I am submitting comments on the draft National Pollutant Discharge Elimination System (NPDES) permit for the Plainville Wastewater Treatment Plant (WWTP) on behalf of the Connecticut River Conservancy(CRC), formerly the Connecticut River Watershed Council. The facility discharges to thePequabuck River, a tributary to the Lower Farmington River, which in turn discharges into the Connecticut River. As such, it is of relevance to us.
The segment downstream of the Plainville WWTP, (CT4315-00_01Mouth Farmington River, US to Railroad crossing (US (south) Route 72 crossing), Plainville), is listed on Connecticut’s 305b list as impaired for failing to support aquatic life and recreation. Specifically, this segment is impaired for habitat for fish, other aquatic life and wildlife due to Total Phosphorus loading.1
We want to thank you for providing CRC with information regarding the Plainville WWTP and the reported violations on the ECHO database. Our comments are primarily focused on these violations.
Public participation in the reissuance of NPDES permits should include the voices and perspectives of community members. Neither the fact sheet nor the draft permit draw attention to the violations listed on the ECHO database. Without extensive prior knowledge of the NPDES permit process, how would members of the general public know of these violations? This should be listed in the fact sheet at a minimum. The public comment process lacked transparency and as such was not an authentic attempt to solicit public feedback in the renewal of this permit. Our suggestions for improvement are outlined at the end of this document.
We appreciate DEEP’s communication regarding permit violations and explanations for why these violations occurred.
- E. Coli: It was explained that fecal and E. coli violations were due to bottle contamination and, for months in which a violation was reported, 29 out of 30 days contained only single digit values and one value from one day in the month caused these violations. Violations were identified for August 2018, May, June July, October in 2019 and May 2020. It is noteworthy that E. coli monitoring only takes place from April through October, meaning that the Plainville WWTP reported an exceedance of its E. coli limits 4 out of 6 months of the monitoring season in 2019, even if only for one day of those months. Bottle contamination obscures the water quality data from the public and demonstrates that the WWTP is not following standard operating procedures. The lack of clarity surrounding E. coli data due to bottle contamination is a serious concern and brings into question the credibility of the WWTP data. We request that DEEP provide documentation of the response to these lab quality assurance and control problems.
- Total Phosphorus: Thank you for clarifying the TP violations in the ECHO database. Again, given the upgrades in process and plans to bring the WWTP into compliance, it would be helpful if these clarifications were listed in the fact sheet. Each year CRC hosts Samplepalooza, a synoptic nutrient monitoring event in which volunteers collect data throughout the Connecticut River Watershed. In the Farmington River Watershed, samples indicated extremely high levels of TP–see the charts at the bottom of this document. While this report predates the Plainville WWTP upgrades for Phosphorus removal, it demonstrates the urgent need to address TP loading in the watershed, especially when considering the impairments of the Pequabuck River due to TP levels. These results remain constant, as indicated in our 2019 Samplepalooza report, in which the Farmington River again reported the highest TP concentrations. While the Plainville WWTP is one of many sources of TP in the Pequabuck and Farmington watersheds, it is clear that significant effort must be undertaken to reduce TP from all sources. For the instream waste concentration of 20.75%, we are concerned that phosphorus limits are based on the average flow from the WWTP, and not the design flow. If so, as the average flow goes up, the facility would not meet the load limit and we believe loading limits should accordingly be based on the design flow of the facility. We request that DEEP responds with an explanation for why design flows are not used to calculated load limits as is normally done.
- TSS, UOD and Nitrogen, ammonia: It was explained that violations for total suspended solids, Nitrogen(ammonia) and ultimate oxygen demand were due to difficulties the WWTP had operating their Sequential Batch Reactors or secondary treatment system in high flows. These exceedances are drastic, peaking at 354% for TSS, 132% for nitrogen and 103% for UOD. In a review of other WWTP on the ECHO database, these violations stand out, even in high flow. I am encouraged to hear that the WWTP has been working to fix these issues and has since had no violations; however, these violations occurred multiple times in the life of the permit with very real impacts on the watershed. Additionally, many of these violations occurred in QTR 3 &4 and then again in QRT 7-12. The persistence of these violations indicates that exceedances were a known issue in 2018 and took at least 2 years to address. We request DEEP provide information as to how DEEP responded to these exceedances and the alacrity with which the WWTP addressed them.
- The ECHO database indicates that there were 15 counts of late Discharge Monitoring Reports (DMRs) and 2 missing DMR measurements. Some of these submissions are marked as being up to 187 or even 486 days late. Instances of significant/Category I Noncompliance in QTR 8-11 correlate directly with late DMRs, meaning that, not only did the violation occur, but was not reported in a timely manner. This contributes to a general lack of transparency in data reporting from the WWTP.
- The ECHO database does not indicate that DEEP has taken any informal or formal actions, as described in Section 1(C).We ask that DEEP provide CRC with a summary of if/what actions have been taken to date to bring the WWTP into compliance.
- We appreciate that ultraviolet disinfection will be used from April 1 through October 31, which more accurately reflects the season when the public accesses the river than systems treating from May –September. We continue to advocate for regulatory changes that would expand the disinfection season for WWTP across the state, especially considering extension into November when temperatures are often temperate enough to bring people down to their rivers. Conclusion and Request for Response Compliance and Enforcement Documentation The Pequabuck River discharges into a Wild & Scenic segment of the Farmington River, with outstanding natural, cultural and recreational value. The Plainville WWTP is a moderate size treatment on a small river. Because of the proportional impact of the WWTP on the Paquabuck and, subsequently Farmington River, it is critical that DEEP take seriously the violations of this permit and take concrete steps to address them, including communication with the communities living and recreating in this watershed. Given the comments outlined above, we request that DEEP respond to the following questions and concerns before issuing the permit: 1.What, if any, actions were taken to bring the WWTP into compliance? We request DEEP provide us with a summary of these actions.
- What is being done to ensure the facility can properly capture E. coli samples to prevent bottle contamination? We request DEEP provide documentation of the response to these lab issues.
- We request information regarding how DEEP responded to violations for TSS, UOD and Nitrogen exceedances.
- Why were DMRs submitted late and how is this being addressed with the facility? Clarifications Phosphorus evaluation and Load Calculations Regarding our concerns outlined in 2(b), we request response to the following questions: Are phosphorus limits based on average flow or design flow? How do limits reflect changes in average flow?
Improvements for Fact Sheets The complex nature of the NPDES permitting process makes it inherently difficult for the layperson to participate in public comment. However, we believe DEEP could take steps to provide greater context and clarity by enhancing its fact sheets to include more information such as the receiving waters’ quality/impairment listing, explanations of the impact of each parameter on water quality and how parameter limits are calculated, endangered species in the receiving waters, maps and historical data, compliance history. EPA issues very thorough fact sheets for states such as Massachusetts (an example can be found here) and we encourage DEEP to explore how it can change fact sheets so as to invite richer public participation in the permit process. CRC requests a meeting with DEEP to explore improvements to the fact sheets. Finally, I want to reiterate my gratitude to Syed and the DEEP staff for their communication and explanations regarding both this individual permit, as well as regulatory questions and concerns. We appreciate the department’s dedication to keeping the state’s waters healthy and full of life, and we look forward to working with you throughout this process.
I can be reach at email@example.com or 860-704-0057.
River Steward, CT