SEEPAGE PITS
SD 10.01 AcceptabiIIty - A seepage pit may be constructed In lieu of
a disposal field only where a special condition justifies its use. It
must be preceded by a septic tank. A seepage pit shall not be used in an
area where wells are within 200 feet.
SD 10.02 Leaching Area - The leaching area of a seepage p.it shall be
determined in accordance with provisions of Section SD 8.00. Only the bottom
and sidewall area below the Invert of the inlet shall be considered to be
leaching area.
SD 10.03 Spacinq - When more than one seepage pit is installed, a
distance of at least 20 feet between sidewalls shall separate the pits.
SD 10.04 Access - The top of a seepage pit shall be provided with an
access manhole with a removable cover of concrete, iron, or other durable
material. The top of the manhole should be brought up to within 12 inches
of the finished grade, and properly marked.
SD 10.05 Construction - The lining of a seepage pit shall be of stone,
brick, or cement block, laid dry with open joints. The space between the
excavation and the lining shall be backfilled with washed stone, 1/2 inch to
2 inches in size, for a distance of at least 6 inches from the lining.
Washed stone 1/2 inch to 2 inches in size shall be p'aced on the bottom of
the pit to a depth of 12 inches.
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R23-I-SD 11.00 CESSPOOLS
SD 11.01 Acceptab11i ty - The i ns+alI atI on of a cesspool will be
approved only in those situations in which the soil has excellent seepage
properties, the need is of short term, or the use is infrequent, or in other
special situations which warrant their approval. Cesspools will not be
approved in areas where water is obtained from wells within 200 feet.
SD 11.02 Leaching Area - The leaching area of a cesspool shall be
determined in accordance with the provisions of Section SD 8.00. Only the
sldewall area below the invert of the inlet shall be considered to be
leaching area. The size shall be determined by the director.
SD 11.03 Construction - The lining of a cesspool shall be of stone,
brick, or cement block laid with dry open joints. The space between
the excavation and the lining shall be backfilled with stone 1/2 inch to
2 inches in size, for a distance of at least 6 inches from the lining.
SD 11.04 Access - The top of the cesspool sb'ail be provided with an
access manhole with a removable cover of concrete, iron, or other durable
material. The top of the manhole should be brought up to within 12 inches
of the finished grade, and properly marked.
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R23-I-SD 12.00 PRIVIES. CHEMICAL TOILETS AND INCINERATOR TYPE
SD 12.01 Acceptabi11ty - The instaIlation of a privy, chemical or
Incinerator type toilet will be approved only where a water-carriage
system is not practicable.
SD 12.02 Location - The Location of a privy shall meet the requirements
of Section SD 3.OS.
SDI2.03 Construction - A privy shall have a self-closing seat cover,
and a fly-tight vault and superstructures. A screened vent shall extend
from the vault to the atmosphere.
SD 12.04 Maintenance - When a privy vault becomes filled to within two
feet of the surface of the ground, it shall be cleaned and the contents
disposed of in a sanitary manner, or it shall be covered with clean
compacted earth to a depth not less than two feet.
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PART D. SOIL STUDIES AND PERCOLATION TESTING
R23-I-SD 13.00 SUBSOIL EXPLORATION
SD 13.01 General - The suitability of the soil for disposal of
sewage by leaching shall be determined through the consideration of the
type of soil, the results of percolation tests, the maximum ground water
table elevation, the occurrence of impervious formations, and any other
relevant data. The director may require percolation tests and ground
water table determinations on individual lots in subdivisions or parts
thereof which have been reviewed and the soil found suitable for the
Installation of individual sewage disposal systems. In areas where
available information makes such tests unnecessary the director may waive
or modify the requirements for soil studies and percolation tests.
SD 13.02 £J±e_SuitabiIity - The instalI at ion of an individual
sewage disposal^^s+em7s^T^ii^ai,1®i>>i n ,ar^s_wh^re the ground water
table at Its hlgfiesT s^sona]'Vla\«iJon/-l(y^J^ijn)jM^elrfTOthe original
ground surface, or where an Impervious layer is wir'nm o *ffe«t of the original
ground surface.
SD 13.03 Percolation Test - At least one percolation test, carried out
In accordance with the procedure ^'jtlined in Section SD 14.00 shall be made
at the lite of each disposal system. More than one test will be required
If the soil structure is highly variable or if a large disposal area is
requi red.
SD 13.04 Exploration holes - An adequate number of borings or
excavations shall be made in the proposed leaching area to clearly
establish the type of soil, and the location of impervious formations.
The borings or excavations shall be carried to a depth of at least 5 feet
below the elevation of the bottom of the proposed seepage system.
SD 13.05 Persons Qualified to Test
(a) Engineers and Surveyors - Percolation tests, ground water
table elevation determinations, and the gathering and submission of
other essential information in addition to the requirements of
Section SD 2.02 shall be carried out by a registered professional
engineer or registered surveyor at the expense of the owner or
cfeve loper.
(b) Sanitarians and Soil Scientists - Percolation tests and the
determination of the depth to the ground water table may be carried
out by a qualified professional sanitarian or soil scientist approved
by the director. Such approval shall be made on the basis of
satisfactory experience and education in the area of soil science and
standards for the design and construction of individual sewage disposal
systems. Such qualifications shall be presented in writing.
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(c) I. Home Owner - If the property owner is installing,
constructing or altering an individual sewage disposal system
to serve a building he occupies or will occupy as his intended
permanent domicile, he or his representative may prepare the
necessary holes and carry out the tests as prescribed in these
regulations.
(c) 2. Whenever in the opinion of the director the requirements
of these regulations protecting the public health and environment
can be met, a home owner as defined in Section SD 13. OS (C-l) may
prepare the plans and layout of his proposed system. For this
purpose any requirements of these regulations may be waived at the
discretion of the director. The director reserves the right to
require any data he deems necessary to fulfill his obligations
under these regulations.
Cd) The director may require that all soil examinations be
performed in the presence of one of his agents.
SD 13.06 Recording Results - The complete record of percolation tests,
ground water table determinations, type of soil, and the location of
Impervious formations in the area shall be recorded on forms provided by,
or approved by, the director. Any person making and/or witnessing the
determinations shall certify to the accuracy of the •'echnical data recorded.
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R23-I-SD 14.00 PERCOLATION TEST PROCEDURE
SO 14.01 (a) Dig two or more test holes within the area of the
proposed seepage system-, not less than 10 feet apart. One of the holes
should be at the depth of the bottom elevation of the proposed seepage
system, and the second hole should be at a depth of about 18 inches below
the bottom elevation of the proposed seepage system. This is to evaluate
the conslstancy with depth of the seepage qualities of the soil. The size
of the seepage system must be based on the highest percolation rate obtained.
The holes shall be not less than 6 inches in diameter or 6 inches square, nor
should they be greater than 8 inches in diameter or 8 inches square.
(b) Scarify the bottom and sides of the test holes and remove all
loose material. Place about 2 inches of coarse sand or fine gravel In the
holes to prevent bottom scouring.
(c) Fill the holes with clear water to a minimum depth of 12 inches
above the coarse sand or fine gravel. Keep water in each hole for at
least four hours and preferably overnight by refilling. If necessary to
maintain water in each hole for this period, provide a reservoir of water
and an automatic siphon to deliver it to the holes intermittently, or the
percolation test holes should be soaked and maintained full for not less
than four hours before the percolation test is made. In uncompacted sandy
sol Is containing no clay or silt, the above saturation procedure is not
necessary; the test can be made as soon as the water from one fi 11ing
has seeped away.
(d) The percolation test should be made following the saturation
process. When the saturation process is complete, the water depth should
be adjusted to 6 inches over the coarse sand or fine gravel before the test
Is begun. The drop in water level should be measured from a fixed reference
place, such as a board laid across the hole, over 30 minute intervals,
refilling the holes to a depth of 6 Inches as necessary.
(e) When three consecutive readings at 30 minute intervals read the
same rate, the test may be considered complete. If no stability is reached
between three 30 minute readings, not less than four hours of readings must
be followed. The drop in water level which occurs during the final 30
minute period is used to calculate the percolation rate. This rate is expressed
In minutes per inch.
(f) Soil's in which the first 6 inches of water seeps away in less than
30 minutes, after the saturation period, the time interval between
measurements should be reduced to 10 minutes and the test run over a period
of one hour. The drop in water level which occurs during the final 10-minute
period is used to calculate the percolation rate. This rate is expressed in
minutes per inch.
SD 14.02 If an unanticipated cut is made, the results of any percolation
test made prior to the cut is invalid. A new percolation test shall be made
under the changed conditions.
M-3-1
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I
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
26
R23-I-SD 15.00 PROCEDURES FOR GROUND WATER TABLE ELEVATION DETERMINATIONS
SD 15.01 The ground, water table elevation determination shall be
made when the water table is highest; this occurs usually during the
months of January through ApriI. (Specific dates may be determined on a
yearly basis by the director). In making this determination It is necessary
to bore or dig an adequate number of holes of convenient size in the
proposed leaching area to a depth of at least five (5) feet below the lowest
point of the proposed sub-surface seepage systern.
aaeawfrnmiitdim Imuran An open perforated pipe at least 4 inches in diameter
shall be installed. Such pipe should be installed at +he beginning of the
wet season and remain in place until a permit has been issued by the
director. This pipe shall be capped at the top and mounded to prevent the
collection of surface water. All water table test holes shall be witnessed
by an agent of the director unless otherwise waived.
SD 15.02 Ground water table determinations made other than during the
months of January ttiiu April will be accepted provided the material in the
test pit consists Qpif&ortflafited sand or gravel containing little or no
fines, and the perco
original soil; and the hole'i^'cMg/l?!
lowest part of the proposed sub-surfaci
encountered.
reater than
(5) min. per inch in the
least 15 feet below the
and no water is
M-32
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I
2
3
4
5
6
7
8
9
10
II
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
27
PART E. SUBDIVISIONS
SD 16.01 Subdivisions - Individual Sewage Disposal Systems - No
person shall construct in any subdivision located in areas where sewage
will have to be disposed of by means of individual sewage disposal
systems until he has obtained certification from the director that the
subsoil is suitable for disposal of sewage by individual sewage disposal
systems. Application for such certification shall be made on forms
orovlded by the director and accompanied by data described in
SD 16.02 through SD 16. 06.
SD 16.02 Topographic Map - A topographic map of the entire area
under consideration shall be prepared to an appropriate engineering scale
and submitted with the application. It should show existing conditions on
the entire site including existing (a) houses, foundations and excavations
for basements; (b) existing individual water supplies and sewage disposal
systems; (c) right of ways or easements; (d) natural waters or water
courses, swamps and marshes; (e) rock out-crops and wooden areas; (f) stone
walls. There shall also be shown, designated, or reported for lands
Immediately adjacent—(a) natural waters or water courses within 200 feet
from the property; (b) wells within 150 feet from the parcel being considered.
The topographic map shall show ground elevations on the tract as
foI lows'1- (a) for land that slopes less than approximately 2% show spot
elevations at all breaks in grade, along all drainage channels or swales,
and at selected points not more than 100 feet apart in all directions;
(b) for land that slopes more than approximately 2% show broken line
contours with an interval of not more than 5 feet where ground slope is
regular and intervals of not more than 2 feet where the ground slope is
Irregular. The datum on which the elevations or contours are based should
be reported.
Where cut and/or fill of more than I foot can be anticipated and
estimated, it should be indicated by solid line contours showing
approximate finished grade. Plan and profile showing existing and proposed
finished grades of proposed roads must be provided.
SD 16.03 Location Map - A location map or sketch showing existing
highways, streets and/or other identifiable landmarks or distances thereto,
shall be furnished to facilitate an inspection of the site. This may be
Incorporated on the topographic map.
SD 16.04 Percolation Tests - An adequate number of percolation tests
not ;ess than one to an acre, with a minimum of two tests in small areas
shall be made by the developer, to indicate clearly the soil conditions through-
out the property. These tests shall be made in accordance with the procedure
outlined In Sections SD IS.00 and SD 14.00. Unfavorable soil conditions
will require more tests, up to one per lot at the proposed site of each
subsurface absorption unit. The results of each percolation test and pertinent
Information shall be recorded in the tabulation provided on the application and
the location of the percolation tests shall be marked on the topographical map
and Indexed by the corresponding number used in the tabulation of results.
M-33
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28
1 SD 16.05 Ground Water Table - An adequate number of borings,
2 excavations or observations shall be made by the developer to clearly
3 establish the elevation of the ground water table in accordance with the
4 procedure outlined in Sections SD 12.00 and SD IS. 00. The ground water
"«5 table determinations should be made when the ground water table is at its
6 highest level. The results of each observation and pertinent Information
7 shall be recorded in the tabulation of the application. The location of the
8 ground water table observations shall be indicated on the topographical
9 map together with the index letter used in the tabulation of the results.
10 SD 16.06 Certification - The engineer, surveyor, soil scientist,
11 or sanitarian shall execute the certificate relating to the accuracy of
12 the technical data on each sheet on which such technical data is recorded.
13 SD 16.07 Nothing in Sections SD 16.01 through SD 16.06 shall prevent
14 the director from requesting any or all of the procedures established in
15 these regulations for a single lot if in his opinion the protection of the
16 public health and environment so requires.
PART P. APPjAiJPEQCMRI
Page 28 (Soe Amendments)
The foregoing rules and regulations, after due notice and hearing.
are hereby adopted and filed with the Secretary of State this 6th
day of July 1973, to become effective twenty (20) days thereafter, in
accordance with the provisions of Chapter 23-1 and 42-35 of the General
Lams of Rhode Island3 1956, as amended.
^^JoJeph E. Cannon, M.D., M.P.B.
Director of Health
notice given on 5 January 1973
Hearing held on 25 January 1973
NEW AfltNDMtHTS EFFECTIVE 30 AUGUST 1974
M-31*
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29
Water
Service¦
Vine
I
I Existing|
1 Leaching,
I Field
17
— 25'
minimum
10 feet minimum
_ 4- to property^ lines
Property Line
•2-
Lin-
s?
Leaching Bed T —I-, „
15' [4 Sep*-
—mwtimumlrj—'
House
\
100 feet Minimum
to leaching fields
SO feet Minimum
to septic vtmks
Top edge of any bank,
for a 25 foot perimeter,
must not drop below
field invert elevation
Well
Property Line
House
J£-5 feet minimum
Septic
Tank
2S feet
minimum
\ LeachingTrenches
100 feet minimum to leaching fields
SO feet minimum to septic tanks
Alternate Area for
future expansion
of leaching field
TYPICAL LOT LAYOUT
(No Scale)
Reference: See Sections SD 2.00 and 3.00
M-35
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30
Ground Surface
S/Aty//
„ Manhole Covers l.foot Man,
p-,,11 P C T r-'-^g
¦"° vrr
Manhole Covers_ l.foot _ Manhole Cover
Inlet
Sanitary_
Tee
Invert of Inlet 2 mehe
above Invert of Outlet*
J i -1
Liquid Level I
Sanitary
Tee
- I -jl-./OOt-
I ,Minimum
\_Baffles may be used.
Instead of Sanitary
Tee 8
(4 to 8 ft)
. Outlet
SECTION VIEW
Manhole
Covers
Inlet
TOP VIEW
TYPtCAL SEPTIC TANK
fWo Scale)
Reference: See Section SD S.00
Outlet
M-36
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31
Manhole
A Outlet
Inlet
TOP VIEW
Manhole
Inlet
Eigh Water Level
Outlet
Section View
TYPICAL DOSING TANK
(No Scale)
Reference: See Section Sn 6.00
M-37
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32
3 Alternate
4 inch-.inlets
^\5 - Knockouts for
4 inch outlets
I f~Baffle
Cover
TOP VIEW
¦v,>'T- ¦'¦•¦f'.jy.
Inlet
fi
i J'
~'/
2 ir\che :a
minimum
" ' • r
___ Outlets
/^\\ X.
(I MM >x
*-Baffle
Outlet
4 incht.
SECTION VIEW
END VIEW
TYPICAL DISTRIBUTION BOX
(No Scale)
Reference: See Section SD 7.00
M-38
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33
Vj
_Solid 4 inch Trench
pe
Building
Perforated 4 inch Pipe
Distribution
Box
Length
TYPICAL PLAN LEACHING TRENCHES
-77^^^^-.
4 Inch Pipe
I
I
Perforatedy
>—i—
6
'^er „LBuildW WC -Earth
Ajap^^eate^
¦ntmum
mi1®?
Feet
T
_3 f£et
Maximum
Minimum
6 Inches
Minimum
Stone
(J/2 to 2 Inches diameter)
TYPICAL TRENCHES
CROSS SECTION
TYPICAL TRENCH TYPE FIELD
(Ho Scale)
Reference: See Section SD 8.00 and 9,00
M-39
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34
Solid 4 inch
uimits of
_ leaching Bed
Building
Setter
Perforated 4 inch_
pipe
Length
Distribution Box
I
' £
"S
I
TYPICAL PLAN LEACHING BED
6 feet maximum
2 feet-
6 feet maximum
2 feet
^RTH.-CO)
< nr.
9;
2 inchesJ*/-
•wfcftoart^-p , ,.
VA^V/i-^/A X'j
¦J?foot
minimum
1 Stone
1/2 - 2 inches diame
^VY'/V"
4^%ndk perforated
pipe
er
Grade^boards
^5^
J /bot
' mirjjrmm
s£>jS&»V
TYPICAL BED
if required '
CROSS SECTION
TYPICAL BED TYPE FIELD
(Ho Scale)
Reference: See SD Section 8.00 and 9.00
M-i»0
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35
Reference
Board V
Ground Surface
Measuring Device J
For Depth
'See Section
SD 14. 01
" ~T~
^ '
y 6 Inches
V
2 inches
of
Band or /A
fine gravel .
Inches
TYPICAL SOIL PERCOLATION HOLE
(No Scale)
Reference: See Section SD 14. 00
M-l»l
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APPENDIX N - ENVIRONMENTAL EFFECTS OF SUBSURFACE DISPOSAL ON GROUND WATER
QUALITY
An important consideration in the evaluation of alternative wastewater
management schesas for Block Island is the impact on ground water quality.
This is particularly significant since the ground water is also the sole
source of supply of water for commercial and domestic use on the Island.
A general assessment of the effects of subsurface disposal on ground
water quality can be developed from the past experience of communities and
individuals as well as scientific studies. A recent comprehensive evaluation
of this question is a report titled The Long Island Sound Ground Water
Pollution Study prepared by the New York State Department of Public Health
and published in 1972. Another important study is the Report on the Investi-
gation of Travel of Pollution prepared by the California Water Pollution
Control Board in 195^. The information presented here is based in part on
information obtained from these studies.
It can be confidently stated that the disposal of domestic wastes into
the ground using subsurface disposal systems such as septic tanks and
leaching fields will result in some degradation of the ground water quality.
The important question is whether the changes in quality are significant
relative to the usefulness of the water as a water supply.
A complex combination of physical, chemical and biological phenomena occur
from the entrance of wastes into a subsurface disposal system and through the
system, the unsaturated soil and saturated soil. Sorption, dilution, diffusion,
chemical reaction, precipitation, filtration ana biodegradation processes take
place, reducing the pollution concentration of the wastewater, nevertheless
some fraction of the pollutants reach the groundwater. Based upon the
information presented in the previously mentioned studies and accepted standards
for drinking water quality, continued use of subsurface disposal systems on
Block Island would not appear to constitute a significant threat to the
ground water quality.
Many rural and suburban communities have utilized and continue to utilize
subsurface waste disposal systems in combination with private individual
water systems or community water systems without effecting significant changes
in the quality of the ground water supply. In many instances this preservation
is sustained ay requiring a physical separation of water supply wells from
subsurface disposal systems. Distances ranging from 1+00 ft. to 1,000 ft.
separation are general guidelines applied for community wells. For individual
water supply systems distances of 50 ft. to 100 ft. are practiced.
Significant ground water quality problems have occurred, such as on
Long Island, where the density of development and soil conditions have stressed
environmental systems beyond their capability to respond. The contamination
of individual water supply systems can usually be attributed to inadequate
physical separation from the subsurface disposal system.
fl-1
-------
Based upon the information available, subsurface disposal systems now
used on Block Island have not significantly impacted the quality of the ground
water used for water supply. Previous scientific studies and investigations
and past experience, indicate that continued use of subsurface disposal systems
will not significantly impact the water quality of the island particularly in
view of the currently proposed densities of development and the seasonal nature
cf the present population. In order to ensure the preservation of the ground
water quality, it is recommended that presently proposed developmental densities
be maintained or reduced. It is further recommended that community water systems
from protected sources be provided in the more densely developed areas of the
island.
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APPENDIX O - COMMENTS ON DRAFT EIS
The following are letters received by EPA in response to
the draft Impact Statement. They are divided into four sections.
First the letters from other Federal agencies, then from other
State agencies, followed by Town officials and finally letters
from the general public. Each group of letters is in chronological
order.
Each paragraph for which a reply is required is marked and
numbered. That number responds to the paragraph response in
Caapter 9 of the text.
0-1
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^«ENr
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DEPARTMENT OF TRANSPORTATION
UNITED STATES COAST GUARD
MAILING ADDRESS:
COMMANDER
FIRST COAST GUARD DISTRICT
150 CAUSEWAY STREET
BOSTON. MASS. 02114
•5922/19
8 April 1975
From: Commander, First Coast Guard District
?To: Regional Administrator, Region I, U. S. Environmental Protection Agency
Subj: Construction of Wastewater Collection and Treatment Facilities at New
Shoreham, Rhode Island; permit for
Ref: (a) Your ltr dtd 27 March 1975
1. Reference (a) has been reviewed by this office and the following comments
are submitted for your consideration.
2. The primary interest of the Coast Guard in the proposal is the possible
impact upon safety to navigation.
3. The proposed outfall for the project is to be submerged in 1.3m (4.3 ft)
of water approximately 70m (230 ft) offshore from Pebbly Beach.
4. No mention is made of complying with 33 CFR 67.15-10 for marking of thel
installation. I
5. On the basis of the information contained in reference (a), the Coast
Guard will withhold approval of the project until additional information
is received as to the impact of the outfall on marine traffic in the area.
38
R. T.
By direction
APfi "9 1975
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
222 Quaker Lane, West Warwick, Rhode island 02893
April 14, 1975
John A.S. McGlennon, Regional Administrator
U.S. Environmental Protection Agency, Region I
Room 2203
JFK Federal Bldg.
Boston, MA 02203
ATTN: Environmental Impact Office
Re: Draft Environmental Impact Statement
Town of New Shoreham Water Pollution Control
Facility and Interceptor System
New Shoreham, RI
Dear Mr. McGlennon:
We have reviewed the Draft Environmental Impact Statement for
Waste Water Collection and Treatment Facilities for New Shoreham,
Rhode Island.
The difinitive information provided to you in November 1974 was used.
Similar (soils) maps are not available for the remainder of the Island.
Therefore, we are unable to make other contributions at this stage.
We are available to assist the contractors develop plans for preventing
erosion during construction.
Sincerely,
/ >M W W ¦ II W . ¦ M W I 1 W I * , W I .
State ~Conservati oni s t
6
-------
< o' TM*,.
U. S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
REGION ONE
I4O Fountain Street
Providence, Rhode Island 02903
IN REPLY REFER TO:
April 22, 1975
Mr. John A.S. McGlennon, Regional Administrator
U.S. Environmental Protection Agency, Region I
Room 2203
JFK Federal Building
Boston, Massachusetts 02203
ATTENTION: Environmental Impact Office
Dear Mr. McGlennon:
Subject: Draft EIS - Wastewater Collection and Treatment Facilities,
New Shorehaiti, Rhode Island
We have reviewed your draft EIS for the wastewater collection and
treatment facilities for New Shoreham, Rhode Island submitted with
your letter of March 27, 1975.
In behalf of Regional Federal Highway Administrator Robert E. Kirby,
please be advised we have no comments to offer on this draft EIS.
Sincerely yours,
Gordon G. Hoxii
Division Engineer
cc:
Region .U
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DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
REGION I
JOHN F. KENNEDY FEDERAL BUILDING
GOVERNMENT CENTER
BOSTON, MASSACHUSETTS 02203
OFF t CE OF
THE REGIONAL DIRECTOR
May 14, 1975
Mr. John A.S. McGlennon
Regional Administrator
U.S. Environmental Protection Agency
Room 2203
J.F.K. Federal Building
Boston, Massachusetts 02203
ATT: Environmental Impact Office
Dear Mr. McGlennon:
HEW's Regional Environmental Council has reviewed the Environmental
Impact Statement for the Water Pollution Control Facility and Interceptor
System, New Shoreham, Block Island, Rhode Island.
HEW previously reviewed the preliminary plans and specificationfffor such
an extended aeration system on 10/18/73. Our primary concerns at that
time centered on the effectiveness of chlorination and the adequacy of the
outfall design and location.
The Impact Statement does not discuss chlorination except for a comment
on page 42 which states that "it was considered that the treatment plant
should at least chlorinate the waste water at all times." It is unclear
whether this means that chlorination will be provided and that tertiary
treatment "might" be provided, or that chlorination might not be provided
but should be. We recommend that chlorination be provided year round as
specified in Food and Drug Administration's guidelines. This includes 30
minutes of chlorine contact prior to discharge into the outfall pipe.
Since HEW's comments in 1973, EPA has changed the outfall location and has
conducted hydrographic studies in the area of the outfall. These studies
show that the major factor influencing the dispersal of the effluent seems
to be the surf. Unless the outfall is extended out beyond the surf line
(±000' off shore), effluent laden waters will be casted onto the shore in
a matter of minutes. With respect to shellfish harvesting, however, this
is a moot consideration since there will have to be a closure in this area
regardless of whether the outfall pipe is extended out 200' or 1000'.
-------
-2-
In conjunction with the hydrographic studies, there is no estimate of
the size of the "closed safety zone" which will have to be established
around the outfall to prohibit shellfish harvesting. It may be that this
zone will extend beyond the area presently classified as SB into the ad-
jacent SA classified area. The SA area affected may, thereby, need to be
reclassified as SB. While it is suggested on page 42 that with a modified,
diffuser design, present water quality standards could be met at all times,
it would be better to make this judgement after the size of the closed
safety zone is estimated.
Thank you for giving us the opportunity to review and comment on this draft
EIS.
Donald Branum
Regional Environmental Officer
-------
DEPARTMENT OF THE ARMY
NEW ENGLAND DIVISION, CORPS OF ENGINEERS
424 TRAPEL.O ROAD
WALTHAM, MASSACHUSETTS 02154
REPLY TO
ATTENTION OF:
NEDPL-R
29 May 1975
Mr. John A. S. McGlennon
Regional Administrator
Environmental Protection Agency
Room 2303
J. F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
This letter constitutes our review of your Draft
Impact Statement concerning the proposed construe
Collection and Treatment Facilities, New Shorehan
The statement contains an adequate assessment of the environmental
impacts and will not pose any problems with regard to navigation or
maintenance of the harbor of refuge. It should be noted however
that a Department of Army permit was issued to the Town of New
Shoreham on 19 September 1974 for an outfall which would extend
approximately 240' seaward of the mean high water line. The Draft
Environmental Impact Statement recommends that the outfall be
extended to approximately 500' seaward of the mean high water mark.
If this recommendation is adopted, a new Federal permit will be
required.
Thank you for the opportunity to review the Draft statement and if
we can be of further assistance to you, please call.
Sincerely vours
CHARLES^TOSTERNDORF V
Col^rr^/Torps of Engineers
A<£&HTtj Division Engineer
e\cis v
IflViMW 2>'"uUi
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
In Reply Refer To:
EGS-ER-75/363-MS108
JUN 1 G 1975
Dear Mr. McGlennon:
This Department has received and reviewed the draft environmental
statement for the Town of New Shoreham Water Pollution Control
Facility and Interceptor System, New Shoreham, Block Island,
Rhode Island, as you requested in a memorandum of March 27. We
offer the following comments for your consideration.
Physical Environment
Potential impacts related to geologic conditions are adequately
discussed in the environmental statement.
We find the conclusions reached concerning the impact of alternative
methods of waste-^ter disposal on water resources and related land
aspects of the environment on Block Island to be generally sound and
adequately documented. We offer the following comment, however, in
connection with the proposal to dispose of sewage sludge fran a
Waste-Water treatment plant in a recently (1974) opened sanitary
landfill (alternatives a, b, d). The report says (p. 17) that the
landfill has been approved by the State for disposal of septic
tank and cesspool wastes in addition to solid waste. However, no
information is provided concerning the expected effect of the
sewage sludge on the character of the leachate that will percolate
fran the landfill to the underlying body of fresh ground water. Nor
is information provided to indicate the fate of the leachate once
it reaches the water table. Inasmuch as there are 20 or more
hemes, all or most of which obtain water supplies fran wells,
within 1,500 feet or so of the landfill (see maps 10 and 11), it
would seem advisable to include such information.
A water-table map (enclosed) of the main zone of saturation for
September 1962, included as figure 9 in "Ground-water resources
of Block Island" (R. I. Water Resources Coord. Bd., Geol. Bull. 14
"1964"), indicates that ground water in the vicinity of the
landfill flows in a northerly to rorth-narthwssterly direction to
the ocean. Under more or less natural hydrologic conditions,
landfill leachate may be expected to move in the same general
direction.
-------
Mr. John A. S. McGlennon, Boston, Massachusetts
Biological Environment
It is indicated on page 13 of the impact statement, under "Fish and
Wildlife," that "80% of the shellfish (. . . bay scallops) are
located in beds outside of the closure ..." We note that,
according to the Rhode Island Shellfish Atlas, large beds of sea
scallops also occur within two miles off the eastern shore of
Block Island.
It is stated (Alternative A, p. 42) that, to meet required water-
quality standards regarding coliform bacteria, the effluent would
be chlorinated continuously. No mention is made of the possibility
of using ozone as a purifying agent. The use of ozone as a sub-
stitute for chlorination is widely practiced in Europe and is
ccming into increasing use in the United States. Fran a fish and
wildlife viewpoint, the lack of harmful residual makes ozone an
attractive substitute for chlorine, which remains toxic to aquatic
organisms long after discharge. We suggest the possible vise of
ozone should be discussed in the impact statement, whichever
alternative is finally chosen.
Recreation
We agree that extending the length of the outfall pipe 500 feet frcm
the shoreline, where the water depth is 10 feet, would "preclude
easy accessibility" of swimmers, children, etc. (p. 43). We
commend the EPA and the State for their assistance in improving
diffuser design, thus insuring that water-quality standards will be
met.
The draft statement does not appear to assess the effects of the
proposed project on recreational use of the area. In addition, the
project's impact on existing and planned recreation facilities near
the project site should be discussed in depth in section 2.3*
"Utilities and Other Community Facilities," and section 2.4, "Growth
and Land Use Analysis." Similar discussions would be appropriate
for each of the alternatives in Chapter 3.
