Second Session
December 18,1968
Concord, New Hampshire
Pollution of the Interstate Waters of the
Merrimack and Nashua Rivers and their
Tributaries, Massachusetts —New Hampshire
and of the Intrastate Portions of those Waters
within the State of Massachusetts
U. S. Department of the Interior—Federal Water Pollution Control Administration
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U. S. DEPARTMENT OF THE INTERIOR
FEDERAL WATER POLLUTION CONTROL ADMINISTRATION
CONFERENCE
IN THE MATTER OF POLLUTION OF THE INTERSTATE
WATERS OF THE MERRIMACK AND NASHUA RIVERS AND
THEIR TRIBUTARIES (MASSACHUSETTS - NEW HAMPSHIRE)
AND OF THE INTRASTATE PORTIONS OF THOSE WATERS
WITHIN THE STATE OF MASSACHUSETTS.
Second Session
Concord, New Hampshire
Wednesday, December 18, 1968
Convened, pursuant to notice, at 9:30 a.m.
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CONTE,NTS_
PAGE
Opening Statement - By Mr. Stein 17
STATEMENT OF:
Thomas E. McMahon 24, 189 and
250
Honorable Thomas Urie 26
Lester Klashman 31 and 254
Herbert R.' Pahren 32
Thomas A. Schrader (For Richard E. Griffith) 93
Charles D. Larson 105
Arthur Newell 117
William A. Healy 118
James A. Sweeney 119
Clarence Metcalf 125
Honorable Maurice L. Bouchard 144
Bertrand Bouchard 149
Donald L. Fthier 151
Donald C. Calderwood 155 and 184
Honorable John C. Mangan 160
John E. Dodge 164
Eliot Priest 167
John E. Henchey 175
Mrs. Selwyn Taylor 177
Sheldon Morrill 185
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C.ONT.E_N.£S.
PAGE
John B. Cassaza 195
Richard Young 229
John J. Pobst 233
Mrs. Hugh F. Stoddart 235
Donald E. Boucher 248
Closing Statements 258
Appendix A
Appendix B
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Second session of the conference in the matter of
pollution of the interstate waters of the Merrimack and
Nashua Rivers and their tributaries (Massachusetts - New
Hampshire) and of the intrastate portions of those waters
within the State of Massachusetts ,• held under the provisions
of the Federal Water Pollution Control Act. Held at New
Hampshire Highway Motel, Concord, New Hampshire, December 18,
1968, (9:30 a.m.)
PRESIDING:
Mr. Murray Stein, Assistant Commissioner for
Enforcement, U. S. Department of the Interior,
Federal Water Pollution Control Administration,
Washington, D. C.
CONFEREES:
William A. Healy, Executive Director, New Hampshire
Water Supply and Pollution Control Commission,
Concord, New Hampshire.
James A. Sweeney, Vice Chairman, New Hampshire
Water Supply and Pollution Control Commission,
Concord, New Hampshire
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CONFEREES (Continued)
Thomas C. McMahon, Director, Division of Water
Pollution Control, Massachusetts Department of
Natural Resources, Boston Massachusetts
Alfred Peloquin, Ececutive Secretary, New
England Interstate Water Pollution Control
Commission, Boston, Massachusetts
Lester Klashman, Director, Northeast Regional
Office, U. S. Department of the Interior,
Federal Water Pollution Control Administration,
Boston, Massachusetts
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PARTICIPANTS:
Betrand Bouchard, Alderman, City of Nashua, Chairman,
Nashua River Water Pollution Committee, Nashua, New Hampshire-
Maurice L. Bouchard, Representative, General Court
Alderman, District 14 of Nashua, Nashua, New Hampshire.
Donald E. Boucher, Lancaster Representative for
Clean Up of the Nashua River, Lancaster, Massachusetts.
Donald C. Calderwood, Member, New Hampshire Water
Supply and Pollution Control Commission, Nashua, New Hampshire.
John B. Cassaza, Supervisory Sanitary Engineer,
Division of Water Pollution Control, Massachusetts Department of
Natural Resources, Boston, Massachusetts.
John E. Dodge, Coordinator, New Hampshire Committee
for Better Water, Concord, New Hampshire.
Donald L. Ethier, Alderman, District 1 of Nashua,
Nashua, New Hampshire.
Terrence P. Frost, Chief Aquatic Biologist, New
Hampshire Water Supply and Pollution Control Commission, Concord,
New Hampshire.
John E. Henchey, City Manager, Concord, New Hampshire.
Thomas A. Lacava, Chief Water Pollution Engineer,
New Hampshire Water Supply and Pollution Control Commission,
Concord, New Hampshire.
Charles D. Larson (Statement entered as if read), Region
1 Shellfish Consultant, Department of Health, Education, and Welfare,
U. S. Public Health Service, Boston, Massachusetts.
Clarence W. Metcalf, Director of Municipal Services,
New Hampshire Water Supply and Pollution Control Commission, Concord,
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PARTICIPANTS (Continued):
New Hampshire.
John C. Mongan, Mayor of Manchester, Manchester,
New Hampshire
Sheldon Merrill, City Council, Franklin, New Hampshire
Arthur E. Newell, Supervisor, Fisheries Research,
New Hampshire Fish and Game Department, Concord, New Hampshire
Herbert R. Pahren, Director, Technical Programs,
U. S. Department of the Interior, Federal Water Pollution
Control Administration, Boston, Massachusetts
John J. Pobst, Staff Consultant, Greater Lowell
Planning Commission, Lowell, Massachusetts
Eliot Priest, Vice President and Chief Engineer,
Public Service Company of New Hampshire, New Hampshire
Thomas A. Schrader (representing Regional Directors,
Bureau of Sport Fisheries and Wildlife, Bureau of Commercial
Fisheries) Assistant Regional Director, U. S. Department of
the Interior, Bureau of Sport Fisheries and Wildlife, Boston,
Massachusetts
Mrs. Hugh F. Stoddart, Massachusetts Coordinator,
Nashua River Clean Up Committee, Groton, Massachusetts
Mrs. Selwyn Taylor, Chairman, Water Resources
Committee, League of Women Voters of New Hampshire, Nashua,
New Hampshire
Honorable Thomas Urie, Representative, General Court,
New Hampton, New Hampshire
Richard H. Young, Executive Director, Central Merrimack
Valley Regional Planning District, Lawrence, Massachusetts
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8
OTHERS IN ATTENDANCE:
Guy C. Aldridge, Executive Director, Manchester
Taxpayers Association, Box 264, Manchester, New Hampshire
R. S. Audley, President, R. S. Audley Corporation,
Route 3A, Bow, New Hampshire
Karl C. Ayers, Sanitary Engineer, The Mead
Corporation, Central Research Laboratories, Chillicothe,
Ohio
Fred C. Benson, Jr., Wildlife Biologist, U. S.
Fish and Wildlife Service, 55 Pleasant Street, Concord, New
Hampshire
Mrs. Mildred Boisclair, 120 Chauncey Avenue,
Manchester, New Hampshire
Bert Bouchard, Alderman, city of Nashua, Chairman,
Nashua River Water Pollution Committee, Nashua, New Hampshire
Maurice L. Bouchard, Representative, General Court,
Alderman-at-Large, Nashua River Water Pollution Committee,
17 Charles Street, Nashua, New Hampshire
Donald E. Boucher, Lancaster Representative to
assist and coordinate the clean-up of the Nashua River,
100 Shirley Road, Lancaster, Massachusetts
V/esley E. Brown, Supervising Engineer, Anderson-
Nichols & Company, Inc., 10 Commercial Street, Concord,
New Hampshire
Richard A. Buck, New Hampshire Water Supply and
Pollution Control Commission, Hancock, New Hampshire
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OTHERS IN ATTENDANCE (Continued):
Donald C. Calderwood, New Hampshire Water Supply and
Pollution Control Commission, P. 0. Box 743, Nashua, New
Hampshire
Raymond H. Carignan, Chemist, Public Service
Company of New Hampshire, Manchester, New Hampshire
Robert J. Caron, Surveyor, Department of Highways,
227 Maple Street, Manchester, New Hampshire
John B. Casazza, Supervisory Sanitary Engineer,
Division of Water Pollution Control, State Office Building,
Boston, Massachusetts
Russell G. Claflin, Chairman, Resources, Recreation,
and Development Committee, New Hampshire House of Representatives,
Box 577, Wolfeboro, New Hampshire
Lindsay M. Collins, Sanitary Engineer, Anderson-
Nichols & Company, Inc., 10 Commercial Street, Concord, New
Hampshire
Daniel J. Costello, Associate, Hayden, Harding &
Buchanan, Inc., 1340 Soldiers Field Road, Boston, Massachusetts
E. J. Cullum, Audubon Society, 67 Shark Lane,
Manchester, New Hampshire
John E. Dodge, Coordinator, New Hampshire Committee
for Better Water, 55 State Street, Concord, New Hampshire
Robert B. Edwards, Selectman, Henniker, New Hampshire
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10
OTHERS IN ATTENDANCE (Continued):
Carl L. Eidam, Jr., Aquatic Biologist, New England
Basins Office, FWPCA, 240 Highland Avenue, Needham Heights,
Massachusetts
Cecil T. Enright, Motel Operator representing On
the Merrimack, 5# Manchester Street, Concord, New Hampshire
Donald L. Ethier, Ward 1 Alderman, city of Nashua,
6 Sioux -Avenue, Nashua, New Hampshire
Alfred Fantini, Secretary, Merrimack River Valley
Sewerage Board, 65 Beach Street, Haverhill, Massachusetts
John H. Foster, Partner, Malcolm Pirnie, Engineers,
226 Westchester Avenue, White Plains, New York
Terrence P. Frost, Chief Aquatic Biologist, New
Hampshire Water Supply and Pollution Control Commission,
Concord, New Hampshire
Harry Greenfield, Sales Representative, Hileo
Supply, 665 Central Avenue, Dover, New Hampshire
John F. Grogan, Executive Director, Southern Ncv
Hampshire Planning Commission, 90S Elm Street, Manchester,
New Hampshire
John E. Harney, Wildlife Biologist, Bureau of
Sport Fisheries and Wildlife, 55 Pleasant Street, Concord,
New Hampshire
George T. Healy, Assistant Surveyor, city of
Manchester, 22? Maple Street, Manchester, New Hampshire
Mrs. William Halieisen, Nashua River Clean-up Committee,
Bayberry Road, Pepperell, Massachusetts
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11
OTHERS IN ATTENDANCE (Continued):
Allyn W. Hemenway, Enforcement Officer, Northeast
Region, FWPCA, Boston, Massachusetts
John E. Henchey, City Manager, city of Concord,
Green Street, Concord, New Hampshire
George A. Hill, Sanitary Inspector, Concord Health
Department, City Hall, Green Street, Concord, New Hampshire
James F. Hogan, City Engineer, city of Nashua,
Nashua, New Hampshire
John S. Holden, Fenton G. Keyes Associates, 120 Main
Street, Nashua, New Hampshire
Russell A. Holden, Vice President, New England Power
Company, 4 Park Street, Concord, New Hampshire
Peter D. Hughes, Water Control Engineer, Weyerhaeuser
Company, Box 601, Fitchburg, Massachusetts
David Kittredge, Water Supply Engineer, Manchester
Water Works, 241 Lincoln Street, Manchester, New Hampshire
Vernon A. Knowlton, Water Resources Engineer, New
Hampshire Water Resources Board, Concord, New Hampshire
Myron 0. Knudson, Acting Chief, Operations Branch,
New England Basins Office, FWPCA, 240 Highland Avenue, Needham
Heights, Massachusetts
*
Clifton L. Kuchinski, U. S. General Accounting
Office, John F. Kennedy Federal Building, Boston, Massachusetts
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12
OTHERS IN ATTENDANCE (Continued):
Ray F. Langer, Chairman, Board of Sewer Commissioners,
Main Street, Hooksett, New Hampshire
V/arren K. Lewellen, Chairman, Merrimack Valley Sewer
Commission, 145 Davis Road, Bedford, Massachusetts
Fred Lynch, Operations Engineer, Continental Can
Company, South Kimball Street, Haverhill, Massachusetts
David L. Mann, Executive Director, New Hampshire
Municipal Association, P. 0. Box 617, Concord, New Hampshire
Fred D. McCutchen, Planning Director, city of
Nashua, 92 Main Street, Nashua, New Hampshire
James J. McKeown, Regional Engineer, National Council
for Stream Improvement, Tufts University, Medford, Massachusetts
Thomas C. McMahon, Director, Division of Water
Pollution Control, State Office Building, Boston, Massachusetts
John S. McQuade, Chief, Plans and Services, Fort
Devens, Ayer, Massachusetts
John C. Mongan, Mayor of Manchester, City Hall,
Manchester, New Hampshire
Robert Morin, Commissioner, Board of Sewer
Commissioners, Main Street, Hooksett, New Hampshire
Romeo P. Morin, P. E., 635 Coolidge Avenue,
Manchester, New Hampshire
Sheldon Morrill, City Council, Lawndale Road, Franklin,
•
New Hampshire
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13
OTHERS IN ATTENDANCE (Continued):
Fred T. Mullen, 96 Chauncey Avenue, Manchester,
New Hampshire
Irene L. Mullen, 96 Chauncey Avenue, Manchester,
New Hampshire
Joseph F. Nelson, Project Director, Manchester
Housing Authority, 12 Market Street, Manchester, New Hampshire
Arthur E. Newell, New Hampshire Fish and Game
Department, Concord, New Hampshire
Roland S. Nickless, Representative, Fish and
Game, Inc., 727 Fairfield Street, Manchester, New Hampshire
Howard Northridge, Chairman, Manchester Highway
Commission, Manchester, New Hampshire
Warren H. Oldaker, Acting Chief, Laboratory Branch,
New England Basins Office, FV.PCA, 2/fO Highland Avenue, Needham
Heights, Massachusetts
Herbert R. Pahren, Director, Technical Programs,
Northeast Region, R/PCA, Boston, Massachusetts
Alfred E. Peloquin, Executive Secretary, New
England Interstate Vvater Pollution Control Commission,
73 Tremont Street, Boston, Massachusetts
Frank E. Pendleton, Jr., Engineer, Fitchburg Paper
Company, Fitchburg, Massachusetts
Raymond W. Peters, Plant Engineer, The Mead Corpora-
tion, 250 Canal Street, Lawrence, Massachusetts
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14
OTHERS IN ATTENDANCE (Continued):
John J. Pobst, Staff Consultant, Greater Lowell
Area Planning Commission, 205 Middle Street, Lowell,
Massachusetts
Richard M. Power, Massachusetts State Department
of Public Health, State House, Boston, Massachusetts
Eliot Priest, Vice President, Public Service Company
of New Hampshire, 10S? Elm Street, Manchester, New Hampshire
Thomas Reed, Executive Secretary, Merrimack Valley
Region Association, 4# Hanover Street, Suite 36, Manchester,
New Hampshire
B. M. Reen, City Engineer, Manchester Highway Depart-
»
ment, 22? Maple Street, Manchester, New Hampshire
Jerome Resnick, Environmental Engineer, Monsanto
Biodize Systems, 112-20 14th Avenue, College Point, New York
George B. Roberts, Jr., State Representative,
R. F. D. 1, Gilmanton, New Hampshire
Paul E. Roche, Chemical Engineer, Gilbert Associates,
Inc., $25 Lancaster Avenue, Reading, Pennsylvania
John F. Scarola, Fishery Biologist, New Hampshire
Fish and Game Department, Concord, New Hampshire
Thomas A. Schrader, Assistant Regional Director,
U. S. Bureau of Sport Fisheries and Wildlife, Post Office and
Courthouse Building, Boston, Massachusetts
Don Sinville, Assistant to the President, Public
Service Company of New Hampshire, Manchester, New Hampshire
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15
OTHERS IN ATTENDANCE (Continued):
William A. Slagle, Jr., Associate Civil Engineer,
Division of Water Pollution Control, State Office Building,
Boston, Massachusetts
Donald R. Smith, Chief, Program Management, New
England Basins Office, FWPCA, 240 Highland Avenue, Needham
Heights, Massachusetts
Mrs. Hugh F. Stoddart, Coordinator, Massachusetts
Nashua River Cle.an-up Committee, Groton, Massachusetts
F. William Swaine, Civil Engineer, New England
Division, Corps of Engineers, U. S. Department of the Army,
424 Trapelo Road, Waltham, Massachusetts
Mrs. Selwyn Taylor, Chairman, Water Resources
Committee, League of Women Voters of New Hampshire, 20 Lock
Street, Nashua, New Hampshire
Worthen H. Taylor, Water Quality Standards Coordinator,
Northeast Region, FWPCA, Boston, Massachusetts
Bert Teague, Vice President, Anderson-Nichols &
Company, Inc., 10 Commercial Street, Concord, New Hampshire
J. F. Theriault, Chemist, Continental Can Company,
Haverhill, Massachusetts
H. Thomas Urie, Representative, New Hampshire General
Court, New Hampton, New Hampshire
Henry C. Waldo, Manager, Wood Department, Franconia
Paper Corporation, Lincoln, New Hampshire
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16
OTHERS IN ATTENDANCE (Continued):
W. Ray Walker, Regional Planner, Southern New
Hampshire Planning Commission, 908 Elm Street, Manchester,
New Hampshire
Norrel Wallace, Area Supervisor, Bureau of Sport
Fisheries and Wildlife, 55 Pleasant Street, Concord, New
Hampshire
Philip Wightman, Fishery Biologist, New Hampshire
Fish and Game Department, 34 Bridge Street, Concord, New
Hampshire
Richard H. Young, Executive Director, Central
Merrimack Valley Regional Planning District, 477 Essex Street,
Lawrence, Massachusetts
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17
Opening Statement - Mr. Stein
PROCEEDINGS
OPENING STATEMENT
BY
MR. MURRAY STEIN
CHAIRMAN STEIN: The second session of the conference
in the matter of pollution of the interstate waters of the
Merrimack and Nashua Rivers and their tributaries (Massa-
chusetts - New Hampshire) and of the intrastate portions of
\
V
those waters within the State of Massachusetts, held under
the provisions of the Federal Water Pollution Control Act.
