Background on Case Studies - Environmental Impact Analysis: Process and Methods - page 362

many federal agencies defer to mature state environmental programs if the state
entity has primary responsibility. In such cases either a “piggyback” (i.e., com-
bined state and federal analysis and documentation) environmental analysis or
incorporating the analysis conducted under the state program by reference is
conducted to meet both state and National Environmental Policy Act (NEPA)
requirements. However, for the Boston Harbor Cleanup the U.S. EPA, which was
responsible for issuing the discharge permit under the Clean Water Act, decided
to conduct a separate and independent environmental impact analysis under
NEPA. This decision was largely based on the history of the situation and past
problems, inactivity of the state agencies involved with wastewater manage-
ment, and oversight.
As described in detail in Section 6.3.1, the cleanup was too complex and
wrought with controversy to address at one time with a single comprehen-
sive solution. Thus the process was a multilevel environmental impact analy-
sis, with the first step being an original EIS addressing the key issue and past
primary stumbling block of where to site the wastewater treatment facility.
This EIS also delegated to subsequent tiers the other environmental analyses
and decisions including:
r Type of wastewater treatment
r Conveyance of raw wastewater
r Location of effluent discharge
r Residuals management, both interim and final
r Combined sewer overflows (CSOs)
The first of these three were addressed by a supplemental EIS (U.S. EPA
1988), which as described in Section 6.3.1 was actually a tiered EIS under the
current use of the term. The next issue (residuals management) was addressed
by an interim plan and then another supplemental EIS. The environmental
impact analysis of the final issue, CSOs, was delegated to the state program
(MEPA) because by that time Massachusetts and MWRA had demonstrated
their competence and commitment to the cleanup of Boston Harbor.
The major elements of the Boston Harbor Cleanup proceeded to comple-
tion in 2001 (Figure 10.1). The sanitary wastewater from the metropolitan area
was reliably collected, treated, and discharged to Massachusetts Bay with con-
tinuous monitoring under the Clean Water Act National Pollutant Discharge
Elimination System (NPDES). Almost two decades of monitoring has demon-
strated attainment of water-quality standards and environmental sustainabil-
ity. It has also confirmed the prediction of impacts in the EIS. The wastewater
residuals program has been similarly successful, achieving near full reuse of
the solids as an agricultural product, and the discharge of sludge to Boston
Harbor has ceased, hopefully for all time. There have been major achievements
and advances in CSOs, but it is an ongoing program with improvements added
every year on an as-needed basis.