Archeological and Cultural Resources
The proposed project will not adversely affect any existing, proposed
or known potential unit of the National Park System, or any known
historic, natural, or environmental education sites eligible for
the National Landmark Programs. We would, however, like to point out
-------
3
Mr. John A. S. McGlennon, Boston, Massachusetts
that there are two historic properties in New Shoreham which are
listed on the National Register of Historic Places. The Block
Island North Light situated on the north end of the island
approximately six miles north of the proposed project vrould
probably not feel any effects of the project.
The Old Harbor Historic District, a landmark since May 8, 1974, is
apparently the site chosen for the proposed sewage treatment plant.
It is essential that contact and continued consultation be main-
tained with the State Historic Preservation Officer (Mr. Frederick
Williamson, Director, Rhode Island Department of Ccmnunity Affairs,
150 Washington Street, Providence, Rhode Island 02903) to assure
that the integrity of the historic district will not be endangered.
In addition, close coordination with that officer is the best
assurance that sites or properties significant to history, archeology,
and architecture will not be overlooked.
The historic resource reference letter (p. L-lj from Richard Alan Dow,
Rhode Island Historic Preservation Cormission, dated Septsnber 16,
1974, suggests a great probability of effect upon cultural resources
by the proposed project. Compliance with 36 CFR Part 800, which
deals with the protection of cultural resources, may well involve
Section 106 of the Historic Preservation Act of 1966, which vrould
bring this draft environmental statement before the Council on
Historic Preservation for review and Garment.
Since a National Register place is to be affected by this undertaking,
we would hold this environmental statanent inadequate until such time
as a carmentary fron the Advisory Council on Historic Preservation
is included and its contents appropriately responded to. Further,
we find this draft environmental statement inadequate in its
failure to consider environmental description of, impacts of the
proposed action alternatives on, and measures to mitigate adverse
impacts (not so stated) on archeological resources. We recormend
that the Environmental Protection Agency contact Dr. James Deetz,
Plymouth Plantation, Inc., Box 620, Plymouth, Massachusetts 02360
to arrange for a survey of archeological resources in the project
area. The reference to "ruins" in the project area indicates a
need to evaluate these resources.
We note that, contrary to the ccnment in the last paragraph on
page 39, enlarging the historic district will not change the
impact of the project on its immediate surroundings.
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4
Mr. John A. S. McGlennon, Boston, Massachusetts
We thank you for the opportunity to review and carment on this draft
environmental statement. Due to the nature of our comments regarding
cultural and archeological resources, we request the opportunity
to review the final environmental statement.
Deputy Assistanl ^
Mr. John A. S. McGlennon
Regional Administrator, Region I
Environmental Protection Agency
J. F. Kennedy Federal Building
Boston, Massachusetts 02203
Enclosure
Sincerely yours
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EXPLANATION
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4I°I2-
Number is altitude of water level in feet
6
Water- table contour; dashed where 4i*n'-
inferred, contour interval 3 feet. Datum
is mean sea level
41*10 —
-
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STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS
HISTORICAL PRESERVATION COMMISSION
Old State House
150 Benefit Street
Providence, R. I. 02903
(401) 277-2678
May 9, 1975
Mr, John A, S, McGlennon,
Regional Administrator
United States Environmental
Protection Agency
J, F, Kennedy Federal Building
Boston, Mass. 02203
Dear Mr, McGlennon:
We have reviewed the draft environmental impact state-
ment for the proposed wastewater collection and treat-
ment facilities in the town of New Shoreham, Rhode
Island (dated 3/21/75), and make the following comments:
1) The alternate proposals recommended by the Environ-
mental Protection Agency -- alternates B and D -- are
the best of the five choices considered in the study
from the point of view of historic preservation.
The Commission plans to send representatives to New
Shoreham shortly and, after that on-site review, to
endorse one of the recommended alternates.
2) A reconnaissance archeological survey of the study
area is necessary to determine if archeological resources
may be damaged by construction of the proposed facility.
If so, funding for salvage archeology will be required.
The reconnaissance survey should be conducted expedi-
tiously so that results can be included in the "Final
Environmental Statement."
Sincerely,
Richard Alan Dow
Executive Director
RAD/af
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STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS
Department of Administration
STATEWIDE PLANNING PROGRAM
265 Melrose Street
Providence, Rhode Island 02907
May 14,. 1975
Mr. John A. S. McGlennon
Regional Administrator
U.S. Environmental Protection Agency
Room 2203
JFK Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
This is to inform you that this agency has reviewed the
Draft Environmental Impact Statement on New Shoreham's Water
Pollution Control Facility and Interceptor System in accordance
with 0MB Circular A-95.
After having reviewed the proposals and having been in
contact with other state agencies on the matter, we have no
comments to make on this study at this time.
Very truly yours
Daniel W. Varin
Chief, Statewide Planning
DWV/JOB/gt
cc: R. Mendoza
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i$s<
STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS
Department of Administration
STATEWIDE PLANNING PROGRAM
265 Melrose Street
Providence, Rhode Island 02907
June 10, 1975
Mr. John A.S. McGlennon
Regional Administrator
U.S. Environmental Protection
Agency-
John F. Kennedy Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
The Rhode Island Statewide Planning Program has com-
pleted its review of the draft environmental impact
statement for wastewater collection and treatment facili-
ties for the Town of New Shoreham, Rhode Island.
We feel that there are additional factors which limit
the economic capability of the Town of New Shoreham.
These are outlined below:
1. New Shoreham is an island community with limited
accessibility. This inaccessibility in turn
limits the economic potential of the town. With
the exception of the tourist industry it is un-
likely that the character of the island would
be altered by industrial development which would
result from the construction of a municipal I 10
sewer system. It is therefore unlikely that a
sewer system in New Harbor will generate the full
secondary impacts outlined in the EIS. This
accessibility factor was also pointed out in a
preliminary engineeing report on water supply
and distribution prepared by Penton G. Keyes
Associates for the town.
-------
Mr. John A.S. McGlennon
- 2 -
June 10, 1975
2. The present water supply system Is extremely »
limited, serving about 60 customers. This factor
to some extent will control economic development.
However, the previously mentioned report proposes
the extension of public water service to the New
Harbor area. With the exception of the tourist
industry, the extension of the water system is
not expected to generate any substantial economic
development.
Based on these additional factors and our review of the
five alternatives presented in this EIS. we feel Alterna-
tive B (Proposed Project Minus Stage II) should be selected
for implementation. This alternative will not generate
residential development, particularly multiple unit, to
the extent expressed in the EIS. In addition, we feel
this Alternative provides the community with a broader
range of options in relation to:
1. the patterns of development (Old Harbor only,
both Old and New Harbors);
2. level of seasonal population growth (moderate or
substantial);
3. distribution of tax burden (maintenance of exist-
ing base or controlled expansion);
4. capacity of treatment plant (maintenance of
original discharge level or gradual increase); and
5. commencement of treatment facilities construction
(immediate start or continued delays)
In order to control the potential secondary impacts
of Alternative B, the town has, at its disposal, several
mechanisms which can control growth. These include:
1. local zoning and Sewer connection ordinances;
2. state salt marsh protection legislation; and
3. NPDES permit discharge limitations.
This alternative also allows the town to balance the trade-
offs between increased development and increased taxes
consistent with its goals and fiscal capabilities, as well
as its water supply situation. The latter is probably the
critical factor in determining how much growth the island
can accommodate,
-------
Mr. John A.S. McGlennon
- 3 -
June 10, 1975
If Alternative D is selected for implementation, the
property owners in the New Harbor areas must bear not
only a portion of the costs of serving Old Harbor, but
must also bear, unassisted, the costs of upgrading their
existing septic systems. This burden seems inequitable,
and may precipitate the closing of revenue-producing proper-
ties in the New Harbor area, in addition to those which
have been lost to the Island's tax base in the past. Sewers
to the New Harbor area will allow more dense development
there, if the residents so choose.
We therefore respectfully suggests that EPA allow the
Town of New Shoreham to proceed with the implementation
of Alternative B which consists of Stage I of the project
proposed by Fenton G. Keyes Associates.
very truly,
Daniel W. Varin
Chief, Statewide Planning
DWV/PJF/jl
cc: Mr. Carleton Maine
Mr. Herbert Whitman
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STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS
AUG 1 1 i#g
DEPARTMENT OF HEALTH
Davis Street
Providence, R.I. 02908
7 August 1975
John A. S. McGlennon
Regional Administrator
Environmental Protection Agency
Region I
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
This is in regard to finalization of the Environmental
Impact Statement on Wastewater Collection on Treatment Faci-
lities for New Shorfeham, Rhode Island.
It is our opinion that collector sewers and adequate
treatment facilities for both the New Harbor and Old Harbor
areas in New Shoreham are exigent. The subsoil conditions
1n both areas are unsuitable for the disposal of sewage by
Individual subsurface seepage systems. Various attempts
to dispose of the sewage from exisitng developments by means
of individual systems have failed. An existing establishment
at New Harbor was closed because of the inability to properly
dispose of the sewage.
New Shoreham is totally dependent upon the tourist trade
to support the Island's economy. New Harbor area is exten-
sively used as a pleasure boat mooring and docking area. The
discharge of sewage from the boats using the area is contri-
buting to pollution of the harbor waters. There are propo-
sals to Install public toilet and washing facilities 1n the
area to reduce pollution from this source. However, the
volume of sewage expected to be generated cannot be disposed
of adequately in the absence of the proposed sewer system 1n
New Harbor.
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STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS
T
inv
DEPARTMENT OF HEALTH
Davis Street
Providence, R.I. 02908
% August J975
Mr. John A.S. McGlennon
Regional Administrator
Environmental Protection Agency
Region I
John F. Kz.nne.dy Federal Building
Boston, MA 02203
Dear Mr. McGlennon:
Recently Mr. Paul Fridette of you)t agency, calling on behalf of Mr. Stickney,
inquired as to the. opinion of this division with reference to the proposed con-
struction of sewers on Block Island.
This division of the Rhode. Island Departmentoh Health has been responsible
ion. the. general environmental sanitation on Block Island as it is in all the
cities and towns o £ the state.. Tt is responsible for the approval fan. construction
of the individual sewage disposal systems and the. abatement of overflowing sewage
problems.
In the many years that we have, been responsible far these activities, there,
have been innumerable instances o6 oversowing sewage on the Island; and because,
of adverse conditions in the Old Harbor and New Harbor area, corrections usually
are temporary. Most problems derive from the. heavy flows which occur during the
tourist season. In our opinion, both the Old Harbor and New Harbor areas cannot
adequately dispose of sewage.
As recently as 6 August, representatives of this division surveyed the area
and confirmed once again that the soil cannot adequately contain the effluents.
Further, the area has a high water table and is not amenable to the disposal of
sewage by sub-surface method.
The solution to this problem remains the one that we have anticipated for
some time, and that is the. installation of a municipal sewerage collection system.
Trusting this is the information which was sought from this agency, I remain
FAS/bad
cc: Mr. G.V. St. Andre.
Dr. J.E. Cannon
Mr. C.A. Maine
Mr. M.T. Canario ISFO I)
Mr. T.J. Voice
Respectfully yours,
VEMmENT OF HEALTH
Frederick A. Siino
Assistant Director for Consumer Protection
Chief - Division of Food Protection
and Sanitation
-------
John A. S. McGlenriori
Page 2
7 August 1975
I implore EPA to approve Alternate "B" as described
in the draft Environmental Impact Statement which includes
the sewer and treatment plant as proposed on Stage I, ex-
clusive of the sewer in Stage II.
Yours very truly,
seph E. Cannon, M. D
Director of Health
JEC:CAM:nab
cc: Guy V. St. Andre
Frederick A. Siino
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Office of
TOWN CLERK OF NEW SHOREHAM
Town Hall
P. O. Drawer 220
TOWN CLE« Block l8IAND. r. I. 02807 telephone:
Edith Little field Blamb 401 — 466-2409
April 16, 1975
Mr. Wallace E. Stickney
U. S. Environmental Protection Agency
J.F.K. Federal Building
Boston, Massachusetts
Dear Mr. Stickney:
The Town Council of New Shoreham has directed me to address
this letter to you to lay before you the basic facts concerning
the Block Island Sewer Project so that you will know the
judgment of Block Island's governing body.
The members of the Council are unanimous in their wish that
construction of the entire system go forward as quickly as
possible and exactly as planned by Keyes Associates, whose
specifications have the Council's complete approval. The
proposed extensions to the system can be left to a later date,
if future need requires them.
The Town Council here wishes to deal with th« doubts set forth
in the environmental impact statement regarding the advisability
of extending the sewer to the New Harbor area. The troubles
this part of the Island is experiencing with over-loaded
septic systems are as extensive and compelling as those that
beset the Old Harbor area, and it is vital to the health of
the Island and to its faltering economy that they be also
corrected by a municipal sewerage system.
It is true that the New Harbor area is in use mainly in the
summer months, but during those months, this area is host to
unnumbered visitors. The ferry from New London brings up to
500 people each day from mid-June until early September; as
many as 600 yachts tie up or anchor in the harbor over busy
weekends, each yacht bringing from two to 10 people. In
addition, the three marinas with their restaurants and other
facilities, the Narragansett Hotel and rooming houses in the
area, Dead Eye Dick's and Smugglers' Cove eating places all
draw crowds from other parts of the island.
Because the deplorable lack of a sewer does not permit it,
there are no public toilets in this area, and in consequence,
the toilets that are available to the public are strained
far beyond their capacity.
14
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Mr. Wallace E. Stickney
U.S. EPA - April 16, 1975
Page 2
As Mr. Mott made clear at the Health. Department meeting on
1^ April, he and the other New Harbor property owners have,
within the last two years, installed new septic systems —
the best they could construct--yet all are now over-loaded.
The disposal fields of Dead Eye Dick's and Smugglers1 Cove
restaurants are in small traffic-impacted areas, and there
is absolutely nothing that can be done to prevent the
effluent from flowing into the harbor.
The Council takes sharp issue with the EPA's statement that
there is plenty of land for good septic drainage--the basis
for the recommendation that this part of the Island not be
sewered. This is simply not so.
The area is close to sea level and marshes cover a good part
of it. The land at Champlin's Marina lies somewhat higher,
yet even here the one public laundry on the Island had to be
closed.by the Health Department because the ground was
saturated.
The tourist season is short and the economy of the commercial
operators is fragile. A hurricane or other calamity could
ruin their season, and to expect them to do more than they
already have—and more would be an exercise in futility--
would strain their finances to the breaking point. To deny
them the government help that will be available to the
establishments in the Old Harbor area would be a grave injus-
tice and a penalty they cannot bear.
The Council therefore hopes that the EPA will weigh these
facts carefully in arriving at its final determination.
Thank you very much.
Very sincerely,
Edith Littlefield B>
Town Clerk '
ELB/b
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BLOCK ISLAND SEWER COMMISSION, BLOCK ISLAND, R. I. 02S07
April 22, 1975
Mr. Wallace E. Stickney
U. S. Environmental Protection Agency
J.F.K. Federal Building
Boston, Massachusetts 02100
Dear Mr. Stickney:
As Chairman of the Sewer Commission I was pleased to meet
with you and your delegation a few days ago.
I had just received the draft of the Environmental Impact
statement from the Environmental Protection Agency #1. I
have since read it over carefully and it is a large book
written rather well in its entirety using various materials
gathered from other fields. However, there is not much new
in this E.I.S. which most of us didn't already know and some
chose to ignore.
One method was to sewer the Old Harbor only as it was thought
that this area was more contaminated than the New Harbor and
we were advised that we could write you or give other sug-
gestions at the Block Island hearing with the E.P.A. here on
May 10th.
The Native Block Islanders have known about the dangers of
contamination at the New Harbor as well as the Old Harbor
for years but three or four newcomers to the Island have
chosen to ignore this matter.
The Block Island Sewer Commission as well as myself as an
individual have recommended the Keyes Associates Plan since
the very beginning as well as the Town Council and they
still do now.
We do hope you will help us with our Sewer Plan so we can
start soon.
Sincerely,
Samuel D. Mott, Chairman
P. S. At a public hearing last August held by the Sewer
Commission, 80$ of the people were for the Keyes Plan.
The details of the plan as explained to them at that time
are enclosed.
J
n*.
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OFFICB OF
THE FIRST WARDEN
TOWN OF NEW SHOREHAM
BLOCK ISLAND, RHODE ISLAND 02807
April 22, 1975
Mr. Wallace E. Stickriey
Environmental Protection Agency
J.F.K. Federal Building
Boston, Mass. 02203
Dear Mr. Stickney:
My position of First Warden of Block Island for the past
four years has enabled me to have an overview of the
situation regarding our proposed Sewer Project that is
second to none because I am in the center of the controversy
that has embroiled us since we took our first step towards
the construction of this vitally needed facility.
The people of Block Island, whose income is the smallest
of any in the State, would never have burdened themselves
with such a debt as the sewer will impose if they did not
know that Block Island's very life depends upon sewering
the entire commercial area of the Town.
Two issues came to light at the hearing on ih April in
Mr. Maine's office: That there is sufficient land available
in the New Harbor area for disposal fields; and that to
sewer that part of the island would bring unwanted growth
in its wake.
No evidence supports the EPA's claim that there is land
available for drainage; and Mr. Mott's statement that new
septic systems serving the Narragansett Hotel and two
nearby restaurants are already over-loaded bears up our
long-held contention that sewers are the only answer to the
pollution problem in that part of the island.
The second issue—secondary growth--is Block Island's
problem to deal with, and that it most certainly will.
Block Islanders are very much aware of the fact that their
home is a priceless jewel—fragile, and easily destroyed—
and if our zoning laws prove inadequate to protect it, we
plan to seek other means. These include declaring the
island a national park and taking such measures as are
inherent in the proposed legislation affecting our sister
islands of Nantucket and Martha's Vineyard.
-------
Mr. Wallace E- Stickney
EPA - April 22, 1975
Page 2
The EPA's concern for our future is no greater than ours,
and it is comforting to know that so prestigious an agency-
shares our fears.
Unwanted growth we must, and sha.ll, deal with; but the sewer
is of such compelling importance that there is no other
solution than to build it--completely and as quickly as
possible.
To discriminate against the New Harbor property owners in
their heavily-threatened area by denying them the government
funding available to those at the Old Harbor would be
manifestly unfair and an incalculable hardship.
This letter reflects the feelings and the wishes of the
great majority of the people who live and work on Block
Island and whose health and well-being hang in the balance.
Very sincerely, ^
Herbert S. Whitman
^irst Warden
cc: Richard Pastore
HSW/b
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SCHOOL DEPARTMENT
New Shoreham, R. I.
(Block Island)
Phone 466-2251
Office of the Superintendent
SCHOOL COMMITTEE Thomas McCabe
Everett R. Littlefield, chairman
Sandra M. Gaffett, clerk
Carol C. Brown
Wendy D. Ernst
Mrs. Lawrence Pomeroy
May 2,1975
Mr. Wallace E. Stickney
Environment Protection Agency
UFK Federal Building
Boston, Mass. 02203
Dear Mr. Stickney:
Now that I have properly digested my surprise from reading the Impact
Statement your agency prepared for Block Island's Guidance, I feel I must write
you concerning my discontents.
I have to keep reminding myself that this extremely conservative community
did without emotional appeals or mis-leading propaganda and after considerable
soul searching vote almost two to one to tax itself severely to create a sewer
system which would be adequate for our now and future needs.
The citizens did'nt then or now think of providing for anything more than
slow community growth.
I am particularly shocked by the re commendation that the envisioned system
not include our new harbor area.
I personally dock my family boat at the Block Island Marina and were I barren
and bereft of all intellect my brute senses would tell me that the existing sanita-
tion facilities are woefully inadequate for the stress present usage puts on them.
I can't help but wonder what motivated your agents to issuB their impact
-------
statement. I must, in charity, assume they lacked in expertise.
Sincerely,
c
Thomas McCabe
TMC/bwb
-------
New Shoreham Minimum
Housing Inspector
May 5, 1975
Mr* Wallace E. Stickney
TJ.S .Environmental Protect ion Agency
J«F*K* Federal Building
Boston* Massachusetts 02203
Dear Mr* Stickney*
In the capacity of Hew Shoreham Minimum Bousing Inspector
I wish to report that Z £$£§. studied the draft of the En-
vironmental Xmpaot Statement relative to the wastewater
collection and treatment faollity of New Shoreham, R.I,
and find many erroneous statements and gross inaccuracies*
A sample of the inaccuracies are as follows*
1. Page X of Summary, * Before final approval of the
project, Blook Island residents brought their key Issues
to the direction of the Regional Administrator". Blook
Island residents did not cause this action* Zt was in*
stigated by a limited few noa resident property owners
who are members of the Blook Island Residents Association,
who certainly are not qualified to speak for the Block
Island people*
2m Page XI of Summary-last paragraph, the report ment-
ions ° On the other hand, Viw Harbor has enough land and
suitable soil for existing development to rely on subsur-
face disposal systems9' Hot true - Recently a reproeenarlvo *&******»r>»V
from the R*I* State Water Pollution Control eame to the
Island to make percolation tests at varftous looatlons in ^
the Hew Harbor area* He personally made four (4) tests, ut
three (3(of which were negative* The other which was ac-
cept able is too olose to an existing spring*
3. Page 2 of the Report - reads as follows, ¦" The higher
cost of the treatment system sparked a new oitsen aware-
ness causing considerable controversy about the ptojeot**
Hot true - The oltisea awareness was the outory of the B*I*
Residents Association, not the cltlnens or residents of
Blook island*
4* Page 4 of the report - Although this fact any be tri-
vial it is an indication ofthe many misstatements la the
report, "Fashionable hotels and Plush golf oourses*'* The O
hotel faet is acourate but to ay knowledge there was only
one golf course and that one was not exactly plush*
-------
5o Map opposite page 24 shows a dense residential zone**
Commercial. It is in the North Area, in the residential sone
and where only 1 house is located*
6* Page 67 - Again states *the general availability of
amenable soils and sufficient land in New Harbor to faolll*
tate subsurfaoe disposal technique" • Not feme • as referred
to tests in previous paragraph 2 of this letter*
7* Page 48 • States that " present zoning does not re*
strlot building heights in the business eones or hotel heights
in other zones where they are allowed by special permit8•
A close study of the New Shoreham Boning laws will prove
this to be a false statement*
8* Page 54* A paragraph states that * the only possible
solution to failing systems is to oonvey the waste to ad*
Joining properties"* This appears to be a ridiculous approaoh
Adjoining property owners would never condone sueh a proposal*
Based on my experience in servicing the problem areas of
New Harbor I am firmly resigned to the faot that not sewering
this area would be detrimental to the whole project*
These are seme of the obvious inaoouraoles in the report
and I appreolate your patienoe in reading my reflections on
the report *
Very truly
Robert L. Bldrldge
Minimum Housing Inspeotor
New Shoreham* R.I.
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TOWN OF NEW SHOREHAM
BLOCK ISLAND, RHODE ISLAND 02807
office of May g, 1975
THE PLANNING BOARD
Mr. Wallace E. Stickney
U. S. Environmental Protection Agency
J.F.K. Federal Building
Boston, Massachusetts 02803
Dear Mr. Stickney:
The Planning Board of the Town of New Shoreham has reviewed
the preliminary EIS carefully and has held several meetings
to co-ordinate our thoughts in order to make an intelligent
response to its recommendations.
At the outset, let us say that we favor Alternative B as a
sewer plan for Block Island, thus serving equally Old
Harbor which must toe sewered immediately, as well as New
Harbor, whose condition is rapidly approaching that of Old
Harbor.
We were particularly interested in the three key issues
brought to the attention of EPA (page 4) by Block Island
"residents". If these so-called residents were summer
colonists only, their knowledge of, and interest in, the
problems of Block Island are limited by their brief tenure
here. If, on the other hand, they are persons living year
round and making a living here their opinions would have
quite a different bearing.
At no time did EPA make any attempt to meet with, or even
contact, the New Shoreham Planning Board to discuss any of
the issues contained in your report. No other official body
of the Town is so intimately concerned with the accelerated
growth of building, etc., in any areas of the township as is
this Board. No one asked us, for example, for an explanation
of our Comprehensive Community Plan. This plan is not in-
flexible; it is intended to serve as a guide for meeting
circumstances to the extent that they can be foreseen, with
periodic updating to meet changing conditions. At this
moment we are working on a major revision of the master plan,
with the help of concerned citizens of the town who comprise
a Citizens Advisory Board. We have great hopes for a new
and much more comprehensive blueprint for the future. It
is therefore fruitless for EPA to have quoted from the CCP
as it now exists, and as if the plan had come down from Sinai
on the Stone Tablets.
For example, on page xi your report recommends sewering Old
Harbor only and cites the Block Island Master Plan as being
-------
Mr. Wallace E. Stickney
E.P.A. - 5/8/75 - Page 2
generally in agreement with that conclusion for the purpose
of maintaining Block Island's rural character. We do indeed
wish to maintain a rural atmosphere but recognize that certain
areas must be developed as business properties in order that
the Island as a whole may live. New Harbor was definitely
included as an area to be sewered in all of our planning
procedures.
Also on page xi you state that New Harbor has sufficient
land for subsurface disposal systems. This is absolutely not
so and we believe that recent tests by the R. I. Department
of Health will substantiate our claim. Also, an analysis
of land ownership in the New Harbor area indicates that many
businesses do not own sufficient land of the type that would
sustain adequate septic systems. Although there is some
land in the area, what does a business do if it does not own
it? Will this not force people out of business?
As a further comment on the use of subsurface disposal systems
(see page 5^ "Technical") crushed rock (-§- to ly") must be
barged to Block Island if it is to be obtained in sufficient
quantity to build septic systems under State specifications.
The cost of a barge and tug for a round trip to Block Island
is approximately $1500. This, plus the cost of the material
delivered to a shore site in Rhode Island and loaded on the
barge, then offloaded at Block Island and delivered to the
job site, makes the cost of crushed rock approximately $45.00
per yard at 1975 prices. As the average home system requires
approximately 35 to 40 yards, you can easily see that septic
systems cannot in any way be considered relatively inexpensive
On page 24, EPA states that Islanders have not addressed the
problem of how much and what kind of development can be and
should be permitted to occur on Block Island. Let us hasten
to assure you that such debate continues at every Planning
Board meeting--often at the Zoning Board of Review meetings,
and at the meetings of the Town Council.
On pages 25 and 26 much is ma.de of growth and its effect on
the Block Island atmosphere. We very much need the sort of
growth which would provide a few of the amenities taken for
granted in other communities--a pharmacy, a barber shop, a
dry goods store, a shoemaker,a garage for auto repair and
vehicle inspection, a laundry and dry cleaner, just to name
a few. We could also use a business, such as a light manu-
facturing plant, to provide at least a small portion of our
population with a year round income. We could use at least
the equivalent of the hotel and boarding house rooms that
we have lost due to fire and hurricanes, and that have closed
due to lack of sewer facilities.
It may interest you to contemplate the attached list of hotels
and boarding houses. It will give you some idea of the
-------
Mr. Wallace E. Stickney
E.P.A. - 5/8/75 - Page 3
numbers of people who vacationed here in the 1920's and 3P's
(not so long ago) and we didn't feel they overcrowded us,
We also had several large steamers from Providence and New
London whose capacities varied between 1000 and 2000 persons.
These boats arrived here every day loaded with passengers and
we didn't suffer from it.
Growth is not a dirty word with us. A certain amount of
properly controlled growth is natural and must be planned for
We have a functioning planning board and zoning board and an
active, alert Town Council. These bodies have been vigilant
to preserve and protect the unique quality of Block Island,
both ecologically and economically. State and local laws
protecting the natural assets of the Island have been enacted
and heeded in all instances and will continue to be imple-
mented. On page 48 you indicate there is no height restric-
tion on the business zone nor on hotels in other zones.
This is not so. On page 50 you remark on the dangers of
development (through beach houses) on Corn Neck Road. We
call your attention to the fact, clearly outlined in our plan
that the entire area is all beach zone and restricted from
building.
On page 53 (third paragraph) your report discusses holding
tank pumpout facilities. It is our understanding that the
federal law requiring holding tanks on boats has been
temporarily suspended, but i6 to be fully implemented in the
foreseeable future. You point out that there is room at the
landfill site to dump this material, providing the marinas
can get it there. But it must be treated by a costly method
before it can be dumped. This doesn't sound too sensible
to us, and certainly makes EPA's preferred alternative D an
unwise course of action.
And speaking of the town landfill site of 23 acres which you
mention in several pages of your report (pages 17 and 53» for
example), we are not aware of any such facility. What we
are aware of is that the Rice Construction Company owns
23 acres of land on the West Side at the spot you indicate,
on which they have obtained clearance by the State Health
Department to dump septage. There is no agreement with the
Town for permanent use of this facility as it is a totally
private operation. We do not think any EPA projection can
properly be based on the use of this private facility.
As to the adverse effects on adjacent beaches of the outfall
pipe, let us state first that adjacent beaches are not
really beaches but piles of boulders which can hardly be
walked on without breaking one's limbs. The water is
-------
Mr. Wallace E. Stickney
E.P.A. - 5/8/75 - Page k
undeslreable for swimming due to shifting rocks, dangerous
breakers, and general discomfort. No boats can approach
closely as the waters are too dangerous, and the seals, God
bless them, for all we know now may actually like the outfall.
If they don't, perhaps they would join their cousins on the
North End.
We would like to comment in regard to "key issue"No. 3,
"possible adverse effects of locating a wastewater treatment
plant in a designated National Historic District", that we
feel with Mr. Richard Allen Dow, Executive Director, Historical
Preservation Commission, that the construction of the treatment
facility is in the best interest.of historical preservation.
We have briefly expressed herein our views on the three "key
issues" and have treated them, we believe, in a manner that
must be convincing. We have pointed to but a few of the
many errors we note in the preliminary EIP. There are many
others but we feel there is no point in belaboring them.
We are certain that the Block Island people are wiser than
those who object to the sewer on the grounds of the three
issues mentioned above. On July 27, 1972, the vote for a
bond issue to build the sewer was overwhelmingly in favor
of the project (292 approve; 121 reject). Again, a straw vote
taken by the Sewer Commission at a public hearing held on
August 29, 197^ at the Empire Theatre, was four to one in
favor of the sewer--not half a sewer, mind you, but the Old
and New Harbors completely sewered.
The Planning Board doesn't have to spend one-half million
dollars to know what the impact of no sewer in New Harbor
will be. We have good common sense, and we can recognize
that delaying tactics of the most blatant kind seem to have
been used to prevent this town from proceeding with a major
improvement desired by the majority of its citizens.
It is an unhappy sight to see the EPA, knowingly or unknow-
ingly, assist the sewer opponents in this extremely expensive,
utterly debilitating experience. It is saddening and
baffling to observe a government agency of great power, set
up to assist communities in their desire to improve the
quality of the environment, being used to thwart that very
type of improvement.
The effect of these delays has been to raise the price of
the project to the most alarming proportions, to say nothing
of the very immense financial strain imposed upon the com-
munity in contending with these tactics; and it doesn't
change our need for the sewer one jot.