Under the provisions of the Act, the Secretary of
the Interior is authorized to call a conference of this type
when, on the basis of reports, surveys or studies, he has
reason to believe that pollution of interstate waters subject
to abatement under the Federal Act is occurring, or when he
has received a request from a State governor to do so. Both
circumstances apply to this conference.
The purpose of the conference is to bring together
•
the State and interstate water pollution control agencies,
representatives of the United States Department of the
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18
Opening Statement - Murray Stein
Interior and the other interested parties to review the
existing situation and the progress which has been made,
to lay a basis for future action by all parties concerned,
and to give the States, localities and industries an
opportunity to take any indicated remedial action under
State and local law.
The first session of this conference was held
on February 11, 1964» on the basis of reports, surveys, or
studies, and upon the request of the Honorable Endicott
Peabody, Governor of Massachusetts.
At the first conference session, the conference
agreed that remedial measures being undertaken were not
adequate to abate pollution, due in part to a lack of
finances and the resulting heavy burden to be placed on
waste discharges.
The Secretary of Health, Education, and Welfare,
in whom Federal enforcement authority then resided,
issued the following Federal requirements for the
conference area after the first session:
That the Merrimack and Nashua Rivers and their
tributaries be classified as to future highest uses by
1965;
That by May 1, 1966, all communities arrange, vote
and authorize financing for remedial facilities, and that
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19
Opening Statement - Murray Stein
all municipal and industrial sources of pollution have
their plans and specifications approved by the appropriate
State water pollution control agency;
That by May 1, 196?, construction be started on
all waste treatment facilities, which, then be placed in
operation within a reasonable time after the initiation
of construction;
That appropriate action be taken by New Hampshire
and Massachusetts under their water pollution programs
and State and local laws to carry out an effective
pollution abatement program, the program and schedule of
compliance for New Hampshire to be commensurate with that
which Massachusetts established soon after the holding of
the first conference session.
This session of the conference was called for the
purpose of reviewing the status of both States' pollution
abatement programs since the first conference session.
As specified in section 10 of the Federal Water
Pollution Control Act, the Secretary of the Interior has
notified the official State water pollution control agencies
of New Hampshire and Massachusetts and the New England
Interstate Water Pollution Control Commission of this
conference. This conference is "between the official State
and interstate agencies and the United States Department of
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20
Opening Statement - Murray Stein
the Interior. The New Hampshire Water Supply and Pollution
Control Commission will be represented by Mr. James A.
Sweeney, Vice Chairman of the Commission, and Mr. William
Healy. The Massachusetts Department of Natural Resources
will be represented by Thomas McMahon, accompanied by Mr.
John B. Cassaza. The representative of the New England
Interstate Water Pollution Control Commission is Mr. Alfred
Peloquin. Mr. Lester Klashman has been designated as
conferee for the Federal Government.
My name is Murray Stein. I am from headquarters of
the Department of the Interior, Washington, D. C., and the
representative of the Secretary of the Interior Stewart
Udall.
The parties to this conference are the representa-
tives of the State and interstate agencies and the United
States Department of the Interior. Participation in the
conference will be open to representatives and invitees of
these agencies and such persons as inform me that they
wish to present a statement. However, only the representa-
tives of New Hampshire, Massachusetts and the New England
Interstate Commission and the United States Department of
the Interior constitute the conferees.
Both the State and Federal Governments have respon-
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21
Opening Statement - Murray Stein
slbllitles In dealing with water pollution control problems.
The Federal Water Pollution Control Act declares that the
States have primary rights and responsibilities for taking
action to abate and control pollution. Consistent with
this, we are charged by law to encourage the States in
these activities.
At the same time, the Secretary of the Interior
is charged by law with specific responslbilltes in the
field of water pollution control in connection with
pollution of interstate and navigable waters. The Federal
Water Pollution Control Act provides that pollution of
interstate or navigable waters which endangers the health
or welfare of any persons shall be subject to abatement.
This applies whether the matter causing or contributing
to the pollution is discharged directly into such waters
or reaches such waters after discharged into a tributary.
Now a word about the procedures governing the
conduct of the conference. The conferees will be called
upon to make statements. The conferees, in addition, may
call upon participants whom they have invited to the
conference to make statements. In addition, we shall
call other Interested Individuals to present statements,
but I would suggest that anyone who wishes to make a
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22
Opening Statement - Murray Stein
statement get in touch first with his representative,
either from Massachusetts or New Hampshire, and have him
call you. Each one of the States will manage its own time.
At the conclusion of each statement, the conferees
will be given an opportunity to comment or ask questions,
and I may ask a question or two. This procedure has proven
effective in the past in reaching equitable solutions.
Now, let me make this clear. We will not entertain
questions from the floor. Because if we did that, we
would be here for a very long time; and I do not know whether
we would arrive at any more equitable solution than we do
by this procedure.
However, everyone who whishes will have an opportunity
to say his piece. Just hold it until we call you. If you
have questions or queries when you are called in an orderly
manner, you can put them forward.
At the end of all the statements, we will have a
discussion among the conferees and try to arrive at a basis
of agreement on the facts of the situation. Then we shall
attempt to summarize the conference orally, giving the
conferees, of course, the right to amend or modify this
oral summary.
A record or a verbatim transcript of the conference
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23
Opening Statement - Murray Stein
Is being made. This is for the purpose of aiding us in
preparing a summary and, also, for providing a complete
record of what is said here. It usually takes about four
or six months for the transcript to come out in printed
form. If you wish a record beforehand, you can check
with the reporter, who is on contract, and make your own
arrangements with him.
I might indicate that we do not print out transcripts
in color. So take that into account on any charts you may
present which are in color. The reproduction will come
out in black and white. Try not to refer to colors if
you use graphic aids in your presentation, as they will be
meaningless when the transcript is printed.
We will make copies of the summaries and transcript
available to the official State and Interstate water pollu-
tion control agencies. The Secretary will prepare a
written summary of this conference and send it forth,
generally within several weeks after the conference is
concluded.
We have found that for the purpose of maintaining
relationships within the States, the people who wish
.*
summaries and transcripts should request them through their
State or interstate agency rather than come directly to the
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24
Thomas McMahon
Federal Government. The reason for this is that, when the
conference has been concluded, we would prefer people who
are interested in the problem to follow their normal
realtions in dealing with the State or interstate agencies
rather than the Federal Government. Again, this has worked
successfully in the past, and we will be most happy to make
this material available for distribution.
I would suggest that all speakers or participants,
other than the conferees, making statements come to the
lectern and identify themselves for the purpose of the record.
Our general procedure is going to be to call on the
Federal Government for statements first, New Hampshire, followed
by Massachusetts, then the New England Interstate Agency. They
will call on their participants. However, the agenda is
flexible. If we have any specific problem, I am sure we can
meet it.
First we have two out of order. Just to start this,
Mr. McMahon of Massachusetts has a short statement to make
at this time. Mr. McMahon.
STATEMENT OF THOMAS McMAHON, DIRECTOR, DIVISION OF
WATER POLLUTION CONTROL, MASSACHUSETTS
WATER RESOURCES COMMISSION, DEPARTMENT
OF NATURAL RESOURCES, BOSTON, MASSACHUSETTS
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25
Thomas McMahon
MR. McMAHON. Thank you, Mr. Chairman.
First, I would like to announce that Commissioner
Yasi could not be here. He is on a special assignment for
the Governor. He expresses his regrets and we hope to see
him in the very near future.
A second one is a general statement that
Massachusetts has made at a number of Federal enforcement
conferences earlier, and I would like to read it into the
record, with your permission, Mr. Chairman, at this time:
"Mr. Chairman, the Massachusetts Division of
Water Pollution Control is present today in the spirit of
cooperation with the Federal Water Pollution Control
Administration, the New England Interstate Water Pollution
Control Commission and the New Hampshire Water Supply and
Pollution Control Commission. Any material, whether
written or oral,, presented at this conference shall in
no way commit the Commonwealth to changes in the
Massachusetts standards of water quality approved by
the Massachusetts Water Resources Commission and the
Secretary of the Interior and shall not convey any authority
that transcends the Jurisdictlonal authority vested in the
Massachusetts Clean Waters Act or the Federal Water and
Pollution Control Act."
Thank you,
CHAIRMAN STEIN. Thank you, Mr. McMahon.
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26
Honorable Thomas Urie
Now, we also at this point would like to call on
Representative Urie, Thomas Urie of New Hampshire who has
requested to make the statement now because he has other
commitments. Representative Urie.
STATEMENT OP THE HONORABLE THOMAS URIE
REPRESENTATIVE, GENERAL COURT
NEW HAMPTON, NEW HAMPSHIRE
REPRESENTATIVE URIE. Thank you, Mr. Chairman.
I am Representative Thomas Urie, Belknap, District
1, and one of the people who has the Job of presenting
water pollution legislation to the New Hampshire Legislature.
As a rule, I do not like to read a speech, but in
this particular instance I feel that I should do so.
At this time, I would like to comment on this
State's pollution control effort, and in particular the
work which has been accomplished or is now under way in
the Pemigewasset-Merrimack River system.
Many of you are aware that I have been an ardent
supporter of clean waters for years. It has never been
necessary for anyone to sell me on the need of cleaning
up and protecting our surface waters. My efforts over
the years in this area speak for themselves, and I will
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27
Honorable Thomas Urie
add that I have closely followed the program of the
New Hampshire Water Supply and Pollution Control Commission,
and agree in every way with its content and timetable for
construction of pollution control facilities.
Regarding this construction schedule of sewage
and industrial waste treatment plants, I would like to
point to what is now taking place on the Pemigewasset
River. Prom the town of Woodstock to the point where
the Pemigewasset Joins the Merrimack, there are six towns
and one industry which are engaged in construction, or
have completed pollution abatement facilities. By this
time next year, every municipality and industry along
the Pemigewasset and its tributaries will be effectively
controlling pollution, and I am convinced that the
realistic timetable established by the Water Supply and
Pollution Control Commission will accomplish the same
results for the balance of the river system to the
Massachusetts line.
Now to get down to the matter of financing. On
the State side of the picture, New Hampshire has the highest
aid program of any of the 50 states; 40 percent, and may I
digress there for a minute.
Yesterday I filed a bill, which I hope will get
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28
Honorable Thomas Urie
attention, which will Increase It to 50 percent.
We reimburse municipalities over the life of their
bonded Indebtedness for the project, provide interest on
the State's share, and guarantee bond Issues used for this
work. This State has committed itself to over $15,000,000 in
State grants since 1959* and never once has it failed to
meet its financial responsibilities.
I am well aware that we have nearly $150,000,000
of pollution control work to complete in this State, of
which nearly $60,000,000 is on the Merrimack or its
tributaries. Even though this represents a much heavier
burden than most other states must carry, I feel extremely
confident that New Hampshire will continue to meet its
future obligations from both the standpoint of time and
money.
Regarding the time involved to accomplish this
work, I have already indicated that I am totally in agree-
ment with the schedule submitted with this State's standards
for compliance by 1977 on interstate waters, and I will add
that my active support was given to the Act which was known
as Senate Bill 83, passed by our 1967 Legislature of which
I was a member. In putting these requirements of the Water
Quality Act of 1965 into New Hampshire law, we even went to
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29
Honorable Thomas Urie
the point of stating our objectives which call for the
initial objective of primary treatment with adequate
disinfection of discharges of sewage and industrial
wastes, followed by a second objective which would
require secondary treatment wherever necessary to protect
uses assigned to the particular stream classification. We
even went beyond this with objectives relating to more
refined treatment, but the point which I Intend to emphasize
is that New Hampshire should adhere to the first objective
of primary treatment throughout the State before we proceed
to the second, third or any other objective. This, as the
law says, is "a matter of legislative intent." That was
what we passed in the Legislature—that it was our intent
to proceed beyond primary after we had got the entire State
on the primary treatment basis.
To conclude, I will mention once again that New
Hampshire has never once failed to meet its financial
obligations in controlling water pollution. Its schedule
to reach the clean waters goal is realistic in every way,
and its initial objective of primary treatment throughout
has my unqualified support.
* *
In addition, I can see no Justification on the
part of the Federal Government in making any demands on
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Honorable Thomas Urie
this State over and above those which we have stated,
especially when it has failed to meet authorized financial
commitments by better than 50 percent during the past
year. To me this means but one thing the Federal Govern-
ment has not produced the money that it was supposed to
produce in the last biennium, but now they are asking the
State to go ahead with its commitments and the Federal
Government, I am afraid, is a little bit lagging in its
commitment. So I feel that it is necessary for the Federal
Government to live up to its obligations, Just the same as
it is for the State to live up to its obligations.
Thank you, gentlemen.
