| Wastewater | Deer Island, Boston Harbor - Page 13 |
| The requirement of secondary treatment in the 1972 Clean Water Act was a logical standard for sewage treatment plants on inland waterways. The effluent from those plants would be discharged into freshwater rivers and lakes where there would be limited mixing available. The standard required that the effluent released by those sewage treatment plants needed to be swimmable, fishable, (and with some limited further treatment, drinkable) by people downstream. Officials from coastal communities argued that secondary treatment was not needed because they could discharge primary treatment effluent into deep waters where strong currents and the vastness of the ocean offered effective dilution, not be harmful to the environment because of this, and save a great deal of money. Scientists on the U.S. West coast had backed the idea noting the strong ocean currents existed only fifty miles offshore where the ocean dropped quickly to over 10,000 feet deep. It is 300 miles east of Boston across relatively shallow waters before a similar depth is reached. The waters are important for recreational and commercial fishing, and frequented by several whale species, dolphins, porpoises, seals, and sea turtles. |
In the spring of 1974, the EPA established a task force to study the issue. Their April 1976 EPA report, Secondary Treatment of Municipal Ocean Discharges, the task force concluded that, “For certain ocean waters the removal of the soluble oxygen demanding materials (soluble BOD) may not be necessary,” that is, secondary treatment would not be required. The caveat was that the analysis in the report only applied to, “certain ocean waters,” including the West coast of the United States, Hawaii, Puerto Rico, America Samoa, and the Virgin Islands.
In December of 1977 President Jimmy Carter signed into law amendments to the 1972 Clean Water Act. One of them, Section 301(h), allowed coastal communities to apply for an exemption from building secondary treatment plants instead allowing for discharge of primary treated sewage if it could be proven that it did not result any harm to the environment. There was no mention in the amendment of any specific cities or regions. All could apply, but to apply for the waiver a detailed environmental study would have to be done of proposed outfall location. The report would then be submitted to the EPA for evaluation. If rejected, the process allowed for the city to reapply after conducting another study to address any issues that had been raised in the first.
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| This was it. Dukakis and Snedeker had put as many roadblocks as they could trying to prevent the building of a secondary treatment plant on Deer Island. Now they had the means to knock the process completely off the rails ending any hope that a solution to cleaning up Boston Harbor would even be started before the end of the 1970s. They were not required to apply for a waiver. They could have continued to work through issues raised by the Environmental Impact Reports underway and ensure that though likely delayed a project could have been completed by the mid-1980s. Their legacy could have been champions of cleaning the up the harbor. Others would earn that honor. |
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The MDC hired Metcalf & Eddy to prepare the filing that would allow Boston to avoid adding secondary to their sewage treatment plants. The report titled, Section 301(h) Application for Modification of Secondary Treatment Requirements for its Deer Island and Nut Island Effluent Discharges into Marine Waters, was submitted, all five volumes of it, in September of 1979. Though they initiated its writing Dukakis and Snedeker were both be out the offices they had held by then. In a topsy-turvy political season Dukakis had been “primaried” by the conservative Democrat Edward J. King, who then went on to beat the liberal Republican candidate, Francis W. Hatch Jr. After the primary Snedeker left the MDC and rejoined the administration of Boston Mayor Kevin White as the executive director of the Water and Sewer Commission. True to form, and to the pleasure of his boss, he cut Boston water bills by 11.6% the next year. Better bill collection was given as the reason with the odd logic that somehow the cut would “allow us to get on with the problems of handling 2,500 miles of distribution of water and sewers.” He did concede the system had been badly neglected and that not enough money for annual maintenance. It is unclear how he meant to pay to correct the situation. |
| The 1979 study Metcalf & Eddy produced for the 301(h) waiver is not available online. It is likely a very technical set of documents. The focus now had shifted from the harbor and MDC member communities to the Massachusetts Bay. Their recommendation was to discharge 520 million gallons of primary treated wastewater a day in about 100 feet of water from a tunnel extending 7.5 miles east from Deer Island into the bay. Sections of the President Roads nautical channel entering Boston Harbor are 90 feet deep. The application was rejected by the EPA. The MDC reapplied as they were allowed relocating the outfall just under two miles further into the Bay. The EPA rejected the second application. The whole process had taken seven years. There had been delays and significant political pressure placed on the EPA to widen the criteria they had set for when an exemption from secondary treatment would be accepted, but the agency resisted the pressure and ultimately did not approve any waiver for large publicly owned treatment works (POTW) on the East Coast. If had been approved, Boston’s waiver would have been the largest. |
