October 15, 2018

Meredith Timony

U.S. EPA – Region 1

5 Post Office Square, Suite 100

Boston MA 02109-3912

Subject:   Springfield Regional Wastewater Treatment Facility and 24 CSOs revised draft NPDES Permit

Permit Number: MA0101613, Public Notice MA-015-18

Dear Ms. Timony,

I am submitting comments on the revised draft National Pollutant Discharge Elimination System (NPDES) permit for the Springfield Regional Wastewater Treatment Facility and 24 Combined Sewer Overflows (CSOs) on behalf of the Connecticut River Conservancy (CRC), formerly the Connecticut River Watershed Council.  We submitted comments on the first draft permit dated February 12, and we attended the public meeting and hearing in Springfield on April 24, 2018.

  1. Revised TN loading limit

EPA and MassDEP now propose to set an annual average TN loading limit of 2,534 lbs/day, rather than an optimization benchmark of 2,279 lbs/day.  The revised draft permit would also allow the permittee to allow incremental TN increases after certain projects are completed by the permittee, as shown in Table 1 of the 2018 Fact Sheet Supplement and Attachment E of the revised draft permit.

CRC can support these proposed changes.  The new limit is enforceable, reasonable for the permittee to meet, and in keeping with the Long Island Sound Nitrogen Total Maximum Daily Load (TMDL).  While CRC thinks the allowable TN increases as laid out in Attachment E of the revised permit may not be necessary if the permittee can successfully optimize or reduce nitrogen, we do not object to the proposal.

  1. CSO notification requirements

EPA and MassDEP have updated the revised draft permit Part 1.b.3.g to require a public notification plan that will inform the public of probable CSO activation and termination of CSO discharges.

CRC fully supports the proposed changes to the revised draft permit.  As we said in our previous comments, CRC has never been notified of CSO discharges and we have not been able to find any press releases or websites that indicate public notification by the permittee of CSO discharges under the existing requirements of the current permit.  We would like to see the Springfield Water and Sewer Commission work with EPA and MassDEP, with consultation from stakeholders, to work on developing a website that provides notification of CSOs and any other unplanned releases from their facility.  The website could be set up to work in conjunction with other communities, akin to the one in CT and VT that report CSO and sewage spills across the state.  CRC has supported new legislation in Massachusetts that would make this a requirement.  See the CT web page at https://www.ct.gov/deep/cwp/view.asp?a=2719&q=525758&deepNav_GID=1654 (there is a link to a real-time map which brings up text about locations and volumes of recent CSO discharges) and the VT web page at https://anrweb.vt.gov/DEC/WWInventory/SewageOverflows.aspx.

  1. Additional comments

CRC requests that EPA revise new permits issued from this point on, including this permit, to include a requirement that any report to be submitted to EPA and MassDEP be done so in electronic form with a submission email address.  CRC has had a difficult time obtaining annual nitrogen optimization and annual CSO reports in the Connecticut River watershed from both agencies.  If the reports were submitted electronically, they would be relatively easy to post online and/or provide to members of the public without a complicated FOIA process.  Recently, CRC requested a series of annual nitrogen optimization reports, nitrogen optimization analysis reports, and annual CSO reports from MassDEP and EPA, and neither agency appeared to have all of them and it was difficult to obtain them all because some would have needed to be scanned.  In contrast, annual NPDES MS4 reports in Massachusetts are all available on an EPA website and are easy to review.

CRC continues to request that monthly Total Phosphorus testing be required in the new permit.

CRC appreciates the opportunity to provide comments on the revised draft permit.  I can be reached at adonlon@ctriver.org or (413) 772-2020 x.205.


Andrea F. Donlon

River Steward

Cc:          Susannah King, MassDEP

Denise Ruzicka, CT DEEP

Jack Looney, CT Fund for the Environment

Josh Schimmel and Bill Fuqua, SWSC

Gabby Queenan, Mass Rivers Alliance