CHAIRMAN STEIN. Thank you, Representative Urie.
Are there any comments or questions?
(No response.)
CHAIRMAN STEIN. I would like to commend you on
the statement. I know, in meeting with Representative
Urie through the years on this problem,there is no one who
works harder for pollution control in the State of New
Hampshire I think in the United States than Representative
Urie. He has been a prime mover in New Hampshire in getting
the program goins.
As one will develop whatever system of government
one represents- state, Federal or local - there are bound
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31
Lester Klashman
to be possibly some differences. However, in dealing with
Representative Urie, we have never had these conceptual
differences or philosophies stand in the way of trying to
get together and meet a problem. As far as I can see, we
have always worked out an accommodation. If we proceed in
this spirit, I hope we will be able to handle that program.
Thank you very much.
MR. Klashman, Director, FWPCA Northeast Regional
Office, representing the Federal Government.
STATEMENT OF LESTER KLASHMAN
DIRECTOR, NORTHEAST REGION
U. S. DEPARTMENT OF THE INTERIOR
FEDERAL WATER POLLUTION CONTROL ADMINISTRATION
BOSTON, MASSACHUSETTS
MR. KLASHMAN. This second session of the conference
of the Merrimack and Nashua Rivers has the following three
objectives from our standpoint:
l) to resolve the schedules for the pollution
abatement programs for Manchester, Concord, Plymouth, New
Hampshire and those municipalities and industries in Massa-
^chusetts where there have been modifications in the dates
[which have been previously submitted and approved by the
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32
Herbert Pahren
Secretary.
2) to present the results of the technical study
of the Merrlmack and Nashua Rivers conducted through 1964
and 1965 by the Federal Water Pollution Control Administra-
tion.
3) to review the status of compliance with
pollution abatement schedules given to the various polluters
within the conference area.
I would like to first call on Mr. Herbert Pahren,
the Director of Technical Programs for the Northeast Region
of the Federal Water Pollution Control Administration to
give our statement.
STATEMENT OF HERBERT R. PAHREN
DIRECTOR, TECHNICAL PROGRAMS
NORTHEAST REGION
U. S. DEPARTMENT OF THE INTERIOR
FEDERAL WATER POLLUTION CONTROL ADMINISTRATION
BOSTON, MASSACHUSETTS
MR. PAHREN: Mr. Chairman, conferees, ladies and
gentlemen. Mr. Chairman, I would like to introduce the
report of our technical study in six parts as an exhibit in
this conference but not as part of the transcript.
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33
Herbert Pahren
CHAIRMAN STEIN. Without objection from the
conferees, this will be done. We will make copies of
this available to the States and they will be on file
and available for inspection during the normal business
hours at our Regional Office in Boston and at headquarters.
(The above-mentioned Federal report in six parts, marked
Exhibit 1, is on file at the Federal Water Pollution
Control Administration Northeast Regional Office, Boston,
Massachusetts, and Federal Water Pollution Control Adminis-
tration Office, Washington, D. C.)
How many copies of this do you have for distribu-
tion in case anyone wants it?
MR. PAHREN. I think the majority of the people
in the audience today have copies already.
CHAIRMAN STEIN. All six?
MR. PAHREN. Yes. Some of them Just want the
summary.
CHAIRMAN STEIN. Right.
If you really need these, I suggest while the
supply lasts you can get them. I would also ask as
reasonably concerned and good citizens you Just take the
summary, so we will have a supply of that technical backup
for the people that really make use of it. Thank you.
MR. PAHREN. The summary of our study is as follows:
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34
Herbert Pahren
The Merrimack River is polluted —
MR. KLASHMAN. Excuse me, Mr. Pahren. Did you
want the summary entered as if read completely? You are
not going to read it all, are you?
MR. PAHREN. The initial summary I will read
verbatim from here.
MR. KLASHMAN. I mean are you going to have this
whole document made as part of the record?
MR. PAHREN. Part One?
MR. KLASHMAN. Yes.
MR. PAHREN. Yes, I would like Part I included in
the transcript as if read.
CHAIRMAN STEIN. Without objection, this will be
done.
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35
Herbert Pahren
CHAIRMAN STEIN: Will you continue.
MR. PAHREN. The Merrimack River is polluted by
the discharge of raw and partially treated municipal and
industrial wastes for most of its length in New Hampshire
and Massachusetts. Every day more than 120 million gallons
of wastewater flow into the Merrimack River alone, polluting
it physically, bacteriologlcally and chemically. This
polluted condition, which has been recognized since the turn
of the century, will become progressively worse unless
effective abatement action is taken immediately.
The major sources of raw or inadequately treated
municipal waste discharged to the Merrimack River Basin are:
New Hampshire: Allenstown, Bristol, Concord,
Franklin, Hooksett, Lincoln, Manchester, Milford, Nashua,
Pembroke, Plymouth, Wilton.
Massachusetts: Amesbury, Andover, Clinton, Dracut,
Pitchburg, Groveland, Haverhill, Lawrence, Leominster,
Lowell, Methuen, Newburyport, North Andover, Salisbury.
The major sources of industrial waste discharged
to the Merrimack River Basin are:
New Hampshire: Ashland Paper Mills, Ashland;
Poster Grant Co., Manchester; Pranconia Paper Corp., Lincoln;
Granite State Packing Co., Manchester; Granite State Tanning
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36
Herbert Pahren
Co., Nashua; Merrimack Leather Co., Merrimack.
Massachusetts: Continental Can Co., Haverhill;
Palulah Paper Co., Fitchburg; Fitchburg Paper Co., Fitch-
burg; Foster Grant Co., Leomlnster; Gilet Wool Scouring
Corp., Chelmsford; Lawrence Wool Scouring Co., Lawrence;
Lowell Rendering Co., Billerica; Mead Corp., Lawrence;
Oxford Paper Co., Lawrence; Southwell Combing Co., Chelms-
ford; St. Regis Paper Co., Pepperell; Weyerhaeuser Paper Co.,
Fitchburg.
Suspended solids in waste discharges in the study
area were equivalent to those in the raw sewage of 1,653,000
persons, with 72 percent originating in Massachusetts. These
materials cause deep sludge deposits which deplete the stream
oxygen supply, produce offensive odors, reduce or eliminate
aquatic life which serves as food for fish, and make once
attractive waters appear murky.
Coliform bacteria equivalent to those in the raw
sewage from 416,000 persons are discharged to the Merrimack
River and its tributaries at the present time, with 3^ percent
originating in New Hampshire and 66 percent originating in
Massachusetts. Sewage effluents receiving no treatment account
for 92 percent of the total coliform bacteria in the stream.
Nashua and Hudson, New Hampshire, contributed over
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37
Herbert Pahren
9S percent of the coliform bacteria at the New Hampshire-
Massachusetts state line during warm low-flow periods. How-
ever, with colder water temperatures and increased flows in
the autumn, the Nashua-Hudson portion at the state line was
reduced to 50 percent; Manchester, New Hampshire, was respon-
sible for 25 percent of the total; and other upstream com-
munities were responsible for 25 percent. Of the bacteria
originating from upstream communities and reaching Nswbury-
nort, Massachusetts, 51-4 percent emanated from the Lawrence
region, 17.1 percent from the Haverhill region, 31.4 percent
from the Amesbury area, and 0.1 percent from the remaining
upstream communities.
Coliform densities as high as 9,200,000 per 100
milliliters were found in the Merrimack River. This value,
found below Lawrence, is 1,350 times the recommended maximun
value of 5,000 per 100 ml. (One hundred milliliters of water
is slightly less than one-half cup.) This excessive bacterial
pollution presents a health hazard to all who come in contact
with the water.
Disease-producing bacteria of the genus Salmonella
were consistently recovered from the Merrimack in both New
Hampshire and Massachusetts, indicating that ingestion of any
water from the Merrimack River before it is treated or of
produce from truck farms using untreated river water for
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38
Herbert Pahren
irrigation is a definite health hazard. Salmonellae were
isolated during every test made at the Lowell and Lawrence,
Massachusetts, water intakes. Typhoid fever, gastroenteritis,
and diarrhea are a few of the many diseases of man caused by
these bacteria.
Sewage and industrial wastes presently discharged
to the basin have an estimated biochemical oxygen demand
equivalent to that in the untreated sewage of 1,422,000
persons, of which 693>000 population equivalents are dis-
charged in New Hampshire. BOD is a measure of the ability
of a waste to deplete the dissolved oxygen resource of a
stream.
Serious depletion of the dissolved oxygen content
of the Merrimack River occurred during the study period.
For the months of June, July, August and September of
1964 and 1965» minimum dissolved oxygen from Manchester
to Newburyport was less than 2.0 parts per million at every
station; zero values were found below Haverhill. At no
point upstream of Manchester was the minimum value in
excess of five parts per million. A value of five parts
per million for at least 16 hours a day is one requirement
of the New England Interstate Water Pollution Control
Commission for Class C waters, C being the class of water
considered acceptable for recreational boating, fish
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39
Herbert Pahren
habitat and industrial water supply but not for swimming
or drinking under normal conditions. Using BOD as an
indicator, the most polluted reach of the Merrimack River
was between Lawrence and Haverhill, Massachusetts.
BOD crossing the state line from New Hampshire into
Massachusetts amounted to 28,300 pounds per day. This is
equivalent to the BOD of raw sewage from 169,000 persons.
As a result of the reduction in dissolved oxygen, fish,
fish food organisms and other desirable forms of aquatic
life are destroyed. In addition, when the dissolved oxygen
content of the river is sufficiently low, obnoxious gases
are given off by the stream, forcing unsightly clumps of
sludge to rise to the surface.
Biological stream studies showed that, with few
exceptions, the entire length of the Merrimack River is
grossly polluted from Franklin, New Hampshire, to its
mouth at Newburyport, Massachusetts. Those desirable
benthic organisms sensitive in their response to pollution
i
were absent in the lower 57 miles of the Merrimack River.
In only four areas did the river recover enough from its
despoiled condition to permit a small number of sensitive
organisms to exist before additional wastes reduced the
quality of the river.
Serious pollution exists in the North Nashua River
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40
Herbert Pahren
from the outfall of the Weyerhaeuser Paper Company,
Fitchburg, Massachusetts, to the confluence of the north
and south branches of the Nashua River at Lancaster, Massa-
chusetts; in the Nashua River from Lancaster, Massachusetts;
in the Nashua River from Lancaster to the mouth of the
Nashua River in New Hampshire; in the Squannacook River
below the dam at Vose Village; and in the South Branch
Nashua River below Clinton, Massachusetts. This pollution
affects present and potential water uses.
Discharges from paper mills result in suspended
solids, organic matter causing biochemical oxygen demand,
and materials causing apparent color in the stream. By far
the largest loadings emanate from the three paper industries
of Fitchburg, Massachusetts. Excessive bacterial densities,
suspended solids, nutrients and organic matter are the
result of inadequate sewage treatment, particularly at
Fitchburg and Leominster, Massachusetts.
Discharges of suspended solids create a severe
problem in the Nashua River. Suspended solids discharged
to the Nashua River Basin are equivalent to those in the
raw sewage from 556,000 persons. Of these, nearly 92 per-
cent come from the paper mills. It is estimated that 17
million cubic feet of sediments have accumulated in
Pepperell pond alone.
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41
Herbert Pahren
Bacteria equivalent to those in the raw sewage of
approximately 24,000 persons are discharged to the Nashua
River Basin at present. Fitchburf and Leominster, Massa-
chusetts, contribute 90 percent of the total. The coliform
bacteria in the North Nashua River were as high as 680 times
the recommended maximum value of 5,000 per 100 ml for this
stream. Disease-causing bacteria were isolated in both the
North Nashua and the South Branch Nashua Rivers.
Sewage and industrial wastes presently discharged
to the Nashua River Basin have an estimated biochemical
oxygen demand population equivalent of 178,000, of which the
paper industries contribute 76 percent of the total. As a
result of the reduction in dissolved oxygen, fish, fish food
organisms and other desirable aquatic life are destroyed and
obnoxious odors are given off by the stream.
Nutrients discharged to the Nashua River Basin result
in excessive densities of algae and other aquatic plants,
creating a nuisance. These plants may die and decompose,
causing unsightly conditions, obnoxious odors and depletion
of dissolved oxygen.
Serious pollution exists in the Pemigewasset River
from the confluence -with the East Branch Pemigewasset River
in Lincoln, New Hampshire, to the confluence of the Winni-
pesaukee River in Franklin, New Hampshire, due to the
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42
Herbert Pahren
discharge of sewage and industrial wastes in the basin.
Suspended solids discharged to the Pemigewasset
River watershed are equivalent to those In the raw sewage
of 287,500 persons, of which over 98 per cent emanate from
industrial plants. These solids result in sludge deposits,
especially in the impoundment behind Ayers Island Dam.
Hydrogen sulfide, resulting from sludge deposits behind
this dam> caused thousands of dollars of damage to houses
in Bristol, New Hamsphire, on August 18, 1965, and on
August 23, 1966, by discoloring the paint on the houses.
Sulflte waste liquor, released to the Pemigewasset
River by the Pranconia Paper Corporation, not only creates
an enormous oxygen demand but also contains lignin sulfonates
which persist as the waters flow into Massachusetts. As a
result of the sulfite waste liquor, the river is discolored,
adding to the water treatment costs at Lowell and Lawrence,
Massachusetts
Restricted recreational use of the Merrimack and its
tributaries due to their polluted conditions alone caused
an estimated loss of $21,300,000 in 1964. There is presently
a very limited amount of fishing in the basin, but the U. S.
Pish and Wildlife Service has expressed interest in reintro-
ducing salmon and other anadromous fish to the streams once
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43
Herbert Pahren
the pollution has been abated.
In 1964 the value of the soft-shell clam harvest
amounted to only $14,000 of a potential $1,000,000. Dis-
charges to the Merrimack River estuary from existing
sewage treatment plants significantly contribute to the
bacterial densities near the shellfish growing areas.
An even greater loss can be attributed to decreased
property values and the resulting decrease in the tax revenues
caused by the polluted condition of the Merrimack River and
its tributaries. In 1964 these losses to communities in the
basin amounted to about $14,600,000.
It is estimated that between $37,000,000 and $70,000,000
is being lost annually as a result of pollution in the
Merrimack River Basin.
Although the Merrimack River is now used for industrial
process water, cooling water, and for hydroelectric power,
sand filters and other treatment methods are often employed
at the Industry's expense to precondition the water before
it can be used. An Increase in industrial development
could be expected once the basin communities can offer Im-
proved water quality.
*
The Merrimack is also used as a municipal water supply
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44
Herbert Pahren
for Lowell and Lawrence, Massachusetts. As the polulation
in the basin increases, more and more communities will be
turning to the Merrimack to meet their water needs because
it is the only water supply of sufficient quantity to meet
the demand. Eight basin communities have already expressed
interest in the use of the river. Well-designed and efficient
sewage treatment plants will be necessary to ensure adequate
water quality.
Sewage and industrial wastes continue to be dis-
charged to the Merrimack River and its tributaries in New
Hampshire, causing pollution which endangers the health or
welfare of persons in Massachusetts; the sewage and indus-
trial wastes discharged to the Merrimack River and its
tributaries in Massachusetts cause pollution which endangers
the health or welfare of persons in New Hampshire and Massa-
chusetts. Therefore, this pollution is subject to abatement
under the provisions of the Federal Water Pollution Control
Act (33 United States Code 4-66 et sequence).
