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

Whittier Bridge/I-95 Improvement Project FEIR
Chapter 2.0: Response to Comments on the Environmental Assessment/Draft Environmental Impact Report
Shut-off devices can be problematic, because they may be operated by personnel who are
not trained in spill response, potentially resulting in extremely unsafe conditions. Also, the
devices are subject to vandalism, weather-related corrosion, and mechanical malfunction
resulting from prolonged exposure and non-use, so that they may not be reliable in a spill
event.
2. ―First Responders‖ are anticipated to be trained in the management of a broad array of types
of spills, which would include the use of specialized equipment and materials brought to the
spill site for controlling and cleaning up spills. However, these first responders may not have
specific knowledge of the location, functional condition, and operating procedures for shut-off
mechanisms that are located at a particular site, and may therefore not be able to use them
in a timely and effective manner. Note that state and local highway department personnel are
not generally first responders to spill events.
3. Shut-down devices can only be effective if the spill occurs within the component of the
drainage system to which they are attached. The effectiveness of any one containment
device is limited, because many events resulting in spills (e.g., truck rollovers) occur off the
pavement, and outside of the contributing area of the drainage system. It is not possible to
design and construct road improvements so that every spill will be captured by the drainage
system.
DEP-23: A construction period erosion control and pollution prevention plan (CP/PP) is required to be submitted as
part of the Wetlands NOI and 401 submissions. While MassDEP allows the CP/PP to be submitted prior to land
disturbance for projects such as this one that must obtain a Construction General Permit from EPA, certain details
must be provided in advance of wetlands permitting so issuing authorities can reasonably judge the extent of wetland
resource areas and buffer zones where work is to occur.
Response: MassDOT has included preliminary construction period erosion control and pollution
prevention details in the NOI applications. The anticipated construction staging and the proposed inwater
work was described by MassDOT during the NOI public hearings to each of the commissions.
The NOI plans clearly identify the limit of work which will be demarcated in the field by various
means including compost filter tubes or an orange construction fence, chain link fence and/or ―No
Work or Disturbance in Wetland‖ signage. The limit of work was designed to specifically include the
expected access locations to facilitate construction equipment. It is expected that the contractor will
be utilizing the entire limit of work not only to install the proposed project components, but to use a
laydown, staging and access. The contractor will not be allowed to extend the limit of work into a
wetland resource area since the sediment control measures and/or fence will limit the operation of
equipment beyond these measures.
MassDOT will meet with the contractor to review the expected construction sequencing, potential
locations for staging and access within the work limits shown, and work towards minimizing and
consolidating access, staging and stockpile locations. MassDOT will submit the detailed construction
period erosion control and pollution prevention plans to each of the commissions for review and
approval at least sixty (60) days prior to the start of land disturbance. With the exception of access to
the south and north bound approaches in the river, all temporary and permanent work zones will be
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