Below are some pertinent pages from the draft permit, click on thumbnails.
A. general terms B. Inflow&Infiltration C. Effluent Limits
Below are pages from the EPA fact sheets which accompany and explain the permit.
A. General facts B. Plant data C. Map of plant site
Below are some useful links
Glossary of commonly used terms (courtesy of Ma Riverways) Here
Information on nutrient pollution HERE
Flow info 7Q10 HERE
Short, Simple, Sample Comments HERE
Our Final Comments
An EPA Friend of mine once told me "Hugs are nice, but they don't clean up rivers"
U.S. EPA
Office of Ecosystem Protection
1 Congress Street, Suite 1100 (CPE)
Boston, MA 02114-2023
Public Notice Number: MA-033-04
Permit Number: MA0101010: Brockton Advanced Water Reclamation Facility
The process which we use to attain the goals set forth in the Clean Water Act has been twisted into an unrecognizable mess in regard to this plant and more importantly the river system which receives its toxic flow. Toxic flow is an appropriate term in regard to this plants discharge. In fact EPA recognized and acknowledged this in their own 2003 press release, " Inspections by EPA and the Massachusetts Department of Environmental Protection (DEP) and the plant's own reports document equipment failures, operator errors, chemical feed problems and chronic bypassing of treatment equipment at the plant. This has led to excessive discharges of sewage solids, bacteria, ammonia and chlorine into the river, which flows to the Matfield River which downstream becomes the Taunton River." In 2001 when all of the above was taking place an employee of the MA DEP, Lakeville office, who is intimately familiar with the plant told me in a phone conversation, " that’s good water coming out of the plant." In the spring of 2003 while at the Lakeville MA DEP office I had the privilege of conversing with a different mid level DEP employee who was "familiar" with the Brockton Sewer Plant and Salisbury Plain River. It was an enlightening conversation. He explained to me that more "water" from the plant was better for the river, " Without the plants discharge of "water" the river below would dry up and become a trickle." (As if pumping your septic system into your neighbors well would be considered a charitable act.) This is merely a sample of the idiocy one has to deal with when entering the Ma DEP regulatory hall of mirrors surrounding the Brockton Sewer Plant.
Page #4 NPDES Permit # MA0101010 paragraph #3; Flows originating from the Towns of Abington and Whitman are limited each to 1MGD. The permitte shall not accept any new sewer connections in other communities from facilities not currently connected to the WWTP. Increased flows from facilities currently connected to the WWTP shall be offset, to the extent feasible, in order to minimize any net increase in flow to the WWTP.
"The permitte shall not accept any new sewer connections in other communities from facilities not currently connected to the WWTP." We feel flow is the essence of this permit. If EPA does not incorporate this one sentence, and this simple language into the final permit it will gut the Federal Clean Water Act, hamstring it, and hang it from a gin pole to rot. This language must be accompanied by flow limits which will reduce the flow pf effluent into the receiving waters. At what point does a river cease to be a river to become a sluiceway for effluent? Naturally, being the simplest language in the draft permit, it also appears to be the most controversial.
The cry of foul has been heard emanating from the bowels of surrounding communities whom are eager to hook up to the Brockton Sewer Plant. East Bridgewater, Easton and West Bridgewater, Oh woe, we need the services of the Brockton Sewer Plant to solve our septic problems.
At what point does a river cease to be a river to become a sluiceway for effluent?
August 2002 Salisbury Plain River flow above plant 1.94 MGD (ESS NPS study 2002 Attachment 1 8/7/02 sample site SPR2), Plant flow "good water Ma DEP 2001" 14.28 MGD, Beaver Brook 0.01 MGD, Meadow Brook 1.18 MGD, Satucket 1.6 MGD below Satucket there are no tributaries of any significant size or flow until the Matfield’s confluence with the Town River. This is approximately eight miles of river. River water 4.73 MGD, Effluent 14.28 MGD, are Salisbury Plain and Matfield, rivers, or are they sluiceways for effluent?
Projected future flow 2025, (City of Brockton Facilities Assessment Report, Camp Dresser McKee 2002, Page 8 Attachment #2) 22.2 MGD. (This figure assumes no additional hookups to outside communities and does not consider 4 MGD of additional water to Brockton from proposed freshwater de sal plant.) Plant flow August 2025, 22.2 MGD (probably still "good water" Ma DEP) Salisbury Plain River flow above plant 1.94 MGD, Beaver Brook 0.01 MGD, Meadow Brook 1.18 MGD, Satucket 1.6 MGD below Satucket there are no tributaries of any significant size or flow until the Matfield’s confluence with the Town River. This is approximately eight miles of river. River water 4.73 MGD, Effluent 22.2 MGD, are Salisbury Plain and Matfield, rivers, or are they sluiceways for effluent?
Upon completion of this plants proposed EXPANSION and upgrade
it will have a capacity of 20.5 MGD. There is no, and will be no capacity for additional flow at this plant from outside communities unless it is expanded beyond what is currently proposed! The following is a quote from David Norton, Brockton's interim Department of Public Works commissioner. It’s from a June 2004 Brockton Enterprise article regarding the septic woes of the above mentioned towns."Expanded connections with other towns would offer some benefits to the city, Norton said. If the regulatory agencies approve a regional system, federal funding may come easier, and it could open the door to other funding sources. Even so, the city's current plant, even with the planned upgrades, would have to be expanded, he said."
What, exactly are the towns of East Bridgewater, Easton and West Bridgewater planning to do? What are their projected future flows? What parts of their towns are going to be sewered? How large will the plant have to be to accommodate their flows into the year 2025 and beyond? It’s ridiculous to even be going through this mind numbing exercise thirty odd years after the passage of the Federal Clean Water Act.
The most fundamental concept of the Federal Clean Water Act and a concept embraced by most everyone from the greenest cub scout to Neanderthal Man is that you don’t crap upstream of your campsite. Furthermore, in the case of the environmentally enlightened hamlet of Easton, you should not, out of common courtesy, crap upstream of your neighbors campsite. Despite these seemingly simple realities and courtesies these communities seem hell bent on defecating all over themselves and their neighbors.
