APPENDIX A
2006 GEIR Certificate and Response to Comments
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MITT ROMNEY
Tel. (617) 626-1000
Fax (617) 626-1181
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GOVERNOR
KERRY HEALEY
U EUTENANT GOVERNOR
December 1, 2006
ROBERT W GOl.lEDGE, JR
SECRETARY
CERTIFICATE OF THE SECRETARY OF ENVIRONMENTAL AFFAIRS ON1HE GENERIC ENVIRONMENTAI. IMPACT REPORT PROJECT NAME
PROJECT MUNICIPALITY
PROJECT WATERSHED
EOEANUMBER
PROJECT PROPONENT
DATE NOTICED IN MONITOR
: Snow and Ice Control Program
: Statewide
: Statewide
: 11202
: Massachusetts Highway Department (MassHighway)
: August 23, 2006
As Secretary of Environmental Affairs, I hereby determine that the Generic
Environmental Impact Report (GEIR) submitted on the above project requires supplemental
review pursuant to the Massachusetts Environmental Policy Act (G.L. c.30, ss. 61-62H) and its
implementing regulations (301 CMR 11.00). On November 29,2006, the proponent submitted a
request that its Snow and Ice Control Program's future submissions be reviewed under the
Special Review Procedures, 301 CMR 11.09. As described in a separate Certificate issued today,
I have established a Special Review Procedure, to replace the GEIR format, by which
MassHighway shall develop an ESPR Work Plan shall be completed on or before December 31,
2007; and a subsequent ESPR. The ESPR Work Plan is to be a limited Scope document that
provides a response to the comments submitted on the 1997 and 2006 GEIRs in the form of a
proposed scope of work and proposed schedule for the ESPR.
I expect that, through the ESPR process, MassHighway will coordinate closely with the
state permitting and resource agencies to systematically address the potential environmental
impacts associated with its snow and ice control removal program.
Project Description
As proposed in 1997, the project consisted ofa description of the methods used by state
agencies to control snow and ice on roadways, the impact these methods have on the
environment, and the mitigation implemented to compensate for these impacts. The agencies
participating in this GEIR process were to include MassHighway, the Massachusetts Turnpike
Authority (MTA), and the Metropolitan District Commission (MDC) (now the Department of
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EOEA#11202 Generic EIR Certificate
December 1, 2006
Conservation and Recreation (DCR)). MassHighway was the designated lead agency in preparing
the GEIR. This GEIR was to be the basis for snow and ice control on state-owned roadways in
Massachusetts. The purpose of this GEIR was to protect sensitive resource areas and determine
whether a proactive (rather than reactive) approach is needed. The Certificate of September 24,
1997, posed three questions based on mapping of known sensitive areas:
1. Does the nature ofthese sensitive areas suggest that the approach to snow and ice control
should be modified to provide better protection of these areas?;
2.. Alternatively, is a purely reactive approach dictated by overriding public safety
concerns?; and
3. Can an intermediate approach be fashioned by deVeloping up-front knowledge of
expected impacts and designing appropriate mitigation while remaining faithful to the
public safety issues?
Prior GEIRs were prepared in 1978 and 1995 for Snow and Ice Control. The 2006 GEIR
is a continuation of this effort by MassHighway.
Review of the GEIR
The GEIR followed the annotated outline included in the Certificate dated September 24,
1997. It included a copy of this Certificate. The GEIR did not include copies of the comment
letters nor was there any formal response to these comments as required in the Certificate.
The GEIR included an Executive Summary. It described the existing snow and ice control
program at MassHighway. It identified the amount of equipment deployed by MassHighway
dwing various storm intensities. The GEIR included an organizational chart for snow and ice
control at Mass Highway. MassHighway has reduced the deicing material to a uniform
application rate of240 pounds/lane/mile from 350 pound silane/mile priorto 1976. The
application rate is controlled by computerized spreader equipment that is standardized and
calibrated on all MassHighway and hired equipment. For most roadways the deicing application
consists of salt (straight sodium chloride) or Pre-mix. Pre-mix is a mixture of sodium chloride
and calcium chloride at a 4 to 1 ratio. Pre-mix is used in most of the twenty-two designated low­
salt roadway sections located throughout the state. These low-salt areas have been established by
MassHighway to protect a nearby municipal water supply well or water body. Pre-mix and
straight calcium chloride may be used on any roadway during low temperature events (below 20
degrees Fahrenheit (F)). The GEIR identified operating costs for snow and ice control. It
suinmarized the tonnage used and the inches of snowfall per district. The GEIR described
MassHighway's remediation program. It provided an inventory of salt storage facilities and
practices. MassHighway has coordinated snow and ice control with municipalities. The GEIR
compared MassHighway's programs with other New England state transportation agency snow
and ice control programs.
The GEIR described the Best Management Practices (BMPs) for deicing. It identified the
alternative deicing materials considered, technological advances, and alternative pavements, pre­
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EOEA#1l202 Generic EIR Certificate
December 1, 2006
wetting and anti-icing, and snow fencing. MassHighway summarized its annual training and
standard operating procedures. It purchased 124 new spreader/plowing vehicles in the mid­
1990's and provided its supervisors with enhanced weather forecasting information and the Road
Weather Information System (RWIS). RWIS provides real-time data ofpavement temperature
and moisture conditions from twenty-three remote locations. MassHighway has determined that
fully closed drainage systems and snow bermed drainage systems provide a significant reduction
in chloride load in groundwater when compared to open drainage systems.
The GEIR summarized the impacts of snow and ice control on drinking water, soils, flora,
agricultme, tourism, Sugar Maples, and cranberry bogs. It identified that sand utilization for
snow and ice control was ineffective. The GEIR described the impacts of snow and ice control on
vehicles, bridges, and pavement corrosion/protection.
The GEIR identified that MassHighway has:
• Reduced the application rate of deicing chemicals to 240 pounds Ilane mile
• Improved equipment, enhanced weather forecasting, installed R WIS, and instituted pre­
wetting and anti-icing procedures
• Contaminated few water supply wells and investigated salt contamination complaints
• Covered all MassHighway salt storage facilities and provided funds for municipalities to
construct salt storage facilities
• Evaluated alternatives to sodium chloride in designated reduce salt areas
• Kept abreast of equipment technology advancements
• Stated that there is a weak correlation between sodium levels in wells in Zone II areas and
the distance to MassHighway roads
• Stated that there is no impact from salt application on flora, fauna, agriculture, tourism,
sugar maples, cranberry bogs, and recreation
• Stated that sand is often ineffective for controlling roadway snow and ice
• Stated that snow and ice operations at MassHighway are vitally important to public
safety and the economy of the Commonwealth
Scope for ESPR Work Plan
The ESPR Work Plan shall be based on formal consultation with the Department of
Environmental Protection (MassDEP), the Department of Conservation and Recreation (DCR),
and the Natural Heritage and Endangered Species Program (NHESP), and in coordination with
the Massachusetts Port Authority, the Massachusetts Bay Transportation Authority, and the
Massachusetts Turnpike Authority (as Authorities with roadway management responsibilities).
The ESPR Work Plan shall present a draft scope of work that represents consensus, to the extent
feasible, among MassHighway, MassDEP, DCR, and NHESP, regarding how the issues raised by
the GEIR and agency comments will be addressed. The ESPR Work Plan shall identify a
schedule for providing that information for MEPA review in the form of subsequent ESPRs .
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EOEA#11202
GeneIlc EIR Certificate
December 1,2006
Project Description
The ESPR should provide a summary/history of MassHighway's snow and ice control. It
should include maps of the Commonwealth's roadways, highway districts and the locations of
salt storage facilities, designated reduced salt zones, municipal groundwater supplies, and R WIS
locations. The ESPR should explain why the information in the GEIR did not include snow and
ice control data for the MTA or nCR. In order to make this snow and ice control program
statewide, I am expanding the list of state agencies which provide snow and ice control along
their respective roadways. I am requesting that MassHighway be the lead agency in this effort
since it has the largest snow and ice control program statewide. MassHighway should provide
correspondence from the MTA, the Massachusetts Port Authority (Massport) (Mysticrrobin
Bridge and other roads), the Massachusetts Bay Transportation Authority (MBTA), and DCR
regarding their participation and cooperation with MassHighway to provide the necessary
information to complete a statewide inventory of snow and ice removal within the
Commonwealth.
In 2005, MassHighway was given the winter maintenance responsibility for certain urban
roadways managed by DCR. These Greater Boston roadways include Centre Street, Fellsway,
Fresh Pond Parkway, Jamaicaway, McGrath Highway, Mystic Valley Parkway, O'Brien
Highway, Revere Beach Parkway, Storrow Drive, and the VFW Parkway. However,
MassHighway does not indicate whether these roadways are included in the information
presented in the GEIR. The ESPR should identify snow and ice control procedures on these DCR
roadways. It should discuss snow and ice removal procedures along sidewalks and crosswalks
within the right-of-way of MassHighway maintained roadways. The ESPR should identify
MassHighway policy for snow and ice removal along sidewalks and at crosswalks. It should
identify MassHighway snow disposal/dumping guidelines.
Response to Comments
The ESPR Work Plan should address the issues raised in comment letters on the 1997
and 2006 GEIRs. The ESPR should include copies of all comment letters listed at the end of the
ENF Certificate of September 24, 1997 and this Certificate. It should provide a response to all
comment letters within the scope ofthis project.
Draft Scope of Work
The ESPR Work Plan shall contain a draft scope of work and schedule by which
MassHighway, in consulation with the agencies, proposes to address issues raised in the
comment letters. I note that in supplemental comment materials, MassDEP provided a summary
of recommended priority implementation actions and operational practices, which I believe can
serve as the basis for agency consultation. I have attached a summary of those comments to this
Certificate. I ask that MassHighway consult with MassDEP and other agencies, as appropriate,
in developing a response to issues raised in the attachment.
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EOEA#1l202 Generic EIR Certificate
December 1, 2006
Mitigation
The ESPR should include a separate chapter on mitigation measures/ recommendations
that were incorporated from the GEIR. In the ESPR, the proponent should commit to either
evaluating annually or biannually its snow and ice control policies and operational programs to
respond to changing conditions. MassHighway should review the following topics during its
evaluations:
•
•
•
•
•
•
Avoidance of sensitive areas for the location of salt sheds
Salt application rates
Snow-fighting equipment
Expansion or elimination of reduced salt zones
Evaluation of spreader routes to maximize efficiency and eliminate overlap
Consideration ofaltemative deicing chemicals, and the implementation of Best
Management Practices (BMPs) for all MassHighway construction/repaving projects
within sensitive reduced salt zones
• Salt storage management practices including housekeeping practices
• Statewide training program and materials for MassHighway personnel and snow and ice
contractors
The proponent should identify the dollar amount of its recommendations/mitigation
measures.. In the GEIR, the proponent has already spent approximately $44,000 for enclosing salt
shed storage areas. MassHighway stated that it spends an additional $2,000 per lane mile in
designated reduce salt areas. It also reported providing $ 230,000 to 23 municipalities to upgrade
their salt storage facilities.
Circulation
The ESPR Work Plan should be circulated in compliance with Section 11.16 ofthe
MEPA regulations and copies should also be sent to the list of"comments received" at the end of
this Certificate and commenters listed on the September 24, 1997 ENF Certificate. A copy ofthe
FEIR should be made available for public review at the State Transportation Library.
I have identified the following preliminary scope of work for the Draft ESPR The scope
will be further refined in the ESPR Work Plan.
December 1,2006
DATE ~~
RObertW.~~
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EOEA#11202 Generic EIR Certificate
Philip Weinberg, MassDEPlBoston
Stephen H. Burrington, DCR
Rick McCullough, MTA
Thomas W. Ennis, Massport
Andrew Brennan, MBTA
Comments received:
cc: DCR, 8/28/06
Richard F. Taylor, 9/18/06
MassHighway, 9/20106
Norton Conservation Commission, 9121/06
MassWildlife, 9/21/06
Mass Wildlife, 9/22/06
Cambridge Water Department, 9/22/06
DCR, 9/22/06
Stephen II. Kaiser, 9/22/06
Riverways Program, 9/22/06
Boston Environment Department, 9/26/06
WalkBoston, 9/27/06
Richard F. Taylor, 10/9/06
Ingeborg Uhlir, 10/9/06
Canoe River Aquifer Advisory Committee, 10/10/06
Water Supply Citizens Advisory Committee, 10/10/06
U.S. Environmental Protection Agency, 10110106
MassDEPlBoston, 10/11106
Connecticut River Watershed Council, 10/11106
BED,10/16/06
MassHighway, 10117/06
MassHighway, 10/18/06
MassHighway, 10/27/06
Connecticut River Watershed Council, 1119/06
MassHighway, 11129/06
11202geir
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Attachment
6
December 1, 2006
Attachment to EOEA #11202 Generic EIR Certificate 12/1/06
Summary of MassDEP supplemental comments on MassHighway's Snow and Ice Control Program In supplemental comments on the GEIR. MasssDEP recommends that Masshighway:
1.
Assess the basis for MassHighway's current salt/sand application rates, and
describe:
• The basis for MassHighway's current "level of service" ("LOS") for maintaining
its roads;
• Why the MassHighway's LOS and the salt/sand application rates used to achieve
the LOS are higher than other New England states and New York, and
• The relationship between the existing and alternative MassHighway LOS and
application rates and an increase in sodium levels to impacted public and private
water supplies and other sensitive receptors (wetlands, ORWs, etc.), taking into
account relevant EPA and DEP public health guidelines;
2.
Assess and document the effectiveness, beneficial outcome and implementation
costs associated with MassHighway's salt reduction programs, regarding:
•
State-wide trends in elevated sodium levels in water supplies alld other sensitive
receptors located near roadways;
•
Other environmental impacts from the runoff of snow removal/decicing
chemicals from roadway and storage runoff into environmentally sensitive areas;
•
The extent to which changes in the amount and composition of salt and other
snow removal/deicing chemicals used affect environmentally sensitive areas near
roadways;
•
The effectiveness of management controls on practices that lead to unnecessary
increases in the application of amount of salt and other snow removal/deicing
chemicals used (e.g. mUltiple applications) and whether revisions or additions to
such controls would result in improved application practices;
•
The effectiveness of MassHighway's Reduced Salt Zone Policy and recommend
any further actions or modifications associated with the Policy; and
•
The effectiveness of Salt Complaint Program, providing a list ofpublic water
systems that have filed complaints and the date and summary of the complaint,
and a summary of results of any data collected and the current status or outcome
of any follow-up investigation by MassHighway.
3.
MassDEP also recommends priority implementation actions more related to
MassHighway's operational practices, including recommendations to:
•
Implement, in accordance with a schedule developed in consultation with
MassDEP, each of relevant modifications identified by these agencies to
MassHighway's Stormwater Management Program ("SWMP") filed pursuant to
the Small MS4 General Permit, particularly those related to water supplies (Part
V.C. of the Permit);
•
Establish a timely schedule for the construction of priority salt storage facilities
located near water supplies (e.g., the Drum Hill facility located in Chelmsford,
highlighted by MassDEP in its comments on the GEIR) and conduct all storage
activities in accordance with MassDEP's Deicing Chemical (Ro.ad Salt) Sto.rage
Guidance- Guideline No. DWSG97-1;
•
Expand the use of MassHighway's Roadway Weather Information System
("RWIS"), particularly near environmentally sensitive areas such as water
supplies;
•
Evaluate the extent to which an increase in the number or assignment of
MassHighway personal responsible for oversight of snow and ice removal
operations would reduce impacts to environmentally sensitive areas and
implement the results ofthe evaluation as rapidly as feasible;
•
Improve and implement training and incentives for MassHighway personnel and
its contractors in operational practices designed to reduce environmental impacts
including, but not limited to, the regular inspection and calibration of spreader
equipment and the proper washing of vehicles;
•
Develop and implement planning measures and operational practices, in
consultation with DCR and MassDEP, applicable to those DCR parkways that are
maintained by MassHighway, including the use of snow fences and the proper
disposal of snow in accordance with MassDEP's Sno.w Dispo.sal Guidance -­
Guideline No.. BRPG01-Ol; and
•
Continue and expand MassHighway's efforts to research, develop and use
alternative anti-icing and deicing agents.
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
ONE WINTER STREET, BOSTON, MA 02108 617-654-6500
~EC[IVE[
MITT ROl'vlNEY
ROBERT W. GOLLEDGE, Jr
Secretary
Governor
JJeT 12_
KERRY HEALEY
ARLEEN O'DONNELL
Commissioner
Lieutenant ('lOvernor
MEPA
",'
October 11, 2006
Robert W. Golledge, Jr., Secretary
Executive Office of Environmental Affairs
100 Cambridge Street
Boston, MA 02114
Attn: William Gage, MEP A Unit
Re: Statewide - Massachusetts..l!!.ghway Department
Snow & Ice COlltrol Generic Environmentaljmpact Report
EOEAo...tt.11202
Dear Secretary Golledge:
The Department of Environmental Protection ("MassDEP") has reviewed the Massachusetts
Highway Department ("MHD ") Snow & Ice Control Draft Generic Environmental Impact
Report (May, 2006) (EOEA No. 11202,jormerly No. 2358) (the "GEIR") and submits the
following comments.
Introduction
The GEIR is a significant effort on MHD's part to report on the current status and results of its
snow and ice control programs and to propose recommendations for future policy and
operational direction and approaches. The GEIR also has direct operational and regulatory
significance because the limitations it sets out on the application of roadway anti-icing and
deicing chemicals and sand are incorporated by reference in MHD's stormwater handbook and
the joint federal and state National Pollutant Discharge Eli~ination System ("NPDES") General
Permit for Storm Water Discharges from Small Municipal Separate Storm Sewer Systems (the
"Small MS4 Permit").
As described in the GEIR, MHD has implemented programs and practices that are designed to
reduce the environmental impact that can result from the use of roadway anti-icing and deicing
chemicals and sand. These activities include reduced salt zones, covered salt storage facilities,
the use of Road Weather Information Systems ("RWIS"), and, to some extent, the use of
traditional and innovative BMPs.
This information is available In allemale formal. Call Apr,1 McCabe, ADA Coo"dinalor all ..61'7..556-1171. JOO Service· 1·800-298-2207.
DEP on the World Wide Web: http://www.mass.govldep
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MassHighway Snow & Ice Control Generic Environmental Impact Report -- MassDEP Comments
Although salt storage ncar certain wetland resource areas is limited pursuant to M.G.I.. c.85,
s.7A and M,G.L. c.92All2, s.5(2)(vi), snow and ice control practices used in routine snow
clearing operations are not regulated directly through the Wetlands Protection Act and its
Regulations (310 CMR 10.00). MHD recognizes the sensitivity of certain wetland resource
areas by applying less road salt on designated highways abutting public drinking water sources to
control snow and ice. MHD also recognizes that reducing the amount of anti-icing and deicing
chemicals and sand applied to roadways improves the quality of stormwater runoff and therefore
serves as "source control" and "pollution prevention" measures. These measures are required for
those MHD projects subject to permitting through the Wetlands Protection Act Regulations and
associated Stormwater Management Policy, the Small MS4 Permit, or the NPDES Construction
General Permit for those MHD projects that include an acre or more of land disturbance.
As addressed in the more specific comments below, while the GEIR reports progress in some
important areas, the absence of sufficient information or adequate analysis in the GEIR precludes
a finding that MHD has minimized the environmental impact of its snow and ice control
activities to the maximum extent practicable and prevented the degradation of ground and
surface waters.
The GEIR Process
As evidenced by the timelines and deficiencies summarized below, MassDEP believes that the
existing approach ofMHD completing periodic GEIRs, separated by multiple years, has not been
an effective means of assessing and addressing the environmental impacts associated with
MHD's snow and ice control programs .
/
The last GEIR completed by MHD on its snow and ice control programs was in 1995, over a
decade ago. MassDEP commented on that GEIR in a letter dated August 24, 1995. In 1997
MHD filed an ENF for the next GEIR to be completed by MHD, which MassDEP also
commented on in a letter dated July 30, 1997. On September 24, 1997 the Secretary issued a
certificate on the ENF filed by MHD and determined that another GEIR was required. The
Secretary stated that she expected MHD's draft GEIR to be made available for review by the end
of 1998. Thereafter, the MEPA regulations at 301 CMR 11.00 were significantly revised in
1998, including changes made to the GEIR process l . MHD's latest Draft GEIR was not
completed until May, 2006, almost nine years after the Secretary's 1997 certificate on the ENF.
In addition to the timeliness issue, the GEIRs have not provided a sufficient historical overview
of and meaningful update on the status ofMHD's snow and ice control programs. This includes
the absence in the 2006 Draft GEIR update of a thorough review of changes since the last GEIR
(e.g., regulatory and policy changes, changes in the state highway system and demographics,
,
changes in water quality impacts, and winter accident trends); and specific responses to the range
of comments made by MassDEP on the 1995 GEIR and 1997 ENF. Consequently, many of
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_.__._..._.........._---,-_.,-,--,-_._.._,...... J While the MEPA regulations no longer use the term "Generic Environmental Impact Reports," the Secretary is authorized under 310 CMR 11.09(4)(a) to establish a Special Project Review Procedure on the implementation of a
program when the cumulative environmental impacts of individual projects undertaken in accordance with the
program may not otherwise be subject to adequate MEPA review or may have similar environmental impacts such
that a common assessment may be necessary or appropriate"
MassHighway
Snow & Ice Control Generic
.
Env~'Orunental Impact Report - MassDEP Comments
ft0.
I
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MassDEP's comments from 1995 and 1997 are being repeated again in this comment letter. In
short, the lack of the above infonnation and responses in the GEIRs, combined with the extende1 time delay between the updates, has not resulted in an effective process or dialogue on this
I
important topic of mutual concern.
I
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MassOEP recommends that alternatives to the existing GEIR process be explored to better assess
the impacts of this program and identify areas for further evaluation and implementation improvements. In light of MassDEP's ~xP:ri_:!l,?e,it would be 1!1{?!:~P~9d.!:!9!h~!'!f9LQ!!!J'_urposesl if, as an alternative'or';;upplemenftoThe'-above described GEIR process, Nl_assOEl' andM!!'Q,,_~ } enga~~~~~_ dlre"ctand more frequent communicati(}ll and an exc~~~: of information on the.~
rang~.{?f.:I1:,\:,i.!o~:I1:~(lI~~p(l~t_concems highli~ted in MassOEP's comments.
,I MHD's Salt/Sand Application Rates and Related Practices
I
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MHO applies more salt per lane-mile annually than state highway agencies in the other New England states and New York (Rhode Island did not provide data). See Table 2.6-2 on page 32 of the GEIR comparing MHO's salt usage with other New England states and New York state. Infonnation is provided in the GEIR that suggests that MHO's application of salt has increased It
in recent years. 2 A related issue is that although MHO limits the spreaders on trucks to a certain .
road salt'sand application rate, the trucks reportedly make multiple passes sanding and salting a
roadway segment until the desired road clearing is provided. 3 This practice is not discussed or
addressed in the GEIR and is contrary to purpose of adhering to salt/sand application rate. While,
MHD indicates that MA's higher salt per lane application rate is "to achieve a high level of
j
service standard," the GEIR does not analyze the benefits of this service standard in terms ofthe 1
environmental detriment. MHO should explore measures to reduce the amount of salt per lane
mile to bring salting rates more in line with those of other States.
.
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Impacts on Public Water Supplies
Drinking water supplies are particularly susceptible to degradation from road salt, and high
levels of chloride adversely impact fresh water aquatic organisms and fish. MassDEP has the
broad authority and responsibility under a range of environmental protection statutes and
regulations to prevent the degradation of public and private water supplies, wetlands, and other
surface and ground waters of the Commonwealth, including Outstanding Resource Waters. As
noted above, this encompasses discharges resulting from MHD's snow and ice control activities
including storm water discharges regulated through the MassDEP's Stormwater Management
Policy under the Wetlands Protection Act Regulations and the Small MS4 Pennit. The
Stonnwater Management Program control measures and BMPs required by the Small MS4
2 Although Fiscal Year 1996 (FY 96) had frequent and large total snowfall, comparable to FY 01 and FY 03, the
tonnage of salt applied pel lane-mile was 43% higher in FY 01 than in FY 96, and 69% greater in FY 03 than in FY
96..
.3 MassDEP notes that the GEIR does not address MHD's compliance with M..G.L.. c. 85, s.7A, which requires any
person who uses more than one ton of such chemicals in any calendar year to report annually to MassDEP on the
amount of the chemicals used (specified by road section or other location) and the amount of chemicals on hand.
4
MassHighway Snow & Ice Control Generlc Environmental Impact Report -. MassDEP Comments Pennit are a critical means of addressing the impact stormwater discharges containing salt or
other anti-icing and deicing chemicals resulting from MHO's snow and ice control activities.
In addition, MassOEP classifies salt storage facilities as "Areas of Higher Potential Pollutant
Loads," for purposes of permitting those facilities subject to the Wetlands Protection Act
Regulations and associated Stormwater Management Policy. Furthermore, MassOEP policies
have a direct bearing on MHD operations: (1) Deicing Chemical (Road Salt) Storage Guidance ­
Guideline No. DWSG97-1 !http;j/~§.,g.Q:ddep/wa!cr!.laws/saltgui.doc] and (2) Snow
Disposal Guidance - Guideline No.. BRPG01-Ol
[http'//www.mass.gov(dep/y!'aterlIQwsls!lo!t·disp.l~W1l. The GEIR should affirm MHO's
commitment to comply with these policies.
A.
Reduced.~alt
0&. ~# 03
Zones
In "reduced salt zones" near public water supply sources, a blend of sodium chloride and calcium
chloride ("Pre-mix") is used in combination with sand and salt. The establishment and
maintenance of a reduced salt zone requires a significant, prior monitoring effort by the public
water supplier to demonstrate to MHO that a reduced saIt zone would provide a meaningful
reduction in sodium levels.
MassOEP is particularly concerned with a recent change in MHD's reduced salt policy and the-­
requirements for maintaining designated reduced salt zones. In August 2006, MHD notified
public water suppliers ("PWS) with reduced salt zones that the reduced salt zones would be
eliminated unless the PWS provided MHD with three (3) years of monthly sodium, calcium,
chloride, specific conductance and pumping data for both the raw and treated water. The MHD
letter stated that ifMHD did not receive a response within 30 days of the date of the letter, it will
assume that the PWS is no longer interested in participating in the reduced salt zone policy.
At the outset, MassDEP notes that MHD's requirement that the PWS provide raw water test
results imposes an added burden on the PWS because raw water testing is not a requirement in
annual statistics reporting for MassDEP. More importantly, the burden should not be on the
PWS to show that the existing reduced salt zones around its water supplies should be maintained.
MassDEP requests MHD to address in the GEIR how many reduced salt zones will be eliminated
due to this policy change, and to reconsider its approach in response to the comments from
MassDEP and other resource agencies.
Consistent with OCR's comments on this GEIR, it is also MassDEP's view that MHD has not
adequately supported its conclusion in the GEIR (p.59) that there is a weak correlation between
sodium levels in Zone II area wells and MHD operations because only 10 % of the tested Zone II
wells within .5 mile ofMHD roads showed elevated sodium levels (which MHD defines as
above 60 mglL). As DCR pointed out, MassDEP's has a Drinking Water Guideline of20 mglL
for sodium4 . The GEIR needs to further analyze the correlation between elevated sodium levels
in public water supplies and MHD's operations, including recommending a sodium level in
drinking water that would trigger MHD's remediation of the salt contamination in the well. In
4 Under MassDEP's Drinking Water Regulations, any detection of sodium in a public water supply must be
reported to the local board of health and the MA Department of Public Health . The MassDEP 20 mglL guideline is
a health threshold for certain sensitive populations such as persons on a sodium restricted diet
DEP- DS­
5
MassHighway Snow & Ice Control Generic Environmental Impact Report- MassDEP Comments that regard, MassDEP disagrees with MHD's statement in the Executive Summary of the GEIR
that sodium will tend to adsorb onto soil pazticles and accumulate in soi1. Sodium tends to
remain in solution once it is dissolved. While it can be adsorbed onto minerals such as clay
particles, in freshwater cation-exchange processes will tend to remove divalent ions, such as
calcium or magnesium, from solution and replace them in solution with monovalent ions such as
sodium (John D. Hem, Study and Interpretation o/the Chemical Characteristics o/Natural
Water, U.S. Geological Survey Water-Supply Paper 2254, 1985, p. 100). For this reason,
MHD's assessment of, e.g., the amount of salt in storm water discharges should not be
predicated on the assumption that sodium is adsorbed onto soil particles.
0 eP-tfo MassDEP also believes that MHD has overstated the cost of using Pre-mix, a 4:1 blend of
sodium chloride and calcium chloride, in the reduced salt zones. The use of a Pre-mix to sand
ratio of 1: 1 means that the material cost of using Pre-mix is not far greater than using salt. The
GEIR states that the cost of using Pre-mix is more than 2.5 times that of using sodium chloride,
based on a cost of$80 per ton for Pre-mix compared to $35 per ton for sodium chloride.
Typically, Pre·-mix is mixed with sand at a 1: I ratio and applied at the standard application rate
in reduced salt areas. Therefore, application of one ton of sodium chloride is replaced by the
application ofone·-half ton of Pre-mix and one-half ton of sand. As the cost of sand is $8.50 per
ton, the material cost of replacing one ton of sodium chloride application with one ton of Pre­
mix/sand application appears to be $44.25 per ton. (As the GEIR notes, this does not include the
costs associated with storage, handling, and springtime removal of sand.) Between the sand and
calcium chloride, application of one ton of the Pre-mix/sand mixture would only place 40% as
much sodium into the environment as application of one ton of rock salt. The environmental
benefit of using Pre-mix in critical areas, such as water supply protection areas, appears to be
worth the added cost. As the GEIR points out, reduced salt zones have generally resulted in "a
substantial decline in sodium levels in adjacent water supplies .... "
The GEIR indicates that most of the reduced salt zones were established in the 1980s. In
previous comments on the 1997 FGEIR, MassDEP asked for an assessment ofthe success of the
Salt Contamination Complaints and Reduced Salt Zones programs including how the number of
salt contamination complaints and requests for reduced salt zones have changed annually since
the 1980s. The 2006 GEIR fails to do so. The GEIR should also describe the nature and history
of its public outreach on the availability of these programs, including confirming or clarifying
whether such efforts are part of the public education and outreach or public involvement and
participation programs that are included in MHD's NOI for coverage under the Small MS4
Permit.
2.
Examples of Elevated Sodium Levels or.Sodium.!!!£!:eas~~at.'p'!!bli£ WatS2Lfuumlies
Although MHD has 478 miles and 1,646 lane miles within reduced salt areas, MassDEP has
identified several public water supplies near highways in northeastern Massachusetts where
sodium levels have shown a marked increase in recent years, discussed below. MassDEP has
already discussed some of these cases with MHD's Environmental Services staff.
MassDEP acknowledges that several chemicals fr'equently used for water treatment and
purification contain sodium (such as sodium hydroxide) and can therefore add to the sodium
concentration in the treated water. However, none of the public water supplies discussed below
L
6
MassHighway Snow & Ice Control Generic Environmental Impact Report- MassDEP Comments use sodium hydroxide presently. In short, while treatment chemicals are considered by
MassDEP to contribute to elevated sodium levels, they are not considered likely to be the
primary source of sodium at any of these water supplies.
Thus, while the cause of the sodium increases at these public water supplies has not been
definitively established, they underscore the need for MHD to complete a systematic statewide
review of sodium levels near highways to determine whether similar trends occur statewide. As
DCR pointed out in its comments on the GEIR, although MHD has conducted studies for sodium'
levels in public water supply wells, the GEIR does not cite studies on the impacts of the 11 MHD
salt storage sheds within Zone lIs. MHD's statewide review should include determining the total
miles of highway that are within wellhead protection areas, the percent of those miles that are
designated as reduced salt areas, the extent to which public water supplies within and outside of
reduced salt zones are experiencing sodium increases trending toward or exceeding MassDEP's
Drinking Water health guideline of 20 mg/L, and a related implementation approach to
remediating public water supplies with sodium levels exceeding the above threshold.
1.
Oe-P-O'1
Chelmsford
As described in Section 4.1.2 of the GEIR, four (4) supply wells of the Chelmsford Water
District (the "District") located in the North Chelmsford have significantly elevated sodium
levels resulting from road salt impacts. The sodium level in individual wells has been as high as
438 mg/L. The mean sodium level in the four wells has been above 100 mg/L since 1997, with a
high of226 mg/L in the July 10,2006 samples. The sodium sources include MHD's road salt
applications on Route 3, municipal road salt applications on local roads, and salt storage at the
MHD Drum Hill facility. MassDEP believes, however, that the primary source ofthe
contamination is the salt storage structure at Drum Hill, which allows sheet flow ofprecipitation
at ground level to dissolve salt from the pile. Although MHD plans to replace this structure with
a more adequate storage facility, funding issues have delayed replacement of the structure for the
past few years. Correction of this situation is a high priority; additional delays by MHD are not
acceptable.
The District's Rivemeck Road Well No.1 receives drainage from Rte. 495. The sodium level in
the well has increased from about 25 mg/L in 1994 to 50 mg/L in 2003. The District's
Meadowbrook Well No.2 receives drainage from Rte. 3. The sodium level in this well was
close to 60 mg/L in 1994. After dipping in 1997, the sodium level has steadily increased to
about 90 mg/L by 2006.
2.
Andoyer
I
The surface water sources in the Town of Andover receive drainage from Rtes. 95 and 495, and
an MHD salt storage facility is located in the watershed. In addition, MHD constmcted a new
salt storage structure a few years ago, and has reviewed the appropriateness of deicing
applications to roadways and ramps in the watershed. A reduced salt zone was recently
,
established in the watershed. The sodium level in the well was at a level in the low 20s mg/L in
1993 but increased to 60 mg/L by 2004. The drop in the sodium concentration to about 50 mg/L \7
III
7
MassHighway Snow & Ice Control Generic Environmental Impact Report - MassDEP Comments in the two most recent samples in 2006 may be related to these improvements in MHD's
operations.
3.
Cambridge
The City of Cambridge's primary reservoirs are located beside Rte. 95. The sodium level in the
well was at 30 mg/L in 1993 but has risen to 70 mg/L by 2005 despite a reduced salt area being
in effect since the late 1980s .
The Dedham-Westwood Water District's White Lodge Well Field receives drainage from Rte.
95. White Lodge Well No.5, which is the closest well to the highway, went into service in 1998.
The sodium level in the well was at a level in the low 30s mg/L in 1994, reached a high of 60
mg/L in 2003, and was at about 50 mg/L in 2004.