-------
Mr. Wallace E. Stickney
E.P.A. - 5/8/75 - Page 5
The Planning Board is unanimously convinced that a sewer,
to be effective, must include New Harbor as well as Old
Harbor. New Harbor will continue to grow and no restrictive
measures or' lack of improvements will stop that development,
but rather may well force it out of control. We should
like to see the Great Salt Pond (a man-made asset, by the
way) remain clean and beautiful--a source of food, recreation
and visual beauty for all time.
Very sincerely,
WM.liam R. Transue
SHOEEH^Jf PLANNING BOARD
—j Chairman
Vice Chairman
Eileen L. Lee
/John R. Lewis
D. Mott
Member
Member
Secretary
Attachment
bis
-------
LIST OF HOTELS, ROOMING HOUSES, BOARDING HOUSES, RENTAL
COTTAGES & APARTMENTS
Presently in
Use
HOTELS
Spring House
Narragansett
Royal Hotel
Surf Hotel
Ballards Inn
Highview Hotel
l66l Inn
Gables
Atlantic Inn
Limited Use
National Hotel
Eureka Hotel (summer
help use)
Bellevue
Vaill Hotel
************
ROOMING HOUSES
Perry Cottage
Old Town Inn
Old Harbor Inn (City Drug)
Historical Society
New Shoreham House
Wayside Inn
Blue Dory Inn
Driftwood
Closed or gone
Highland House (gone)
Highland House Annex (Skarden Hse.
Ocean View Hotel (gone)
Shamrock Inn (empty)
Union House (gone)
Windsor House (gone)
Crown Hotel (gone)
Hygeia Hotel (gone)
Manisses (being restored)
Block Island Inn (now a tavern)
Adrian (now a church)
Solviken (closed)
West Hillcrest (private home)
Beachcomber (closed)
Sunnys ide (gone)
Bridgegate House (private home)
Continental Inn
Mitchell Cottage
Sheffield House
Pilot Hill House
Block Island Inn
Central House
Bridgeton House
Allendale
Longue View
Barrington (private home)
Lakeview " "
Star Cottage " '•
Oradell
Summit House
Allen Cottage
Smith Cottage
II
" (S.E
fl
fl
tl
-------
Presently
in Use
Limited Use
List of Hotels, etc. - Page 2
Closed or gone
BOARDING HOUSES
*********
APARTMENTS & RENTAL COTTAGES
Twin Maples
Neptune House
Cuttings Cottages
Mill Pond Cottages
Tiny-Barb Cottages
Cyr's Sea Breezes
Negus Cottage(private home)
Cottage Farm (private home)
Poplar Cottage (gone)
Sam Hayes Cottage (private home)
Bayside (private home)
Breakers " "
Sunnyside
Maxfield"s " 11
White Cottage (private home)
Dodge Cottage " "
New Haven House
Red Gate Farm
Sunset View
Noah Dunn House
Chapel Cottage
James Murray Cottage
Bonanza
Harborview
Gov. Gorton Farm
Sea Breezes
NOTE: It is estimated that most boarding houses accommodated 25-35 persons, using
neighboring private homes to care for "overflow". Large hotels, such as the Ocean
View and the Hygeia could accommodate 350 or more persons.
-------
Block Island Republican Town Committee
BLOCK ISLAND, RHODE ISLAND
May 13, 1975
Mr. John A. S. McGlennon
Regional Administrator
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. McGlennon:
The Block Island Republican Town Committee would
like to advise the Environmental Protection Agency
that the committee; by a majority vote, favors the
adoption of Plan B, as shown in the Preliminary E.I.S., Fenton
Keyes plan for sewering both Old and New Harbor without imple-
menting Phase II. We believe that this alternative is the
best one, environmentally and economically, and that basically
it is the plan favored by the majority of Block Island citizens.
By citizens we mean those who have Block Island's best interests
at heart; not their pocketbooks.
We won't make detailed comment or criticism of the Environ-
mental Protection Agency's preferred recommendation except
to say that sewering half of the pollution threatened area
makes very poor sense both ecologically and economically.
New Harbor will eventually have to be sewered or the Great
Salt Pond will be lost as a source of food, recreation and
visual pleasure. It needs to be done now.
We would like to point out that the issue is not partisan
in the political sense - Republicans and Democrats have
joined forces to work for Block Island's wastewater treat-
ment system. However we do feel that responsible Republican
leadership by the Town Council of New Shoreham has been
shown and that a statement of support by the Block Island
Republican Town Committee is in order.
We trust that the Environmental Protection Agency has been
enlightened by the May 10th public hearing. We were.
Respectfully yours,
Adrian L. Sprague, Jrf,
Chairman
Republican Town Committee
ADRIAN L. SPRAGUE, JR.
Chairman
MRS. JOHN F. THOMAS
Vice Chairman
HERBERT S. WHITMAN
Secretary
MRS. ADRIAN L. SPRAGUE, JR.
T reasurer
LINUS E. DODGE
Honorary
MRS. EDWARD J. BLANE
ALVIN L. ERNST
JOHN F. GRAY
MRS. JOHN J. LEE
KEITH A. LEWIS
LESTER L. LITTLEFIELD
THOMAS C. LITTLEFIELD
GEORGE G. Ml LLI KIN
ARTHUR F. ROSE
ELLIOT F. SANFORD
MRS. STANLEY R. WIGGINS
ALS/b
-------
BLOCK ISLAND RESIDENTS' ASSOCIATION, INC.
POST OFFICE BOX 520
BLOCK ISLAND, RHODE ISLAND 02807
May 17, 1975
Plr. John A. 5. Mc Glennan
Regional Administrator
Environmental Protection Agency
J. F. Kennedy Building
Boston, Massachusetts
Dear Mr. Mc Glennon:
As Secretary Pro Tern of the Block Island Residents' Association,
I feel it necessary to add facts to answer some of the extraordinary
biased statements made about B.I.R.A. at the May 10th E.P.A. hearing
on Block Island, which was so well conducted by your staff.
1. Mrs. Self's statement that B.I.R.A. had continued using her name
after she had resigned. She neglected to say she lived in Mexico
six months of the year and constantly complains about not receiving
mail. The B.I.R.A. post box is opened daily and mail processed by
two responsible members -- Mrs. John Ryan and Mrs. Henry Hutchinson.
B.I.R.A. was unaware of the Self resignation letter until three weeks
after Mrs. Self arrived on the Island. Her letter still has not been
received. But her resignation was quickly accepted by the Board of
Directors.
2. A complaint by Mrs. Kaupe about voting procedures at the 2nd
half of our August Annual Meeting. Uie were aware there might be
controversial subjects voted on and we needed to know accurately
the membership's thinking on B.I.R.A's continuation of its Sewer
Fact-finding Committee. Thus, it was decided to issue colored
voting cards to each qualified member. Mrs. Kaupe attempted to
obtain two additional voting cards for her parents, who were not
B.I.R.A. members. Her demand did not comply with the by-laws'
definition of family membership and was not granted.
3. Neither the BI.R.A. Board of Directors noft 100$ of the member-
ship is in complete agreement on the Fact-finding efforts of the
B.I.R.A. Sewer Committee. After all, Mr. Mott and Mr. Whitman on
the B.I.R.A. Board are a vocal minority voice. This is normal in
any organization. Members such as Mr. Abeshouse, who spoke against
B.I.R.A., no doubt wishesB.I.R.A. would cease its fact-finding and
dissemination of information on sewer facts. Mr. Abeshouse for
some time has had plans filed to subdivide into plots his land.
Until there is a massive municipal /sewer, his plans cannot be realized.
4. Membership strenqth and makeup. Membership has grown by
twenty-five percent since Mr. Connolly became president. There now
are Island residents and property owners of stature expressing keen
-------
- 2 -
BLOCK ISLAND RESIDENTS' ASSOCIATION. INC.
POST OFFICE BOX 520
BLOCK ISLAND, RHODE ISLAND 02807
interest in Board membership, tuhereas a year ago B.I.R.A.'s Nominat-
ing Committee could not find six people to serve and presented an
incomplete slate at the Annual meeting. Nominations and votes From
the floor put on our Board a core of experienced, concerned citizens.
Mr, Gill. brother-in-law of 5am Mott, inferred at your hearing that
B.I.R.A. represents hotel residents. This statement first appeared
in print in Mrs. Self's-edited 1974 Block Island TimBS. We then
analyzed our membership and discover"ed~t1TaT~over~9^tr*of our members
own property or are members of families uiho own property. Some
15.5?? of 8,1.R.A. live on the Island year-round (which is the percent-
age of actual year-round to Summer residents). And our membership
represents more than 5b% of the taxable property on the Island.
Only one member has resigned (after joining the previous week), and
letters and telephone calls to the President have bean uniformly
supportive.
In July 1974, 0.I.R.A. membership was 300 family members (2 votes each).
Today the membership is exactly 461. Unpaid members are 62, of which
we estimate 10 will not renew. This group includes Iflrs. Self, her
son, and F. Albert Starr, '[fir. Whitman and Wr. Watt are paid up and
in good standing.
5. Polling the membership. At the July 1974 nim 1 meeting, the
vote was almost unanimous that the President appoint a fact-finding
sewer committee. At the 2nd half of the Annual Meeting in August '74,
a vote again was taken and a significant majority supported B.I.R.A's
continuation of its Sewer Fact-finding Committee. Then 3.I.R.A.
immediately was sued by Mr. Ufhitmab and the Town Council to challenge
its leadership. The Court granted a re-election of eleven members
of the Board in October 1974 by ballot. All Board members were re-
turned to office and Iflr. Connolly polled more votes than (fir. Whitman
normally receives in a general election for Town Council.
6. While a concerted effort was made to discredit B.I.R.A. at the
E.P.A. hearing, it was impressive to note that Mr. Whitman at the
conclusion of the meeting, stated members of the Town Council, and
the Sewer Commission would meet with 3.I.R.A. in the hopes of
compromise on sewer matters.
3.I.R.A. always has been ready and eager to meet and discuss sewer
facts — although it has had to dig hard and long to separate fact
from fiction, or even get for the public any indication from officials
on what actually is planned.
Now Dr. Pic Ginnes and Mr. Ringen (who has served on a sewer commission
on the mainland) meet periodically with soma of these officials.
The two have volunteeriAto work with Mr. fflott on methods of sewer
financing.
Everyone we speak for in B.I.R.A. are dedicated individuals interest-
ed only in the best interests of the Island. It is the definition of
"best interests" in which disagreement arises (more bitter perhaps
by those who have more at stake financially). Let us hope that E.P.A.,
in its more objective and professional rolef can firmly point to the
right direction. (^^/iolettj^ l^r^Connol^, B.I.R.A. Secretary Pro Tem
-------
BLOCK ISLAND RESIDENTS' ASSOCIATION
P. O. BOX 520
BLOCK ISLAND, RHODE ISLAND 02807
May 23, 1975
Mr...John A.S. McGlennon. Reg, Admn.
u.S, Environmental Protection Agency
JFK Federal Building
Boston, Mass. 0Z2u3
My Dear Mr. McGlennon:
As indicated in our telegram , we are
requesting an additional 30 days in which comments may be filed
WITH YOUR OFFICE ON THE DRAFT IMPACT STATEMENT FOR BLOCK IS-
LAND* Reason for this request essentially is that numerous
B.I.R.A, members and/or Board members business commit-
ments AND TRAVEL HAVE PREVENTED THEM FROM FILING APPROPRIATE
COMMENTS, WHICH THEY WISH TO DO,
IT HAS BEEN BROUGHT TO OUR ATTENTION, BOTH
FROM THE PRESS ACCOUNTS AND STATEMENTS ATTRIBUTED TO TOWN
Officials, that a so-called compromise has been or is about
to, reached on the proposed sewer for New Shoreham* unless a
signed document reaches your office with the signatures of the
town's -irst Warden, Sewer Commission Chairman and the president,
of the Residents7 Asso. there is no compromise in effect. B.I.R.A.
continues to support the EPA s evaluation on growth potential
AND ITS DECISION RELATIVE TO THE OLD HARBOR DISTRICT.
In MY OWN COMMENTS TO BE DIRECTED TO YOUR
OFFICE, WE WILL ENCLOSE A LIST OF B,I.R.A, MEMBERS WITH ADDRESSES.
TO THE BEST OF OUR KNOWLEDGE, ONLY TWO MEMBERS ON OUR ROSTER
OF OVER 900 ARE NON-PROPERTY OWNERS AND WILL BE SO INDICATED.
WE ARE AWARE OF A LOCAL MOVEMENT FOR A NEW REFERENDUM ON THE
OVERALL SEWER PROPOSAL, ESPECIALLY IN VIEW OF THE POSSIBILITY OF
no State aid after the late June State bond referendum. B.I.R.A.
IS CONSIDERING ITS OWN INTERNAL REFERENDUM SHOULD THE TOWN RE-
FUSE THE ELECTORATE AN OFFICIAL REFERENDUM.
. We continue to support EPA in its efforts
ON BEHALF OF BLOCK ISLAND.
SiNCERE^T)
C CoNNOLL
'RESIDENT
-------
TOWN OF NEW SHOREHAM
BLOCK ISLAND, RHODE ISLAND 02807
OFFICE OF
THE PLANNING BOARD
May 30, 1975
Mr. Wallace E. Stickney
U. S. Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. Stickney!
The New Shoreham Planning Board wrote to you on May 8, 1975»
expressing our belief that Alternative B as outlined in
your Preliminary Environmental Impact Statement, is the
only correct solution for Block Island's sewer project.
The Planning Board attended the E.P.A. hearing on May 10th,
and after listening with care to the testimony presented
by inhabitants and summer residents of the town, we find
ourselves all the more firmly in favor of Alternative Plan B.
So far as we: could determine the Block Island Residents'
Association president's statement was without content
except for an unreasonable and unworkable proposal for the
sewering of Old Harbor (cost to be borne by the Old Harbor
users). All other evidence we heard was largely on the
subject of the cost of the sewer and who pays for it - not
the need for the sewer.
We feel that E.P.A. must and will come to the same conclusion
that we have - namely that the sewering of both Old and New
Harbors is mandatory for the continued health and wellbeing
of Block Island's people and their environment.
We are confident that your decision will be in favor of
Alternative Plan B. There really is no other choice.
Very sincerely,
William R.JTransue
Eileen L. Lee
Jx>hn R. L
/ jTfzFT
Member
Member'
Secretary
-------
TOWN OF NEW SHOREHAM
BLOCK ISLAND, RHODE ISLAND 02807
OFFICE OF
THE FIRST WARDEN June 2, *75
Mr. Wallace E. Stickney
U.S. Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. Stickney:
Transmitted herewith is a resolution adopted by the Town
Council at its tegular monthly meeting on June 2nd setting
forth the Town's desire to implement Alternative plan B
in the Draft Environmental Impact Statement.
At the hearing on May 10th the question was raised on the
number of yachts using Block Island's New Harbor, and
since pollution in this area is of mounting concern to us,
I have compiled statistics that bear on this problem.
The Town maintains a free daily garbage collection service
from yachts anchored or moored in the harbor. The man who
runs the garbage boat keeps a tally of the number of yachts
and of those he collects from. The daily average in 1974
from June 16 to September 17 was 78. This figure increases
over weekends to an average of 113.
In addition to the yachts anchored are those tied up at the
marinas. Champlin's Marina tied up 85 yachts on week days
and 135 over weekends; Payne's Dock 25 on week Says and 75
on weekends; and the Block Island Marina tied up 100 yachts
every day of the week. The weekend average for those three
marinas totals 388, and that figure, added to the average
anchored comes to 500.
Each yaetat brings from two to 10 people, and the larger
yachts bring even more. This is quite a host of people
using the heads on their yachts and/or the toilets at the
marinas. These visitors, of course, also use the shower
and laundry facilities the marinas maintain, and as you
well know, these facilities are strained to their absolute
limit.
It is little wonder, therefore, that we strongly favor
sewering the New Harbor area.
Every other year (this year is one of them) the Storm
Trysail Club bases its activities on Block Island for one
week in June. The club brings about 225 yachts and between
2500 and 3000 people. These figures do not show in those
given above because this club did not come to Block Island
in 1974.
-------
Mr. Wallace E. Stickney
June 2, 1975
page 2
Enclosed for your interest are two post cards taken on
July 4th weekend last year giving you a look at the harbor.
Payne's Dock is at the far right, and you can see how little
land is available for septic tank disposal fields. In the
center is the Block Island Marina whose dark colored build-
ing houses toilets, showers, a small laundry, and a bar.
Disposal fields there are also minimal because the lush
green area on the shore side of the long white building and
to its left is all marshland. Champlin's Marina, at the far
left, fares no better than the other two.
In closing this letter, I want to convey to you that the
Town Council, the Planning Board, and the Sewer Commission
all express their deepest thanks to you and your colleagues
for the really fine job you did at the hearing on May 10th.
It was expertly run, it cleared the air for all of us and
answered many questions; and we fervently hope that the
statements presented served to indicate Block Island's
feelings as to the course we should follow in building our
sewer.
My compliments to you and my warmest thanks for your very
great help to this beleaguered little community.
Very sincerely,
\
Herbert S. Whitman, First Warden
New Shoreham Town Council
HSW/elb
-------
WHEREAS it has been clearly established that Block Island's
fate as a viable community depends upon the sewering of the
entire commercial area, and
WHEREAS it is obviously cheaper and more practical to build
the entire sewer now instead of part of it now and the rest
at some future time, and
WHEREAS the Health Department of Rhode Island has made it
known that the septic disposal situation in the commercial
area is so rapidly deteriorating that if the sewer is not
built soon, Block Island will, because of the danger to the
health of its residents, be compelled to do so, regardless
of cost or other consideration, and
WHEREAS th£ residents of Block Island, although mindful
of the EoPoAo's concern for the possible dangers inherent
in future growth, and grateful to the E.P.A. for this
concern, state that the Town's zoning laws and other devices
will protect it against unwanted growth, and
WHEREAS the draft environmental impact statement on page 61
states that although the E.P.A. favors Alternative D, the
final choice of alternatives is the Town's to make, and that
if Alternative B is the Town's choicejpls acceptable to the
EoP oAo
NOW BE IT THEREFORE RESOLVED that the Town Council of New
Shoreham, its governing body, takes this means of stating
that it truly and unequivocably reflects the wishes of
great majority of Block Island 's residents and taxpayers
in favoring Alternative B, and that it implores the E.P.A.
to expedite the implementation of this wish as quickly
as possible.
Herbert S. Whitman, First W-arden
Attests
fJxM. Xr'Y// Js/.-'a a/a**
Edith Littlefield ^'lane, Town Clerk
-------
BLOCK ISLAND SEWER COMMISSION, BLOCK ISLAND, RHODE ISLAND 02307
Mr. William E. Stickney
U. S. Environmental Protection Agency
J.F.K. Federal Building
Boston, Massachusetts 02100
Dear Mr. Stickney:
The Block Island Sewer Commission has again reviewed the dr*aft
of the Environmental Impact Statement. We think it may help
you to recommend alternate B rather than alternate D by point-
ing out certain errors in the impact study which you gathered
from other sorces who had the wrong information.
First, I don't believe you took any percolation tests at the
New Harbor. The State has recently (I believe last week) come
down and taken these tests and found them unsatisfactory and
they say the sewer should also take in the New Harbor area. I
had brought this out in our meeting in Providence. You can
verify this with Carleton Maine or Mr. Boghosian in the Rhode
Island Department of Health.
Next, I don't believe that you ever tried to check with our
Town Planning Board who could have given you a few definite
facts such as that the New Harbor area and Ocean Avenue area
are zoned for business and also need the sewer. Also, they are
working to revise the Comprehensive Community Plan. In regard
to growth which you mention that we have no restrictions on
building heights, we do have such restrictions in our present
zoning laws of thirty-five feet. We do believe we need growth
in our business area which includes New Harbor but the Planning
Board is working on increasing the lot sizes in other areas to
keep more open space and to provide a more controlled growth.
You also mention a town owned landfill site where we may dump
sewerage. The town does not own it. It is privately owned,
and I don't believe that any real study has been made that it
won't eventually contaminate our drinking water. Also, the
E.P.A. Mentioned in our meeting in Providence that the boats
would probably have to have holding tanks eventually. Most all
of these boats come in the New Harbor rather than the Old Harbor
Without extending the sewer to the New Harbor area, the places
there will be forced to close according to the Rhode Island
Department of Health. What about these abandoned buildings
such as the hotels and restaurants with the loss of these tax
revenues to the town, State and Federal governments? Certainly
the other taxpayers will have to pay higher taxes.
-------
Page -2-
The so called Resident's Association members who have caused all
this trouble are only here for a while in the summer and some
members do not even own land here. The native Block Islanders
who live here year round must make their living here and believe
me, we must plan for an orderly growth including the New Harbor.
On July 27, 1972, the vote on the Bond Issues to build the sewer
for both harbors was 292 approve and 121 reject. Again, at a
public hearing held by the Sewer Commission on August 29, 1973
the vote was four to one for both harbors - not just one - even
though the so called Resident*s Association had held a meeting
opposing it the week before where they distributed false infor-
mation.
Why should we discriminate against the New Harbor when we know
they need it almost as badly as the Old Harbor? Why build half
a sewer when we know the other half will have to be built later
and all the equipment brought back again at a higher additional
cost?
In these days of unemployment, why not put more people to work,
instead of being on unemployment insurance?
Let's try to get on with the job necessary - Alternate B - for
both Old and New Harbors.
Sincerely,
Samuel D. Mott, Chairman
Sewer Commission
Samuel D. Mott, Chairman
Robert L. Eldridge, Vice-Chairman
John A. Corey
Stanley X. Wiggens
Paul A. Filippi
-------
BLOCK ISLAND SEWER COMMISSION, BLOCK ISLAND, RHODE ISLAND 02307
Mr. Wallace E. Stickney
U. S. Environmental Protection Agency-
John F. Kennedy Building
Boston, Massachusetts 02203
Dear Mr. Stickney:
After the Public Hearing which you held on Block Island on May 10, 1975,
it seems obvious to us and should to you that the majority of year round
residents here were in favor of Plan Alternate B - to sewer both Old
and New Harbor areas. Of course there were a few (very much in the
minority) summer cottage people who go under the misleading name of the
Block Island Resident's Association who were against this plan. They
do not seem to grasp the needs of the working people who live here year
round. These working people have to make a living and need a planned
orderly growth. Even without growth, the hotels, marinas, and othere
businesses need the sewer now in ©both harbors in order to survive.
We still recommend Alternate B and are supported by our Planning
Board and the Town Council. We live here year round and have for many
years. We understand our problems better than a few newcomers or sum-
mer cottage people.
In your Environmental Impact State Draft, on page 61 you quote as fol-
lows: "the people of Block Island may feel that their Town's existence
is predicated on the stimulus for development that will be provided by
sewers in the New Harbor." you also state here that "the question of
development in New Harbor, however, is not really a decision to be made
by the E. P. A., but a decision for the Town."
The New Harbor is business zoned as well as the Old Harbor. The Block
Island Sewer Commission not only feels that we do need the sewer at
New Harbor for orderly growth, but also we definitely need it anyway
even without growth as some of the present establishments may be forced
to close.
We feel that we represent the people of Block Island as does the Plan-
ning Board and the Town Council.
We hope in your final Environmental Statement you will see the wisdom
of recommending Plan Alternate B for our town.
S'
Samuel D. Mott, Chairman
Members of B. I. Sewer Commission - Samuel D. Mott, Chairman
Robert L. Eldridge, Vice Chairman
Stanley Wiggens
John Corey
Paul Filippi
Barbara Milner, Sec.
-------
April 14, 1975
Mr. John A.S. McGlennon
Regional Administrator
UoS,,Environmental Protection Agency, Region I
Room 2203, JFK Federal Bldg.
Boston, MA 02203
ATTN: Environmental Impact Office
Dear Sir:
Thank you for your courtesy in sending me copy of the Draft of the
Block Island Environmental Impact Study for my review and comments.
On at least one aspect of your Draft Statement, I claim to be especially
qualified to comment because mine is one of the only two families on B.I.
who live on the bluff overlooking Crescent Beach and mine is probably
the only one with the time and interest to have made a practice of
observing ocean current movements from that vantage point during most
of the summer daylight hours over the past 15 years.
It was for this reason that I took the trouble to write to the E.P.A.
last year, pointing out that, based on my long observation, the planned
placement of the sewage outfall on the east side of the island and
north of Old Harbor Point would probably result in the carrying of
sewage effluent along the Public Beach.
As you may know, the EaP.A. replied that it had already recognized this
possibility and, as a result, had obtained an agreement from the Town
Council that.would require the Town of New Shoreham to extend the
outfall as far as necessary to cure such a condition if, in the sole
judgment of the EPA, it should develop.
But, after reading the Draft Statement, I cannot find any reference of
Such an agreement, or the important reason for it.
Nor, after examining the detailed positives and negatives regarding the
various systems considered, can I find any reference to this danger in
any of the systems analyses.
However, back in the Appendix, I note considerable information that tends
to sustain the EPA (and my own) original concern.
1; OCEAN CURRENT STUDIES (H 3-)
32
H14: "Floats placed at Station 1 moved parallel to the shoreline
all were washed on to the north shore of the near Point."
HI5: "Drogues released at Station 6 moved south but gradually turned
westward as they approached the near point. Once entering the cove area,
the drogues moved northward parallel to the shoreline."
H16: "Drogues plaeed at Station 5 moved northwest and started to parallel
the shoreline."
H16: "Floats deposited at 0900 hours were on shore within nine minutes.
Those dropped at 1020 hours were at Station 1 in six minutes and on shore
two minutes later. Others placed at 1200 hours were on shore innine minutes.'
Of course, the author zigs from this data with the comment (H17) that,
"Their paths were erratic and drogue velocities in this area were not
reliable indicators of current movements." (Underlining, mine75 ~~
But, then, he zags,".....one can expect that anything discharged at that
location under subh conditions would be on the beach in 1 to 2 minutes".
Finally, he concludes,"However, since winds are reportedly (underlining
mine) from the south and west during the late spring,summer and early fall
months, sewage wash may be an infrequent problem during the months of
high recreation use."
-------
Mr. John A.S.McGlennon
-2-
April 14,1975
I consider this a surprisingly inappropriate generalization from an
engineer who admittedly, has gathered other of his basic information
from the Weather Bureau and could easily have examined the daily records
of wind direction for late spring, summer and early fall. These would
have led to a completely different conclusion. They would show that
although southwesterly winds are most frequent during these seasons, they
are not at all routine as the engineer's assertion suggests, but are
frequently interspersed with winds from all the less cooperative
points of the compass.
One final statement by the engineer (H18) that I must note as casting
further doubt on His scientific objectivity: "At no time did a float
or drogue get within 300 meters (1000 ft) of Ballard's Beach." In view
of his previous observations, a careful reader of this Draft Statement
can only conclude that they did not reach Ballard's Beach because they
went ashore at Pebble Beach, first.
2; DILUTION (H40)
This engineer writes, found that it would be desirable to relocate
the outfall in deeper water to increase dilution."
H57: "A diffuser system that is located inside the surf line is
subject to widely varying hydrodynamic forces, most of which are adverse."
H57; "The surface plume, when caught in a surf would experience high
velocity which would be guaranteed to be shoreward in. direction, and
dilution would be significantly reduced."
H57: "The following is quoted from Bfooks (2) pp 262:
'The [prediction of the eoliform count in the surf jgpne presents
an added difficulty because of the littoral draft upwelling of bottom
water, and the less rapid flushing in the shallow region very close
to shore. Because of these effects, the shore count' (of eoliform
bacteria) 'of a given magnitude may be as much as two or three times
as frequent as predicted by the above analysis. The experience of the
Los Angeles County District indicates that the frequency of counts
greater than 10 per mil is greater at the shore than it is offshore.
"Therefore a diffusor located in only 3 to 4 feet of water at only
two hundred feet offshore, and known to be within the surf line
in some current conditions, would not b© likely to produce significant
sewage dilution with a high degree of qjpnfidence. Any site for an outfall
which falls within the surf lines should be considered a poor site."
(Underlining mine) ' "
According to the drogue engineer's report, the surf line ranges from 200
to 1000 feet off shore. And according to previous EPA estimates , ex-
tending the outfall to 1000 ft. could cost in the neighborhood of another
million dollars.
I respectfully suggest that this material from the Appendix in the Draft
Statement, be given suitable presentation in the appropriate main
portions of the final statement. Iw
In conclusion, may I also comment on the following:
"REHABILITATION": In what is otherwise, for the most part,
a reasonably objective presentation, the Draft Statement, has, several
times, referred to the "rehabilitation" of the Old Harbor area as one
of the objectives of the proposed sewer project. Such a referral is
without any foundation in fact.
r
-------
Mr. John A. B.McGlennon
=3=
April 14, 1975
There is no assurance at all that the owners of the near century old
hotels would "rehabilitate" their structures beyond their usual
cosmetic treatments just because a town sewer would relieve them of
the cost of rebuilding their own septic systems. Nor would there be
any economic justification for them to make any major investment to
"rehabilitate". With Block Island's relative inaccessibility and
extremely short season, there is no business incentive for investment
in first class hotel facilities on B.I., with or without a sewer.
Several successful chain hotel, motel and restaurant organizations have
visited B.I. and arrived at that oonclusion.
But a sewer facility would probably attract additional marginal
operators whose investments would be as limited and the quality of whose
facilities as poor as we now have. This kind of "rehabilitation" would
be no benefit to the bulk of Block Island'^taxpayers.
If the final Impact Statement is impartially realistic, it will eliminate
these references to "rehabilitation" and describe the problem simply as
it is: Unsatisfactory septic systems in the Old Harbor area which must
be cured - cured either by a multimillion dollar sewage plant (that
would only serve about 100 people 75% of the year) largely at the non-
participating taxpayers expense; or cured by having the relatively
few hotel owners who are critically affected rebuild their own septic
systems at their own expense (or, in some cases where their land area
is inadequate, with a possible assist from the Town, as described in the
final section of this commentary).
As the tables in the early part of the Draft Statement show, the future
development of Block Island clearly trends to summer cottage development.
These already represent the bulk of the taxpayers, 8f commercial interests
wish to expand on Block Island such expansion is the responsibility
of their shareholders, not the taxpayers, for whom I assume this
costly Environmental Impact Statement is intended.
BQ&TSSS; P.36: The assumption by Fenton G. Keyes Associates
that boaters'Vill spend a majority of time on land", is not founded
on any ascertainable facts. As a boater, myself, my own assumption
would be directly the contrary.
OPERATING COSTS: P.46 and elsewhere. Annual Operating Cost
estimates do not make any itemized breakdown whatsoever. Certainly, the
low total figures quoted cannot include the cost of diesel fuel to
operate the generating plant. Based on the Draft Statement's estimate
of 57,000 gallons per year, at current oil prices, all "Annual Operating
Cost" figures quoted would appear to be drastically understated and,
therefore, fundamentally misleading.
