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HomeMy WebLinkAboutHuman Health Impacts - comments Rev2a FINAL - jkPage | Human Health Impacts - 1 Rev2a HUMAN HEALTH IMPACTS 1 According to the DEIS the “repair, maintenance, fueling, washing and detailing of boats would occur in the same manner as they currently do on-site. Repair and maintenance would occur within the on-site buildings and/or at the existing dock” (emphasis added) (pp. xxvii, 279). This sentence is ambiguous in that it is unclear whether it means repair and maintenance activities will continue to occur only within presently on-site buildings, or if on-site buildings include the proposed storage buildings. The DEIS states that it “is noted that the proposed action would not alter the maximum amounts of chemicals and antifouling paint stored onsite” (pp. xxviii, 279). The DEIS also states that “[n]o changes to chemical storage nor chemical storage volumes are anticipated as part of the proposed action” (p.90), and that the “proposed action would not require SYC to modify its current quantities of chemicals stored onsite nor require additional chemicals be stored on-site” (pp. xv, 190). However, other statements in the DEIS call these statements into question. The DEIS states that “new employees would be for the boatyard only and include positions for boat maintenance, machinery operators, engine technicians, administrative, and wood and fiberglass re- finishing personnel” (pp. xxviii, 20, 279) and “the proposed action would create new jobs for the servicing of the larger vessels to be stored on-site,” (p.178). Many (most?) of the newly created jobs would presumably be related to the servicing of boats stored inside the new storage buildings. It is difficult to reconcile this with the statement that the amount of chemicals stored on site will not increase. This inconsistency is also supported by the fact that the scale of maintenance and repair activities will increase significantly as a result of the proposed Project. This is evident from the fact that in 2020 SYC revenues from boat servicing totaled $1,262,936, but will increase more than 40% to an estimated $1,800,000 in 2024 if the Project is completed. It is also noted that the Planning Board also believed that the proposed Project would necessitate an increase in the volume of chemicals stored on site. This is evident from the DEIS Scope requirement that the applicant provide “an analysis on the chemicals stored and disposed on site and the potential adverse impacts from the increase in volume of chemicals used and stored on site during the proposed action” (emphasis added) (DEIS Scope p.11). The DEIS notes that “SYC maintains an Article 12 Permit from SCDHS dated September 1, 2017 for the storage of hazardous materials at the subject property (see Appendix J)” (pp. 51, also pp. 160, 188), and states that because there “are no changes proposed to the existing tanks or volume of materials stored on-site. . . no additional Article 12 permitting [is] required for the proposed action” (p. 77). The DIES also states that the “current Article 12 permit issued by SCDHS on September 1, 2017 would not be adjusted” (p.190). A copy of SYC’s Article 12 permit is included in DEIS Appendix J. Condition 1 of the permit states that “This site operating permit does not imply that each individual storage unit at the site is in compliance 1 The DEIS discusses the SYC Fire Safety Plan as part of its mitigation of the Project’s potential impacts on human health (p.187). The significant deficiencies in this plan are discussed as part of other comments relating to fire and public safety. Page | Human Health Impacts - 2 Rev2a with all applicable codes.” Permit Condition 3 states that the permit “is limited to storage unit(s) listed on the latest renewal/invoice notice. That list is made a part of this permit.” This information is not included with the copy of the Article 12 permit included in the DEIS. DEIS Table 13 (and DEIS Appendix M Table 3) is a list of “On-Site Stored Chemicals for Boat Maintenance, Repair and Detailing.” According to the SYC website,2 (COMMENT FIGURE - HEALTH 1) on-site services offered by SYC include “Gelcoat Refinishing.” According a manufacturer’s Material Safety Data Sheet (MSDS), Gelcoat is considered hazardous by the OSHA Hazard Communication Standard (29 CFR 1910.1200).3 Gelcoat does not appear among the list (DEIS Table 13) of on-site stored chemicals. The DEIS states that “The proposed action would not require SYC to modify its current quantities of antifouling paint stored on-site as painting services would not be offered to customers storing yachts in Buildings 9 and 10” [proposed storage buildings 1 and 2] (p.190). However, no such statement in regard to Gelcoat refinishing services, or other maintenance activities, is included in the DEIS.4 This is concerning since the DEIS states that new employees hired if the Project proceeds will include “wood and fiberglass re-finishing personnel.” The latter activity involves the use of Gelcoat. 2 https://strongsmarine.com/strongs_yacht_location 3 https://www.sherfab.com/assets/images/LILLY%20RAM%20W-1%20WHITE%20%20GELCOAT%20%20SDS.pdf 4Under the heading “Battery and Engine Oil Storage “, in the DEIS section dealing with toxic and hazardous material stored at SYC, the DEIS states that the “proposed action would not require SYC to modify its current quantities of antifouling paint stored on-site as painting services would not be offered to customers storing yachts in Buildings 9 and 10.” This is presumably an editorial error, but it leaves unanswered of what types of maintenance services will be offered to customers storing yachts in the proposed storage structures, and if those services would generate hazardous wastes. Page | Human Health Impacts - 3 Rev2a COMMENT FIGURE - HEALTH 1 https://strongsmarine.com/strongs_yacht_location (accessed May 12, 2023).