The Town ofSalisbury's Well No.6 receives drainage from Rte. 95. A reduced salt zone is in
effect along this stretch of Rte. 95. The sodium level in the well was close to 60 mg/L in 1994,
peaked at 140 mg/L in 1998, declined in 1999-2000, but thereafter rose again and was in the 100
mg/L range in the 2002-2003 timeframe.
The Town of Weymouth's municipal wells, which are treated at the Winter Street Water
Treatment Plant, receive drainage from Rte. 3. One ofthe wells is located in a cloverleaf of a
Rte.3 exit. 'There has been a significant increase in sodium levels in the treated water from 1994
- 2006, reaching as high as 180 mg/L in 200 I, followed by a modest decline in 200.3, but is now
at 160 mg/L in 2006.
The wells treated at the Town ofWilmingtoIl's Sargent Water Treatment Plant receive drainage
from Rte. 93. There has been an increase in sodium levels in the treated effluent from the plant,
a rise over time from a level of 60 mg/L in 1994 to close to 100 mg/L level in 2005-2006.
MassDEP would like to understand whether the pattern of increased sodium levels in public
water supplies is related to changes in MHD's road salting practices, such as the increase in road
saIt applications by private contractors or the replacement of sand/salt applications with
applications of pure salt. Table 2.2-4 in the GEIR suggests that there has been an increase in the
tons of salt applied per lane-mile per inch of snow since FY93. This increase occurred despite a
drop in the salt application rate from 300 to 240 pounds per lane-mile in 1995. The GEIR should
further analyze these questions and report on the results and proposed related recommendations
to address any required further implementation steps.
Dr P 10
~ - \;
8
MassHighway Snow & Ice Control Generic Environmental Impact Report -. MassDEP Comments MassDEP also found that the GEIR does not identify or emphasize protection for those aquifers
that support private wells exclusively, such as in the Town of Boxford. In the limited
f1 ~D _ 1\
discussions of private wells in the GEIR, there is no mention of Boxford as a "particularly
troublesome area," even though the water quality problems observed in that town appear to fit
V x..;. ,- \
the definition. That raises the question of whether other private well areas in Massachusetts were
excluded from analysis under the GEIR. Based on MassDEP's knowledge of the salt impacts to
Boxford wells and the related question raised by its exclusion from the GEIR, MassDEP believes
that the GEIR has not adequately addressed the issues related to the impacts ofMHD's snow and
ice control activities to private wells.
Wetlands and Other Environmentally Sensitive Waters and Areas
MHD's snow and ice control practices may also impact wetland resource areas and the range of
interests they protect. As noted in the Introduction section of these comments, MHD's snow and
ice control practices are typically regulated in a wetlandslstormwater context through compliance
with MassDEP's Storm water Management Policy and under the Small MS4 Permit or NPDES
Construction General Permit. The need to do so effectively is heightened by the reality that
many of the waterways abutting existing highways are listed ort MassDEP's 303d list of
impaired waterways.
Towards this end, MHD's Stormwater Handbook and NOI under the Small MS4 Permit both
provide that MHO will limit the road sand and salt applied to highways in accordance with limits
set forth in this GEIR. For highways that include country drainage with stormwater discharges
to adjacent wetlands, where no improvements are currently proposed, reduced road sanding and
salting, and street sweeping, represent the only opportunities to improve the quality of adjacent
wetlands. This is another reason why it is important that the limits and practices identified in the
GEIR be based on adequate data and analysis that takes into account the comments ofMassDEP
and other parties.
In addition to public drinking water sources, wetland resource areas and other waters and
environmental resource areas require protection from the impacts ofMHD's snow and ice
control practices. More specifically, as part of this GEIR, MHD needs to adopt an alternative
analysis that may be employed through their Stormwater Handbook, the Small MS4 Permit or
NPDES Construction General Permit, permit requests under the Wetlands Protection Act and
401 Water Quality Certification Regulations (314 CMR 9.00), and where TMDLs have been
established for receiving waters. The purpose of the analysis is to select alternatives to reduce
impacts to those wetlands that have been detrimentally affected by road sanding and salting
practices, rather than rely on a one size fits all approach.
Moreover, in addition to reduced salting around public water supplies, the GEIR should provide
for the establishment of reduced saIt zones around other wetland resource areas, including
designated Areas of Critical Environmental Concern (ACECs). Greater use of snow fence to
limit blowing and drifting of snow onto highways should be considered as well. As MassDEP
commented earlier in this letter, certain ofMHD's salt and sand application practices require
D€P,- \'2-.
9
MassHighway Snow & Ice Control Generic Environmental Impact Report - MassDEP Comments
review and more training of MHD staff and contractors as well as a firm commitment on MHD' s
part to eliminate practices (such as multiple passes) that defeat the purpose of reduced
application rates.
The GEIR also needs to contain a list or graphic identifying all the Section 303d list impaired
waters impacted by mnoff from MHD activities, as well as an evaluation of alternatives and
related recommendations to reduce those impairments that result from MHD's road salt and sand
practices.
Although MHD is to be complimented for constructing many new salt storage facilities, there
remain several older facilities that provide incomplete protection from rain and snow and result in
stormwater mnoff containing road salt. The GEIR should include a schedule providing for the
upgrade of the remaining older salt storage facilities within a reasonable time period.
A related concern that must be addressed in the GEIR is the washing of vehicles that are
employed in road sanding and salting operations. These vehicles are expensive and are often
hosed down between sanding and salting operations. Unless this vehicle wastewater is contained
and disposed of properly, it mixes with stormwater runoff that may make its way into nearby
wetlands or groundwater underlying the location where the vehicle washing occurs. In addition
to assessing the scope of the problem, the GEIR should contain recommended implementation
steps to ensure the protection of these water resources.
l)(;~~.:.r~ (1~r:w,I» D~P-tLj
DEP-iS­
DEP- tb
nCR Parkways
The GEIR should address the need for a more collaborative effort, and a review of special
measures, between MHD and DCR for those DCR parkways that are maintained by MHD. The
use of snow fence along some parkways was discouraged by DCR because of its perceived
incompatibility with parkways" However, because snow fence has been shown to reduce
blowing and drifting of snow onto roadways, the GEIR should require snow fence to be used in
such instances rather than rely on higher road sand and salt applications. Some DCR parkways
have sensitive vegetation abutting them that may not withstand sanding and salting as well as
other types of vegetation abutting the highways. Those Parkway segments with sensitive
vegetation (which often is wetlands vegetation abutting a waterway) need to have alternatives
identified to ensure that sanding and salting practices do not create vegetation die-back.
Of particular importance is disposal of snow along the OCR parkways. MassOEP has received
complaints in the past about DCR's disposal of snow directly into the Charles River, Muddy
River, Hull beaches, Wollaston Beach, and Revere Beach. MassDEP's Snow Disposal Guidance
prohibits such practices except in emergencies. The identification of snow disposal locations in
the GEIR that comply with the MassDEP snow disposal policy will help ensure that future snow
disposal along DCR parkways is in compliance with MassDEP's Snow Disposal Guidance.
Snow disposal at MHD and DCR maintenance yards must also be conducted in accordance with
the MassDEP snow disposal policy.
DEP- \~
PE~
- t8
10
MassHighway Snow & Ice Control Generic Environmental Impact Report -- MassDEP Comments
Use of State-specific Data
The GEIR provides. an overview of the impacts of sand and salt practices, but falls short of fully
evaluating the problem within the state's borders because it fails to use all available data from
the Commonwealth of Massachusetts. Much of the GEIR is composed of reprints of
maintenance manuals and forms in the appendices, but actual data from Massachusetts is rarely
presented_ Instead, technical papers from other states are referenced.
Moreover, in an instance that the GEIR does reference state-specific data, MHD appears to
undervalue the findings by claiming that the Kampoosa Bog study along the Mass Turnpike was
"inconclusive". However, the abstract of the study, Richburg et aI., 2001
http;L!.~~F-!sgnis.orglpublicatirichia.htm states:
High salt concentrations in the ground water (due to the application of deicing salts on
the Turnpike) and Phragmites australis colonies appear to be impacting the native
vegetation at this site.
See also a similar comment made by DCR in its September 22, 2006 comments on the GEIR.
To address the above issue, MassDEP recommends that MHD revise the GEIR to include all
available state-specific data, including:
• Doug Heath's (EPA- Boston) studies on salt impacts on Lake Quannapowit;
• studies of road salt contamination linking MassHighway to salt in Massachusetts' streams
(Mattson and Godfrey, 1994 Environmental Management);
• Huling and Hollocher's 1972 Science paper on road salt contamination of groundwater in
Massachusetts;
• Forman and Deblinger in Conservation Biology 2000 on impacts of salting Massachusetts'
roads http:/(www.blackwell-§y!!er.:gy.coln(links/doil1 O. !.o4QLi.J 523-.11J9 .2QQO. 9908~!~;
• Lake TMDLs that cite sanding impacts near Worcester, etc.
Road Weather Information Systems ("RWIS")
MHD has been using pavement sensors (the RWIS) at 23 locations, but it is unclear from the
GEIR how effective these systems are, or can be, in reducing salt applications. Although the
GEIR indicates that reductions in deicing chemicals have been substantial, the data to support the
statement are not provided. The GEIR should consider how to assess and monitor the effective
use of pavement sensors, and identify goals for highway crews that will have tangible
environmental benefits. For example, the GEIR should address whether RWIS are located in
critical areas, such as wellhead protection areas around public water supplies, Zone A for surface
supplies, and other Outstanding Resource Waters. Ifnot, the GEIR should describe what plans
MHD has to expand the program to such high priority, environmentally sensitive receptors.
DE p- 20
I
II MassHigbway Snow & Ice Control Generic Environmental Impact Report - MassDEP Comments Need for Increased MHO StaffmglTraining to Optimize Snow and Ice Control Practices
The GEIR is clear that better supervision and increased staffing are needed to optimize statewide
salt use. However, because no commitment to increased staffing is made in the GEIR, MassDEP
urges MHD to, at a minimum, improve the staffing levels that cover deicing operations in critical
areas of the state, particularly the public water supply areas identified in this comment letter
where higher levels of salt are likely to be linked to deicing practices on nearby state highways.
By increasing staffing in these critical areas, MHD would be able to better achieve the stated
goal in Section 5.2.2 to monitor reduced salt zones during stomlS "to ensure the proper timing of
saIt applications and minimize the potential for overuse of deicing chemicals."
The GEIR states that the MHD annual training for staff "focuses on the operational and the
equipment aspects that minimize salt use and the potential environmental impacts that may result
from deicing chemical usage." MassDEP questions whether the training program is adequate if
only MHD staff receives the training, while 90% of road salt applications are made by outside
contractors. MHD should discuss what training or guidance materials it currently provides to its
contractors and what training measures it proposes to implement for that group to address the
issues raised by the comments it receives. MassDEP recommends that MHD and its contract
applicators receive specific training on proper salt/sand application practices and on the locations
of water supply protection areas where they wi1l be applying deicing chemicals.
O£P-21
Use of Sand
MHD is to be complimented for undertaking several experiments to reduce its sanding and
salting impact. While the GEIR (p.69) notes that road sand provides minimal road traction and is
a contaminant to receiving waters, it does not appear to make any concrete recommendations to
reduce the amount of sand to be applied during snow clearing operations. Because MHD's
research regarding the ineffectiveness of sand for traction appears to be conclusive, specific
measures should be proposed in the GEIR to reduce its use.
DEP-1L
The GEIR should include a commitment by MHD that when using sand, it will increase street
sweeping to remove more sand from the highways, rather than have it wash off into receiving
wetlands. The GEIR should also address road shoulder stabilization impacted by snow clearing
operations. Currently, MHD's goal is to sweep each highway at least once a year. Research
conducted by EPA in connection with the National Urban Runoff Program ("NURP") study
indicate that once a year street sweeping is ineffective at removing TSS along roadways. MHD
and USGS conducted a street sweeping study in Boston and found that street sweepers had a
negative removal efficiency because the road shoulders along the Southeast Expressway were
eroding onto the highway faster than the street sweeper could clean it off. The road shoulder was
judged unstable potentially due in part to snow clearing practices. FurthemlOre, recent USGS
studies on improved high efficiency highway vacuum sweepers conducted in New Bedford
'V
(Breault et aI., 2005) are not reviewed in the GEIR. Such studies now document up to 5 times
12 MassHighway Snow & Ice Control Generic Environmental Impact Report -. MassDEP Comments greater removal from roadways ofpollutants associated with sanding, but the possible use of this
technology by MHD is not mentioned in the GEIR.
I
OI"iP-2Z
MHD's Development and Use of Alternative Anti-icing and Deicing Agents
MHD proposes to end a number of experiments that are exploring the effectiveness of alternative
anti-icing and deicing agents. As DCR noted in its comments, the GEIR describes alternative
deicers that have been shown to be very effective and are more cost effective (e.g., RWIS may
save up to 50% per lane mile). Rather than eliminate or reduce research in this area, MHD
should continue and expand its efforts to develop and use innovative alternatives to road sand
and salt to minimize the environmental impact of its snow mid ice control activities. For
example, pre-wetting roadways does appear to show some promise in reducing sodium chloride,
however the pre-wetting agent also includes chloride.
Solid Waste and Hazardous Waste Management
The GEIR states, without further explanation, that MHD will dispose of street sweepings and
catch basin cleanings. The GEIR should be revised to expressly affirm that the disposition of
these materials shall be in accordance with 310 CMR 16.00,310 CMR 19.000 and any
applicable policies pertaining to street sweepings and catch basin cleanings. MassDEP also
notes that any contaminated materials must be evaluated in accordance with the Hazardous
Waste Regulations, 310 CMR 30.0000, and managed as hazardous waste, as appropriate.
MassDEP appreciates the opportunity to comment on this GEIR and is interested in collaborating
with MHD to reach firm commitments on policies and practices that reduce the environmental
impact ofMHD's snow and ice control activities while protecting public safety. If you have any
questions regarding these comments, please contact Derek Standish at (617) 654-6611.
j;zIY,
Philifweineb"er(;g~l2d~r----
Associate CommiSSIOner
cc: Brona. Simon, Massachusetts Historical Commission
Nancy Baker, Jason Lederer, Jim Persky, Richard Tomczyk, MassDEP - NERO
Dennis Dunn, Warren Kimball, Elizabeth Kotowski, Mark Mattson, MassDEP - CERO
Craig Givens, MassDEP - WERO
Sharon Stone, MassDEP - SERO
Mark Casella, Frederick Civian, Richard Lehan, Thomas Maguire, Suzanne Robert, Kathy
Romero, Catherine Sarafinas, Derek Standish, Michael Stroman, MassDEP --- Boston
DtP- '23 ~Ci~IO"'V;'I;~M;;';:~YS
tJ.(~ PRO G RA: Building Partnerships) Protecting Rivers
Joan C Kimball. RiverHQ)'s Director
Robert W. Gol/edge, Secretary
Executive Office of Environmental Affairs
Attn: MEPA Unit
MEPA Analyst William Gage; EOEA # I 1202
100 Cambridge Street, Suite 900
Boston, MA 021 14-2524
[
EOEA #11202 - Massachusetts Highway Department Snow and Ice Control Generic Environmental Impact Report Dear Secretary Golledge,
The Riverways Program staff have reviewed the Generic Environmental Impact Report for the
Massachusetts Highway Department Snow and Ice Control Generic Environmental Impact
Report. The use of many snow and ice management materials poses real threats to our natural
resources and it is important to fully weigh options carefully to find the treatment methods able
to provide an adequate level of public safety while providing the least degradation to our
resources. Riverways staff would like to offer the fol/owing comments and observations.
MHD past and on-going efforts have resulted in significant reductions in the use of salt and sand
on roadways without compromising driving safety. The Department's diligence has made great
inroads, it is our hope this admirable downward trend in salt and sand use and adoption of
advanced treatment techniques continues.
The recommendations MHD have detailed in the GEIR are a great start toward keeping the
momentum of reducing environmental impacts. The efforts MHD plans to expend to improve
their ice and snow control are commendable. We would like to suggest a few additional ideas
for consideration:
Policy and Program Review
• The GEIR included information on an overlooked byproduct of sand use which is the
presence of phosphorus in purchased sand. Eutrophiction is a serious problem in
numerous waterways. If possible, we would like consideration to be given to instituting a policy limiting the allowable concentration in a sand mixture. Ideally this maximum concentration would be conservative and be based on the potential load to a given waterways and whether EPA recommended Ecoregional instreamllake concentrations could be exceeded.
25 I Causewa} Street· Suite -+00 • Boston, Massachusetts 02114 • \m w massri\<cJways.org • (617) 626-1540
Rivec'vYays Program, A Division of the Department ofFish and Game David M Peters, Commissioner
K\Np... 01
Reduce Sand Applications
• The GEIR lays out a thorough argument for the reduction in the use of sand in snow
and ice control. While the reduced use is warranted, the GEIR contains an interesting
sociological twist which may result in adverse reactions and MHO may want to give
some consideration to proactively circumventing possible misperceptions. As the
document noted, most people perceive sand as a positive control measure. MHO mig~
.
want to consider outreach and education to the general public and also to local OPW
staff about the ineffectiveness of sand, its total cost of use (purchase, application and
clean up) and also the environmental issues surrounding its use so the reduced use of
this material is not perceived as a reduction in safety.
• The GEIR indicates sand is often mixed with salt to prevent freezing during storage.
\
While all MHO salt piles are stored in enclosed structures, not all sand is so contained.: P-03.
We hope MHO can make it a priority to find covered storage for sand supplies starting!
I
with those sand stores mixed with salt.
._--,-,
• The GEIR discussed proximity of ice and snow control materials storage to public .
drinking water supplies. We wonder if MHO can also supply information on the
l
proximity of storage areas to all water resources and the feasibility of relocating facilitie
in resource areas as defined by the MA Wetlands Protection Act (e.g. on the banks of rivers, streams and lakes)? For example the Lowell storage area sits directly on River Meadow Brook. A large. uncovered pile of sand is adjacent to the river and the pile was placed past the jersey barriers. spilling into the stream. The jersey barriers provide an RWP
ineffectual barrier between the sand pile and salt that accumulates during loading activities and the open water and street drainage is directly into the stream. The Brook has a large berm of sand downstream from this storage site likely a result of spillage, wind blown sand and runoff containing sand and salt. Given the efforts to restore anadromous fish to the Concord River system. of which River Meadow Brook is tributary, these conditions are significant impediments to protecting spawning and feeding habitat. There may be similar situations across the state. A methodical assessment on the feasibility of moving storage areas near these sensitive resource areas and stop gap BMPs to reduce impacts in the interim would be a valuable effort in protecting our waterways
__~~__ "~"""u••• ,~,,-.•_ __ l'
R,\N P-Oz
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Maintenance of the RWIS System
• The Roadway Weather Information System is a great tool and it has obviously benefited
MHO ice and snow control efforts. We support any expansion of this sort of system
deemed necessary by MHO. We would like to suggest MHO allow municipalities access
to this invaluable information along with training on how to better manage their local
roadway clearing using this great tool.
Anti-icing and Pre-wetting
• We are pleased to see MHO will continue to expand the use of anti-icing to most, if not
all, roadways in the Commonwealth. Intimately tied to this expansion is the advantages
of increased investigation and study of anti-icing techniques including their
environmental impacts, costs and effectiveness in keeping roadways safe. As the GEIR
points out, many states have found anti-icing efforts reduce annual snow and ice control
costs and this saving offsets the increased costs associated with anti-icing equipment and
materials. (one of the more compelling arguments for anti-icing is found on page 38 of
251 Causeway Street· Suite 400 • Boston. Massachusetts 021 14 • wwwmassri'venvuys olg • (617) 626·1540
Riverway~ Program, A Division of the Department ofFish and Game David M.. Peters. Commils;uner
2
iRWP-~CfO
t
the GEIR citing a statistic indicating it requires five fold as much energy to remove snow
and ice once a snow-pavement bond is established}. In section 3.2.7 of the GEIR. the
narrative implies pre-wetting is the alternative being pursued most actively and the
section does not specify the efforts being expended to investigate anti-icing. We hope
MHO can further detail their use of anti-icing and its success as this will greatly influence
-,-.,~"-'"'
practices on a local level. Training
Proper application, timing, and materials handling are key components of both an
effective control effort and one that minimizes environmental impacts. The MHO
already has a training program for maintenance personnel in the different districts.
While not explicitly stated, it appears the training extends to MHD staff and not to the
contractors hired each winter to undertake the majority of the snow removal and ice
control. Certain statements in the GEIR imply individuals plowing and applying salt or
sand may receive no training with the likely outcome that they do not understand all of
the concepts, nuances and procedures required for the advanced methods now used by
MHO. We would like to suggest the MHO look into requiring training for all personnel
involved in snow and ice control, not just for contractors working in limited salt areas.
Training could be further augmented by requiring evaluations and even in-the-field
assessments of compliance with procedures.
Research
• Waterways are sensitive receptors and are in need of a high level of protection and
consideration vis-a- vis snow and ice control chemicals. While the focus on public water
supplies and groundwater contamination is understandable and justified, our river and
streams are also threatened by contaminated runoff. For instance, field studies have
found acutely toxic pulses of salt during snow melt events, (D. Heath, US EPA pers.
Comm.). Other undesirable effects of salt and chlorides include degradation of habitat,
loss of biodiversity and shifts toward invasive and/or non-native species, and loss of
water quality. We would like to advocate for expanded research into these issues with a
particular focus on monitoring the concentrations of sodium and chloride in rivers,
lakes and streams. Ascertaining annual loads of salt into a waterway does not provide
enough detail or capture the brief but potentially toxic slugs of melt water that enter
our waterways during thaws. Annual averages are not an accurate portend of the habitat
and ecosystem degradation associated with runoff contaminated with ice and snow
control substances. A few hours of significantly elevated salt concentrations (sodium or
chloride) could devastate a streams ecosystem- essentially killing all aquatic organisms in
an acutely toxic event that would not be captured by sporadic monitoring. We do not
feel enough data has been collected to state, "The impacts of salt applications on flora.
fauna ... is not significant in Massachusetts." (page 93. GEIR) and we hope much more
data can be collected on both the short and long term impacts to aquatiC. wetland and
terrestrial ecosystems.
___._,_,"",","",.,,"
• We hope additional work and assessment on water quality and wetland impacts will be
done when MHO is considering enhanced drainage efforts to protect groundwater and
public water supplies. As the GEIR states, covered drainage typically discharges to
adjacent rivers and other water bodies. Protecting groundwater from salt contamination
is important but we feel the impacts to (potential) receiving waters should be assessed
251 Causeway Street· Suite-lOO • Boston, Massachusetts 02114 • www . massriverways.org • (617) 626-1540
Riverways Program, A Division of the Department ofFish and Game David M Peters, Commissioner
3
~WP-DCo C(O~t, )
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whenever expanding, rehabilitating or installing directed drainage conveyances. By
quantifying the impacts to the receiving water the most environmentally benign option i fl..\J)t~Dq
can be determined.
-~I (co"'\- \
• Costs should be carefully explored. For example, the costs for pre-mix is stated as 2.5x I
as much as rock salt. Cost comparisons such as these could be refined since pre mix is
mixed with sand at a I: I ratio and costs for sand is one fourth the cost of salt per ton. I,' RWf\ _ \0
This makes the actual cost for using pre-mix only slightly greater than salt. With
.
'"
!
incomplete or misleading cost comparisons, it is difficult t.o fully vet the different
1
options. If possible the environmental costs should also be a part of the equation. With
this greater level of information, comparisons and assessments will be more accurate
and hopefully leading to the most cost effective and enVironmentally sensitive o"gtions. !
• Magnesium chloride use has not been pursued as a control option by MHD because of a!" .
tOXicity issue but other states have been using this material for years. If possible it would, f{\X)\f - l \
be informative to know how these other states have dealt with the toxicity factor and i
how significant an issue it is in contrast to its beneficial qualities.
"="--_ _ _."""",,,,r,,,,,,,,,_,;,.!
• There have been many advancements in alternative pavement materials, in particular,
the types of semi-pervious pavement available has increased markedly. Since semipervious pavement allows water to infiltrate below the surface of the road, this quality
~_
may also reduce the development of ice on roadways and would be an interesting
technique to investigate or research. We would like to encourage MHD to renew t.heir
investigations of pavement materials as their have been such significant gains since the
1980's leadig to a pavement material that does provide the qualities and costs needed
for consideration by MHD for use on our roadways.
I
Riverways staff appreciate this opportunity to comment on this project. Please contact our
office if we can be of any assistance.
Kind regards,
{l__ ~-;>Yr
Cindy Delpapa, Stream Ecologist
Riverways Program
251 Causeway Street· Suite 400 • Boston, Massachusetts 02114 • www . massri\.emays.. ol"g • (617) 626-1540
Riverways Program, A Division ofthe Department ofFish and Game David M. Peters, Commissioner
4
Commonwealth ofMassachusetts
Diwilion
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fMassWildlire
Wayne F. MacCallum, Director
September 21, 2006 Robert Golledge, Secretary Executive Office of Environmental Affairs Attention: MEPA Office William Gage 100 Cambridge St. Boston, Massachusetts 02114 Project Name . ·
Proponent:
Location:·
Document Reviewed:
EOEAlNHESP Nos ..:.
MEPA
Massachusetts Highway Department Snow and Ice Control Program Massachusetts Highway Department Statewide Massachusetts Highway Department Snow and Ice Control Program, Generic Environmental Impact Report (GElR) 11202/06-20527 Dear Secretary Golledge,
The Natural Heritage & Endangered Species Program (NHESP) of the MA Division of Fisheries & Wildlife has reviewed the Generic Environmental Impact Report for the Massachusetts Highway Department Snow and Ice Control Program and would like to offer the following comments. The MA Endangered Species Act is administered by the NHESP of the MA Division of Fisheries & Wildlife, and prohibits
the "take" of state-listed species. The "take" of state-listed species is defmed as "in reference to animals, means to harass,
harm, pursue, hunt, shoot, hound, kill, trap, capture, collect, process, disrupt the nesting, breeding, feeding or migratory
activity or attempt to engage in any such conduct, or to assist such conduct.. ...Disruption of nesting, breeding, feeding or
migratory activity may result from, but is not limited to, the modification, degradation or destruction of Habitat." (321 CMR
10.02). We would like to offer the following comments regarding impacts to species state-listed pursuant to the
Massachusetts Endangered Species Act (MGL c13IA, MESA) and its implementing regulations (321 CMR 10.00).
Portions of the Massachusetts Highways' snow and ice control program are located within Priority Habitat. Priority Habitatp
is defmed "to mean the geographic extent of habitat for State-listed Species as delineated by the Division of Fisheries and
Widlife pursuant to 321 CMR 10.12. Priority Habitats ar·e delineated based on records of State-listed Species observed within
the 25 years prior to delineation and contained in the Division's NHESP database." These regions of the state are very
important habitat areas for state··listed species.
We note that several sections of the GEIR address potential impacts associated with deicing activities . Although we
appreciate Massachusetts Highw'lYs addresses these issues, we fmd that the GEIR does not adequately convey the extent to
which adverse impacts of deicing activities have been documented in the scientific literature, including some notable studies
in Massachusetts. For example, on page 63, the GEIR references a study at Kampoosa Bog by Richburg et al. (2001).
Kampoosa Bog, located in Stockbridge and Lee, is a relatively undisturbed and unfragmented calcareous fen . It supports
many state··listed species and has been declared an Area of Critical Environmental Concern. The GEIR states that the study
was inconclusive and that the study reported salt intrusion as much as .300 feet from the roadway. The study actually
documented salt intrusion more than 300 meters (984 feet) from the roadway. The GEIR states that results of the study were
unclear due to Kampoosa Bog being a groundwater fed calcareous fen. While it is accurate to describe Kampoosa Bog as a
:"_n_d=~_IC_'reo: re~_,_th_e=ne~e_r_b: n'_tu_ra_IIY:=:I_t_de:~d_o_c_um_~t:;:~:~;~:::;
Division of Fisheries and Wildlife
Field Headquarters, One Rabbit Hill Road, Westborough, MA 01581 (508) 792-7270 Fax (508) 792-7275
An Agency of the Department ofFisheries, Wildlife & Environmental Law Enforcement
;\!
I
EOEA No. 11202, NHESP No. 06-20527, Page 2 of3
median concentration of chloride sampled from >25 calcareous wetlands in western Massachusetts was 10 mg/L (Mattson
1992). Therefore, it is highly unlikely that the study results were confounded by natural salt deposits. Richburg et at (200 I:Ii'­
...,
documented a clear salt gradient at Kampoosa Bog, fmding 275 mg/L chloride near Interstate 90 and <15 mg/L in samples
taken farther away from the interstate, providing strong evidence that the observed elevated salt levels can be attributed to lj~w-02
road deicing. The study also attributed decreases in plant diversity and individual abundance to higher salt concentration.
Mattson and Godfrey (1994) examined sodium concentration in 162 streams associated with roads in Massachusetts. Based I
on predictive modeling, Mattson and Godfrey (1994) state that "[t]he highest salt loading rates are associated with interstate
01
and major state roads with an estimated 22,500 and 17,700 kg of salt per kilometer, respectively" Our mass balance
calculations indicate road salt is the major source of salt to the streams in Massachusetts." Massachusetts Highways, on page
48 of the GEIR, found discemable reductions in sodium levels found in wells after
reduced salt practices.
Dfw-
A recent study by Kaushal et a1. (2005) reported increased salinization of several freshwater areas in the northeast and
concluded" ... the accumulation of road salt in aquifers and groundwater has eventually led to increased salinity throughout
all seasons and across years in the northeastern United States and may persist for decades, even if use of salt is
discontinued,," The authors also "suggest that salinization associated with increasing submban and mbanization deserves
attention as one of the most significant threats to the integrity of freshwater ecosystems in the northeastern United States."
Support for the role of deicing operations in salinization of freshwater resourceG by the Massachusetts Highway
Department is documented in the GEIR.
Research referenced for the sublethal and lethal affects to fauna are not cited in the GEIR, see page 69 and elsewhere in the
GEIR, but at least some of the data appears to rely on United States Environmental Protection Agency studies that typically
used a small number of relatively common fish and invertebrate species. Studies conducted on these more common species !,)l\fW~ oS­
may not fully represent effects on state-listed species, many of which are habitat specialists. Further, a lethal dose
jJ
evaluation that results in killing 50% of the individuals tested is not an adequate standard for populations of species that are (! already at risk of extirpation in Massachusetts . The resear·ch conducted in the northeast and elsewhere indicates that saIts l fiom deicing operations do enter fr'eshwater resources and contribute to habitat change, biodiversity shifts, and stress on ecosystems supporting state-listed species. Therefore, we must disagree with the conclusion on page 93 that "the impact of ! salt applicants on flora, fauna .. .is not significant in Massachusetts."
-"->,-,~--" I
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The use of sand by Massachusetts Highways, while clearly on the decrease (i.e", Table 4.2-1), can also have impacts on
Priority Habitat areas, Adverse effects fr'om sedimentation have been documented in lotic food webs (Henley et al. 2000, 1t'ti)7(~1 ~.rl'_
Shaw & Richardson 2001), mussels (Watters 1999), and benthic invertebrates (e.,g." Newcombe & MacDonald 1991; IV\'
VU
Collier & Winterbourn 2000; Suren & Jowett 2001). In geneIal, adverse effects have been associated with abrasion or I
smothering, reduction in food supply, or alteration of habitat. We support Massachusetts Highways continued use of
alterative techniques that result in reducing and eliminating the use of sand in Priority Habitat.
(~
I
We recognize that the safety of the citizens of Massachusetts and the driving public is an important consideration
informing decision about the type and intensity of deicing operations. As noted in the GEIR, the use and testing of
innovative deicing tools is ongoing by Massachusetts Highway DepaItment and others., We request that the Massachusetts
Highway Department consult with the NHESP in developing Best Management Practices (BMPs) for the deicing of roads
in and immediately adjacent to Priority Habitat. Pursuant to 321 CMR 10.05, the NHESP is prepared to work with the
Massachusetts Highway Department to develop strategies that ensure public safety while minimizing impacts to state-listed
species habitat. We note that it may be possible to focus such BMPs on a narrower subset of Priority Habitats that include
ar'eas likely to be the most sensitive to the effects of sedimentation and salinization. If you have any questions about this
letter, please contact Tim Simmons at (508) 792-7270 ext. 126. We appreciate the opportunity to comment on this project.
Sincerely,
Thomas W. French, PhD.
Assistant Director
cc:
Gregory H. Pendergast, MassHighway
EOEA No. 11202, NHESP No 06-20527, Page 3 of3
Literature
Collier, KJ, MJ Winterbourne eds. 2000 . New Zealand Stream Invertebrates: ecology and implications for management.
Christchurch, New Zealand Limnological Society. 415p..
Henley, WF, MA Patterson, RJ Neves, A Dennis Lemly. 2000 . Effects of Sedimentation and Turbidity on Lotic Food
Webs: A Concise Review for Natural Resource Managers. Reviews in Fisheries Science 9(2): 125-139.
Kaushal, SS, PM Groffinan, GE Likens, KT Belt, WP Stack, VR Kelly, LE Band and GT Fisher. 2005. Increased
salinization of fresh water in the northeastern United States. Proc . Nat Academy of Sciences 102, (38) 13517-13520
Mattson, MD, PJ Godfi'ey, MF Walk, PA Kerr and OT Zajicek. 1992. Regional chemistry oflakes in Massachusetts. Water
Resources Bulletin 28: 1045-1056
Mattson, MD and PJ Godfi·ey. 1994. Identification of road salt contamination using multiple regression and GIS.
Environmental Management Volume 18, Number 5.
Newcombe, CP and MacDonald DO. 1991. Effects of suspended sediments on aquatic ecosystems . North American
Journal of Fisheries Management 11: 72·82.
Richburg. JA, W A Patterson III, F Lowenstein. 2001. Effects of road salt and Phragmites australis invasion on the
vegetation of a western Massachusetts calcareous lake basin fen. Wetlands 21 (2) 247-255.
Shaw AE, JS Richardson . 200 I. Direct and indirect effects of sediment pulse duration on stream invertebrate assemblages
and rainbow trout (Oncorhynchus mykiss) growth and survival. Can. J. Fish. Aquat. Sci. 58(11): 2213-2221.
Suren AM, IG Jowett. 200 1. Effects of deposited sediment on invertebrate drift; an experimental study. New Zealand
Journal of Marine and Freshwater Research 35: 725-737 .