SEWAGE PLANT BREAKDOWN: In addition to the Draft Statement's
appropriate warnings about the potential problems of sewage odor,
exhaust fumes, excessive noise, unsightliness, operating difficulties I
and unforeseeable results due to extreme seasonal variations in use,
need for continuous, competent technical personnel, etc. etc., should -1
not the community also be warned of the degree of risk and the various
possible consequences of plant breakdown on our remote island? I am
reliably informed that a sewer plant not subject to periodical break-
downs has yet to be designed.
-------
Mr. John A.B.McGlennon
-4-
April 15, 1975
SEPTIC TANK COSTS; ; P.55, 1-3 et.al. Costs quoted are
greater than local estimates. Most important, however, is the basic
question of the logic of including these costs at all in any
Environmental Impact Statement supposedly analyzing among other things,
the relative costs to the Community, of the various choices presented
to it for its decision and its tax appropriations. As the EPA has
pointed out in the Draft Statement, these sB6pi;ic tank repair costs
would not be borne by the community but by the private owners responsible
for the original nuisances for which a taxpayer financed supported sewer
system would be only as alternative solution. Since the taxpayers
are not shareholders in the commercial enterprises involved, these
septic tank repair costs would not seem to be the taxpayers' concdrn.
ADDITIONAL ALTERNATIVE: One "alternative" not proposed,(although
broadly suggested on Page 54-, 55, 60)is that the Town provide the means,
by taking ever the needed vacant property, by condemnation if neeessary
and building a connecting sewer line, to give certain Old Harbor hotels
needing it, the necessary area for their own septic tank leaching fields.
One varient might be to buy the National Hotel, demolish it and use
the land for adjacent hotels' leaching fields. This would lake care
of the bulk of B.I.'s waste water problem. It would also allow, at
long last, the elimination of the dangerous curve between the Surf
and the National. This would be a real environmental enhancement on
Block Island.
SUMMARY
I submit that the basic conclusions offered by the Draft Statement:
1: That the waste water effluent will not reach
Crescent Beach (P.42)
2: That Alternatives B and D are preferable to Alternative C
are not sustained by the engineering studies and other factual data
in the Draft Statement.
Actually, the Draft Statement describes Alternative C as "a viable solution"
(P60) and as "simple, relatively inexpensive, reliable and effective
if designed, constructed, operated and maintained properly" (P54).
The only qualifications are (a) lack of available space in the Old
Harbor area (soluble, however, by acquisition of nearby land as
suggested in Draft Statement (P54,55,)and as proposed in this commentary)
and (b) "unattractive secondary impacts" (described, however, as
involving" development pressures, but such pressures should be less in-
tense than those likely to result from construction of a sewer system",
(P56). Moreover (P 53) 'Seasonal use of these systems further enhances
the prospects for their successful use".
I would, therefore, propose that the appropriate conclusions of gh this
Impact Statement should be that:
1: Altlfceratives B and D (and, of course, Alternative A) will
be ugly, noisy and odorous-and financially,ecologically and aesthetically
hazardous due to (a) unknown problems attendant to the unique, extreme
seasonable variations, fb) need for skilled operating personnel at all
times and (c) inevitable of periodic breakdowns.
2: Alternatives B and D will risk polluting Crescent Beach
irretrievably.
3 Alternative C,with an assist from the to acquire adequate
leaching space,will correct the bad sanitary conditions at Old Harbor
without incurring the hazards to the Island of Points 1 and 2 above and
without any cost to the taxpayers. Respectfully submitted,
Carroll HnWpstrom
PO Box # ^Craryvirfle, N.Y12521
3?
-------
April 14, 1978
Mr. Joseph V. Connolly, President
Block Island Residents Assn., Inc.
Box # 520,
Block Island, H.I. 02307
Dear Jos:
1 have just road tho Draft Environmental Inpnct Statement and I think
that I can summarize it in one sentence: It says,"Jfou Block Islanders
aro trying to swat a mosquito with a baseball bat."
JoOj, 1 don't seo how anyono can road that Draft Statement without
holding up his hands in horror that consideration of a socage program
for B.£. ever got as far as it has.
Tfea problsn is: Who is going to road tho Statement? In the first
place, most people would hnva to try to borrow a copy at tha Town Hall
if they wore on tho Island at thia-eolikefcy season. Or make a trip
to Boston! Evoa then, to gat ticao to road it, is a job. Z spent
about 6 hours-
Of course, that's how the se^er program got this far. People just dida'.t
know what was going on. And, incredibly, it could continue to go on*
if people don't inform theme©Ivest
Zt does seem to me that B.I.B.A. has a major responsibility send,
at least, a digest of this Draft Statement to its membership FAST -
so that they can react diract to EPA, to the Town Council (for
whatever that would be worth) or arrange to ba present (or write
or telegsaph B1KA to give their views) at the May 10th meeting.
lly ova digest of th® Draft Statement is as follows*
1: SPA go®© on record as HOff being 4e favor of the lossg
touted Town Council Plan.
2: EPA prefers- either a modified version of substantially
restricted size ~ or a still more drastic reduction to include the
Old Harbor area only, on the basis that (1) there isno present
certainty that there trill ever be any need for holding tank discharge
points at the marinas and (2) a sewage system at the Hew Harbor might
lead to undesirable development there.
3: EPA is less in favor of upgrading the Old Harbor hotels
soptic systems because this would not require EPA money and the hotels
would haW to pay the whole cost. (Frankly, a strange negative to
present to the taxpayer readers of the Draft Statement). Also, becaus®
a few of the hotels do not have enough land to upgrade their systems. (Thi>
is a better argument*, but on the other hand, perhaps the Town could
help provide that needed land at a small fraction of the cost of
a mult&-»illioD dollar sewer system. But BPA does admit that such
septic upgrading youId solve the Old Harbor problem and, at the eSae
tlma„ presaat oavjtgoaaastsl rising than any sewer system
of course, cost the taxpayers nothing.
i: BPA warns that any sewage plant will stink - both from
tjotvage and from diesel fuaas. (Remember tho Power Co. smoke and smell
last summer? It would be doubled - plus the additional sewage and
plant odors in the heart of town •» and wherever the wind blew..
5: SPA warns that any sewage plant will be noisy -> audible,
on a quiet day, for a radius on 1.2 miles.
-------
Mr. J. Y. Connolly
2-
April 14, 1975
6: EPA warns that any sewage plant will be an eyesore and
will need costly landscaping and planting with attendant permanent
maintenance.
7: EPA warns that due to extreme seasonal variations in use.
(500 people residing on the island for 3/4 of the year, but only a fraction
of them on the sewer line, vis. several thousand during the 1/4 year
"season") may face the Town with special problems and extra costs
which cannot be foreseen because there are insufficient precedents for
such a strange project (who else would dare promote a multi-million
dollar sewer system for a couple of dozen hom^s during most of the
year in order to save a few marginal profit making commercial estab-
lishments from having to fund their own septic system upgradingJ J-
8: EPA warns that any plant will need an expert technician
at all times. (Suppose he gets sick or wants a vacation or goes a>
strike for higher pay or quits? Losing a doctor is bad enough, but
you can't fly an ailing sewage plant to the mainland.)
9: EPA warns that it is impractiaal to put the sewage outflow
anywhere but on Pebble Beach, between Old Harbor Point and the Public
Beach, but, the Draft Statement further warns that unless the outflow
is extended beyond 1000 ft. (it is presently planned and cost figured,
at 200 ft) the effluent will not properly diffuse and is likely to
be thrown back on the beach in any but optimum weather conditions.
(EPA previously estimated that extending the outlet to 1000 ft might
cost another million dollars and reported that the Town had agreed to
build this extension if, in EPA's sole judgment, it eventually proved
necessary. This agreement has never been reported to the taxpayers
by the Town Council.)
10: EPA repeats the observation made in Sen. Pastore *s
publicity release: This is only the EPA's opinion. If, in spite this^
Opinion, thetpeople of B.I. choose to ignore the warnings and commit
themselves and their descendants to a debt of admittedly, at this
time, immeasurable multi-millions and substantially higher taxes,
in order to save a small handfull of commercial institutions from having
to correct their own faults at their own expense - which latter move,
according to the EPA Draft Statement, would be more to B.I.'s environ-
mental advantage than any sewer system - that is their privilege. That
choice will be made by the taxpayer who does nothing. Those choosing
to heed the EPA warnings, should make their opinions heard -at EPA,
the Town Council and BIRA and the May 10 hearing.
As you will note from attached carbon of my commentary letter to the
EPA, I have proposed , as a viable additional alternative to any
of the sewage plans, for consideration of EPA (in view of their
opinion that improvement of private septic systems would be environ-
mentally preferable to any sewags program) that the Town take steps
to provide sufficient land, by condemnation or otherwise and, perhaps
connecting pipe facilities, for an adequate leaching field for those few
businesses'and residences that need it,-largely in the Royal, Surf,
Post Office area. One possibility would be for the Town to acquire
the National Hotel, raze it and use the area as a leaching field and
park or parking area - and ease that miserable turn between the National
and the Surf. BIRA might or might not consider this a suitable idea
to support as a constructive solution to an unescapable problem.
Tours truly,
CR:a
Carroll Rheinstrora
-------
Mrs. 12. Paul »u Powt
Moxtchasin, Hkuivware iuiio
April 15, 1975
My dear Mr. McGlennon,
I am impressed and interested by the material which
you have forwarded from the Environmental Protection. Agency
survey at New Shoreham.
While we are not registered voters in the Town of
New Shorehqm, there is a small colony of us here in Dela-
ware who are intensely interested. I have endeavored to
get intelligent and useful discussion of the project and be-
lieve that it is fair to say that we should all prefer a
sewer and treatment plant for the business section, i.e.
Old Harbor, but recognize that the area near the post office,
Historical Society, Paynds Wharf, the Block Island Hotel,
T ransue's Marina, etc. are also perilous.
I am not quite clear as to what is meant by the
Spring Street site, but shall regret using the site as was
once proposed — the cliff above the Old Harbor — for a
treatment plant. It is a beautiful place and should fe kept
for recreation or possibly residential use, even if that in-
cludes the building of a good hotel to take the place of the
Ocean View,
Were it possible to put the treatment plant adjacent
to the State—Town Garage and the electric light plant, using
the pond for the final basin to catch the effluent after
treatment — and so, to the New Harbor — it would be prac-
tical. Would it be possible, then, to service the New
Harbor area, as well as the Old?
-------
Unhappily, the cost and how the system is to be paid
for influence one's honest opinion of what is wise or what
would be useful. It is fair, I believe, that all land owners
and, in fact, those who just use the lodging facilities, should
pay a proportion of the construction costs. Operating costs
should be paid by those who use it.
I shrink at financing the operations of the Royal
Hotel — even the Yellow Kittens — but, still and all, I do
not think they, or even the good Surf Hotel or Blue Dory or
Spring House should pollute the beaches and the Sea around them.
I shall, of course, return the precious manual immedi-
ately if you feel that I should, but I will gladly pay to
have one for myself and those of us who come seasonally to live
at the Parsonage.
On page 46, the proposed cost for the Old Harbor plan
seems to be about $400,000 — a great improvement over the
$4 million involved in the plan of Fenton Keyes Associates,
page XII. The property owners form only a small part of the
Community. Strangely enough, there appears to be no actual
count of those of us who own the land,, but in Winter, the popu-
lation goes down to 400-500, while in Summer, it may be five
times that.
New Shoreham taxes should, of course, reflect a
reasonable part of the cost of the sewer project, even if
the State and Federal Government carry a good part of the load.
Mrs. E. Paul duPont
-------
Block Island, R.I.
April 21, 1975
Mr. Wallace E. Stickney
Environmental Protection Agency
J. F. K. Federal Building
Boston, Mass. 02203
Dear Sir,
It is not necessary for me to use a lot of words to
let you know that I feel we need the sewer project
on Block Island (as plan of Fenton Keyes).
It would be an economical disaster to have it only
in the Old Harbor area.
I have been on Block Island since 1912-owning and
operating Ballard's Inn at the Old Harbor for 37
years-when I sold in 1957.
We certainly need a sewer more extensive than
the Old Harbor area—it is urgent that it include
the New Harbor section.
Yours
Alice L. Ballard (-Mrs. Henry R . )
P.O. Box 4&9
Block Island, R.I» 02&07
APR 2 2 1975
-------
April 21, 1975
Mr. Joseph F. Barone
Barone's Restaurant
Box 572
Block Island, RI
TO WHOM IT MAY CONCERN
In reference to the sewage on Block Island, as a commercial
businessman I feel that we are in desperate need of the sewers.
They mentioned that the sewers would be adequate for Old
Harbor, but you must realize that we also do business at New
Harbor as they bring in tourists for the season to help us with
our businesses.
As conditions are now without proper sewage, we nay not be
able to continue servicing these people that come to the island.
We understand that federal grants only propose sewages for Old
Harbor but even if the sewage was continued to at least the main
roads leading into New Harbor, it would be a help to these busi-
nesses .
I as a conmercial operator feel that we need a complete
sewer system and that prolonging the project only means setting
back prosperity. Hoping you will consider this request, I remain,
Sincerely
OR
-------
Block Island, R.I
April 21, 1975
Wallace E. Stickney
Environmental Protection Agency
J.F.K, Federal Building
Boston, Mass. 02203
Dear Sir,
I have lived on Block Island all of my 65 years.
I think we need the sewer in the New Harbor area
of Block Island as well as the Old Harbor area.
I live in the Old Harbor area and 4&aa±d probably
ray property would be on it, but we need to go on
with this sewer project at onc^, as per the
Fenton K^yes Plan, which includes the New Harbor
area.
Yours truly,
y
^ John F. Thomas
P.O. Box 4&9
Block Island, R.I. 02807
A?R 2 z 1975
-------
Safitiit dfiuicA
BLOCK ISLAND, RHODE ISLAND 02807
REV. W. STANLEY PRATT, Pastor
April 22nd
1975
Mr. Wallace E. Stickney
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Mass 02203
Dear Mr. Stickney:-
I have been following with both interest and dismay the whole
matter of providing for the sewage wastes to be taken care of in
the area of the Old Harbor at Block Island, and through to the New
Harbor as well. There is, I am sure, great misunderstanding as to
the needs that are facing our Island people and businesses of the
Island. As you know, several summer folk who do not reside on the
Island all year have put a monkey wrench in the works, and stalled
the forward movement of this much-needed project for the good and
the safety of the Island.
I am a minister with very limited income, but I know that I
shall have to do my share in taxes eventually to take care of this
problem, so in asking you to look further into this matter, it is
not going to help my responsibility financially. But as a resident
of Block Island, and actively acquainted with it for over a quarter
of a century now, I am getting sick and tried 6f the off-Island
people coming over here and trying to take over the Island affairs
by their shenanigans and their personal self-interests without
regard to the year-long needs of the Island and its health and safety.
May I urge you to look further into this whole matter and see
what is really going on here on Block Island. It seems that a number
of "Off-Island" families have come out here to this beautiful spot
and like it as a way to get away from the rat-race of their regular
mainland experiences. So they want to protect their own self-interests
and keep the Island from being a Vacation place for others to enjoy
by holding back the Sewer Project which is so much needed now. By
doing this, they will force the R. I. Department of Public Health to
shut down the businesses and restaurants and hotels and rooming place®
because the leach-fields of their septic tanks can no longer take care
of the requirments for them to stay in business, unless a proper sewer
system comes in to take care of these needs.
As the Pastor here on the Island, I am interested and working for
the "abundant life"of our people here as residents of the Island, so
they may enjoy the good life as the;y have for some 300 years and
more.
-------
A whole re-thinking of this project needs to be done in terms of
looking at the larger view of what is good for the permanent resi-
dents of block Island, R.I. And this should be done apart from
any political or subtle attitudes of personal selfishness and
self interest of those who only summer on the Island.
May I personally thank you for anything that you may do to
help this situation to be heading toward a solution of the Island
needs
Sincerely your
-------
Editors: Margaret C. Self
Sydney B. Self
BLOBK ISLANi
Box 111, Block Mand, Rhode Island
Telephone 401 -486 - 5518
TIMES
Publisher: Dan's Papers
Drawer AR, Bridgehampton, New York 11932
Telephone 516 -537 - 0500
April 23, 1975
Mr Wallace E.Stickney,
U.S.Environmental Protection Agency
J.F.K.Federal Building
Boston, Mass. 02203
My dear Mr. Stickney,
As Editors of the Block Island Times and, of neccessity,
cognisant of the situation, the reasons for and the objections
to the building of a sewer on Block Island, we were delighted
to receive a copy of your analysis and study of this project.
We would like to make the following comments»
We are pleased that you realize that to leave the situa-
tion as it is at present would be extremely hazardous to the
Island from a sanitary and health point of view unless the fif-
teen or more septic systems now in use and in violation could
be either abandoned or completely redesigned. And that to do
the latter in certain parts of Town would be, at best, extreme-
ly expensive and in many cases impossible due to the lack of
available land for the construction of proper fields for drainage.
We are also pleased to note that the system chosen by Fen-
ton Keyes and accepted by the Town Council is adjudged the most
appropriate for our needs. Also that there is no reason to fear
adverse results from the impact of our sewer on animal or mar-
ine life.
We do note a few inaccurapies, due no doubt to the unavail
ability of more recent resource material than those of 1968-72.
•You state that no young people are staying on the Island. This
was quite true until a few years ago. Now many are settling here
or remaining after having graduated and setting up businesses
of their own. Others take year round or summer work. These busi-
nesses are related to both our present and our future needs and
we welcome these young people^ut.. thej|must have places to live.
Many have to be turned away because houses which would have been
available cannot now be used as the septic systems are not ade-
quate .
We note that you say that there is no restriction on the
allowable height of buildings.Our building code requires that
no building .either residential or commercial, be higher than
-------
35 feet. You also say that the Town, in order not to die, must
"be allowed to grow naturally, but you say that this growth as
far as business goes, should be restricted to properties in the
vicinity of Old Harbor. There is no land (except for one or two
very small lots ) available in this area. Yet the Town has no
barbershop, no hair dressers, no cleaning establishment, no shoe
repair or tailoring shop no drugstore that fills prescriptions and ^
no real department store. At the turn of the century it had all
of these things and today we need them. The obvious place for ^
such small businesses to establish themselves is along Ocean Avenue.
From reading your Impact Statement one g^ins the idea that
virtually all of the tourist activities are concetrated in the
Old Harbor area. You forget that there are several weeks in the
year when marine activities occur ( Block Island Week, Storm Trysail
Week, Tuna Derby Week and special weeks such as the recent Tall Ships
Regatta) and that these activities bring as many a four thousand
people all of whom are based in the New Harbor or its surrounding
areas. Think what it would mean if the Narragansett, Dead Eye Dicks
and Smugglers Cove, the two latter our most popular restaurants
were to close down. All those people would have to travel back and
forth between the two Harbors not once but several times a day.
Finally public facilities to handle the needs of the many
thousands of visitors who get off the ferries or private boats in
both harbors are essential.
We feel strongly that when you say that in all probability
condominiums and new hotels will spring up in the New Harbor area
should the sewer be extended to that point that you are forgetting that
the Islanders who make their living here are just as aware as are
the summer residents that the most important thing we have is our
rural atmosphere and they will certainly not allow anything to spoil
it/ They don't want another Vineyard , they want their Island to
keep its heritage, and because we are protected by an active Zoning
and Planning Board as well as a strict building code, we shall do so.
We therefore urge that Alternative Plan B and not Alternative Plan
D be recommended.
Margaret C.Self Eds
Sincerely yours
-------
Mrs. E. Paul »u Pont
HONTCHASIir, Delawakh 19T10
April 25, 1975
My dear Mr. McGlennon,
I write to ask if you endorse the findings of the Block
Island Residents Association in its summary of the EPA's Environ-
mental Impact Statement. The whole report is tremendously interest-
ing, but almost too complex for the average person to interpret to
a useful conclusion. My neighbor, Mr. Carroll Rheinstrom, whose
house is on the cliff above Scotch Beach, has made a very clear,
an}, in my mind, a very wise digest—and this I also send to you.
Will you endorse it, or make corrections as you see fit. It is
most important that we have a definite rallying point, and our
respect for you for the study makes EPA the leader.
I have tried to do some constructive thinking on my own
part and offer my conclusions. We should take care of Old Harbor
district but avoid including the New Harbor district at this time;
make certain that Old Harbor is protected from odors from the treat-
ment plant; give Old Harbor protection from excessive treatment plant
noise; extend the pipe to at least 500 feet into the sea and have
it end in at least 10 feet of water; and whether we have the new
sewer or not, the septic systems on the whole Island should be kept
in good working order. We should limit the growth to a reasonable
proportion, really a replacing of "dead wood"—people who die, move,
or who cannot come year after year. Do not encourage, or in fact
permit a sudden influx of prefabricated houses, motels and condomin-
iums. It is obvious that the Community must expect to share the
tax burden when sanitary facilities are required at the wharfs, near
the library,and other places where the public gathers. But, we
-------
- 2 -
should not have to finance the places of entertainment. The sewage
system,is, no doubt, an absolute necessity in the business section,
but should not be developed to attract transients who contribute
nothing in the long run but destroy the peace and beauty of the land.
Your proposed cost for the Old Harbor plan seems to be about $400,000
— a great improvement over the $4 million involved in the plan of
Fenton Keyes Associates.
is, in fact, the heir apparent and will someday own the Parsonage
and land around it. He intends to fly, and should weather or other
circumstances prevent, he has my permission to designate a substi-
I shall ask myAson, Alexis, who occupies a cottage on my
land at Beacon Hill, U^representme at the May 10th hearing. He
With thanks for all the work you do, and awaiting your
prompt reply with interest.
Ever gratefully
Mrs. E. Paul duPont
-------
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BOX 426
BLOCK ISLAND. RHODE ISLAND 02807
Area Code 401
Telephone 466-2341
li April, J975
Mr. Wallace. E. Stikney
Environmental Protection Agency
J.F.K. Federal Building
Boston, Mass. 02203
Dear Mr. Stikney,
I am witting as the Town Physician oi New
ShoA.th.am, R.J. and alio as a soon to be pn.opzn.ty owne.sc to
stress the. need ior sewers as planned by the town to .include
the New Han.bo* area as well as the Old Harbor Area.
As you know the sewers were planned accord-
ing to need by a proiessional engineering company and were
overwhelmingly voted ior by the residents oi Block Inland
(New Shoreham).
I have read the EPA impact statement and
while agreeing with parti oi it, I disagree with parti and
with its recommendations as being inadequate lor our needs.
There apparently parti oi the report that are inaccurate and
inapplicable as some were apparently cilled irom illes and
are not particularly applicable to the present condition*.
In New Harbor even though three establishment* have recently
attempted to correct their sewage problems, the conditions
are still deplorable with overflow running Into New Harbor.
There are many places between Old and New Harbors that are
badly in need oi sewers as they are in violation oi state
regulations and/or can not meet present or iuture septic
regulations because oi the lack oi necessary land or because
oi the land conditions.
Those on Block Island who are against sewers
and/or extending sewers to the New Harbor area are mostly
not year round residents and are being shortsighted euen to
their own seli-interests.
As to the potential commercial development
in the New Harbor area alluded to In the report- I believe
that It is up to the town to control thru present or iuture
planning and zoning controls.
-------
S)l. Chctoles . C&nbtooks,
BOX 426
BLOCK ISLAND, RHODE ISLAND 02807
Area Code 401
Telephone 466-2341
Mzdically, tt ti mij opLnLon that & zvoza& aAz
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a& fiavoA-ing the oAtgthal Wew ShoAzham azmza plan.
StnzzAzly you.A&t
cc: Ha. R-tchaAd PaAtoAz
1S30J Tazz l/tzw CouAt
CAo&ton, MaAyland, 21114
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Box 368
Old Tovm Road
Block Island
Rhode Island
02807
April 28, 1975.
Mr. John A. S. McGlennon, Regional Administrator
United States I&vironmencal Protection Agency
Region I
John F. Kennedy Federal Building — Room 2203
Government Center
Boston^ Massachusetts 02203
DRAFT
EUVIRONMSTTAL IMPACT STATEMENT
WASTEWATER COLLECTION" AND TREATMENT FACILITIES
NEW SHOREHAM, RHODE ISLAND
Dear Sirs
I would like to express to you ray thoughts concerning
the above, and HLock Island's needs for an appropriate, adequate
wastewater collection and treatment system.
I feel that I can speak with some authority in this
matter, for the following reasons s
I am a native Block Islander, actually born on the
Island as were several generations of my ancestors before me;
all of these ancestors lived oat: their lives on this Island.
I. too, was raised on Block Island and have lived all
of my life nere except for a period of sixteen years before,
throughout, and following Wbrld War II when I vent to sea in the
U. 3. Mercnant Marine with American Export Lines, Inc. I started
with; Americazi Export Lines , Bic. as a Cadet at the age of eighteen
and worked up to be Master of my own vessel at the age of twenty-
five at which time I was reputed to be the youngest Shipmaster in
the entire United States (res The Providence Journal, August 8. 19^+3).
I also served two years as Chief Officer of the Company1 s brand new
passenger liner S.S. Excalibur, the flagship of their fleet.
Ever since retiring from American Export Lines. Inc.
I have been self-employsd as owner of Block Island's hardware store,
John Rose & Co. Believe me, Block Island is a hard place to make
a living, and at the same time it costs more to live here. During
this period I have also served in the following positions of public
responsibilityt Chairman of the New Shoreham School Committee,,
an elective office, for twelve years; Commissioner on the
State Pilotage Commission of the State of Rhode Island, appointed
to two successive three year terms by the Governor? Member osf the
-------
Environmental Protection: Agency Capt. John R. Lewis
Draft B.I.S. New Shoreham, H.I. Page 2
New Shoreham Planning Board, appointed by the Town Council,
currently to my second five year term; Executive Vice-President
front 1966 to 1973 and President since 1973 of the Block Island
Historical Society; President of Block Island Conservancy, Inc.
since its founding in 1972.
Now, in regard to this sewer system -which, is under
consideration, let me state at the outset that no matter which way
tiie decision goes it would not affect the sewerage requirements of
me or any member of my family one bit. Our property is all
outside the sewer district, except that my own none would be art
the sewer line if Stage II were implemented, and I agree with your
report that the value of Stage II is doubtful. Mjy hardware store
would be on the main line if the minimum system goes through: end
here again I don't need the public system to serve our store's
needs, as our 0x01 system works perfectly said we don't have any
problem. Kit in either case I would want to support my community.
Let me start a here that I would resent: being classed as "Commercial
Interests" by any of the opponents of the sewer, as I would rather
starve than have the community suffer- for my financial benefit;
making money simply does not mean that much to me, as there are
many things in life which I value far more highly — a let of
which we are endowed with by Nature "For Free"<, I challenge the
opponents of the sewer, many of whom are bet tea* off financially
than I, to make this same statement. Also, it should be sated
that many of them rent their houses in competition with native
people who depend upon this for a living; so who, then, are the
"Commercial Interests'1.
I would like to recommend to you that you examine the
qualifications or all \^io express themselves an: the question of
this sewer controversy, either for or against. It seems to me
that the hurricane of protest is all out of proportion to the
Island's native population:. It seems to me that a large number
of those what are protesting would have little knowledge of the
Tslanrt and little experience In living here since, afxer all,
there are less than rive hundred of us who live here year round;
and very few indeed who have spent a major part of their lives
here. Since Block Island is a part time, summer, second home
to many, it is quite possible that there are those who, having the
means« would look upon it as a place ta maintain a sunmer heme as
cheaply as possible through cheap taxes, etc.^ lending as little
support to the community as possible* and who. when they don8t get
their way, simply sell out (usually at a profit) and move cm.
Often I have found, in: my experiences In life where human relation-
ships are involved, that it is the empty barrel that makes the
most noise.
I would respectfully point out to you. Sir. that those
to whom B3.ock Island is really home, have demonstrated a willingness
to make a great financial sacrifice in support of a sewer system.
We are not an affluent people, but we love eur Island, indeed*
for those of us who make our living here this is a difficult task,
as I have already pointed out. For many, many years the Block
Island people have worked hard, their conscientious best* for a
sewer system appropriate to the community, m the more recent
-------
Environmental Protection Agercy Capt. John R. Levis
Draft S.I.So New Shoreham, R.I. Pag® 3
period ©f these times when wiblic discussions were held with
Fen tan G, Keyes Associates w> make plans* the prevailing attitude,
as I understood it. was that this was what the Block Island people
wanted and Fenton Q. Keyes Associates tried hard to plan a system
along those lines. Since thai, opposition: has been, institute
uhich has severely drained awaythe comnnanlty^s financial resources,
as a vampire drains away the blood of its victim. so that the point
is mowreached where, as I see it. in* order for me victim to>
revive, additional outside financial help is needed to compensate
far tto very great inflationary cost increases which have resulted
from the; considerabla delays. This thing for which the Block Island
people have worked so long and so hard, just as It came within reach
has been snatched away by, as it: might appear to some,, "outsiders".
As to my own opinion of what system of wastewater collect*
Ion and treatment would best serve Block Island in the long runt if
one is to be built,, I think that your "Alternative B% with Stele I
implemented in Its entirety so as ta serve the existing Hen Harbor
marinas would be the correct one* Stage II, I think the Island
would be better off without according to your findings, sod develop-
ment of the system should stop at the comkLetica of the entire
Stage I* However, I think that the-capacity of the treatment plant
should remain as originally planned, for it is batter to have more
capacity than needed than it is to nave not enough^ for just as
the amount of waste water per person per day is greater to-day than
it was a few years age, so too Is It likely to be greater a fectf
years hence than it is to-day. Furthermore, it would be wise to
have some reserve capacity in the event a community need, now
unforeseen, should arise. Likewise* I believe that It would be
a bad mistake to downgrade the quality of tha prelect in any other
way for, as & seafaring man, the practical realities of experience
teach m& that there is only one way tor do a job and that is tha
right way — the first time! As far as saving money is concerned,
trying to save a nickel now and having it cost more then a dollar
In the long run for the sake of saving that nickel is not the way
to save money.
I think that it is especially important that the marinas
be served, trucking stored sewage ta a land fill disposal site.
I do not think is at all practical, and it would be more harmful
to the environment, and more expensive In the long run. Further-
more, human nature being what it. Is, I think that it would be
very tempting for boats in the harbor to surreptitiously duaro their
sewage overboard into the harbor rather than inconvenience them-
selves by dutifully going ta a marina, waiting in line when neces-
sary, and ideallstically disposing of their sewage in this m&aner
into a less convenient interim collection tank. I have observed
that human nature performs In this unidealistic manner in the
tidal docks of London, and Liverpool, and Bombay , and Calcutta,
where the controls are stricter, the conveniences better, and the
health hazards greater. The full implementation of Stage I would
make far more effective policing tiie sanitation of Or eat Salt Pond.
Incidentally, I think that on any summer® s day yoa would find among
the quahaugers in Great Salt Pond members of the group now protest-
ing the Tom's proposed measures for dealing with the contamination
therein.