Over the past several years the City of Brockton has been pulling every political string possible to have a freshwater de sal plant built in Dighton at the base of the Taunton River. This plant will supply the city with drinking water, a well of sorts? Over the past several years the City of Brockton has also been pulling every political and legal string possible to expand and regionalize their sewer plant at the top of the Taunton River, a toilet of sorts?
Salisbury Plain and Matfield Rivers are the largest rivers in East Bridgewater. They run through the heart of the town. Since the Brockton Sewer Plant was built, and to this very day East Bridgewater and it’s largest river have been and continue to be the City of Brockton’s toilet. Today rather than being offended by this indignity and trying to clean up this toilet of Brockton, East Bridgewater has apparently chosen to elbow their way onto this porcelain throne alongside their neighbors. What a disgusting spectacle.
These communities have options, EPA has indicated that large centralized sewer plants emptying into small river systems were mistakes. The Brockton plant is a classic example of such a plant. One only needs to spend some time in the waters of these rivers, through a season, to see the havoc that has been wreaked on a once diverse and bountiful ecosystem. The towns of East Bridgewater, Easton and West Bridgewater can build their own plants. Better yet they could partner with Brockton to build modern, smaller regional plants which would recycle the effluent or put it back in the ground. All of these communities have streams which suffer the consequences of heavy water withdrawals. Canoe River, Queset Brook, Stump Brook, Satucket, Beaver Brook, West Meadow Brook, all have dried up in seasons past. Today in 2004 we need to be looking forward in our quest for water, in both its use and disposal. The Brockton Sewer Plant "solution" may be economically attractive, however its environmental impacts have been and will continue to be devastating in the future.
Much of the above may be irrelevant to this permit process. I don’t know? It’s really not meant to be offensive either, although it will sound that way to many. In many ways the Clean Water Act is an act to protect us from our own ignorance. Who would argue that our practices regarding our water before the Clean Water Act were not ignorant? We must begin reducing flows here. To do otherwise would be unconscionable and an affront to the Federal Clean Water Act and to the Public Trust in which all our rivers are held.
NPDES Permit #MA0101010 Page #6 Part I.A.I Line A
a. "The discharge shall not cause a violation of the water quality standards in the receiving waters".
This permit requirement clearly states that this plants discharge will not cause a violation of the water quality standards in the receiving waters. If the final permit is reflective of this draft permit it will clearly cause a violation of the receiving waters Class B standard. This has been the case for twenty odd years and will be the case for twenty more if EPA continues issuing permits like this one.
Is the above language required by law to be in the final permit?
If so, will the plants flow violate the water quality standards of the receiving waters upon issuance of this final permit?
According to this plants 1999 NPDES Permit (Attachment 3) the instream 7Q10 flow of the receiving waters is 0.39 MGD at the plant. Can a stream with a flow of 0.39 MGD assimilate an effluent flow of approximately 20 MGD?
Considering MA EOEA has approved an upgrade and expansion of this plant which will increase its discharge by 2.5 MGD to total capacity of 20.5 MGD, does EPA feel this draft permit contains limits stringent enough to allow the receiving waters to attain its assigned standard?
Does this draft permit lay the groundwork to move incrementally closer to attaining this standard in a timely fashion?
EPA has indicated through personal communication that the receiving waters will probably not attain their assigned standards for 50 or 100 years. While we fully recognize that achieving the goals of the Clean Water Act is an incremental process, we do not believe it is reasonable to wait eighty or one hundred and thirty years after passage of the Clean Water Act for attainment to be realized.
Does EPA feel that fifty or one hundred years is a reasonable amount of time to achieve attainment?
Does EPA feel the intent of the Clean Water Act was to maybe achieve attainment eighty or one hundred and thirty years after its passage?
If EPA does not feel this is a reasonable amount of time then how does EPA justify issuing a permit which does not bring us incrementally closer to attainment?
What does EPA consider a reasonable amount of time to achieve attainment?
Neither this draft permit or the proposed upgrade to the plant will allow Salisbury Plain River to meet its Class B water quality standard. More disturbing is the fact that this permit and the proposed upgrade offer no hope of it meeting this standard in the foreseeable future or beyond. Whether or not line (a) is a requirement of this permit is irrelevant, the broader laws clearly dictate that Salisbury Plain must at some point in time meet its attainment goal of a Class B waterway.
Flow is the primary limiting factor. Without significant flow reductions the Salisbury Plain will not meet its assigned standard.
August 2002: Salisbury Plain River flow above plant 1.94 MGD. (Actual flow above sewer plant as recorded by the ESS Group, Matfield and Salisbury Plain Non Point Source Pollution Study 2002 Attachment 1)
August 7 2002 Brockton WWTP discharge: 14.28 MGD.
(From Brockton AWRF records for 2002-2003 Attachment 4)
Dilution (stream flow: plant discharge): 1:7.36
August 2002 Salisbury Plain River flow above plant plus tributaries entering
Matfield River below plant: 4.73 MGD (Actual flow above sewer plant as recorded
by the ESS Group, Matfield and Salisbury Plain Non Point Source Pollution Study
2002 see CD #1 and Bridgewater State College Watershed Access Lab Overnight
Nutrient Studies 2002 see CD #2)
August 2002 Brockton WWTP discharge: 14.28 MGD (From Brockton AWRF records for
2002-2003 Attachment 4)
Dilution in Matfield River (stream flow: plant discharge): 1:3.22
Using the EPA 7Q10 figure of 0.39 combined with the future estimated plant flow of 20.5 MGD provides the following figures.
Salisbury Plain River flow above plant 0.39 MGD (City of Brockton WWTP1999 NPDES Permit Attachment 3)
Brockton WWTP discharge 20.5 MGD
Dilution (stream flow: plant discharge) 1:52.5
What possible chance does this stream have of meeting its assigned standard with this dilution?
Does EPA agree that this is unacceptable dilution?
At what point does a river cease to be a river to become a sluiceway for effluent? This is a serious and relevant question given the flow figures above.
This formula of increased plant flow coupled with I&I reduction has serious implications for the future of the receiving waters.