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The delay that resulted from applying and then reapplying for the 301(h) waiver is often given as the reason why Boston did not advantage of the initial offer from the EPA to fund 75% of the harbor cleanup project. For local and state politicians the rational for advocating for a waiver is obvious, to prevent having to tell their constituents that they will have to pay for an expensive secondary treatment plant. Oddly, there are examples of highly intelligent people who argued that Boston officials, including Governor Dukakis, should not be blamed for applying for the waivers. One such person was the highly respected Harvard Law School professor Charles M. Haar. In the mid-1980s he would author a report for Judge Paul G. Garrity that was key to the decision that led to the cleanup of the harbor. In an October 18, 1988 New York Times article, Mr. Bush Sinks the Truth in Boston Harbor, Haar complained that the decision to prevent Boston from receiving a 301(h) waiver was purely political and aimed at the Massachusetts governor. He noted that the EPA had granted waivers to 16 coastal communities in New England including Kennebunkport, the location of then Vice President George H.W. Bush’s Walker’s Point summer retreat, but not Boston. It is difficult to believe that Haar did not understand the difference between Kennebunkport’s less than 0.7 mgd effluent discharge compared to 500 million plus mgd discharge from Boston’s Deer Island treatment plant. Later, Paul Levy, who as executive of the Massachusetts Water Resources Authority (MWRA) would successfully lead the agency through the difficult first stages of the harbor cleanup, would argue in a 1991 statement to a U.S. House subcommittee that the MWRA was somehow tricked into applying for the 301(h) waiver, stating that Boston was “encouraged by the EPA” to apply. It would be the next MWRA director, Douglas MacDonald, who put it in simple terms why the waiver was never accepted. In a 1995 report to a U.S. House committee, he was asked how Boston’s 301(h) waiver request compared to that of San Diego, Calif. He explained, “the distinction between our situation and San Diego is that San Diego discharges about half as much water as we do, and the discharge in twice the depth of water.” |
| In the mid-1970s the opinions of Charles Haar, Paul Levy, and even the existence of the MWRA, was in the future. On Deer Island in the mid-1970s an experiment was underway to prove that high-energy radiation could be used to destroy disease causing micro-organisms in the sludge making it safe for use as compost or fertilizer. The head of the project was a noted MIT professor and a pioneer in the scientific, engineering, and medical applications of high-voltage radiation. He had earned international praise for his work starting in the mid-1930s solving the problems of delivering radiation to deep cancer tumors without destroying the intervening healthy tissue. Late in his career, upset by pollution in Boston Harbor, he turned to the idea of using a high-voltage electron beam to destroy disease causing bacteria and viruses in the sludge the Deer Island treatment plant produced. When he died in 1985 his name joined a list of many other prominent MIT professors who made significant scientific contributions to society. John G. Trump would gain added recognition when 30 years after his death his nephew would become president of the United States. |
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Working with a grant from a National Science Foundation’s RANN (Research Application to National Needs) program, Trump and his colleagues installed in a concrete shielded building a high voltage 50-kilowatt electron accelerator that delivered doses of radiation to a wide thin stream of sludge that flowed below. After a few years of operation the study was done, the equipment disassembled, and a paper written. The system had proven that an electron beam could efficiently at low cost disinfect sludge killing bacteria, destroying viruses, parasites, and some toxic chemicals. While only a test the system could process one-third of the plant’s sludge output. Clearly a success. Electron-beam processing is in regular use today for sterilizing of medical products, ensuring aseptic packaging for foods, and for disinfection of live insects from grain and tobacco crops. While research continues the technology is not being used at any sewage treatment plant in the United States. For Boston the problem was what do with the highly watered sludge. It had to disposed of somewhere and as the U.S. Army discovered land application was not a popular option. The alternative was to dry the sludge and that process while using far more energy provided similar sterilization to electron-beam processing and needed to be done anyway to dewater the sludge. |
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