Recommendations:
Many suggestions of the Merrimack River Project
concerning water quality criteria and stream classification
have already been implemented by the two Basin States in the
process of adopting water quality standards. Still others
are being considered by the New England Interstate Water
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45
Herbert Pahren
Pollution Control Commission for the region as a whole as
well as the basin waters.
Implementation and construction schedules submitted
by the States of New Hampshire and Massachusetts and approved
by the Secretary of the Interior, as required by the Federal
Water Pollution Control Act, as amended, shall be followed
for the Merrimack River Basin. Implementation and construc-
tion schedules for sources of pollution on intrastate portions
of the Merrimack River Basin in Massachusetts shall be in
accordance with State and local requirements so as to meet
the stream classificiations.
It is recommended that the implementation program for
the following New Hampshire communities in the Merrimack River
Basin that did not receive approval by the Secretary be as
follows:
For Manchester, Concord and Plymouth we are recom-
mending secondary treatment.
For Manchester, final plans and specifications by
December 1970; start construction by April 1972; complete
construction by December 1974.
For Concord, final plans and specifications by May
>
1969; start construction by April 1971; complete construction
by April 1973.
Plymouth, final plans and specifications by July
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46
Herbert Pahren
1971; start construction by July 1973; complete construction
by December 1974.
Consideration shall be given in the water pollution
control programs, as necessary, to the following:
1. Sewerage systems with collection sewers terminating
in adequate treatment facilities shall be provided in
those 'areas along the stream where sewers do not now
exist and where homes discharge either raw wastes or
septic tank effluent to the watercourse and where local
treatment facilities will not suffice.
2. All new construction of sewer lines and revisions to
existing systems shall provide for the separation of
storm runoff and sewage.
3. All new and existing, waste treatment facilities shall
by designed or modified, if possible, to prevent by-
passing of untreated wastes during maintenance and
renovation operations and power failures.
4. All municipal and industrial wastes in the Merrimack
River Basin are to receive a minimum of secondary
treatment or equivalent. All effluents containing
domestic wastes are to receive adequate disinfection.
Maximum removal of nutrients, including phosphates, by
the most effective available means is to be provided,
f>
as necessary, to meet stream classifications.
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47
Herbert Pahren
5. All industries and municipalities in the area dis-
charging waste material to the public waters shall
maintain an inventory of critical waste treatment
parts and supplies on the plant premises so that a
minimum delay in effective waste treatment will result
when replacement or repair is necessary.
6. Consideration shall be given for 24-hour supervised
operation of all sewage treatment plants.
7. Provisions shall be made to allow sampling of the final
effluent prior to discharge.
8. No backwater or eddies shall exist near the outfall
that would hinder mixing. The location of the outfall
should be such as to enhance mixing of the treatment
plant effluent.
9. Operation of dams in the Merrimack River Basin should
be regulated by the appropriate agency so that certain
adequate flows are released at all times.
10. All water treatment plants shall dispose of spent
activated carbon and settled solids by means other
than to the stream.
11. Facilities to accept septic tank t^ruck discharges are
to be provided at sewage treatment plants or other
approved areas.
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48
Herbert Pahren
12. There shall be no discharges from septic tank
cleaning operations directly to the waters of the
basin.
13. All marine conveyances equipped with marine toilets
operating upon the basin waters shall use a holding
tank or other approved pollution control device.
14. The appropriate agency should prohibit garbage or
refuse (including automobile bodies and other unsightly
debris) from being dumped along the banks of the
river, and no open dumps should be allowed on the flood
plain. Material in present dump sites along the river
banks shall be removed and appearance of the bank
restored to an aesthetically acceptable condition.
Present open dumps on the flood plain should be converted
to sanitary landfills operated acceptably to the appropri-
ate State agencies.
15. In the shellfish growing areas near the mouth of the
Merrimack River, the requirements of the National Shell-
fish Sanitation Program are to be met in order to permit
reopening of the maximum number of those areas presently
closed to the harvesting of shellfish.
16. Consideration should be given by the city of Newburyport
and the town of Salisbury, Massachusetts, to developing
an engineering report which would include the relative
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Herbert Pahren 49
merits of:
a. Treatment and joint discharge of the Atlantic
Ocean;
b. Individual discharges to the Atlantic Ocean;
c. Joint treatment and discharge to the Merrimack
estuary; and
d. Individual discharges to the Merrimack estuary.
In all cases, the report shall include the relative
economic values of the estuarine resources.
Mr. Chairman, this completes my statement.
(Part 1, of above-summarized report follows.)
-------
RE PORT ON POLLUTION OF
THE MERRIMACK RIVER
and CERTAIN TRIBUTARIES.
PART 1
SUMMARY CONCLUSIONS
and RECOMMENDATIONS
U.S. Department of the Interior
Federal Water Pollution Administration
Northeast Region
BOSTON, MASSACHUSETTS
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51
REPORT ON POLLUTION OF
THE MERRIMACK RIVER
AND CERTAIN TRIBUTARIES
PART I — SUMMARY, CONCLUSIONS, AND RECOMMENDATIONS
U. S. Department of the Interior
Federal Water Pollution Control Administration
Northeast Region
Boston, Massachusetts
December, 1968
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TABLE OF CONTENTS
Page No.
SUMMARY ii
INTRODUCTION 1
STREAM STUDIES — PHYSICAL, CHEMICAL, AND BACTERIOLOGICAL 3
Study Area 3
Pollution Sources ^
Water Uses 7
Effects of Pollution on Water Quality 8
STREAM STUDIES — BIOLOGICAL lU
PILOT PLANT STUDY OF BENTHAL OXYGEN DEMAND 16
NASHUA RIVER 17
PEMIGEWASSET RIVER 20
RECOMMENDATIONS 22
-i-
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53
SUMMARY
The Merrimack River is polluted by the discharge of raw and partially
treated municipal and industrial wastes for most of its length in Nev
Hampshire and Massachusetts. Every day more than 120 million gallons of
waste water flov into the Merrimack River alone, polluting it physically,
bacteriologically, and chemically. This polluted condition, which has
been recognized since the turn of the century, will become progressively
worse unless effective abatement action is taken immediately.
The major sources of raw or Inadequately treated municipal waste
discharged to the Merrimack River Basin are:
Hew Hampshire
Allenstown Hooksett Nashua
Bristol Lincoln Pembroke
Concord Manchester Plymouth
Franklin Milford Wilton
Massachusetts
Amesbury Oroveland Lowell
Andover Haverhill Methuen
Clinton Lawrence Newburyport
Dracut Leominster North Andover
Fitchburg Salisbury
The major sources of industrial waste discharged to the Merrimack
River Basin are:
-ii-
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54
Nev Hampshire
Ashland Paper Mills, Ashland
Foster Grant Co., Manchester
Franconia Paper Corp., Lincoln
Granite State Packing Co., Manchester
Granite State Tanning Co., Nashua
Merrimack Leather Co., Merrimack
Massachusetts
Continental Can Co., Haverhill
Falulah Paper Co., Fitchburg
Fitchburg Paper Co., Fitchburg
Foster Grant Co., Leominster
Gilet Wool Scouring Corp., Chelmsford
Lawrence Wool Scouring Co., Lawrence
Lowell Rendering Co., Billerica
Mead Corp., Lawrence
Oxford Paper Co., Lawrence
Southwell Combing Co., Chelmsford
St. Regis Paper Co., Pepperell
Weyerhaeuser Paper Co., Fitchburg
Suspended solids in waste discharges in the study area were equiva-
lent to those in the raw sewage of 1,653,000 persons, with 72 per cent
originating in Massachusetts. These materials cause deep sludge deposits
which deplete the stream oxygen supply, produce offensive odors, reduce
or eliminate aquatic life which serves as food for fish, and make once
attractive waters appear murky.
Coliform bacteria equivalent to those in the raw sewage from
ta.6,000 persons are discharged to the Merrimack River and its tributaries
at the present time, with 3^ per cent originating in New Hampshire and
66 per cent originating in Massachusetts. Sewage effluents receiving no
treatment account for 92 per cent of the total coliform bacteria in the
stream.
-iii-
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55
Nashua and Hudson, Nev Hampshire, contributed over 98 per cent of
the coliform bacteria at the Nev Hampshire-Massachusetts state Line dur-
ing varm lov-flov periods. However, with colder water temperatures and
increased flows in the autumn, the Nashua-Hudson portion at the state
line was reduced to 50 per cent; Manchester, Nev Hampshire, was responsi-
ble for 25 per cent of the total; and other upstream communities were
responsible for 25 per cent. Of the bacteria originating from upstream
communities and reaching Nevburyport, Massachusetts, 51-^ per cent ema-
nated from the Lawrence region, 17.1 per cent from the Haverhill region,
31.^ per cent from the Amesbury area, and 0.1 per cent from the remaining
upstream communities.
Coliform densities as high as 9,200,000 per 100 milliliters (ml)
were found in the Merrimack River. This value, found below Lawrence, is
1,850 times the recommended im«riTmnn value of 5,000 per 100 ml. (One
hundred milliliters of water is slightly less than one-half cup.) This
excessive bacterial pollution presents a health hazard to all vho come
in contact with the water.
Disease-producing bacteria of the genus Salmonella were consistently
recovered from the Merrimack in both Nev Hampshire and Massachusetts, in-
dicating that ingestion of any water from the Merrimack River before it
is treated or of produce from truck farms using untreated river water for
irrigation is a definite health hazard. Salmonellae were isolated during
every test made at the Lowell and Lawrence, Massachusetts, water intakes.
Typhoid fever, gastroenteritis, and diarrhea are a fev of the many dis-
eases of man caused by these bacteria.
-iv-
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56
Sewage and industrial vastes presently discharged to the basin have
an estimated biochemical oxygen demand (BOD) equivalent to that in the
untreated sewage of 1,422,000 persons, of which 693,000 population equiva-
lents are discharged in Nev Hampshire. BOD is a measure of the ability
of a waste to deplete the dissolved oxygen resource of a stream.
Serious depletion of the dissolved oxygen content of the Merrimack
River occurred during the study period. For the months of June, July,
August, and September of 1964 and 1965, minimum dissolved oxygen from
Manchester to Newburyport was less than 2.0 ppm at every station; zero
values were found below Haverhill. At no point upstream of Manchester
was the minimum value in excess of 5.0 ppm. A value of 5.0 ppm for at
least 16 hours a day is one requirement of the Hew England Interstate
Water Pollution Control Commission for Class C waters, C being the class
of water considered acceptable for recreational boating, fish habitat,
and industrial water supply but not for swimming or drinking under normal
conditions. Using BOD as an Indicator, the most polluted reach of the
Merrimack River was between Lawrence and Haverhill, Massachusetts.
BOD crossing the state line from Hew Hampshire into Massachusetts
amounted to 28,800 pounds per day. This is equivalent to the BOD of raw
sewage from 169,000 persons. As a result of the reduction in dissolved
oxygen, fish, fish food organisms, and other desirable forms of aquatic
life are destroyed. In addition, when the dissolved oxygen content of
the river is sufficiently low, obnoxious gases are given off by the
stream, forcing unsightly clumps of sludge to rise to the surface.
-v-
-------
Biological stream studies shoved that, irith few exceptions, the
entire length of the Merrimack River is grossly polluted from Franklin,
New Hampshire, to its mouth at Newburyport, Massachusetts. Those desir-
able benthic organisms sensitive
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58
92 per cent come from the paper mills. It Is estimated that IT million
cubic feet of sediments have accumulated in Pepperell Pond alone.
Bacteria equivalent to those in the raw sewage of approximately
?U,oon persons are discharged to the Nashua River Basin at present.
Fitchburg and Leominster, Massachusetts, contribute 90 per cent of the
total. The coliform bacteria in the North Nashua River were as high as
680 times the recommended maximum value of 5,000 per 100 ml for this
stream. Disease-causing bacteria were isolated in both the North Nashua
and the South Branch Nashua Rivers.
Sewage and industrial wastes presently discharged to the Nashua
River Basin have an estimated biochemical oxygen demand population equiva-
lent of 178,000, of which the paper industries contribute 76 per cent of
the total. As a result of the reduction in dissolved oxygen, fish, fish
food organisms, and other desirable aquatic life are destroyed, and ob-
noxious odors are given off by the stream.
Nutrients discharged to the Nashua River Basin result in excessive
densities of algae and other aquatic plants, creating a nuisance. These
plants may die and decompose, causing unsightly conditions, obnoxious
odors, and depletion of dissolved oxygen.
Serious pollution exists in the Pemigewasset River from the conflu-
ence vith the East Branch Pemigewasset River in Lincoln, Nev Hampshire,
to the confluence of the Winnipesaukee River in Franklin, Nev Hampshire,
due to the discharge of sewage and industrial wastes in the basin.
Suspended solids discharged to the Pemigewasset River watershed are
equivalent to those in the raw sewage of 287,500 persons, of which over
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98 per cent emanate from industrial plants. These solids result in
sludge deposits, especially in the impoundment behind Ayers Island Dam.
Hydrogen sulfide, resulting from sludge deposits behind this dam, caused
thousands of dollars of damage to houses in Bristol, Nev Hampshire, on
August 18, 1965, and on August 23, 1966, by discoloring the paint on the
houses.
Sulfite waste liquor, released to the Pemigevasset River by the
Franconia Paper Corporation, not only creates an enormous oxygen demand
but also contains lignin sulfonates which persist as the waters flow into
Massachusetts. As a result of the sulfite waste liquor, the river is
discolored, adding to the water treatment costs at Lowell and Lawrence,
Massachusetts.
Restricted recreational use of the Merrimack and its tributaries due
to their polluted conditions alone caused an estimated loss of $21,300,000
in 196^. There is presently a very limited amount of fishing in the basin,
but the U. S. Pish and Wildlife Service has expressed interest in reintro-
ducing salmon and other anadromous fish to the streams once the pollution
has been abated.
In 1964 the value of the soft-shell clam harvest amounted to only
$1^,000 of a potential $1,000,000. Discharges to the Merrimack River
estuary from existing sewage treatment plants significantly contribute
to the bacterial densities near the shellfish growing areas.
An even greater loss can .be attributed to decreased property values
and the resulting decrease in the tax revenues caused by the polluted
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condition of the Merrimack River and its tributaries. In 1964 these
losses to coomunities in the basin amounted to about $1^,600,000.
It is estimated that betveen $37,000,000 and $70,000,000 is being
lost annually as a result of pollution in the Merrimack River Basin.
Although the Merrinack River is nov used for industrial process
water, cooling vater, and for hydroelectric power, sand filters and other
treatment methods are often employed at the industry's expense to pre-
condition the vater before it can be used. An increase in industrial
development could be expected once the basin communities can offer im-
proved vater quality.
The Merrimack is also used as a municipal vater supply for Lowell
and Lawrence, Massachusetts. As the population in the basin increases,
more and more communities will be turning to the Merrimack to meet their
vater needs because it is the only vater supply of sufficient quantity to
meet the demand. Eight basin communities have already expressed interest
in the use of the river. Well-designed and efficient sewage treatment
plants will be necessary to ensure adequate water quality.
Sewage and industrial wastes continue to be discharged to the
Merrimack River and its tributaries in New Hampshire, causing pollution
which endangers the health or welfare of persons in Massachusetts; the
sewage and industrial wastes discharged to the Merrimack River and its
tributaries in Massachusetts cause pollution which endangers the health
or welfare of persons in New Hampshire and Massachusetts. Therefore,
this pollution is subject to abatement under the provisions of the
Federal Water Pollution Control Act (33 U. S. C. k66 et seq.).