When you review the actual daily effluent flows from the plant as opposed to the average flow, there appears to be a significant drop in plant effluent flows during periods of low water. In effect the plants flow appears to fluctuate with the rising and lowering of groundwater levels. In periods of high groundwater the plants flow goes up due to infiltration. In periods of low water the flow appears to drop significantly (see attached daily plant flows, Attachment 4). According to Brockton WWTP flow data 2002-2003 between the months of June and mid September actual plant effluent flows dropped well below 18 mgd for significant periods of time. If this infiltration flow is reduced and then replaced by a constant year round flow of 20.5 MGD it could have a devastating impact on the already failing aquatic ecosystem of the Salisbury Plain, Matfield and Taunton Rivers. Again, according to actual daily plant flows the plant’s flow drops below 13 MGD during low summer flows. If in the future flow becomes steady at 20.5 MGD there will be up to an additional 7 MGD of effluent entering the river system when it is most stressed. This would be the equivalent of adding six new treatment plants about the size of the Middleboro WWTP.
One could reasonably argue that during low flow periods the headwaters of the Matfield and Upper Taunton Rivers are the Brockton WWTP. While the physical discharge of the plant is at the plant site, the overwhelming dominance of its flow has the effect of turning the Salisbury Plain River into an extended sluice way comprised of 99% effluent. This in turn becomes the Matfield River and then further down stream the Taunton River.
"USGS partial recording station stream flow data for similar-sized streams in the Taunton River Basin suggest that the naturally occurring 7Q2 at the site locale without augmentation by the City of Brockton AWRF would be approximately 1.7 cfs. The 7Q10 at this point on the Salisbury Plain River would be approximately 0.6 cfs. USGS long-term monitoring of streams throughout the basin suggests a naturally-occurring minimum monthly mean flow of 0.8 cfs in this segment of the Salisbury Plain River." (Epsilon Associates, inc 1998 water resources 29298/deir/Sec5.8water.doc Attachment 5)
According to Brockton Advanced Wastewater Treatment Facility Upgrades Environmental Notification Form September 2003 (Attachment 6) average historical flow (98-02) is 19.79 MGD. Projected flow (2025) is 20.49 MGD. Based on the figure 19.79 the following summarizes the amount of effluent in the receiving waters.
(98-02) equals 19.79 mgd or 30.5 cfs there is a mixture of 927 thousand gallons of river water (0.6 cfs divided by .647 = 927 TGD) to 19.79 million gallons per day of effluent during periods of low flow. In other words the Salisbury Plain below the Brockton AWRF is a river of effluent. Unfortunately the Brockton AWRF impacts do not end with the Salisbury Plain. According to USGS Survey Water-Resources Investigations Report 84-4283 the Salisbury Plains major tributary Beaver Brook has a 7Q10 of .6 cfs or 463 thousand gallons per day. Where the Salisbury Plain and Beaver Brook conjoin is the beginning of the Matfield River. Therefore at the beginning of the Matfield River the approximate mix of effluent to water is 1.4 mgd water to 19.79 mgd effluent during low flows. Therefore at this point 2.2 miles downstream of the Brockton AWRF the river is little more than a river of effluent. The next significant down stream tributary (in terms of flow contribution) to the Matfield River is the Satucket River. Satucket is approximately 3 miles downstream from the confluence of the Salisbury Plain and Beaver Brook According to USGS Survey Water-Resources Investigations Report 84-4283 Satucket’s 7Q10 is 1.3 cfs or approximately 2 mgd. Therefore at this river junction the ratio of water to effluent is approximately 3.3 mgd water to 19.79 mgd effluent during periods of low flow. Therefore at this point approximately 5.2 miles downstream of the Brockton AWRF the river is little more than a river of effluent. Down stream of Satucket approximately 8.2 miles from the Brockton AWRF the Matfield River joins the Town River to become the Taunton River. According to USGS Survey Water-Resources Investigations Report 84-4283 the Town River’s 7Q10 is 2.7 cfs or 4.1 mgd. Therefore at this river junction the ratio of water to effluent is approximately 7.4 mgd water to 19.79 mgd effluent during low flows. Therefore at this point approximately 8.2 miles downstream of the Brockton AWRF the river is little more than a river of effluent. The next down stream tributary is the Winnetuxet River which is several miles below the confluence of the Town and Matfield River. According to USGS Survey Water-Resources Investigations Report 84-4283 the Winnetuxet has a 7Q10 of 7.8 cfs or 5 mgd. Therefore at this river junction some 14 miles from the Brockton AWRF the ratio of water to effluent is approximately 12.4 mgd water to 19.79 mgd effluent.
For comparison we will compare actual Brockton dilution to the minimum dilution ratios required by the State of Maine.
Before embarking on this futile exercise we would like to make note of this and request clarification on how EPA calculates dilution ratios. It is our understanding that EPA assumes the effluent discharge dilutes itself upon discharge into the receiving waters. In other words they add the effluent flow to the stream flow and then calculate dilution, rather than taking the actual stream flow and dividing it by effluent discharge.
Is the above a fair all be it simplified representation of EPA methods?
If so the evidence of its effectiveness is clear in the filthy polluted water that fouls the receiving waters.
How can effluent dilute itself?
If the stream flow is 0.39 MGD, and plant flow is 20.5 then the dilution ratio is (stream flow: plant discharge) 1:52.5 period.
Did Joseph Heller write the EPA formula for calculating dilution?
The lowest allowable dilution rate we found for plants on small streams is 5.2:1 (stream flow :plant flow) at 7Q10 (10-year drought conditions) at the Limestone, Maine WWTP. At normal flows, the dilution rate for that plant is 13.3:1. Limestone Stream is about the size of the Salisbury Plain.
To achieve even a 5:1 dilution ratio on the
Salisbury Plain River at August 2002 flows (stream flow = about 2 MGD), the
total Brockton plant discharge would have to be reduced to 0.4 MGD -- which is
2.8 percent of existing plant flows, representing a 97.2 percent REDUCTION in
existing plant flows.
The minimum dilution ratios required in the Maine permits for small streams
range from 11:1, 13:1, 18:1, 20:1, 32:1, 50:1, 75:1, 100:1 or 150:1 (stream
flow: plant flow).
