Clean Water Action

John McNabb has sent the following letters to DEP and MEPA:

Department of Environmental Protection Letter - Click here
MEPA Letter - Click here

Department of Environmental Protection Letter

December 28, 1999

Mr. David Ellis

Southeastern Regional Office

Department of Environmental Protection

20 Riverside Drive

Lakeville, MA 02347 FAX TO: 508-792-7621 (8 pages)

RE: Abington Transfer Station, BWP SW 05, Transmittal # 204518

Dear Mr. Ellis:

Clean Water Action urges you to REJECT the Application for a Large Handling Facility, submitted by the Abington Transfer Station, or at the very least stay consideration until such time as the applicant has completed an Environmental Impact Report that has been approved by MEPA.

The project is a proposed 1,800 ton per day transfer station which would take in putrescible waste, household garbage, and commercial trash, as well as construction & demolition waste, in what would be the largest solid waste transfer station in New England. The project would be located at a site within close proximity to many residential homes and on already congested Route 18.

The application should be REJECTED because of its many deficiencies and because an EIR has not been prepared yet for this proposed facility, although the project obviously would result in many significant adverse environmental impacts to both Abington and Weymouth, such as:

TRAFFIC. The existing traffic study conducted for the proponent is obviously inadequate, according to the public testimony at the December 15 MEPA consultation meeting (which you attended) in Abington. These deficiencies include: being conducted in the summer, when there was no school bus traffic; being limited to a small area that did not include nearby Route 3 only four miles away; and inadequate provision for acceptable gaps between trucks entering and leaving the facility. A new traffic study, appropriately scoped by MEPA, is required before further review of this application.

ODORS & AIR QUALITY. The 1,800 tons per day capacity of solid waste and the 744 trucks per day added to the roadways will inevitably cause a severe odor problem for the surrounding residential and business areas that needs to be addressed in an EIR.

Since many trucks will be idling outside the facility at all times with their loads of solid waste, and the bay doors will be open all the time during facility operations, it seems clear that there will be significant odor impacts from both this enormous quantity of solid waste as well as from the fumes from the trash trucks. An odor and air quality impacts study, appropriately scoped by MEPA, is required before further review of this application.

VECTORS. There has been little attention paid to adverse vectors such as seagulls, which are inevitably attracted to transfer stations that take garbage, and other vectors including rats, mice, insects, and other vermin that will be attracted to the facility in droves because eof its abundant food supply. A comprehensive vector study, appropriately scoped by MEPA, is required before further review of this application.

GROUNDWATER. According to the existing site assignment (which the Board of Health plans to reconsider), the facility is in fact less than the required two feet above the maximum groundwater table. While "passive dewatering" has been proposed as a mitigation measure, DEP should view with skepticism such proposed "mitigation" of such a severe violation of the Site Suitability Criteria. A study of the potential adverse effects of the facility on groundwater, appropriately scoped by MEPA, is required before further review of this application.

Finally, we urge DEP to be skeptical of any claims made by the proponent, particularly any claims that the facility will be operated properly, and to be aware and to take into account the proponents compliance history for the other solid waste facility, the Cohasset Heights Ltd. (CHL), which they operated from 1982-1998. A review of the MEPA records for that facility (EOEA #7223), and the DEP records at the Northeast Regional Office in Wilmington, will show that CHL has had many violations of the solid waste regulations, and is still in violation of their site assignment and their DEP plan approval (for exceeding permitted slopes). We understand that there are a number of still pending enforcement actions by DEP against CHL. Please see the enclosed partial list of violations and enforcement/operational issues for CHL 1982-1998, and the news clipping about the owner of CHL admitting to a violation of the site assignment.

A project of this size and scope clearly should not be approved by DEP prior to the preparation of an EIR, and we again urge DEP to REJECT this application or at the very least delay any further consideration until the proponent prepares and EIR that has been approved by MEPA. Thank you.

Very truly yours,

John K. McNabb, Jr.

CLEAN WATER ACTION

Enclosure

cc: Senator Robert L. Hedlund

Senator Michael W. Morrissey

Senator Robert S. Creedon

Rep. Paul R. Haley

Rep. Ronald Mariano

Rep. Kathleen Teahan

MEPA letter to Robert Durand

December 28, 1999

Secretary Bob Durand

Executive Office of Environmental Affairs

ATTN: MEPA Office, William T. Gage, EOEA # 8694

100 Cambridge Street - 20^th Floor

Boston, MA 02202 FAX TO: 617-727-2754 (7 pages)

RE: Abington Transfer Station - Notice of Project Change

Dear Secretary Durand:

Clean Water Action urges you to require the preparation of an Environmental Impact report for this project. While the issue before your office are the four project changes described in the Notice of Project Change, we request that you utilize your discretion to require an EIR be prepared for the entire project as a whole.

An EIR has not been required yet by MEPA for this proposed facility, although the project obviously would result in many significant adverse environmental impacts to both Abington and Weymouth which clearly warrant the preparation of an EIR, such as:

TRAFFIC. The existing traffic study conducted for the proponent is obviously inadequate, according to the public testimony at the December 15 consultation meeting in Abington. These deficiencies include: being conducted in the summer, when there was no school bus traffic; being limited to a small area that did not include nearby Route 3 only four miles away; and inadequate provision for acceptable gaps between trucks entering and leaving the facility. A new traffic study, appropriately scoped by MEPA, is required.

ODORS & AIR QUALITY. The 1,800 tons per day capacity of solid waste and the 744 trucks per day added to the roadways will inevitably cause a severe odor problem for the surrounding residential and business areas that needs to be addressed in an EIR.

Since many trucks will be idling outside the facility at all times with their loads of solid waste, and the bay doors will be open all the time during facility operations, it seems clear that there will be significant odor impacts from both this enormous quantity of solid waste as well as from the fumes from the trash trucks. An odor and air quality impacts study, appropriately scoped by MEPA, is required.

VECTORS. There has been little attention paid to adverse vectors such as seagulls, which are inevitably attracted to transfer stations that take garbage, and other vectors including rats, mice, insects, and other vermin that will be attracted to the facility in droves because eof its abundant food supply. A comprehensive vector study, appropriately scoped by MEPA, is required.

GROUNDWATER. According to the existing site assignment (which the Board of Health plans to reconsider), the facility is in fact less than the required two feet above the maximum groundwater table. While "passive dewatering" has been proposed as a mitigation measure, MEPA should view with skepticism such proposed "mitigation" of such a severe violation of the Site Suitability Criteria. A study of the potential adverse effects of the facility on groundwater, appropriately scoped by MEPA, is required.

Finally, we urge MEPA to be skeptical of any claims made by the proponent, particularly any claims that the facility will be operated properly, and to be aware and to take into account the proponents compliance history for the other solid waste facility, the Cohasset Heights Ltd. (CHL), which they operated from 1982-1998. A review of the MEPA records for that facility (EOEA #7223) will show that CHL has had many violations of the solid waste regulations, and is still in violation of their site assignment and their DEP plan approval (for exceeding permitted slopes). Please see the enclosed partial list of violations and enforcement/operational issues for CHL 1982-1998,

A project of this size and scope clearly requires the preparation of an EIR before any work is allowed to commence on the project. We urge the Secretary to require an Environmental Impact Report for this project. Thank you.