Watters, GT. Freshwater mussels and water quality: A review of the effects of hydrologic and instream habitat alterations .
Proceedings of the First Freshwater Mollusk Conservation Society Symposium. Pp 261-274.
pG­
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Massachusetts
~I&{'lJ£t
September 22, 2006
SEP 22­
Secretary Robert W. Golledge, Jr. Executive Office of Environmental Affairs Attention: MEPA Office (Bill Gage) 100 Cambridge Street, Suite 900 Boston, MA 02114 Re: Massachusetts Highway Department Snow & Ice Control -- Generic EIR
EOEA No. 11202
Dear Secretary Golledge:
The Department of Conservation and Recreation (nCR) has reviewed the Massachusetts
Highway Department (MHD) Snow & Ice Control GEIR and submits the following comments.
I look forward to using the final GEIR to guide OCR and MHD snow and ice control activities
on OCR properties in the future.
DCR and MHD have a strong working relationship at many levels that extends to many
different prqjects and operations across the Commonwealth. In 2005, MHD began providing
snow and ice control services for certain historic parkways under the care and control of OCR.
This support and cooperation are invaluable to nCR, and we hope that future cooperation
between the departments will provide for enhanced protection and public enjoyment of the
Commonwealth's resources. Many recommendations included in this letter would be
applicable to DCR's own ice and snow control program.
In general, OCR agrees with all ofMHD's statewide recommendations for its snow and ice
control program cited on pages xvii and 93-96 of the GEIR and recommends that the
department prioritize its program evaluation, research, and operational improvements to
provide the greatest protection to environmentally sensitive areas. DCR has concerns about
the cumulative impacts of the use of anti-icing and deicing chemicals and sand wherever state
highways, municipal roadways, DCR-maintained roads, or salt storage facilities are located
adjacent to important water resources and other natural resources under OCR's care and
control. These include public water supplies, especially those designated as Outstanding
Resource Waters (314 CMR 4.00); lakes, ponds, and rivers used for public recreation;
lacustrine, riverine, and wetland ecosystems, including river and stream segments identified as
cold Vvater fisheries (314 CMR 4.00); and, the critical resources and ecosystems within
designated Areas of Critical Environmental Concern (301 CMR 12.00). Again, OCR
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EXECUTIVE OFFICE OF ENVIRONtolENTAL AFFAIRS
Mitt Romney
Robert W Gol:edge, Jr . , Secretary
Governor
ExeOJtlve Office of Environmental Affairs
{eny tiea!ey
Stephen 11 D!.lrrington
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recognizes that its own practices affecting these and other resources need continual review and
improvement.
Publi~
DrinkinJLWater Resources
MHD states that there is a weak correlation between sodium levels in Zone II area wells and
its operations, because only 10% of the tested Zone II wells situated within .5 mile ofMHD
roads showed elevated sodium (above 60 mg/L) (p.59). However, further study ofMHD data
on wells, in light of the regulatory standards referenced below, suggest the need to reduce salt
contamination in order to bring drinking water to federal and state-recommended standards.
The federal Environmental Protection Agency, in its 2003 drinking water advisory,
recommends maintaining sodium concentrations in drinking water between 30 and 60 mg/L,
and the Massachusetts Department of Environment Protection's Drinking Water Standards
contain a health guideline of 20 mg/L.
Wells with sodium levels above the proscribed standards need to be remediated. _MHD's Salt
Complaints Program for public and private water suppliers provides a model process for
requesting remediation for salt contamination in wells or water supplies; however, the GEIR
does not provide information about the extent to which Reduced Salt Areas have been created
through this program. In addition, although MHD has conducted studies for soamm levels iri·~c
wells, the agency does not cite in the GEIR studies on the impacts of the 11 MHD salt storage
sheds located within Zone IIs.
Related recommendations:
• Consult with DCR regarding well driller laws and regulations (MGL c.2I, § 30 and
313 CMR 3.00) and comply with such laws and regulations when private wells
must be replaced due to contamination.
• Determine changes necessary to bring more wells into compliance with the
recommended EPA and DEP guidelines.
• Implement a specific health threshold for sodium in drinking water above which
remediation will automatically occur.
• As recommended on page xvii, replace or repair inadequate salt storage sheds and
locate and cover sand piles outside wetland buffers.
The DCR Office of Watershed Management staff encourages MHD to work with the
Department of Environmental Protection's Drinking Water Program to ensure that best
management practices (BMPs) for the protection of public drinking water sources are
integrated into the standard operating procedures at all of its facilities. The agency
DCR-oLi • Maximize efforts to use alternative deicers and new technologies to provide the
most efficient and least environmentally harmful snow and ice programs.
The GEIR indicates that MHD has offered financial assistance to municipalities on the
construction and maintenance of salt storage facilities; the report also notes that funds are not
currently authorized for this purpose (p. 27). The GEIR also refers to MHD's participation in
the Bay State Roads Program and Local Technical Assistance Program, which offers
occasional training to municipalities in a variety of snow and ice control topics (p. 28). DCR
encourages the creation of annual training programs at the municipal level that could result in
a sizeable reduction in mistaken use and overuse of deicing and anti-icing chemicals in
Massachusetts.
Related recommendation: •
,
-,-------"----,, I
I,
Provide additional training for municipal departments of public works and private
contractors on salt application and BMPs for snow and ice control.
",-",--,--,.,,-
""",.-".-,-,,-
The GEIR, in Section 4.13, mentions a storm water modeling study that is being conducted by
the U.S. Geological Service through a cooperative agreement with MHD. DCR is very
interested in this study and will contact MHD to obtain copies of any reports or other products.
,
Related recommendation: • Examine alternative highway drainage BMPs, such as wet ponds, water quality
swales, and biofilters, that might be more effective at mitigating salt-laden runoff.
Future research could build on results from the current USGS study.
OCR invites MHD to collaborate with local groups and municipalities on further studies and
actions aimed at preventing adverse impacts by road salt practices on wetlands, aquifers, and
rare species habitats adjacent to MHD roads in ACECs.
In the Kampoosa Bog ACEC, 20 rare species exist in a unique and sensitive calcareous fen,
and long-term studies, monitoring, and actions have been taken to eradicate invasive species
and to determine the sources of potential contaminant effects. Contrary to the conclusio~ in
the GEIR on page 63, based on a 2001 study by Richburg, preliminary evidence suggests that
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recommends that copies of any MHD Facility Environmental Handbooks be sent to the DEP
Drinking Water Program, and requests that copies for facilities located within the Quabbin
Reservoir, Ware River, Wachusett Reservoir, and Sudbury Reservoir watershed systems also
be sent to DCR Office of Watershed Management.
:::::::::~=::::::es:::;::::o eovITonmenrnlly sensitive areas, MHD refers
i.
II
ill
the II
GEIR (p. ix) to an existing unnamed program for this purpose, but does not provide data as to 'I ()
I cR-OiO
its success or failure. The GEIR describes the impacts of salt reduction strategies on flora
(often citing national, rather than Massachusetts, data), but m~"1!Q"_~1l~£1fic nl~J}jiQ!1.Qf_"___"_ \
impacts to wetlands, aquatic ecosystems, or rare species.! Continued commitment and
! D::4Z-01­
increased attention to the monitoring of water quality in nearby water bodies and wetlands for 1t
chronic and acute levels of sodium and chloride (as defined by EPA) is essential to improving j
saIt management and resource q~ality. I?CR is also ~o.ncemed about t~e cumulative impacts "pc.F,-oS
on water resources that are assocIated WIth the deposItIon of sand that IS transported from'
roadways.
Related recommendations:
• As MHD recommends on page xvii, reduce the application of sand and advance this
;
_Dec
,
policy through the Federal Highway AdministrationIMHDlUniversity of Massachusetts bC.R
Bay State Roads Program and other public outreach.
• Expand the use of the Global Position System (apS) technology to facilitate identification of drainage structures. • Improve drainage BMPs in high priority areas.
In the GEIR, MHD describes alternative deicers that have shown very effective outcomes.
For example, according to the GEIR, anti-icing techniques may save 10-20% ofan agency's
snow and ice budget, and Road Weather Information Systems (RWIS) may save up to 50% per
lane mile. Pavement temperature sensors (truck mounted and in pavement) are also mentioned
as useful tools. OCR would be interested in information about the extent to which these
devices have been implemented and about their impacts.
Related recommendation:
I
winter salt nmoff from the Massachusetts Turnpike (1-90) and Route 7, which border the basin
of the bog, may be negatively impacting these species. It is also suspected that salt intrusion I,
may be facilitating the spread of invasive plants, such as Phragmites, through the bog.
Preliminary investigation shows a persistent salt plume emanating from 1-90 and that the salt
ions are binding to peat and ~ltering peatland water chemistry. ~ thre~-yea~ hydr~geochemicall
study of these effects by SmIth College professor Amy Rhodes IS neanng completIOn. DCR l 1\'/,(\ -15­
recommends that MHD and the Massachusetts Tumpike Authority (MTA) meet with the
!Ui£...v",
Kampoosa Bog Stewardship Committee in order to review these results and consider possible
Cc:o*)
modification of road salt management strategies for the Kampoosa Bog area. (Paul Kelly of
MHD, Rick McCullough ofMTA, and Liz Sorenson ofDCR are members of the committee.) I
l
The Cedar Swamp ACEC, in Westborough and Hopkinton, is also mentioned in the GEIR, on
page 63. nCR is unaware of the reported study OIl the tissue salt content of red maples in the !
J
ACEC and will contact MHD for a copy of it.
~
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Massachusetts has a total of28 ACECs in 73 municipalities. Other ACEC communities and I
stewardship groups may offer opportunities for further selective studies on the impacts of salt !DGQp \"
management and on alternative methods for snow and ice control near sensitive environmental I
resources. ACECs should be considered in any pilot projects, funding programs, or municipal 1
outreach for improving and monitoring salt and sand application practices to optimize the use
of road salt and reduce impacts to natural r e s o u r c e s . " __ ,-~!
I
Thank you for the opportunity to comment on the GEIR. Please contact Liz Sorenson «617)
626-1394) for information related to ACEC Program issues, Chief Engineer Noel Baratta
«(617) 626-4948) for information related to stormwater and BMP issues, and Division of
Watershed Protection Director 10nathan Yeo «617) 626-4987) for information regarding state
watershed lands and Outstanding Resource Waters.
As noted above, DCR has enjoyed a positive working relationship with MHD on a variety of
projects and operations across the Commonwealth. We look forward to working with MHD to
identify and implement strategies to lessen impacts of chemical and sand application on
natural resources of the Commonwealth.
Very truly yours,
Stephen H. Burrington
Commissioner
I
cc: Luisa Paiewonsky, MHD Commissioner
Gregory Prendergast, MHO Director of Environmental Services
Paul Kelly, MHD District 1-- Environmental Section
Rick McCullough, Massachusetts Turnpike Authority
Kathleen Romero, DEP Bureau of Resource Protection -- Drinking Water Program
Richard Lehan, DEP Acting Deputy Associate Commissioner for Operations
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1 1 CONGRESS STREET, SUITE 1100 BOSTON, MASSACHUSETTS 02114··2023 October 10, 2006
Henry L. Barbaro
Wetlands Unit Supervisor
Massachusetts Highway Department
10 Park Plaza. Room 4260
Boston, MA 02116-3973
Subject: Massachusetts Highway Department Storm Water Management Program and Snow & Ice Control Generic Environmental Impact Report Dear Mr. Barbaro: !
I
!
By letter dated August 18, 2006, EPA required MassHighway to amend its stonnwater
management program (SWMP) pursuant to the National Pollution Discharge Elimination System i
General Permit for Storm Water Discharges from Small Municipal Separate Storm Sewer
Systems (Small MS4 Permit). EPA requested that MassHighway amend its SWMP to include.
!
II
among other things, additional information regarding its Snow and Ice Control Program as it
relates to source control and water supply protection. In our August 18th letter, we further noted If
that we recently received a copy ofMassHighway's Snow & Ice Control Generic Environmental .
Impact Report (GEIR) and that we would review the document to determine the extent to which I
it provides information relevant to the SWMP. Having now reviewed the GEm. we are
i
providing this additional guidance as to the infonnation MassHighway should include in its
~::u::m~::I:E:::::::~:::~:~~ended SWMP ilie
following infonnation related to snow and ice control: (1) an assessment of current salt
application and reduction measures and planned practices for reducing salt impacts to surface
and groundwaters, and (2) a ,monitoringgrogram and strategies to minimize stonnwater impacts
to public water supplies. See August 18 Letter at 7 and 11.
I
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With regard to salt application and reduction measures, the GEIR provides a detailed assessment
ofcurrent materials, equipment, and practices. The GEIR demonstrates a cO}lllllendable effort by
MassHighway to implement a snow and ice control program that balances safety, environmental
impact, and cost. While MassHighway identifies a variety ofrecommended measures that could
Toll Free -1·888-372·7341 Internet Address (URl) - htlp:l/www.epa.gov/region1 Recyc'-d'RtcyClabla -Prfnted with Vegetable 011 Baaed Inlcs on R~clad Paper (MInimum 30"4 P08tCOl18umer> MassHighway Snow & Ice GEIR and SWMP
October 5, 2006
Page 2 of3
yield continued environmental and fmancial benefit, it offers no specific plan or goals for
implementing many of these recommendations. For instance, MassHighway should provide
additional detail, schedules, or goals regarding the implementation ofthe following:
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• Reduction in uniform deicing chemical application rates (i.e. data needs and criterialbasis! f:P'~
for future reductions);
!
- -.. . .. --"··'l • Increased staffing for better supervision of deicing operations;
•
I
---tif'" Construction of additional gambrel-style salt storage sheds (i.e. estimated quantity,
location, and schedule);
• Expansion of its Roadway Weather Information System (RWIS) (i.e. are additional
climate region coverage warranted);
• Expansion ofanti-icing and pre-wetting systems for MassHighway and contracted
equipment (Le. number ofadditional systems warranted and plan for securing);
• Inspection arid calibration of spreader equipment (Le. warranted improvements); and
• Research programs (Le. selection process and schedule for implementation)
As detailed in our August 18th letter, EPA considers the implementation ofthe Small MS4
Pennit to be an iterative process that continually optimizes the reduction ofpollutants in
stormwater runoff, rather than a static pollution reduction requirement. See August 18th Letter
at 1. Accordingly, MassHighway's amended SWMP should include (or reference a GEIR that
includes) a detailed description of current BMPs and a plan and schedule of future activities to
further reduce impacts to surface and groundwaters from its snow and ice control operations.
In addition to detailing its current and planned abatement practices, EPA also requested that
MassHighway include in its amended SWMP a monitoring program and strategies to work with
water suppliers to minimize impacts ofsalt to water supplies. We note that the GEIR includes
Salt Complaint Program Standard Operating Procedures (SOP), including a protocol for when
and how to conduct site-specific investigations. To the extent MassHighway intends to rely on
its Salt Complaint Program SOP as part of its SWMPt we request that Mass Highway provide the
following infonnation regarding the program: (1) a list ofthe specific public water systems that
have filed complaints and the date of the complaint, and (2) a summary of any investigations,
including the results ofany data collected and the current status ofthe investigation. In addition,
2
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• Post-storm vehicle washing and residue disposal practices for MassHighway and
contracted equipment;
D2
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MassHighway Snow & Ice GEIR and SWMP
October S, 2006
Page30f3
please include in the amended SWMP other strategies MassHighway may have to share the
results ofmonitoring and to collaborate with water suppliers to minimize the impacts of snow
and ice control operations.
Please include your responses to the issues raised in this letter together with the other
amendments EPA requested to MassHighway's SWMP by letter dated August 18th , In addition,
please feel free to contact David GIay at 617-918-1577 or gray.davidj@epa.gov with questions
you may have regarding this letter or for assistance in preparing your response. EPA looks
forward to continuing to work with MassHighway as it improves its Snow and Ice Control
Program and SWMP.
Office of Ecosystem Protection
cc: Mary Griffin, MADEP
Damon Gutterman, MADEP
Steve Lipman, MADEP
Fred Civian, MADEP
Thomas McGuire, MADEP
Stephen Pritchard, EOEA
3
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CONNECTICUT RIVER WATERSHED COUNCIL
Pr:otecting the Con!le.~!.~cut River Sin5:.~.L95L_._..__.._._.______ .
15 Bank Row, Greenfield, MA 01301
October II, 2006
Secretary Robert W. Golledge, Jr.
EOEA, Attn: MEPA Office
William Gage, EOEA No. 11202
100 Cambridge Street, Suite 900
Boston, MA 02114
SUbject: Generic Environmental Impact Report for EOEA# 11202 Massachusetts Highway Department Snow and Ice Control Dear Secretruy Golledge,
I am submitting comments on the Generic Environmental Impact Report (GEIR) for Massachusetts
Highway Department's (MassHighway's) Snow and Ice Control program on behalf the Connecticut River
Watershed Council (CRWC). CRWC is the principal nonprofit environmental advocate for protection,
restoration, and sustainable use of the Connecticut River and its watershed. Salt and sand application on
state roads, together with snow and ice control operations for municipal roads, commercial parking lots
and roadways, and private establishments, together affect the environment across the Commonwealth of
Massachusetts. Application of salt and sand on driving and walking surfaces have become an essential
prut of our lifestyle .'- we all rely on MassHighway's Snow and Ice Control program to help us safely go
about our nonnal busy schedules, even during winter weather events. Nevertheless, this must be balanced
against the ecological impacts of these activities. Our comments on MassHighway's GEIR are below.
1. Section 4.0 of the GEIR addresses the environmental impacts of Snow and Ice Control. We found this
section to be very minimal, especially when considering the recent reseru'ch that has been done to look at
impacts of salt to the environment. For example, Kaushal et. al published an article in the September
2005 edition of the Proceedings o/the National Academy o/Sciences ofthe United States titled,
"Increased salinization of fresh water in the northeastern United States." (abstract and link to full ruticle
on line at http://www.pnas.org/cgi/contentlabstract/102/38!1,3517). The article states that, "Increased
salinity should be included as an impOltant ecological variable in explaining the extremely low abundance
and diversity of freshwater life observed in inland waters draining rapidly developing landscapes." And
the abstract concludes that, "Our analysis shows that ifsalinity were to continue at its present rate due to
changes in impervious surface coverage and current management practices, many surface waters in the
northeastern United States would not be potable for human consumption and would become toxic to
freshwater life within the next century." As a follow-up to that article, Jackson and Jobbagy published an
ruticle in the same publication titled "From Icy Roads to Salty Streams" (online at
n!!Q.;lfwww.pnas.org/cgilcontentlfuIl/102/4 III 4487). This article cites several studies on salt application
trends in the US and effects on the environment. Environment Canada has also done a considerable
runount of work looking at effects ofsalt usage and management of proper application
(http://www.ec.gc.calnopp/roadsaltlenlindex.cfw). None of the recent research on this subject was
included in the GEIR submitted by MassHighway, and a final version of this GEIR should contain a more
complete analysis of the current reseru'ch on the environmental impacts of road salt application.
HEADQUARTERS: (413) 772-2020
FAX: (413) 772-2090
UPPER VALLEY: (802) 869..2792
E-MAIL: crwc@ctriver.org
LOWER VALLEY: (860) 704D057
WEB: www.. ctriver.. org
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Connecticut River Watershed Council
Page 2
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2. Given the serious environmental impacts ofsnow and ice control, MassHighway should be continually
striving to do better with less salt usage. There is some indication that Mass Highway is doing that - for
example, page 49 ofthe GEIR describes replacing the entire MassHighway fleet of spreader trucks with
vehicles that are equipped with computerized spreader controls and since 1994, hired spreaders must have,
calibrated automatic controls as well. MassHighway's application rate policy 0[240 lbs/lane-mile is also
on the low end of the range of other northeast state's application rates and those recommended by the Salt I
Institute. However, according to Table 2.6-2 in the GEIR, the actual annual salt usage amount of23.9
tonsllane-miIe is much higher than the other New England states and New York, which range
between 8.2 and 18.2 tons/lane-mile annually. Mass Highway explains this high figure only by stating on
page 32 and elsewhere that, "This higher usage is primarily due to the high level ofservice standard that I
Mass Highway maintains to keep its roadways free from snow and ice during winter storm events." No
further analysis or justification is given. Are the other states not providing a high level of service? We
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have traveled and lived throughout the Connecticut River watershed states and have not noticed an___ I
appreciable difference.
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As part ofthe GEIR, Mass Highway should do more to analyze the factors that contribute to their very
high salt usage amount. For example, are there any flaws in the spreader calibration policy or its
enforcement? Has the calibration policy actually worked to bring down the tonsllane-mile application
rate as it should? No data to answer that question were presented in the GEIR. Does the high rate of
hired equipment inadvertently contribute to the high usage? Are there other factors?
The photo below was taken on February 15,2006 on Route 2 in Buckland near the ramp for Route 112
South. In the upper right comer of the photo is a sign at the town line of Charlemont, and beyond that is a
bridge over the Deerfield River. As you can see, a high amount of excess salt was applied very close to a
river, and this salt was present on the road for many days afterward until it eventually drained into the
river. This anecdotal account indicates that there is room for improvement in application rates.
Excess salt at intersection of Route 2 and Route 112 S in Buckland near the Deerfield River
3. Snow disposal is an element of snow and ice removal that did not appear to be covered in this GEIR.
In some areas, it is necessary to remove snow and dispose of it (pile it) in order to create the room needed
Connecticut River Watershed Council
Page 3
for safe passage and adequate road shoulders. Materials in snow moved by snow dumping can include
salt, sand, pollutants from car and truck exhaust, and trash. Does MassHighway engage in snow disposal
and what guidance or best management practices are followed? As of2001, Massachusetts DEP has
prepared snow disposal guidance available online at http://www.mass.gov/dep/waterllaws/snowdisp.htm.
4. We support MassHighway's philosophy behind reduced use of sand. The environmental effects are
high and its effectiveness on well-traveled paved roads is minimal. We recommend the article from New
Hampshire's Technology Transfer Center's Fall 200 I newsletter called "Pros and Cons of Sand on Snow
and Icepack" at h..tt.Q:/lww:w.t2.unh.edu/faIlOllpg6-7.html. This article cites a study in Iowa and
recommends that the use of dry abrasives on high speed urban roads are "inappropriate."
5. As a state agency, MassHighway should be a trend-setter and lead the way for reduced salt usage.
Unfortunately, budget strains on towns are so dire that at least one Massachusetts town finance
department in the Connecticut River watershed announced at town meeting this year that they are going to
have to apply more salt in lieu of hiring the staff to maintain the roads with plows. While this kind of
thinking is not MassHighway's responsibility, MassHighway can contIibute to a culture change among
towns and private snow removal companies by doing a smarter and better job as inexpensively as
possible.
We thank EOEA for the opportunity to comment on this GEIR.
Sincerely,
Andrea F. Donlon, M.S.
River Steward
cc: Christine DuerTing, MA DEP Connecticut River watershed team leader
Robert J. McCollum, MA DEP WERO
Cindy Delpapa, Massachusetts Riverways Program
Christopher J. Ahmadjian, Program Director of Bay State Roads
C.RWC-D3
(J-Ol/"~' ')
Gage. Bill (ENV)
Subject:
Andrea Donlon [adonlon@ctriver.org}
Wednesday, October 11, 2006 354 PM
Gage, Bill (ENV)
Christine Duerring; Bob McCollum; Cindy Oelpapa; Chelsea Gwyther;
ahmadjia@ecs.. umass.edu
MassHighway GEIR Snow and Ice Control
Attachments:
CRWC MassHighway GEIR 11202 10-11-06.pdf
From:
Sent:
To:
Cc:
CRWC
fighway GEIR 1120=
Dear Mr. Gage,
Attached are comments on MassHighway's Generic Environmental Impact Report for Snow and Ice Control on behalf of the Connecticut River Watershed Council. EOEA No. 11202. Andrea
Andrea DonIon,-·River-Ste-ward-----....-.....-----.--­
CONNECTICUT RIVER WATERSHED COUNCIL, INC.
15 Bank Row
Greenfield, MA 01301
phone: (413) 772-2020 ext. 205
fax: ( 4 13 ) 7 72··20 90
email: adonlon@ctriver.org
www.ctriver.org
1
Canoe R i v e r
Aquifer Advisory Committee
417 Bay Road
South Easton, MA 02375
Tel. (508) 230··0850
Fax: (508) 238-6485
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October 10, 2006
Secretary Stephen R. Pritchard
Executive Office of Environmental Affairs
Attn: Bill Gage, MEPA Office
100 Cambridge St, Suite 900
Boston, MA 02114
RE: tAl'~
11202-GEIR, Mass Highway Snow and Ice Control Program
Dear Secretary Pritchard:
The Canoe River Aquifer Advisory Committee voted at its October 5, 2006 meeting to support the NortOn
Conservation Commission in their efforts to prevent any unnecessary damage to the environment and the
water quality of the Canoe River from the MassHighway's Road Salting Practices along Route #495 and
Route #12.3 in Norton.
TIlls area has been designated as an AIea of Critical Environmental Concem by the State of Massachusetts
and from the Federal EPA as a Sole Source Aquifer"
Our Committee is charged with protecting this aquifer, which supplies 50% of the municipal water supply
of Norton, Easton, Mansfield, Sharon and FoxboIO.
We appreciate any and all efforts to protect this valuable resource.
s~;r~~v~:.
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Wa'ydp. Southworth
Chainnan, Canoe River Aquifer Advisory Committee
cc: Keith Silver, Norton Highway Superintendent
Jim Purcell, Norton Town Manager
Bill Napolitano, SRPEDD
Liz Sorenson, ACEC Director
Jon Regosin, NHESP
Gregory H. Prendergast, Director Environmental Selvices, Mass Highway
Henry Barbaro, Wetlands Unit Supelvisor, Mass Highway
DEp·BERO
MACC
Norton Conservation Commission
L.\~,:f\.f\G"'O I
WATER SUPPLY CITIZENS
ADVIS()RY COMMITTEE
to the Mass. Water Resources AuthoT"ity
8 River Or-ive • P.O . Box 478
Hadley, Massachusetts 01035-0478
(413) 586-8861
FAX: (413) 585-9257
E··mail: wscac@rcn.com
October 10, 2006
Secretary Robert Golledge
EOEA, Suite 900
100 Cambridge Street
Boston, Massachusetts 02114
EOEA # 11202, MHD Snow and Ice Control GEIR; MEPA Analyst, William Gage
WSCAC's charge to advise the MWRA on water supply matters always leads us to an interest inf
winter road treatments. Although we make special mention of the Cambridge Water Department!
comments (CWD) our concerns are both general for all surface water systems and wells, and
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specifically applicable to the Wachusett Reservoir and Quabbin (especially in its northern
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sectors), the Ware River upstream ofMWRA's diversion point, and MWRA's emergency water
supply system at the Sudbury Reservoir and Reservoir #3 in Framingham.
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This GEIR contains a good deal of us~ful information that describes improved highway
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practices, such as the covering of salt sheds. The Report, however, is not very user friendly.
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Appendices are crossed referenced in such a way that it is hard to find material e.g., the chart on
30 low salt application areas referred to in App. F is then directed to B and pre-attachment pages.
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It is not clear whether the MHD is recommending the studies it lists or whether it is merely
saying these should be proposed sometime in the future or are just interesting. Also, how do the
GEIR methods and recommendations from MHD relate to and/or influence the many miles
non-state roads that are treated each winter season? Do municipalities benefit from the
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experiences of activities and studies? Are the two tiers of government and road maintenance
actually speaking in a constructive manner?
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The text in Section 5 says MHD "could take a variety of measure that likely would lead to
envirorunental benefits as well as reduced costs ... " The text proposes recommendations for
statewide application and then merely lists the might do's or could do's. When will experience
and monitoring lead to more determined actions of the part of MHD? Will MHD use a
computer model or not? This is all very vague. Are pages 94 and ff actually recommendations?
Although as taxpayers we all want state agency operations to be efficient, we also recognize the
cost of envirorunental degradation. The cost statements are too easily passed on in this report.
More needs to be done to compare the value of lost drinking water supplies and fisheries, to the
cost of road clearance and how much economic benefit is accrued through maintaining the best
road-treatment devices, such as "bar" applicators. It is disturbing to fmd that some problems
have been found with temporary employees pressed into service that may not understand or
properly control sensitive area applications. This should be remedied. Contractors supplying
equipment and personnel should be in possession ofthe maps and routes and application details
needed to comply with the MHD's reduced treatment areas.
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There remain other outstanding issues: Wh): do~~~sachus~tts st!llps.e so m'y~.q lJlo~,IQ~g,c~
cl~ng gJateria}? It is recommended that sanding be reduced, except at low-slope intersections, !
but that salting actually be increased through the use of anti-icing spray. Studies are needed to
determine if this practice actually will reduce the salting load over-time" Are there actual
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voidance materials effectively. !l!More documentation is needed of initial cost versu,s tota,I, e ,ort,~o q
to determine the methods that are most suited, especially to sensitive surface waters along
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roadsides such as the Cambridge water system.rMHDdoes not seem~to be-taklng~aproaaIve'" 'lO
stance on adding reduced salt areas. Why? Page xvi of the summary says "relatively feW';=~o"~~r
public drinking water wells having problems. Is there documentation we have missed? Since J
salt is persistent, Zone II's should be monitored and studied more diligently. Are there road 'I
surfaces that require less winter treatments? Is Massachusetts using them? The CWD lists an
area of new pavement in Lexington on 1-95. Is study being made of this segment for winter
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management?
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The Cambridge Water Department provided detailed comments on its concerns. We have reaJ
its comments in detail and concur completely with their recommendations. These are detailed!
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comments seeking better protection ofdrinking water supplies. For example, CWD
documents the increasing sodium levels in their sources and notes that the GEIR speaks
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primarily to impacts on small water bodies. Precisely! More needs to be done to individualize;
road treatments, regardless ofinitial road costs, when such sensitivefeatures will be negativei)
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impacted. Another example is that the MHD seems to use an extremely high sodium-level
trigger, 250 mgll. This is excessive. If sufficient monitoring were being done, increasing trends
would be able to trigger actions in advance ofthese levels being reached. We also strongly
support the use of better information technology such as the RWIS system for treatment
management~ and we urge the use of low-tech methods such as snow fencing wherever it will not
interfere with road visibility.
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Keeping our roadways safe and clear is an important responsibility. It is also important to keep
the forum on highway practices open and under public scrutiny. Roadways have huge impacts
on the natural environment and winter treatments have a unique potential to impact waterways
and water bodies of all kinds.
Thank you for this opportunity to comment.
Sincerely yours,
Eileen Simonson and Alexandra Dawson
Co-Executive Directors
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CITY OF CAMBRIDGE
MASSAC/:fUSETTS
Water Department 250 Fresh Pond Parkway Cambridge, Mass 02138 (617) 349-4770
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September 22,2006
Secretary of Environmental Affairs
Attention: William Gage MEPA Unit, Suite 900 100 Cambridge Street Boston, MA 02114 SEP 26 2006
tAlPA Re: Snow and Ice Control General Environmental Impact Report: EOEA # 11202
Dear Mr. Gage:
The City of Cambridge Water Department (CWD) has reviewed the above referenced
General Environmental Impact Report (GEIR) for the Massachusetts Highway
Department (MHD) Snow and Ice Control program. The GEIR demonstrates efforts the
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MHD is making to optimize the efficiency oftheir snow and ice control program, for
both environmental and cost considerations. The City of Cambridge is a relatively I~rge_ ,
stakeholder in MHD's Snow and Ice Control program. The GElR maintains that one of ;\
the largest reduced-salt zones is within the City of Campridge water supply area (pg. 21).
However, the CWD water quality monitoring program has tracked increasing
concentrations of sodium and chloride in the reservoirs over the years. In consideration
of historic environmental trends in the Cambridge reservoirs, the CWD believes that
some of the information should be updated, more detail should be supplied on specific
operations in reduced··saIt zones, and several of the recommended practices should be
applied specifically to the zone within the Cambridge Watershed.
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There are several key pieces of data that should be reevaluated to represent current work
in the field of snow and ice management as well as water quality. A cost analysis
referenced in the GEIR concluded that maintaining reduced salt areas are an additional
$2000 per lane-mile in 1995. This value should be updated to reflect the latest
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technologies, particularly with the fleet replacement that took place in the mid nineties
(pg. 49), increased efficiency of application techniques, and increased fuel costs.
The GEIR should discuss the communication of salt-laden groundwater to surface water
given the results of continual water quality monitoring in these smaller, heavily-impacted
waterways along 1-95 in the Cambridge watershed. Currently, both the CWD and the
MHD in cooperation with the United States Geological Survey (USGS) are conducting
studies that will assist with estimating loads of de·,icing compounds from highway
surfaces. The discussion on surface water impacts (section 4.1.3, page 60) should be
expanded. This section asserts that "impacts of salt on surface water are generally
limited to small volume streams or lakes adjacent to heavily salted areas". A significant
portion of the surface water inputs to the Cambridge Water Supply are small volume
streams. All of the streams in close proximity to the highway exhibit elevated levels of
salt during baseflow conditions indicating that salt·,contaminated groundwater can impact
surface water.
The MHD has not quantified the total amount of material applied annually to the road
surfaces during winter storms in the Cambridge watershed in the past; this data is critical
in mass balance calculations within CWD's water quality monitoring program as it
attempts to calculate salt loads from various streams that are impacted by highway runoff,
and from direct discharges from the highway to the reservoirs.
Further details of operations in reduced-salt areas including distribution of staff, drivers,
contractors, and all associated equipment and materials should be incorporated into the
GEIR (in addition to Attachment 1, Chapter 5 of the MHD Maintenance Manual). This
would assist stakeholders within the reduced-salt areas to understand how the MHD
operates during winter storms.
The GEIR evaluates several practices that can assist the MHD in reducing levels of salt
applied to highways during winter storms. Section 5.2.2 lists several examples of such
practices recommended for reduced-salt zones which enhance application of calcimn
chloride by: "1) pre-wetting the road salt before application to accelerate melting and to
promote salt adherence to the roadway surface; and 2) anti-icing the road surface, using a
spreader bar dispenser, prior to a snowfall or freezing rain events" (pg. 96). The CWD
would like to see these processes applied to the roadways within the Cambridge
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watersheds.
In addition to specific recommendations for reduced-salt area operations, section 3.1.2 of
the GEIR discusses the use of Road Weather Information Systems (RWIS) which have
been proven to reduce costs by 50% in some cases (pg. 40). In light of the high costs of
the Cambridge watershed reduced-salt zone, and the fact that salt concentrations are
elevated in its reservoirs, MHD should consider installing a RWIS in this portion of the
highway to optimize application of more expensive de-icing mix. The costs of the RWIS
could potentially be offset by the savings the system brings to the operation of the
highway.