Based on the above, let's use a 20:1 dilution ratio as the 'average' minimum
dilution ratio for the Maine WWTPs located on streams of similar size as the
Salisbury Plain River. For August 2002 data (Salisbury Plain flow at 2 MGD),the
total Brockton plant discharge would have to be reduced to less than 0.1 MGD --
which is 0.7 percent of existing plant flows, representing a 99.3
percent reduction in existing plant flows.
Flow Limits and Dilution Requirements Included In
Recently Issued NPDES Discharge Licenses for
State of Maine POTWs Discharging into Small Rivers and Streams
Source: NPDES Licenses on file at Maine Department of Environmental
Protection, State House Station 17, Augusta, ME 04333.
1. Mars Hill POTW, Mars Hill, Maine.
Receiving water: Prestile Stream (Class B waterway)
MEPDES ID No.: ME0101079
License issued: December 10, 2002.
Maximum allowed discharge: 1.0 MGD
Flow limitations:
50:1 flow dilution from March 1 to May 31 and Oct. 1 to Nov. 30.
75:1 flow dilution from June 1 to Sept. 30 and Dec. 1 to Feb. 28.
2. Sanford POTW, Sanford, Maine
Receiving water: Mousam River (Class C waterway)
MEPDES ID No.: ME0100617
License issued: Feb. 2, 2002
Maximum allowed discharge: 5.5 MGD
Flow limitations:
Tier I discharge limits (prior to June 1, 2005)
a) No discharge allowed when river flow is less than 10 cfs.
b) 5.5 MGD from Nov. 1 to April 30.
c) 3.48 MGD from June 1 to Oct. 31.
Tier II discharge limits (beginning June 1, 2005):
a) No discharge allowed when river flow is less than 20 cfs.
b) 4.4 MGD from Oct. 1 to April 30.
c) 3.48 MGD from May 1 to Sept. 30.
Tier III discharge limits (beginning Jan. 1, 2006)
same as Tier II except discharge of up to 8.8 MDG allowed from Feb. 15 to
April 15 but ONLY if river flow exceeds 100 cfs.
3. Thomaston POTW, Thomaston, Maine.
Receiving water: St. George River (marine estuary)
MEPDES ID No.: ME0100668
License Issued: March 23, 2003
Maximum allowed discharge: 0.9 MGD
Flow limitations:
Discharge of 0.9 MGD allowed in Jan., Feb., March. only.
No in-river discharge allowed from April 15 to Nov. 15;
Must use land-based, spray irrigation system April - November.
4. Canton POTW, Canton, Maine.
Receiving water: Whitney Brook (Class B waterway)
MEPDES ID No.: ME0102067
License Issued: February 3, 2003
Maximum allowed discharge: 0.25 MGD
Flow limitations:
No discharge allowed at stream flow is less than 20 cfs.
Must maintain 53:1 dilution ratio at all times.
5. Clinton POTW, Clinton, Maine
Receiving water: Sebasticook River (Class C waterway)
MEPDES ID No.: ME0101699
License Issued: February 14, 2003
Maximum allowed discharge: 0.35 MGD
Flow limitations:
No discharge between June 1 and Sept. 30
when river flow is less than 65 cfs.
6. Corinna POTW, Corinna, Maine.
Receiving water: East Branch Sebasticook River (Class C waterway)
MEPDES ID No.: W-002179.
Maximum allowed discharge: 0.2 MGD
Flow dilution at 7Q10: 11.6: 1
Flow dilution at harmonic mean: 32.7: 1
Note: POTW now in process of converting to land-based,
spray irrigation and cessation of in-river discharge
(Gregg Wood, P.E., Maine DEP, pers. comm. June 16, 2004)
7. Dexter POTW, Dexter, Maine.
MEPDES ID No.: MEU500830
License issued: December 20, 2002.
Maximum allowed discharge: 0.273 MGD
Note: Land-based, spray irrigation system, no discharge allowed to surface
waters. Former discharge location was East Branch Sebasticook River.8. Limestone
POTW, Limestone, Maine.
Receiving water: Limestone Stream (Class C waterway)
MEPDES ID No.: W-000860.
License issued: January 25, 2001.
Maximum allowed discharge: 0.3 MGD
Discharge limited to 0.2 MGD from July 1 to Sept. 30
Dilution ratios: 5.2:1 (7Q10); 13.3:1 (harmonic mean)
9. North Berwick POTW, North Berwick, Maine.
Receiving Water: Great Works River (Class B waterway)
MEPDES ID No.: ME0101885
License issued: August 14, 2002.
Maximum allowed discharge: 1.0 MGD
Flow limitations:
Discharge must be seasonally limited to maintain
minimum dilution of 20:1.
10. Norway POTW, Norway, Maine.
Receiving water: Little Androscoggin River (Class C waterway)
MEPDES ID No.: ME0100455
License issued: May 3, 2001.
Maximum discharge allowed: 0.975 MGD
Flow limitations:
No discharge allowed from June 16 to August 31.
No discharge allowed when river flow is less than 31 cfs.
When river flow is greater than 31 cfs, discharge limits are:
a) 0.947 MGD from Jan. 1 to May 15
b) 0.755 MGD from May 16 to June 15.
c) 0.755 MGD from Sept. 1 to Dec. 31.
11. Unity POTW, Unity, Maine.
Receiving water: 25 Mile Stream (Class B waterway)
MEPDES ID No.: ME0101150
License issued: August 13, 2002.
Maximum discharge allowed: 0.5 MGD
Flow limitations:
No discharge allowed when stream flow is less than 15 cfs.
Dilution factor of 100:1 required from March 16 to Dec. 15.
Dilution factor of 150:1 required from Dec. 16 to March 15.
12. Warren POTW, Warren, Maine.
Receiving water: St. George River (estuarine segment)
MEPDES ID No.: ME0102253
License issued: May 15, 2001.
Maximum discharge allowed: 0.244 MGD
Flow limitations:
Discharge limited to 0.0795 MGD from June 1 to Sept. 30.
Discharge limited to O.244 MGD from Oct. 1 to May 31.
13. Farmington POTW, Farmington, Maine.
Receiving water: Sandy River (Class B waterway)
MEPDES ID No.: ME0101249
License issued: November 27, 2001.
