March 3, 2014

Danielle Gaito
U.S. EPA – Region 1
5 Post Office Square, Suite 1100 (OEP-06-4)
Boston MA 02109-3912

Subject: Montague (Bitzer) State Fish Hatchery draft NPDES Permit
Permit Number: MA0110051, Public notice MA-005-14

Dear Ms. Gaito,

I am submitting comments on the draft National Pollutant Discharge Elimination System (NPDES) permit
for the Montague (Bitzer) State Fish Hatchery on behalf the Connecticut River Watershed Council
(CRC). The receiving water for this discharge is a small, unnamed tributary that does not seem to have ever been monitored by MassDEP as far as we know. The section of the Connecticut River where this stream discharges is a popular area for quiet water paddling and occasional swimming. As noted in the Fact Sheet, the section of the river in Montague downstream of the Turners Falls dam and Cabot station is a very important habitat for federally endangered shortnose sturgeon; sturgeon spawn and spend the winter on the river bottom in this area. The Connecticut River upstream of the Holyoke Dam is listed as an impaired water body due to Escherichia coli and PCBs in fish tissue. We are interested in improving water quality in the Connecticut River such that it can one day meet Class B water quality standards and be safe for swimming. Our comments are below.

1. CRC supports the increased monitoring for dissolved oxygen, formaldehyde, and Whole Effluent Toxicity (WET) testing, if the facility uses formalin again, for the reasons given on page 15 of the Fact Sheet.
2. CRC supports the addition of a hydrogen peroxide limit when Perox-aid is used.
3. CRC is pleased to learn that implementing best management practices for solids control during the last permit period has reduced the annual average concentration of total phosphorus in the effluent from 0.3 mg/L to 0.14 mg/L.
4. CRC is uncertain if EPA considered whether the federally endangered dwarf wedgemussel, Alasmidonta heterodon, was or could be present in this unnamed tributary. According to Freshwater Mussels and the Connecticut River Watershed by Ethan Nedeau (2008), the dwarf wedgemussel has been observed in the Mill River (Northampton), Mill River (Hatfield), and the Fort River, which are all tributaries to the Connecticut River between the Holyoke and Turners Falls dam.
5. CRC noted a minor inconsistency in the Fact Sheet. On page 7, it says that formalin has not been used at the hatchery in more than 15 years, and on page 14, it says formalin has not been used at the fish hatchery in more than 10 years.

Thank you for an opportunity to comment on this draft permit for the Montague State Fish Hatchery.


Andrea F. Donlon
River Steward