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The GEIR affirms that the use of snow fences in Wisconsin reduced the cost of plowing by up to 100% (pg. 46). Installation of snow fences where drift occurs due to cross­
winds in the open sections of highway near the reservoirs could substantially cut down on plowing costs, reduce associated de-icing requirements. Secondarily, snow fences would reduce incidental introduction of debris from the highway to the reservoirs, which would cut down on refuse collecting activities and further protect the water supply in non-winter months. 'The GEIR states that in some cases it is possible that "the use of contractors for snow and
ice control services results in excessive application of deicing materials due to contractors \
typically hiring temporary drivers who, compared to year-round maintenance staff, lack
: CJD~'"
operational experience and knowledge in the application of deicing materials" (pg. 77).
A very important recommendation discussed in the GEIR is the monitoring of reduced
salt zones during storm events to "ensure the proper timing of salt applications and
minimize the potential for overuse of deicing chemicals" (section 5.2.2, pg. 96). Solesourcing drivers in reduced salt areas within the watershed could assist with this goa1.
61
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'The CWD requests that MHD create post-storm reports that summarize snow and ice
control procedures in the reduced-salt zone within the watershed after each storm event,
including the quantity of materials applied to roadways. Formalizing the process for
managing this segment of the highway system during winter storms would significantly
contribute to this effect.
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A segment of 1-95 was recently resurfaced with semi-permeable, low spray pavement in
Lexington, near the upper portions of Hobbs Brook Reservoir. The snow and ice
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treatment requirements of this new road surface are not discussed in the GEIR. If this
road surface requires more de-icing chemicals than the conventional asphalt surface used
in most other areas, the CWD is requesting this important addition to the Report ..________
Lastly, the GEIR should discuss snow and ice control practices on pedestrian walkways
within the MHD system.
In summary, the GEIR provides a helpful reference for the challenges of keeping the
roadways open and safe during winter storms but the CWD encourages the MHD to
implement the following measures to cut costs of reduced-salt zones and minimize the
amount of material placed in the Cambridge watershed area:
• Implement the recommendations outlined in section 5.2.2;
• Install a RWIS within the segment of 1-95 that bisects the Cambridge Reservoir system; • Install snow fences where 1-95 crosses Stony Brook Reservoir in Weston, and as it passes in direct proximity of the larger Hobbs Brook Reservoir in Waltham and Lexington; • Consider sole··sourcing drivers in reduced salt areas within the watershed;
• Issue post-stonn reports to stakeholders in reduced-salt zones that summarize snow and ice control procedures after each stonn event. LW{J- l \
• Establish an independent monitor for snow and ice management within the
Cambridge water supply;
• Annually quantify the de-icing chemicals applied to the road surfaces in the
watershed; and
• Continue to fund water-quality monitoring projects that assess impacts ofMHD
de-icing practices on receiving waters.
The CWD appreciates the opportunity to comment on this important aspect of managing
the extensive State transportation infrastructure within its water supply and looks forward
to working with MHD to reverse water quality trends seen in the past.
Sincerely,
Peter Varga, Watershed Protection Supervisor
City of Cambridge Water Department
CC: Stephen P. Corda, Managing Director, Cambridge Water Department
Cambridge Water Board
Dorothea Thomas, Weston Conservation Commission
Gloria Champion, Waltham Conservation Commission
Karen Mullins, Lexington Conservation Commission
Bob Boone, MHD
Henry Barbaro, MHD
Eileen Simonson, WSCAC
Dave Kaplan, CR WA
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Norton Conservation Commission
70 East Main Street
Norton, MA 02766
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REC£!yEf)-­
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September 21, 2006
Secretary Stephen R. Pritchard
Executive Office ofEnvironmental Affairs
Attn: Bill Gage, MEPA Office
100 Cambridge St, Suite 900
Boston MA 02114
~.-.-
RE: 11202-GEIR, MassHighway Snow and Ice Control Program
Dear Secretary Pritchard,
The Norton Conservation Commission has received the copy of the Massachusetts Highway
Department Snow and Ice Control Generic Environmental Impact Report (GEIR) dated May 2006.
MassHighway is responsible for several major roads that transect the Town of Norton, including Rt.
495, Rt 123 and Rt. 140. The Town of Norton receives its drinking water primarily from municipal
wells located along the Canoe River. The Canoe River is designated as an Area of Critical
Environmental Concern and contains a Federal designation as a Sole Source Aquifer" The Natural
Heritage and Endangered Species Program designates the Canoe River as rare species habitat as shown
on the most recent Priority Habitats and Estimated Habitats Map (Oct. I, 2006). Route 49.5 and R1. 123
(East Main S1.) are both within the ACEC, Sole Source Aquifer and Priority Habitat and are the
primary areas of concern regarding the snow and ice control at the salt storage facility the application
of sand and salt on roads. Additionally, sand and salt impacts to a portion ofR1. 140 (Mansfield Ave.)
is a concern for the Conservation Commission.
Recently, major drainage improvements have occurred along Rt. 123 (West Main St.) as well as
sewage disposal related improvements to the salt storage facility located on Rt. 123 (East Main S1.).
The Conservation Commission appreciates the cooperation received from MassHighway staff for those
projects. We appreciate the opportunity to comment on the snow and ice control plan and see this as an
opportunity to address serious concerns that have yet gone unaddressed.
It should be noted that the Conservation Commission requested a copy of the GEIR on Thursday
September 7, 2006 from Henry Barbaro. One week later, on September 14, 2006, the Commission's
Secretary again spoke with Mr. Barbaro requesting to receive the copy of the GElR, which still had not
been mailed . The Commission received the copy of the GEIR on Monday, September 18, 2006, four
days before the comment deadline. On September 20, 2006, the Conservation Commission contacted
Bill ('Jage regarding the potential for an extension of the comment time . We appreciate Mr. Gage's
attempts to contact MassHighway in order to obtain the extension but are extremely disappointed in
Phone ,508)28')·0271 • Fax (JOB) 285-0277 • c,mseflati,ll1@nurtonm3uscom
the obvious attempts to limit public comment on the GEIR by the proponent by not providing the
requested information in a timely or reasonable fashion.
3.2 BMPs Used by MassHighway
The Conservation Commission has previously brought concerns of impaired water quality to the Mass 1
Highway Dept. In particular, we have requested that the operation and management of the salt shed on ~
Rt. 123 (East Main St) be upgraded and otherwise improved . Mass Highway staff claimed at a wetland 11
hearing that the storm water bmps, including non functional detention basins at the salt shed do not . ~(.(.;­
work properly. We have requested that this be upgraded since the sand and salt-laden water travels to
the lowest point in the road and is transferred from the road directly to the Canoe River via catch
basins. The catch basins alone do not meet the DEP Storm Water Management Policy for TSS removal •
or storm water treatment to a Critical Area. We have also requested that the application of sands and
salts within the proximity of the Canoe River be reviewed and improved. Residents and Commission" I
members have frequently observed large quantities of rock salt that have spilled or been applied to Rt. I
123 (East Main St) such that the salt left a thick white crust on the road long after snow melt. The I
Conservation Commission therefore, requests that:
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a. MassHighway designate portions ofRt. 123 (East Main St) and Rt. 495 that discharge to the ! N .
Canoe River as an environmentally sensitive area.
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b. Redirect stormwater runoff from the site to the existing on site detention basins to prevent I
sediment and salt from entering Route 123
c. We request that Mass Highway use alternatives to rock salt for portions of state roads that I
direct storm water to the Canoe River. We also request that proper signage be installed on I
the highways.
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d. We request that the storm water bmps that direct storm water to the Canoe River be I
enhanced and upgraded to meet storm water management policy.
e. Please add the Canoe River to the areas within ACECs that will be tested for salt related
impacts to the section on Research 5.2.3. (page 96).
f. Please add all requested actions to the Recommendations section 5.2.
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Section 3.2 BMPs Used by MassHighway
The second major area of concern is on Rt. 140 (Mansfield Ave.) where the highway bisects the main
section of Norton Reservoir and the southern coves of the Reservoir. In recent years the highway has
been upgraded and paved sluices have been introduced to the drainage system. The paved sluices direct
water from the road directly into the Reservoir without treatment . Residents and Commission members
have observed sand and salt plumes extending approximately 30-40 feet into the Reservoir in the
winter. The Reservoir Dredging Project has been an ongoing project and goal of the Conservation
Commission. Sand and salt being directly dumped into the Reservoir from State roads does not meet
the storm water management policy and is exacerbating the problems within the Reservoir. We request
that:
g. MassHighway designate portions of Rt. 140 as a sensitive area and salt alternatives be
utilized. We also request that the roads be posted as "no salt areas". We also request that
proper signage be installed on the highways.
We also request that the storm water bmps be upgraded and enhanced to meet the Storm
h. water management policy.
i. Please add all requested actions to the Recommendations section 5.2
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Section 2.5 Coordination Efforts Between MassHighway .and Municipalities for Snow and Ice Control
The Commission requests that the sections regarding Coordination between Mass Highway and
Municipalities be greatly improved. While we have received a written response to our comment letters
t Jtv
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there has been little to nothing done to address the concerns. We are told to follow the correct
~
procedure for voicing complaints but cannot be directed to the "correct procedure" so that we can \ . r
follow it. Staff should be able to direct us to the complaint program rather than impeding our t N Cl.­
complaints. Concerns are met with indifference and a defensive tone. I'm surprised to read about the ' L I
salt complaint program. We have an agreement to meet with MassHighway in the winter to review our
concerns but strongly request that the submitted comments be incorporated into the Snow and Ice
Control Plan to ensure that they will be completed.. This complaint program is not found anywhere on
the website. We request that:
a..
The complaints program and contact information be added to the state website.
b.
Mass highway representatives meet with Norton officials .
6
There should be no mistake about the intentions of the C"onservation Commission with regard to the
Mass Highway's Snow and Ice Plan. Our intention is not to prevent Mass Highway from pretreating or
treating the roads for the safety of the public. Our intention is to cooperatively work with Mass
Highway to improve the storm water treatment, prevent sand and salt from polluting our drinking
water source and protect our natural resources. Thank you.
Sincerely,
~~~:+~-. C~Z\to
Jennifer Carlino
Conservation Agent
CC: Keith Silver, Norton Highway Superintendent
Jim Purcell, Norton Town Manager
Bill Napolitano, SRPEDD
Liz Sorenson, ACEC Director
Jon Regosin, NHESP
Wayne Southworth, Canoe River Aquifer Advisory Committee
Gregory H Prendergast, Director Environmental Services, MassHighway
Henry Barbaro, Wetlands Unit Supervisor, MassHighway
DEP-SERO
MACC
October 16 2006
I
Robert W. Golledge, Jr., Secretary
Executive Office of Environmental Affairs
100 Cambridge Street 19th Floor
Boston, MA 02114
Attention: William Gage, MEPA Office
.,'
...­
Re:
Massachusetts Highway Department Snow and Ice Control Generic Environmental
Impact Report EOEA #11202
I
Dear Secretary Gol/edge:
The City of Boston Environment Department has reviewed the Generic Environmental
Impact Report (GEIR) and offers the following comments. A Final GEIR was submitted to
MEPA in 1995.
The Massachusetts Highway Department (MHD) is responsible for snow and ice operations
on about 4,132 linear miles (IF) of roadways. Issues associated with these activities
include:
• salt storage
• reduced salt zones
• improved highway drainage systems
• salt application rates
• salt application near environmentally critical areas
• alternatives to salt
• sodium standards
• use of private contractors
• recycling of sand sweepings
• coordination of snow and ice operations with local communities
• snow removal on sidewalks and shoulders
• economic impacts of lake and pond eutrophication
• public education
• structural alternatives
.
BED comments - MHD Snow and Ice Control GEIR, EOEA #11202, Page 2
The 1995 Final GEIR recommendations included:
• using only automated spreaders
• ensuring regular, proper calibration of public and private vendor spreaders
• consistent application rates
• more efficient application patterns
• proper storage and handling of materials
• modify the Materials Control System and standard operating procedures
• new training programs
• District-based corps of chemical application monitors
• use public education to inform the public and government officials about the
need to reduce salt use and the effects of reductions on standard of
maintenance
• developing a management system that stresses reduced salt application
The GEIR states that:
• the current deicing material uniform application rate policy calls for 240
pounds per lane mile (lbs/ln mile), down from the 300 Ibs/ln mile policy in
effect from 1976 to 1995
• several chemical deicing materials are or have been in use including sodium
chloride, calcium chloride, sodium chloride/calcium chloride mix (Pre-mix),
calcium magnesium acetate (CMA), magnesium chloride, potassium acetate,
ethelyne glycol, sodium formate, methyl alcohol and chemically-treated
abrasives such as sand
• although they are in use or have been in use by other agencies, MHD has not
tried salt brine, liquid brine, urea and alcohol/glycol
• anti-icing techniques such as applying liquid calcium chloride or magnesium
chloride are also used
• experiments with CMA have led MHD to conclude that CMA and magnesium
chloride will not be used on its roadways
• MHD has found no viable alternative to sodium chloride
• experiments with alternative pavement materials conducted from 1981 to
1985 showed that they did not reduce the need for deicing chemicals
• salt can enter surface water, groundwater and soils
• maintenance depots with salt storage in Boston are located beneath the
expressway at Columbia Road in Dorchester, the CANA Yard off of
Rutherford Avenue in Charlestown and under Route lA at Neptune Road in
East Boston (material storage)
• it is costly to clean up, remove and dispose of sand
BED comments - MHD Snow and Ice Control GEIR, EOEA #11202, Page 3
• MHD should engage in one or more research programs designed to collect
data and analyze findings about critical operational factors that affect road
salt usage and develop a plan for improving salt management
• abrasives, particularly when pulverized by repeated vehicular contact, can
degrade air quality with particulate matter of special concern
We concur with many of these conclusions and offer additional thoughts.
It is apparent from the GEIR that assessing abrasive-related localized concentrations of
particulate matter and its affects is a difficult task. The monitoring of criteria air
pollutants to establish compliance with National Ambient Air Quality Standards (NAAQS)
does not provide sufficient data upon which to reach conclusions and NAAQS and the
State Implementation Plan (SIP) are not intended to reflect localized impacts. We note
that the majority of cites in the Air Quality section of 4.2, Environmental Concerns of
Sand, date to the from the early- to mid-1990s and question if there is more recent data.
Is there an established protocol for determining the level of particulate matter in areas
along MHD roadways where abrasives are routinely applied and as the result of clean-up?
Are ultrafine particles a potential concern with abrasive used in thi~ context? Have these
questions been addressed in other jurisdictions and, if so, with what results? If abrasives
will continue to be a significant part of the MHD snow and ice management program, air
quality issues and mitigation should receive greater attention.
--­
~~~
01 \6~-~-~
It has been 21 years since alternative paving materials were evaluated by MHD and section
3.1.5 does not include significant recent data from other jurisdictions. We suggest that
MHD research current options and engage in a multi-product testing program.
02 ­
This department and the Boston Conservation Commission (BCC) concur with MHD that
there should be ongoing research into methods of snow and ice management that can
~£y-'
maintain driver safety while reducing the amount of salt and sand applied to roads. The
states of New Hampshire and Maine have reduced rock salt application levels in recent
years with the use of a salt brine solution on their highways and we suggest testing of this
method. The GEIR indicates that it can reduce the use of both salt and abrasives. We
believe that pre-wetting and anti-icing are practices worthy of MHD's investment. Like
other methods of snow and ice management, they are not benign but seem to offer a
substantial safety benefit and fewer costly environmental impacts when there are
accurate weather and roadway condition predictions, strict adherence to application
procedures are and comprehensive public education. We suggest that pilot programs be
conducted in several areas of the Commonwealth designed to assess the performance
measures outlined in Table 4.4-1. ~~~~--
c3 BED comments - MHD Snow and Ice Control GEIR, EOEA #11202, Page 4
r
We endorse the Recommendations at Section 5.2. In addition to those identified, we
~£i~""
encourage MHD to engage in research on topics beyond those identified for funding under i
the Federal Highway Administration's (FHWA) Transportation Pooled Funding Program.
10'1
for example, as we noted previously, pavement options may have improved since the mid­
1980s and the health-related effects of particulates are better understood making air
quality a subject deserving of additional consideration.
There is a brief discussion in this GEIR about an ll-year old survey of regional state agencies on data program costs related to the percentage of private contractors used in the program. Although data such as "lane miles" is not similarly defined amongst agencies,i MHD concluded that the use of private contractors was cost-effective in the long- term. In an updated 2001 questionnaire, information was sought about deicing agents, alternative technologies, annual salt use, average traffic volumes and the extent of private contractor· use. MHD concluded that it operates a program similar in cost, predominant deicers, equipment and evaluation of other technologies to those used by other transportation agencies in New England. i
On September 24,1997, then-Secretary Trudy Coxe issued a Certificate of the Secretary
of Environmental Affairs on the Environmental Notification Form for an
MHD/Massachusetts Turnpike Authority (MTA)/Metropolitan District Commission (MDC)
Snow and Ice Control Program. Secretary Coxe indicated her expectation that the MHD
would be the lead agency in preparing a GEIR and would solicit, but not wait for,
contributions from the MTA and MDC (now the Department of Conservation and
Recreations [DCR) and that a joint effort of the agencies might be difficult due to "vastly
dissimilar levels of technology available to the agencies (e.g. computerized versus manual
dispensing apparatus), significant differences in the extent of public employee versus
private contractor utilization, and overall level of expertise in dealing with snow and ice
control." She further noted that she, "expect[ed] that the GEIR (once completed) will act
as the basis for snow and ice control on state-owned roadways in Massachusetts and I
therefore encourage the participation of the affected agencies, particularly the MDC,
which is in the Executive Office of Environmental Affairs."
There is no discussion in this GEIR about attempt to coordinate efforts with other Massachusetts' transportation agencies. We believe that the use of common technologies,
best practices, training resources, anti- and deicing-chemicals and research has potential cost, effectiveness and safety benefits. While we understand the issues cited by then­ Secretary Coxe in 1997, efforts to bring the agencies in line with each other in those
areas should have been policy and practice since that time. Expertise should be shared
and knowledge of effective snow and ice management equal across agencies. Training,
BED-­
OS' I
t
BED comments - MHD Snow and Ice Control GEIR, EOEA #11202, Page 5
monitoring and researching technologies, equipment, chemicals and techniques and major
components of developing standard best practices that make all of the Commonwealth's
public roadways equally safe for motorists and those who maintain those roads. Levels of
technology should, over time, become standardized, on a par and compatible. The
implications of the "significant differences in the extend of public employee versus private
contractor utilization" should be examined carefully. Bringing all of the transportation
agencies into line on snow and ice management should be a goal of the Commonwealth and
we urge the Secretary to take the steps necessary with other Executive Agencies to move
toward this end.
As part of an effort to minimize the air quality impacts, all on- and off-road, public and private diesel equipment used in snow and ice control management should be retrofitted with oxidation catalysts or particulate filters and operated on ultra low-sulfur diesel.
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We believe that the filing of a GEIR on a more frequent basis is appropriate at this tim-e---1i
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and suggest that a new one be filed in five, rather than 10, years.
Thank you for the opportunity to offer comment.
Sincerely,
Bryan Glascock
Director
MHDSnowIceControllOO6.doc.. DBG;MTZ.. mtz/061007
Gage. Bill (ENV)
From:
To:
Ziody, Maura [Maura..llody@cityofboston.gov]
Monday, October 16, 2006 7:27 PM
Bi/lGage
Subject:
FW:
Attachments:
MHDSnowlceControI1006.. doc
Sent:
MHDSnowIceContro
1l006.. doc (50 ...
Sorry Bill.
This is the right version.
-----Original Message----­ From: Zlody, Maura Sent: Monday, October 16, 2006 7:09 PM To: 'Bill Gage' Subject: Maura T. Zlody City of Boston Environment Department Boston City Hall, Room 805 Boston 02201 617 --635--4 421 617-635-3435 (fax) maura.zlody@cityofboston.gov The substance of this message, including any attachments, may be confidential, legally privileged and/or exempt from disclosure pursuant to Massachusetts law.
It is intended solely for the addressee.
If you receive this in error, please contact the sender and delete the material from all computers. The substance of this message, including any attachments, may be confidential, legally privileged and/or exempt from disclosure pursuant to Massachusetts law. It is intended solely for the addressee. If you received this in error, please contact the sender and delete the material from any computer. 1
SEP 2 ~ ;
September 27,2006
•;r:­
OJ o
Ul , I
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MEPA
Secretary Robert Golledge
Executive Office of Environ menta I Affairs, MEPA Office
100 Cambridge Street, Suite 900
Boston, MA 02114
RE: Comments on Generic Environment Impact Report (GEIR) for the Snow and Ice Control
Program of the Massachusetts Highway Department
EOEA#u202
Dear Mr. Golledge:
WalkBoston appreciates the opportunity to comment on the GEIR for the Snow and Ic.e
Control Program of the Massachusetts Highway Department. We are commenting because
of concern about the pedestrian issues associated with this program.
The GEIR covers many of the steps that the MHO has taken to deal with the impacts of its
application of chemicals on roadways. It discusses in detail the impacts that these
materials have on pavement and the relative degree of effectiveness that the materials
exhibit when removing snow and ice. It describes procedures that snow plowers (whether
state empioyees or service-providers hired by the state) must follow, along with ways that
the state will oversee the operations associated with snow plowing. In several ofthes~
discussions within the GEIR, the MHO comes tantalizingly close to describing potential
impacts on pedestrian movement, yet there is no explicit acknowledgement that
pedestrians have a stake in the way the state removes ice and snow from roadways and to
the relationship between roadway and sidewalk snow and ice clearance.
•. WQ.\"-­
or
I!:!.~.impact_of roadwgy.~now and
ice clearance on pedestrians.
Pedestrians are clearly affected by the remova I of snow from roadways and sidewalks and
the effects of inadequate clearance that results in unsafe conditions for walking. After a
snowfall in Massachusetts, it is possible to view city or town streets where the roadways
are well plowed, but the sidewalks are impassable. Common public services such as postal
deliveries or meals on wheels can be disrupted. Commuters and school children find their
routes blocked. Uncleared sidewalks parallel to snow mounds can force pedestrians onto
the street where pedestrian·automobile crashes are far more likely to occur. Even where
sidewalks are cleared, pedestrian access at intersections is frequently blocked by roadway­
related snow mounds that impede safe walking through the intersection.
The simple activity ofwalking is dramatically altered by the presence of snow. Snow
mounds present a physical challenge to pedestrians, and walkers who are trying to cross
mounds of snow to get to a safe walking route may have their attention diverted away from
oncoming traffic. Intersections clogged with snow or snowmelt can challenge pedestrians
trying to cross, again causing temporary diversion of attention from oncoming traffic.
Drivers may not be able to see pedestrians forced onto roadways.
MAKING OUR COMMUNITIES MORE WALKABLE
Old City Hall I 45 School Street I Boston MA 02108 I T: 617.367.9255 I
1
F: 617.367.9285
I
info@walkboston.org
I
www.walkbostonorg­
Gage. Bill (ENV)
From:
Sent:
To:
Subject:
Zlody, Maura [MauraZlody@cityofboston.gov] Tuesday, September 26,20063:18 PM Gage, Bill (ENV) FW:
\
\
Now it seems that the con\ment due date has been changed to 10/11. True? If so, our Con Com person\may want to comment (he's on vacation) . \
-----Original Message----- \ From: Zlody, Maura
'
Sent: Tuesday, September 26, \4006 3: 11 PM \.c
To: 'bill.gage@state.ma.us'
Subject:
Hi Bill.
/
I
;'
We're taking a pass on 'the MHO Sndw
&
Ice Control GEIR.
Maura
Maura T. Zlody
City of Boston Environment Department
Boston City Hall, Room 805
Boston 02201
617-635':"4421
617-635-3435 (fax)
maura.zlody@cityofboston.gov
The substance of this message, inttluding any attachments, may be confidential, legally
privileged and/or exempt from dis'closul:e pursuant to Massachusetts law. It is intended
solely for the addressee. If Y911 receive this in error, please contact the sender and
delete the material hom all computers .
_'-_
..... -----._-_._-_.__ ......... .... _----_._-.,_._---;....
.._" ... _.. _-- .... ­
The substance of this message, including any attcrchments, may be confidential, legally
privileged and/or exempt from disclosure pursuant\to Massachusetts law. I t 1s intended
solely for the addressee. If you received this in error, please contact the sender and
delete the material from any computer.
"
1
Sidewalks are found along state roadways throughout the Commonwealth, and some roads
that were originally constructed without sidewalks now have them as a result of the
continuing urbanization and suburbanization of tt:e state. Adding sidewalks is likely to
continue as communities become increasingly aware of the need to provide pedestrian
access to workplaces, schools, shopping and recreation.
The importance of providing safe pedestrian access in all seasons cannot be taken lightly. It is a matter of public safety, adequate transportation, social justice (many of our citizens who are pedestrian and transit-dependent are lower income or elderly), and economic well­
being (we discourage elders and the disabled from staying in Massachusetts if they feel isolated and home-bound by wintry conditions). The GEIR states: "It is the policy of MassHighway not to perform snow removal functions on
sidewalk areas abutting state highways or bridges." (Appendix B, Chapter 5 of MHO's
Maintenance Manual, Section 5.3.8)
W~\~-
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This policy does not seem to conform to the MHD Project Development and Design Guide,
2006 edition, which states: "MassHighway. in its role as steward of our roadways, must
consider a broad range offaetors in maintaining (emphasis added) or improving this
system. including:
• Safety for all users
• Functionality -- the need for access and mobility
• Accessibility for people with disabilities...
• Input and participation from local constituents .....
The manual quotes state law: "Chapter 87 of the Acts of1996 requires MassHighway to
'make all reasonable provisions for the accommodation of bicycle and pedestrian traffic...'"
(Section 1_2.1, p. 1-3) The manual continues with this Guiding Principle: "Multi modal
consideration - to ensure that the safety and mobility of all users of the transportation
system (pedestrians, bicyclists and drivers) are considered equally through all phases of a
project so that even the most vulnerable (e.g., children and the elderly) can feel and be safe
within the public right of way..•." Section 1.2 Guiding Principles of the Guidebook. detailed in
Section 1.2.1. p. 1-3.
, I
The public right of way frequently includes sidewalks on one or both sides of the r~adway,
and these sidewalks are needed to "ensure the safety and mobility of all users of the
transportation system." If snow and ice are not to be removed from sidewalks, as stated in
this GEIR, this places the GEIR at odds with current state policy.
WalkBoston believes that the GEIR should be modified to show the methods by which the
state will ensure removal of snow and ice from aU parts of the transportation system that
are within the rights of way of its roadways. MHO might do the work on its own, through
hired agents, or by means of agreements with local communities or private abutters. The
GEIR also fails to cover methods for accomplishing a full-scale removal of snow and ice from
all routes through its rights of way, and faits to cover potential additional environmental
impacts that may accrue from a more comprehensive approach to snow and ice removal.
2
The environmental impacts of snow removal for pedestrians have not generally been
closely examined.
The GEIR should address the issues noted below.
Safm for both_d!:blers and pedestrians. The state has determined that highway safety and
vehicle mobility are high priority reasons for snow and ice removal. Clearing only the road is
insufficient as a method for providing safety. Pedestrians crossing roadways or walking
within the roadway constitute significant dangers for both drivers and themselves. The
extent to which pedestrians use roadway pavements for walking is greatly expanded when
sidewalks are left uncleared or when roadside snow mounds force people to clamber over
them to cross streets. Many miles of MHO roadways are paralleled by sidewa Iks and are
thus critical components of the pedestrian (and transit) transportation networks.
Development of a protocol for determining who will be responsible for sidewalk snow clearance on MHO roadwa~. Sidewalk clearance responsibilities may well faU to several different parties including MHO, local municipalities, otherstate or locat agencies, or private abutters. In order to "ensure the safety and mobility of all users of the transportation system." t~js responsibility must be assigned. managed and enforced throughout the state. As the owner and operator ofthis transportation network, MHO should assume the job of leading the effurt to determine how and by whom the sidewalks ' will be cleared. :The right of way as a bas!~fQr snow and ifg removal. Municipalities throughout
Massachusetts remove snow and it;e from local roadways and establish methods for
removing snow and ice from sidewalks; Yet the state does not take on the same
responsibility for its roadways. Thus. local jUrisdktions must provide for snow and ice
removal from sidewalks along state roadways without substantial state assistance.
Without coordination between the state and the municipalities. several issues emerge:
1. Intersections. The maintenance of a safe pedestrian passageway is critical at street
crossings. The crossings are often blocked by snow plowing procedures that si mply
pile up snow evenly along the road, covering sidewalks, handicapped ramps and
street corners, forCing pedestrians to walk in the roadways. According to the MHO
plowing standards, the state or its plowing agents clear important Intersections for
roadway traffic. No mention is made of attention to crosswalks or for sidewalk access
into the crosswalks. The responsibilities of the state and its agents in clearing
intersections -, including pedestrian access through the intersection - should be
spelled out, as has been stated in 2-lane Plowing Standard 1, GEIR Attachment 7. that
states that "Truck #3 is also responsible for clearing important intersections." This
assign ment of responsibility is significant, and should be augmented by detailing the
actions to be taken to provide for pedestrians at intersections and should be
extended to all Plowing Standards. Attention to this issue can help municipalities
cope with comprehensive snow removal for sidewalks.
2. Roadwa>t use by walkers. When the state or its agents clear roadways of snow. safe
pedestrian passage must be maintained.IFthe roadway is temporarily used as a
substitute sidewalk because sidewalks have not been cleared pedestrian and
vehicular safety is compromised. Snow removal frequently results in substantial
3
mounds of snow paralleling the state highway that, in many cases, block the
sidewalks and driveways connected to the roadway. Snow mounding as a method of
disposal may exacerbate the problem of clearing sidewalks because of the sheer
volume of the snow plowed onto the sidewalks.
I~.Ianni!l& Streets can be designed to make plowing easier. Sidewalks might be placed 1\fJa\~_
at a distance from the roadway that is sufficient to accommodate snow plowed from
I"~,
the street. Snow fences could be located to control snow buildup on pedestrian
V'\J
facilities and help reduce removal costs. Pedestrian safety islands should be designed
to remain snow-free after plowing operations. The state should establish guidelines
for improved design.
~~~-~.!
Resear!;h. The GEIR contains documentation of lane-miles plowed under state
responsibility. Perhaps research is necessary to document pedestrian miles on
sidewalks along state highways and to show how state snow plowing policies affect
pedestrians and how those policies need to be amended or supplemented. In addition
to providing a ptan for ensuring the clearance of sidewalks,lt would be useful to know
what financial and technical assistance the state might provide for communities and
pedestrians during snowy conditions along state roads through a variety of funding
sources such as CMAQ, safety funds or hazard elimination funds.
~ _____________,
-----'1
3·
4·
(fir:..
COQrdination of local and state efforts. The method by which state and local coordination takes place is described briefly in Section 2.5 of the GEIR, with subtopics of technology transfer and complaints. Some other issues that should be addressed are: 1. DivisiolJ..of responsibHities. As noted above, MHO must determine sldewaik snow·
;\.AA\t­
dearing responsibilities and how state, local and private entities will divide the work. A
detailed plan fGr coordination is essential to determine precisely how the
responsibilities will be divided, especially at locations where different responsibilities
will abut or overlap. For example, at intersections where there are sidewalk
connections into intersections, pedestrian crossings through intersections, and
sidewalks along the roadways and across driveways. It is important for the MHO to
include information about pedestrian issues for inclusion in the plow route schedule
each fall, as specified in GEIRAppendix B. Chapter 5 of the MHO Maintenance Manual,
Section 5.5.3. and for information to be disseminated by the Traffic Operations Center
(Section 5.3.4). MHO Districts (Section 5.3.5). and shared (Section 5.1-4).
.
2. Sidgwalk snow r.~!l1oval.RrQ~edures. Written procedures can help clarify how snoWiST6->"--"--r
be removed from sidewalks along state roads by agents other than the MHO. The state.
municipalities or other state agencies can estJblish priority sidewa Iks that must be
maintained for walkers right from the start of a snow emergency. One model has been
prepared by the OCR, which works with the MHO to clear certain of its roadways. The
state clears curb-to-curb, and the OCR clears the sidewalks according to a
predetermined priority rating assigned to each sidewalk. Some communities (e.g.
Concord) dear snow from sidewalks along state roads according to a plan that has been
developed in conjunction with the school department to facilitate safe access to
schools. Priorities may need to be established for sidewalks leading to schools. transit,
hospitals and clinics, business concentrations, and public services such as police and
fire stations, as well as based on the density of pedestrian use.
3. Bartering. A bartering process described in the GEIR (Section 2.5.3. p. 29) is an informal
method of coordinating operations. with the state taking on some municipal
oS
4
responsibilities. This method of coordination could be used to establish procedures for
loca.1 communities. Coordination might be embedded in written agreements between
the state and the cities and towns that define responsibilities for the details of snow
removal.
4. Lnformatio!ubaring t The state should make every effort to share information from its
Road Weather Information System (RWIS) so that local communities could further
coordinate snow removal and deicing of roadways and sidewalks in their communities.
5. Communication with the public~ The public should be informed of policy decisions
concerning snow removal on sidewalks, streets and at intersections, so that individuals
can plan routes to work or school or for other purposes. One method is to place
information delineating responsibilities on the Internet or on printed material that can
be widely distributed. A good example of delineating agency responsibilities for snow
removal is laid out in the Department ofConservation and Recreation's website at
www.mass.gov/dglwinterstormplan.htlll.Bylayingoutsnowremovalintentions.it
may be possible to avert tragedies involving pedestrians walking in roadways.
Thank you for the opportunity to comment on this GEIR. Please feel free to contact us for
clarification or additional comments. We would be very pleased to work with MHD on this
important issue.
S'i~' /;a~
Wendylan
an
Executive Irector
Robert Sloane
Senior Planner
Cc: louisa Paiewonsky, Commissioner of the MHO Steve Burrington, Commissioner of the OCR 5
:'
/\
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,.1 ...
f
RICHARD F. TAYLOR, Ph.D.