-------
ftnrirenBental Protection Agency Capt* John R. Lewis
Draft S.I.3. Hew Shoreham, R.I. Page h
As to cost effectiveness,, it seems to ma that a system
off this scope offers the best chance for maximizing the benefits
and minimising the burdens, since a system of lesser scarce would
weigh tiie burden heavily upon: a disproportionately small number ,
off people while benefiting the general public, in return for their
tax money, almost insignificantly and making, on balance, only
a minimal, contribution to the quality of the environment* There
are certain principles and arguments surrounding this point of the
controversy — that is, costs — which it is highly important to
establish and resolve before the overall controversy can be finally
settled once and for all. It must be recognized that those net in
the sewer district who maintain their owa sewage disposal systems,
usually at considerable cost and perhaps even more than those
served by the community system, are already making their am
contribution to the environment. Certainly those who are the cause
ot this burden being imposed upon the community, and those who reap
its benefits including the boats, should pay their full measure,
including all operational, maintenance, and depreciation costsj
im other words, taking into account the fact that those outside the
sewer district are already making their own contributions via their
own systems, the public system, once established, should, as far as
the communliy is concerned, be self-supporting and self-maintaining*
Nor do I see any threat to the environment from the
implementation of Stage I im full. As an organizer and promotes? of
the purposes of Block Island Conservancy. Inc. I don't think that
anyone can find reason) to doubt my deep interest sad r^ir^yn la the
causes of conservation and preservation in and around Black Island*
I believe that Black Island must stand by itself as a well balanced,
fully integrated, completely self-sufficient, entity.
As an experienced Shipmaster, may I point out to yott the
importance of local knowledge. Just as a Shipmaster in approaching
a port, erven though he has been there many times and knows it well,
is eapected always to engage a Pilot under ordinary circumstances
for the sake of the Pilot* s local knowledge related to the circusu
stances at the timet so too may I say, in all due respect, that
I think the United states Eavir onmea tal Protection Agency should
seek out local knowledge in this matter, and that the sources
should be checked as to their qualifications to be sure that they
are sounds Certainly an inexperienced summer person who is here
oft and on only during two summer months of the year doesn't
qualify, in my opinion*
May 1. for the sake off honestly expressing my opinions,
be allowed the temerity to state that in studying the Draft of tne
Environmental Impact Statement I find some things ifcich I cannot
reconcile with my own knowledge and/or opinions* Certainly, I do
not doubt the conscientiousness of those who have put it together
— a monumental task* But I do find here a great deal of material
brought together from other sources which I have seen elsei&ere
before, and I can* t help but wonder iff cracks might appear due to
weak foundation stones someplace, just as the world9 s great
literature is changed in the normal human fallibility off its
translators. I don't know of anyone with good local knowledge who
has been consulted In this study — and I do not mean necessarily
an academic person, but practical people who deal with practical
-------
Environmental Protection Agency Capt. John R. Lewis
Draft E.I.3. New Shoreham, R.I. Page 5
reality. As ana suggestion I am thinfrlng that time spent in
going over the study in detail with the Hew Shoreham Planning
Board would toe yell spent} this might in turn suggest other
sources of information.
While I am not an Bigineer and do not pretend to under-
stand engineering techniques, and while I think that your
"Alternative B" with Stage I implemented in its entirety is the
right concept for Block Island, if a sewer system is to be built,,
there is cne thing about the whole matter which worries me more
than any other regardless of -which decision. is made, and that is
the outfall* It really troubles me, very deeply, and I am fearful
of it. Ho matter where the outfall is to be located a real
problem is presented. Originally the engineers proposed, and
liked, an outfall from the end of the east breakwater of Old Harbor*
This proposal was abandoned due, I think, to uninformed protest and
subsequent inadequate study. I think that the proposal should be
examined again* this time properly* If, as your studies show, an
outfall at PebDly Beach would not contaminate Ballard8 s Beach* how
could an outfall at the end of the breakwater possibly contaminate
Crescent Beach? To be sure, there are problems here, but they
might be easier to cope with than the outfall now proposed at
Pebbly Beach* Furthermore, this alternative would not detract
esthetically from the environment since it would be superimposed
upon, and blend in with, an already existing artificial structure
wnich is itself, I thins, esthetically pleasing. The alternative
at Pebbly Beach would. I should think, be a blight upon the
seascapo~landscape ana it would create a brand new artificial
barrier not: attractive like the Old Harbor breakwater end perhaps
not as substantial. It must be understood, of course, that the
breakwater takes a pounding — but it does take it — and rocks
are sometimes dislodged in outstandingly violent storms which,
by the wayr i&en they occur are generally off seasons but the
inner side of the breakwater provides considerable shelter aid
I would consider this plan at least as feasible and practical as
the Pebbly Beach alternative if correct!? engineered* 2he best
available enginscoring talent is essential in. either ease* and it is
important to realize that either alternative carries vita it the
risk of an occasional break in the lines but the Old Harbor break-
water,. I think, permits the benefit of creaks being more easily
repaired. & any event, breaks along the inner length of the
breakwater would be far less likely to occur* and if occurring in
the outer length would pose something less or a threat. Di
advancing these arguments I want to emphasize that I would feel
more comfortable having them examined m the light of bettor
qualified opinion and more knowledgeable facts than my ow. Ho
responsible person can blithely put forward such arguments without
benefit of extensive engineering analyses Including thorough model
tests. I cannot see an outfall off Pebbly Beach being able to
withstand the onslaughts of severe winter storms, let alone
hurricanes: the more so -when one considers the conditions involving
rocks and huge boulders being hurled against it by forces almost
beyond comprehension. How is it to be secured so as to withstand
all this? And if a crack develops, or a section is twisted adrift,
ham is it to be dealt with? And who is to pay for its maintstance?
-------
Eavircnmantal protection Agasicy Capt. John B. Lewis
Kraft S.I.S. lew Shoraham, R.I, Page &
G«rtaialy at the vary least an engineering firm engaged t® under-
take saaa a ccMstruefticai should be very well Investigated as tor
their qualifications . vtithesxt having lived here a long time,
would they really un&arststid the farces and eondiltians tot be
dealt with?
Jnd idaat about the seal population that congregates her®
during a good part of the year? Froa tlata immemorial tills has
been a special haven for the».
Perhaps a tertiary treatment system should "be considered»
la suggesting this I m thinking of broken pipelines in both
locations. Certainly this would relieve some of the anxieties
arising from uncontrolled outfall spillsf but it night offer
other practical advantages as vail* Since the effla^at would be
in a- form isfedch coo&d be returned more directly into the environ*-
seat, the outfall problem could be Bore neatly disposes of.
Considering the problems of maintaining m outfall froa a secondary
treatment plant, the econofldes of a tertiary treatment plant might
be better justified,
l&tit tongue in cheek: — bat not exactly, either* for
I feel that: any avenue which might offer hope should be esplcaped —»
I am attaching hereto a copy of tile NEiffilP IHFOSMIIION 71 Bulletin,.
April 1975s froa the EEaiversity of Rhode Island (New England Marine
Resources Information Program), whsrein is an article entitled
"Mariculfcura 3ystam Uses Wastes To Hake Food". This describes the
progress of the Woods Hole Oceanographie Institution's waste
recycling project 'jfeich, as will be seen, is already well post
the early experiJ&ental stages acid no*? developing ia the pilot plant
stage. Could this be HLock Island^ ultimate s duties*? la
interesting by-product of this noxCLd be new Industry ^hich Kl&ck
Islaad has long sought. I donft know how the economics of all this
would -»osk out,, but certainly the production, of useful products
out of waste: products we are trying to rid ourselves of would tlp>
the scales toward the other way. It Is- interesting to note that
have approached the problem from the opposite direction as we,
Is, from the standpoint of producing food, whereas we are
looking fro® the standpoint of disposing of waste. It is to be
noted, toot, that they are, even now, going to the trouble of truck-
ing secondarily treated sewage from an outside town.
la dosing these remarks, I wonld point sot that I haare
chosen tills method of communicating ay thoughts because I feel it
is better to try to reason things out in one® s own mind, and not
to allow one1 s thoughts to be distracted by confusion. I think
that it Is better to present them this waff than in the emotionally
charged atmosphere of a public hearing; but now that fchoy are set
down X would be glad to present them there too, if need be. and
let the chips fall where they may* let me emphasize that in spite
of the superior academic education that many of the people involved
in this decision making process have, no one knows and understands
Block Island as well as the people who have lived here year round
for significant periods of their lives, and wha have had to deal
with the forces of nature here, and who have had to make their
living here.
-------
Environmental Protection Agency Capt. John R. Lewis
Draft E.I.S. New Shoreham, R.I. Page 7
I would dose now with just ana more thought, a gruesome
one to contemplate, but nevertheless it Is better to examine it In
this perspective than in reality:
If an epidemic of typhoid, or cholera, or soma such
plague were to break cut on Block Island, it vould in all liklihood
do transmitted largely through inadequate treatment of sewage and
contamination of drinking water, and everyone on this: Island,
whether ho lived in to\m or remote from town, w>uld be in danger
of his life. "Ho man is an Island.*
lours faithfully,
^ 01.
Cap to John R. Lewis
Box 368
Old Tottn Road
Block Island
Rhode Island
02807
Copy to:
Mr. Wallace E. Stickney
United States Environmental Protection. Agency
Region I
John F. Kennedy Federal Building
Government Center
Boston, Massachusetts 02203
-------
NIMR1P
Information
April 1975
71
OUTDOOB v'-i '£*?*'
TEST *«E*
- '-¦ ''>^0
EnvironmentaJ Systems Laboratory, designed to serve as a pilot plant for Woods Hole Oceano-
graphic Institution's waste recycling-aquaculture project has been operating on a waterfront tract at
Quisset, Massachusetts, since Fall, 1973. A mixture of filtered seawater and 8,000 gallons per day o/
secondarily treated sewage, trucked from nearby town o/Wareham, is/ed into the six algae ponds,
each o/ which holds 35,000 gallons. Seawater-effl uent mix is varied, depending on time of year and
sunlight. In summer it is 50-50 and turnover rate of pond volume is increased from 25% to 50%. To
fool shellfish into feeding year-round water can be heated 20°C. over ambient temperature before
gravity flow sends it to raceways stocked initially with 300,000 seed oysters. With this system oysters
can be grown to market size in hal/the time needed in nature. Outflowfrom Raceways 1 and 3, before
discharge, pass through 2 and 4 where commercially valuable seaweeds that also provide jinal
cleansing o/ the water are grown. The project has been supported by National Science Foundation
(RANN) Grants and NOAA Sea Grants.
Mariculture System Uses
Wastes to Make Food
Aquaculture has been tantalizing scien-
tists and businessmen in the U.S. for close to
ten years now. A lot of breakthroughs have
been made, a great many successes achieved,
but the big one — dollar profits — remains
elusive. Intensive aquaculture systems that
depend on heavy feeding with artificial
foods to produce high yields (as modern
chicken farming does so successfully) have
generally proved too costly to be feasible on
a commercial scale. The food itself may ac-
count for as much as 50 per cent of operating
costs, as well as giving rise to other problems
like waste removal that further increase ex-
penses.
For the past four years, Dr. John Ryther, a
senior scientist at Woods Hole Oceano-
graphic Institution, and his staff have been
experimenting with a possible way out of
this dilemma. Their alternative, now being
tested on a pilot plant scale, has the added
attraction of also providing a solution to a
waste disposal problem.
Treated organic waste, such as domestic
sewage, looks to the naked eye like clear
water. But it still contains such mineral de-
composition products as nitrogen, phos-
phate, ammonia, et cetera, which if not re-
moved by tertiary treatment before the
waste water is discharged back into the en-
vironment, will produce such dense
growths of algae in fresh water bodies that
they are eventually smothered by them.
This process, called eutrophication, readers
may remember was what the great washing
machine detergent flap was about a few
years back. Although these dramatic effects
are not seen when the ocean is similarly en-
riched by sewage effluents, scientists be-
lieve it isn't a sound practice.
Dr. Ryther's plan is to use such minerally
enriched waste water, which has the same
composition and properties as commercial
fertilizer, to grow algae under controlled
conditions. The algae, having consumed all
or most of the nutrients in the water is then
fed to oysters, one of aquaculture's most
successful products. The result, ideally, is
faster-growing, fatter oysters, plus waste
water that has been given the necessary ter-
tiary treatment. So this thrifty recycling can
not only help control pollution of coastal
waters but save fertilizer, which threatens to
become scarce, and eliminate the need for
commercial feed. Ryther has estimated that
the system could use the treated sewage
from a coastal town of 50,000 people to pro-
duce over 900 tons of oyster meat a year — a
crop that could be worth up to $5 million.
Needless to say, no full-scale working
system is as beautifully simple as this one
sounds. Even on a laboratory scale, prob-
lems were encountered, and the larger pilot
plant operation has turned up others, some
of them anticipated. It has also suggested
new directions the system might take, For
instance, it was found that when the algae
did not remove all nutrients from the water
and, additionally, shellfish returned some
from their own excretion, seaweeds intro-
duced into the system would finish the
cleansing process and, incidentally, pro-
duce a saleable by-product. Oysters grown
on trays, as they are in the Woods Hole sys-
tem would be smothered by their own solid
wastes if these were not removed. Several
varieties of worms (which also have a cash
value) were found to be highly effective for
the job, and they in turn provided food for a
small population of winter flounder that
was introduced into the system.
Not all the effluent from the algal ponds
has been used to grow oysters. One of the
raceways was stocked last year with seed
continued on page 3
-------
European Fishing
Described at Forum
Fishermen who attended this year's
Fishermen's Forum were given some color-
ful descriptions of how their European coun-
terparts conduct their fishing operations, not
only on their trawlers, but in the chambers of
government as well.
Among the Forum topics were the
200-mile fishing limit, reflections of New
England skippers on the state of Europe's
coastal fishing industry, and possible future
offshore oil development that may affect
New England's fishing industry.
The Forum, held at Galilee, R.I., was also
attended by federal and state officials, re-
searchers, members of the press and others
involved in the industry. It was sponsored by
the University of Rhode Island Marine Ad-
visory Service (MAS), part of the Sea Grant
Program at URI, and the Point Judith
Fishermen's Cooperative.
A panel of fishermen's representatives
brought up the subject of the 200-mile limit,
which remains number one on their list of
priorities, and requested fishermen to sup-
port lobbying efforts for a Congressional
200-mile bill. However, they could not have
stated their case for the fishing limit as elo-
quently as Leslie Innes, a Scottish fisherman
who spoke of similar problems facing his
industry. Innes was brought to Rhode Island
by the MAS to participate in the Forum and
to build a European style trawl for fishing in
New England's waters.
Because they have caught their quota,
Innes said, Scottish fishermen must stand
idly by while the Danes, Norwegians and
Russians harvest once-rich herring stocks
within six miles of his coast. As a result of
the foreign fishing, he said, Scottish fisher-
men and processers have united, for the first
time, to push for a 50-mile limit which
would give them relief from the foreign
fleets.
"We went to London recently and got
Harold Wilson by the lapels," Innes said,
"and told him, if you don't give us a 50-mile
limit, you're in trouble, boy.
"You've the same problems that we face in
Scotland now don't you," he told the Forum
audience. "The boys from New Bedford have
got to pull along with the boys from Point
Judith and other places and you've got to
fight; it's either fight or die.
"Harold Wilson doesn't know it, but we
have a trick or two up our sleeves. We're
going to put 100 trawlers down on an impor-
tant harbor — I can't say where — and shoot
all the gear. And 100 boats ahead of that are
going to be at anchor, so nothing will get in
or out. We've got something else planned;
we're going to take 30 or 40 tons of trash fish
and dump it on the steps of Parliament if
they don't wake up."
Jacob J. Dykstra, a longtime fishermen's
representative, said many believe that the
American 200-mile limit will come soon, not
through the current United Nations Law of
the Sea Conference, but through a Congres-
sional bill. Dykstra said that even some op-
ponents of a 200-mile bill believe they can-
not prevent passage much longer. Dykstra is
president of the Point Judith Fishermen's
Cooperative, the eastern region of the Na-
tional Federation of Fishermen, and an ad-
visor to the U.S. delegation to the interna-
tional sea law conference.
Dykstra asked fishermen for contributions
for support of two Federation lobbyists in
Washington who are working without pay
much of the time. The Federation's address
is: National Federation of Fishermen, P.O.
Box 24042, Washington, D.C. 20024.
Three of eight New England fishing skip-
pers, who toured European ports last fall,
told the Forum of their impressions of Euro-
pean fishing technology. The skippers, who
were abroad for 25 days, spent much of their
time on board vessels from Scotland, Eng-
land, Holland, Denmark and Germany.
"The Europeans are way ahead of us in
technology. The electronics they use are far
superior to ours," commented John Rita,
who fishes out of New Bedford, Mass.
Trawlers they saw were frequently equipped
with $100,000 worth of electronic equip-
ment, said Robert Taber, the MAS commer-
cial fishing specialist who organized the
European trip (and who organizes the an-
nual Forum).
Also superior, Taber said, were European
techniques of fish handling, which may be a
consequence of their market system. "Two
boats here (U.S.) land fish side-by-side and
get the same price whether cr not one boat's
fish is better than the other's. Over there,
merchants know which boats handle fish
the best and pay accordingly."
The New England skippers found that
European ex-vessel prices were far above
prices at home. Herring brought 15 to 30
cents per pound, compared to about three
cents per pound in the U.S. Sole landed at
Holland ports brought $2 per pound. Dogfish
(marketed under the pseudonym, rock salm-
on) and monkfish brought 35 cents a pound.
Even industrial fish ex-vessel prices were
found to be much higher. At Esbjerg, Den-
mark, industrial plants pay $80 to $100 per
ton, compared to the $24 per ton that indus-
trial fish commonly bring in the states.
Government support of European fishing
industries has helped development, Taber
explained. In Britain, he said, the govern-
ment may subsidize up to 40 percent of boat
construction, nets, electronics and other
costs.
If oil exploration and development in the
Georges Bank area takes place, as many now
believe it will, how will it affect New Eng-
land fishermen and small coastal villages?
James Friedman, legal expert of the
Woods Hole Oceanographic Institution said
the Institution is conducting a study which
may answer some of the questions of the
potential impact of coastal oil development.
Leslie Innes said that recent coastal oil
development in the North Sea has already
begun to affect Scottish fishermen and
communities near his home of Fraserburgh,
Scotland. Since development began four
years ago, drilling rigs have taken over
prime fishing grounds. Another complaint
of fishermen, he said, is that numerous un-
charted obstructions have appeared since
development began, resulting in costly
losses of fishing gear for which fishermen
are rarely compensated.
There are estimated to be 20,000 species
offish, but there may be as many as twice
that number.
The world's largest fish is the whale
shark, which grows to over 50 feet in
length and weighs several tons. The smal-
lest fish is the goby, seldom more than half
an inch long.
-------
For Those Who Dream of Cruising — And Those Who Do It
This is indeed the age of specialization!
And magazines are no exception. A new one
has just been launched nationally from
Newport, Rhode Island, devoted exclusively
to the art and pleasures of cruising. Not just
any old kind of cruising, either, but cruising
under sail.
The publication's name is Cruising World.
It plans to put out seven issues at $1 apiece
this year, hopes to go monthly in '76, and if
its past performance as an annual at boat
shows is an indicator, should attract a read-
ership of over 60,000.
It may seem unlikely that there are 60,000
people in this country with the leisure or
the money to knock about the world in their
own boats, but undoubtedly there are that
many who dream about doing it someday
and who might pay a buck meanwhile to
enjoy the experience vicariously. More im-
portant, believes the magazine's editor/
publisher/founder, Murray Davis, an in-
creasing number of Americans are getting
hooked every year on the satisfactions of
being afloat, if only for a weekend or a week's
vacation. To this audience he offers a combi-
nation of technical information on design,
seamanship, and sailboat handling, hand-
some color photographs, travel tips and
first-person accounts of memorable voyages
contributed by members of that elite band —
the hard-core cruisers. (Only one of them, we
believe, could get away with serving cat food
as Specialite du Bateau to a visiting
yachtsman — a confession included, with
recipe, in the March issue's cooking col-
umn.)
Davis may well, as he fervently hopes,
have timed his publication right. He believes
that modern-day pressures make cruising a
compellingly attractive pastime for a grow-
ing number of people, and, furthermore, that
they find it more attractive than other ways
of being on the water. Racing, with all the
custom-builts it requires, is a diversion that
for many has priced itself out of the running,
and the boat shows last fall, he says, reflected
that fact, showing fewer racing boats and
more cruisers than in previous years. The
announcement that preceded Cruising
World's debut noted that it is "the only boat-
ing magazine in North America with no rac-
ing stories."
It would be hard to imagine anyone better
qualified than Murray Davis to make a suc-
cess of this venture, combining as he'does, a
long background in both journalism and in-
ternational cruising. An Australian by birth,
he spent six years in his country's Merchant
Navy and followed that with a writing stint
at NATO headquarters in West Germany.
There he met his British-bom wife, Barbara,
and not long after their marriage, the Davises
had succumbed to the charm of a 37-foot
yawl in which they sailed the Mediterranean
and crossed the Atlantic. After a six-year in-
terval back in Australia, where Davis was
sailing writer on a newspaper and com-
pleted a book on Australian ocean racing, the
lure of the sea got to them again and they
made their way, by stages, from Australia to
England to Trinidad to Newport, which they
now call home. For several years, Davis was
editor of Sail magazine.
Asked about the financing of Cruising
World, Davis said simply, "My wife and I put
everything we had on the line." He intends
to keep the magazine small — "We're not
trying to challenge Yachting" — he says, but
would like to be able to afford a product-
testing service for his readership. At the
moment, his staff numbers nine, all nauti-
cally minded, who are comfortably settled
into an old building on Newport's Thames
Street. Production is done in Boston and the
magazine is actually printed in Kentucky.
Two Davis Children, Kate now 15 and
Paul, 14, have been enthusiastic participants
in their parents' cruising and publishing
ventures. They went to sea for their first ex-
tended period, a year and a half, when they
were six and seven. "I believe there is no
experience like it," Davis says, "for teaching
one self-reliance and the, essentials of deal-
ing with and depending upon other people."
While they were at sea, their mother kept
them up in their studies by means of a cor-
respondence course, and all four Davises
were gratified to find that the children had
no trouble in Newport schools when the fam-
ily at last settled down ashore. Although
their time is now otherwise occupied, the
young Davises were much involved in the
early stages of the new magazine, their father
says.
Although Cruising World is the fulfill-
ment of a dream for Murray Davis, it also
poses a considerable problem. The family's
32-foot sloop, Turtle, idles reproachfully at
the wharf behind the magazine's office.
"Somehow," Davis says, "I've got to figure
out how to make time enough for us all to go
cruising again."
MARICULTURE continued
hard clams, which also feed on algae. They
have shown poor growth, Ryther says,
though this may be because they were an
inferior batch to start with. Nor have the
oysters fattened as extravagantly as might
be hoped, probably, the scientist explains,
because the species of algae that tends to
dominate the ponds is not the ideal food for
them — another problem that came to light
last year. But juvenile lobsters, stocked in a
separate raceway grew like topsy on a diet
composed entirely of the tiny invertebrates
that lived on the oyster wastes. And brine
shrimp larvae, introduced last summer into
one of the algal ponds had within a few
weeks completely filled the pond with
adult, reproducing brine shrimp — another
valuable cash crop.
Dr. Ryther emphasizes that even at the
pilot plant stage, the system is a long way
from being biologically, technically and
economically practical on a commercial
scale. His hope is that the basic research his
team is working on will point the way to
some new and badly needed approaches not
only to aquaculture but to waste recycling.
-------
Marine Careers Conference Scheduled
The URI Marine Advisory Service and the
New England Aquarium will co-host a
Marine Careers Conference for elementary
and secondary school guidance counselors
and teachers May 2 at the Sheraton Islander
Hotel in Newport, R.I.
For further information and pre-
registration forms please write:
Conference Coordinator's Office
Memorial Union
University of Rhode Island
Kingston, R.I. 02881
New Poster Available
Another of those good-looking marine-life
posters has just been issued by NOAA. This
one, the sixth in the series, shows 60 species
of shellfish found in the Atlantic and Pacific
Oceans, and lists both their common and
scientific names. The 30-by-48-inch charts
are printed on washable, non-glare plasti-
cized paper that hangs flat without curling.
Copies of Mollusks and Crustaceans of the
Coastal U.S. are available for $3.20 apiece
from the Superintendent of Documents,
Washington, D.C. 20402.
Summer Program at MIT
A special one-week summer program will
be offered at M.I.T. June 9-13 for profession-
als concerned with the problems of heat dis-
posal associated with fossil and nuclear
power generation. Topics will include:
mathematical and physical models of once-
through cooling systems in lakes, rivers, es-
tuaries and the ocean; heat dissipation in
cooling ponds, spray modules, wet and dry
cooling towers, and more. For further in-
formation, contact:
Director of the Summer Session
Room E19-356
MIT
Cambridge, Mass. 02139
New Englanders wishing information
about marine subjects or activities are
invited to send written inquiries to
NEMRIP, the New England Marine Re-
sources Information Program, a Sea
Grant advisory service of the National
Oceanic and Atmospheric Adminis-
tration, U.S. Department of Commerce.
Please make questions as specific as
possible.
Information, published monthly by
NEMRIP, is a Sea Grant project of the
University of Rhode Island.
Director, Walter Gray
Editor, Elisabeth Keiffer
The newsletter will be sent free of
charge to persons who supply their
name, address (including zip code),
and organization to NEMRIP, Univer-
sity of Rhode Island, Narragansett Bay
Campus, Narragansett, R I. 02882.
mmip
information
University of Rhode Island
Narragansett, R.I. 02882
Second-class postage paid at Wakefield,
R. I. 02880 and at additional mailing offices.
71
-------
Center Road
Block Island
Rhode Island
April 29, 1975
John A.S. McGlennon, Regional Administrator
U.S. Environmental Protection Agency
JFK Federal Building
Boston, Massachusetts
Re: Draft Environmental Impact
Statement
New Shoreham, Block Island
Rhode Island
Dear Mr. McGlennon:
May I thank you f$r having ordered the New Shoreham
Environmental Impact Statement and the resulting excellent
and thorough Statement. I believe you have done a great
service for the Island, I have heard many favorable comments
from the residents.
As a resident and a Director of the Block Island Residents
Association I am Interested in maintaining the present rural
character of Block Island and slowing devel6pement to a
conservative rate. At the same time, it is necessary to
correct the Old Harbor area pollution condition, which should
be accomplished at as reasonable a cost as possible, for It
really amounts to a ten week service during the tourist season.
After a thorough study of the Impact Statement I believe
the Alternate Plan D is the answer to Block Island's problem
and the only sensible plan to adopt for installation.
Alternate Plan A would be a financial and environmental
impact monstrosity that would be very damaging t© the present
Island Environment.
Thank you for what Environmental Protection Agency haa
done for the community of Block Island.
Sincerely Yours
Cyru^/A. Draper, D«D.S
-------
Dr. King B. Odell
GuwunStrc8t= 130 CONGDON St.
Providence, Rhode Island 02906
Mr, Wallace E, Stickney
Boston, r
1 May 1975
Dear Mr. Stickneys
I presently own and operate the drug store and movie theatre
located in the Old Harbor area of Block Island, Rhode Island,
and serve as Assistant Manager of the Narragansett Inn in the
New Harbor area,
I have read the EPA report on the proposed sewer system for Block
Island.and can fully appreciate the work, effort, and logic be-
hind EPA s work with that report, I wholeheartedly endorse its
remarks concerning the sewerage program for Old Harbor, the area
of greatest concern to the entire island. I also do not relish
any enlargement of the business zone or further proliferation of
housing developments on the island.
However, I strongly advocate further study of the proposed elimin-
ation of sewering the New Harbor area. While recent plans call
for no pumping stations for the marinas, there is still a vital
need to provide sewers to the businesses now located in New Har-
bor. To say that present septic systems are adequate, or that
such systems can be modified, is simply not correct. The obvious
pollution of Great Salt Pond by such systems now is ample reason
to restudy the ban on sewers in the New Harbor sector. Town zoning
would be enough protection to prevent further commercial develop-
ment in New Harbor. However, the Town cannot legislaiei: an end
TO THE INSIDIOUS POLLUTION OF THE POND ITSELF, ONLY A SEWER SYSTEM
COULD DO THAT, DAILY TRIPS BY THE PUMPER TRUCK IS NOT THE ANSWER.
There is just not enough ground to continue enlarging the leaching
FIELDS. I URGE YOU TO TAKE ON THE SPOT INSPECTIONS OF THE NEW HAR-
BOR AREA TO OBTAIN THE VERIFICATION OF MY ABOVE REMARKS.
Thank you for your concern for Block Island.
Sincerely yours
-------
Box #441
Block Island, R. I. 02807
May 1, 1975
Mr. Wallace E. Stickney
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. Stickney:
The Preliminary Draft of' the Environmental Impact Statement
for New Shoreham has been available since early April. I
have spent considerable time studying it, and I must tell
you my bitterness grows each time I look at the book. Funds
used for its publication could have been spent for construc-
tive use, for instance on our proposed sewer system. The
import tells us little that is new, and much that is incorrect
wna& now been given the stamp of approval by a government
agency. That in itself will convince some people that town
government has not presented all the facts correctly. I
sincerely hope that errors brought to your attention will
be corrected in the final statement, and noted as corrections.
The report seems to t^ll us over and over again that develop-
ment is "bad". I don t agree. Overdevelopment would be
harmful but no growth indicates a stagnant town and one that
is dying. We need the sewer to give our residents the
opportunity to improve their holdings in the business areas
for a reasonable return and to make a living. The report
also mentions growth in population. I look forward to seeing
growth in the year-round population of Block Island and could
only wish some of the people who were forced to go to the
mainland because opportunities were so limited, and whose
names ending in Ball, Smith, Dodge, Allen or Littlefield,
could be the ones to increase our population. We need to
provide an area, on the sewer line, where smaller lots
could be purchased by young people. We need them for the
services they provide and for manning our volunteer fire
department and rescue squad, not to mention for the civic
jobs which must be performed within our town.
The overdevelopment I fear most is the building of single
fiamily dwellings on 80,000 square feet of land- I believe
we^able to control our growth if we can get the help we
need to build our sewer system. We have done a fair job
of keeping Block Island beautiful for over 300 years, not
a bad record.
Communities plan for growth and Block Island is no exception.
Our Zoning Ordinance designates the area between New and Old
Harbors as business zone, including a small portion on the
south and southwesterly of Great Salt Pond, near the marinas.
It is the logical direction for controlled growth as witness
the new post office-bank building, a new service station,
and a new grocery store. Old Harbor needs New Harbor. They
should not be separated on the sewer system. Nothing in the
EIS indicates the facts to back up the statement that septic
systems in the New Harbor area can be safely installed.
-------
Mr. Wallace E. Stickney
May 1, *75 page 2.
The EIS states that we must keep the marsh and shore areas
open, and once again stresses the fact that over-development
with possible hotels and condominiums might be possible if
the sewer line was carried to the New Harbor. Economics
will control the hotel building in any area of Block Island
for with a 2 month season and the weather in winter time
making the island inaccessible much of the year from Dec.
to March, who is going to build huge hotels.
