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Final Environmental Impact Report - Whittier Bridge/I-95 ...

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<strong>Whittier</strong> <strong>Bridge</strong>/I-<strong>95</strong> Improvement Project FEIR<br />

Chapter 2.0: Response to Comments on the <strong>Environmental</strong> Assessment/Draft <strong>Environmental</strong> <strong>Impact</strong> <strong>Report</strong><br />

MassDOT has also provided each conservation commission with an independent peer review of the<br />

Notice of Intent applications.<br />

DEP-18: Tables 6 to 9 list a number of wetlands where no stormwater treatment appears to be proposed for<br />

redevelopment drainage. In application of the macro-approach, which provide stormwater standards may be met on<br />

sub-watershed basis versus at each separate discharge outlet, disproportionate impacts to any one wetland must still<br />

be avoided. For example, drop inlet structures may be able to be converted to deep sump catch basins to provide at<br />

least some level of TSS treatment to avoid disproportionate impacts to any one wetland.<br />

Response: The comment is noted. MassDOT has provided supplemental information to the<br />

conservation commissions to demonstrate compliance with the standard as described in<br />

section 1.4.2.<br />

DEP-19: Additionally, Tables 6 to 9 should be reviewed to ensure MassDOT is properly credited with treatment to<br />

wetlands it appear to be proposing but may not have taken credit for. MassDOT will need to document to each<br />

conservation commission that the redevelopment drainage within their town boundaries meet the TSS standard<br />

through exercise of macro-approach to maximum extent practicable and improve existing condition.<br />

Response: The comment is noted. MassDOT has provided sufficient information to the conservation<br />

commissions to demonstrate compliance with the standard as discussed in Comment DEP-10 and<br />

DEP-17.<br />

DEP-20: MassDOT has indicated to MassDEP that there are no discharges in the Zone II in Newburyport, limited<br />

recharge in the Zone II of Salisbury, no discharge or treatment in the Newburyport Zone A, and no direct discharge,<br />

other than from scuppers, into the Merrimack River. This information should be confirmed in the FEIR.<br />

Response: As noted in the comment, there are no stormwater discharges located in the Zone II in<br />

Newburyport, limited recharge in the Zone II in Salisbury, no discharge or treatment in the<br />

Newburyport Zone A and no direct discharge other than scuppers into the Merrimack River.<br />

DEP-21: Design of Wet Basin 9A in conjunction with Infiltration 9B needs to be reviewed further to ensure wet basin<br />

treatment is not short circuited.<br />

Response: The comment is noted. MassDOT has provided this information to the Salisbury<br />

Conservation Commission.<br />

DEP-21A: A long term pollution prevention plan (LTPP) needs to be provided to each conservation commission as<br />

part of meeting stormwater standard 4 (310 CMR 10.05(6)(k)(4)(a) and 314 CMR 9.06(6)(a)(4)(a)). The LTPP needs<br />

to identify source control activities to be implemented. The LTPP needs to be specific to the <strong>Whittier</strong> <strong>Bridge</strong> project. A<br />

generic state-wide plan is not sufficient to serve as the LTPP.<br />

Response: MassDOT has prepared a project-specific LTPP and submitted it to the conservation<br />

commissions as part of the wetlands permitting process. The LTPP is attached as Appendix A. In<br />

general, LTPP measures and related maintenance activities will be conducted consistent with the<br />

MassDOT NPDES Stormwater MS4 Permit, and the measures outlined in MassDOT‘s Stormwater<br />

Management Plan (SWMP). LTTP measures identified in the document include the following: litter<br />

2-25

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