Maximum discharge allowed: 0.9 MGD
Flow limitations:
From June 1 to Sept. 30: BOD5 and TSS limited to 150 lbs./day (monthly
average). From Oct. 1 to May 31, BOD5 and TSS limited to 225 lbs./day
(monthly average).
Dilution at 7Q10: 18.2:1.
Receiving water drainage size at plant outfall: 268 square miles.
Note: All daily discharge limits (MGD) calculated as monthly average.
We are not sure how the EPA, MA DEP and City of Brockton can respond to this disparity, except to say Maine likes clean rivers and Massachusetts prefers effluent. It’s nuts.
EPA must go beyond just prohibiting hookups to outside communities in this permit. Without significant reductions in plant flow Salisbury Plain and Matfield Rivers have no hope of attaining their assigned standards today or twenty years from now.
To begin the process of incrementally achieving the goals set forth in the Clean Water Act we offer the following simple suggestions.
Maintain in the final permit language preventing an increase in hookups to outside communities and facilities.
Add language to this permit which would prohibit additional flow to the plant as I&I is reduced. This should be a prohibition on flow from any sources, from within the City of Brockton and without. If the City and surrounding communities need additional sewer services let them partner together and build smaller plants to share the burden. The Salisbury Plain, Matfield and Taunton Rivers have been our draft animals long enough. Its time to put them out to pasture.
There is no middle course in this matter, permit limits and numbers are a facade in regard to this plant, they serve no other purpose than to muddy the waters when the solution is clear. EPA itself has acknowledged that large centralized plants which empty into small river systems were a mistake. For streams such as Salisbury Plain the only answer is to begin the process of de-centralizing this plant. This draft permit and the pending expansion and upgrade of this plant move us in the exact opposite direction. To continue following along this misguided course is to repeat history at a great expense to the environment and the rate payers.
Fifteen years ago in 1988 the City of Brockton newly updated and expanded plant was failing to meet permit limits less than five years after an expansion and upgrades were completed. CDM states the following on page 1 of attachment 1 in the Brockton Advanced Wastewater Treatment Facility Upgrades Environmental Notification Form September 2003 (Attachment 7) . "Wastewater treatment in Brockton first began in the early 1900s, at a site west of the Veterans Administration Hospital on Belmont Street. Additional sewer construction and treatment facilities were required in the City by 1960, and a new plant was placed into service at the site of the current treatment facility. By the late 1970s, this plant was nearing the end of its 20-year design life, and a major plant expansion project was completed in the mid-1980s. Since that major expansion, the Brockton WWTF has not undergone a major plant-wide upgrade program." Shortly after completion of this "major plant expansion project" the upgraded and expanded plant was failing to meet permit limits, and in 1988 the City of Brockton entered into a consent decree with the regulating authorities. On November 14, 2001 the Ma DEP issued a notice of non-compliance to the City of Brockton. If EPA, Ma DEP and the City of Brockton continue on this course this cycle is certain to be repeated.
The following pages are a synopsis of the current state of the receiving waters. In addition to this synopsis we are submitting various water quality studies that have been undertaken in the receiving waters over the past several years, we would like these attachments to be entered as part of our official comments and as part of the public record.
It is worth noting that several of these studies were overseen or undertaken by Ma DEP, yet Ma DEP has not used them in their 305 b assessments. In fact the receiving waters although on the 303 d list have not been reassessed in the last two assessment cycles (see Attachment 8 for our comments on this). This is a disgrace and is an indication of gross incompetence on the part of Ma DEP. Having been involved in this process for the past several years it is clear that Ma DEP through their own incompetence and lack of leadership have enabled the City of Brockton to continue the gross pollution of the receiving waters. The Ma DEP has and continues to be a willing obstacle to river advocates perusing the goals set forth in the Federal Clean Water Act. In 2004 it is convenient to blame budget cuts for this lack of attention to their responsibilities. However this has been going on as far back as 1998 (see attachment 9) when the DEP was better funded and staffed.
Water Quality Synopsis
(Attachment 10) The Taunton River Watershed 2001 Biological Assessment at site TR03 Salisbury Plain River 2 km downstream from the Brockton Sewer Plant was found to be moderately impaired by the DEP surveyor. He made the following statements about this reach. "That habitat quality here was found to be highly comparable (actually better) to the reference condition suggests that water quality limits biological potential in this portion of the Salisbury Plain River. Metric values for the TR03 benthos were strongly suggestive of water quality degradation related to organic enrichment and low dissolved oxygen levels. Pollution sensitive EPT taxa, as well as algal scrapers (Tables A1) - generally less tolerant of organic pollutants than filter feeders and gatherer collectors, were virtually absent from the benthos sample taken here and suggest an oxygen stressed community. Community imbalance also characterized the TR03 benthic community, the result of the hyper dominance of a single family. Indeed, the Chironomidae comprise well over half of the assemblage observed at TRO3. The numerical dominance of the chironomid Polypedilum flavum is particularly significant, as this species is considered very tolerant of organic pollution. It has been associated with sewage "recovery zones"
(Attachment 11)The following is from the Draft Taunton River Watershed Assessment Report 1998, Taunton River Watershed Benthic Macroinvertebrate Biomonitoring.
The surveyor had the following comments on this sampling site (TRO3) which is also at Belmont St. East Bridgewater Salisbury Plain River.
"I recommend omitting TRO2 as an upstream reference site and instead using the regional reference station TRO1 as the primary reference for TRO3. With an EPT index of 1 and a taxa richness of only 6, it would seem unconscionable to place TRO3 anywhere near the non-impaired category. The relatively high habitat assessment score (83% comparable to the regional reference station) received by TRO3, coupled with its low metric scores, lead me to believe that impairment to the invertebrate community is primarily due to degradation of water quality. The Brockton WWTP seems the likely pollution source here, although a horse farm adjacent to the stream at Belmont St. may be a possible source of nutrient loading."