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INTRODUCTION
In accordance with the written request to the Secretary of Health,
Education, and Welfare from the Honorable Endicott Peabody, former
Governor of Massachusetts, dated February 12, 1963, and on the basis of
reports, surveys, or studies, the Secretary of Health, Education, and
Welfare, on September 23, 1963, called a conference under the provisions
of the Federal Water Pollution Control Act (33 U. S. C. k66 et seq.) in
the matter of pollution of the interstate waters of the Merrimack and
Nashua Rivers and their tributaries (Massachusetts-New Hampshire) and the
intrastate portions of those waters within the State of Massachusetts.
The conference was held February 11, 196\ in Faneuil Hall, Boston,
Massachusetts. Pollution sources and the effects of their discharges
on water quality were described at the conference.
In February, 196\ the U. S. Department of Health, Education, and
Welfare established the Merrimack River Project to study the Merrimack
River Basin. The basic objectives were twofold:
1. Evaluation of the adequacy of the pollution abatement
measures proposed for the Merrimack River within Massa-
chusetts .
2. Development of adequate data on the water quality of the
Merrimack River and its tributaries. Waters in both New
Hampshire and Massachusetts were to be studied.
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Headquarters for the Projeet wre established at the Lavrence Experi-
ment Station of the CoMmnraalth of Massachusetts, Lavrence, Massachusetts.
The Project becaae operational July 1, 1964.
During the first year of Oferatioa, efforts were concentrated pzlaarlly
In the Massachusetts section of the Nerrlaack River. Second year studies
were Mainly of the Hew Haapshlre sectioms involving suspected interstate
pollution and of the lashua River.
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STREAM STUDIES — PHYSICAL, CHEMICAL, AND BACTERIOLOGICAL
Study Area
The Merrimack River Basin lies in central Nev England and extends
from the White Mountains in New Hampshire southward into northeastern
Massachusetts. Through Nev Hampshire, the river flovs in a southerly
direction. Upon entering Massachusetts, the river flovs easterly for
1*5 miles, emptying into the Atlantic Ocean at Nevburyport, Massachusetts.
The lover 22 miles of the river are tidal. Lands drained by the Merri-
mack River consist of 5,010 square miles, of vhich 3,800 square miles are
in Nev Hampshire, vhile 1,210 square miles lie in Massachusetts.
The I960 population vithln the Merrimack River Basin is estimated to
be 1,072,000, of vhich 71*7,000 are in Massachusetts and 325,000 are in
Nev Hampshire. For the most part, the population centers are located
along the Merrimack River.
Precipitation is distributed fairly uniformly throughout the year,
and frequent but generally short periods of heavy precipitation are
common in the basin. The southeastern part of the vatershed, because of
its proximity to the Atlantic Ocean, does not undergo the extremes of
temperature and depth of snov found in Nev Hampshire at the higher eleva-
tions.
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Pollution Source*
The Merriaack Hirer is polluted by the discharge of rav and partially-
treated municipal and Industrial wastes for most of its length in Nev
Haapshire and Massachusetts. Every day acre than 120 Million gallons of
vaste vater flov into the Merriaack Hirer. The river is polluted bacterio-
logically, physically, and chemically. This polluted condition, which has
been recognized since the turn of the century, will become progressively
worse unless effective abatement action is taken immediately.
Coliform bacteria, equivalent to those in the rav sewage from
Itl6,000 persons, are discharged to the Merriaack River Basin. Thirty-
four per cent of the bacteria are discharged in lew Hampshire; the
remaining 66 per cent in Massachusetts. These bacteria are discharged by
the Nev Hampshire communities of Alienstown, Boscaven, Concord, Derry,
Franklin, Hooksett, Hudson, Manchester, Merriaack, Milford, Nashua,
Pembroke, Salem, and Wilton and by the Massachusetts communities of
Aaesbury, Andover, Ayer, Billerica, Clinton, Concord, Oracut, Fitchburg,
Oroveland, Haverhill, Lancaster, Lawrence, Leoainster, Lowell,
Marlborough, Maynard, Methuen, Newburyport, North Andover, Pepperell,
Salisbury, Shirley, and Vestborough.
The suspended solids in the discharges to the study area are equiva-
lent to those in the rav sewage of 1,653,000 persons. Seventy-two per
cent of those solids originate in Massachusetts. Major sources of
suspended solids in Nev Hampshire are the communities of Concord,
Franklin, Manchester, Milford, and Nashua and the industries of Brezner
Tanning Corp., Boscaven; Franconia Paper Corp., Lincoln; Granite State
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65
Packing Co., Manchester; Granite State Tanning Co., Nashua; Hillsborough.
Mills, Wilton; Merrimack Leather Co., Merrimack; and Seal Tanning Co.,
Manchester. Massachusetts sources are the communities of Amesbury,
Andover, Fitchburg, Haverhill, Lawrence, Leominster, Lowell, Methuen,
Newburyport, and North Andover and the industries of Amesbury Fibre Corp.,
Amesbury; Commodore Foods, Inc., Lowell; Continental Can Co., Haverhill;
Palulah Paper Co., Fitchburg; Foster Grant Co., Leominster; Fitchburg
Paper Co., Fitchburg; Gilet Wool Scouring Corp., Chelmsford; Groton
Leatherboard Co., Groton; H. E. Fletcher Co., Chelmsford; Hoyt & Worthen
Tanning Corp., Haverhill; Jean-Allen Products Co., Lowell; Lawrence Wool
Scouring Co., Lawrence; Lowell Rendering Co., Billerica; Mead Corp.,
Lawrence; Merrimack Paper Co., Lawrence; Oxford Paper Co., Lawrence;
Southwell Combing Co., Chelmsford; St. Regis Paper Co., Pepperell; and
Weyerhaeuser Paper Co., Fitchburg.
Sewage and industrial wastes presently discharged in the basin have
an estimated biochemical oxygen demand equivalent to that in the untreated
sewage of 1,^22,000 persons, of which 693,000 population equivalents are
discharged in N^v Hampshire. The following communities and industries
are the major contributors of this BOD to the study area: In New Hamp-
shire, the communities are Concord, Franklin, Manchester, Milfori, and
Nashua, and the industries are Foster Grant Co., Manchester; Franconia
Paper Corp., Lincoln; Granite State Tanning Co., Nashua; Hillsborough
Mills, Wilton; Merriraack Leather Co., Merrimack; MKM Knitting Mills, Inc.,
Manchester; M. Schwer Realty Co., Manchester; Seal Tanning Co., Manchester;
Stephen Spinning Co., Manchester; and Waumbec Mills, Inc., Manchester.
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66
In Massachusetts, the communities are Amesbury, Andover, Fitchburg,
Haverhill, Lawrence, Leominster, Lowell, Methuen, Newburyport, North
Andover, and Westhorough, and the Industries are Amesbury Fibre Corp.,
Amesbury; Commodore Foods, Inc., Lowell; Continental Can Co., Haverhill;
Falulah Paper Co., Fitchburg; Fitchburg Paper Co., Fitchburg; Foster
Grant Co., Leominster; Gilet Wool Scouring Corp., Chelmsford; Groton
Leatherboard Co., Groton; Hollingsworth & Vose Co., Groton; Hoyt &
Worthen Tanning Corp., Haverhill; Lawrence Wool Scouring Co., Lawrence;
Lowell Rendering Co., Billerica; Mead Corp., Lawrence; Merrimack Paper
Co., Lawrence; North Billerica Co., Billerica; Oxford Paper Co., Lawrence;
Simonds Saw and Steel Co., Fitchburg; Southwell Combing Co., Chelmsford;
St. Regis Paper Co., Pepperell; Suffolk Knitting Co., Lowell; Vertipile,
Inc., Lowell; and Weyerhaeuser Paper Co., Fitchburg.
Discharges, other than bacteria, suspended solids, or oxygen demand-
ing material, include color-producing waste discharges by the Franconia
Paper Corp., Lincoln, New Hampshire; plating wastes probably containing
copper and cyanide by the Sanders Associates, Nashua, New Hampshire;
2,380 pounds of grease per day by the Southwell Combing Co., Chelmsford,
Massachusetts; 3,120 pounds of grease per day by the Gilet Wool Scouring
Corp., Chelmsford, Massachusetts; periodic dumping of dye by the Roxbury
Carpet Co., Framingham, Massachusetts; and 860 pounds of grease per day
by the Lawrence Wool Scouring Company, Lawrence, Massachusetts.
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67
Water Uses
The Merrimack River is the municipal -water supply for Lovell and
Lawrence. Massachusetts. As the population in the basin multiplies, an
increasing number of communities vill be turning to the Merrimack River
to meet their water needs. Construction and efficient operation of
veil-designed sewage treatment plants vill ensure adequate water quality
to enable the municipalities and industries to utilize this abundant and
inexpensive source of water.
Extensive use of the Merrimack River water is presently being made
by the basin's industries. This use is limited mainly to flow-through
applications, cooling water, power generation, and waste transport, with
very little consumptive use. Sand filters and other treatment methods
are often employed by industries to precondition the water. It would not
be unreasonable to expect an increase in industrial development once the
basin communities can offer improved water quality to both management and
employees for process water and recreational use.
Merrimack River water is used for irrigation of truck crops along
most of its banks, with a concentration of farms occurring between
Manchester, New Hampshire, and Lawrence, Massachusetts. Following con-
struction of adequate waste treatment facilities, irrigation water would
have a lower bacterial density, resulting in a reduced health hazard.
Recreational use of the main stem Merrimack River is severely re-
stricted due to the river's polluted condition. Fishing is limited by
aa environment unsuitable for game fish common to the area and by public
abhorrence to fishing in water polluted with raw sewage and other waste
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68
materials. Proper control of this pollution vould enable 10.5 million
people within a day's drive of the river and thousands in the rest of the
country to fully utilize the tremendous fish, wildlife, and recreational
potential of the Merrimack River Basin.
For the basin area, a minimum estimate of the potential resources
lost due to pollution is $37,000,000 for the year 196^. The income lost
from various sources is:
Commercial Shellfish $ 300,000
Recreational Visitor Income 21,300,000
Increased Property Value 9,100,000
Increased Tax Revenue 5,500,000
Miscellaneous 800,000
$37,000,000
This annual loss may be as high as 60 to 70 million dollars or $65 per
year for every man, woman, and child in the basin.
Effects of Pollution on Water Quality
Concentrated water quality studies in the Merrimack River Basin were
conducted during July and August of 196^4- and 1965. Other supplemental
studies were made throughout the year. Pollution of the Merrimack River
and its tributaries was evaluated primarily on the basis of coliform
bacteria, dissolved oxygen, biochemical oxygen demand, and temperature.
Time of travel data were obtained from Rhodamine B dye studies.
The temperature of the Merrimack River during the summer months
averaged 73.^°P (23°c). There was only one significant source of thermal
pollution, that being the Public Service Company of New Hampshire's power
generating facilities at Bow, New Hampshire. A temperature increase of
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69
(3°C) was apparent below the discharge area. Facilities should be
provided for cooling of the waste discharge, thereby preventing an exces-
sive temperature build-up in the river.
Biochemical oxygen demand (BOD) crossing the state line from New
Hampshire into Massachusetts amounted to 28,800 pounds per day during
August, 1965. This is equivalent to the discharge of raw sewage from a
city of 169,000 persons.
Substantial amounts of BOD are discharged by the industries and
communities of Concord, Manchester, and Nashua, New Hampshire, and Lowell,
Lawrence, and Haverhill, Massachusetts, causing serious reduction in the
dissolved oxygen content of the Merrimack River during the summer months.
In June, July, August, and September of 196^- and 1965, minimum dissolved
oxygen from Manchester to Newburyport was less than 2.0 ppm at every
station; zero values were found below Haverhill. At no point upstream
of Manchester was the minimum value in excess of 5»0 ppm. A value of
5.0 ppm is considered by most state water pollution control agencies to
be the minimum value to be maintained in order to provide for the maximum
potential warm-water sport fish population. It is also one of the re-
quirements* for Class C water, as established by the New England Inter-
state Water Pollution Control Commission.
A depletion of the oxygen resource of a river will reduce or elimi-
nate aquatic life which serves as food for fishes. The biological study
of the Merrimack River shows that those benthic organisms sensitive in
their response to pollution were absent in the lower 57 miles of the
Merrimack River. In only four extremely short portions of the river,
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70
consisting of less than 15 miles out of the total river mileage of Il6,
did the river recover enough from its despoiled condition to permit a
small number of sensitive organisms to exist.
With the exception of a short section of the river between Hooksett
and Manchester, bacterial pollution presents a health hazard for all full
body contact recreation, such as swimming and water skiing, from Franklin,
New Hampshire, to Newburyport, Massachusetts. Below Manchester and Nashua,
New Hampshire, and Lowell, Lawrence, and Haverhill, Massachusetts, coli-
form densities in excess of 1,000,000 per 100 ml were not uncommon, being
found as high as 9,200,000 per 100 ml. Recommended limits of coliform
densities for water contact sports range from 50 to 3,000 per 100 ml in
various states.
Nashua and Hudson, New Hampshire, contributed over 98 per cent of
the coliform bacteria crossing the New Hampshire-Massachusetts state line
during warm, low-flow periods of the year. However, with colder water
temperatures and increased flows in the autumn, the Nashua-Hudson portion
at the state line was reduced to 50 per cent; Manchester, New Hampshire,
was responsible for 25 per cent of the total; and other upstream communi-
•
ties were responsible for 25 per cent. The discharge of raw and partially
treated sewage to the study area is a health hazard to the residents in the
downstream communities as well as to the local population.
Vegetables that are ordinarily eaten without cooking are irrigated at
several truck farms with water from the Merrimack River. Fecal coliforms
were present on vegetables grown from farms irrigating with Merrimack River
water in a significantly greater number of cases than on vegetables that
were not irrigated with the river water.
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While coliform bacteria densities indicate the magnitude of poten-
tial disease-producing organisms, detection of pathogenic Salmonella bac-
teria is positive proof of the presence of such organisms. Typhoid fever,
gastroenteritis, and diarrhea are but a few of the many diseases of man
caused by these bacteria. Salmonellae were consistently recovered from
the Merrimack River in both New Hampshire and Massachusetts, indicating
that ingestion of untreated Merrimack River water is a definite health
hazard. Salmonella organisms were isolated during each test made at the
Lowell and Lawrence water intakes. These disease-producing organisms
vere isolated from river water having a total coliform density as low as
180 per 100 ml.
The major contributors of coliform bacteria to the estuary are: the
communities upstream of Newburyport and the two communities of Newburyport
and Salisbury. Of the bacteria originating from upstream communities and
reaching Newburyport, 51.k per cent emanated from the Lawrence region,
17.1 per cent from the Haverhill region, and 31.4 per cent from the Amesbury
area. Discharges into the estuary from existing treatment facilities in
Newburyport and Salisbury significantly increase the bacterial densities
near the sHellfish growing areas. If the potential one-million-dollar
annual shellfish harvest is to be a reality, the discharge of treated
sewage in the greater Lawrence, Haverhill, and Amesbury areas will need
constantly and efficiently operating disinfection facilities. In addition,
the communities of Newburyport and Salisbury will need to discharge their
Bastes, adequately treated, to the Atlantic Ocean instead of to the estuary.