P.O. Box 285
West Boxford, MA 01885
18 September 2006
Secretary Stephen R. Pritchard
Exectutive Office of Environmental Affairs
Attn: MEPA Office
100 Cambridge Street, Suite 900
Boston, MA 02114
~£CfIVE[
SEP 20_
MEPA
Re: Mass Highway Snow and Ice Control Program GEIR, EOEA #11202
Dear Secretary Pritchard:
As a member of the Boxford Board of Health, and on behalf of many concerned citizens in Boxford, I
would like to bring to your attention serious deficiencies in the above referenced MassHighway GEIR.
Drinking water in Boxford is completely dependent on private wells. Storm water runoff from a MHO
road salt storage shed in Boxford (referenced in the GEIR, Appendix H, Highway Maintenance
Section '0', Topsfield Road) and operations associated with that facility; together with inadequate
control of saft runoff from Interstate Route 95 has resulted, by MHO's own admission', in the
contamination of at least 31 private wells in Boxford to the extent where well replacement (if possible)
is required. In addition, data are available which show increasing salt contamination with time of a
pond in the same area, and projection of the eventual contamination of a public water supply located
at Andrews Farm, Boxford (DEP Source 10#3038020-01 G). Water testing results from sampling over
the past 10 years or more have shown a gross increase in sodium and chloride levels in area private
wells, riSing in some specific cases from less than 20ppm sodium to more than 500ppm sodium, and
chloride contents exceeding 1000ppm.
160 )(-­
! 0\
Other indicator compounds such as calcium and manganese have also Significantly increased in
analysis data from Boxford wells in the salt shed area. Such increases are well documented from
scientific studies on road salt effects and are known to indicate high salt concentration ion exchange­
mediated mobilization of heavy metals (including lead, cadmium and mercury) and organics
deposited along roadways (such as polyaromatic hydrocarbons) into ground water and aquifers. High
road salt concentrations maya/so extract and mobilize soil and rock-bound arsenic, which is known to
occur naturally in Boxford. The sodium ferrocyanide used in road salt as a decaking agent is also of
concern to this Board since it is known to photolize to cyanide ions and pose a potential toxic threat in
---­
ponds and pools.
e:o)<.­
() 2.
,
Without remedial action by MHO, such as moving the salt shed and adequately controlling storm
water runoff, we project that more wel/s, ponds, and aquifers will become contaminated with salt; and
with toxic materials released by high salt concentration from soils, such as arsenic, heavy metals, and
toxic organiCS.
Yet, no such remedial action, such as moving a salt shed from an area where it is a confirmed point
source of pollution is proposed by MHO in the GEIR.
_,___.
MHO quotes on page 22, Section 2.4 of the GEIR, MGL Title 14, Chapter 85 §7A which specifically prohibits storing n, •.. sodium chloride, calcium chloride or chemically treated abrasives or other
I
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Secretary Stephen R. Pritchard, eOEA
18 September 2006
page 2
chemicals used for the removal of snow or ice on roads in such a manner or place as to subject a
water supply or groundwater supply to the risk of contaminants ... ". The law also specifically states
that it applies to, among others. " ... the chief engineer of the state department of highways ... ". MHO
further implies that it follows this state law.
We request that MEPA requires a specific plan from MHD to address known point sources of
salt contamination of aquifers such as the salt shed on Topsfield Road in Boxford, and that
this plan be included in the GEIR.
We further ask that MEPA requires that MHD adhere to MGL Title 14, Chapter 85 §7A without
exception.
MHO's GEIR also is deficient in addressing the manner in which it carries out its salt remediation
program (pages 18-22 of the GEfR). Our opinion is that this remediation program is central of any
GEIR and needs to be addressed in more detail.
While MHO does have a well replacement program, the program relocates wells in areas where the
aquifers are already contaminated, and ignores the point sources of the pollution such as a salt shed.
As a result, replacement wells still contain high levels of sodium, chloride and other indicator ions of
salt contamination . With time, such wells will also become unusable as more salt is added to the
plume emanating from the point source.
MHO also fails to address environmental and property damage caused during its well replacement
program, and the fact that it refuses to observe state and local well installation regulations and
wetland regulations. When challenged about the latter by the Boxford Board of Health, Conservation
Commission, and Board of Selectmen, MHO claimed it is Ita solvent power" and not subject to MGL
governing private well installation (MGL Title 2 Chapter 21 §16 and 313 CMR 3.00), nor to state or
local wetlands protection laws.
.
For example, on 6 February, 2006, at a meeting of the Boxford Board of Selectmen attended by State
Senator Bruce Tar, and State Representatives Brad Hill and Barbara L'ltaJien, David White and Rick
Manta of MHO stated that MHO is not subject to state and BOH well regulations and neither MHO nor
its well driller contractors had or intended to follow state and BOH regulations. Another MHO
employee, Henry Barbaro stated that MHO was also exempt from the Wetlands Protection Act and
local wetlands regulations administered by the ConsCom.
MHO was served with five Enforcement Orders in February and MarCh, 2006. issued by the Boxford
ConsCom for violations of the Wetlands Protection Act. In a meeting of the Boxford ConsCom on 12
April 2006, William Hicks, Counsel to MHO stated that the MHO well drilling operations are exempt
from the Wetlands Protection Act since the drillings are actually 'exploratory borings.' When it was
Secretary Stephen R. Pritchard, EOEA
18 September 2006
page 3
pointed out to Mr. Hicks that the Wetlands Protection Act does not classify a well as an 'exploratory
boring,' Mr. Hicks deferred to 'a need for further communication with OEP.' When Henry Barbaro,
MHO wetlands supervisor, was asked whether he considered all drilled wells 'exploratory borings' until:
they prove productive and are ready to be linked to a house, he replied 'absolutely.'
' \
A\
We request that MEPA require MHD, as part of its GEIR, to determine the extent of damage
MHD has caused to the surrounding aquifer and groundwater in Boxford and other
communities and to propose a specific means to eliminate these problems; and to ensure it
will follow all state and local regulations, including well installation and wetlands protection
regulations, in any remediation program.
We realize that snow and ice control is important to safety on Massachusetts' highways. However,
MHO has not adequately addressed the inadequate storage and use of salt in communities such as
Boxford. The MHO GEIR if accepted as written will only contribute to continued contamination of
critical aquifers by MHO operations and a remediation program which falls far short of true and long
lasting remediation. We hope that MEPA will refuse the GEIR as submitted and ask for a
resubmission addressing the pOints above.
cc: Boxfo
Boxford Board of Selectmen
RICHARD F. TAYLOR, Ph.D. PO Box 285 \-Vest Boxford. :\-IA 01885 ~lt[\vtt
9 October 2006
Secretary Stephen R. Pritchard
Exectutive Office of Environmental Affairs
Attn: MEPA Office
100 Cambridge Street, Suite 900
Boston, MA 02114
\OCl \ 1 zoot>
tAlP~
Re: Mass Highway Snow and Ice Control Program GEIR, EOEA #11202
Dear Secretary Pritchard:
This letter supplements and provides data in support of my letter to you dated 18 September
2006, addressing deficiencies in the above GEIR filed by Massachusetts' Highway Department
(MHO).. I am submitting this under the extension for comments allowed until 12 October 2006.
In the 18 September letter, we pointed out that while MHO purports to follow Massachusetts
Law and, specifically, MGL Title 14, Chapter 85 §7A (page 22, Section 2.4 of the GE/R), in fact
MHO has violated and continues to violate this law in Boxford by refusing to address a salt shed
on Topsfield Road in Boxford which they have admitted is the source of contamination for a
major drinking water aquifer. Based on these facts, we requested that MEPA reject the
proposed GE/R based on a failure by MHO to provide satisfactory remedial action to restore the
aquifer and remove the salt shed as a point source of pollution.
We provide, herein, evidence to support our claim that MHO's remediation plan for salt
contamination in Boxford is flawed and, simply, is not working.
Table 1 (attached) reports a summary of water quality data reported to the Boxford Board of
Health for nine wells installed by MHO in Boxford as part of their salt contamination remediation
plan. The data from sodium analyses show that all the wells far exceed the EPA reporting limit
of 1mg/L; and all but one exceeds the Massachusetts' ORSG guideline for sodium of 20mg/L,
by as much as 14 fold. Other quality parameters such as chloride, magnesium, sulfate, calcium,
hardness and specific conductance also far exceed ,normal guidelines for safe drinking water.
The values in Table 1 also, in all cases except calcium, far exceed average water quality
parameters in Boxford.. Boxford has been coordinating town-wide water testing for over 20
years for our residents and as part of specific studies. For example. Table 2 reports the results
from a five-year study on water quality at 34 weI/locations spaced throughout Boxford. While all
parameters exceed EPA reporting limits except volatile organics, none approach the levels in
the MHO 'remedial' wells. For example, the average sodium content of 18.8 mg/L (n 34 wells
x 5 years = 170 samples) is below the Massachusetts' ORSG guideline and approximately five
times less than the average sodium content in the MHO 'remedial' wells reported in Table 2 .
~imilar differences can be seen in the other parameters. MHO does not test for volatile
organics.
=
Secretary Stephen R. Pritchard, EOEA
9 October 2006 page 2
These data support the obvious conclusion that trying to remediate a salt contamination
problem in drinking water wells cannot be accomplished by drilling new wells into the same,
contaminated aquifer. MHO needs to propose a remedial plan to address the point source of the
contamination, i.e., the salt shed on Topsfield Road. Until this salt shed is moved away from
drinking water aquifers, it will continue to contaminate the aquifer.
This latter point is graphically illustrated in Figure 1, which approximates the locations of MHD
installed wells or wells under construction/investigation in the area of the Topsfield Road salt
shed. From the well locations, it is obvious that the contamination is widespread and moving in
a southerly direction. As pointed out in our 18 September letter, it appears only a matter of time
before the public water supply at Andrews Farm, Boxford (DEP Source 10#3038020-01 G) is
contaminated from the MHO salt shed.
Based on the data enclosed, we again request that MEPA reject the MHD GEIR until such
time that MHO provides a satisfactory and realistic remedial plan to obey Mass General
Law and which addresses the Topsfield Road salt shed contamination in Boxford.
cc: Boxford Board of Health Files
Boxford Board of Selectmen
.,,_..
_-_._-_.__......__
....
_-._._._--- •.__......•
_
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..
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eMail: TC4dlilJlor7f:cs.com
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..
Table 1. Representative Water Test Results from Mass Highway Salt Impacted Residences'
!
+___
~ EPA Re£2~ing ll~-t_'L I
, - - - - Addres:·---T Sodium Chloride! Calcium
~ __~m...2ie or te~t date)
'!1.st.h..~ mgll :. mgll
i
~1..§ilv~.r:broo~~.ane.J.D!~----.!6__ ~7 !
6
I
i
9.&-+
Iron
mall
0.1
M~~~es- ! M::::mglL
I
mglL
Sulfate
mall
Nitrate
mgll
0.1
I
0.05
3
0.02
Ars-:::-i Lead
mg/l
mgll
0.005
0.001
I
I Hardness ll--;'::Cffi~ ---I
b
i
I
I conducta!!~~1
2
.t--_L.__~
L.J!1_i--~CL_-J
32
27
19.7
0.32
31.2
0.052
0.004
0.011
I
i
·
I
I
11ZJ>!!~~roo~i1~.Q~_--i- ___ .~1L...i-_180
29
ndd
20'
nd
22
nd
i nd--L 0.001
150. ' ----'!!L___-I
i
I
I
i
i
i
~~~!Y~_rboO~.@!.Q61_-.__+-.-2~-L 42
5
nd
2.6
0.032
83
nd
nd
0.0013 +--~_--+- __ .~_300~.'.j'
I
I '
I
I
I
Tit.~..h.ane (1219.§l_ _~_~7
200
!
77
1.4
44
0.7
17
nd
nd
0.002!
310
~~o -_,
I
I
I
r
I
I
r
I
~_UitusJ:.~.n~.?I05)
I ..-.1~~_3_1_-L. 5.6
I
:
~J_Ii.t!:'~J.:~ne (12/05)
no
I
I
--L- _110_--+_...28 !
1 18
Kill~mJ::!!!!Bl:I'
12105
1L__
.__~.?__
1__
14 Roberts ~oadJ:1.!'Q6~_
i
._+
rLver~gevalue(n=9):_1_~_6~.l
I,
nd
36
no
i
nd
nd
I
nd
l.13 Tit~~haneJ..12/051___+-I ...!QO--0~-1
9.8
I ~ !
I
1.5
i
T
I
I
1
+--+
I
20
I
0.024
nd
3.7
nd
29
nd
0.5
1.6
no
34
n J nd
nO
--LI
31
I
nd
I
100
I
8.7
I
25\
0.2
9.9
nd
15
nd
0.001
31
.
2 4 2.7
11
0.08
16
nd
0.005
O.001!
~10_._~
.
77.9
23.2
I
I
12.7
31.5
111
-----------_.­
450__
~~
I
440
__ -1
220
"_.1
I
260_. __
1
~ 598 ___ .1
'Data supplied by Mass Highway. These results represent only 9 residences of over 30 known to date with a salt-contaminated drinking water supply
bMeasured a8 mg/L calcium carbonate
C measured as jlohms/cm. Specific conductance's a measure of dissolved salts and corroslvity.
d nd
not detected at lower limit of amalysis
=
J
.+___ _____j
nd
.
32
I
Table 2. Water Quality Paremeters (mg/L), Five-Year Boxford Studt
Ir-- Parameter
Reporting
limit (mg/l)
4189
3/90
3/91
5/92
4193
5-Year
average
II
Sodium
1
16.4
17.2
20.4
19.9
20.2
18.8
I
Chloride
6
25.3
34.6
30.2
29.3
36.4
31.2
Calcium
0.5
43.4
38.1
47.8
58.3
23.2
42.2
0.81
0.51
I
I
I
i
! Iron
I
!
i
Manganese
I
0.1
i
I
0.45
I
0.083
I
I
I
I
I Sulfate
I
,
I
I Nitrate
I
t
0.068
0.059
!
3
I
0.55
I
iI
0.05
I
I
13.2
!
I
!
0.069
I
I
19.2
15.8
I
i
21.9
I
I
i
I
I
i
i
0.90
I
I
0.64
I
0.075
I
I
0.071
i
I
23.9
I
18.8
i
0.02
0.49
0.47
0.29
0.41
0.36
0.40
I Hardness
2
91.5
85.6
76.9
87.3
91.7
86.6
\ Specific
. Conductancec
2
250
267
251
275
268
262
I Organicsd
1
<0.01
<0.01
<0.01
<0;01
<0.01
<0.01
I
b
Water samples from 34 wells spaced throughout Boxford were collected for five consecutive years and. analyzed by the same
laboratory using the same (EPA) methods to establish a baseline of Boxford water quality. bMeasured as mg/L calcium carbonate cMeasured as lJ.ohms/cm <Volatile organics. EPA Method 524.2 !
I
Bf'#~VVI~M
(Pages 120, ~ 121)
"":
\\0
FIGURE 1
Approximate Locations of Mass Highway installed wells, or
wells under construction/investigation near the Mass Highway
salt shed on Topsfield Road, Boxford
• =Installed well or in progress
• = well under investigation
The salt shed location and Andrews Farms public water supply
are indicated
October 9,2006
Secretary Robert W. Golledge, Jr.
Executive office of Environmental Affairs
Attn: :MEPA Office
100 Cambridge Street, Suite 900
Boston, MA 02114
re: EOEA # 11202
~[C[IVEl
oct
12~
MEPA
Dear Secretary Golledge:
Thank you for the opportunity to review and comment on the GEIR for the Mass Highway Snow and Ice Control Program. Overall, some progress seems to have been made since the 1995 review. Investments in new equipment and training are welcome. That trend should be continued and expanded. Mass highway has expertise that can benefit local public works departments. If you don't already offer these services you might consider it: 1. Determining key locations for pavement temperature monitoring
2. Interpretation of monitor information
3. Calibration of equipment including rentals
4. GPS location identification of vehicles
Integration of ongoing monitoring of certain watersheds under Section 61
Findings may be a helpful cross-check of positive results achieved. This is
particularly true for places where state highways have major impacts on
public water supplies. For example, sodium concentration at seven
monitoring locations in the Hobbs Brook and Stpny Brook Watersheds are
now the responsibility of the Cambridge Water Department under Sec. 61
Findings drafted for EOEA # 8263. Since the data is reviewed twice a year
with CWD what actions, if any, are called for?
Another provision of the same Sec. 61 Findings calls for Mass Highway
updates of Emergency Response Maps every three years. Is this current?
Has information reported in this current GEIR about relative salt-tolerance
among trees an<} shrubs been shared with local tree wardens? Does the
Michigan DOT! information agree with that of the Salt Institute?
(
._-­
(~
'-­
October 9,2006
~£&['V£l
OCT 12 2006
Secretary Robert W. Golledge, Jr.
Executive office of Environmental Affairs
Attn: :rvfEPA Office
100 Cambridge Street, Suite 900
re: EOEA # 11202
Boston, MA 02114
"EPA
Dear Secretary Golledge:
Thank you for the opportunity to review and comment on the GEIR for the
Mass Highway Snow and Ice Control Program. Overall, so~e progress
seems to have been made since the 1995 review. Investments in new
equipment and training are welcome. That trend should be continued and
expanded. Mass highway has expertise that can benefit local public works
departments. If you don't already offer these services you might consider it:
1. Determining key locations for pavement temperature monitoring
2. Interpretation of monitor information
3. Calibration of equipment including rentals
4. GPS location identification of vehicles
Integration of ongoing monitoring of certain watersheds under Section 61
Findings may be a helpful cross-check of positive results achieved. This is
particularly true for places where state highways have major impacts on
public water supplies. For example, sodium concentration at seven
monitoring locations in the Hobbs Brook and Stony Brook Watersheds are
now the responsibility of the Cambridge Water Department under Sec. 61
Findings drafted for EOEA # 8263. Since the data is reviewed twice a year
with CWD what actions, if any, are called for?
Another provision of the same Sec. 61 Findings calls for Mass Highway
updates of Emergency Response Maps every three years. Is this current?
CA~ II R- b
l\t+~l ~-
03
Has information reported in this current GEIR about relative salt-tolerance
among trees and shrubs been shared with local tree wardens? Does the
lA t.t L I ({ - OLt
Michigan DOT information agree with that of the Salt Institute?
2
Damage to roads and bridges due to salt is only beginning to be compiled.
Recent events have highlighted dangers from falling structural members as a
growing problem. The tendency has been to do quick fixes like patching
surfaces. That is the ostrich approach to a pervasive problem. I have seen
one other "quick fix" approach. The bridge that spans Route 9 just west of
Route I-195 in Wellesley is wrapped in netting. Great chunks of concrete
have separated from the upper parts of the bridge. They pose a real threat to
any vehicle and passengers in vehicles traveling both east and westbound on
Route 9. How widespread is the use of such netting? I, for one, will avoid
that spot until further notice that real repairs have been made.
Prior years' GEIRs on Snow and Ice Control Programs contained
information about MBTA, MDC and Mass Turnpike practices. Have these
been integrated into the information presented by MassHighway? If not, do
they report to any agency and to the public?
Thank you for making the GEIR available for comments.
"erytruly y~rs,
~~'U~
Ingeborg Uhfir
/
45 Kendal Common Road
Weston, MA 02493
cc: Gregory H. Pendergast, Director, Environmental Services
MassHighway Environmental Section
Attn: Henry Barbaro, Wetlands Unit Supervisor
10 Park Plaza, Room 4260
Boston, MA 02116-3973
Representative Alice Peisch
Senator Susan Fargo
September 22, 2006
Page 1
r--'"-'~'-"--'"'--"-
I
..--"----.. --...-...---. _........._. . _.-..__
.._................
To:
Robert Golledge, Secretary of En'vin>nDlebltal
MEPA Review Unit, 100 Cambridge
Attention: William Gage
From: Stephen H. Kaiser, PhD
Generic ErR on Snow and Ice Control EOEA #11202
The Generic EIR for Snow and Ice Control a.k.a "Road Salt" is the seeming
completion of a lengthy analysis that began in the early 1970s. The report is
designated as "Prepared for Mass Highway" in May 2006 but by whom? I know
Normandeau Associates had a contract with MHSD. Did they write the report?
Was it edited by an internal committee at MHD? Did the consultant request that
their name not be printed on the cover?
This GEIR does not provide an adequate historical summary of the concerns
or the MEPA scope. The MEPA certificate on the 1997 ENF specified that the EIR
should include as appendices the ENF, the comments received (a total of eleven),
and the response to comments. None of these three elements were included in
this GEIR. Such disregard for the public comment process undermines the
credibility of both the MEPA process and the Mass Highway Department. The
GEIR should be found inadequate.
HISTORY OF SALT USE AND EIRS
The rapid expansion in salt use appears to have occurred during the decade
1955 to 1965, and in the early 1970s there was a popular rebellion against salt
use which caused three communities (Concord, Burlington and Woburn) to cease
all salt usage for at least two winters. In 1974 Mass DPW prepared a Snow and
Ice Draft EIR which was judged inadequate -by MEPA, with the result that a Road
Salt Task Force was formed under the auspices of the Environmental Unit at
MDPW. After numerous meetings in the 1987-1990 period the Task Force was
disbanded by EOEA in 1997. In the 1970s and early 1980s I participated in the
September 22, 2006
Page 2
Task Force as the EOENMEPA represented, and then was appointed to the Task
Force as a citizen member in 1986 by the Secretary of Environmental Affairs and
continued as a member until the Task Force was disbanded in 1997. The scope
for the new GEIR was issued in September 1997 and stated that EOEA expected
this EIR to be available for review by the end of 1998. The current 2006
submission shows that it has taken nine years for the state highway department
to respond to the MEPA scope.
The sequence of EIR activity on Snow & Ice issues appears to be an initial
Draft EIR in 1974, which was found inadequate and resulted in the formation of
the Road Salt task Force, followed by a new Draft in 1976, a Final in 1978, and
updated Draft in 1989, and Final in 1995. The next submission was this GEIR
dated May 2006.
ISSUES OF CONCERN
There are numerous issues relating to the effects of road salt and the ensuing
analysis in an erR. Some of them are Drinking Water and Health .... Effects on
vegetation ... Corrosion of highway structures ... Corrosion of vehicles .... Effects
on highway safety .... Economic Implications .... Cost-Benefit evaluation .... and
Alternate treatment methods and chemicals. I will begin with safety because it is
the stated purpose of the program in Legislation, and deal briefly with some of the
others.
SAFETY ISSUES
The MHD
Maintenan<~e
Manual Chapter 5 provides definitions and laws
relating to program purpose which stress the goal of keeping the highway system
"reasonably safe." The primary mandate for the snow and ice control program
¥.-'S. {:< ­
comes from M.G.L. Chapter 81, Section 19 authorizing and directing the highway
010·
department to keep state highways "sufficiently clear of ice and snow to be reasonably
safe for traveL" Neither the Manual nor the GEIR provides a clear explanation of what
"reasonably safe" means.
,
~"
;~_-
•• ____ " .
~C"
___
c_.
September 22, 2006
Page 3 According to Chapter 5, the objective of the program is "to treat or remove ice and
snow to produce or maintain a roadway surface that will allow the motorist's tires to
remain in contact with the road." [App. B : Chapter 5, p. 1] The department's
standard of maintenance makes no direct reference to safety: "The policy adopted by
MassHighway is to maintain the entire width of paved roadways and shoulders of all
roads .... cleared of snow and free of ice as far as reasonable expenditure of funds will
permit." [Id. p. 2]
Such a standard raises questions whether "bare pavement" is the
goal and whether there should be "preemptive salting" whereby dry roads are salted in
anticipation of a storm.
I
i
All references in the GEIR to convenience, time saving and economic values may
be politically correct, but they do not describe the actual purpose specified in the
Legislation. The legislation was amended by Chap 187 of the Acts of 1933, when there
was virtually no salt use on roads and all activities were related to plowing. Has the
MHD definition of "reasonably safe" changed from the all-plowing concept of the
1930s, and if so, in what way?
In all of my research, I could find no reports covering the period 1955·1970
I
which dealt with the issue of the effects of roadsalting and safety. If indeed road
, salt improved safety. surely there would be numerous studies from that decade
I
when salting went from virtually zero to a full-blown program in most Northern
states. Surely, if there were a safety connection, the highway departments and
I the Salt Institute would have prominently reported them and demonstrated the
!
relevance of road salt to safety. Instead, there are no such reports --, a total
i
vacuum, which suggests that there was no proof of the safety virtues of salting in
I
In 1971 Carolyn Whittle, a Newton housewife, wrote a paper called "The Case
the 1950s and 1960s. Ii Against the Use of Highway Deicing Salts for Snow and Ice Control in Newton."
The paper was 28 pages long and received considerable local publicity, as well as
coverage in Newsweek magazine. Her initiative was primarily on environmental
grounds and made little if any reference to safety. However, her ideas had much
to do with Concord, Burlington and Woburn all suspending their salting programs
in the early 1970s, thus providing a research test site to evaluate the effects of
September 22, 2006
Page 4
r-.-.-------.---..----.·---..·. -'_'_'. -..
I
l
l
I
I
j
-.-.-.-'"-~
..-.---.-.----..- -.. _.....-......._-.. _...__.. _......__......._-_... '-".'-""
-.-~-.,.-
..--...--..--.--, salt vs. no salt on safety. The state highway department's own data and studies
showed that a no-salt policy resulted in an increase in fender-bender accidents
but a reduction in injury accidents. The conclusion was that removing salt did not
represent a safety hazard, so by implication using salt does not result in a safety
, benefit.
The 1976 Draft EIR on pages 17-21 reported similar experiences with salt
cutbacks in many communities showed no significant connection between salt and
'
safety. This EIR did not make any claim of a salt-safety connection. The 1978
Final ErR also made no safety claims but defmed the problem somewhat
differently: "This benefit measures the motorist sense of security from accidents
on roadways free of ice and snow and properly sanded. Empirical data is not
available to quantify."
i
kSQ.­
Several EPA reports, including one prepared by Don Murray of Abt Associates
also were critical of the use of salt (1971-1976). Murray found inconsistency in
0'2. (CoV\-+.,"j
of Salt to Deice Highways," which claimed extensive benefits for salting as listed
I on page 86 of the GEIR. The Brenner study claimed only that accidents went up
I
on winter roads or under snowy conditions, not that salting helped. It concluded:
"the overall pattern of results convinces us that large numbers of accidents are
prevented by expediting snow and ice removal. The alternative is completely
unacceptable to us, that is, that there would be fewer accidents if snow and ice
conditions were allowed to run their course, or if salt was not used to reduce the
time duration of these risks," (p. 66). This statement is at least a statement of
obvious bias.
The best explanation I can fmd for the lack of any data showing a clear
correlation of salting with safety is that under no-salt conditions cars drive more
slowly on admittedly more slippery roads, so that a few more fender-benders may
occur. But the lower speeds mean that injuries are slightly less. I remember
discussing these results with a top-notch state highway traffic engineer, the late
Ed Fitzgerald, who told me of the results of his data analyses and his frustration
at receiving criticism from his superiors and in particular from maintenance
September 22. 2006
Page 5
r--------.-.----------..- ..------..-----..-----.--...---------.. _-.-._-..----..-----------------.----..----..-..-_.-._-_.
I
i
engineers. "That's what the data said," he said in exasperation. I saw evidence
!
I of the bureaucratic bias in the late 1970s when during a Salt task Force meeting
I Iinformed the state Snow & Ice Engineer about the safety studies showing no
connection between salting and safe1:}j and his response was to stare straight
ahead and repeat "It's gotta be, it's gotta be."
The March 1989 Draft GEIR by Normandeau concluded a literature review
that "accidents are more frequent but less severe during winter storm driving
I
conditions. However, neither the literature nor two local Massachusetts studies
has established the relationship between snow and ice control and traffic safety
sufficient to characterize the net effect of MDPW deiCing chemical use on traffic
safety. (p. 4·12) Nevertheless the Draft GEIR sought to create a logic for
II
claiming safety be constructing a model with numerous assumptions about icy
roads, and assuming lower accident rates on non-ky roads. In effect, the analysts
were assuming the very results they wanted to prove, so they concluded that
there was a net safety benefit of $138 to $208 million from the use of road salt.
The analysis is not COllvinCing and is not based on data assessment.
The Draft Final GEIR of February 1992 reached a similar conclusion, claiming
, "a review of the relevant literature indicates that researchers have been unable to
j
establish an empirical relationship between Winter maintenance and traffic
safety... [while] the literature suggests that accident frequencies increase when
roads become ice or snow covered ... [and] the literature suggests that accident
severity is lower on snow-covered pavement as compared with slush, wet or dry
i
conditions." The report quotes from Terry's 1974 report on the legislative salt
study commission that "available evidence neither proves nor disproves a clear
i
cause and effect relationship between salt and traffic accidents. It also provides
II
a glimpse of the future by reporting on a German study by H. Hanke (undated,
with no sponsor indicated) claiming that snowy roads had a accident rate six
times higher than roads after salt spreading. This result is extraordinary and out
of line with almost all other studies.
The current GEIR on pages 85-89 represents an extremely retrogressive step
in safety analysis. Four sources of data are identified -- all of them funded by the
Salt Institute. In addition, there is a reference to the Salt & Highway Deicing
Newsletter which I presume is an industry publication. There are no other
Page 6
September 22, 2006
sources identified and no indication that in the past the literature showed mixed
conclusions with no evident connection between salt and safety. There is the
1976 TISA study funded by the Salt Institute, a press release (I) from the Salt
Institute, a Standard & Poor's study commissioned by the Salt Institute, and a
Marquette University Department of Civil and Environmental Engineering Study,
also commissioned by the Salt Institute.
The Marquette study reported no-salt accident rates seven to nine times
higher than the salt-case. Such dramatic contrasts with prior data should have
warranted comparative comment from Mass Highway but instead there was
silence and only the presentation of the four pro-Salt Institute items. This form of
analysis in a public document is totally unacceptable and lacking in professional
credibility. It opens Mass Highway up to charges that the results of the original
study were rigged, and that both the Department and the Salt Institute were
exercising their inclinations to believe that "It's gotta be" when it comes to salting
and safety.
I am not opposed to including reports and positions by the Salt Institute, and
indeed I welcomed their participation in the Salt Task Force. My problem is for
the state Highway Department enthusiastically adopting Salt Institute positions,
policies and studies while ignoring the existence of any contrary evidence. For
me it is the equivalent of the Federal Government cozying up to the Tobacco
companies and their Tobacco Institute. The problem is not necessary one of ''junk
science," but intentionally biased "spin" and politicized science, with the results
taken as gospel by a public agency.
There is one point of ready agreement which does appear from some of the
experimental studies done by Mass Highway along various sections of roadway.
i Almost all experiments showed an increase in accidents, and one contributing
factor could be that if there is uneven road treatment. higher accidents are likely
to occur. For example, passing from an area of "bare pavement" to snowy or icy
pavement at speed is an obvious safety problem. No matter what the treatment
policy, uniformity of road conditions should be the goal. It would be unwise policy
to allow some road sections to have bare pavement while immediately nearby
there could be ice, snow or slush. Similar conditions occur for transitions
between higher speed new roads and lower speed older roads, where there is too
September 22, 2006
Page 7 abrupt a transition between road geometries and drivers can be caught unawares.
The evidence suggests that drivers can adjust their driving to whatever conditions
they encounter (even blizzard conditions) if they have sufficient warning and time
to adjust.
i
~---.~
DRINKING WATER AND HEALTH
During the 1970s and 1980s, there were major concerns about the health
implications of sodium in drinking water, especially for those suffering from high
blood pressure. During this period the DEQE (predecessor to DEP) under
director of Water Supply George Coogan promulgated a sodium limit of 20 ppm in
I drinking water, which when exceeded required communities to notify residents of
! the exceedance. The City of Cambridge Water Board in its notices of 1985 and
1987 responded that although Cambridge levels were 40-43 ppm this exceedance
"does not represent any health hazard."
Cambridge has since reduced its 20 ppm sodium load from water treatment
by the substitution of calcium and potassium chemicals. In 1988 the EPA under
the Reagan Administration removed sodium entirely from its list of contaminants
in drinking water, in effect saying that sodium represents no threat whatsoever.
At the Federal level, sodium went from being a major threat to being no threat at
all. The state followed thew same strategy and eliminated any limits on sodium in
1993.
!
i
At the Federal level in 2003, EPA returned the sodium standard to
! effectiveness, by recommending a limit of 30 to 60 ppm. Under the
circumstances of poor documentation and vacillating standards, any state
highway department could feel legitimately confused about the sodium situation
and what level of concern should be brought to health problems. The removal of
the 20 ppm limit at the state and Federal levels may have been a result of
lobbying by drinking water suppliers, than by highway departments -- because so
many treatment plants had been using sodium··based water treatment chemicals
in excess of 20 ppm. Currently, Massachusetts has no formal standard except for
chlorides, that of 270 ppm.
September' 22, 2006
PageS
EFFECTS ON VEGETATION
The text materials on pages 61-67 provide a concise summary of the effects of
salt on vegetation, but the summary of each item may be all too brief. I would
note that the references are all in the period 1985 to 2001, which suggests that
this was Normandeau's research, and it has not been updated since 2001.
The most recent reference comes from 2004, Table 4.1-1 which is a listing of
the relative salt tolerance of trees, as listed on the web site of the Salt Institute.
Again, note the role of the Salt Institute and its lobbying affiliation with the road
salting industry. Rather than refer to "salt sensitivity" the Salt Institute uses
"Salt Tolerance" and instead of "Low Salt tolerance" they use "Reduced Salt
Tolerance." Mass Highway must not present Salt Institute material as the
unvarnished truth. Interest group activity should be welcomed just as other
public comments are, but the credibility of the Salt Institute as an expert source
is severely diminished by their business interest in the use of road salt.
Over the years we have relatively little information on the effects of road salt
on health. The 20 ppm limit came from an American Heart Association advisory
based on hypertensive patients and the intake of drinking water. More intriguing
are the medical descriptions of the nerve mechanisms in both animals and plants
which are based on the concept of the "sodium pump," whereby the balance
between sodium and potassium in a chloride medium provides the basis for the
transmission of nerve impulses. It is sodium which provides for nerve stimulation
and potaSSium which produces nerve relaxation. I could find no discussion of
these issues in the EIR and I never heard anyone discuss the topic during the
Task Force meetings.
Another industry representative, United Stated Gypsum, has proposed to
supplement salt use with another chemical: Gypsum or calcium sulfate.
Limestone or calcium carbonate was not as successful at reducing sodium levels
in soil. The company claims that gypsum "breaks up compacted clay soil so roots
can breathe, and greatly improves drainage." Potassium-based chemicals could
also reduce sodium damage or "brownout" effects on vegetation, and the issue
warrants consideration -- both for grass kill adjacent to roads and impacts on tree
roots. Potassium chloride could be used directly in a mix with sodium chloride.
