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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 />

limited to the established work limit. All areas temporarily disturbed will be restored according to<br />

MassDOT specifications for permanent seeding and/or appropriate permanently stabilized ground<br />

cover.<br />

DEP-24: Further, for wetlands and 401 permitting, although the final CP/PP may be provided to conservation<br />

commissions for review and approval prior to land disturbance, at least a conceptual level CP/PP can and should be<br />

provided to the 3 commissions and MassDEP. The conceptual level CP/PP can be reviewed to ensure it contains<br />

adequate controls to prevent unintended alteration to wetland resource areas and discloses all work projected to<br />

occur in each buffer zone, including work yards/lay down areas, so that the work may be appropriately conditioned. In<br />

addition, the conceptual level CP/PP will serve as a guide to the design-build contractor in preparing the final CP/PP.<br />

Because the wetland impacts are being considered on a town-by-town basis, the CP/PP will need to be specific to<br />

each town. If the final CP/PP is not submitted prior to the close of the wetland public hearings, the final CP/PP will<br />

need to be conditioned to be submitted and administratively approved by the commissions prior to land disturbance.<br />

The design-build contractor needs to be made aware that the commissions will need to be granted adequate time to<br />

review the CP/PP after it is submitted, and commissions may require changes to the CP/PP as part of their<br />

administrative approval.<br />

Response: The demarcation of the work limits are clearly defined on the NOI plans and include<br />

compost filter tubes or an orange construction fence, chain link fence and/or ―No Work or<br />

Disturbance in Wetland‖ signage. The installation of these measures at the limit of work will eliminate<br />

the possibility of the contractor operating equipment in the adjacent resource areas. The level of<br />

information provided in the NOI was intended to provide the contractor with established work limits,<br />

perimeter sediment control measures and specific details of erosion and sediment practices which<br />

the contractor must use as the basis for the CP/PP.<br />

The design/build contractor will develop a CP/PP which meets the requirements of the EPA<br />

Construction General Permit and the Orders of Conditions. The newly reissued EPA Construction<br />

General Permit (February 15, 2012) will require a 30-day waiting period from the time that EPA<br />

acknowledges receipt of the Notice of Intent. As such, the CP/PP will be provided to each<br />

Commission at least 60 (sixty) days prior to the start of land disturbance in order for any updates to<br />

be made to the CP/PP in support of the NOI filing with the EPA.<br />

DEP-24A: Standard 9 –Operation and Maintenance Plan (310 CMR 10.05(6)(k)(9) and 314 CMR 9.06(6)(a)(9): A<br />

Long Term Operation and Maintenance (O/M) Plan specific to the stormwater control practices proposed in the 4.25<br />

mile project area is required. A generic state-wide plan is not acceptable to meet regulatory requirements. The O/M<br />

Plan must be provided to the 3 conservation commissions. The Long Term O/M Plan must meet 6 specific<br />

requirements specified in MassDEP Stormwater Handbook in Volume 1, Chapter 1, including an on-going<br />

maintenance log to be made available to MassDEP and conservation commissions and making provision inspections<br />

by MassDEP and conservation commissions upon request.<br />

Response: MassDOT has prepared a project-specific Operation and Maintenance (O&M) Plan and<br />

submitted it to the conservation commissions as part of the wetlands permitting process. Appendix A<br />

includes the O&M Plan. In general, long term O&M activities will be conducted consistent with the<br />

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

MassDOT District 4 office will be responsible for the maintenance of the roadway facilities and<br />

associated stormwater management features, in accordance with MassDOT standards.<br />

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