In the Matfield & Salisbury Plain River Watersheds Nonpoint Source Pollution
Assessment Report May 19, 2003 page 45 (Attachment 12) the following was
observed at a sampling site at High St. Bridgewater Matfield River. This site is
approximately 8 miles downstream of the Brockton AWRF and one quarter mile
upstream of the beginning of the Taunton River. "Copious amounts of macrophytes
and algae were observed at this site which could be a result of the elevated
nutrient levels found at this site. Strong chlorine odors were also noted during
every visit to this site, which can be an indication of over chlorination by a
sewage treatment plant or chemical industry, or discharge of swimming pool.
Evidence of primary recreation was noted at this site in the form of a rope
swing. It is advised that such activities should be actively prohibited."
The following is from the same study at the sampling site at Belmont St. Bridge Salisbury Plain River East Bridgewater (Attachment 12) this site is about one and a half miles below the Brockton AWRF.
"SPR1 was sampled on five dates and exhibited elevated levels of bacteria on two out of three wet weather sampling days, with a peak level of 14,000 col/100 ml on 6/6/02. This site ranks as number 7 on the "Recommended Priority for Site Management (during wet weather)" list (Table 9), and number 4 on the "Recommended Priority for Site Management (during dry weather)" list (Table 10). Which means overall this site was relatively bad in terms of water quality during wet and dry weather conditions."
The following is from summer 2000 over night nutrient studies performed by the Bridgewater State College Watershed Access Lab on the Upper Taunton River. (See attachment 14 for more detail)
"Once again, the nutrient loading in the Upper Taunton River near the confluence of the Matfield and Town Rivers is mostly due to the contributions from the Matfield River Basin."
"Surveys of tributaries within the Matfield Basin revealed that most of this load appears to be from the Brockton Sewage Treatment Plant by late summer"
It is our understanding that high loads of phosphorus can be a limiting factor in freshwater systems, causing algae blooms which in turn reduce levels of dissolved oxygen. The following are DO levels found at several sample sites below the Brockton AWRF during the Matfield & Salisbury Plain River Watersheds Nonpoint Source Pollution Assessment Report May 19, 2003.(see attachment for more detail Attachment 13)
Salisbury Plain River sample site SPR1 at Belmont St. East Bridgewater (7/24/02/ 2.4 mg/l) (8/30/02/ 4.4 mg/l) (6/20/02/ 4.3 mg/l) (8/7/02/ 1.9 mg/l) Mean DO 3.3 mg/l.
Matfield River three separate sample sites MR1 being High St. Bridgewater approximately 8 miles downstream of plant and one quarter mile above the beginning of the Taunton River.
(7/10/02/ 3.6 mg/l) (7/24/02/ 5.6 mg/l) (9/16/02/ 3.9 mg/l) (6/24/02/ 5.0 mg/l) (8/8/02/ 5.4 mg/l) Mean DO 4.6 mg/l (Attachment 14)
See Attachment 13 for Bacteriological and Nutrient Data as well.
Tim Watts
Executive Director
Glooskap & the Frog
633 Wareham St
Middleboro Ma 02346
Works Cited
1. Matfield and Salisbury Plain River Non Point Source Pollution Study, ESS Group 2002.
2. City of Brockton Facilities Assessment Report, Camp Dresser McKee 2002
3. City of Brockton WWTP1999 NPDES Permit.
4. Brockton AWRF records for 2002-2003
5. Epsilon Associates, inc 1998 water resources 29298/deir/Sec5.8water.doc
6. Brockton Advanced Wastewater Treatment Facility Upgrades Environmental Notification Form 2003.
7. USGS Survey Water-Resources Investigations Report 84-4283
8. Public Comments on 305 b assessments, Glooskap & the Frog 2004
9. Comments by Taunton River Watershed Alliance, Water Quality Monitoring advisory Committee Dr. Brian Brodeur 1998
10. Taunton River Watershed 2001 Biological Assessment Technical Memorandum TM-62-4
11. Draft Taunton River Watershed Assessment Report 1998, Taunton River Watershed Benthic Macroinvertebrate Biomonitoring.
12. Bridgewater State College Overnight Nutrient Monitoring 2000, 2002
Taunton River below Rt. 104 Bridgewater, Summer 2003
Our Public Comments on DEP failure to properly access these streams.
Ma DEP
Division of Watershed Management
627 Main St, Second Floor
Worcester MA 01608
Attn: Arthur S. Johnson
Hi Arthur,
These are our public comments regarding the Proposed Massachusetts Year 2004 Integrated List of Waters. Enjoyed talking with you the other day and keep up the good work.
Take care,
Tim
Taunton River (6235000) MA62-01_2004 Confluence of Town and Matfield Rivers to Route 24 Bridge, Taunton. 20.5 miles
This segment of the Taunton River should be listed on the 303d list. It fails in aesthetics. It smells like a sewer treatment plant through the whole segment and much of the bottom substrates are coated with thick layers of filamentous algae. In order to confirm this one need only to go down to the river and smell it, it stinks and looks like crap in the summertime.
This segment should also be listed as impaired by organic enrichment for obvious reasons.
This segment also appears to fail Aquatic life support criteria for the toxic pollutant, ammonia. According to USGS sampling at Titicut St. gauging station the ammonia limit of 0.204 was exceeded several times between 1999 and 2002, (see attached document).
In regards to this segment we are submitting some comments which we submitted for the 2002 listing because they are still relevant. This 20 mile segment of Taunton River, one of the largest rivers in the state of Massachusetts remains unassessed in 2004 despite the obvious degradation and impairment of its water by the City of Brockton Sewer Treatment Plant.
Salisbury Plain River
(6237100) MA62-06_2004 Brockton WWTP, Brockton to confluence with Beaver Brook and Matfield River, East Bridgewater. 2.2 miles - Cause Unknown - Pathogens
Matfield River (6236925) MA62-32_2004 Confluence of Beaver Brook and Salisbury Plain River, East Bridgewater to confluence with Town River and Taunton River, Bridgewater. 6.7 miles -Pathogens
Why are these to river segments not being listed as impaired by organic enrichment and low dissolved oxygen and aesthetics? According to the Matfield and Salisbury Plain River Watersheds Nonpoint Source (NPS) Pollution Assessment Report 2002 which was administered through the Massachusetts Department of Environmental Protection (MADEP), which was also a key manager and technical advisor to the Project these two river segments suffered from both organic enrichment and horribly low levels of dissolved oxygen, (see attachment).