To build the absolute minimum is to me poor use of public
funds. Some provision for growth is good management. Who
can assure us that in two or three years time the Federal
Government will not change the present regulations for
holding tanks on boats?
I wish to mention two events that changed the history and
development of Block Island. One was building the break-
water at Old Harbor, resulting in the start of tourism
because with docks and a safe harbor steamboats could come
here. The other was cutting a channel into Great Salt Pond
and building a breakwater, creating one of the most magnifi-
cent harbors on the eastern seaboard. When the channel was
cut through to the sea surely the perch and tadpoles died
but look what we got in return: clams, quahaugs, .scallops,
oysters, flatfish etc.plus 1,000 acre^s of safe anchorage
for boats. Thank goodness our forefathers had the wisdom
to complete these projects.
In regard to the foregoing paragraph both projects were
completed in an era when the people of Block Island lived
and worked here year-round. They had no other homes. We
now have two completely different types of landowners in
one town, those who live and work here with one home, and
the other group who have a second home here. To the first
group this town is everything, to the second a lovely place
to come but if it fails then they can retire to the mainland
home.
On page 2 of the Introduction to the EIS I notice a date,
September 17, 1974, when the EPA decided to reverse the
original determination and proceed with an EIS. Did the
EPA make any effort to determine how many opponents of the
sewer system were concerned doout the future of Block Island.
How many opponents were there? Does it require only one
man or woman to successfully stop a project by using this
delaying tactic? Did the EPA give credence to the very
name of the Block Island Residents* Association, an organi-
zation with no legal standing in this town, an organization
originally created to bring together the summer and year-round
residents of Block Island, and to stimulate the cultural
activities of the town. They did accomplish their goals and
it was a fine organization until it was torn apart by strife
and this terrific polarization of the two groups that live
in this town. The association is no longer representative
of Block Island year-round residents.
Eleven years passed between the introduction and adoption
of Block Island's Zoning Ordinance and many unhappy things
-------
Mr. Wallace E. Stickney
May 1, 1975 page 3
occurred in that time. I don't believe my town has that
much time to wait for the sewer system. Has it ever
occurred to the powers that be that what is desired by
the sewer opponents may be indeed that no town exist on
Block Island, to be enjoyed in summer free of any commercial
properties, with only a housekeeping population in the
winter months.
I favor adoption of Alternative A, without the provision
for Stage II.
Very sincerely,
Mrs. Edward J. Blane^y'
Secretary to B.I. Chamber of Commerce 4 years
Secretary to B.I. Residents' Association - 4 years
(membership dropped 2 years ago)
Secretary at Block Island School 4 years
Town Clerk - 6% years^ and in office at the present time
Cd : J eft rJ fj. 6/ff 0- fj
-------
May 1, 1975
MRS. ULRIC CYR, owner
HOward 6-2241
Mr. Wallace Stickne$
U.S. Environmental Protection Agency
J. P. K. Federal Building
Boston, Massachusetts, 02803
Dear Sir,
My wife and I are the owners and operators of the Surf Hotel,
Block Island, R.i.
We are writing this in reference to the Sewage impact Stu.d$ on
Block Island , by the U.S. Environmental Protection Agency*
As quoted by the Block Island Resident's Association News Letter,
dated Hay 1975* Vol. 3, Ho* i|., it quotes "E.P.A. calls sewer plan
undesirable; Would halve cost , size."
As you probally know, more than three quarters of the members of the
Block Island Hesid«»t «s Association, are off Islandvra, and only
come to the Island during the warn weather, or summer months* A good
m&ay ©f them are not votars or even own property on the island. Moflfe
of them either live or rent on the west side or north side of the
Island, They do not use the village services, except, the restaurants,
grocery stores, gift stores, boats, beaches, theater, shellfish, etc*
They feel that the hotels and other businesses, Should foot all the
bill, for the sewage plan, because they do not need it in the area
where reside* There has been very much friction between some of the
members, and even some of the directors, enough that, it had to be
settled In court.
We the users, are very much out-numbered by the non-users*
I am not a professional sewage consultant, but as for cutting down
the size of the plan, I think it will defeat its purpose* Some of
areas that are being deleted, are in just as bad a condition, as ths
village*
We own a piece of land, almost two acres, on Ocean Ave*, which my
daughter has been trying since last July to get a perculation test
approved, so she could build, a new home* According to the results
of the test, such a large septic system must be built, that the
driven well on the property, can not be used, therefor, at our
expense we must have an extension of the Island Water Works, about
fifteen hundred feet*
-------
MRS. ULRIC CYR, owner
HOward 6-2241
I in the New Hatobor area, hotels, marinas and restaurants, all have
serious problems, and they do not have the land to expand their
existing septic systems.
In our own case at the Surf Hotel, we have bought all the land
available, that could be used for septic system* We have put in
four new systemsasiHXS®X3SOEX2SaOSHIKXj£ since 1957* each costing about
three thousand dollars, and the life of a system is about four years,
not counting the maintenance every summer, such as use of the "Honey
Wagon", and also bringing in sand and gravel to cover up* We have no
other place to go, but to close or be closed by the health depart-
ment, if the sewage project is delayed much longer*
Sincerely yours
ULRIC
BEATRICE E. CYR
-------
May 1st, 1975
Mr. John A.S. McGlennon
Regional Administrator
U.S. Environmental Protection Agency,Region I
Room 2203, JFK Federal Bldg.
Boston, MA 02203
Attn : Environmental Impact Office
Dear Mr. McGlennon:
Please forgive this shorter Addenda to my long commentary of
April 14, 1975 on the Block Island Draft Environmental Statement,
but I am an old man whose life has spanned the inventions of the
airplane, radio and the conversion of the bulk of the U.S. population
from rural to urban - and I I sometimes think we tend to drown common
sense in a sea of technology. (Have you ever tried to get a computerized
billing system error corrected?)
All of the wind and wave studies quoted in the Draft Statement and
about which I commented at length, are merely exercises in our
wonderful world of technology - while cue simple, common sense fact
is as unescapable and as obvious as the nose on one's face: The -Qq
quickest glance at an aerial map of Block Island shows Nature's
beautiful arc of Crescent Beach; it could only have been carved out
over the years by prevailing northward shore scouring currents.
Actually, as is well known, these prevailing currents are gradually
cutting Block Island in half. My own records, going back some half
century show an average cutting rate of about one foot per year.
And for the past 15 years, as stated in my earlier commentary, I have
personally observed the apparent overflow from defective septic
systems in the Old Harbor area drifting in these beach-scouring currents.
Therefore, to any objective map reader, it must be obvious that any
sewage discharge on the East side of Block Island - especially North of
Old Harbor Point - will be carried by these characteristic beach-scouring
currents along Block Island's choicest environmental possession, its
Public Beach and that, inexorably the men, women and playing children might
well be trustfully bathing in "99% pure" sewage effluent.
Needless to say, the only solution to this inevitable disaster would be to
discharge so far at sea as to be prohibitive in cost for a tiny spot
like Block Island, or to discharge on another side of the island, also
undoubtedly prohibitive in cost, or for the offending commercial
enterprises properly to rehabilitate their own septic systems, with
Town assistance in making adequate leaching fields available, where nec-
essary „
einstrom
CR:AD
-------
Mr. Wallace Sfcicknay
U. S. Environmental Protection Agency
J. P. K. Federal Building
Boston, Massachusetts 02803
Miss Lorraine Cyr
Ocean Avenue
Block Islaads Rhode Island 02807
May 2, 1975
Dear Sirs
I have been asked to write to you to express my feelings on
the proposed sewer system on Block Island.
To start off, let m® identify myself. Jfy name is Lorraine Cyr.
I am twenty-eight years old and the daughter of the owners of the
Surf Hotel. I have lived here as a permenant resident since ninet©en-
fifty-five. (My father grew up here until entering the Armed Services.)
As a child I Didn't really have much interest in sewers. I only
remembered the fun of riding the hay wagon and watching it being
put into the large hole in our back yard;not realizing of course
the hay was the basis of our new sewer system* It was fun then,
and when my father did it again about three years later I just
assumed it was the natural thing to do. As I grew older, I began
to realize there just wasn't any more land* But, I was only slightly
concerned then. I still figured it went with the business* I didn't
know a sawer is supposed to last about twenty years.
This year I am in the process of building my own home on Ocean
Avenue* I put in for a percolation test in July of last year. It
has just been approved this Hay. This has taken a full year of
phone calls,talks, and considerable changing of plans between oar
engineers and The State Board oil Health. All this came about only
after they settled upon an enormous drain field and septic systam*
-------
She load I am building on is two and a half acres with a small
cottage in front. If my land as a private owner is that saturated
with water now what must the entire area ofi Ocean Avenue all the
way to Hew Harbor be like with businesses and buildings already
existing there*
I think most of the Islanders can see this present problem
of sewage disposal and want to see it oorreeted*
I dread and mourn just like everyone else when a new house
goes up on my beautiful paradise# I don't want to see this place
become a roaring m»%r»polis ,but 1 do want to see what is existing
here now, still here twenty, thirty, or forty years from now.
If the sewer is not in very soon, our tourist trade which
is the Islands main source of income will soon die* If that dies
so will our businesses and then oar town. Mhen our town dies, so
will our means for living. Do you want to be responsible for that?
Please kelp us to live. Is not living difficult enough today with
inflation, taxes, and the new laws without being worried about
extrication from our ho mes because of running raw sewage waste?
Loving Block Island as I do, I want to be able to live and
vesfe here* I*m not out for big development, I don*t want to expand,
I Just want to M
Sincerely,
Lorraim® Cyr
-------
Mr. Wallace E. Stickney
Environmental Protection Agency-
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Mr. Stickney:
The preliminary EIS for Block Island's proposed sewer system
is, at first reading, an impressive document. Filled with
facts, figures, statistics and maps it appears compelling
in its preliminary recommendations. Close examination,
however, reveals dozens of errors, false assumptions and a
rehash of old information gleaned from studies compiled long
ago. My conclusion is that the statement is not convincing
and I disagree utterly with its recommendations. The facts
as they exist do hot agree with the material presented and
therefore the inferences drawn are equally unrealistic.
X will not list the total number of factual errors and false
assumptions at this time as it would make too lengthy a docu-
ment. Others will undoubtedly bring these to your attention.
The EPA recommendation of sewering the Old Harbor area only,
leaving the New Harbor to fend for itself, is neither reason-
able nor wise.
In days gone by Old Harbor hotels discharged their raw sewerage
directly into the Atlantic Ocean; most of the small businesses
and homes in that area used various types of septic systems.
It all worked out fairly well until R. I. State law required
that the sub-surface disposal systems must be used by all. So
Old Harbor businesses and residents, many at enormous cost, did
all they could to comply with the law to the best of their
ability and with what land was available. Many rooming houses
and hotels which originally flourished in the village have been
forced to close or drastically reduce their operations. We now
see what a health menace Old Harbor has become. Fortunately
EPA agrees with the people of, Block Island (as shown by the
referendum of July 1972) that the Old Harbor must be seweredi
But what about New Harbor? Is it reasonable to suppose that
the businesses already j.n being in the marina area will simply
fold up and disappear and that no development will take place
in that harbor if it is not sewered? That is short sighted
thinking indeed. What will happen will be the increasing
pollution of the land and the certain pollution of our greatest
natural asset, the Great Salt Pond. Do you imagine that the
harbor won't be filled every season with the yachtsmen who have
made Block Island a regular part of their summer vacations for
more years than we can remember? The sailors will come and the
businesses that serve them will somehow find a way to remain in
being, and new ones will spring up as the demand for service
grows. That growth cannot be prevented by closing our eyes and
hoping it will go away.
Mrs. John J. Lee
Neck Road
Block Island, R. I. 02807
-------
Mr. Wallace E. Stickney
May 2, 1975
page 2.
Although I don't want to dwell too much on the errors contained
in the preliminary EXS I must mention one or two in reference to
New Harbor. The statistical figure on the summer population of
Block Island is grossly underestimated. A simple count of the
boats rafted at the docks or anchored and on moorings on almost
any summer weekend will reveal a total figure larger than that
given for the Island as a whole.
It is easy to say that no sewer means no development but I can't ¦
agree. Those boats will still come in and what will they do? r
With no adequate onshore toilet and laundry facilities they will '
use the Great Salt Pond as a dumping ground. It is unrealistic
to expect the marinas to provide the pump-out facilities and to
truck this lethal material over the road to what EPA has referred
to as a "town landfill disposal area of 23 acres". The town does
not own that property and has no agreement with its owner for its
use throughout the foreseeable future. And it is by no means
clear to me how the continual dumping of toxic wastes in that J
area can be anything but harmful to our ground water supply. I
No part of the Preliminary EIS convinces me that our ground water
is safe from the continuing assaults of septic wastes that are
being dumped into it. No study has yet been made that gives the
EPA authority to say, as it does on page N-2, that sub surface
disposal systems are satisfactory and are no threat to the
ground water supply.
The sewering of both Old and New Harbors, EPA's second alterna-
tive recommendation, is the only reasonable course. It is the
course which was anticipated when the people of Block Island
approved the referendum for a bond issue to build it. They
did not for one moment plan to spend all that money for half a
sewer. We really must not allow the New Harbor business area
to fall into the frightful condition in which Old Harbor now
finds itself. If we do we will be blamed (by future generations)
for the most conspicuous epidemic of Myopia Block Island has ever
suffered.
Throughout the preliminary EIS I sensed a theme underlying the
various parts of the statement. Stated in various ways and
reiterated time after time it stated that essentially Block
Island's rural character should be preserved regardless of all
other considerations and that development can only degrade the
pastoral atmosphere. To me, that view is naive. Orderly develop-
ment in areas where it should properly take place must be planned
for in any sane society. Development is natural and proper in the
present marina area of New Harbor.
We cannot turn the clock back to an earlier century much as we may
wish to. Our summer colonists I fear would like to have us do that
so that we may provide a story book atmosphere in which they may
escape the 20^ century, The development I fear most is that which
is now going on apace, all over Block Island, as vacation home
after home is built on our precious open lands on the South and
North ends. That is the development which will destroy forever
our fragile island environment. It is cancerous and I would like
to see it curtailed by much more detailed zoning regulation and
by strict enforcement. The development I would welcome would be
-------
Mr. Wallace E. Stickney
May 2, 1975 page 3.
the upgrading of both Old and New Harbors by the installation
of the sewer system, as designed by Fenton Keyes, which will
allow proper sanitary facilities where they are needed and
which might at least restore to us the same number of available
hotel accommodations as we had in the past. If we do this we
will create a much more healthy atmosphere on Block Island both
physically and economically. We are at a turning point. If we
lose our battle to properly improve and develop the New Harbor
business area as well as Old Harbor I foresee a sad time ahead
for all of us, summer residents and year round citizens alike.
For the summer colonist it will merely mean moving on - for the
rest of us it will really be the end!
I appeal to you for help from a rather helpless position: that
of a year round resident of Block Island, an island born
descendant of generations of islanders who lived and made their
livings here as I do, a citizen of this community who worries
mightily about its future and who is dedicated to the preserva-
tion of its resources.
^Respectfully ypurar,
.-7
^7 0(
Mrs. John J. Lee
P. S. To show some evidence that I am sincerely dedicated and
not motivated by self-interest the following is listed regarding
positions held in civic affairs (past and present):
Member, Block Island Planning Board since its inception in 1971
(Chairman 1 year)
Member, Block Island Tercentenary Committee 1958-1961
Member, Block Island Community Center Study Committee 19^2
Trustee, Island Free Library,and member of new library building
committee 1972 to present
Member of Block Island School Committee - for 12 years
Member and incorporator of Block Island Conservancy
Charter member, Block Island Residents' Association and secretary-
treasurer for 4 years (membership now dropped)
Member, Block Island Medical Facility Study Committee 1973
Member, First Baptist Church Renovation Committee - 1971
Occupation: Artist designer, President of Ragged Sailor, Inc.
gift shop and art gallery in Old Harbor.
Education: Graduate of Block Island School - 1936
Graduate of Rhode Island School of Design-19^0
-------
LAWRENCE POMEROY
BLOCK ISLAND. RHODE ISLAND 02807
(401) 466-5537
May 3, 1975
Mr. John A. S. McGlennon, Regional Administrator
U.S. Environmental Protective Agency, Region 1
John F. Kennedy Federal Building, Room 2203
Boston, Massachusetts 02203
Attention: Environmental Impact Office
Dear Mr. McGlennon:
As a concerned citizen and year-round resident of
Block Island, Rhode Island, and as a taxpayer, federal, state
and town, I have endeavored to follow the proceedings relating
to the proposed municipal sewer system over a period of now
almost four years. It is an immeasurable benefit to our com-
munity that the EPA is formulating an Environmental Impact
Statement for this proposed project. The critical importance
of the project to the future of our Island calls for an ex-
pression of appreciation and gratitude for the fine job that
has been done by your office in the preparation of the first
draft of the Statement.
In my reading of the draft Statement, I have been im-
pressed by the helpful and relevant detailing of facts necessary
for the formulation of appropriate recommendations relating to
the proposed sewer system. In two areas, however, there seem
to be omissions of background data or statements now inaccurate
because based on obsolete premises which may lead to inaccurate
affirmative statements of fact. I refer to the discussion of
Alternatives in which there appears to be a failure to provide
adequate factual detail as to the capability and practicability
here of so-called packaged sewage disposal systems, for example,
of the extended aeration type.
-------
LAWRENCE POMEROY
- 2 -
May 3, 1975
I refer also to almost all the many references to waste
disposal from boats which would now seem to be obsolete, and
therefore, inaccurate, under the new EPA ruling which substitutes,
as I understand it, a type of mascerating head for boat holding
tanks. Accordingly, the need for pumpout stations at the marinas
is eliminated. Some of this apparently obsolete data and dis-
cussion thereof is involved at pp. 12, 41-42, 53 and Appendix B.
Assuming that the final draft will require thoroughgoing
change relating to this important area, it seems to follow that
the case for Alternative D over Alternative B becomes stronger
and no doubt will be presented in this light. Moreover, if waste
treatment capacity to serve pumpout stations at the marinas need
not now be expected, the data in the Impact Statement as to desir-
able waste treatment capacity requires substantial reduction.
The 300,000 gallons capacity, perhaps even before a high estimate,
now comes down considerably.
As to the first area mentioned, the need for factual de-
tail with regard to packaged sewage disposal systems, it would
seem that a good case can be made that the existing needs for
the Old Harbor area can be met by one or more packaged systems.
These have, of course, received the approval of the Rhode Island
State Department of Health and are in service in quite comparable
situations. For example, it is understood that in Coventry,
Rhode Island there is such a waste disposal system serving the
shopping center known as Coventry Plaza. This is understood to
cover an area of 97,500 square feet which includes approximately
some 25 W.C.'s plus some 20 lavatories. Also included is a 700-
square foot snack bar serving approximately 100 meals per day,
the whole requiring approximately 6,000 gallons per day flow.
The cost of the unit is not known exactly, but it is
understood that it is in the area of $30,000 to $50,000. Another
system serving a hotel is at King's Inn, Tower Hill at Route 138,
Kingston, Rhode Island. If the needs of Block Island can be met
by a number of such units of varying capacity, properly located,
it would be sad indeed, even ludicrous, that the Island should
embark on a municipal sewer system costing millions of dollars.
To be sure, the cost of Package Treatment Plants is in-
cluded at Appendix D, Table A, with the other types of plant, but
the practicability thereof seems to have received overly short
shrift. For example, at p. 28, 3.2 it is taken for granted that
because the Rhode Island Health Department requires that there
-------
LAWRENCE POMEROY
- 3 -
May 3, 1975
be only one discharge into the waters of Block Island, multiple
facilities are impractical. Surely, the reduced amount of ef-
fluent discharge at scattered locations could be discharged on
land into berm surrounded rock filled areas(or into septic tanks)
as at Coventry and elsewhere. It is understood that this is ap-
proved standard practice for large mobile home parks and other
developments inaccessible to sewage systems.
Is it not clear, almost beyond reasonable argument, that
the needs of the entire New Harbor area could be met forthwith
by these relatively low cost packaged sewage disposal systems?
The Impact Statement points out that the septic tank system in
the New Harbor area would appear adequate to meet the existing
need there except in the most developed areas. Surely, this
conclusion could well be amplified by a more complete factual
description of the capability of these packaged systems as a
presently available supplement to meet the waste disposal problem
at the Narragansett Inn, the marinas and Dead Eye Dick's Restaurant.
It has been said rather wryly, that the proposed municipal
sewage system for Block Island is like swatting a mosquito with a
baseball bat. As the draft Statement presents the Alternatives,
it is either A, B, D or no action C. If it should develop from
further consideration that the needs of Block Island can be met
adequately otherwise, then this further alternative, if selected,
would result in our saving both our environment and a great deal
of federal, state and town tax money.
Sincerely yours,
LPsksa
-------
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-------
40 FERN STREET •
NORMAN C. DAHL
LEXINGTON, MASSACHUSETTS 02173
May 5. 1975
(617) B61-8919
Environmental Protection Agency
Region 1
John F. Kennedy Federal Building
Boston, Mass. 02203
Dear Sirs:
I wish to complement the EPA on the draft
Environmental Impact Statement which it has prepared for
the sewer on Block Island. Mrs. Dahl and I are summer resi-
dents on West Side Road and during the remainder of the year
spend many weekends there.
In my view the EPA has done a thoughtful and re-
sponsible job of considering carefully the legitimate needs
and desires of all the various groups which make up the
Block Island community.
There is absolutely no doubt that the area
around the Old Harbor needs a sewer and the EPA Alternative D
provides "amply for this need. All residents of the island
should support this alternative plan. The health needs of
all the island make this imperative. Further, the economic
needs of all the island make this imperative. All of us,
whether full time or summer residents, need the support of
the service businesses which are in Old Harbor and we need
the economic activity which gives employment to the permanent
island population. It is this economic base from which springs ,
the additional capacity to serve the additional summer popu-
lation.
At the same time that the EPA recognized the
crucial nature of Old Harbor as the center of economic activity,
it had the wisdom to see that the expansion of the sewer to
New Harbor was not necessary for either the economic health
of the existing businesses or for the maintenance of proper
health conditions.
Block Island does not require another large and
concentrated area of business activity in New Harbor in order
to ensure the economic health of the island. The density of
business now there is low enough so that the sewage needs can
-------
EPA, Region 1, May 5, 1975
page 2
be handled by the available land with well designed and well
maintained septic systems. That is, the businesses now there
can take care of their sewage in exactly the same way we in
the rest of the island outside of Old Harbor do now and will
continue to do in the future. This is a cost of doing busi-
ness on Block Island, just as it is a cost to us homeowners
for the privilege of living on Block Island.
The fact that the New Harbor area is now zoned
for business and is not completely built up with businesses
is no argument for extending the sewer to New Harbor. No
hardship is imposed on the present owners of business zoned
land by requiring that the density of building2in the area
be limited by the capacity of the land to handle sewage by use
septic systems. The selling price of land for residential pur-
poses already is so high on Block Island that no one can
legitimately argue that they are being unfairly treated be-
cause the sewer is not being extended to New Harbor and, as
a result, they cannot sell their land for the even higher
price which business use commands.
Again, as I said earlier, I congratulate the EPA
in being responsible, not only to all the diverse groups now
living on the island but to those who, as a result, will en-
joy a more beautiful Block Jkland after we are all dead.
I will be unable to be at the public hearing on
May 10 and I would appreciate it if this letter is read there
so that my views may be known.
Very truly yours,
Norman C. Dahl
-------
High Street
Block Island, Rhode Island
May 1975
Wallace E. Stickney, Chief
Environmental Impact Statement Office
JFK Federal Building
Boston, Massachusetts 02203
Dear Mr. StickBBy: Res Environmental Impact Stucty-, Block Island
I was born on Block Island and ray people have beenhere for over 300 yeaess
I am a teacher and librarian. For twenty-seven years I have lived in the
Old Harbor area and for twenty-five years was associated with my husband in
the first business regularly cusingheavy excavating and grading equipment
on Block Island, so I am familiar with the conditions on the Island
Until Julji 1$, 19lh, I was a director and vice president of the Block Island
Residents Association. On that date I resigned when I felt that that organi-
zation had ceased to represent the real residents of the Island. There has
always been a division between the residents of the Island and the Block Island
Residents Association which to Islanders represents the summertime point of view.
However, over the years the Association was accepted and Islanders were joining
and some on the point of joining until last July when the direction of the
Association abruptly changed SCESSXXM and a bitter division took place. When
this Association claims to represent residents, the real Islanders want no part
of it.
I have looked through the recent Environmental Impact study made with regard to
a sewer on Block Island. I was disappointed to find a number of discrepancies
not very important but enough off tm some of the things I knew about for me to
be disturbed about the rest of it. For instance, there was a statement that
we have no local thunderstorms. ".'That very night I was awakened by something
that all ity life I have called thunder and lightening! Houses and objects
have been struck and set fire to through the years. It seems to me tat's about
as local as you cm jet.
Another point—minor but inaccurate—the Block Island Report was mentioned several
times as being a study done by the University of Rhode Island. This report was
done by the Rhode Island School of Design.
Another statement concerned retirees coming to live on Block Island, giving
the impression somehow that they are the only people coming here to live. In
the last few years, a number of young people have come here, attracted by the
informal way of life. Unlike many of the retirees who go to Florida or else-
where during the winter, tbese young people cling to a very precarious foothold
here. They have much trouble finding places to live in that they can afford
and they wind up living in all sorts of arrangements. We desperately need some
low cost housing for them. A community cannot be viable without young people
to do the work and raise up children.
It would not be healthy for the economy to develop one part of the business zone
{Old Harbor) at the expense of another part (New Harbor). There are restaurants
in New Harbor in desperate straits as regards sewage disposal. A short look
around in the area would show there is not enough land available there for septic
systems. There is in both sections much marsh and wetlands.
-B m
-------
-2-
There is no way that boating will decrease xn the coming years. Both harbors
are packed with boats many times in the summer and this will increase. People
seem to be taking to the water in ever increasing numbers and BEbck Island is
a handy place to go. They will increase sewage problems and demand more in
the way of services which will in inturn incur still more disposal problems.
New Harbor is the place that will bear the brunt of this.
As land in the residential areas is built on, and unfortunately there is no way
to stop this, the very force of numbers will demand more and more services—many
not currently available. We have no cobbler, hairdresser, barber, dry cleaner,
television repair, laundry, to name a few. We have two grocery stores the year
round, a part time hardware store and some gift shops in the summer, but few
services. People who might supply these services find it just about impossible
to find headquarters. Few structures are available and some have sewage dis-
posal problems. The weather bureau man, for one, has been having a most dif-
ficult time to find a pice for his family to live in and we feel the Weather
Bureau is important to us.
A hundred years ago we llU? year round people and 299 school children. I
remember a time when we had more hotels and the economy was healthier. I see
no evil in having a few good hotels here—not high rise buildings, but modest
structures which would provide needed services to transient visitors, boat
people and summer residents, and make more jobs available. Jobs are we
need—jobs for the peminent residents •¦"¦ic 1?.. 3 '"ere. .'v. ve re the
summer jobs with the youn-; people who come here with their families in the
summer. More jobs would certainly help. Maybe some of our own people would
come back if they could earn a living here.
Some small industry is a real need for jobs. Many of the summer residents and
retirees seem to regard making a living a rather dirty way of life. They call
it chasing the dollar, now that they n© longer do it. It seems difficult to see
how living on one's investments is superior to earning one's way by work. These
same summer residents and retirees would simply pick up and go if there were md>t
these working people here to keep things going. They expect to find everything
in working order when they ierive here with the warm weather, but somehow our
pepple have to survive the other nine months.
Perhaps the sewer would not accomplish all the things needed but it is difficult
to understand how the Island economy can survive without providing the means for
enough development for youjjg people to make a living.
I hope you will take some of th£se things into consideration and -understand that
when someone says be represents hundreds of Islanders, his definition may be a
little different from ours.
Yours truly,
jQcuttf Q^rzdt
Mrs. Weldon H. Dodge /
-------
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-------
Box #146
Block Island, R.I. 02807
May 6, 1975
Mr. John A. S. McGlennon
Regional Administrator
Environmental Protection Agency
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Dear Sir:
I am a fisherman by trade and a Block Islander by birth. I
have lived here all my life, seventy-seven years, as did
my forefathers before me.
My home is not in the proposed sewer district and never will
be served by it. In spite of that I voted in favor of the
sewer and still do, even though the payment of any increased
tax is hard for older people like myself who live on small
fixed incomes.
Although I am no engineer and therefore can't comment on the
technical aspects of the sewer there are a few things I do
know and I will comment on them.
The New Harbor, as well as every other inch of this Island,
is as familiar to me as the back of my hand. The New Harbor
needs to be sewered, no question about it. If it isn't we
can say goodby to the Great Salt Pond. There should be no
new private docks, breakwaters or other constructions along
the Pond shore.
I know the waters of Block Island and can find my way on
them day or night, in good weather and bad, and I will say
this: that outfall on Pebbly Beach will never last, or,
if it does, it wall always be under repair.
Fenton Keyes original plan, calling for the outfall to be
placed on the inner side of the Old Harbor breakwater is more
sensible although still hazardous. Any outfall o.n the east
side of Block Island would be difficult to maintain due to
the heavy seas and shifting boulders.
I have always been sorry that a neighbor of mine, a summer
resident, who lives on Crescent Beach as I do, made so much
objection to the breakwater outfall that it was not properly
considered by the engineers. This gentleman thought that the
effluent from the outfall would run north on Crescent Beach
and spoil the swimming. He probably based his objection on
a natural phenomenon which occurs near his house and mine in
what we call "Sea Foam Alley" where great collections of sea
foam roll in on occasion. This could cause a relative new-
comer to think it was detergent foam from the Old Harbor. It
is not. I've walked that beach for over seventy years, long
before detergent was invented, and the foam has always
collected there.
-------
Mr. John A. S. McGlennon May 6, 1975 page 2.
Probably the best place for a treatment plant and outfall
is on the west side of the Island where we don't get the
heavy seas of the eastern side. Near Cormorant Cove and
the New Harbor breakwater could be a safe spot. However,
knowing that there would be a "hoorah" heard from here to
Boston if that proposal was seriously advanced I guess we
can forget that notion.
I would hatei to see Block Island lose this chance to better
itself by installing sewers in both the harbors. I will
not live to see it but the Island will not be a fit place
to live and make a living if that happens. My children
and grandchildren will have a poor time of it and that
worries me.
Respectfully yours,
Byron S. Littlefield
-------
q/. A»d>uL
GEORGE BREMSER, JR.
Mansion Road
Block Island, Rhode Island
Dallas, Texas
May 7, 1975
The U.S. Environmental Protection Agency-
Region 1
John F. Kennedy Federal Building
Boston, Massachusetts 02203
Subject: Block Island Sewer Plan
Gentlemen:
Many generations of Block Island residents have protected their
island from the kind of damaging overdevelopment which has
destroyed much of America's natural beauty. It would be a
crime if the present generation were encouraged to break that
trust.
