March 28, 2012

Michele Cobban Barden
USEPA Region 1
5 Post Office Square, Suite 100 (OEP06-1)
Boston MA 02109-3912

Subject:    South Hadley Wastewater Treatment Plant NPDES Permit
Permit Number: MA0100455, Public Notice MA-009-12

Dear Ms. Barden,

I am submitting comments on the draft National Pollutant Discharge Elimination System (NPDES) permit for the South Hadley Wastewater Treatment Plant (WWTP) on behalf the Connecticut River Watershed Council (CRWC).  The Connecticut River, an American Heritage River, is a regional resource that merits the highest level of protection.  The Connecticut River downstream of the Holyoke dam is listed as an impaired water body due to priority organics (PCBs), pathogens, and total suspended solids.  CRWC is particularly interested in improving water quality in the Connecticut River so that it can support a high quality fishery as well as existing primary and secondary contact uses, even during wet weather.  Our comments are below.

  1. The protection of existing uses is required under 40 CFR 131.12(a)(1).  Below is our understanding of existing uses on the Connecticut River in the vicinity of the outfall, which is located downstream of the Holyoke dam, just over the South Hadley/Chicopee town line in Chicopee.
  • The Perjovski state ramp is a small state-owned boat launch just upstream of the outfall pipe.  This spot is used mostly by boaters and anglers.
  • A boat launch owned and operated by the City of Holyoke is located directly across the river from Chicopee’s Jones Ferry CSO Treatment Facility, a little over three miles downstream of the outfall.  This site, the Jones Ferry River Access Center, has a newly built meeting room and picnic area, and is the launching point for a group called Holyoke Rows (, which offers rowing, kayaking, and canoeing programs for children and adults.  The general public uses this site as a launching point, mainly for canoes and kayaks.  In addition, anglers use the wooden docks at this access point as a fishing spot.
  • A state-owned boat ramp (Medina Street) is located in Chicopee about 4½ miles downstream of the outfall.  This boat ramp is extremely busy with motor boat launching on most weekend days in the spring, summer, and fall.  This is especially true during the height of the spring fish migration period.

2.   We commend the town of South Hadley for eliminating their CSOs in 2007.  This was a significant investment by the town and has been a boon to the river.

3.   We support the increased frequency in testing for total residual chlorine, especially because of the frequent violations.

4.   We are very supportive of the addition of brook trout (Salvelinus fontinalis) for whole effluent toxicity testing.  It is re-assuring to see a species added that is a closer reflection of the types of fish present in the Connecticut River and that matches the restoration goals for the entire watershed.

5.   We support the increased testing frequency for total phosphorus and nitrogen compounds.

6.   Page 10 of the Fact Sheet describes the 7Q10 and dilution calculation for the Connecticut River at the outfall pipe.  It would be nice to verify this 7Q10 because the outfall pipe is located across from the Holyoke canals, and though there are several discharges from the canal upstream of this point, the full river flow is probably not present at this spot.  The new location for the USGS gage downstream of the Holyoke dam has been in place for 10 years and there should be a reasonable 7Q10 by now.  Perhaps the old USGS gage would produce a more representative flow because that location was upstream of the canal discharge.

7.   The Fact Sheet at page 13 explains that five bacteria violations over the past 24 months were due to mechanical failure of the chlorine pump, which has been replaced.  This would lead us to believe that not enough chlorine was used to kill the bacteria, but the fact sheet at page 14 indicates that there have been 11 exceedences of the maximum daily total residual chlorine (TRC) limit in the last 24 months.  The Fact Sheet explains the permittee’s difficulty with TRC control, saying pumps were replaced, but that plant staff have also been unable to pinpoint a cause for communication errors in the SCADA system.  Until this problem is fixed, it seems to us that TRC and bacteria will continue to be a problem.

8.   The Fact Sheet on page 23 says that the Town of South Hadley estimates an average of 770,000 gallons of infiltration and inflow (I/I) per day that flows into the treatment plant.  That is a high amount of I/I.  The Fact Sheet also gives detailed information on the I/I Control Plan and past studies.  However, what is missing is the amount of progress on I/I reductions over the years, since the Town first surveyed I/I 20 years ago.  Their plan was developed approximately 5 years ago – has the plan helped them reduce volumes at all?

9.   Section B of the permit stipulates special conditions for nitrogen, requiring the permittee to complete an evaluation of alternative methods for operating the facility to optimize the removal of nitrogen.  The permit expects the facility to discharge less than the “existing” annual average discharge load of 793 lbs/day.  This number is based on 2004-2005 data, and many NPDES permit fact sheets include a table showing all municipal NPDES permits in MA, NH, and VT with average total nitrogen concentrations, average flow amounts, and the loading values. This table (not provided in this Fact Sheet, but we referred back to Chicopee’s Fact Sheet), indicated that in 2004-2005, South Hadley had the 9th largest discharge volume of wastewater treatment plants in the Massachusetts part of the Connecticut River watershed, but was 4th highest in terms of nitrogen load.  In fact, the average concentration of nitrogen was the second highest in the MA part of the watershed.

Because the current permit has been in place for five years and has required monthly nitrogen sampling, CRWC took a look at more current data available for the facility as provided in the EPA ECHO database.  To get monthly average concentrations for total nitrogen, we added TKN and nitrate+nitrite together.  We then calculated a monthly loading value by taking the monthly average total nitrogen concentration, multiplying it by the monthly average effluent flow, and using conversion factors to get the units right.  We then averaged those numbers over a calendar year for 2009 and 2010, the two most recent years that have data for the entire year available online.  We calculated an annual average discharge load of 304 lbs/day in 2009 and 397 lbs/day in 2010.  If our calculations are correct, then we question whether using 2004-2005 as a baseline in this permit is the most appropriate, for two major reasons:

  • The 793 lbs/day limit proposed in this permit is so much higher than what seems to be the actual current loading range for this plant, that the limit and the required nitrogen reduction loading plan is immediately rendered meaningless.
  • We all know Long Island Sound is impaired and additional nitrogen reductions are needed.  Why not take credit for reductions that have already taken place, and work to get meaningful reductions in the most cost-effective ways possible?  If towns like South Hadley have already reduced nitrogen inputs and could do more relatively easily, won’t this be less costly for tax-payers and ratepayers in general than trying to identify and implement a variety of other projects like stormwater BMPs in the watershed?

Thank you for an opportunity to comment on the draft permit for the South Hadley Wastewater Treatment Plant.


Andrea F. Donlon

River Steward



Kathleen Keohane, MassDEP

Christine Duerring, MassDEP

Cindy Delpapa, Massachusetts Riverways program

Betsey Wingfield, CT DEEP

Melissa LaBonte, South Hadley Water Pollution Control Compliance Manager