Was this Matfield and Salisbury Plain River Watersheds Nonpoint Source (NPS) Pollution Assessment a valid study?
If so then why was it not used in this 2004 assessment?
Will it be used in future assessments, or will it be outdated information by then?
The Taunton River Watershed 2001 Biological Assessment at site TR03 Salisbury Plain River 2 km downstream from the Brockton Sewer Plant was found to be moderately impaired by the DEP surveyor. He made the following statements about this reach. "That habitat quality here was found to be highly comparable (actually better) to the reference condition suggests that water quality limits biological potential in this portion of the Salisbury Plain River. Metric values for the TR03 benthos were strongly suggestive of water quality degradation related to organic enrichment and low dissolved oxygen levels. Pollution sensitive EPT taxa, as well as algal scrapers (Tables A1) - generally less tolerant of organic pollutants than filter feeders and gatherer collectors, were virtually absent from the benthos sample taken here and suggest an oxygen stressed community. Community imbalance also characterized the TR03 benthic community, the result of the hyper dominance of a single family. Indeed, the Chironomidae comprise well over half of the assemblage observed at TRO3. The numerical dominance of the chironomid Polypedilum flavum is particularly significant, as this species is considered very tolerant of organic pollution. It has been associated with sewage "recovery zones"
The 2001 bioassessment of TR03 was similar to results documented by DEP during the last biomonitoring survey conducted here in 1996, when high densities of filter feeding hydropsychids and pollution tolerant chironomids resulted in poorly performing metrics (especially EPT Index and Scrapers/Feeders) and an assessment of moderately impaired" (Fiorentino 1996). That the TR03 macro invertebrate community remains structured in response to organic enrichment is not surprising given its location downstream from the Brockton WWTP. Nutrient loadings originating from the treatment facility’s discharge probably not only shape benthic community structure and function in this portion of the river, but also account for the luxuriant algal growth and macrophyte cover observed here.
Was this MA DEP bioassessment reviewed for the proposed listing? If not why?
Was the 1996 bioassessment reviewed? If not why?
Has anything been reviewed by anyone regarding any of these polluted streams? If not why?
Will they ever be reviewed? If so when?
Did DEP review discharge violations at the Brockton WWTP for this listing? If not why?
"Inspections by EPA and the Massachusetts Department of Environmental Protection (DEP) and the plant's own reports document equipment failures, operator errors, chemical feed problems and chronic bypassing of treatment equipment at the plant. This has led to excessive discharges of sewage solids, bacteria, ammonia and chlorine into the river, which flows to the Matfield River which downstream becomes the Taunton River". The above quote is from a June 4, 2003; (Release # 03-06-03) US EPA press release regarding violations at the Brockton Sewer Plant.
Is the DEP reviewing agency aware of these ongoing violations?
Does MA DEP consider excessive discharges of sewage solids, bacteria, ammonia and chlorine as impairments to aquatic life and might they be aesthetically displeasing?
Does MA DEP accept their own documentation as being valid?
Do the attached chlorine violations at the Brockton Sewer Plant constitute violations of the aquatic life standard for toxic pollutants in the stream?
As an example according to plant records during July 2002 a chlorine violation of 0.192 mg/l occurred. It’s our understanding that the state toxicity limit is 0.011 mg/l. During the summer more than 90% of the streams flow at and below the discharge is effluent. What impact does a chlorine violation of this magnitude have on the streams aquatic life? Do these violations warrant listing the stream as being impaired for aquatic life due to chlorine toxicity?
The continued failure of the DEP to properly assess and list all of these obvious impairments to the above rivers is a disgrace. There is no reason or excuse for it. These impairments can be observed first hand, in the river by anyone willing to take the time to visit them. As we have pointed out above there is ample documentation to update the proposed listings as we have suggested. Furthermore, these are not small rivers, the Taunton River is one of the largest in our state. The Matfield and its tributary the Salisbury Plain River make up as much as 70% of the flow of the Upper Taunton River during low flows. More than 90% of the Salisbury Plains flow is effluent during low flows. What’s up? We need to do better, don’t ya think?
NOTE:
Although there is an update and expansion plan for this plant it will not be completed for several years and there are questions remaining about the proposed expansion and upgrades ability to adequately reduce pollution to the stream. Therefore we can not assume these violations will stop anytime soon and we should not assume they will for the purpose of this and future assessments.
Tim Watts, Overpaid Executive Director
Glooskap & the Frog
633 Wareham St.
Middleboro Ma. 02346
Our Draft Comments
We will be adding more as we complete them. If you have any thoughts or comments to contribute please send them along and we will post them.
While detailed and technical comments are most effective they are not required. Write what you are comfortable with, long or short, technical or non technical every voice matters. Take what you want from our website, cut, paste, trace, copy, whatever.
The comments below although not complete cover some of the more vital issues.
Flow
The outside hookup cap in this permit, which prohibits additional hookups too outside communities as specified on page 4 # 3 of the permit is a vital component of this permit. While it is physically possible to expand the capacity of the plant to accommodate twenty, thirty, forty or fifty million gallons per day, the receiving water, Salisbury Plain River and the river system which receive it, simply does not have the capacity to receive and assimilate such a large flow and maintain its biological integrity as a river, (let us not forget that this the purpose of this whole exercise is to bring Salisbury Plain and the river system which receives it up to their assigned water quality standards). In fact it is common knowledge that the plant’s current design capacity of 18 mgd is far more than this river system can assimilate (attached water quality data, personal communication EPA region 1). Even, assuming completion of the proposed upgrade of the plant and its treatment processes in 2008, this river system will likely still not meet its assigned Class B standard at a flow of 18 mgd. Therefore, without a specific flow limit of x amount per day it is vital that the plants flow be limited to the City of Brockton proper and the communities of Abington and Whitman whom are currently under contract for one million mgd each.