Construction^of the oversized sewer system advocated by some
for Block Island would be just such an encouragement of commer-
cial exploitation and overdevelopment, the kind that would inevi-
tably lead to destruction of the environmental values which are
basic to Block Island's quality of life. I therefore urge that the
original sewer plan be rejected and that the current sanitation
problems be solved by a different approach which would be much
more limited in scope and much less likely to damage Block
Island's fragile ecology.
The EPA's Five Point Plan described in the May 1975 issue of
the Block Island Newsletter, ("Alternative D"), seems to meet
my requirements. As a Block Island taxpayer, I strongly support
it.
Very truly yours,
GB/vt
0
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ROCK - WOOD PRODUCTS CO.
401-466-2463
BOX 86
BLOCK ISLAND, RHODE ISLAND 02807
DESIGN AND MANUFACTURING OF WOOD PRODUCTS
May 7, 1975
Mr. Wallace E. Stickney
E.P.A.
J.F.K. Federal Building
Boston, Massachusetts 02203
Dear Mr. Stickney:
I am in support of Plan B to cover the New Harbor area.
The existing soil conditions cannot sustain the sewage outflow
from the hotel and restaurants now or by any other ground level
leach field type system. A visual inspection of this area during
the summer months would, of course, show this fact.
By connecting this area to a system that has a proven track
record rather than a hit or miss one that shows up ten years from
now as having caused damage to the harbor and/or soil would be the
only economically feasible system.
As far as the impact of growth to the New Harbor area, after a
sewage line is installed, we believe that the area will be built to
the limits of zoning with or without a sewage system. Due to the
high price of land on the isiind no one in the business district is ^
going to let his land become unproductive. Just look at the court £
records across the country to see if you can stop someone from
building on his or her land because of improper sewage. All that
happens is a "special* type of leach field and tanks is designed by
"experts" that "should" mack (probably because of the high cost)
and the persons involved get the go-ahead to build. Very seldom do
they work.
This is a small island with limited funds (using the year-round
residents) and cannot afford to add on or rebuild the system in ten or
twenty years to connect to New Harbor after we get through playing
around with "John Doe's" new improved miracle system.
If year around growth in this business zone areai is a problem,
then shut the line down during the winter months. But let's not
say that by connecting to New Harbor will cause an environmental
impact of growth in the future, but say that we can save an environ-
mental impact of raw sewage in the harbor area by connecting.
-------
ROCK - WOOD PRODUCTS CO.
DESIGN AND MANUFACTURING OF WOOD PRODUCTS
401-466-2463
BOX 86
BLOCK ISLAND, RHODE ISLAND 02807
I cannot visualize a judge closing down the business in this
area because of a sewage problem caused by our neglect.to connect
to a syfefeem we would have in the other harbor area. We cannot
have raw sewage leaking into a harbor fourteen miles out to sea
and not do something feasible about it.
Notice I have not mentioned the errors or ommisions of the impact
study. This is only to say that you should not rely on other "studies"
to do your own study, a fresh clean approach with on site testing
and open minds is usually the best way.
cc Richard Pastore
-------
yufw7*~
Mr. Wallace E Stickne y
E. P. A.
John F. Kenned y Bldg.
Boston, 02203
Dear Mr. Wallace,
On/fche issue of the sewer for Block Island, I would like to advise
gto of my position and thinking on the present proposals. As a
member of th§; "business community in town, I would like to see a
s^jyer installed~ As a resident of the south end of the islandr
I would not want to be taxed for it . But speaking, I hope,
objectiveily , as one sincerely interested in the development
pattern ckT the island and the retaining of its most valuable
asset a, I believe that:
(l) The se#er should serve both ©Id Harbor and New Harbor. Both
have been zoned for business and it would be capricious and unfair
to deny this much needed service to one part of the business community
and 4|4ijl$€.it t o the other. We should rely on our zoning law, fairly
and openly administered, to control the growth pattern, rather than the
devious device of the sewer service.
(£) In as much as the swer will add substantially to the value of
those properties which it serves, I think it should be paid for
by those property owners.. ( In cases where it might cause an imme-
diate hardship to home owners, an extended period of grace could
be arranged.) While all of the island indeed has a vital interest
in supporting a village community and its services, they have an
ample opportunism to do so by their patronage of businesses and
should not be coerced by taxation into d oing so.
(3)Along with the well known natural asseets of our island, I believe
one of its most important assets is its people. To me, and I'm
sure to many others, one of the pleasures of living on Block Island
is the opportunity to have as friends and neighbors, people off all
^-ggg^^d^all walks of life. This kind off community is entir ely
dependent on a viable business and commercial sector nthat can provide;
jobs for the young people growing up here as well as for the more
recent11 immigrants". I believe most of us want to keep Block Island a
"whole" and balanced town, with its richness and variety, and to
avoid turning it into an homogenized suburbia. And to this end ,
I believe the sewer shoulg serve the entire business area.
I would also think it important to consider the effect now and
in the future of removing (however many) gallons of water, daily,
tV om the ecological system of the island,^thus far a recycling
system primarilj^) and possibly consider alternate methods~
There have been some fairly large scale experimental pr ojects
49
-------
t her is the Michigan State University experiment which has
recently completed a highly innovative closed recycling system
of a large campus araa.
And having read in the Pr ovidence Journal April 25,that a4
desalination plant has been urged by an area legislator, for
Middletown, as a necessary measure of insuring that the state
will have adequate fresh water , I believe , we on Block Island
should look carefully at our water supply before disturbing
i^s historic recycling system.
sLaaj fi&dZsQji ,
¦fax
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Clay Head Swamp
Black Island
Rhode Island
May 13, 1975
Ehvirenmental Protection Agency
Region 1
Basten
Massachusetts
Dear Mr. Stickneyt
Last Saturday I attended an EPA hearing en Bleck Island. I came away
frem it rather cenfused.
Upen entering the hall everyene was asked t# register, a narmal hear-
ing procedure, I believe. Near the registration table a weman was handing
eut copies ef a letter written by the island Sewer Commission. On the
table sat a pile ef sewer related issues af the Black Island Newsletter.
Why was the meuthpieee (the Newsletter was originally meant as a newsletter;
only this past winter has it disintegrated inte a propaganda sheet) ef a
private organization given such a pesitien ef prominence? One would think
it an EPA endorsed publication.
As I listened to various people, I was amazed at the importance of
the Bleck Island Residents' Association. In particular I noticed the often
employed phrases "we suggest" and "we recommend", the "we" being the Board
of Directors ef the BIRA. I was surprised that one group, one private
group, could be given such status by a governmental agency.
You see, I live en Block Island. I know whe does net belong to the
BIRA. I am a member; I joined over a year age when I realized^the direction
in which the organization was heading. I felt, then, that I would be mere
justified objecting to Association policies as a member than I would be as
an outsider. It was net until last summer that I realized hew little member-
ship meant, especially to the Association's president. A member is net even
allowed access to the BIRA by-laws.
Since Saturday's hearing I have reviewed newspaper articles saved frem
last summer. Saturday, Mr. Connolly, the current BIRA president, spoke of
a large membership and ef a "pell" taken at a mass meeting last summer. An
"estimated persons" (re» Providence Journal, August 25, 197*0 attended
that meeting. I was one ef those persons and I knew, for a faet, that many
who attended were net members of the Association. One vote mentioned in
that August 25 article was tallied at "84 to 76".
Carefully avoided, it seemed, was mention of a straw vote taken at last
summer's Sewer Commission meeting attended by the general public in approxi-
mately the same number as were at the BIRA meeting. A very stong majority
of these present registered support ef the Cemmissien and the project.
I think it should be recognized, also, that while many of the BIRA are
taxpayers, many are net a part of the community. Block Island is the site
of their second, or third house, a vacation place where they pay very low
taxes. It is net their heme. I find it interesting that for the fuss they
make regarding their deep concern for the town, their abounding desire to
know how tax money is spent, few of these people attend meetings of which
they are net in charge (Town Council, budget hearings and the like). One
of the mere prominent members of the Board of Directors, for example, re-
signed in mia February frem a committee which had been abolished December
-------
31, 197^» a meti®n which was officially pasted (I read ®f the m®ve in a no-
tice placed in one ef the grocery steres) at the time. Such an incident
rather disproves the claim of constant contact with the island,
(I weald like t® say there are many "summer people" who are honestly,
and selflessly, interested in this town. Unfortunately, in matters such as
these human nature prevails! the constructive, those who work fer, rather
than against things are the least vocal, the least concerned with publicity.)
Perhaps this all seems irrelevant to the issue of a sewer for Block
Island. It is not irrelevant to the greater issue of truth. God, when are
people going t® wake up?
I have now been through the whole end-of-innecence-eraiVietnam, Chicago
in '68, Nixon and Watergate, and, now, an EPA office which seems mere heed-
ful ef a small lobby than ef the People.
post-scripts Simply for the record, I do support the Sewer Commission. I
read a good part ef the recently published EPA impact study en the pro-
posed sewer project. I cann®t possibly comment on the technical aspects
ef the study. I can only say that I very much resented the implication
that some of the proposed lines would bring an extreme amount ef new de-
velopment i as has been mentioned by several before me, what happened t®
eur zoning beard and our planning board? If they did not exist (and,
even if I felt they were controlled by irrational persons) I would
readily agree with your reservations. The more I think of it, the more
incredible becomes the credibility allowed the BIRA and the lack ef even
acknowledgment of the existance allowed our own town committees.
Sincerely yours.
'rfowL
Mirth. A. Ball
-------
Qlelseco ^Ylavigahon (So.
P. O. Box 482 • New London, Connecticut 06320 • (203)442-7891
May 13, 1975
U.S. Environmental Protection Agency
Region 1
J chn F. Kennedy Federal Building
Government Center
Boston, Mass. 02203
Gentlemen:
After reviewing the draft environmental impact statement for wastewater
collection and treatment facility - New Shoreham, Rhode Island; we have the following
comments:
Alternative B of the proposal is most acceptable providing that the design capacity of the
sewage treatment plant is not reduced. This would allow for expansion of the system to
include stage 11 of alternative (a) at some later date, if it ever became necessary to do so.
We are in total disagreement with Alternative (d) and feel that no further consideration
should be given to it for the following reasons; Both alternative (b) and (d) are Environ-
mentally acceptable. Alternative (d) makes no provision for the New Harbor Area. The
New Harbor is the prime harbor that is most heavily used commercially and recreationally.
Alternative D will place the burden of the cost of proper sewage disposal upon the
businesses and property owners in the area. Under such a system it is unlikely that
property owners will overburden themselves with the necessary expenditures to properly
rehabilitate existing septic systems.
Considering the above and the fact that sewage from the three Marinas in the harbor will
have to be stored and then trucked to a disposal site, alternative (d) , in our opinion, is
totally impractical.
Enclosed is a copy of our letter to Mr. R. Train, administrator of the E. P. A.
dated 3 Oct 74 urging him to take immediate action on a complete (alternative $>)) sewage
system for the Island.
We again strongly iurge that alternative (b) be approved and construction of the
project start at the earliest possible date. Also if a sewa,ge system is installed, we will
provide in the old harbor, a comfort station on our property and also help the town to"
provide one in the new harbor.
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Page (2)
When the Marine inspector forces every boat on the water to have a holding
tank for there sewage they will have to have some place to pump off and with Block
Island it will be a necessity.
Our own vessel which on a trip from shore to Block Island , if the tank fills
we will have to pump ashore or close the facility on the vessel until we reach our
departure point.
Respectfully,
Nelseco Navigation Company
/kc
phn H. Wronowski,
'resident
-------
may 21
1975
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INCORPORATED DESIGNERS & ENGINEERS
OLD LYME, CONNECTICUT 06371
PHONES
203 - 434-2428
203 - 245-9684
May 15, 1975
U. S. Environmental Protection Agency
New England Region I
John F. Kennedy Federal Building
Government Center
Boston, Mass. 02203
Gentlemen:
May I compliment you on the way Mssrs. Thompson, Sutton and Stickney
conducted the hearing on Block Island May 10th relative to the proposed sewer
for New Shoreham.
As a director of the Block Island Resident's Association (BIRA), I should like
to stress several points for your consideration.
1) Attempting to take care of the waste from boats in either harbor is a
complete and utter waste of time, and I will tell you why. I have sailed for
many years and am a member of many Yacht Clubs, such as the New York Yacht Club, AQ
the Royal Norwegian and also fb« six years, Race Secretary of the Off Soundings
Club, and I think I know something about boats.
Some years ago a group of politicians wrote the holding tank law for New
York state. Had any of them the slightest knowledge of boats they would have
realized that the law was ridiculous and completely unworkable, which it has now
turned out to be. If a large racing group arrives in Block Island with 250 boats and
there are already 100 in the harbor, it would be completely impossible to pump
out even a fraction of this number. The time consumed in coming up to a dock,
tieing up, getting pumped out, etc. would in calm weather amount to processing about
five boats an hour. If there were a chop and a breexe, you probably would process
three. On top of this the whole thing is a completely useless gesture, and I will
tell you why. In 1965 when the first Storm Trisail Race Week was held at Block Island,
I was concerned about the Affluent that would occure in Great Salt Pond with an
additional 250 boats. In those days ecology was just a word and very few people were
even thinking about it. I therefore engaged a marine biology lab to take samples
before, during and after Race Week. The sample was taken around Champlin's Dock,
where the highest density of boats occurred during the entire week. The pdlution
increase was practically uimmeasurable. I then talked to the medical fraternity,
who said that solid wastes that float are very rapidly oxidized by the sun. Those
that sink are actually a fish food, and unless there was a case of infectious
hepatitis on board one of the boats, there was simply nothing to worry about.
Having an infectious crew member is also extremely unlikely, so that the effluent
from yachts is too ridiculous to even consider.
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2.
It is only when you have outfalls from towns and areas where a number of
people reside permanently that the sewage builds up to a point where it is
untreatable. Therefore, to go to the expense of pumping out stations and
injecting boat sewage into the New Shoreham sewage system is, I repeat, completely
unnecessary and unworkable.
2) The bland statements made that the Zoning Board and the Planning Board can
easily keep things under control is pretty much a myth. I bought land and built
a house on Block Island in 1959 before they even had zoning and I can tell you
that over the years there have been some very fast shuffles changing zoning
requirements and or granting variances because of some expediency, which of course,
benefits one or more persons.
People investigating situations on Block Island can not be aware of the
real nature of the Island or of the nuances that prevail. Block Island is unusual
in that it has no community identiy and many native islanders professing great love
of the island and "let's keep it unspoiled" in actual fact will do a complete about
face if the situation will benefit them physically or financially. If you will
consider the background of these people you can understand this very mercenary
attitude.
3)- He had a lot of emotional rhetoric at the meeting, all of which proved
absolutely nothing, but one person who is basically for the sewer made more sense
than all of the impassioned speeches combined. That was Captain John R. Lewis,
who read excerpts from a 7-page letter regarding the physical problem of an outfall.
He has a right to be concerned as he used to be a tanker captain and knows full
well the power of wave action. Unless you have been on Block Island during a winter
storm, you have no idea what these forces are like. Some years ago my company was
engaged in a research study for offshore islands, and in the course of our work
we discovered that wave forces can reach as high as 2500 lb. per square foot.
Therefore, I feel Captain Lewis is justified in questioning the use of an outfall
simply from a practical viewpoint. The expense of maintainance and repairs over
the years would be extremely high. I also feel that an outfall should be eliminated
entirely because of obvious other reasons.
4) Last summer the BIRA employed two independent sewer engineers to inspect the
plans and figures presented by Fenton G. Keyes Associates. Independently and. t
separately they both came up with the same conclusions, which were that
a) the very basic statistics upon which this sewer was designed are highly
questionable.
b) the treatment plant itself was in their opinion inaccurately sized and
contained a number of engineering errors.
Because of the*above I respectfully urge the EPA to consider retaining a
firm of top engineers of unquestioned ability to not only cut through the mass
of errors, prejudice, etc. but also to investigate the use of other means of
accomplishing proper sewage treatment for certain parts of the Island. Among
these approaches I would suggest packaged treatment plants and also the very
interesting German concept of using open ditches planted with reeds and bulrushes.
These have been successfully used throughout Europe, Ireland, and some are going
into use in this country. Ve have had the engineer out to visit the Island and he
-------
3
feels it is perfectly possible to employ this concept.
All of these alternatives should be thoroughly explored, and I feel that
in so doing you will find many approaches that completely eliminate the serious
outfall problem.
Again, let me say how much we of B1RA and I personally appreciate your
interest and efforts in our behalf.
John B. McPherson
President
Sincerely
JBM/pc
-------
MRS. JEANNE FIELD SPALLONE
OLD WESTBROOK ROAD
WINTHROP
DEEP RIVER, CONNECTICUT Q6417
May 16, 1975
Environmental Pretectien Agency
Regien 1
Jehn I'1. Kennedy Federal Building
vesten, Mass., 02203
Dear Sir:
I was not. able to attend the public hearing en Block Island
on I-tay 10.
H»wever, frerri the briefed^ewn versien ef your ree#«mendatiers,
as published in the *1® clqpewsletter, 1 would like t& state
that I am in general agreement with y©ur rectr.uaenaations - if
y®u feel there is no ©ther alternative, such as a communal
septic system in the Old Karber area.
I am a tax payer e-n XI© ck Island. My property dees nat abut
®n any rf the prepeseci sewer lines (we have a new septic system),
but is located a relatively short aistance frsm the Old Karber
area.
Sincerely
-------
£i±[ancl do.
P. 0. BOX 518
BLOCK ISLAND, RHODE ISLAND 02807
Phone 466-2323
May 17, 1975
John A.S. McGlennon, Regional Administrator
U.S. Environmental Protective Agency, Region 1
John F« Kennedy Federal Building, Room 2203
Boston, MA 02203
Attn: Environmental Impact Officer
Statement by
Henry 6. Hutchinson
Re; Draft Environmental Impact Statement pertaining to proposed Municipal
Block Island Sewer, with reference to Summary page X*
As President of the Block Island Power Company and as a year-round
resident of Block Island, 1 wish to express my appreciation to your agency
for the services now being rendered in the preparation of a sewer system
Environmental Impact Statement for Block Island. Your encouragement of
discussion and thought concerning the environmental consequences of a sewer,
is the kind of public service many of us had all but despaired of receiving
on this island*
If there is criticism to be made of the draft Environmental lopact
Statement it is that summer population data, derived from a report by Fenton
Keyes Associates, has been accepted as valid but is highly questionable in
ay opinion. I would also suggest the desirability of up-dating construction
cost as well as operation and maintenance data* Please see the enclosed
table of cost escalation of the past three years as it affects the Power
Company.
It might also be said that insufficient emphasis was placed on the fact
that a majority of commercial subsurface septic systems were iiqproperly
constructed of less than optimum materials and have thus failed to function
properly after a few years* It is worthwhile to examine the question why
some businessmen tolerate this kind of makeshift or make-do septic system*
They may believe their attitude is quite valid because of the built-in
weaknesses of our summer resort economy8 Each summer is a challenge, with
factors such as weather and mainland business conditions having varied and
unexpected influences on the revenues of the short season* A hurricane in
August could be an economic disaster*
No municipal sewer system will lengthen the season or control the
weather or mainland economy, and it is, therefore, my belief that major
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Page 2
H3>[oclz {Jitand ^J-^oujez do.
P. O. BOX 518
BLOCK ISLAND, RHODE ISLAND 02807
Phone 466-2323
John A.S. McGlennon
commercial growth cannot be sustained here, no matter how big the boom may
be immediately after a sewer is installed. In fact, the bigger the boos,
the bigger the bust* Please see the enclosed "tip of the iceberg" news
clipping from the Providence Journal, Monday Hay 12, 1975 regarding the
Island's first major "Tear-Around Resort" on Ocean Avenue*
1 was happy to see recognition given to the basic instability of our
summertime economy on page 66 of the draft Environmental Impact Statement*
This reads as follows:
"In addition, growth rates can be stimulated which
will result in population and development densities
beyond optimum capacities for the Island, and once
development is there, it will stay whether the
population does or not."
The Block Island Power Company has more than a casual interest in the
kind and amount of growth on the island. Our electrical rates now average
over twice those of mainland rates* A major increase in summer activity
will call for substantial increases in capital expenditures by the company.
These dollars will buy only one-third to one-fourth what dollars already
in the rate base have bought* Since depreciation and the cost of money
are a major portion of the cost of service, this will result in a steep
increase in electric rates to all the customers, old as well as new* This
steep increase in electric rates will be an additional factor in the
instability of commercial activity*
The above statement is a plea to all concerned and particularly to the
EPA, to prevent the installation of that type of sewer system which will
encourage an accelerated increase in summertime commercial installations and
activity*
Approved by the Rhode Island Department of Health and installed to
serve shopping centers, condominiums, etc* are a variety of waste water
treatment plants* The plants are small, prefabricated units that are
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Page 3
P. O. BOX 518
BLOCK ISLAND, RHODE ISLAND 02807
Phone 466-2323
John A.S. McGlennon
rendering reliable service* Such units could be installed on Block Island by
the restaurant-hotel centers without involving federal, state or local tax
monies and take care of the present problem areas without involving the
town*8 debt structure and creating the pressures for an accelerated increase
in summertime conmercial establishments to "share the tax burden".
HutcKinson
Very truly yours,
r/M y .
HGH/pb
encl: 2
May 26, 1975
1 hereby certify that: the above letter was read, discussed and
approved by the Block Island Power Company board of directors at
their annual meeting held May 17, 1975*
Phillip F* Bannister
Assistant Secretary
-------
Block 9&l(md powek Go*
P. O. BOX 518
BLOCK ISLAND. RHODE ISLAND 02803
ITEM PRICING
UNIT
1972
1973
1974
1975
Increase
1975 Price over
1972 Price
25 KVA single phase pole type distribution
transformer - stock code T1660203
ea.
$218.00
$248.00
$265.00
$348.00
60%
4-4; In* suspension insulator - stock code
207700
ea.
1.95
2.10
2.51
3.30
70%
15 KV 500 MCM 3/C poly jacket paper insu-
lated lead covered copper cable - stock code
151081
ft.
5.83
6.53
8.07
11.66
100%
.
1272 MCM 45/7 strand bare aluminum trans-
mission cable trade name Bittern - stock
code 120175
lb.
.25
.24
.43
.47
88%
6 strand - 4 solid split bolt connectors -
stock code 190904
ea.
.18
.20
.23
.24
| 33%
28 In. galvanized flat crossarm brace -
stock code 019275
ea.
.40
.40
.55
.59
I
!
| 47%
35 ft. Class 4 Southern pine creosoted wood
pole - stock code 079044
ea.
39.07
49.58
81.15
j 84.16
115%
#2 Fuel oil
gal.
.145
.155
.196-.315
.315
117%
Lube oil U.R.S.A. - ED 40
gal.
.98
.98
1.30-1.50
1.50
53%
April 25, 1975
-------
Editors: Margaret C. Self
Sydney B. Self
BUOK ISLAM
Box 111, Block Island, Rhode Island
Telephone 401 -466 - 5518
TIMES
Publisher: Dan's Papers
Drawer AR, Bridgehampton.^New York 11932
Telephone 516 -637 - 0500
May 18, 1973
Mr Wallace E.Stickney
U.S.Environmental Protection Agency
J.F.K.Federal Building
Boston,Mass. 02203
Dear Mr. Stickney,
First I should like to congratulate Mr. Thompson,Mr. Sutton
and yourself on the way in which the May 10th Meeting to discuss
your draft of the Impact Statement of the Block Island proposed
sewer might effect the environment, was conducted. You were all
patient, impartial and willing to listen to all who cared to speak.
I am enclosing clippings from the different issues of
the Block Island Times in the years 1972 and 197^ which discuss
the sewer. I should particularly like you to read the letter
to the Editor from Joseph Connolly which was printed in the August
8th, 197^ issue and my reply to it in which I refuted every point
which he made. Nor did he at any time afterwards question my re-
marks. His letter, printed at his personal request to me, was
never put before the full Board of Directors of which I then was
one. I think it brings out the lack of credibility of Mr. Connolly
as a witness.
Unfortunately ours is a summer paper, thereof or-* there was
no publication of what occurred at the meeting held in September
of 1972 at which Mr. Raymond Murphy went into detail andpexplained
why there could be no adverse effect on Crescent Beach should the
outfall be at the end of the jetty and why this location was
vastly preferable.Both Mr. and Mrs. Rheinstrom refused to accept
the explanation which he gave and which he had given in some de-
tail in his letter Aug 31. 1972 in reply to that of Mr. Rheinstrom.
Mrs. Rheinstroms final remark was the she for one "had no intention
of swimming in chopped up sewage.
The question of provision for handling sewage from boats
in New Harbor was also discussed at this meeting and at one point
Mr. Connolly declared that "Not a penny of his money should go to-
wards any plan which did not include the handling and clearing of
pollution in New Harbor".
Our final issue in 197^ being August 22 I was unable to publish
a report of the meeting held August 23 by the BIRA nor that held
Sept k ( am not sure of exact date) held by Sewer Commission. At
this stage of the proceedings the BIRA had no interest in any
environmental impact. Their sole cry was that facts concerning
the apportionment of the assessment were deliberately being witheld.
-------
Just "before the BIRA meeting of the 22nd, members of the
Board of Directors made a tremendous effort to get people
to join and vote on their side. They had a special table on the
sidewalk where people that they had approached might pay they
dues there and then and so have a right to vote. On the other
hand we had guests staying with us, friends from Chicago who spend
ten days on the Island each year and who had been members for over
five years who were not permitted to vote on the grounds that their
names were not on the currant list.
The meeting was so badly handled, certain menber'S in -
eluding Samuel S.Mott, Chairman of the Sewer Committee and
F.Albert Starr, Town Counselor, were not permitted to say everything
they wanted to, that at one point the police came down the aisle
to prevent violence. No written poll was taken ,only a show of
hands which was so close,( only members of the BIRA were allowed
to vote ) that there was some discussion as to which side had won.
At the meeting called by the Town the following week,
all present were allowed to express their opinion whether voters
or not. The straw vote thus taken was overwhelmingly in favor of
the sewer.This was after Mr. Mott had announced the very small per-
centage that non abutters would have to pay and had distributed
written sheets giving the amounts each commercial abutter would
be called on to pay as well as some of the non-abutters.
Finally I wish to endorse Mr. Gill's suggestion that the
outfall pipe be relocated at the jetty. The engineers and others
with whom I have been talking agree that this is the most econom-
ical and most practical from the esthetic point of view. Nor am I
saying this because the new location is near my house. Others
besides myself enjoy Pebbly beach and it is one of the prettiest
views of the Island, but I object to having the views of one man
considered against the wishes of the experts and the neighbors.
I therefore urge that the EPA uphold and recommend the
outfall being at the end of the Jetty on Old Harbor and that
Alternative B be adopted.
Sincerely yours
Margaret C.SElf, Ed. Block Island Times
-------
P. 0. Box 525
Block Island, R. I. 02607
May 19, 1975
Mr. tf. E. Stickney
U. S. Environmental Protection Agency
JFK Federal Building
Boston, Massachusetts 02203
Be: EIS New Shoreham Water Pollution Control
Dear Sir:
I will be brief - and leave the technical aspects of subject project to those
qualified to evaluate them.
I urge you to support the Town of New Shoreham1s sewer project to include OLD
and NEW Harbors.
Let me say this—I am 59 years old, single, have resided on Block Island for nearly
six years, and I live on a small Federal retirement which I supplement with a part-
time job at the local bank. I live in a 4-room apartment which I rent. ANY expense
which increases the tax rate on Block Island is reflected in my rent and other ex-
penses. Such increases mean that I must tighten my belt I repeat, I urge
your support of the Town's sewer project to include Old and New Harbors.
I have served as Secretary of the local Chamber of Commerce for more than five years.
I served as Secretary to the Block Island Residents Association for approximately two
years. These activities offered me a good opportunity to hear all sides—commercial,
summer-residential, year-round residential—of many controversial issues.
I have also been employed as a secretary by a local real estate agent where I had a
good opportunity to learn of the great number of home owners who are financing their
summer homes, including upkeep, by renting their homes to simmer visitors. It seems
to me that those who emphasize the "selfish" commercial interests on the Island are
drawing a fine line in defining "commercial."
I resent those persons who claim to represent a Block Island Residents Association
solid stand against the sewer project as proposed. These people do NOT represent me
(among many others), although I am a dues-paying member (initially because the
organization appeared to have worthwhile goals, and now because I want to be in a
position to vote AGAINST such irresponsible actions as the organization is now pur-
ported to support. )
I urge EPA to support a sewer system on Block Island which includes Old and New
Harbors, and to offer every possible assistance to obtain maximum funding assistance
to permit this project to carry forward, despite the awesome cost increase which has
resulted from the delaying tactics of a few irresponsible people (not all opposition
is irresponsible, of course).
Respectfully,
Kleenar R. Long
-------
Paiuj- E. Taylok Jr.
May 20, 1975
Mr. John A. S. McGlennon
Regional Administrator
U. S. Environmental Protection Agency
Region #1, Room 2203
JFK Federal Building
Boston, Massachusetts 02003
Attention: Environmental Impact Office
Re: Block Island, Rhode Island Sewer System
Dear Sirs:
I with my family have been a summer resident of
Block Island for approximately thirteen years and a property
owner for almost nine years. On Block Island we live on the
west side in a large, old home on four acres of ground which,
certainly within my lifetime, will never be served by any
sewage system installed in the town and harbor areas.
I, like many summer "cottagers" such as myself,
have become aware of and sympathetic about the sewage con-
ditions which the larger commercial establishments in the two
harbor areas must contend with. It has been my feeling that
I, with the other summer "cottagers," should, in fact, con-
tribute in some reasonable way to the correction and improve-
ment of those conditions, possibly even by paying some moderate
increase in property taxes to finance a system which would re-
solve these problems.
However, throughout the course of the developments
of the past two years concerning the whole sewage subject on
Block Island, such a position of moderation between the two op-
posing factions has not been given very much consideration.
2 2 1975
-------
- 2 -
Under the circumstances, being confronted with the rather
stark alternatives of accepting the town administration im-
posed "super" sewage system proposal vs. joining forces with
those who would obstruct such a plan, I regrettably have had to
sympathize with the latter, i.e. the "anti's."
I.understand that your office has submitted a pre-
liminary environmental impact Statement, in which you tend
to favor the installation of a system having a markedly reduced
capacity to that originally proposed by the town administration
(viz. alternative "D"). In your statement you also indicate that
a second alternative, i.e. "B," may also be appropriate and
feasible. You also seem to indicate no alternative should be
adopted without a confirming vote of the residents of the Island
who would include, I hope by your definition, not only those
registered to vote in national elections, as "permanent" residents
of Block Island, but those who own property and pay taxes thereon.
I would like to register my views in favor of alternative "D" of
the various alternatives suggested in your Statement and certainly
hope you impose on the town the requirement that some kind of
referendum among the residents be held to corroborate this choice.