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Phosphate and nitrogen concentrations in the Merrimack River are far
in excess of the amount needed to produce nuisance algal blooms. In order
to reduce taste and odor problems with municipal vater supplies taken from
the river and to improve the esthetic quality of the vater, the concentra-
tion of these nutrients should be reduced.
Severe to moderate pollution exists in several tributaries of the
Merrimack River. These include the Souhegan River near Wilton and Milford,
New Hampshire; Beaver Brook near Deny, New Hampshire, and Lowell, Massa-
chusetts; the Assabet River below Westborough, Hudson, and Maynard, Massa-
chusetts; Hop Brook (a Sudbury River tributary) below Marlborough,
Massachusetts; the Concord River below Billerica and in Lowell, Massa-
chusetts; the Spicket River in Salem, New Hampshire, and Methuen and
Lawrence, Massachusetts; the Shawsheen River below Bedford and in Andover,
Massachusetts; and the Powwow River below Amesbury, Massachusetts.
Gross oxygen production from photosynthesis in the Merrimack River
was between 0.8 and 2.0 ppm per day during the summers of 1964 and 1965.
These values were obtained by the use of light and dark bottle tests
between Manchester, New Hampshire, and Newburyport, Massachusetts. The
rate of oxygen production on cloudy days was found to be approximately
one-tenth the value found on sunny days.
In the 67-mile reach of the Merrimack River between Manchester and
Newburyport, there are approximately 16,900,000 cubic feet of settled
solid material, 7,900,000 of which are located between Lowell and
Lawrence, and 7,800,000 between Haverhill and Newburyport. The oxygen
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73
demand of these benthal deposits in the overflowing waters ranged from
0.2 to 1.0 ppm per day.
Oxygen balance studies were carried out, and the variables affecting
the oxygen sag curves were obtained for each of the six reaches below
Manchester, New Hampshire. These variables were adjusted to reflect the
future conditions in 1985 when a secondary waste treatment program for the
Merrimack River would be in effect. Dissolved oxygen calculations for the
1985 conditions indicated that oxygen levels of 75 per cent of saturation
(Class B water as established by the New England Interstate Water Pollu-
tion Control Commission) can be met from Franklin, New Hampshire, to
Lawrence, Massachusetts, and from Amesbury, Massachusetts, to the Atlantic
Ocean.
Existing and potential future water uses in the Merrimack River indi-
cate that it will be used for a variety of purposes. Consideration was
given to water quality limits for various constituents that would affect
the suitability of the stream for each water use. In order to decrease
the biochemical oxygen demand and bacteria in the wastes to be discharged
to the Merrimack River, to provide an effluent more esthetically accept-
able to the public, to assure the existing and future desirable uses of
the river, and to protect the health and welfare of the public, it will be
necessary to provide secondary waste treatment or equivalent, with disin-
fection, for all waste discharges. If the recommendations of this report
are followed, water quality of sufficient purity to accommodate the
*
various water uses will be attained.
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74
STREAM STUDIES — BIOLOGICAL
The biological studies show that, with few exceptions, the Merrimack
River is grossly polluted from Franklin, New Hampshire, to its mouth at
Newburyport, Massachusetts.
Benthic organisms sensitive to pollution were absent from the samples
taken in the lower 57 miles of the Merrimack River. In only four extremely
short portions of the river, consisting of less than 15 miles out of the
total river mileage of 116, did the river recover enough from its despoiled
condition to permit a small number of sensitive organisms to exist before
additional wastes reduced the quality of the river. These four areas were:
four miles below the confluence of the Pemigewasset and Winnipesaukee
Rivers; above Concord, New Hampshire; in the reservoir behind Amoskeag Dam;
and just above the Nashua River confluence.
Organisms intermediate in their response to pollution were predominant
from below Franklin, New Hampshire, to the confluence of the Contoocook
River. Additional waste discharges between the Contoocook River and the
Suncook River resulted in an increase in the proportion of pollution-
tolerant forms. Between Hooksett and Manchester, New Hampshire, the
majority of bottom organisms again were of the types intermediate in their
resistance to pollution. From Manchester to Amesbury, Massachusetts, a
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75
distance of 66 miles, pollution-tolerant organisms constituted the entire
benthic population or the majority of the forms found.
The number of species found in the Merrimack River vas far below the
levels desired in a benthic community. Pollution-sensitive benthic fauna,
such as mayflies, stoneflies, and certain beetles, vere not found in the
river from Manchester, Nev Hampshire, to the Atlantic Ocean.
A number of tributaries vere sampled near their confluences with the
Merrimack River. Results show that all of the sampled areas were polluted.
In most cases, wastes were discharged into the lower part of the tributary
and affected the bottom fauna.
A biological survey was carried out on the lower Souhegan River, a
tributary which discharges into the Merrimack River 12.5 miles upstream
of the New Hampshire-Massachusetts state line. Between Wilton and Milford,
New Hampshire, the Souhegan deteriorated considerably, with pollution-
tolerant leeches and sludgeworms making up most of the benthic fauna.
This polluted condition of the river continued for several miles down-
stream of Milford. From a biological standpoint, the river was moderately
polluted from Wilton, New Hampshire, to its confluence with the Merrimack
River, a distance of 20 miles.
A productivity study of the Merrimack River was conducted between
Manchester, New Hampshire, and Lowell, Massachusetts, that reflected a
relative increase in productivity as the river flowed downstream.
The surface water of the Merrimack River at the entrance to the
Essex Canal in Lawrence was monitored periodically for phytoplankton and
2ooplankton from April through October, 1965. Most of the kinds of
Phytoplankton found were tolerant of pollution.
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PILOT PLANT STUDY OF BENTHAL OXYGEN DEMAND
The areal oxygen demand of bottom sediments taken from the Merrimack
River in Massachusetts was determined by a small pilot plant. Parameters
in the benthic rate equation vere evaluated on the basis of the data ob-
tained, and the effect of sediment depth on the benthic rate constant, k^,
was studied.
The value of the benthic rate constant, kj^, varies with the age and
depth of the deposit. A marked decrease of k^ with increase in sediment
depth occurred between 1.5 and 10 cm. Above 15 cm no significant decrease
in k^ was observed.
Only the upper 15 cm of sediment had any significant effect on the
areal oxygen demand. The observed data were closely approximated by the
equation L^ = !« • 10"^ at all sediment depths except the 1.5 cm depth.
Nitrification was believed to play a role in the oxygen demand of the
sediments and was especially significant in the shallow depths studied.
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NASHUA RIVER
Serious pollution exists in the North Nashua River from the outfall
of the Weyerhaeuser Paper Company, Fitchburg, Massachusetts, to the con-
fluence of the north and south branches of the Nashua River at Lancaster,
Massachusetts; in the Nashua River from Lancaster to the mouth of the
Nashua River in New Hampshire; in the Squannacook River below the dam at
Vose Village; and in the South Branch Nashua River below Clinton, Massa-
chusetts. This pollution affects present and potential water uses.
Discharges from paper mills result in suspended solids, organic
matter causing biochemical oxygen demand, and materials causing apparent
color in the stream. By far the largest loadings emanate from the three
paper industries of Fitchburg, Massachusetts. Inadequate sewage treat-
ment, particularly at Fitchburg and Leominster, Massachusetts, contributes
to the problem by causing excessive bacterial densities, suspended solids,
nutrients, and organic matter causing biochemical oxygen demand. Plastics
and metal fabrication industries also add suspended solids and materials
that cause biochemical oxygen demand.
Bacteria equivalent to those in the raw sewage of approximately
2^,000 persons are discharged to the streams at present. Fitchburg and
Leorainster, Massachusetts, contribute 90 per cent of the total. The coli-
•s
form bacteria in the North Nashua River were as high as 680 times the
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78
reconnended *»rl«ni value of 5,000 per 100 ml for this stream. Pathogenic
bacteria vere isolated in both the North Nashua and South Branch Nashua
Rivers.
Discharges of suspended solid* create a severe problem in the Nashua
River. These materials cause deep sludge deposits vhich deplete the
stream oxygen supply, produce offensive odors, and reduce or eliminate
aquatic life vhich serves as food for fishes. The suspended matter also
makes these once attractive waters appear turbid. Suspended solids dis-
charged to the Nashua River Basin are equivalent to those in the raw
sevage of 556,000 persons. Of these nearly 92 per cent come from the
paper mills. It was estimated that IT million cubic feet of sediments
have accumulated in Pepperell Pond alone.
Sewage and industrial wastes presently discharged have an estimated
biochemical oxygen demand population equivalent of 178,000, of which the
paper industries contribute 76 per cent. As a result of the reduction in
dissolved oxygen, fish, fish food organisms, and other desirable forms of
aquatic life are destroyed. In addition, when dissolved oxygen is re-
duced to zero, obnoxious odors are given off by the stream.
Nutrients discharged to the Nashua River Basin result in excessive
densities of algae and other aquatic plants, creating a nuisance. These'
plants may die and decompose, causing unsightly conditions, obnoxious
odors, and depletion of dissolved oxygen. In addition, in the absence of
sunlight, the algal respiration depresses the dissolved oxygen to low
levels—at times to zero. Estimates based on severed population and
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stream analyses indicate that 128,000 population equivalents of ortho-
phosphates are discharged to the Nashua River. Phosphates are key
nutrients which are readily available for the growth of algae and other
aquatic plants.
As a result of the severely polluted condition of the Nashua River,
the people vho live in the towns bordering the river in Nev Hampshire and
Massachusetts petitioned the governors of the two states to take immediate
abatement action. The people demanded that the river be restored to a
high state of water quality.
The Nashua River system has been classified for future highest use
by the state and interstate agencies. The classification of the North
Nashua and Nashua Rivers was set at Class C. However, in Massachusetts
the Nashua River was assigned the coliform limitation established for
Class B water. Class C waters would be suitable for recreational boating
and fish and wildlife usage, while the coliform limit on the Nashua River
would permit recreational bathing. These classifications would permit
the recreational developments desired by most of the citizens of the area
and would probably provide water quality adequate for industry.
In addition to many other uses, the Nashua River can be used at the
Port Devens Military Reservation for training exercises involving rivers
and for recreation when pollution is controlled. The sections of the
river forming the post boundary could be used for public recreation,
^hile the sections entirely within the reservation could be used for
^creation either by post personnel or by the public by permit.
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80
PEMIGEWASSET RIVKK
Serious pollution exists in the Pemigewasset RLver from the conflu-
ence with the East Branch Pemigewasset River In Lincoln, New Hampshire,
to the confluence of the Wlnnipesaulcee RLver in Franklin, Nev Hampshire,
due to the discharge of sewage and industrial wastes in the basin. Effects
of these discharges persist all the vay into Massachusetts.
Discharges of raw sewage from several towns result in excessive den-
sities of bacteria and make much of the Pemigewasset River unsuitable for
recreational purposes, even where only limited body contact is involved.
About 29 of the 35 miles of stream between North Woodstock and New Hampton
are above the 5,000 conforms per 100 ml limit usually recommended for rec-
reational uses. Some of these bacteria may be pathogens which can infect
persons Ingesting the water.
Suspended solids discharged to the Pemigewasset River watershed are
equivalent to those in the raw sewage of 287,500 persons, of which over
98 per cent emanate from industrial plants. These solids result in sludge
deposits, especially in the impoundment behind Ayers Island Dam. The
sludge reduces or eliminates aquatic life which serves as food for fishes,
depletes the stream oxygen supply, and produces offensive odors. Hydro-
gen sulfide, resulting from sludge deposits behind Ayers Island Dam,
caused thousands of dollars of damage to houses in Bristol, New Hampshire,
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81
on August 18, 1965, and on August 23, 1966, by discoloring the paint on
the houses.
Dissolved oxygen concentrations in the Pemigevasset River are de-
pressed by the discharge of organic materials vhich decompose in the
river and exert an oxygen demand. Minimum dissolved oxygen concentra-
tions vere belov desirable levels from the East Branch Pemigevasset River
in Lincoln, Nev Hampshire, to the mouth of the Pemigevasset in Franklin.
The Franconia Paper Corporation is responsible for 9^-5 per cent of the
oxygen demand in the Pemigevasset River Basin, vith a discharge having an
oxygen demand equivalent to that of the raw sewage of ^00,000 persons.
Low dissolved oxygen concentrations destroy fish, fish food organisms,
and other desirable aquatic life.
Sulfite vaste liquor, released to the Pemigevasset River by the
Franconia Paper Corporation, not only creates an enormous oxygen demand
due primarily to the wood sugars but also contains lignin sulfonates
which persist as the waters flow into Massachusetts. Pollution from the
Franconia Paper Corporation was included in the first session of the
conference. As a result of the sulfite vaste liquor, the river is dis-
colored, adding to the water treatment costs at Lowell and Lawrence,
Massachusetts.
The Pemigevasset River is in the heart of prime recreational area of
New Hampshire. Hovever, as a result of pollution, recreational use of the
Pemigewasset is reduced or destroyed, impeding the economic growth of the
area downstream of the pollutional discharges.
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RECOMMENDATIONS
Many suggestions of the Merrimack River Project concerning water
quality criteria and stream classification have already been implemented
by the tvo Basin states in the process of adopting water quality standards.
Still others are being considered by the New England Interstate Water
Pollution Control Commission for the region as a whole as well as the
Basin waters.
Implementation and construction schedules submitted by the states of
New Hampshire and Massachusetts and approved by the Secretary of the
Interior, as required by the Federal Water Pollution Control Act, as
amended, shall be followed for the Merrimack River Basin. Implementation
and construction schedules for sources of pollution on intrastate portions
of the Merrimack River Basin in Massachusetts shall be in accordance with
state and local requirements so as to meet the stream classifications.
It is recommended that the implementation program for the following
New Hampshire communities in the Merrimack River Basin, that did not
receive approval by the Secretary, be as follows:
Manchester Concord Plymouth
Type of treatment Secondary Secondary Secondary
Final plans and specifications Dec. 1970 May 1969 July 1971
Start construction Apr. 1972 Apr. 1971 July 1973
Complete construction Dec. 197^ Apr. 1973 Dec. 1974
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83
Consideration shall be given in the water pollution control pr
as necessary, to the following:
1. Sewcrace systems with collection sewers terminating in
adequate treatment facilities shall be provided in those
areas alonp; the stream where sewers do not now exist and
where homes discharge either raw wastes or septic tank
effluent to the watercourse and where local treatment
facilities will not suffice.
2. All new construction of sewer lines and revisions to
existing systems shall provide for the separation of
storm runoff and sewage.
3- All new and existing waste treatment facilities shall be
designed or modified, if possible, to prevent bypassing
of untreated wastes during maintenance and renovation
operations and power failures.
-4-. All municipal and industrial wastes in the Merrimack
River Basin are to receive a minimum of secondary
treatment or equivalent. All effluents containing
domestic wastes are to receive adequate disinfection.
Maximum removal of nutrients, including phosphates, by
the most effective available means is to be provided,
as necessary, to meet stream classifications.
5- All industries and municipalities in the area discharging
waste material to the public waters shall maintain an
inventory of critical waste treatment parts and supplies
on the plant premises so that a minimum delay in effective
waste treatment will result when replacement or repair is
necessary.
6. Consideration shall be given for 2^-hour supervised opera-
tion of all sewage treatment plants.
Provisions shall be made to allow sampling of the final
effluent prior to discharge.
8. No backwater or eddies shall exist near the outfall that
would hinder mixing. The location of the outfall should
be such as to enhance mixing of the treatment plant
effluent.