The language used in the above cited section is also important and must be maintained in the final permit. It is our understanding that only the towns of Abington and Whitman are contractually committed as towns to the Brockton Plant. All other hookups are hooked up as individual facilities. As an example, Stonehill College is hooked up to the Brockton plant but the Town of Easton as a town entity is not. Therefore, the language in the permit which reads "The permittee shall not accept any new sewer connections in other communities from facilities not currently connected to the WWTP." is important and must be maintained as such in the final permit. It is also our understanding that the town of West Bridgewater has some individual facilities with minor hookups but has no contractual agreement with Brockton as a town. The fact that these minor individual facility hookups exist in West Bridgewater should not entitle the town of West Bridgewater proper to add any additional hookups.
The following flow figures are from water quality sampling preformed by Bridgewater State College and the ESS Group summer 2002. Using the flow data from the plant for that day (August 7, 02) provides the following flow figures for the significant tributaries to the Salisbury Plain, Matfield and Upper Taunton River.
The flow figures for Satucket, Meadow Brook and Beaver Brook are from the ESS Group Matfield River NPS data and were taken on August 8, 2002. All others are from Bridgewater State College Watershed Access Lab (August 7, 02). Flows are million gallons per day (mgd).
During periods of low summer flows the plants discharge often drops to between 13 and 15 mgd, because there is little Inflow and Infiltration into their sewer delivery infrastructure.
Beginning at the plant and moving downstream.
Plant flow to Salisbury Plain 14.28 mgd
Salisbury Plain flow above plant 1.94 mgd
Meadow Brook 1.18 mgd
Beaver Brook 0.01 mgd
Satucket 1.6 mgd
Matfield at High St. Bridgewater 18 mgd
Town River Haywood St. 4.0 mgd
Winnetuxet .4 mgd
Nemasket 5.0 mgd
Taunton River Titicut St. 32 mgd
Below are the same figures showing how dominant the plants flow will be if Brockton eliminates their I&I and replaces it with their requested 20.5 mgd flow.
Plant flow to Salisbury Plain 20.5 mgd
Salisbury Plain above plant 1.94 mgd
Meadow Brook 1.18 mgd
Beaver Brook 0.01 mgd
Satucket 1.6 mgd
Matfield at High St. Bridgewater 18 mgd
Town River Haywood St. 4.0 mgd
Winnetuxet 4 mgd
Nemasket 5.0 mgd
Taunton River Titicut St. 32 mgd
Prohibiting additional hook ups as outlined in this draft permit is both a reasonable and prudent action to insure future permit compliance and to meet the Salisbury Plain River’s water quality attainment goal of a Class B river. The current plant design capacity will remain at 18 mgd throughout the five-year cycle of this draft permit. Until the city significantly reduces their I&I problems and completes the proposed expansion and upgrade of the plant their will be no additional capacity at the plant to accommodate additional hookups from outside communities. Furthermore, given the inherent difficulty of reducing current I&I sources and controlling those that will arise in the future it is highly unlikely that the expanded and upgraded plant could accommodate the sewer demands of surrounding communities. Beyond the I&I issues Brockton is planning on receiving up to 4 mgd of drinking water from the proposed freshwater desalinization plant in Dighton which will further reduce capacity to outside communities.
While it may be cost effective and convenient for surrounding communities to solve their septic woes by hooking up to the existing plant, neither the city nor the regulatory authorities are bound by any obligation to accommodate them. The language in this draft permit regarding additional hookups simply insures that one additional hookup will not lead to another and then another and so on and so forth until ten years from now we our back to square one with an overburdened plant and more importantly a grossly polluted river.
Chlorination/Dechlorination
The use or better yet misuse of chlorine at this plant has been a chronic problem for many years. The fact that the plant has problems with bacteria violations and chlorine violations indicate either poorly trained operators, inadequate equipment or a combination of the two (most likely the latter). According to plant records the maximum daily limit for total residual chlorine, 0.019 mg/l was exceeded during the month of July 2002 (0.192 mg/L) August 2002 (0.066 mg/L) November 2002 (0.17 mg/L) and May 2003 (0.86 mg/L)
Chlorine, which is used to sterilize bacteria in the effluent, is equally effective at sterilizing aquatic life in the stream. Stream sterilization is not good. As we have pointed out this plants effluent becomes the flow of the stream during low flows. A single annual chlorine violation of significant magnitude represents more than a simple permit violation. It can sterilize the streams aquatic ecosystem.
Consider this, if once or twice a year a local manufacturing plant sent forth a toxic plume from its smoke stack which left the ground littered with dead birds, would we simply shrug our shoulders and write it off as violation? NO! The difference is nobody is there to witness the results of such an event in the Salisbury Plain River. These chlorine violations are no small matter and must stop. We feel the addition of continuous chlorine monitoring in this permit is essential to both identifying and eliminating future violations.
Another repulsive aspect of the chlorine/dechlorination process, is the smell. The odor from this process persists not only in the water of the Salisbury Plain River but in the Matfield and Taunton Rivers as well. The flow of this plant is so dominant in this river system that it can be smelt twenty miles downstream of the plant at Vernon St. on the Middleboro, Bridgewater town line. While we recognize that for the time being this chlorine/dechlorination process will continue, it must be done within the safe limits of the permit.
We suggest that as part of the proposed expansion & upgrade and as part of the pending Federal Judicial Consent Decree that both the City of Brockton and regulatory agencies consider eliminating this chlorination process, and replace it with a modern ultra violet effluent disinfection system. This change alone would be a significant step forward in protecting the river systems aquatic life and aesthetic value.
I&I Reduction
The inflow and infiltration reduction plan outlined in this draft permit is an improvement and one we support. Although significant I&I reductions could probably be realized in a shorter period, this schedule coupled with the impending Federal Judicial Consent Decree will not only send the city a clear message, it will compel them in an enforceable manner to fix their neglected sewer delivery infrastructure.
The benefits of this I&I reduction are two-fold and far-reaching. First, it will prevent the plant and river system from being overwhelmed during high flows. Second, it will go along way toward cleaning up the river system above the plant.
If water from extraneous sources is leaking into the sewer system during high flows, it stands to reason that sewer leaks out into the city’s streams during low flows. The Matfield & Salisbury Plain NPS Study of 2002 shows that this is the case at several sample sites in the city. This studies water quality sampling revealed that many sample sights had elevated levels of bacteria during low flows (see attachment). A well supervised and an enforceable I&I reduction plan will in time improve water quality in river reaches above and below the plant.