I am sure it has not escaped your awareness that the
prevalent sentiment among a large body of property owners,
principally the summer "cottagers," is that the town officials
have, in a sense, railroaded the whole idea of a sewer upon the
Island, at a tremendous capital cost, not only to the Island but
to the Federal Government, with the inevitable consequence that
the property taxes of all owners will be significantly increased,
all of this to benefit a small minority. Such distasteful conno-
tations can only be dismissed by an Island-wide vote approving the
final EPA -blessed alternative. Such an approach on your part
would be eminently equitable to all parties concerned and the town
administration should not find it objectionable at all.
I hope that these views, which are shared by people in
a status similar to mine, will have some small influence upon you
when you are making your final decisions.
Very truly yoi
Box 462
Block Island, Rhode Island 02807
-------
To:
Mr. John A.S. McGlennon, Regional Adm
U.S. Environmental Protection Agency
Region 1, Room 2203
JFK Federal 31dg.
Boston, Mass. 02203
Atts Environmental Impact Office
FROM
Ln. Edward W. Hildreth
BOX 442
OLD SAYBROOK, CONN. 06475
(203) 388-3296
DRAFT- EPA Environmental Impact Statement
SUBJECT: Town of Maw Shorohomp Rili
DATE: 5/20/75
Dear Mr. McGlennon:
Refuse Disposal.
Please refer to subject DRAFT SectionPage 17
I would request that this section be eliminated altogether from this DRAFT.
Such a use would be in an area that is residential and consisting of ex-
tremely valuable land. We have a new home in the Immediate area and are
very disturbed at reading this section in your Impact Statement. I am sure
that the Town has not sanctioned such a use at all for such as "solid waste
disposal needs". Apparently this little squib in the Draft is the first
any of the many landowners in the area have heard of such possible planSj/»*«
I am sure that they will be shocked and dismayed as much as I am at the mere
inferences contained in this section. There is absolutely no basis for
such a section to be ln this DRAFT. Will you please let me know whether
you can strike this section so as to ease the minds of all these landholders
nearby? If you are unable to do so, will you please advise me how this
thought ever came up ln the first place? We would like to nip this in the
bud now- I am sure things will be lots more peacefull if we settle this
one question. May I please hear from you or meet with you?
Thank you for anything you can do to help.
-------
CORNING GLASS WORKS
CORNING
CORNING, NEW YORK 14830
R. LEE WATERMAN
Honorary Vice Chairman of the Boerc
May 22, 1975
Mr. Wallace E. Stickney
Environmental Protection Agency
J.F.K. Federal Building
Boston, Massachusetts 02203
Dear Mr. Stickney:
As a property owner on Block Island, I would like to
go on record as strongly favoring 'Plan B* for the development
of sewage disposal facilities there.
It is my observation that any further development or
even improvement of community life depends on solving the pollution
problem at both harbors, which are the natural centers of activity
on the island.
Your favorable consideration will be appreciated.
Sincerely,
RLM:paf
-------
INCORPORATED DESIGNERS & ENGINEERS
OLD LYME, CONNECTICUT 06371
PHONES
203 - 434-2428
203 - 245-9684
May 30, 1975
U. S. Environmental Protection Agency
New England Region I
John F. Kennedy Federal Building
Government Center
Boston, Mass. 02203
Gentlemen:
In my letter to you of May 15, 1975, paragraph 2, I specifically stated that
the idea that undesirable growth on Block Island can be controlled because it has
a Zoning and a Planning Board is wishful thinking and absurd. The Islanders and/or
people looking for jobs on the Island will use any and all means to obtain these
jobs. The welfare of the Island to them is a low priority indeed.
The enclosed item from the Providence Journal. May 12, 1975, outlines exactly
this situation on the Island. Can you imagine the increase of similar propositions
and the pressures that will be brought to bear whould the Island install a large
sewer system? I think this shows exactly what will happen and you and I both know
that finally, one undesirable proposition will get pushed through, and then it will
be all over. One after another we'll get similar pressures and "steam-rollering".
It would also be interesting to check on the financial structure and the
principles of the Blackstone Valley Investment Corp. of Providence. Again I repeat,
there are satisfactory packaged sewage treatment plants on the market and in
operation around the country and these can be installed for a tenth of the cost of ,
a "Plan B", and they will take care of those most needing the service.
The idea of committing the town to a vast expenditure for an over-capacity
treatment plant in the hope that expansion will fill it to capacity negates the
very false protestations of the few commercial establishments that are trying des-
parately to dump this financial monster on Block Island.
9
/ Jol
/ Pri
JBM/pc
Enc.
John B. McPherson
President
-------
JfeaMterelDtmral
WEST BAY EDITION-SECTION B
Monday, May 12, 1975
Block I. 'year-round resort' closer
By FRIT/. KOI H
Joumiit-ltiiliftin Muff U'rllcT
BLOCK ISLAND — The
dead of winter, a phrase
that's more truth than cliche
in This close knit community
of 500 year-around residents,
may soon belong to New
Shorehum's past
Plans for the island's first
majoi1 "year-uround resort,"
¦ $2/5 milion, 32-unit apart-
ment complex with indoor
swimminc l>o*>l and tennis
courfs, are moving ahead
briskly.
The apartments wil be situ-
ated ion Ocean Avenue in the
village near Old Harbor on
tha jsi(e of the Block Island
ii£?,' a turn-of-tbe-century
structure that will be* razed to
make room for the new proj-
ect.
The $750,(XX) first phase of
the venture, which includes 16
living units and a lounge, has
been approved by town offi-
cials. Construction is expected
to begin in the fall and be
completed by next spring.
Major jwrtners of the all-
Rhode Island interests back-
ins the project, known colec-
tively as "the Block Island
partnership," ace Niihokis A.
Depetrillo, owner of ihe inn,
and the Blackstone Valley In-
vestment Corporation of Prov-
idence.
The second phage of the
prompt, an additional 16 units
and the recreational facilities,
is planned for completion the
following year'on an adjacent
parcel of land. Th«it phase,
estimated to cost more than
SI.5 miiion, is currently
stalled at the state level,
where the Department of
Natural Resources is review-
ing a plan to alter a small
brook on the property.
TV four wood-shingled
buii 'ings, each containing
eisht livimT units, and the rec-
reation buildings are designed
t., iit the terrain and charac-
ter of the island. Depetrillo
said. Rentals for the units
have not been set hut will be
' very expensive,'' he said.
Islanders raised no object
iions to the plan at a recent
public hearing. Town officials
and the zoning board also
have blessed the plan.
Also being razed with the
Block Island Inn is the Block
Island Tavem, the familiar
white extension of the inn that"
is the island's only winter
watering spot and a hub of ac-
tivity.
"A1J my friends ask me
what it'll be like when this
bar goes,' said Depetrillo.
"I tell them it'll be expen-
sive, but it'll provide us jobs,"
he said. Depetrillo wants 90
percent of the construction
work done by local residents
and. says the project
provide many jobs.
-------
LAWRENCE POMEROY
BLOCK ISLAND, RHODE ISLAND 02807
(401 ) 466.5537
May 30, 1975
Mr. John A.S. McGlennon, Regional Administrator
U.S. EPA, Region 1
JFK Federal .Building, Room 2203
Boston, Massachusetts 02203
Attn: Environmental Impact Office
Request for Extension of Time
Dear Mr. McGlennon:
In connection with the preparation of the Impact Statement
for Block Island, I have previously written, under date of May 3, 1975,
and at the public hearing held May 10, 1975 I spoke in furtherance of
presenting in the Impact Statement greater factual detail as to the
capability and practicability of so-called packaged sewage disposal
systems for the conditions unique to Block Island. The point was made
that there had been given little if any consideration to this alter-
native and that only in this fashion can Block Island be provided with
appropriate and adequate waste treatment facilities.
From the evidence adduced to this time as the result of the
May 10, 1975 Public Hearing and from further inquiries that have been
made, it seems abundantly clear there has not been adequate or reasonable
consideration of the packaged sewage system, more correctly described as
a tailored or custom designed waste treatment facility. For example,
at the Public Hearing Mr. John Corey, a member of the Block Island Sewer
Commission, in contending that this alternative had been considered,
was able to state only that the Town's engineering firm had advised that
the Rhode Island Health Department would never approve it. However,
Mr. John Bogoshian of that Department conceded that there had been good
experience with some packaged waste treatment plants, and it is the fact
that a goodly number have been approved and are now in use in Rhode Island.
There appears to be but one problem, that of handling the
discharge of effluent. Available evidence (not in any way as yet
investigated) demonstrates that with expertise, imagination and ingenuity
borne of conscientiousness, this matter of the discharge of effluent from
the custom designed facility can and has been effectively dealt with under
more difficult conditions than exist at Block Island. For example, at
Stowe, Vermont a 173,000 gallon per day custom designed facility (not the
conventional municipal sewer system proposed for Block Island) has been
assembled with an effluent discharge so treated that discharge into
a local reservoir has been approved.
The capacity of this plant seems to be more than adequate for
Block Island, and at a cost but a fraction of that here proposed.
Moreover, the flexibility of the custom designed component-part waste
treatment approach will reduce the compulsion, that will be inexorable,
-------
LAWRENCE POMEROY
Mr. John A.S. McGlennon
May 30, 1975
Page 2
to expand commerce and industry on our Island in order to use and
pay the costs of an oversized conventional municipal sewer system.
As a matter of general interest I take the liberty of enclosing a
copy of an article in the Smithsonian. May 1975, relating to current
innovations.
Tfte ultimate key circumstance requiring individual consideration
here is the uniqueness of the Block Island situation. Uherelse in the
entire United States is there a $4,000,000 municipal sewer system
serving some 400 people for ten months and some twelve hundred people
for two months of the year? All the more does imaginative consideration
of the custom designed facility seem an imperative when the evidence
shows that the outfall pipe for the proposed sewage system will likely
present horrendous maintenance problems.
Accordingly, it is herewith respectfully requested that the
time for presentation and evaluation of evidence for the Impact Statement
be extended at least thirty days beyond June 4, 1975. During the further
period thus made available it is further requested that the services of
a competent and impartial engineering firm be retained to make a
preliminary survey adequate to determine the feasibility for Block
Island's special conditions of custom deafened waste treatment facilities.
It is requested that your Agency Include in the cost of your Impact
Statement the oost of this Independent, Impartial survey so that in
arriving at the conditions of the Federal grant this alternative may be
implemented effectively.
zo
In the event that it should be considered inappropriate for
the cost of this proposed preliminary survey to be so absorbed, then
it is requested that the time be extended nevertheless so that there
will be an opportunity for this survey to be otherwise funded.
In cooperation with other concerned parties, a highly regarded engineering
firm has been found, believed to be expert in this field, well and
favorably known to your office, and ready and able to make this survey.
She name of the firm and estimate of cost will of course be provided
to you upon your response to this request for an extension of time.
Sincerely yourst/y
Lawrence Pomeroy
LPtm
-------
J hXiTttSesf/A-*/
MAY,
By Sam Love
An idea in need
of rethinking:
the flush toilet
Our present system is a major contributor
to environmental decay and a waste of
resources, but new ideas are proliferating
The Reverend Henry Moule's hellfire and brimstone
sermons failed to make much of a mark on history,
but his tinkering will never be forgotten in the annals
of human sanitation. His most successful invention
was the earth closet. Constructed by him in 1860, it
consisted of nothing more than a wooden seat over a
bucket and a hopper filled with dry earth, charcoal or
ashes. The user simply pulled a handle to release a
layer of earth from the hopper into the bucket. The
container could be emptied at intervals.
Mr. Moule's original earth closet is a rather austere
piece of household furniture, but later innovators
loaded it with accessories. For example, a device could
be added thai released the earth each time a user rose
from the seat. But the automatic earth release met
with some opposition: "In sick rooms," according to
one account, "this method of distribution of earth
may be found objectionable, as more or less vibration
follows the rising, and this is apt to disturb the nerves
of a patient."
While sanitary historians may recognize Henry
Moule's contribution, he is no longer a household
word. Certainly he is not as well known as Thomas
Crapper, the father of the flush toilet. In fact, while
folk history is good to him, I am convinced he is a myth
created by British, author Wallace Reyburn, who
wrote an amusing biography of him in 1969 entitled
Flushed, with Pride. Although the book and the his-
tory seem to be a complete figment of the author's
imagination, many libraries, including the Library of
Makers used to decorate chamber pots with images
of archenemies. In this case, target is Napoleon.
Congress, file their bibliographical cards for the book
as if it were a serious historical treatise 011 the origin
of the water closet.
Who actually invented the water closet is a mystery;
its origins go far back in history. One of the earliest
indoor bathrooms has been found by archaeologists
on Crete. According to the bathroom history Clean
and Decent by Lawrence Wright, the great palace of
King Minos at Knossos included a water-supply sys-
tem of terra-cotta pipes that some have judged supe-
rior to modern parallel pipes. One of the Knossos
latrines appears to have sported a wooden seat and
may have worked much like a modern flush toilet.
Cities in the Indus Valley between 2500 and .1500 b.c.
also had indoor bathrooms flushed with water. The
waste was carried to street drains via brick-lined pits
>i.nilar to modern septic tanks. Except for the briefly
used water closet of Elizabethan times, such engineer-
ing did not appear in England until the middle of the
18 th century.
Generally, the 18th and 19th centuries in Europe
were dominated by the pan closet or the jerry pot. By
1800 many were elaborate, even to the extent of plac-
ing portraits of archenemies (Napoleon was a big hit
in England) in the target area. After use, the pots
were either emptied or concealed in commodes.
At first the contents of the urban jerry pots were
collected by nearby farmers who were delighted to get
nitrogen-rich organic fertilizer. But as London and
other cities grew, the journey became uneconomical
A coordinator of Earth Day in 1970 and formerly
the editor of Environmental Action and a book Earth
Tool Kit, Sam Love is an environmental consultant.
Illustrations by John Huehnergarth
61
-------
Flush toilets: a passing idea
and the waste was generally dumped in larger com-
munal cesspits or in the nearest river. Today's modern
sanitary system, with its maze of underground pipes,
pumps and treatment techniques, is a direct descend-
ant of the communal and private cesspits and open
sewers which emptied into rivers. For centuries, water
as a waste-removal vehicle functioned adequately
from the urban resident's standpoint. Ecologically,
the price may have been high, but urban users found
it convenient because it allowed them to simply flush
wastes and forget them. Only those people living
downstream might be forced to question the wisdom
of such a system.
Now, though, as cities grow larger and rivers be-
come more saturated, increasing numbers of people
are finding themselves living downstream. In area
after area, urban growth is creating major water prob-
lems which are becoming front-page news stories. For
example, Virginia's Fairfax County, a suburb of Wash-
ington, has been forced to declare a moratorium
throughout most of the county on residential and
commercial sewer applications.
A major villain in each case is the flush toilet. Of
all home water users, the flush toilet is the biggest
single consumer: The average North American family
annually uses 35,200 gallons for toilet flushing.
In addition to water costs, the economic costs of the
flush toilet and centralized waste treatment are rising.
Currently, the investment in the utilities infrastruc-
ture in Western countries is around $500-$600 per per-
son. This contrasts sharply with a country such as
Tanzania, which in 1969 could spend only $8 per
urban inhabitant. Thus, because of costs, the "mod-
ern" sanitary system, which Westerners now take for
granted, is out of reach to most of the world's popu-
lation. Reportedly, 70 percent of the human race does
not even have piped water. The World Health Orga-
Future archaeologists might well misinterpret today's
plumbing as a centralized food-distribution system.
nization estimated in 1972 that only 8 percent of
urban families in developing countries of Asia and
Africa had access to a sanitary sewage system.
Moreover, energy costs of large centralized sewage-
treatment systems are staggering. While the profes-
sional literature is slim in this area, one estimate is
that, at full capacity, a 309 million-gallons-a-day
waste-treatment system, such as that being built now
for the Washington, D.C., area, will consume as much
as 900,000 kilowatt hours of electricity, 500 tons of
chemicals and 45,000 gallons of fuel oil daily. Some
environmental groups, however, consider this estimate
to be a low one and point out that, in any case, burn-
ing the sewage to produce 400 dry tons of sludge each
day will create a major air pollution problem. Thus,
even if the water required for the flush-toilet system
were available in abundance, the growing scarcity of
the other resources that support such a system is be-
ginning to impose limits.
Already the flush-toilet, central waste-treatment sys-
tem is in trouble. One response from toilet manufac-
turers was to begin marketing a "water-saver closet,"
which uses one-third less water than many older mod-
els now in use. Although major manufacturers have
had water savers available for several years, an indus-
try source says that these toilets account for no more
than five percent of those installed today. He attrib-
utes the lack of sales to public apathy concerning
62
-------
One new toilet design, which freezes wastes for
later removal, had disadvantages to be worked out.
water problems and the slightly higher price of the
water savers.
Even with water savers, however, many of the flush
toilet's basic problems still exist, so some people in
the field are actively pushing alternative methods of
human waste disposal both on a public and a private
level. Dr. John R. Sheaffer, a resource manager with
the Chicago firm of Bauer, Sheaffer and Lear, con-
tends that one possibility is simply to use the nutrient-
rich sewage, after deodorizing and disinfecting it, to
irrigate agricultural lands and let the water filter
through the soil and into an "under drainage" system
where purity can be monitored. The soil naturally
cleanses the liquid wastes, except during freezing
winter months, when the sewage can be stored for
spraying on fields later.
Dr. Shearer's system has been tried in communities
and found to work successfully. Bakersfield, Califor-
nia, and Abilene, Texas, are among larger cities that
rely on land treatment of sewage. These systems use
far less energy and chemicals than the advanced waste-
treatment system, which tries to restore the waste
water to its original quality. Michigan's Muskegon
County recently put into operation a large (28-mil-
lion-gallons-a-day) system using Dr. Sheaffer's "living
filter" principle.
Among its advantages is the fact that the land treat-
ment system lets man work with nature, not against it.
But its critics are quick to point out that land treat-
ment requires large areas of land, a commodity that is
also in short supply around large metropolitan areas.
There is also concern among health officials that such
systems might not screen out potentially harmful
viruses, bacteria and industrial chemicals. Dr. Sheaf-
fer's answer is that the water in projects he has worked
with has always met pure-water specifications. In ad-
dition, the drainage system prevents salt build-up and
waterlogging of soil.
For all its promise in cities that already have the
plumbing, access to agricultural land and abundant
water, land-treatment schemes fall short of meeting
criticism that challenges the centralized waste-treat-
ment approach with all of its piping, rights-of-way,
energy use, water waste and control regulations.
One critic of the centralized flush-it-and-pass-it-on
system, Berkeley architect Sim Van der Ryn, has imag-
ined how future archaeologists, sifting through the
material remains of our present culture hundreds of
years from now, will interpret the curiously shaped
ceramic bowl in each house, hooked up through miles
of pipe to a central factory of tanks, stirrers, cookers
and ponds, emptying into a river, lake or ocean. Ac-
cording to Van der Ryn their report might read:
By early in the twentieth century, urban earthlings
had dievised a highly ingenious food production
system whereby algae were cultivated in large cen-
tralized farms and piped directly into a ceramic food
receptacle in each home.
A search for alternatives
The difficult challenge is to find a workable alter-
native. In a publication entitled "Stop the Five Gal-
lon Flush!" the Minimum Cost Housing Group at
McGill University's School of Architecture in Mon-
treal examined systems from around the world that
are designed for home use, and catalogued 52 of
them from 11 countries. In their evaluation, the
group steered clear of thinking of the modern flush
toilet as "advanced," compared to a technology such
as the pit latrine. As the researchers point out, "under
certain conditions the latter is ecologically sound,
cheap and quite safe."
What they found is a tribute to human ingenuity.
For example, you can purchase a toilet from a Nor-
wegian company for about $400 which uses an at-
tached freezer to solidify the wastes so that there is no
smell and no bacterial action. The toilet does require
electricity, but no water or chemicals. The wastes are
stored in a biodegradable plastic bag which can later
be composted. At first the toilet suffered from a slight
technological problem: The refrigerated air not only
froze the waste, but it also chilled the seat, in turn
63
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Flush toilets: a passing idea
chilling consumer interest. Now, however, freeze toi-
lets stream warm air from the refrigeration unit's
compressor over the seat to keep it warm.
If the freeze toilet doesn't light consumer fires,
there are a variety of toilets that go to the other ex-
treme; they incinerate the wastes with natural gas and/
or electric heat. A,Swedish design, the Pactor 101, uti-
lizes the versatility of plastic to collect waste in a tube
which is sealed by heat after each use to form a link
in a large plastic "sausage." The chain is then stored
in a removable plastic bag until it is discarded, along
with other nonbiodegradable industrial age byprod-
ucts, somewhere in the great "away."
The World Health Organization, with headquarters
in Geneva, has another, more ecological, approach:
It offers plans for constructing a small-scale plant
that can recover methane gas from human and ani-
mal wastes. The gas can be used for cooking, heat-
ing or for power. Critical to the operation of such a
unit is an abundance of manure so that animals,
which produce larger quantities of manure than peo-
ple, are essential to this approach. Horses and cows
produce about 10 to 16 tons of waste per year, whereas
humans add only 30 to 60 pounds per capita in the
same time period. What humans lack in quantity, they
make up in quality; our waste is rich in nitrogen and
phosphorous, needed for biological digestion and
methane production from materials such as cellulose,
which have a high carbon content. The World Health
Organization points out that a ton of manure can
yield 65 to 90 cubic yards of gas per digestion cycle,
depending upon the temperature. A cycle can be from
1 to 12 months. The initial costs of such systems are
comparatively high, but operation and maintenance
are insignificant.
For those without the necessary animals to support
a methane toilet, the Swedes, who are undoubtedly
emerging as the leaders in the world's alternative-toilet
development race, have come up with another design
which uses virtually nothing as a transport medium,
thus eliminating the problems created by moving
wastes with large volumes of water. This toilet, manu-
factured by Sweden's Electrolux Company, utilizes a
vacuum pipe to move wastes. Invented in the 1950s,
it has been applied successfully in a number of differ-
ent scales of operation, including railroad cars, a camp
site with 83 toilets and a small community of 273
homes. The advantages of the system are that it re-
quires only a small amount of water, less waste is
created which has to be stored and removed, and
smaller pipes can be used. Although cheaper to oper-
ate than a conventional system, its initial costs are
high: A one-toilet installation costs about $1,200.
Other countries have also developed interesting de-
signs which rely upon water, utilizing it much more
efficiently. A Japanese model, made by Toto Ltd., takes
the bold step of mating the standard washbasin with
the standard toilet. The result is a freestanding unit
which uses water from the sink, mounted on the top
of the toilet tank, for flushing. The saving on water
from this integration is around 25 percent. In addi-
A freestanding Japanese model saves water by mating
a standard washbasin with a standard water closet.
-------
tion, there are also savings in cost and space, since
the two bathroom fixtures occupy the space normally
required by one. The Minimum Cost Housing Group
at McGill University has modified this design and cast
it in sulfur concrete, an extremely cheap material,
so that these toilets can be made for about $50. An
English modification, marketed by Ideal-Standard
Ltd. for less than $20 each, allows a person to selec-
tively flush the toilet. The tank releases either one or
two gallons depending upon the requirements. Uru-
guay has produced a flexible toilet tank which func-
tions on the principle of the punching bag. It has
virtually no moving parts and is activated when the
user depresses a plastic cistern by hand so that water
an flow into the downpipe. This gives the user con-
trol over the amount of water released.
Even these ingenious approaches to waste removal
have their drawbacks, because they are either too ex-
pensive for much of the world's population, or use too
much energy or water. But after a careful search for
toilet alternatives, another approach to the waste prob-
lem is beginning to interest increasing numbers of
people—composting.
The principle of using human waste or night soil as
fertilizer has been known and utilized in some cul-
tures for centuries, although it has been little used in
the West. In the late 1930s Rikard Lindstrom, a Swed-
ish art teacher, began experimenting with a toilet that
would compost human waste for use on his garden. He
was also motivated to work on the system out of con-
cern for the sewage contamination of the Baltic bay
near his home. The product of his work is the Clivus
Multrum, a toilet which successfully composts wastes
without water, electricity or chemicals. The name
comes from clivus, which is Latin for "inclining," and
multrum, which is Swedish for "composting room."
How the Clivus works
The device itself is a fiber glass container about
nine feet long, three feet wide and five feet high. It
contains three compartments, a top one for human
waste, a middle one for vegetable scraps and other
organic refuse, and a lower one which holds the fin-
ished compost. A vent pipe at the top of the compost-
ing chamber allows odors and gas to exhaust out the
top of the house. The early Clivuses had to be installed
in basements directly underneath the bathroom and
garbage chutes, but a later model utilizes a screw trans-,
port to move wastes so that the toilets and composting
chamber can be mounted at the same level. It also
allows multiple toilets to be connected to the same
Clivus. The Clivus is odorless, thanks to a unique de-
sign which utilizes the heat created by composting
organic matter. The heated air in the chamber rises
What human waste lacks in quantity, compared
to cows, it makes up in quality, being rich in nitrogen.
through the vent pipe, thereby creating a downdraft
at the toilet stool and garbage chute. It is strong
enough to pull the flame of a ma tch downward when
held over the toilet.
To get the composting process started, the bottom
of the container must be lined with organic material
such as peat, garden soil and grass clippings. After the
initial loading the process continues indefinitely, pro-
ducing several buckets of humus per year per person.
The newly formed rich soil in the bottom chamber
can be removed about once a year, after a startup
period of about two years.
In Sweden and Norway more than a thousand
Clivuses are in operation, and it has been given the
blessings of the Swedish Ministry of Health. Some
communities in Sweden even give Clivus owners a tax
rebate because they reduce the cost of municipal serv-
ices such as sewage and garbage collection. Extensive
tests by Swedish health authorities have found that no
harmful bacteria, viruses or parasites can withstand
the year or so of heat and bacterial action produced
by the composting process. Although tests indicate
that the end product of the Clivus process is perfectly
safe for garden use, Organic Gardening and Farming
magazine recommends, as an extra safety precaution,
that it not be used on edible root crops. It can be used
on other plants.
The composting toilet is getting widespread use in
Scandinavia, but only a few have been sold in the
United States. A firm in Cambridge, Massachusetts,
Clivus Multrum USA, Inc., has acquired a franchise
65
-------
for the system and is now producing them in a plant
in Maine. Although costs are still high at about $1,500
per installation, this is expected to come down with
mass production. Experiments are also under way to
fabricate the toilet out of cheaper materials.
The state of Maine has recently rewritten its
plumbing code to permit the installation of compost-
ing toilets. Some health authorities in other states are
also allowing them to be installed experimentally.
Established and backed by Abby Rockefeller, the
company she has created is staffed by people who pro-
mote the toilet with all the fervor that her ancestors
used to sell Americans on Standard Oil. "I look at it
this way," says Bob Pacheco, the installations director
who, if possible, personally visits the site of each in-
stallation. "I don't like the idea of turning the oceans
and rivers into open sewers. Every Clivus I install in
a family dwelling could mean 40,000 gallons less sew-
age for Boston harbor or another body of water."
The Clivus can handle all human waste, including
urine, plus table scraps and other organic material
such as the contents of the vacuum cleaner bag, but it
cannot handle too much water. As a result the "gray
water" produced by washing dishes or hands must go
into a conventional system. But Miss Rockefeller
thinks she can solve that problem. Her next project
is a greenhouse adjacent to her conventional frame
house in Cambridge that will utilize waste water to
grow plants. She has installed a Clivus in her house
and reports no trouble after more than a year of oper-
ation. To get the composting process going, she
dumped into her Clivus all the organic wastes from a
neighborhood restaurant. She has also added earth-
worms and other creatures to see if they can tolerate
the heat and speed of the decomposition process.
The initial costs may appear prohibitively expen-
sive, yet it is already competitive in areas where steep
sewer hookup fees are required for conventional toi-
lets. As mass production and alternative materials
bring the Clivus' price down, it will be even more
attractive. In addition, a group that Sim Van der Ryn
works with in California, the Farallones Institute, is
experimenting with ways people may build their own
composting toilet. Their initial model can be built for
less than $100 out of concrete blocks.
Some may view the composting toilet as simply a
throwback to the outhouses of the past and reject it,
but that would be shortsighted. Its time appears near
at hand, as "No swimming, fishing or boating" signs
pop up with increasing frequency on the banks of our
rivers. With no connections to external networks, no
moving mechanical parts, and its useful by-product,
the composting toilet is a beautifully simple piece of
technology of which a society could be proud.
Many benefits would accrue if we used our heads
instead of'using our rivers as the great "away."
imming,
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Box 211
Block Island, R.I.
June 3, 1975
Mr. John A. S. McGLennon
Regional Administrator
Region I
U. S. .Environmental Protection Agency
J.F. Kennedy ELdg.
Boston, Mass. 02203
Dear Sir:
We write as year-round Block Island residents, taxpayers and voters to ask
that jsPA adopt the firm position that Alternative D (Draft JSIS, dated March
21, 197$) is the outer limit of any island sewer system entitled to receive
construction funds through the U. S. Environmental Protection Agency.
It is our understanding after reviewing Congressional debate and legislation
leading to the creation of J5PA that it (JBPA) shall not become a party to
any plan for the enrL chment of the business segment of a community, or in-
deed a whole community, at the risk of damage to that community's environ-
ment. The role of assisting private enterprise, in any case, has been
tradionally assigned to the Department of Commerce.
Examination of the record of the BPA May 10 hearing on Block Island will
demonstrate that those advocating extension of the proposed sewer to the
New Harbor area, and opposing Alternative D, do so for commercial reasons,
despite the threat to the environment clearly spelled out in your Draft
Environmental Impact Statement.
The resolution adopted Monday, June 2, by the island Town Council does not
and cannot represent the views of selreral hundred property owners who are
deprived of voting rigits on such questions as the sewer because they are
registered voters in eastern states other than Rhode Island.
These disenfranchised property owners are Federal taxpayers, yet their
voices are not heard on this Federal matter because of a local rule. We
cannot believe that Congress intended to place the destiny of SPA funds in
the hands of any local group which manages to capture and manipulate the
political machinery.
Finally, it is a curious development that the Town Council is stubbornly
opposed to a referendum even with the limitations
-------
I. M. Pel FAIA
Eason H. Leonard FAIA
Henry N. Cobb FAIA
I. M. PEI & PARTNERS Architects
Bartholomew Voorsanger AIA
Associate
Associate Partners
Leonard Jacobson AIA
James L Freed AIA
Werner Wandelmaier AIA
June 6, 1975
Mr. John A. S. McGlennon
U. S. Environmental Protection Agency
J. F. Kennedy Bldg.
Boston, Mass. 02203
Re: Draft Environmental Protection Study
Town of New Shoreham
Water Pollution Control Facility
Dear Mr. McGlennon:
The enclosed comments regarding the above Draft EIS were sent
on May 29, 1975, by Telex from Tehran, Iran. Because of the uncer-
tainity of communication from that part of the world, I am sending a
copy by mail.
Please note an error in transmission in Part 2 of my Telex
which I corrected in ink.
Thank you.
BV/ar
600 Madison Avenue, New York, New York 10022 PLaza 1-3122 Cable: IMPABCE Telex: 127953
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