* -v
). Operation of dams in the Merrimack River Basin should be
regulated by the appropriate agency so that certain ade-
quate flows are released at all times.
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84
10. All water treatment plants shall dispose of spent acti-
vated carbon and settled solids by means other than to
the stream.
11. Facilities to accept septic tank truck discharges are
to be provided at sewage treatment plants or other
approved areas.
12. There shall be no discharges from septic tank cleaning
operations directly to the waters of the Basin.
13« All marine conveyances equipped with marine toilets
operating upon the Basin waters shall use a holding
tank or other approved pollution control device.
Ik. The appropriate agency should prohibit garbage or refuse
(including automobile bodies and other unsightly debris)
from being dumped along the banks of the river, and no
open dumps should be allowed on the flood plain. Mate-
rial in present dump sites along the river banks shall
be removed and the appearance of the bank restored to
an esthetically acceptable condition. Present open
dumps on the flood plain should be converted to sanitary
landfills operated acceptably to the appropriate state
agencies.
15. In the shellfish growing areas near the mouth of the
Merrimack River, the requirements of the National
Shellfish Sanitation Program are to be met in order
to permit reopening of the maximum number of those
areas presently closed to the harvesting of shellfish.
16. Consideration should be given by the City of Newburyport
and the Town of Salisbury, Massachusetts, to developing
an engineering report which would include the relative
merits of:
a. Treatment and joint discharge to the Atlantic Ocean;
b. Individual discharges to the Atlantic Ocean;
c. Joint treatment and discharge to the Merrimack
estuary; and
d. Individual discharges to the Merrimack estuary.
In all cases, the report shall include the relative
economic values of the estuarine resources.
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85
MERRIMACK RIVER BASIN
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86
Herbert Pharen
CHAIRMAN STEIN: Thank you, Mr. Pahren.
Are there any comments or questions:
MR. McMAHON: Yes.
CHAIRMAN STEIN: Mr. McMahon has one.
MR. McMAHON: Mr. Chairman, first I would like to
commend Mr. Pahren and'Mr. Klashman and Mr. Stein on the
preparation of what I call a substantial effort over the
past two years, and I am not just referring to volume 1, but
also the backup volumes which will be used for technical
information by other agencies.
I would say that we also have one comment in the
recommendations. Essentially, all of the recommendations
that are in volume 1 of this report, we feel, are inherent
within our particular water pollution control program in
Massachusetts or as vested in the appropriate agencies in
order to satisfy all of these recommendations.
My one exception would be No. 13, which states that
all marine conveyances equipped with marine toilets
operating upon the basin waters shall use a holding tank or
other approved pollution control device.
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Herbert Pahren
At the present time we in Massachusetts do not
have a Massachusetts approved pollution control law. V\e
are interested in getting one, however. We have been
working with the New England Interstate Water Pollution
Control Commission and other States to come up with
legislation that is compatible or equal to one State to
another.
I am not saying this is not a o;ood idea. It is
an excellent idea. I am merely saying that at the present ,
time Massachusetts does net have a boat pollution control
law. I would exp---:c<: that within a year or two or 18 months
we will have.
CHAIRMAN STEIN: Mr. Pahren, do you have a comment
on that or do you want to respond to it?
MR. PAHREN: No. I think that Mr, McMahon's comment
that they do expect to have it in the law in 12 to 18 months
is adequate.
CHAIRMAN STEIN: You might check on some of the
experience we have had with the States in other areas.
-------
Herbert Fahren
For example, Lake Michigan, all four bordering States have
adopted, at least in substance, uniform requirements. I
think we have about achieved that with the five Lake Erie
States.
New, this is possibly for Mr. Peloquin or anyone
else in the interstate agencies; You try in this area almost
more than anyone else to get reasonable uniformity on
requirements. For example, in the upper Mississippi River
between Minnesota and Wisconsin we did not quite have that.
What happened was boat owners did what came naturally. As
you know, thev do not like to stay in one place; they like
to travel. When a man in one State would have what he thought
was an adequatelv equipped boat and he would go across a State
line, he suddenly found himself ticketed and had to pay a
$25 or $50 fine. This did not rest too well with either
State and certainly not the public.
I really believe the basic issue you must determine
is whether you are going to go for holding tanks, as at the
present time, or you are going to permit a macerator-
chlorinator, as well, or in addition. In the Great Lak«:s
States they pump from the holding tank, nothing else. In
the upper Mississippi between Minnesota and Wisconsin it is
split and this is what causes the problem.
I would suggest that the mechanics of the legislation
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39
Herbert Pahren
have been developed in other areas, and I suggest that you
look at these. This is a fairly direct legislative and
regulatory procedure that has been worked out. All of these
States have developed a pretty good law. However, I would
hope, again, that the States can get together on this issue
and come up with a uniform provision so that the sportsmen
in the area can reasonably feel that if their boats meet the
requirement in one State, they could take them to the waters
of another State in the New England area and expect to have
full acceptance of the device.
MR. PELOQUIN. I wonder if I could comment on this,
Mr. Klashman?
MR. KLASHMAN. Yes.
MR. PELOQUIN. For the record, the New England Inter-
state Water Pollution Control Commision particularly has had
this problem under study for the past year, and we also have
had participating on this committee a member of the Federal
Water Pollution Control Administration and the United States
Public Health Service. V.'e have discussed the recommendation of
this committee to the Technical Advisory Board for holding
tanks preferable and for the development of standard legisla-
tion, which would be applicable as a minimum to the six New
England States,and, hopefully, considering either further range,
preferably Ithe East Coast because of the traffic alonf the
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Herbert Pahren
Coast, and to support Federal legislation and control of
military and commercial vessels plying along the Coast.
At the present time we are beginning to develop
standard legislation which we hope will be adopted by the
Compact member States. This is under consideration.
MR. KLASHMAN. Mr. Stein, before Mr. Healy can say
it, we want to say that we in the Region recognize that
New Hampshire has actually been one of the forerunners in
this handling of marine waste. Actually, New Hampshire has
had the holding-tank law in effect for some time now. I
think that some of the other States have copied from it
out in the Midwest.
CHAIRMAN STEIN. Did you want to comment?
MR. HEALY. Yes, I would very briefly, because you
have a long agenda and we want to get along.
I think New Hampshire ascribes generally to the
comments' Mr. Pahren has made in regard to the recommendations
outlined in the summary report.
We do have some strong reservations about the dates
concerning Manchester, Concord and Plymouth. This stems
largely because of the status of the grant funds.
Our program of control ,of necessity, has been based
upon the amounts of Federal and State funds which we can
anticipate over the next ten years. We have a 10-year program
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91
Herbert Pahren
here, or we did have when we submitted it in the form of
our water quality standards in compliance with the 1965 Act.
Now, the funds have not been forthcoming, as
Representative Urie emphasized. We here will have to make
some adjustments in our schedules. Either that, or there
will have to be a very serious effort made to establish a
prefinancing system here at State level, which would enable
us to more nearly adhere to the original dates established
by the Commission and by the Legislature in submitting our
standards.
Now, if I could just add this thought on the boat
pollution control aspect of our operation: We feel here,
and have, as Mr. Klashman has indicated, that there must be
a real strong effort in this area, and we have attempted to
have one for the last several years by means of macerator-
chlorinator devices. In our judgment, this has left results
or brought about results which left something to be desired
and we have now converted to the holding system method which
we believe will be superior. In fact, a number of these
units are now in use in the State.
Beginning January 19691 it will be manditory that
*11 boat operators, pleasure craft included, plying New
Hampshire waters will have to have a holding tank so as to
\
receive and store the waste for on-shore disposal at convenient
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92
Herbert Pahren
points around our lakes.
We applaud and endorse the effort at the New England
Interstate level, because this will facilitate the control
measures in this State.
Thank you.
CHAIRMAN STEIN. Thank you. I think, Mr. Healy, that
is the trend.
Without wishing to prolong it and get into the
technical part of this problem, I shall draw out one point
for the consideration of the New England States on the boat
ordinances. These boats can be put on trailers. We know
they are used on lakes as well as rivers. Many of the States
have come up with Mr. Healy1s judgment on this — they have
had the same experience -- that the macerator-chlorinator
has not quite proved satisfactory on lakes because whatever
it does it does not remove the nutrients. You tend to get
a rapid nutrification of those lakes. So this is something
to keep in mind.
Are there any other questions or comments?
(No response.)
CHAIRMAN STEIN. If not, thank you very much.
Mr. Klashraan.
MR. KLASHMAN. We may want to have Mr. Pahren recalled
and ask him another question later, but we have none at this time.
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0
Thomas Schrader
CHAIRMAN STEIN. Proceed.
MR. KLA3HMAN. I would like to now call on Mr. Thomas
A. Schrader, Assistant Regional Director, Bureau of Sport
Fisheries and Wildlife.
Mr. Schrader, do you have a statement?
MR. SCHRADER. Yes.
MR. KLASHMAN. If there are any other Federal agencies
in the room that would like to make a statement I would very
much appreciate it if they would make themselves known to
me and let me know now.
STATEMENT OF THOMAS A. SCHRADER
ASSISTANT REGIONAL DIRECTOR
U. 3. DEPARTMENT OF THE INTERIOR
BUREAU OF SPORT FISHERIES AND WILDLIFE
BOSTON, MASSACHUSETTS
(Representing Regional Director Richard E. Griffith)
MR. SCHRADER. Mr- Klashman, with your permission,
I would like to leave the statement that I turned over to
someone earlier to be entered into the record as written,
but I am going to modify the statement that I read just
slightly to take care of the situation that I find myself
iri, in that pur Regional Director Mr. Griffith could not
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91
Thomas Schrader
attend. Our Regional Director had intended to be here and
present this statement in person until about 4 o'clock yesterday
afternoon. So I am going to modify it just slightly to take
care of the fact that I am reading the statement and the
oral presentation. But I would like the record to show it
as though Mr- Griffith read the statement.
My name is Thomas A. Schrader. I am Assistant
Regional Director of the Northeast Region of the Bureau of
Sport Fisheries and Wildlife, which, with the Bureau of
Commercial Fisheries, makes up the United States Fish and
Wildlife Service. By agreement with Regional Director John
T. Gharrett, Bureau of Commercial Fisheries, the statement
I am presenting represents our combined views.
We are pleased to have the opportunity to speak at
this conference. Mr. Griffith's predecessor, and now
Director of the Bureau of Sport Fisheries and Wildlife,
John S. Gottschalk, said at the first Merrimack River
conference in Boston in 1964, ''Throughout the Nation, people
are saying, '...let's do something about pollution!" I am
pleased to report that we are making progress. One of the
things we have learned, however, is that progress in pollution
elimination is slow, due to the enormity of the problem and
the tremendous expenses involved. We cannot resolve all
the problems overnight.
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Thomas Schrader
As our increasing human populations achieve more
leisure time their demands for worthwhile activities, such
as fishing and boating, increases. By the year 2000, we
expect approximately 3,000,000 of the projected New England
population of 17,000,000 people will fish. We will be hard
pressed to provide fishing opportunity for these people.
Cleanup of the polluted areas would provide many thousands
of man-days use for fishing. It would also help to more
evenly distribute fishing pressure on the available waters.
If we are successful in solving the myriad problems facing
fisheries management and can provide outstanding angling
opportunities, we hope that a much higher percentage of our
population will be encouraged to take advantage of fishing
opportunities.
The potential of the Merrimack River for satisfying
these demands is enormous. The ORRRC report ''Sports Fishing
Today and Tomorrow'' estimates that the main stem alone could
support at least 290,000 man-days of fishing each year. In
addition, the river could support at least 290,000 man-days
of fishing each year. In addition, the river could support
several thousand man-days of hunting each year. The potential
is magnified by the proximity of the river to urban areas.
There are few, other opportunities available to create new
and hunting areas where they are most needed.
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96
Thomas Schrader
The Bureau of Sport Fisheries and Wildlife and the
Bureau of Commerical Fisheries are vitally concerned with the
various aspects of fish and wildlife conservation and develop-
ment within the Merrimack Basin.
Our concern reflects both the specific and general
interest of the Congress in the conservation of the Nation's
fish and wildlife resources. The general policy of the
Federal Government is expressed in these words quoted from
the Fish and \\ildlife Act of 1956, "The Congress hereby
declares that the fish, shellfish and wildlife resources of
the Nation make a material contribution to our Nation's
economy and food supnly, as well as a material contribution
tc the health, recreation, and well-being of our citizens;
that such resources are a living renewable form of national
wealth that is capable of being maintained and greatly
increased with proper management; but equally capable of
destruction if neglected or unwisely exploited; that such
resources afford outdoor recreation throughout the Nation
and provide employment, directly or indirectly, to a substan-
tial number of citizens.''
The restoration of anadromous fish and the full
utilization of resident fish are needed to meet future
demands. Adequate control of pollution is essential if we are
to accomplish maximum fisheries utilization.
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Thomas Schrader
In common with other afencios of the Department of
the Interior, we are convinced that use of streams for
waste disposal is a single-purpose use we can no longer
afford. >/e welcome an opportunity to cooperate with any
effort aimed at the restoration of New England rivers.
(prepared text of above-mentioned statement follows.)
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98
U. S. Fish and Wildlife Service
Interest in the Waters of the
Merrimack River
Presented at the Second Conference
December 18, 1968
at
Concord, New Hampshire
My name is Richard E. Griffith. I am Director of the Northeast
Regidn of the Bureau of Sport Fisheries and Wildlife, which, with
the Bureau of Commercial Fisheries, makes up the U. S. Fish and
Wildlife Service. By agreement with Regional Director John T.
Gharrett, Bureau of Commercial Fisheries, the statement I am
presenting represents our combined views.
We are pleased to have the opportunity to speak at this conference.
My predecessor, and now Director of the Bureau of Sport Fisheries and
Wildlife, John S. Gottschalk, said at the first Merrimack River con-
ference in Boston in 1964, "Throughout the Nation, people are saying,
'... let's do something about pollution^'" I am pleased to report
that we are making progress. One of the things we have learned,
however, is that progress in pollution elimination is slow, due to the
enormity of the problem and the tremendous expenses involved. We cannot
resolve all the problems overnight.
As our increasing human populations achieve more leisure time their
demands for worthwhile activities, such as fishing and boating, in-
creases. By the year 2000, we expect approximately 3,000,000 of the
projected New England population of 17,000,000 people will fish. We
will be hard pressed to provide fishing opportunity for these people.
Cleanup of the polluted areas would provide many thousands of man-days
use for fishing. It would also help to more evenly distribute fishing
pressure on the available waters. If we are successful in solving the
myriad problems facing fisheries management, and can provide outstanding
angling opportunities, we hope that a much higher percentage of our pop-
ulation will be encouraged to take advantage of fishing opportunities.
The potential of the Merrimack River for satisfying these demands is
enormous. The ORRRC report "Sports Fishing Today and Tomorrow" es-
timates that the main stem alone could support at least 290,000
man-days of fishing each year. In addition, the river could support
several thousand man-days of hunting each year. The potential is
magnified by the proximity of the river to urban areas. There are
few other opportunities available to create new fishing and hunting
areas where they are most needed.
The Bureau of Sport Fisheries and Wildlife and the Bureau of Commercial
Fisheries are vitally concerned with the various aspects of fish and
wildlife conservation and development within the Merrimack Basin.
