The MDC has been plagued by a number of management issues that have 
remained unresolved for the last ten to fifteen years. Basically, it has been a case study 
of management at its worst. The management issues that are most outstanding involve 
three areas: (1) determination of a level of treatment that the MDC facilities will 
provide, (2) the siting of new treatment facilities, and (3) the disposal of sewage sludge. 
There have been many reasons for the delay in resolving these issues, but I feel 
that four of them are most pertinent. The first is simply the magnitude of the system. 
The service area is so large that to resolve the issues takes more time than it would if you 
were dealing with smaller systems that discharge 1 to 3 mgd. Secondly, the issues have 
been the subject of a great deal of public controversy that has impeded reaching 
decisions. It has been difficult reaching a consensus as to compliance with the 
environmental regulations and to equitable distribution of responsibility in providing 
sewage services for the 43 communities. Another important factor in the delay has been 
that during the last 10 to 15 years, environmental impact assessments have changed as the 
various regulatory requirements have been revised both for water quality and air quality. 
Lastly, in the intervening years, new scientific information has prompted better and 
different management decisions. 
Now I would like to discuss three of the main management issues that have 
been prominant in the Boston Harbor cleanup effort, including a chronology of events and 
a brief update of more recent developments. First, a long history involving the 301(h) 
waiver process has determined the level of treatment that the MDC facilities should 
provide. The MDC applied for its initial waiver from secondary treatment requirements 
in 1979. Following this application, the U.S. Environmental Protection Agency (EPA) 
requested that the MDC submit more technical information on the assessment of potential 
biological impacts. This information was provided in 1982. Following analysis of this 
supplemental information, EPA issued a tentative denial of the application in 1983 based 
on questions of whether the primary discharge would be able to meet dissolved oxygen 
requirements and whether it would also adversely impact benthic organisms in the marine 
environment near the proposed effluent discharge site. 
When faced with this decision, the MDC exercised its right under the 301(h) 
administrative regulations to reapply for a waiver and submitted a revised application. 
This revised application, submitted in 1984, included a new deep-ocean outfall site at a 
different location than proposed in the first application. In April 1985, the EPA again 
issued a tentative denial for basically the same reasons that it denied the first 
application. We see that just to resolve the level of treatment the plants are to provide 
has taken six years. Now that the tentative denial has been issued, EPA will next issue a 
draft discharge permit. At this stage, there will be opportunity for public comment and 
for the MDC to contest the denial decision. Ultimately, the drafting of the permit is 
what will determine the level of treatment required and specifically, what effluent 
limitations the MDC system will have to meet. 
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