September 22, 2006
Page 9
COST BENEFIT ANALYSIS
The 1978 Final EIR made a significant effort to provide a comprehensive cost­
benefit analysis, including a listing of all factors which could not be quantified.
The new GEIR discusses many factors such as corrosion damage to bridges and
vehicles without providing any information which would allow an assessment of
the magnitude of the impacts. For energy savings, the GEIR again quotes the Salt
Institute as its source. There is no justification in the literature search
demonstrating comprehensively that "The impacts of salt application on flora,
fauna, agriculture, tourism, sugar maples, cranberry bogs, and recreation is not
significant in Massachusetts." (page 93)
Something appears strange in the assessment of lane miles on page vii. For
I there to be an increase in lane miles from 7,060 lane miles in 1976 to 13,286 lane·
I
miles in 2006 implies an increase in the state highway system of 6,226 lane-miles
I
or the equivalent of more than 1,500 miles of four lane highway. I have difficulty
I
years. I recall seeming data showing new expressway construction of 25 miles a
I believing that that level of highway construction was achieved during the past 30
!I year in the Commonwealth during the 1950s and 20 miles a year during the
I
period 1960 to 1966, after which new expressway work dropped to almost zero
1
for a few years, except for J.·190 and I-391. I estimate this expressway program
represented a total of 2,000·lane miles over two decades, so I wonder whether the
6,226 new lane-mile figure is credible, given that much of the 1970s and 1980s
was a period of minimal new highway construction.
Dlere remains a need to provide a comprehensive cost-benefit analysis of
road salting. I suggest that the task be assigned to Greg Prendergast for
I
I
completion.
I
j
!
i
!
=====================================
-'1\
/ Ij""
l
September 22, 2006
Page 10
CONCLUSIONS
This GEIR is a classic example that the assessment of environmental impacts
cannot be performed by the proponent of a project. Public comments are ignored,
supporting data from biased lobbying sources are quoted as fact in a public
agency document, and any derogatory information is downplayed or in true 1984
style dropped down the memory hole. The only way that MEPA can work is if
there is openness and responsiveness, and this GEIR is a poor example of these
features.
Sincerely,
Stephen H. Kaiser, PhD
Member, Road Salt Task Force, 1985-1996
I
i
I
cc. Greg Prendergast, MHD Environmental
Nancy Baker. DEP MEPA Reviewer
Salt Institute
t._~~, ..•. ,,,,,~ .... ~.,~.,,,"'<C~~ ."
"'.~e·~_,. .. _~,.".'.~ ·~._~r'."_ "'~~'_"'_"""' __" __ "~'_" ....~~__~,~
• ....
_ .•.. ~"c ~,,~~" .~ .._, _•. ",._.",.' ..... _~" ____ •. ,_~~ •• _"_.~ .•_ •. ","-.~._._," ""'•. ""'~~ ~_,-ec_ .".. ,-c ,.,,~_~ ..•. _•.• _, ••. ~ , _.".~"
,~.
•
MassDOT Responses to Comments Submitted on the 2006 EOEA Certificate Related to the Snow and Ice Generic Environmental Impact
Report Comments Received from 16 Different Agencies and Individuals
STATE AGENCIES
EOEA: ENF – December 1, 2006; EOEA # 11202
Comment
Category
No.
ESPR Work
Scope
EOEA-01
GIS Mapping
EOEA-02
General
EOEA-03
Operations
EOEA-04
Reporting
EOEA-05
MassDOT Response
Comment
Coordinate and meet with MassDEP, DCR and NHESP regarding the
proposed work plan and address environmental concerns/issues raised
during the ENF comment process.
The ESPR should include updated GIS Mapping of state-maintained
roadways, highway Districts, salt storage locations, reduced salt zone areas,
municipal Zone II͛s, surface water Supply watersheds, ORW͛s, !E͛s, and
RWIS locations. Also, Priority Habitat areas and 303(d) listed impaired water
bodies.
Consult with, document participation in the ESPR process and provide Snow
and Ice Control information with regard to other agencies including MTA,
MassPort, MBTA and DCR.
Identify/Discuss Snow and Ice Removal Policies for sidewalks and crosswalks
along MassHighway (MHD) maintained roads.
MassDOT has met with representatives from the MassDEP Drinking Water Program and the ACEC Program
Coordinator during the development of the ESPR Work Plan. MassDOT anticipates meeting with MassDEP,
the ACEC Program Coordinator, NHESP, DCR and other state agencies in finalizing the 2012 Snow & Ice ESPR.
GIS mapping of the MassDOT road network, reduced salt zones and salt storage sheds has been updated and
included in the Draft ESPR.
The former Turnpike Authority is now part of the MassDOT Highway Division. MassDOT has contacted the
MBTA and DCR to compile Snow and Ice Control information and received some information from the MBTA.
Massport͛s deicing operations are reported in their own ESPR/
MassDOT͛s responsibilities for snow and ice control are confined to the roadway area from curb to curb/
Sidewalks are maintained by municipalities even along the MassDOT maintained roadways. Cross walks across
roadways are cleared when the roadways are cleared. The only location where MassDOT may remove snow
from sidewalks is on movable bridges in order to reduce the weight on the moveable elements.
MassDOT will seek to develop an annual report process following the completion of the ESPR to update
MassDEP and other agencies annually on recently deployed or planned operational changes in areas of
concern. It is anticipated that this would be a relatively brief report on a select list of items which can be
discussed and finalized as part of the completion of the ESPR.
Investigate a possible Annual Reporting procedure that would update state
and perhaps local agencies on any new policy or operational changes to
reduce salt usage, improve efficiency and/or protect environmental
resources. Include anticipated benefits and cost information.
Mass DEP Comments – Philip Weinberg, Assist. Commissioner, Oct. 11, 2006 letter
Agency
Coordination
Application
Rate –Overall
Salt Usage
DEP-01
DEP-02
[abbrev.] MassDEP recommends MHD engage in more frequent and direct
communication with MassDEP as an alternative or supplement to the GEIR
process to exchange information on the various environmental concerns.
MHD applies more salt per lane mile annually than other state highway
agencies in New England states and New York (Rhode Island did not provide
data). See Table 2.6-2 on page 32 of the 2006 GEIR comparing MHD͛s salt
usage with other New England states and New York state. Information is
provided in the GEIR that suggests that MHD͛s *annual} application of salt
has increased in recent years. A related issue is that although MHD limits
the spreaders on trucks to a certain salt/sand application rate, the trucks
reportedly make multiple passes on a roadway segment until the desired
road clearing is provided. This practice is not discussed or addressed in the
GEIR and is contrary to the purpose of adhering to a salt/sand application
rate/ While MHD indicates that M!͛s higher salt per lane mile usage is ͞to
achieve a high level of service standard͟, the GEIR does not analyze the
benefits of this service standard in terms of the environmental detriment.
MHD should explore measures to reduce the amount of salt per lane mile to
bring salting rates more in line with those of other States.
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
See Response to Comment above regarding possible Annual updates. With regard to the more
comprehensive updates on the Snow and Ice ontrol Program, associated with future ESPR͛s MassDOT would
plan on updates being prepared every 5 years following the 2012 ESPR.
As discussed in the 2012 ESPR, as a result of numerous efficiency measures and equipment upgrades
implemented over the last 5 years, MassDOT͛s statewide salt usage in the 2010/11 winter was approximately
23 percent or nearly 170,000 tons lower than that used in previous years with similar winter severity. The
various efficiency measures are described in Chapter 3 of the 2012 ESPR. This reduction in salt usage is even
more notable given the fact that MassDOT͛s road network has increased by approximately 20 % with the
inclusion of the Mass Turnpike and associated ramps and other road widening projects.
MassDOT͛s application rate of 240 lbs per lane mile is similar to those used in other New England states.
There is a difference in the rate applied for each application and the cumulative total over a given season. The
number of applications for a given storm or season depends on a wide variety of weather and non-weather
related factors. One reason MassDOT may have more applications per storm or per season is that most
MassDOT roadways require around the clock maintenance for the entire storm duration. In contrast to some
rural areas of northern NE states, deicing operations at times are suspended or reduced during the overnight
hours resulting in fewer overall applications. This is not a viable option for MassDOT roads that carry traffic
volumes in excess of 100,000 vehicles per day. One accident on these highly traveled roads can have a serious
impact on travel times, lost work time, delayed deliveries, increased accident potential, etc. as compared to
less traveled rural roadways. MassDOT͛s ͞level of service͟ policy is to provide reasonably safe road surface
conditions to allow motorists to maintain vehicle control at reduced speeds during inclement weather.
MassDOT does not expect to have roadway surfaces free of snow during winter events but strives to return to
clear roadways as soon as practical once the storm has ended.
1
2/27/2012
Category
Comment
No.
DEP-03
Comment
MassDOT Response
The GEIR should affirm MHD͛s commitment to comply with MassDEP͛s salt
storage and snow disposal polices included in Deicing Chemical (Road Salt)
Storage Guidance – Guideline No. DWSG97-1 and Snow Disposal Guidance –
Guideline No. BRPG01-01. located at www.mass.gov/dep/water/laws
BMPs
Drinking
Water
DEP-04
PWS
Sodium levels
in Zone II’s
DEP-05
MassDEP is concerned with MHD͛s Aug 2006 policy change for establishing
new and maintaining existing reduced salt zones (RSZs) requiring PWS to
supply three (3) years of monthly wq data for both raw and treated water.
Raw water testing poses an added burden to PWS͛s because raw water
testing is not required as part of the annual reporting to MassDEP. More
importantly, the added burden should not be on PWS to show that an
existing RSZ should be maintained. MHD should identify how many RSZs
may be eliminated due to this policy change, and reconsider its revised
approach based on DEP͛s concerns and those of other commenter͛s/
MassHighway has not adequately supported its conclusion on pg 59 that
there is a weak correlation between sodium levels in Zone II area wells since
only 10% of the tested Zone II wells within 0.5 mile of MHD roadways show
Na levels above 60 mg/L. The GEIR needs to further analyze the correlation
between sodium levels and MHD operations and establish a recommended
sodium threshold where salt remediation measures would be initiated.
MassDEP maintains a DW guideline of 20 mg/L.
Sodium
adsorption
with soil
DEP-06
MassDOT͛s salt storage policies are consistent with Mass DEP͛s guidelines where all salt piles and stock piles
of sand mixed with salt are located under cover/ MassDOT͛s Policy for deicing chemical storage is described
in its Deicing Chemical SOP-ENV-01-08-1-000 ͞Management of Sand and Deicing hemicals at MassDOT
Facilities. In District 6, the overhead cover for salt piles at three locations consists of bridge decks. MassDOT
does not engage in snow dumping activities and continues to support DEP͛s Snow Disposal Guidance.
The August 2006 letters sent to PWS͛ within established RSZs were not the result of a policy change but
instead were sent to remind PWS of MassDOT͛s policy that submittal of water quality data is essential to
monitor the effectiveness of RSZs and evaluate whether additional operational changes are needed. This
provision for requiring the submittal water quality has been in existence for nearly two decades. However,
out of fifty- three established RSZs, only a handful of PWS provide water quality data to MassDOT on a regular
basis. MassDOT periodically sends out reminder letters to explain the importance of this data. Since
MassDOT incurs considerable costs to maintain a RSZ, it seems reasonable to request PWS͛ to submit water
quality data of both raw and treated water to be able to assess the potential benefits and long-term
effectiveness of RSZs throughout the state.
Chapter 2 of the DRAFT ESPR provides an updated review of the reported sodium data through 2010. The
data indicates that more than 50 and 90 percent of the municipal water supplies with at least one water
source within 0.5 mile of a MassDOT maintained roadway have average sodium levels that are below 20 and
60 mg/l, respectively. The 60 mg/l level represents the upper limit of the EPA recommended drinking water
guideline for people on doctor-prescribed sodium restricted diets. MassDEP still maintains a lower health
advisory level of 20 mg/L, which is geared toward people with severely –restricted sodium diets of no more
than 500 mg per day. The results suggest that MassDOT͛s S&I ontrol practices are not causing adverse
impacts to a large majority of the municipal water supplies across the state. The results also indicate that
close proximity to a MassDOT roadway (i.e., within a 0.5 mile) is not a strong indicator as to which PWS͛ may
have elevated sodium levels. Elevated sodium levels can be due to other sources within the Zone II area
including the application and storage of road salt used on parking lots or municipal roads. In situations where
other sources have a major impact on sodium levels, any remedial action imposed by MassDOT is likely to
have little change in the sodium levels and only adds unnecessary costs and delays to mitigating the sodium
levels. MassDOT will continue to work with PWS͛ on a case by case basis and will take appropriate actions
where data clearly indicates that the elevated levels are the result of MassDOT deicing or storage practices.
So noted, the conclusions of the previous GEIR and the current Draft ESPR were not predicated on the
assumption that sodium adsorbs to soil particles.
Operations –
BMPs ; Cost
of Pre-mix
DEP-07
Reduced Salt
Zone
Effectiveness
DEP-08
Salt Storage
/ Snow
Removal
MassDEP disagrees with MHD͛s statement in the 2006 GEIR͛s Executive
Summary that Na will tend to adsorb to soil particles and accumulate in soil.
The conclusions contained in the GEIR should not be predicated on the
assumption that Na is adsorbed on to soil particles and therefore, not
expected to migrate with surface or ground water.
MassDEP believes that MHD may have overstated the cost of using Pre-mix
when the actual application is a 50:50 mix of Pre-mix and sand resulting in a
blended material of $44.25 per ton. The application of this sand/CaCl
mixture would place only 40% as much Na into environment in comparison
to straight rock salt. The environmental benefit of using Pre-mix in PWS and
other critical areas appears worth the added cost.
The GEIR indicates most of the RSZs were established in the 1980s. The GEIR
should provide a summary of the successes of the Complaints Program and
RSZ Program including how many complaints and requests for RSZs on
annual basis over last 20 years or so. The GEIR should describe the nature
and history of any public outreach on the availability of these Programs
including whether such efforts are part of MHD͛s NOI and !nnual Rpt for
MS4 Permit.
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
2
MassDOT utilizes a 1:1 blend of Pre-Mix and sand in most Reduced Salt Zones. Based on 2011 material cost
information, the cost of Pre-Mix is approx. $160.00 per ton and sand is at $15.00 per ton. The 1:1 blend
results in an approximate cost of $87.00 for each ton of blended mix applied, which is about 40% greater than
the cost of a ton of road salt, which is now about $60 per ton.
Chapter 2 of the Draft ESPR provides an overview of MassDOT͛s Salt Remediation Program and its successes
in reducing sodium levels in private wells following remediation. In cases where remediation measures were
implemented, more than 90 percent of the wells had a substantial reduction in sodium levels. MassDOT has
updated its web site to include various materials and instructions with regard to filing salt contamination
complaints.
2/27/2012
State Agencies (cont.)
Mass DEP Comments (cont.)
Comment
Category
No.
Sodium levels
in PWS’s
DEP-09
Sodium levels
increases vs
Annual Salt
Usage
DEP-10
Private Wells
DEP-11
Wetlands/
TMDL’s
DEP-12
Comment
MassDOT Response
MassDEP acknowledges water quality treatment chemicals (eg. Sodium
hydroxide) can add sodium to the treated water; however, MassDEP believes
these chemicals are not the primary source of sodium in several municipal
PWS reporting increased sodium levels including those in Andover,
Cambridge, Chelmsford, Dedham-Westwood, Salisbury, Weymouth and
Wilmington.
MassDOT has coordinated with most of these communities and has conducted field investigations in most
locations including Andover, Cambridge, Chelmsford, Dedham-Westwood, and Wilmington to try to
quantify the relative contributions of sodium from its operations. MassDOT relies on the PWS to provide
water quality data to confirm elevated levels. MassDOT will then work with the PWS to identify remedial
measures. Recent examples include completion of a new storage shed in Chelmsford to help address
sodium levels in the N Chelmsford wells as well as the proposed relocation of the Andover salt storage
shed outside the Haggetts Pond watershed. MassDOT is currently working with the Town of Wilmington
and the Dedham-Westwood WD to identify measures to increase salt use efficiencies in these Zone II
areas. MassDOT is assisting in monitoring sodium levels in CWD water supply areas and periodically meets
with CWD representatives. MassDOT has not received any water quality data from the Town of Salisbury.
MHD should conduct a systematic statewide review of Na Levels near
highways to determine if similar trends exist statewide.
With respect to a statewide review of sodium levels, see Response to Comment to DEP-05 and the analysis
of reported sodium data presented in Chapter 2.0.
This review should quantify the total miles within Zone II͛s, and percentage of
those miles that are in designated RSZ͛s, the extent of PWSs in and outside
RSZs that are experiencing higher Na levels and trending toward or exceeding
the DW guideline of 20 mg/L and develop a remedial approach for PWS͛
having Na levels above the MassDEP DW Health guideline of 20 mg/l.
MassDEP would like to understand whether the pattern of increased sodium
levels in public water supplies is related to changes in MHD͛s road salting
practices, such as increases in road salt applications by private contractors or
by switching to pure salt from sand/salt mixes. Table 2.2-4 in the 2006 GEIR
suggests that the tons of salt applied per inch of snow has increased since
FY93 despite the application rate being reduced from 300 to 240 lbs per ln-mi
in 1995. The GEIR should further analyze these questions and report on the
results and propose recommendations for future implementation steps.
MassDEP believes the GEIR has not adequately addressed the issues related
to MHD͛s S & I control practices on private wells such as those in the Town of
Boxford.
Most of the MassDOT roadway segments in these Zone II areas are already designated Reduced Salt Zones
(RSZs). MassDOT has 53 RSZs throughout the state. In many of the more urbanized areas, MassDOT may
not be the largest contributor of road salt in the Zone II areas, particularly in areas with large amounts of
commercial parking lots. Recent anecdotal evidence reporting in New Hampshire suggests that the amount
of road salt usage in parking lots could be similar, if not greater, than that used on state roadways.
As described in Response to Comment DEP-02 above, the annual salt usage in the most winter of 2010/11
represents a 23 percent reduction in salt usage compared to previous years with similar winter severity.
This reduction occurred despite an estimated 20 percent increase in roadway miles being maintained by
MassDOT and the 2010/11 winter being one of the most severe winters in the last 10 years. The reduction
is attributed to numerous implementation measures that were incorporated into the operations over the
last 5 years since 2006. MassDOT plans to continue to fully implement these measures statewide as well as
adopt additional measures to increase the efficiency and effectiveness of road salt usage. A number of
new recommendations have been included in the 2012 ESPR.
MassDOT has created a new Salt Remediation Program brochure and added a whole section on its website
to provide information materials about the Program. MassDOT has enlisted the services of the UMASS
Engineering Dept to conduct extensive field investigations in response to salt contamination complaints.
MassDOT has provided additional training to S&I personnel and has invested in numerous measures to
increase its salt use efficiencies. With respect to the Town of Boxford, MassDOT will launch an extensive
hydrogeological study In 2012 to assess the potential effects of its operations on the local groundwater
quality. The study will be conducted with input from representatives of the Town of Boxford.
MassDOT believes the best approach to minimizing potential impacts to the state͛s environmental
resources is through increased efficiency measures and the use of newer innovations as they become
available. MassDOT has incorporated many efficiency measures over the last five years which has lead to a
reduction in overall salt usage statewide (See Response to Comment DEP-02 above). MassDOT expects to
achieve further reductions in the future and has included a number of recommendations in the 2012 ESPR.
In addition to PWS͛s, wetlands, other water resources and other
environmental resources (e/g/ !E͛s) require protection from the impacts of
MHD͛s S&I Control Practices. As part of the GEIR, MHD needs to adopt an
alternative analysis that may be employed through their Stormwater
Handbook, MS4 Permit, Wetland Permitting process, 401 WQ Certifcate and
where TMDLs have been established, that identifies alternatives that can be
used to reduce potential impacts based on the site-specific conditions rather
than a one –size fits all approach. The GEIR should evaluate the need for
reduced salt zones adjacent to the !E͛s established around the State/
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
3
In addition, MassDOT has initiated an Impaired Waters Program as part of its MS4 stormwater permit to
assess its relative potential impact on impaired waters and to identify ways to reduce this impact through
stormwater BMPs (e.g., treatment basins, bioretention, etc.).
2/27/2012
State Agencies (cont.)
Mass DEP Comments (cont.)
Comment
Category
No.
Training
DEP-13
Comment
Preliminary Responses
Certain MHD practices require more training of MHD personnel and
contractors to ensure a thorough understanding of the measures being
employed to reduce salt use. Reducing the number of repeat applications in
reduced salt zones is one example. Greater use of snow fences to limit
drifting snow in critical areas should be considered as well.
GIS Mapping
DEP-14
MassDOT has significantly increased its annual training program and holds more than 15 different
training sessions across the state to train more than 750 employees that are involved in snow and ice
operations. MassDOT also conducts numerous tailgate training sessions at various locations throughout
the state that include both contractors and municipal personnel. Snow fences are used in locations
where appropriate (see Response to Comment DEP-18 below). As mentioned above, MassDOT has
invested in numerous equipment upgrades and technologies to improve the efficiency of applied deicer
materials as well as enhance its weather forecast capabilities, which have resulted in significant
reductions in salt use. (See Response to Comment DEP-02 above)
Salt Storage
DEP-15
The GEIR also needs to contain a list or graphics that identify all of the
Section 303(d) listed impaired water bodies impacted by runoff from MHD
activities, as well as an evaluation of alternatives and related
recommendations to minimize these impairments.
Although MassHighway is to be complimented for constructing many new
salt storage facilities, the GEIR should include a schedule for upgrades to the
remaining older salt storage facilities that provide incomplete protection
rain and snow and produce runoff contaminated with road salt.
Vehicle
Washing
DEP-16
Agency
Coordination/
reporting
DEP-17
Snow
Disposal GIS
Mapping
DEP-18
Recent
Research
DEP-19
The GEIR should contain measures and implementation steps to protect
adjacent water resources from runoff as it relates to washing of vehicles
used in snow and ice control operations.
The GEIR should outline a more collaborative process between MHD and
DCR in reducing salt use and protecting resources near MHD maintained
DCR Parkways. The use of snow fences was discouraged by DCR b/c of its
perceived incompatibly with Parkways. The GEIR should identify road
segments where snow fences would be beneficial as well as other protection
measures that may be needed particularly with sensitive vegetation.
The GEIR should identify appropriate snow disposal locations consistent with
MassDEP snow disposal policy. MassDEP has received complaints in the past
about DR͛s disposal of snow directly into the harles River, Muddy River,
Hull beaches, Wollaston Beach and Revere each/ MassDEP͛s snow disposal
guidance prohibits such practices except in emergencies. Snow disposal at
main yards must also be consistent with the Policy.
MHD appears to undervalue the findings of the Kampoosa Bog study
claiming that the findings were inconclusive. However, the abstract of the
Richburg et al 2001 study states- ͞High salt concentrations in groundwater
(due to the application of deicing salts on the Turnpike) and a Phragmites
australis colonies appear to be impacting native vegetation at his site.͟ The
GEIR should include relevant state-specific data including:
1. Lake Quannapowitt Study ( Doug Heath: EPA –Boston),
2. Mattson and Godfrey, 1994. Env. Mgt; Road salt in Mass streams
3. Huling and Hollocher͛s 1972, Science, Road salt contamination in
groundwater
4. Forman and Deblinger, 2000, Biology, Impacts of salting on Mass roads.
5. Various lake TMDL studies that cite sanding impacts in Worcester area.
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
4
MassDOT has launched as separate Impaired Water Program as part of its MS4 Stormwater General
Permit to identify areas where stormwater BMP retrofits can be installed to reduce the potential impact
of roadway runoff on 303(d) listed impaired water bodies.
MassDOT sheds are generally inspected on an annual basis to assess and identify needs for repair
and/or upgrades. As mentioned above, MassDOT has recently constructed a new shed in Chelmsford,
has plans for a new shed in Andover and has completed numerous facility upgrades in other storage
locations including roof extensions and door replacements to minimize exposure of stored salt to
stormwater.
MassDOT has developed standard operating procedures for vehicle washing (Vehicle Washing SOP ENV01-22-1-000) where the rinse water is collected and stored in either holding tanks or connected to a
municipal sewer system. Contractors assume responsibility to wash their own vehicles appropriately.
MassDOT utilizes snow fences where appropriate in areas where windblown snow can be an issue
including areas along DCR roadways that are now maintained by MassDOT equipment and personnel.
In addition to snow fences, MassDOT has made significant improvements in the application practices
now used on DCR roadways. MassDOT requires spreaders to have pre-wetting equipment where
previously there was no requirement for DCR equipment. MassDOT will continue to implement these
improvements along other DCR roadways as MassDOT assumes additional winter maintenance
responsibilities in the future.
MassDOT is aware of DR͛s past snow dumping practices referred to in this comment, and where
MassDOT has taken over winter maintenance responsibilities on approximately 60 % of DCR͛s roads in
the greater Boston area, these snow dumping practices have stopped. MassDOT has requested DCR to
identify their snow storage areas as a means to review compliance with MassDEP͛s snow disposal policy/
The 2012 ESPR provides a detailed summary of the Kampoosa Bog study findings, including information
from the latest Kampoosa Bog study prepared by Rhodes et. al (2008). The Richburg study noted that
the initial establishment of the Phragmites was perhaps due to the soil disturbances caused by gas
pipeline construction along the Turnpike right-of-way rather than road salt use itself. However, the
increased in salinity within the Bog attributable to road salt may have helped to create more favorable
conditions for Phragmites to spread. Prior to 2010/11. MHD had no jurisdiction or authority to alter
operations along the Turnpike as this roadway was maintained by Mass Turnpike. MassDOT plans to
assess various options that may be available to increase the efficiency of salt applications in this area.
MassDOT has conducted an updated literature search of recent environmental studies pertaining to the
impacts of road salt use. As discussed above, MassDOT believes the best approach to minimizing
impacts is to continue to adopt innovative measures to increase efficiency of deicer materials and
reduce salt use as was recently demonstrated in the 2010/11 road salt totals.
2/27/2012
State Agencies (cont.)
Comment
Category
No.
Mass DEP Comments (cont.)
OperationsBMPS
RWIS
DEP-20
OperationsTraining
DEP-21
ENV- WRSSand Impacts
DEP-22
Operations
BMPS
DEP-23
Comment
MassDOT Response
MHD has been using RWIS at 23 locations, but it is unclear as to how
effective these systems are on reducing salt applications. The GEIR
indicates that the reductions in salt usage have been substantial, but
supporting data has not been provided. The GEIR should consider how to
assess and monitor the effective use of pavement sensors, an identify goals
for highway crews that will result in tangible environmental benefits. For
example, the GEIR address whether RWIS are located in critical areas and
recommend add͛l areas for use in environmentally sensitive areas such as
Zone ! for surface waters, ORW͛s, Zone II͛s and !E͛s/
MassDEP questions whether the training program is adequate if only MHD
staff receives the training, while 90% of the road salt applications are made
by contractors. MassDEP recommends that MHD provide training to their
contractors that are geared specifically to the locations they apply
chemicals especially in Environmentally Sensitive areas.
While the GEIR (p.69) notes that road sand provides minimal road traction
and is a contaminant for receiving waters, there are no concrete
recommendations to reduce the amount of sand used in snow and ice
operations. Additionally, the GEIR should include a commitment by MHD
that when using sand, it will increase its street sweeping frequency or
effectiveness to remove more sand from the roadways. A recent USGS
study (Breault et al., 2005) conducted in New Bedford showed up to 5
times more sand removed with the newer high efficiency vacuum
sweepers. This data should be included in the GEIR.
MHD should continue and expand its efforts to develop and use innovative
deicing practices to minimize environmental impacts. For example, prewetting roadways (i.e., brine) appears to show some promise in reducing
NaCl use, however, the pre-wetting agent also included chloride.
MassDOT utilizes several tools to assist in decision making process including RWIS. The combination of
RWIS data, detailed weather forecast information, and mobile pavement temperature sensors have
helped MassDOT personnel to decide when deicing applications are necessary, especially the initial
application. The new technology helps to reduce the number of applications that may have been done
given borderline or expected conditions that in the end were not necessary given the enhanced data
available. Perhaps the biggest savings related to reduced labor hours when potential equipment call-outs
are avoided or delayed based on the data provided by these tools. During major storm events when road
conditions are deteriorating rapidly and the decision for treatment applications are more obvious, the
potential benefits gained by these tools are more limited.
MassDOT has been using tailgate training sessions as a means to train the privatized forces in
environmentally sensitive areas. MassDOT has received excellent feedback on this approach and has
expanded the training from three locations in the first year to 15 different locations scheduled last year.
In the near future, MassDOT intends to utilize and require participation in web based training sessions as
these tools become available for both hired contractors and MassDOT personnel.
MassDOT intends to use less and less sand since it provides little benefit in preventing ice build-up on
roadways. Sand has been primarily used in RSZs to replace road salt. MassDOT plans to utilize innovative
technologies such as computerized closed–loop spreaders and perhaps friction meters to increase
efficiencies and use less salt and sand in RSZs. MassDOT does conduct street sweeping more frequently in
areas where sand is used.
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
5
MassDOT has greatly expanded its efforts to utilize innovative approaches to minimize impacts especially
with the use of liquid deicers for anti-icing and pre-wetting purposes. The current Draft ESPR provides a
detailed description of the various measures used to increase salt use efficiency, which have already
resulted in substantial salt reductions. See Response to Comment DEP-02 above.
2/27/2012
State Agencies (cont.)
Comment
Category
No.
Comment
MA Riverways Program – Cindy Delpapa – Stream Ecologist
MassDOT Response
Sand impacts
RWP-01
Planning –
Public Outreach
RWP-02
OperationsSand Storage
Operations –
Sand storage
Operations
BMPs
RWP-03
Operations
BMPs
RWP-06
Promote the use of Anti-icing techniques discussed on pg. 38 on GEIR – not just
pre-wetting
OperationsTraining
RWP-07
Conduct more training for all personnel and contractors involved S&I control –
not just reduced salt zones.
Field Monitoring
RWP-08
Recommends more field data collection – monitoring of Na & Cl in streams –
mentions D. Heath͛s of EP! comment that he disagrees with the statement of
͞No Significant Impacts0 ͞on pg/ 93 of GEIR/
Planning
/Permitting
RWP-09
Add and improve stormwater treatment BMPs with road improvements &
upgrades
Operations
BMPs
Alternative
Deicers
Pavement
Alternatives
RWP-10
Provide detailed cost & benefit comparisons of different MP͛s – Altern. Deicers
–pre-mix, etc.
How do other states deal with toxicity issue of MgCL – how significant is the
issue compared to benefits
Research the benefits/feasibility of porous asphalt or other pavement
alternatives
RWP-04
RWP-05
RWP-11
RWP-12
Evaluate potential impacts of total phosphorus loading as a by-product of sand
use – Eutrophication in ponds (Refer to recent TMDL studies for ponds in central
Mass.)
MHD might want to consider public education/outreach to general public and
local DPW staff about the ineffectiveness of sand, its total cost of use (purchase,
application and cleanup) and also the environmental issues.
We hope MHD make it a priority to cover all uncovered sand piles mixed with
salt
Assess proximity and relocate any sand/salt piles adjacent to rivers. (Ex. Lowell
Storage facility next to River Meadow Brook).
Expand RWIS system and allow municipal DPW͛s to have access to data
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
6
MassDOT agrees that winter sand can be a source of phosphorus and plans to use less sand as it
provides minimal benefit for snow and ice operations. See Response to Comment DEP-23 above.
MassDOT believes that this may be worthwhile but a public education campaign focusing on the
limitations and impacts of sand use is likely to be more effective if done with MassDEP and other
interested agencies included. The training provided by the Baystate Roads could be integrated.
MassDOT has made this a priority and revised its Snow and Ice Control SOP to require all deicing
chemicals including sand piles mixed with salt to be stored under cover when not in use.
This sand pile has been evaluated by District 4 personnel and has been moved further away from the
Brook and has been further contained by a new concrete block wall.
Being a proprietary system, access to the RWIS data requires the purchase of additional licenses for
each user. Through the Baystate Roads Program, MassDOT has provided instructions on obtaining and
purchasing licenses to access data.
MassDOT has greatly increased its equipment availability to conduct pretreatment or anti-icing
applications using liquid brine solutions just prior to storm events. In the last two years, the number of
tanker trucks available has doubled from approximately 30 to over 60 trucks for pretreatment
applications. This increase has largely been due to changes in the contractor compensation rates for
contractors that have equipment capable of pre-treatment applications. In addition, each District has
increased its storage capacity for liquid solutions for anti-icing. Pretreatment applications have been
highly effective in preventing buildup of ͞hardpack͟ where snow and ice bonds to the pavement,
especially on the heavily traveled major roadways.
MassDOT personnel are required to attend a full day S&I training each year. MassDOT has also
instituted tailgate training sessions in key areas where private contractors are invited as well. More
and more contractors have been participating in these training sessions. In the future, MassDOT plans
to incorporate a Computer Based Training Program currently being developed by AASHTO as a training
tool for contractors, at which they can complete at their own convenience.
MassDOT through its ISA with the UMASS Engineering Dept has conducted numerous field
investigations in many locations as it relates to the Salt Remediation Program. In terms of an overall,
broad-based, regional or statewide monitoring study, MassDOT believes that other state agencies such
as MassDEP or federal agencies such as or USGS or EPA are better suited for these types of studies as
they are more aligned with their mission and purpose and are likely to have the appropriate
equipment, expertise and experience to conduct in-depth monitoring in streams or lakes. The study
results could be included in future annual reports or ESPR updates.
As discussed earlier, MassDOT is currently evaluating key locations where stormwater BMP retrofits
may be most appropriate as part of its Impaired Waters Program. A similar evaluation is conducted
with all proposed major roadway improvements and upgrades.
Chapter 2 of the ESPR contains an update on the cost and benefits related to the various alternative
deicers and other technologies.
The previously reported MgCL toxicity issue was related to personnel exposure to fugitive dust
associated with handling the solid or granular form of material and not the liquid brine solutions.
Chapter 3 of the Draft ESPR includes a discussion of the potential benefits and limitations of porous
asphalt or open graded friction courses as it relates to snow and ice operations.
2/27/2012
State Agencies (cont.)
Comment
Category
Comment
No.
MA Division of Fisheries & Wildlife (MDFW) – Comment letter dated September 21, 2006
MassDOT Response
Priority
Habitat / GIS
Mapping
ACEC
Rec. research
DFW-01
Need to identify MHD roadways within or adjacent to state Priority Habitat areas
MassDOT has updated its GIS mapping regarding Priority Habitat areas in relation to MassDOT roads
and a general discussion has been included in the Draft ESPR.
DFW-02
Need to revisit Kampoosa Bog Study – Study shows salt intrusions of more than
300 meters and CL Concentration above 275 mg/L near I-90 – reduced plant
diversity
Recent
Research
DFW-03
Recent
Research
Env – Recent
Research
DFW-04
Mattson and Godfrey (1994) study presents sodium conc. In 162 stream & salt
loadings of 17,700 kg and 22.500 kg per kilometer for major roads & interstates,
respectively
Kaushel et.al study (2005) shows increased salinization in fresh waters of the
Northeast
Research referenced for the sublethal and lethal affects to fauna are not cited in
GEIR see page 69 – Disagree with conclusion on pg. 93 – ͞the impact of salt0on
flora, fauna0is not significant in M!
Request that MassHighway consult with NHESP in developing MP͛s for deicing
adjacent to Priority Habitat areas
MassDOT has reviewed the more recent Kampoosa Bog study and has included a summary of the
data in the Draft ESPR. As part of the list of recommendations included in the ESPR, MassDOT will
evaluate various innovative measures to increase efficiency and reduce salt use in this area now that
the roadway has recently become part of the MassDOT road network.
The information and findings of this study have been summarized in the Draft ESPR.
DFW-05
Agency
DFW-06
Coordination
DCR –Comment Letter from Stephen H. Burrington, Commissioner dated September 22, 2006
The assessment of sodium levels in Zone II wells within 0.5 miles of MHD Roads
Drinking
DCR-01
uses too high of a threshold at 60 mgl/L – 2003 EPA drinking water advisory
Water
recommends 30 to 60 mg/L – MaDEP DW standards contain a health guideline of
20 mg/L.
Drinking
Water
DCR-02
Drinking
Water
DCR-03
Drinking
Water
DCR-04
Wells with sodium levels above the prescribed standards need to be remediated;
discuss how reduced salt areas have been and can be used to lower sodium levels
in adjacent wells.
MassHighway should evaluate sodium levels in wells as they relate to 11 MHD salt
storage sheds in Zone II areas.
Related Recommendations:
a) Consult with DCR regarding well driller laws and regulations (MGL c.21, sec 30
and 313 CMR 3.00) and comply with such laws and regulations when private
wells must be replaced due to contamination.
b) Determine changes necessary to bring more wells into compliance with the
recommended EPA and EPA guidelines.
c) Implement a specific health threshold for sodium in drinking water above
which remediation will automatically occur.
d) As recommended on page xvii, replace or repair inadequate salt storage sheds
and locate and cover sand piles outside wetland buffers.
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
7
The information and findings of this study have been summarized in the Draft ESPR.
Chapter 2 of the Draft ESPR contains a detailed discussion of the EP!͛s recommended water quality
standards for chloride set for the protection of aquatic life. This discussion includes information on
the revised standards adopted in the State of Iowa based on more recent toxicity testing information.
MassDOT will consult with NHESP in finalizing the ESPR to address any concerns and identify possible
action steps to further protect Priority Habitat areas.
The assessment included both the upper and lower thresholds of 20 and 60 mg/L of the EPA
guidelines. These guidance limits are recommended for individuals on doctor-prescribed sodium
restricted diets, which represents a relatively small percentage of the overall population. At these
levels, EPA estimates that the overall daily sodium intake from water consumption of 2 liters per day
would be 2.5 and 5 % of the total daily intake. Given the relatively low level of potential intake and
current reporting requirements at 20 mg/L, it would seem unreasonable or not cost-effective to
impose relatively costly remedial measures. See also Response to Comment DEP-05 above.
See Response to comment above. MassDOT continues to work with the relatively few PWS͛ within
the state that have reported much higher or increasing sodium levels to determine if a reduced salt
zone areas would be beneficial/ There are 53 RSZ͛s throughout the state to reduce sodium levels.
When MassDOT has been notified of elevated sodium levels in public wells or private wells through
its Remediation Program, MassDOT will work with the well owners to remediate the problem if it is
confirmed through field investigations that its operations are contributing to the elevated levels.
a) MassDOT is familiar with the state well driller laws and regulations and only hires certified well
drillers for well replacement activities.
b) MassDOT will continue to work with well owners on a case by case basis through the Salt
Remediation Program where appropriate remediation measures are deemed necessary following
detailed field investigations.
c) See Response to Comment No. DEP-05 regarding sodium remediation. Implementing remedial
measures will always require a field investigation since MassDOT is not the only source of salt and
in certain locations, adopting more costly alternatives may not be the best use of taxpayer dollars
if MassDOT is a relatively minor contributor compared to municipal roads and parking lots.
d) MassDOT continues to evaluate their storage sheds and will repair and replace sheds as necessary,
contingent on available funding. See Response to Comment DEP-16.
2/27/2012
State Agencies (cont.)
DCRComments (Cont.)
Category
Drinking
Water
Comment
No.
DCR-05
Comment
MassDOT Response
DCR Office of Watershed Management recommends MassHighway to work with
M!DEP͛s drinking water program to ensure that MP͛s are used for protection of
public drinking water sources near maintenance sheds and salt storage facilities
Water
Resources
DCR-06
GEIR (p.ix) refers to an un-named program to reduce salt use in environmentally
sensitive areas - GEIR describes the impacts of salt reduction strategies on flora –
but makes no mention of impacts on wetlands, aquatic ecosystems or rare species
Water
Resources
DCR-07
Water
Resources
Municipal
Coordination
DCR-08
Planning/
Permitting
Planning/
Permitting
DCR-10
Continued commitment and increased attention to the monitoring of water quality
in nearby water bodies and wetlands for chronic and acute levels of sodium &
chloride (as defined by EPA) is essential to improving salt management and
resource quality.
DCR is also concerned about the cumulative impacts on water resources that are
associated with sand deposited and transported from roadways
Reduce the application of sand and advance this policy to the municipal level
through the Bay State programs and other public outreach avenues associated with
municipal DPW͛s
Expand the use of GPS technology to identify and document location of drainage
structures
Improve drainage MP͛s in high priority environmentally sensitive areas
Operations
BMPs
DCR-12
Training
DCR-13
Stormwater
BMPS
DCR-14
ACEC’s
DCR-15
ACEC’s
DCR-16
ACEC’s
DCR-17
DCR-09
DCR-11
DCR is interested in the extent and success to which various alternative
technologies have been implemented such RWIS, anti-icing; or pavement
temperature sensors, etc.
DR encourages an annual training program for municipal DPW͛s and private
contractors
DCR is interested in the results of the storm water modeling study conducted by
USGS for MassHighway? DCR is curious as to whether the study will help to identify
stormwater MP͛s that may be effective in mitigating salt-laden runoff.
More study is needed for Kampoosa Bog – A Smith College Professor Amy Rhodes is
finishing up a 3-year hydro chemical study – DCR recommends MassHighway to
meet the Kampoosa Bog Stewardship Committee – Paul Kelly of MassHighway and
Liz Sorenson of ACEC Program is on the Committee.
DCR is unaware of Cedar Swamp ACEC Study on salt content in red maples tissue
samples. DCR will request a copy.
MassHighway should evaluate and consult with local stewardship groups regarding
the 28 other !E͛s in 78 municipalities/
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
8
MassDOT has previously met and will continue to consult with MassDEP͛s Drinking Water Program in
finalizing the 2012 ESPR and to discuss the status of sodium levels in PWS͛ throughout the state, the
measures that MassDOT has employed to protect PWS and whether any additional measures are
necessary as they relate salt storage facilities near PWS͛/
The program mentioned refers to the Reduced Salt Zone Program administered collaboratively
between the MassDOT Snow and Ice Control Program and the Environmental Services Section of the
MassDOT Highway Division. The ESPR provides a summary discussion of the locations of key habitat
areas including Kampoosa og and other !E͛s relative the various MassDOT Maintenance Districts
within the Commonwealth.
See Responses to Comment No. RWYP-08 and Comment No. DFW- 05 above.
As stated above, MassDOT intends to continue to reduce its use of sand as part of the Snow and Ice
Control operations.
MassDOT will provide an update on its use of sand as well as other deicing operations through the
Bay State Program.
Recently, MassDOT has initiated an extensive mapping effort to document locations of existing
drainage structures as part of its MS4 Stormwater Program.
MassDOT will improve drainage MP͛s on a case by basis as new roadway improvements are
proposed as well as part of the Impaired Waters Program as discussed above where investigations
indicate that runoff from MassDOT roadways may contribute to listed impaired water bodies.
See Response to Comment DEP-13 and discussions in Chapter 1 of the DRAFT ESPR.
So noted. See Responses to Comment No. DEP-22 and Comment No. RWYP-07.
MassDOT is continuing to work with USGS in finalizing the completion of the stormwater modeling
effort. The model is still a work in progress and it is hoped that the model will be finalized and be
made available for public review in the next 12 to 18 months. It is anticipated that the model will be
a useful tool to predict potential sodium and chloride concentrations in receiving streams
MassDOT Met with Elizabeth Sorenson (former ACEC Coordinator) in the development of the 2008
Work Plan for the ESPR and has reviewed the latest report on the Kampoosa Bog prepared by
Professor Rhodes and has provided a summary of the findings in Chapter 2 of the DRAFT ESPR. See
also Response to Comment DFW-02 above.
Upon further review, the reference to salt content data in red maple tissue samples was not intended
to be linked to Cedar Swamp. The red maple tissue data was in reference to a separate study
conducted by the UMass Cooperative Extension Service that was partially funded by MassHighway. A
copy of this study can be provided
As noted above, MassDOT has coordinated with the ACEC Coordinator in the development of the
ESPR Work Plan and plans to meet with the Coordinator again in finalizing the ESPR. It is understood
that there are now thirty (30) designated !E͛s in the state/ ! listing of the !E͛s by District is
provided in the Draft ESPR.
2/27/2012
Federal Agencies
Comment
Category
No.
Comment
EPA– Office of EcosystemProtection : David J. Gray, P. E. , October 10, 2006
Planning/
Permitting
EPA-01
Planning/
Permitting
EPA-02
Operations –
BMPs
MassDOT Response
In our August 18th letter, we requested that MHD include in its amended SWMP the
following:
1. an assessment of current salt application practices and reduction measures and a
schedule of planned BMPs for reducing salt impacts to surface water and groundwater;
2. a monitoring program and strategies to minimize stormwater impacts to PWS supplies
While MHD identifies a variety of recommended measures that could yield continued
environmental and financial benefit, it offers no specific plan for goals for implementing
many of these recommendations. MHD should provide additional detail, schedules, or
goals with regard to implementation of the following:
As discussed in the responses above, MassDOT has implemented numerous equipment upgrades
and application technologies in the last few years that have caused substantial reductions in salt
use relative to previous years of similar winter severity. These measures have been further
described in Chapters 1 and 3 of the ESPR. See Responses to Comment No. DEP-02 and
Comment No. RWYP-08 above in particular.
The Draft ESPR contains a list of Recommendations geared toward improving the effectiveness of
the Snow and Ice Program and minimizing its potential effects on environmental resources. See
Responses to below to each of the following items that are addressed separately :
EPA-03
1) Reduction in uniform deicing application rates (i.e, data needs and criteria/basis for
future reductions
Operations –
BMPs
EPA-04
2) Increased staffing for better supervision of deicing operations;
Operations –
BMPs
Operations –
BMPs
Operations –
BMPs
Operations –
BMPs
Operations –
BMPs
Operations –
BMPs
EPA-05
EPA-08
3) Construction of additional gambrel-style salt storage sheds (Estimate No. of sheds,
location, schedule)
4) Post-storm vehicle washing and residue disposal practices for MHD and contractor
equipment;
5) Expansion of RWIS (prioritize different climate regions and environmentally sensitive
areas)
6) Expansion of anti-icing and pre-wetting systems for MHD and contracted equipment
MassDOT will continue to seek ways to improve its application efficiency through the use of antiicing techniques as well as other measures. This will lead to further salt use reductions relative to
previous years of similar winter severity. However, reducing the standard application rate of 240
lbs/ ln-mile is not anticipated at this time or is considered warranted. A sufficient amount of
material must be applied in order to be effective in reducing the freezing temperature of water
and prevent snow and ice from bonding to the pavement. Further reductions in salt use will
likely come from innovative technologies that reduce the number of applications by more
accurately determining when applications are needed and by improving the effectiveness of each
application rather than modifying the application rate.
MassDOT certainly agrees that additional supervisory personnel would be helpful; however,
additional staffing for supervisory roles would involve a major budget increase that would require
legislative approval. MassDOT has been very successful in getting more hired contractors to
upgrade their equipment and utilize the latest application technologies through incentivized
compensation rates. This change has lead to substantial reductions in salt usage relative to that
used in previous years with similar winter severity. This results in both cost savings and
environmental benefits.
See Response to Comment DEP -16 above.
EPA-09
7) Inspection and calibration of spreader equipment (i.e., warranted improvements)
EPA-10
8) Research programs (i.e., selection process and schedule for implementation)
Planning/
Permitting
EPA-11
EPA requested that MHD include in its amended SWMP a monitoring program and
strategies to work with PWS͛s to minimize salt impacts. We note that MHD intends to rely
on its Salt Complaints Program to process complaints and respond to possible
contamination issues. We request that MHD provide the following information: 1) a list of
the specific PWS that have filed complaints and the date of complaint; and 2) a summary of
the investigations, including results of any data collected and current status of the
investigation.
EPA-06
EPA-07
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
9
See Response to Comment DEP-17 above.
The RWIS system has been expanded to 28 stations and provides coverage to most of the
geographic and climate regions of the state.
The use of pre-wetting/anti-icing techniques has been greatly expanded as discussed in greater
detail in the responses above.
MassDOT has implemented a spreader calibration inspection team to perform random audits of
spreader settings on MassDOT and contractor equipment during storm events.
MassDOT is in the process of completing an internal research effort geared toward identifying
ways to make the snow and ice operations more efficient. The results of this study will likely be
included in the Final ESPR once the study is completed.
Chapter 2 of the ESPR provides a detailed discussion of observed sodium levels in PWS wells and
a listing of those wells that have elevated and/or have shown an increasing trend of elevated
sodium levels in wells/ Many of these PWS are listed in MassDEP͛s omment DEP-09 above.
2/27/2012
Regional Agencies
Category
Comment
No.
Comment
Connecticut River Watershed Council; submitted by Andrea F. Donlon, River Steward, October 11, 2006
Env- Recent
CRWC-01 We found Sec/ 4/0 of the GEIR (Env/ Impacts) to be ͞very minimal͟ especially when
Research on
Env Impacts
Operations
Overall Annual
Usage – LOS
CRWC-02a
OperationsCalibration
Policy &
Enforcement
CRWC-02b
Excessive Salt
Application
CRWC-02c
Snow
Disposal
CRWC-03
Sand
CRWC-04
considering the following recent research :
1) Kaushal et al, 2005, Proc/ of Nat/ !cad/ Sci/ ͞ Increased salinization of fresh water in
northeastern US͟ The abstract concludes that, ͞ Our analysis shows that if
salinity were to continue at its present rate due to increased impervious surface
coverage and current mgt practices, many surface waters in the northeastern US
will not be potable for human consumption and would become toxic to
freshwater life within the next century/͟
www.pnas.org./cgi/content/abstract/102/38/135/17.
2) Jackson and Jobbagy, 2005 ͞From Icy Roads to Salty Streams͟
(www.pnas.org/cgi/content/full/102/41/14487.
3) Environment Canada has also done a considerable amount of research
www.ec.gc.ca/nopp/roadsalt
A final version of the GEIR should include a more complete analysis of the current
research on the env. Impacts of road salt applications.
According to Table 2.6-2, MassHighway͛s average annual salt use of 23/9 tons/lane-mile
is much higher than the other NE states and New York , which range from 8.2 to 18.2
tons/lane-mile annually. MassHighway explains on page 32 that the higher usage is due
to a higher LOS used on MassHighway roadways. No further analysis or justification is
given. Are other states not providing a higher level of service? Based on our travels
throughout the Conn. River watershed, we have not noticed any appreciable difference
between states.
MHD should do more to analyze factors that contribute to their higher ave. annual
usage amount. For example, are there flaws in the spreader calibration policy or its
enforcement? Has the calibration policy actually worked to bring down the ave annual
application rate as it should? Does the high rate of hired equipment inadvertently
contribute to the higher usage? Are there other factors?
A photo was taken on Feb 15th, 2006 on Route 2 in Buckland near the ramp to Route
112 South showing excess dry road salt on pavement. The location is very close to the
bridge going over the Deerfield river. The salt was present for many days afterward
until it washed off. This anecdotal evidence indicates that there is room for
improvement on minimizing excessive applications.
Snow disposal is an element of snow and ice control that did not appear to be covered
in the GEIR. In some areas, snow removal and disposal is necessary. Does MHD engage
in snow disposal and what guidance or BMPs are followed? As of 2001, MassDEP
prepared snow disposal guidance document.
We support MHD͛s philosophy for reducing the use of sand for traction/ We
recommend the article NH T2 enter͛s Fall 2001 newsletter called ͞ Pros and ons of
Sand on Snow and Ice Pack͟
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
10
MassDOT Response
Chapter 2 of the Draft ESPR provides a summary of recent environmental research regarding
the effects of snow and ice operations, including the results of several chloride TMDL studies
completed in southern New Hampshire. One important finding of the chloride TMDL studies is
that municipal roads and salt used on parking lots can be major sources of salt in certain
watersheds. In the last 5 years, MassDOT has made great progress in implementing various
efficiency measures, which have resulted in considerable salt use reductions on state roads.
MassDOT expects this trend to continue with greater reductions in the future. Even though
there has been substantial progress, it is worth noting that MassDOT has no jurisdiction and
minimal influence on other users of road salt such as municipalities and parking lot
contractors, which could use as much, if not much more road salt in certain watersheds.
MassDOT maintains approximately 16,000 lane-miles of roadway for snow and ice purposes,
whereas, according to the 2010 Statewide Roadway Inventory, the amount of municipal and
private roadways within the state amounts to approximately 60,000 lane-miles. This does not
include the impervious area associated with the extensive parking lot areas located
throughout the state.
MassDOT͛s annual salt usage on a per lane basis depends on a number of weather and nonweather related factors. Most MassDOT roads require around the clock maintenance and have
a relatively small margin of error with respect to preventing traffic accidents and minimizing
traffic congestion. Traffic volumes and congestion during peak travel periods can be
substantial even without inclement weather. Minimizing travel delays and increases in vehicle
accidents rates during snow events is a major challenge for MassDOT personnel. In light of
today͛s media scrutiny, increased travel delays can provoke greater demand for salt
applications through calls received by local and state police to improve road conditions. If one
or two more applications are conducted in each storm event in response to emergency calls or
to maintain roads during overnight hours, multiplied by 20 to 30 events per season can result
in a notable difference in the amount of road salt used per lane-mile per season as compared
to that reported in other states. On more rural roadways in other states such as northern
Maine, NH, VT and NY, maintenance personnel may allow snow to accumulate overnight and
then plow/apply deicers in the morning. See Response to Comment DEP-02 above.
Many equipment improvements have been implemented for both state and hired equipment.
MassDOT͛s greater reliance of hired equipment relative to other states does pose a challenge
for monitoring hired equipment operations, but MassDOT has made great progress in
incentivizing hired contractors to use closed-loop controls that electronically record actual
material usage. Nearly 70% of the contractors now use closed-loop controllers.
So noted. MassDOT will continue strive towards improved application methods. The rising
cost of road salt alone provides a major financial incentive to apply salt most judiciously, in
addition to environmental reasons. MassDOT has not only upgraded its own equipment but
has also incentivized its hired contractors to upgrade their application equipment as well. See
Response to Comment DEP-02 above
MassDOT does not engage in snow removal from most of its roads, if there is a need to
remove and dispose snow, MassDOT complies with Mass DEP͛s Snow Disposal Guidance Policy
and most recently, enforced the policy guidance on the DCR roadways that MassDOT has
recently taken over the winter maintenance responsibilities.
So Noted. MassDOT is familiar with the reference documents cited in the T2 Center
newsletter. As mentioned earlier, MassDOT intends to continue to reduce its use of sand for
deicing operations.
2/27/2012
Regional Agencies (cont.)
Category
OperationsApplication
Efficiency
Comment
No.
CRWC-05
Comment
MassDOT Response
MassDOT should be a trend-setter and lead the way for reduced salt usage. Some
Towns have gone to using just salt for snow and ice control and minimal plowing
as a cost saving measure. !lthough this trend may not be MassDOT͛s direct
responsibility MassDOT can contribute to a culture change among towns and
private snow removal companies by doing a smarter and better job as
inexpensively as possible.
MassDOT does not use or condone a policy where salt is used to ͞burn͟ off snow instead of plowing/
MassDOT promotes a policy that plowing is the primary and most effective means of removing snow from
roadways and conveys this message through its employee training. As noted by the commenter,
MassDOT has no direct responsibility and limited influence on municipal DPWs. Other agencies, such as
MassDEP or EPA may have more influence and direct control over municipal practices through the MS4
stormwater permitting program.
Canoe River Aquifer Advisory Committee: by Wayne P. Southworth, Committee Chair, October 10, 2006
ACEC
CRAAC-01 The Canoe River Aquifer is a designated ACEC by the Mass EOEA and a Sole Source Following the 2006 GEIR, MassDOT had consulted with the Town of Norton Conservation Commission on
Aquifer by EPA. The Canoe River Aquifer Advisory committee is charged with
at least two occasions to exchange information and address their concerns. Since that time, no further
Agency
protecting this aquifer, which supplies 50% of the municipal water supply to the
communication has been received from the Town of Norton officials. MassDOT had also conducted
Coordination
Towns of Norton, Easton, Mansfield, Sharon and Foxboro. The CRAAC voted on
Oct. 5, 2006 to support the Norton ConsComm in their efforts to prevent
unnecessary damage to the environment and Canoe River from road salting
practices on Routes 495 and 123 in Norton.
additional ͚tail-gate͟ training in the Norton area for district personnel/ MassDOT will consult with the
ACEC Coordinator to get an update on the status of the ACEC during the completion of the ESPR.
Water Supply Citizens Advisory Committee, submitted by Eileen Simonson and Alexandra Dawson, co-Executive Directors, Oct 10, 2006
So noted.
General
WSCAC- WS!͛s charge to advise MWRA on water supply matters always leads us to an
interest in winter road treatments. Although we make special mention of the
01
ambridge Water Dept/͛s comments, our concerns are both general for all surface
water systems and wells, and specifically applicable to the Wachusett Reservoir and
Quabbin (especially in its northern sectors), the Ware River upstream of the
MWR!͛s diversion point and the MWR!͛s emergency water supply system at the
Sudbury Reservoir and Reservoir #3 in Framingham.
The GEIR is not very user friendly. The Appendices are cross-referenced in such a
way that it is hard to find material e.g. the chart of 30 low salt application areas
referred to in App. F is then directed to App. B and the pre-attachment pages
It is not clear whether MHD is recommending the studies it lists (for
implementation) or whether MHD is merely saying that these studies would be
interesting and should be proposed sometime in the future.
Report Format
WSCAC02
Report Clarity
WSCAC03
Municipal
Coordination
WSCAC04
How do the GEIR methods and recommendations relate to and/or influence the
way non-state roads that are treated each winter season? Do municipalities
benefit from the experiences of activities and studies? Are the two tiers of
government and road maintenance actually speaking in a constructive manner?
Operations
BMPs
WSCAC05
Operations
BMPs
WSCAC06
Section 5.0 of the GEIR states that ͞MassHighway could take a variety of measures
that likely would lead to environmental benefits as well as reduced costs0/͟ When
will experience and monitoring lead to a more determined actions on the part of
MassHighway? Will MHD use a computer model or not? This is all very vague. Are
pages 94 and ff. actual recommendations?
The cost statements are too easily passed on in this report. More needs to be done
to compare (emphasis added ) the value of lost drinking water supplies and /or
fisheries to the cost of cleared roads and how much economic benefit is accrued
through maintaining the best road treatment devices, such as ͞bar͟ applicators/
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
11
So noted. The cross-referenced to Appendix F from Appendix B was inadvertent and unnecessary. Efforts
will be made to provide a more stream-lined report format for the future Annual Reports and the next
ESPR.
The 2006 GEIR list of recommended studies related to various innovative approaches recently studied. As
noted above, MassDOT has already implemented many of these approaches over the last five years
including the use of liquid brine solutions for pre-wetting and pre-treatment applications. MassDOT
continues to evaluate new technologies and approaches and has joined a FHWA pooled funded
cooperative study investigating the true costs of snow and ice control.
MassDOT has no jurisdiction or responsibility for municipal DPW deicing practices. MassDOT will continue
to share information and guidance through the Baystate Training Program, but MassDOT does not
anticipate any formal process where it would directly affect municipal operations. MassDEP and/or EPA
are likely to have a greater potential to influence municipal practices through existing regulatory
programs.
As noted above, MassDOT has implemented numerous equipment upgrades and innovative technologies
that have lead to substantial salt use reductions as discussed in Chapter 1 of the Draft ESPR. See
Response to Comment No. DEP-05. MassDOT will continue to evaluate and use newer technologies and
innovations to further increase the efficiency of deicer material.
See Response to Comment Above. MassDOT continues to work with PWS͛ to remediate potential
contamination issues on a case by case basis. MassDOT is unaware of any drinking water supplies that
have been ͞lost͟ due to salt contamination/ The remediation costs in replacing private wells or
remediating public wells have been documented in the ESPR. Also, noted above, MassDOT is currently
participating in Clear Roads Pooled Funding Research Study with other transportation agency to update
the true costs of snow and ice operations. This study is not expected to be completed until 2013.
2/27/2012
Regional Agencies (cont.)
Water Supply Citizens Advisory Committee (cont.)
Category
Operations –
Training
Comment
No.
WSCAC-07
Salt Usage
Sand Use
WSCAC-08
WSCAC-09
Alternative
Deicers
WSCAC-10
Env- Reduced
Salt Zones
Policy
WSCAC-11
Pavement
Alternatives
WSCAC-12
Comment
MassDOT Response
It is disturbing to find that some problems have been found with temporary
employees pressed into service that may not understand or properly control
sensitive area applications. This should be remedied. Contractors supplying
equipment and personnel should be in possession of the maps and routes and
application details needed to comply with the MassHighway͛s reduced treatment
areas.
Why does Massachusetts still use so much more road clearing material?
It is recommended that sanding be reduced, except at low-slope intersections, but
that salting actually be increased through the use of anti-icing spray. Studies are
needed to determine if this practice actually will reduce the salt loading over time,
Are there actual studies to determine that the cost of alternative treatment
materials are more expensive over time?
Implications abound that communities outside of our state are using more
expensive ice-avoidance materials effectively. More documentation is needed to of
the initial cost versus total effort to determine the methods that are most suited,
especially to sensitive surface waters along roads such as the Cambridge water
supply system.
MHD does not seem to be taking a proactive stance on adding reduced salt areas.
Why? Page xvi of the summary says ͞relatively few͟ PWS wells are having
problems. Is there documentation that we have missed? Since salt is persistent,
Zone II͛s should be monitored and studied more diligently/
Are there road surfaces that require less winter treatment? Is Massachusetts using
them? The CWD lists an area of new pavement in Lexington on I-95. Is this segment
being studied for winter maint. needs?
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
12
As noted in Response to Comment CWRC-02a, MassDOT has recently incorporated greater
controls for hired contractors by promoting the use of closed-loop controllers on hired spreaders
that allows record-keeping of actual material usage. The accuracy of these controllers is highly
dependent on the calibration process, which MassDOT is currently working on methods to
improve this process. MassDOT anticipates that this process will have major
See Response to Comments No. DEP-02 and CRWC-02a
As discussed above, MassDOT has already converted to an anti-icing based program, which has
recently shown to result in reductions in salt use. However, the conversion requires upfront
capital investments and increased operating costs to compensate contractors to purchased and
utilize different spreader equipment. MassDOT must also invest funds to increase its liquid brine
storage and manufacturing capabilities. The ESPR includes updated cost information with respect
to using non-chloride deicers as an alternative approach. The biggest challenge to using nonchloride products are the costs, as they are 10 to 15 times more costly than road salt, which
would have substantial budget implications. Non-chloride deicers are also not completely benign
and present their own potential environmental risks with respect to oxygen depletion and
possible nutrient loading associated with their organic base material. MassDOT believes that
improving salt use efficiency is the most effective approach going forward from an operational
and environmental standpoint but it may be too early to tell whether the cost of the efficiency
measures are offset by the potential cost-savings associated with less material used, reduced
corrosion potential and environmental benefits. MassDOT is currently participating in a Clear
Roads Pooled-Funded Research Study, which is geared toward updating the ͚true cost͟ of Snow
and Ice Control activities. The results of this study are not expected to be available until 2013.
See Response to omment above regarding MassDOT͛s use of innovative measures and potential
related costs. In addition, MassDOT periodically meets with representatives of the Cambridge
Water Supply System to discuss concerns and progress on ongoing remedial measures.
See Responses to Comments above and in particular Responses to Comments DEP-05 and DEP10. , MassDOT continues to consult with and seek information from the PWS wells that have
shown elevated Na levels through its Salt Remediation Program.
MassDOT has been using open graded friction coarse overlays on many of its interstate roadways
because of its various benefits during non-winter months. During winter months, however, some
district personnel have indicated OGFC pavement may require more chemical treatment during
snow events with colder than usual temperatures. As the salt brine forms at the pavement
surface, some of the brine material drains down into the void space leaving the pavement surface
vulnerable to refreezing. However, under other circumstances, OGFC overlays can limit the
amount of moisture that might accumulate on the surface during melt events. MassDOT will
continue to evaluate the benefits and limitations of OGFC pavement as pavement technology
advances.
2/27/2012
Local Agencies
Comment
Category
No.
Water Supply Citizens Advisory Committee (cont.)
Salt
Complaints
Program
WSCAC13
Comment
MassDOT Response
MHD seems to be using an extremely high sodium level threshold of 250 mg/L for
remediation. This is excessive. If sufficient monitoring were being done, increasing trends
would be able to trigger actions in advance of these levels being reached.
The 250 mg/L threshold is actually used for chloride not for sodium – the chloride content in
road salt is typically 1.5 times greater than the sodium content. Chloride is used to determine
if remediation is warranted because sometimes PWS may add sodium hydroxide to the water
treatment system which would give a false indication that the sodium content in drinking
water is the result of road salt use. MassDEP drinking water regulations require PWS to
perform their own monitoring and reporting of sodium if levels are above 20 mg/L, MassDOT
relies on this data for assessment of trends rather than duplicate efforts.
City of Cambridge Water Department; submitted by Peter Varga, Watershed Protection Supervisor, September 22, 2006
PWS
Reduced Salt
Zone in
Cambridge
Watershed
CWD-01
The GEIR maintains that one of the largest reduced-salt zones is within the City of
Cambridge water supply areas (pg.21). However, the CWD water quality monitoring
program has tracked increasing concentrations of sodium and chloride in the reservoirs
over the years. In consideration of historic environmental trends in Cambridge reservoirs,
the CWD believes that some of the information should be updated, more detail should be
supplied on specific operations in reduced-salt zones, and several of the recommended
practices should be applied specifically to the zone within the Cambridge Watershed.
Operations –
Cost of
maintaining
RSZ’s
CWD-02
NaCl in
environment –
relationship of
surface water
and
groundwater
CWD-03
Operationshistorical salt
usage in CWD
watershed.
CWD-04
OperationsTraining &
equipment
CWD-05
There are several key pieces of data that should be re-evaluated to represent current work
in the field of snow and ice management as well as water quality. A cost analysis
referenced in the GEIR concluded that maintaining reduced salt areas are an additional
$2000 per lane-mile in 1995. This value should be updated to reflect the latest
technologies, particularly with the fleet replacement that took place in the mid nineties (p.
49), increased efficiency of application techniques, and increased fuel costs.
The GEIR should discuss the communication of salt-laden groundwater to surface water
given the results of continual water quality monitoring in these smaller, heavily-impacted
waterways along I-95 in the Cambridge watershed. Currently, both the CWD and the MHD
in cooperation with the United Stated Geological Survey (USGS) are conducting studies
that will assist the estimating loads of de-icing compounds from highway surfaces. The
discussion on surface water impacts (Sec 4.1.3, page 60) should be expanded. This section
asserts that ͞impacts of salt on surface water are generally limited to small volume
streams or lakes adjacent to heavily salted areas͟/ ! significant portion of the surface
water inputs to the Cambridge Water Supply are small volume streams. All of the streams
in close proximity to the highway exhibit elevated levels of salt during base flow conditions
indicating that salt-contaminated groundwater can impact surface water.
MHD has not quantified the total amount of material applied annually to the road surfaces
during winter storms in the Cambridge watershed in the past; this data is critical in mass
balance calculations within WD͛s water quality monitoring program as it attempts to
calculate salt loads from various streams that are impacted by highway runoff, and from
direct discharges from the highway to the reservoirs.
Further details of operations in reduced-salt areas including distribution of staff, drivers,
contractors, and all associated equipment and materials should be incorporated into the
GEIR (in addition to Attachment 1, hapter 5 of MassHighway͛s Maintenance Manual).
This would assist stakeholders in the reduced-salt areas to understand MHD operations in
RSZs.
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
13
MassDOT has met with CWD representatives – most recently in August 2011 to discuss the
status of the monitoring data and the latest changes in deicing operations within this
watershed. MassDOT intends to continue to meet with CWD on an annual basis to provide
updates on operations and the various innovative measures. It is also important to point out
that MassDOT͛s ability to reduce or minimize sodium levels in this watershed is limited to only
its share of the overall use of road salt in this watershed. There are numerous large
commercial parking lots and many local roadways in this watershed as well. In fact, the
amount of impervious area associated with commercial parking lots alone in this watershed is
likely to be several times greater than the amount of MassDOT roadways in this watershed.
MassDOT will continue to review the expected cost savings over time with improved
technologies and equipment. At one time, MassDOT had estimated that the additional cost of
$2,000 per lane-mile cost was associated with the cost differential in alternative materials
used e.g., pre-mix), the added supervisory personnel needed to closely monitor road
conditions and the additional storage and handling requirements for the alternative materials.
So noted: MassDOT is proving funding to support the ongoing monitoring efforts being
performed by USGS and UMASS personnel. The data is still being collected, compiled and
analyzed and will be shared with CWD representatives.
MassDOT is in the process of incorporating more innovative spreader controllers for this area
to allow more precise reporting of salt usage in this area.
MassDOT will plan to provide updates to CWD representatives through future meetings and
annual reports regarding the progress being made in reducing salt usage in this watershed
through innovative techniques that have been recently installed and likely to be expanded in
the future.
2/27/2012
Local Agencies (cont.)
City of Cambridge Water Dept (cont.)
Comment
Category
No.
Operations –
Use of Prewetting & AntiIcing in CWD
watershed
CWD-06
Operations –
RWIS in CWD
watershed
CWD-07
Operationssnow fences
CWD-08
Operations- use
of contractors in
RSZ’s
CWD-09
Operationspost-storm
reporting in
RSZ’s
CWD-10
Operationspavement
CWD-11
Comment
MassDOT Response
Section 5.2.2 lists several examples of such practices recommended for reduced-salt
zones which enhance application of calcium chloride by. ͞1) pre-wetting the road salt
before application to accelerate melting and to promote salt adherence to the roadway
surface; and 2) anti-icing the road surface, using a spreader bar dispenser, prior to a
snowfall or freezing rain events͟ (pg/ 96)/ The WD would like to see these processes
applied to the roadways within the Cambridge watersheds.
In addition to specific recommendations for reduced-salt area operations, section 3.1.2
of the GEIR discusses the use of Road Weather Information Systems (RWIS) which have
been proven to reduce costs by 50% in some cases (pg. 40). In light of the high costs of
the Cambridge watershed reduced-salt zone, and the fact that salt concentrations are
elevated in its reservoirs, MassHighway should consider installing a RWIS in this portion
of the highway to optimize application of more expensive de-icing mix. The costs of the
RWIS could potentially be offset by the savings the system brings to the operation of
the highway.
The GEIR affirms that the use of snow fences in Wisconsin reduced the cost of plowing
by up to 100% (pg. 46). Installation of snow fences where drift occurs due to crosswinds in the open sections of highway near the reservoirs could substantially cut down
on plowing costs, reduce associated de-icing requirements.
The GEIR states that in some cases it is possible that ͞the use of contractors for snow
and ice control services results in excessive application of deicing materials due to
contractors typically hiring temporary drivers who, compared to year-round
maintenance staff, lack operational experience and knowledge in the application of
deicing materials ͞(pg/ 77)/ ! very important recommendation discussed in the GEIR is
the monitoring of reduced salt zones during storm events to ͞ensure the proper timing
of salt applications and minimize the potential for overuse of deicing chemicals͟
(section 5.2.2 pg. 96). Sole-sourcing drivers in reduced salt areas within the watershed
could assist with this goal.
The CWD requests that MassHighway create post-storm reports that summarize snow
and ice control procedures in the reduced-salt zone within the watershed after each
storm event, including the quantity of materials applied to roadways. Formalizing the
process for managing this segment of the highway system during winter storms would
significantly contribute to this effect.
A segment of I-95 was recently resurfaced with semi-permeable, low spray pavement in
Lexington, near the upper portions of Hobbs Brook Reservoir. The snow and ice
treatment requirements of this new road surface are not discussed in the GEIR. If this
road surface requires more de-icing chemicals than the conventional asphalt used in
most other areas, CWD requests this information be added to the GEIR.
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
14
MassDOT has already installed most of the previously recommended measures and will
continue to evaluate other innovative technologies to improve salt use efficiency. See also
Response to Comments DEP -02 above.
So noted. MassDOT does have spatial coverage from RWIS stations that are near the CWD
watershed.
So noted. The GEIR provided a comparison of previously reposted costs for snow fences vs
snow plowing based on an EPA Fact sheet. The GEIR did not affirm that snow fences would
eliminate the need for plowing and therefore reduce cost of snow plowing by 100%. Snow
fences in certain location may help to minimize the accumulation of drifting snow but do very
little to prevent snow from accumulating during snow storms. Snow fences are used in wide
open areas and areas of unobstructed wind fetch. To be effective, the fences need to be a
certain distance from the road that is equivalent to 35 times the height of the fence. Thus, for
a typical 4-foot high fence, the fence should be located 135 feet from the roadway, which, in
most locations, would be outside the ROW limits.
So noted. MassDOT has made great progress in increasing its consistency and uniformity in
the snow and ice operations regardless of whether its MassDOT personnel or private
contractors performing the operations. One tool that has helped in this regard Is the
increased use of closed-loop controllers on spreaders that are not only apply a much more
consistent and uniform application of material, but also digitally record the amount of
material applied per lane mile of spreader route. The percentage of contractors of using
these types of controllers has grown from just from about 25 percent just two years ago to
more than 50 percent last winter.
MassDOT already has a post storm reporting policy where all District supervisors submit
reports to the Director of Snow and Ice Operations in MassDOT͛s central office. MassDOT
has recently improved its Snow and Ice Materials System (SIMS) to track material usage in a
more timely and consistent manner.
The use of open-graded friction coarse (OGFC) pavement has been installed on many
interstate roadways. OGFC pavement has many non-winter related benefits including
increased visibility due to reduced wet-weather spray and less road noise. See Response to
Comment WSCAC -12 above.
2/27/2012
Local Agencies (cont.)
City of Cambridge Water Dept (cont.)
Category
Operations –
sidewalks
Operationsvaries
Comment
No.
CWD-12
CWD-13
Comment
MassDOT Response
Lastly, the GEIR should discuss S&I control practices on pedestrian walkways within the
MassHighway system.
Specific Recommendations:
Implement the recommendations outlined in section 5.2.2;
Install a RWIS within the segment of I-95 that bisects the Cambridge Reservoir system;
Install snow fences where I-95 crosses Stony Brook Reservoir in Weston, and as it passes
in direct proximity of the larger Hobbs Brook Reservoir in Waltham and Lexington;
Consider sole-sourcing drivers in reduced salt areas within the watershed;
Issue post-storm reports to stakeholders in reduced-salt zones that summarize snow and
ice control procedures after each storm event.
Establish an independent monitor for snow and ice management within the CWD
watershed;
Annually quantify the de-icing chemicals applied to the road surfaces in the watershed;
and
Continue to fund water-quality monitoring projects that assess impacts of MHD de-icing
practices on receiving waters.
See Response to Comment EOEA-04/ MassDOT͛s snow removal responsibility is the
roadway surface from curb to curb. Snow removal on sidewalks is the responsibility of
the local municipality.
So noted. Many of these recommendations have been implemented and discussed in
the above comments.
Norton Conservation Commission; submitted by Jennifer Carlino, Conservation Agent, dated September 21, 2006
Operations
Shed drainage;
Road drainage
BMPs
ACEC protection
NCC-01
Operations
Shed drainage;
Road drainage
BMPs
ACEC protection
NCC-02
The ConComm has previously brought concerns of impaired water quality to MHD͛s
attention. In particular, we have requested that the O&M of the Rte 123 (E. Main St) salt
shed be upgraded and otherwise improved. MHD staff claimed at a Wetland Hearing that the
stormwater BMPs, including a non-functional detention basin at the salt shed did not work
properly. We have requested that this be upgraded since sand and salt-laden water travel
directly to the anoe River via catch basins/ The ͛s alone do not meet the DEP Stormwater
Mgt Policy for TSS removal or for discharges to an ACEC. We have also requested that the
application of sand and salt within the proximity of the Canoe River be reviewed and
improved.
Residents and ConComm members have frequently observed large quantities of rock salt
that have spilled or been applied to Rte 123 such that the salt left a thick white crust on the
road long after snow melt. The ConComm therefore requests the following:
a) MHD designates portions of Rte 123 (E. Main St.) and Rte 495 that discharge to the Canoe
River as environmentally sensitive areas.
b) Redirect stormwater from the site (salt storage shed) to onsite detention basins to
prevent runoff entering the Rte 123 drainage system and ultimately to Canoe River.
c) MHD use alternatives to rock salt for road segments that drain to the Canoe River. We
also request that proper signage be installed along these segments.
d) That existing stormwater BMPs within the Canoe River watershed be upgraded to meet
DEP͛s Stormwater Mgt Policy/
e) Please add the anoe River to the areas within !E͛s that will be tested for salt related
impacts (See Section 5.2.3, pg 96).
f) Please add all requested actions above to the Recommendations listed under Sec 5.2.
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
15
MassDOT is aware of the Norton ConComm concerns as well as thosse of the Canoe
River Aquifer Advisory Committee (CRAAC). On October 10, 2006, MassDOT sent a
letter to the hair of R!! to explain MassDOT͛s process for investigating and
addressing potential salt contamination issues. MassDOT will continue to communicate
and work with Norton and CRAAC to address the concerns. MassDOT has also held
͞Tailgate͟ training sessions with Town officials to discuss these concerns/
Again, as noted above, MassDOT has communicated with the Town of Norton following
the completion of the GEIR. MassDOT personnel have also inspected the storage
facility in the area to identify any needs for improved housekeeping measures.
MassDOT will continue to work with the Town of Norton to address their concerns.
MassDOT has incorporated many of the recommendations listed in Sec 5.2 of the 2006
GEIR and will work towards implementing the new recommendations included in the
2012 ESPR.
2/27/2012
Local Agencies (cont.)
Comment
Category
No.
Norton Conservation Commission (cont)
Operations
Road drainage
BMPs
Reduced Salt
Zones
NCC-03
Municipal
Coordination
NCC-04
Comment
MassDOT Response
The second major area of concern is on Rte 140 (Mansfield Ave) where the highway
bisects the main section and the southern coves of the Norton Reservoir. In recent years,
the highway has been upgraded and paved sluice ways have been added that direct
runoff into the Reservoir without treatment. Residents and ConComm members have
observed sand and salt plumes extending out approx. 30-40 feet into the Reservoir during
the winter. The Reservoir Dredging Project is an ongoing project – sand and salt
discharged directly into the Reservoir does not meet the Stormwater Mgt Policy and also
exacerbates problems within the Reservoir. We request the following;
a) MHD designate portions of Rte 140 as an environmentally sensitive area and salt
alternatives to be utilized. We also request roads be posted as ͞no-salt areas͟/
b) The existing stormwater BMPs be upgraded to meet the Stormwater Mgt Policy.
c)
Please add all requested actions to the Recommendations listed under Sec. 5.2.
The ConComm requests that the GEIR sections regarding coordination between
MassHighway and municipalities be greatly improved. While we have received written
responses to out comment letters, there has been little to nothing done to address the
concerns. We are told to follow the correct procedure for voicing our complaints but
cannot be directed to the ͞correct procedure͟ so that we can follow it/ We have an
agreement to meet with MHD in the winter to review our concerns but strongly request
that the submitted comments be incorporated into the Snow and Ice Control Plan. The
complaint program is not found anywhere on the website. We request that:
a) The complaints program and contact information be added to the state website;
b) MassHighway representatives meet with Norton Officials
As noted in the many responses to comments listed above, MassDOT has made numerous
improvements to their snow and ice control operations resulting in less salt and sand
being applied to roadways compared to previous years. MassDOT intends to continue to
increase its efficiency with the goal of using less deicer material. MassDOT has also
launched am Impaired Waters Program, which is geared towards identifying and
prioritizing roadway areas to implement storm water BMP retrofits. MassDOT would be
happy to meet again with the Town of Norton officials to provide an update on both the
Snow and Ice Program and/or the Impaired Waters Program.
MassDOT has added informational materials and contact information on the MassDOT
website pertaining to the Salt Remediation Program. MassDOT has communicated and
met with Norton officials on a number of occasions since the 2006 GEIR.
City of Boston Environmental Department, submitted by Bryan Glascock, dated Oct. 16, 2006
Use of Sand
Air Quality
BED-01
OperationsPavement
Alternatives
OperationsBMPs
Salt Brine Use
BED-02
BED-03
We note that the majority of the information regarding Air Quality in Sec. 4.2 (Env
concerns of sand) dates back to the early to mid-1990͛s, and wonder if there is more
recent data. Secondly, is there an established protocol for determining the level of
particulate matter in areas along MHD roadways where abrasives are routinely applies
and as the result of clean-up? Are ultrafine particles a potential concern with abrasives
used in this context? Have these questions been addressed in other jurisdictions and, if
so, with what results? If abrasives will continue to be a significant part of the MHD snow
and ice program, air quality issues and mitigation should receive greater attention.
It has been 21 years since alternative paving materials were evaluated by MHD and
section 3.1.5 does not include significant recent data from other jurisdictions. We suggest
that MHD research current options and engage in a multi-product testing program.
MassDOT plans to continue to use less sand in its deicing operations, which will help to
avoid any air quality issues associated with particulates.
NH and Maine have reduced rock salt application levels in recent years with the use of
salt brine solutions and we suggest testing of this method. The GEIR indicates that it can
reduce the use of both salt and abrasives. We believe that pre-wetting and anti-icing are
practices worthy of MHD͛s investment/ We suggest that pilot programs be conducted in
several areas of the Commonwealth designed to assess the performance measures
outlined in Table 4.4-1.
MassDOT has implemented the use pre-wetting and anti-icing practices since the 2006
GEIR. We will continue to expand the use of these techniques and evaluate the benefits
of these new technologies in the future ESPR. See Response to Comment DEP-02 above.
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
16
MassDOT has included additional information in the 2012 ESPR with regard to alternative
paving materials.
2/27/2012
Local Agencies (cont.)
Comment
Category
No.
City of Boston Environmental Dept (cont)
Comment
MassDOT Response
Operations
BMPs
Research of
Alternatives
Agency
Coordination
BED-04
We endorse the Recommendations specified in Section 5.2. In addition to those
identified, we encourage MassHighway to engage in research on topics beyond those
identified for funding under the FHWA Pooled Funding Program.
So noted. MassDOT has recently completed a limited internal research study to
identify opportunities to improve the efficiency of its snow and ice program. Much of
the preliminary findings have been included in the Draft ESPR.
BED-05
MassDOT has consulted with MBTA and DCR to obtain information on their policies
and procedures for snow and ice control. Only MBTA provided relevant information.
The MassDOT Highway Division has no jurisdiction or operation control over the
practices and procedures used by these other agencies.
Operations
Air Quality –
Diesel Vehicles
BED-06
There is no discussion in the GEIR about attempts to coordinate efforts with other Mass
Transportation Agencies. We believe that the use of common technologies, best
practices, training resources0//etc has the potential for cost-effectiveness and safety
benefits. Expertise should be shared and knowledge of effective snow and ice
management equal across agencies. The implications of the ͞significant differences in the
extent to which public employees versus private contractor utilization͟ should be
examined carefully. Bringing all of the transportation agencies into line with snow and ice
management should be a goal of the Commonwealth and we urge the Secretary to take
the steps necessary with other Executive Agencies to move toward this end.
As part of an effort to minimize the air quality impacts, all on- and off-road, public and
private diesel equipment used in snow and ice control management should be retrofitted
with oxidation catalysts or particulate filters and operated with low-sulfur diesel.
GEIR Reporting
Frequency
BED-07
We believe that the filing of a GEIR on a more frequent basis is appropriate at this time
and suggest that a new one be filed in five, rather than 10 years.
As MassDOT continues to replace its trucks, all new trucks are equipped with the
latest emission reduction technology. Most, if not all, diesel purchased these days
consists of the low sulfur variety. All hired equipment must be registered and
inspected in accordance Massachusetts vehicle inspection requirements.
MassDOT has agreed to meet with the resource agencies including MassDEP, NHESP,
and the ACEC program coordinator on an annual basis to provide a brief update on
Snow and Ice Program. MassDOT will also consider completing an updated ESPR
every five years following the completion of the 2012 ESPR.
WalkBoston, submitted by Wendy Landman, Exec. Director dated September 27, 2006
Sidewalk snow
Removal
Walk-01
Sidewalk snow
Removal
Walk-02
Sidewalk snow
Removal
Walk-03
In several discussions within the GEIR, the MassHighway comes tantalizing close to
describing the potential impacts on pedestrian movement, yet there is no explicit
acknowledgement that pedestrians have a stake in the way the state removes ice and
snow from roadways and to the relationship between roadway and sidewalk snow and ice
clearance.
Pedestrians are clearly affected by the removal of snow from roadways and sidewalks and
the effects of inadequate clearance that results in unsafe conditions for walking. After a
snowfall in Massachusetts, it is possible to view the city or town streets0 are well plowed,
but the sidewalks are impassable. Common public services such postal deliveries and
meals of wheels can be disrupted. Commuters and school children find their routes
blocked/ Unblocked sidewalks0/can force pedestrians onto the street 0 Pedestrian access
at intersections are frequently blocked roadway related snow mounds00
The importance of providing safe pedestrian access in all season cannot be taken lightly.
It is a matter of public safety, adequate transportation, social justice (many of our citizens
who are pedestrians and transit-dependent are lower income or elderly), and economic
well-being (we discourage elders and the disabled from staying in Massachusetts if they
feel isolated and home-bound during wintry conditions).
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
17
MassDOT͛s responsibility for winter maintenance is the road surface from curb to
curb and does not include sidewalks – the responsibility of sidewalks is with the
municipalities that the MassDOT road traverses through. Similarly with the DCR roads
that MassDOT now maintains, MassDOT͛s responsibility is from curb line to curb line
and not the sidewalks according to the agreement with DCR.
So noted. See Response to Comment above. Snow removal of sidewalks is the
responsibility of local municipalities.
So noted. See Response to Comments above.
2/27/2012
Local Agencies (cont.)
Comment
Category
No.
WalkBoston (cont)
Sidewalk
snow
Removal
Walk-04
Sidewalk
Snow
Removal
Sidewalk
snow
Removal
Walk-05
Sidewalk
Snow
Removal
Walk-07
Sidewalk
snow
Removal
Walk -08
Walk-06
Comment
MassDOT Responses
The GEIR states. ͞It is the policy of MassHighway not to perform snow removal functions
on sidewalk areas abutting state highways or bridges. ͞ (!ppendix , h/ 5 of
MassHIghway͛s Maintenance Manual, Sec/ 5/3/8)/ This Policy does not seem to conform to
the MHD Project Development and Design Guide, 2006 Ed/ , which states. ͞MHD, in its role
as steward of our roadways, must consider a broad range of factors in maintaining
(emphasis added) or improving this system, including:
 Safety for all users
 Functionality – the need for access and mobility;
 Accessibility for people with disabilities.
 Input and participation from local constituents0/͟
The Manual quotes state law. ͞hapter 87 of the Acts of 1996 requires MassHighway to
make all reasonable provisions for the accommodations of the bicycle and pedestrian
traffic0/͟ (Sec/ 1/2/1, p/1-3). The Manual continues with this Guiding Principle:
͞Multimodel consideration – to ensure that the safety and mobility of all users of the
transportation system (pedestrians, bicyclists and drivers) are considered equally through
all phase of a project so that even the most vulnerable (e.g., children and the elderly) can
feel and be safe within the public right-of-way0͟
If snow and ice are not to be removed from sidewalks, as sated in the GEIR, this places the
GEIR at odds with the current state policy.
WalkBoston believes that the GEIR should be modified to show the methods by which the
state will ensure removal of snow and ice from all parts of the transportation system that
are within the rights-of-way.
So noted. The Project Development and Design Guide provides specifications and design
guidance for new roadways or major improvements to roadways. In other words, where
new roadways or major improvements are being designed, these factors referred to
would be included in the design. After full consideration of these factors as well as
impact to adjacent resources, the design may include a sidewalk that is set back from the
curb line and thus would be less impacted from roadway plowing operations. The Design
Guide was not intended to setting the policies for snow removal on existing roadways.
Streets can be designed to make plowing easier. Sidewalks might be placed at distance
from the roadway that is sufficient to accommodate snow plowed from the street. Snow
fences could be located to control buildup on pedestrian facilities and help reduce
removal costs. Pedestrian safety islands should be designed to remain snow-free after
plowing operations. The state should establish guidelines for improved design.
The GEIR contains documentation of lane-miles plowed by MassHighway or other
agencies. Perhaps research is necessary to document pedestrian miles on sidewalks along
sate roads and show how existing state plowing policies effect pedestrians and potential
changes to the policy might affect conditions. It would be useful to know what financial or
technical assistance the state may be available to provide to communities in helping to
clear sidewalks through sources such as CMAQ, safety or hazard elimination funds.
The method by which state and local coordination takes place is described briefly in
Section 2.5 of the GEIR, with subtopics of technology transfer and complaints. Some other
issues that should be addressed include; Division of Responsibilities (e.g. Intersections,
ramps, sidewalks, etc); Sidewalk snow removal procedures (e.g., standardizing the
process); Bartering; Information Sharing (e.g. RWIS data) and Communication with the
Public (e.g. the public should be informed of policy decisions concerning sidewalks, priority
routes, similar to the winter storm plan posted on DR͛s website/
Guidance for public involvement in project design is described in MassDOT͛s Project
Development and Design Guide.
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
18
So noted. See Response to Comments above.
So noted. See Response to Comment Walk-04 above.
So noted. See Response to Comments above.
2/27/2012
Local Agencies (cont.)
Comment
Category
No.
Comment
th
Richard F. Taylor, a member of the Boxford Board of Health, West Boxford, MA , letters dated Sept 18 and October 9, 2006
Salt Storage
and Private
Wells
Box-01
Salt
Remediation
Program
Box-02
Salt
Remediation
Program
Box-03
Env- Salt
Remediation
Program
Box-04
Salt
remediation
Program
Box-05
Runoff from the MassHighway salt storage shed as well as from I-95 has resulted in the
contamination of 31 private wells in the Town of Boxford. In addition, data are now available
which show increasing salt contamination of a pond used as a public water supply at
Andrews Farm, Boxford (DEP ID#3038020-01G). Water sampling over the last 10 years or
more have shown a gross increase in sodium and chloride levels in area private wells, rising in
some specific cases from than 20 ppm to more than 500 ppm sodium, and chloride contents
exceeding 1000 ppm.
Other indicator compounds such as calcium and manganese have also significantly increased
in the analysis of data from Boxford wells in the salt shed area. Such increases are well
documented from scientific studies on road salt effects and are known to indicate high salt
concentration ion exchange-mediated mobilization of heavy metals (including lead, cadmium
and mercury) and organics deposited along roadways (such as polyaromatic hydrocarbons)
into ground water and aquifers. High road salt concentrations may also extract and mobilize
soil and rock-bound arsenic, which is known to occur naturally in Boxford. The sodium
ferrcyanide used in road salt as a decaking agent is also of concern to the Board since it is
known to photolize to cyanide ions and pose a potential toxic threat in ponds and pools.
Without remedial action by MassHighway, such as moving the salt shed and adequately
controlling storm water runoff, we project that more wells, ponds, and aquifers will become
contaminated with salt; and with toxic materials released by high salt concentration form
soils, such as arsenic, heavy metals and organics.
MassHighway quotes on page 22, Sec 2.4 of the GEIR, MGL Title 14, chapter 85 Sec 7A, which
specifically prohibits storing͟0sodium chloride, calcium chloride or chemically treated
abrasives or other chemicals used for the removal of snow and ice on roads in such a manner
or places as to subject a water supply or groundwater supply to the risk of contaminants0͟
The law also specifically states that it applies to, among others, ͞0the chief engineer of the
state department of highways0͟ MHD further implies that it follows the state law. This
assertion is contrary to MHD͛s replies to oxford 0// and the press0 in that the law only
applies to uncovered salt piles and thus not to the facility in Boxford, which is covered. In
addition, requests by the oard of Selectmen to relocate this shed 0. have been dismissed by
MHD. Further, MHD is now nearing completion of plans to build a new storage shed and 0 at
the same site in Boxford.
We request that MEPA requires a specific plan from MHD to address known point sources of
salt contamination of aquifers and that this plan be included in the GEIR. We further ask that
MEPA require MHD adhere to MGL Title 14, Chap 85, and Sec 7A without exception.
MassHighway͛s GEIR is also deficient in addressing the manner in which it carries out its salt
remediation program (pg 18-22 of the GEIR). Our opinion is that this remediation program is
central of any GEIR and needs to be addressed in more detail/ 00 the program relocates
wells in areas where the aquifers are already contaminated, and ignores the point sources of
the pollution such as a salt shed. MHD also fails to address the environmental and property
damage caused by its well replacement program 0/ and particularly with respect to the state
and local wetland regulations͟ 0//
We request that MEPA require MHD to determine the extent of damage MHD has caused to
the surrounding aquifer and groundwater in Boxford and to propose a specific means to
eliminate these problems; and to ensure it will follow all state and local regulations, including
well installation and wetlands protection regulations, in any remediation program.
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
19
MassDOT Response
So noted. Starting in 2012, MassDOT will launch an extensive study to assess the
potential effects of its operations on the local groundwater quality. The study will be
conducted with input from representatives of the Town of Boxford.
Similar to iron, both calcium and manganese are also naturally occurring elements in
fractured bedrock and MassDOT is unaware of any demonstrated correlation between
the presence or absence of these elements with sodium and chloride. MassDOT, in
partnership with the Town of Boxford, will be launching an in-depth hydrogeological
study of the groundwater conditions within the affected area in the Town of Boxford.
This study will include extensive water quality sampling that may present findings that
can be used to address these questions.
See Response to Comment Box-01 above.
Starting in 2012, MassDOT will launch an extensive study to assess the potential effects
of its operations on the local groundwater quality. The study will be done in partnership
with the Town of Boxford.
See Response to Comment Box-01 Above regarding the pending 2012 study in Boxford.
2/27/2012
Public at Large
Comment
Category
No.
Ingeborg Uhlir, Weston, MA dated October 9, 2006
Operations
BMPs
UHLIR-01
Groundwater
/Surface
water
monitoring
UHLIR-02
Emergency
Response
Vegetation
UHLIR-03
Bridge
Damage
UHLIR-05
Agency
Coordination
UHLIR-06
UHLIR-04
Comment
MassDOT Response
Overall, some progress seems to have been made since the 1995 review. Investments in new
equipment and training are welcome. The trend should be continued and expanded.
MassDOT has expertise that can benefit local DPWs/ If you don͛t already offer these services
you might consider it:
1. Determining key locations for pavement temperature monitoring
2. Interpretation of monitor information
3. Calibration of equipment including rentals
4. GPS Location identification of vehicles
Integration of ongoing monitoring of certain watersheds under Section 61 Findings may be a
helpful cross-check of positive results achieved. This is particularly true for places where
state highways have major impacts on public water supplies. For example, sodium
concentrations at seven monitoring locations in the Hobbs Brook and Stony Brook
Watersheds are now the responsibility of CWD under the Sec 51 findings for EOEA #8263.
Since the data is retrieved twice a year with CWD, what actions, if any, are called for?
Another provision of the same 61 Findings calls for MHD updates of Emergency Response
Maps every three years. Is this current?
Has information reported in this current GEIR about relative salt-tolerance among trees and
shrubs been shared with local tree wardens? Does the Michigan DOT information agree with
that of the Salt Institute?
Damage to roads and bridges due to salt is only beginning to be compiled. Recent events
have highlighted dangers from falling structural members as a growing problem. The
tendency has been to do quick fixes like patching surfaces. That is the ostrich approach to a
pervasive problem. The bridge that spans Route 9 just west of Route I-195 in Wellesley is
wrapped in netting. Great chunks of concrete have separated from the upper parts of the
bridge/ They pose a real threat to any vehicle and passengers0//How widespread is the use
of netting?
Previous GEIR͛s on Snow and Ice ontrol Programs contained information about MT!, MD,
and MTA practices. Have these been integrated into the information presented by MHD? If
not, do they report to any agency and to the public?
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
20
MassDOT is committed to continuing along this trend of improving its application
efficiency and incorporating other technologies to reduce the amount of salt used for
deicing purposes. MassDOT has installed RWIS to get more accurate data on pavement
conditions in multiple locations and has also incorporated the use of GIS locators for
vehicles. MassDOT has also improved its spreader calibration methods. Additional
technology and equipment updates will be included in the future ESPR.
With regard to monitoring data, see Response to the very next Comment below.
MassDOT has helped fund the monitoring efforts in the CWD watershed through
contractual arrangements with the USGS and the UMass Engineering Dept. As noted
above, MassDOT has met with CWD representatives as recently as August 2011 and will
continue to coordinate on at least an annual basis. MassDOT has incorporated several
newer technologies and evaluating others such as the use of friction meter to monitor
road surface conditions during storm events. MassDOT will continue to seek ways to
minimize its salt use in this watershed. It is important to point out that the observed
sodium and chloride concentrations in this watershed are also influenced by the road salt
used on municipal roads and the numerous commercial parking lots in this watershed.
The Emergency Response Mapping is up date d by the Cambridge Water District and not
MassDOT.
Much of the information reported in salt-tolerances was provided by UMass Cooperative
Extension Service, whose specialists generally have a pretty close relationship with the
local tree farmers and foresters in the region.
The use of netting to capture potentially falling debris beneath deteriorating bridges is not
a widely used practice as is used only as an interim measure. It must be recognized that a
major bridge repair or full replacement often requires a detailed design study that
includes preliminary and final design, environmentally permitting and a contractor bidding
phase, all of which can all take 18 to 24 months or more, depending on the situation. As
discussed in the ESPR, MassDOT had recently initiated an Accelerated Bridge Repair
/Replacement Program to prioritize and speed up the replacement of existing red-listed
bridges.
During the development of the Draft ESPR, other transportation agencies were contacted
such as the MBTA, Massport and DCR to obtain information about their deicing practices.
MBTA was the only agency that provided some information on their winter maintenance,
which focused primarily on their commuter parking lots.
2/27/2012
Public at Large (cont.)
Comment
Category
No.
Comment
Stephen H. Kaiser, PhD, member of Road Salt Task Force, 1985-1996, submitted Sept. 22, 2006
MassDOT Response
Level of
Service
KSR-01
Safety Issues
KSR-02
[paraphrased] There has been little to no data presented in the current or
previous GEIRs that shows a clear connection between the use of road salt and
improved road safety/ ͞The current GEIR on pages 85-89 represents an extremely
retrogressive step in safety analysis. Four sources of data are identified – all of
them funded by the Salt Institute. In addition, there is a reference to the Salt and
Highway Deicing Newsletter which I presume is an industry publication.
Cost-Benefit
Analysis
KSR-03
For energy savings, the GEIR again quotes the Salt Institute as its source where
there is no justification in the literature search demonstrating that ͞the impacts of
salt applications on flora, fauna, agriculture, tourism, sugar maples, cranberry
bogs, and recreation are not significant in Massachusetts (pg 93)
Additional
Road miles
maintained by
MHD
KSR-04
The GEIR states that the number of lane-miles maintained by MassHighway has
increased from 7,060 lane-miles in 1976 to 13,286 lane-miles in 2006. What
accounts for all this additional roadway since there seems to have been very few
additional roadways constructed over the last 20 to 30 years? [paraphrased]
Cost-benefit
Analysis
KSR-05
There remains a need to provide a comprehensive cost-benefit analysis of road
salting.
a) The primary mandate for the S&I Control Program comes from M.G.L. Chapter
81, Section 19 authorizing and directing the highway department to keep state
highways ͞sufficiently clear of ice and snow to be reasonably safe for travel͟/
Neither the Manual nor the GEIR provides a clear explanation of what
͞reasonably safe͟ means/
b) The policy adopted MHD is to maintain the entire width of paved roadways
and shoulders of all roads/. cleared of snow and free of ice as far as
reasonable expenditure of funds will permit. The standard raises
questions as to whether ͞bare pavement͟ is the goal or whether there
should be ͞preemptive salting͟ whereby dry roods are salted in anticipation
of snow.
c) Has the MassHighway definition of ͞reasonably safe͟ changed from the allplowing concept of the 1930͛s, and if so, in what way?
MassDOT Responses to 2006 GEIR Comments -Feb-2012.docx
21
a) The term ͞reasonably safe͟ involves personal judgment on the part of the vehicle operator
and therefore is subject to broad interpretation but it is intended to mean providing road
conditions that allow motorists to maintain vehicle mobility and control at speeds well
below posted speed limits while using safe driving techniques.
b) The ͞entire width ͞refers to the width of travel lanes only. Breakdown lanes and shoulder
areas are generally not cleared and treated until near the end of the storm. MassDOT does
not have a ͞bare pavement͟ policy where road surfaces are expected to be entirely free of
snow and ice during snow events.
c) The definition of ͞reasonably safe͟ has not changed but the tools available to meet this goal
have changed. Plowing is still the primary means of snow removal; however, plowing alone
is not always sufficient to prevent ice and snow from bonding to the pavement. Recently,
MassDOT has gone to an anti-icing approach and has increased its use of liquid brine
solutions for pretreatment applications to prevent snow and ice from bonding to pavement.
Liquid brine is much more effective than dry salt for pretreatment applications.
The Draft ESPR cites and summarizes a number of studies that have demonstrated a causal link
between winter weather and increased vehicle accident rates. Admittedly, fewer studies have
studied the actual benefits or the effects of snow and ice operations on vehicle accident rates but
one study was done the University of Marquette Engineering Department and another study
conducted by the Idaho Department of Transportation reported an 84 percent decrease in year to
year accident rates after switching to an anti-icing approach. The Marquette study concluded that
on average there was approximately $6.50 in direct benefits in terms of reduced accident rates
and associated costs for $1.00 spent on winter maintenance activities.
MassDOT recognizes that snow and ice operations can pose potential adverse risks to
environmental resources. However, as discussed above, MassDOT has adopted numerous
measures to reduce the amount of deicer material it uses and continues to work with the affected
parties to lessen and remediate reported negative impacts. On a statewide basis, MassDOT does
not believe that its snow and ice practices are having widespread deleterious impacts, particularly
with water supplies; otherwise, there would be a much greater level of complaints and/or public
outcry throughout the years or during this GEIR review process.
The basis for the 1976 estimate of roadway lane miles is not known at this time. The discrepancy in
the number between 1976 and 2006 may be due in part to differences in the way lane miles and
center-lane miles were defined after 30 years. With the advent of GIS technology in the 1990͛s,
the accuracy and accounting of this data has greatly improved. The number of lane miles
incrementally increase each year as roads are widened with either new travel lanes or turning
lanes. Many roadways have added turning lanes especially at major intersections. In the last 5
years since 2006, MassDOT͛s road network for winter maintenance has increased by
approximately 2,700 lane-miles, with more than 50 percent of the increase due to assuming
responsibility of I-90 and more DCR roads.
MassDOT is currently participating in a multi-state, pooled research study sponsored by the Clear
Roads Program designed to update the ͞true cost͟ of snow and ice practices by accounting for
both the costs and benefits. This study is not expected to be completed until 2013 and the results
will be included in future report updates.
2/27/2012