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99
Our concern reflects both the specific and general interest of the
Congress in the conservation of the Nation's fish and wild"Hf^
resources. The general policy of the Federal Government is expressed
in these words quoted from the Fish and Wildlife Act of 1956, "The
Congress hereby declares that the fish, shellfish, and wildlife
resources of the Nation make a material contribution to our Nation's
economy and food supply, as well as a material contribution to the
health, recreation, and well-being of our citizens; that such resources
are a living renewable form of national wealth that is capable of being
maintained and greatly increased with proper management; but equally
capable of destruction if neglected or unwisely exploited; that such
resources afford outdoor recreation throughout the Nation and provide
employment, directly or indirectly, to a substantial number of citizens."
The restoration of anadromous fish and the full utilization of resident
fish are needed to meet future demands. Adequate control of pollution
is essential if we are to accomplish maximum fisheries utilization.
In common with other agencies of the Department of the Interior, we are
convinced that use of streams for waste disposal is a single-purpose
use we can no longer afford. We welcome an opportunity to cooperate vrith
any effort aimed at the restoration of New England rivers.
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100
Thomas Schrader
CHAIRMAN STEIN. Thank you, Mr. Schrader.
Are there any comments or questions?
MR. KLASHMAN. Mr. Schrader, Mr. Pahren in his
statement made reference to the fact that the Fish and
Wildlife had expressed an interest in reintroducing salmon
and other anadromous fish in the Merrimack and some of the
other streams up here. I understand that you have done
this or are doing some work on the Connecticut and Penobscot,
I believe. Do you have any specific plans on the thoughts
about this on the Merrimack?
MR. SCHRADER. I can add to this statement I
delivered.
I would like to point out that I guess I am nearing
the end of a rather long career in the field of conservation.
I have been involved in fish and wildlife conservation for
some 35 years, and one of the most exciting pieces of
legislation, from my point of view, in this 35 years has
been the Anadromous Fish Restoration Act which was enacted
by the Congress three years ago. And this provided for a
Federal cost-sharing program to assist the States in anadromous
fish restoration projects and authorized the appropriation of
money to carry out this program.
1 I can remember back in the middle 1930fs attending
conferences of conservationists where pollution was the
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101
Thomas Schrader
subject of considerable discussion and the people generally
were convinced that pollution abatement was absolutely essen-
tial to full utilization of our potential fish resources.
The Federal Water Act, the Pollution Control Act, has, I
think, opened up a tremendous opportunity to the restoration
of fish in the waters of America; and in connection with the
anadromous fish, which are important both to the commercial
fishery and to the sport fishery, we have a mechanism now
to go to work on the streams as a successful pollution
abatement program is carried out.
There is no question that there is going to be needed
other things done besides the pollution in order to restore
the anadromous fish runs. The program has been under way
for about three years now. We have had appropriations for
three years; and, of course, the money that was appropriated
each year by the Congress was put into use in those streams
or areas where we had an immediate potential, and the Penobscot
got, I would say, the lion's share of the money that was
allocated throughout the Northeast.
Now, the Bureau has also made somewhat larger amounts
°f money available for anadroraous fish restoration on the
Connecticut River, and I would suspect, or I believe, that
°ne of the reasons for the larger allocation for the
Connecticut was due to the fact that the four States involved,
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102
Thomas Schrader
plus our two Bureaus in the Fish and Wildlife Service,
had gotten together and agreed on a program for the
Connecticut River.
Now, we have made some money available to carry
out restoration work on the Merrimack River, but I suspect
that the amounts that could be made available on the
Merrimack could be increased rather substantially if we
had some sort of a joint plan for restoration that we
could get ahead with.
I view the Merrimack as a river which historically
had access at one time to anadromous fish. We think there
is every reason in the world to believe that they can be
restored. I am in hopes that very soon we can embark on a
major program on the Merrimack River. V/e stand ready to
join with the two States in making additional funds.
I perhaps might point out that this, of course,
will depend upon the temper of the Congress. We will make
more funds available if Congress appropriates more money
for this program.
CHAIRMAN STEIN. Thank you, Mr. Schrader.
Any further comments?
(No response.)
CHAIRMAN STEIN. By the way, I would like to again
emphasize what Mr. Schrader said. This is very clear to me.
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103
Thomas Schrader
Let me first begin by quoting a Congressman from the South
who has always said that he is shocked that New England
does not take advantage of the water resources development
that we have in other areas. As I see it from an economic
impact, we have a problem here that other places in the
country either because climate or other conditions have
kind of ameliorated. That is, your recreation season is
relatively short. It goes from the 4th of July to Labor
Day and it is all over. You have the facilities - the
motels, the filling stations, the restaurants. They are
all here.
Now, when you are in a river basin situation, such as
the Connecticut, the Merrimack or the Penobscot, you do not,
of course, get the ski business in the wintertime. However,
we know that if the fish are restored the amount of business
you will get from the fishery business will extend this
season materially and will very well do that before or
after your peak loads. All you have to do is go out to
the Pacific Northwest and see the kind of operation that
they have up there.
It seems to me that you people have the facilities.
You are all ready to go. If we can get this pollution
cleaned up and restore these anadromous runs so that we
have a reasonably decent habitat for the fish in the
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Thomas Schrader
Merrimack River, and with the cooperation of the Fish and
Wildlife Service and their counterparts in the States, we
would have the same kind of experience that we have had in
the Pacific Northwest. Possibly, we would have the same
success as we have had with the introduction of Coho Salmon
in Lake Michigan. Some of you may have seen this -- Coho
Salmon were put into Lake Michigan as a method to control
the alewives, which, as you know are a nuisance. However,
that is not the issue now. The point is that the people
in these areas around Lake Michigan now have salmon fever
when the fishing season is opened, and it has opened a
completely expanded industry to areas in times when they
were not normally used for vacation facilities.
Now, I think the people in the Merrimack Valley
and New England rivers have the same, same situation.
Let me emphasize this for one moment; because this
is going to be the sort of problem which is not only
pollution alone. The rivers have been dammed up and these
fish stopped coming in. However, as we have shown in
rivers in other areas, the Fish and Wildlife people have
fish-passage devices that can get these fish over the dams,
a lot higher dams than you have here.
The first step and prerequisite is to get these
waters cleaned up, so that they can maintain the fish.
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105
Charles D. Larson
I am sure anyone could make a respectable
argument to Congress for authorizing and making available
these funds to put in these devices if it is going to do
some good and pollution is not going to kill the fish.
Clean water is what we first must have.
Any other comments?
(No response.)
CHAIRMAN STEIN. Thank you.
STATEMENT OF CHARLES D. LARSON
REGION I, SHELLFISH CONSULTANT
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
U. S. PUBLIC HEALTH SERVICE
BOSTON, MASSACHUSETTS
I am here representing the Consumer Protection and
Environmental Health Service of the U. S. Public Health
Service. We welcome the opportunity to speak in favor
of the continuing efforts to abate the pollution of the
Merrimack and Nashua Rivers.
On September 1, 1966, President Johnson approved
-*
an Interdepartmental agreement between the Department of
Health, Education, and Welfare and the Department of Interior.
\
This agreement sets forth the responsibilities of the.two
-------
106
Charles D. Larson
Departments in the field of water pollution control. Under
this agreement, the Surgeon General of the Public Health Service
shall provide consultation, advice and assistance relative to
the health aspect of water pollution. We are interested in safe
drinking water, adequate and healthful water-based recreation,
shellfish that are free from contamination, and crops that are
not contaminated by polluted irrigation waters.
Since the Merrimack River is already used as a water
supply and may be used by more communities in the future, and
since pathogens were isolated from the river during the Public
Health Service study of the river in 1965, we are interested in
seeing the water quality improved to further protect the
consuming public. The Merrimack is also used for irrigation and
in its present condition this is a questionable practice.
The river is used in some areas for water contact
recreation, but there are many areas that cannot be used at the
present time. If the quality was improved, the river could
provide some needed water-based recreation.
The Merrimack River estuary has a good soft clam
population and a Massachusetts Department of Natural
Resources Report published in June 1965 estimates that
there are 73>379 bushels of legal sized soft clams, and
1. "A Study of the Marine Resources of the Merrimack River
Estuary"; Jerome, W.C.? Chesmore, A.P.; Anderson, C.O.;
and Grice, F.; Massachusetts Department of Natural R
Resources, Division of Marine Fisheries, June 1965.
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107
Charles D. Larson
23,011 bushels, just under legal size, in the estuary.
The report indicates that under proper management these
populations could be doubled. They indicate that at the
then existing wholesale prices approximately $300,000 worth
of clams could be harvested annually. With proper manage-
ment this value might double or triple. The total impact
on the economy would raise this figure even more. How
much would depend on how the clams are used.
The Public Health Service has been active in the
Field.of Shellfish sanitation since 1925 when an outbreak of
typhoid fever occurred and was attributed to the consumption
of raw oysters taken from polluted waters. The state shell-
fish control agencies and the shellfish industry at that
time requested the Public Health Service to aid them in
developing a program of Shellfish Sanitation which would
establish consumer confidence in this important food item.
From that beginning the present Shellfish Sanitation
Branch of FDA has evolved. Presently the program is guided
by three manuals, the first of which deals with surveying
i,
and classifying growing waters. There are four classifiba-
tions of growing waters, but the one that could apply to the
Merriraack Estuary is the "'Conditionally Approved'' classifica-
tion (The pages of the Manual describing these classifications
i
are attached.)
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108
Charles D. Larson
Before any closed areas in the Merrimack Estuary
can be opened, the requirements of the National Shellfish
Sanitation Program must-be met. This would involve reduced
pollution from upstream sources and efficient operation of
the Newburyport sewage treatment plant. Even with efficient
operation of the treatment, sorr.e area must remain closed near
the outfall. Dye studies have indicated that the effluent
of the treatment plant goes over the shellfish areas during
ebb tide and therefore efficient administrative procedures
must be established and used to insure the immediate closure
of the conditional area if the treatment plant fails. The
only way the whole estuary could be used would be to re-
locate the treatment plant outfall.
The goals of the National Shellfish Sanitation
Program are: (1) the continued safe use of this natural
resource (2) active encouragement of water quality programs
which will preserve all possible coastal areas for this
beneficial use. It is in keeping with this second goal,
our interest in safe drinking water and healthful water-
based recreation, that the Public Health Service supports
the recommendations of the Federal Water Pollution Control
Administration.
Attachment
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109
3. Approved Areas.—Growing areas may
be designated as approved when: (a) the sani-
tary survey indicates that pathogenic micro-
organisms, radionuclides, and/or harmful in-
dustrial wastes do not reach the area in dan-
gerous concentration, and (b) this is verified by
laboratory findings whenever the sanitary sur-
vey indicates the need. Shellfish may be taken
from such areas for direct marketing.
Satisfactory compliance.—This item will be
satisfied when the three following criteria are
met:
a. The area is not so contaminated with fecal
material that consumption of the shellfish might
be hazardous, and
b. The area is not so contaminated with
radionuclides or industrial wastes that con-
sumption of the shellfish might be-hazardous
(see section C, item 7, regarding toxins in shell-
fish growing areas), and
c. The coliform median MPN of the water
does not exceed 70 per 100 ml., and not more
than 10 percent of the samples ordinarily ex-
ceed an MPN of 230 per 100 ml. for a 5-tube
decimal dilution test (or 330 per 100 ml., where
the 3-tube decimal dilution test is used) in those
portions of the area most probably exposed to
fecal contamination during the most unfavor-
able hydrographic and pollution conditions.
(Note: This concentration might be exceeded if
less than 8 million cubic feet of a coliform-free
dilution water are available for each population
equivalent (coliform) of sewage reaching the
area). The foregoing limits need not be ap-
plied if it can be shown by detailed study that
the coliforms are not of direct fecal origin and
do not indicate a public health hazard (19)
(20) .8
Public-health explanation.—A review of epi-
demiological investigations of disease outbreaks
attributable to the consumption of raw shellfish
reveals that two general situations prevail ° in-
sofar a? pollution of growing or storage areas
are concerned.
"This MPN value is based on a typical ratio of coliforms
to pathogens and would not be applicable to any situation in
which an abnormally large number of pathogens might be
Present. Consideration must also be given to the possible
MMence of industrial or agricultural wastes In which there
linn atypical coliform to pathogen ratio (30).
There is a third general consideration in which shellfish
"toy be contaminated through mishandling. This is not re-
"ted to growing area sanitation and is considered in part II
°' this manual.
( 1 ) Gross sewage cont animation of a grow-
ing or wet storage area. (A report of a 1910
outbreak of typhoid fever involving 41 per-
sons notes that raw sewage from a city with
a population of 30,000 was discharged only
a few hundred feet away from clam beds and
floats (27) (£8). In 1947 a case of typhoid
fever was attributed to clams harvested 200
yards from the outlet of a municipal sewage
treatment plant (29). In the latter case, the
coliform MPN of the harbor water exceeded
12,000 per 100 ml. and the area had been
posted as closed to shellfish harvesting.)
(2) Chance contamination of a growing or
wet storage area by fresh fecal material which
may not be diffused throughout the entire area
(14) (16) (17) (19) and therefore not readily
detectable by ordinary bacteriological pro-
cedures. The possibility of chance contami-
nation was noted by Dr. Gurion in his report
on a 1902 typhoid outbreak, and who is quoted
in Public Health Bulletin No. 86, as "there
is a zone of pollution established by the mere
fact of the existence of a populated city upon
the banks of a stream or tidal estuary which
makes the laying down of oysters and clams
in these waters a pernicious custom if per-
sisted in, because it renders these articles of
food dangerous at times, and always suspi-
cious". The 1956 outbreak of infectious
hepatitis in Sweden (691 cases) attributed to
oysters which were contaminated in a wet
storage area is an example of such contami-
nation (16). Similarly in 1939, 87 cases of
typhoid were attributed to fecal contamina-
tion of a storage area by a typhoid carrier
It is well established that shellfish from
water having a median coliform MPN not ex-
ceeding 70 per 100 ml.8 and which is also pro-
tected against chance contamination with fecal-
material, will not be involved in the spread of
disease which can be attributed to initial con-
tamination of the shellfish. This is not surpris-
ing since a water MPN of 70/100 ml. is equiv-
alent to a dilution ratio of about 8 million cubic
feet of coliform-free water per day for the fecal
material from each person contributing sewage
to the area. This tremendous volume of water
is available in shellfish growing areas through
1965
13
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1
d
>
3
I
PROHIBITED AREA
Sewer outfall ifj^k RESTRICTED AREA
Sewage
treatment
plant
PROHIBITED
AREA
CONDITIONALLY
APPROVED
AREA
APPROVED AREA
FIGURE 1
-------
Ill
tidal action which is constantly bringing un-
polluted water into the area.8
Areas which are approved for direct market
harvesting of shellfish which will be eaten raw
must necessarily meet one general test; i.e,
sewage reaching the growing area must be so
treated, diluted, or aged that it will be of neg-
ligible public-health significance. This implies
an element of time and distance to permit the
mixing of the sewage or fecal material with the
very large volume of diluting water and for a
major portion of the microorganisms to die out.
Studies of the natural die-off of microorganisms
in an unfavorable marine environment have
been summarized by Greenberg (##).
The effectiveness of sewage treatment proc-
esses must be considered in evaluating the san-
itary quality of a growing area since the bacte-
rial and viral content of the effluent will be
determined by the degree of treatment which is
obtained (0) (73) (74) (75). The results of
bacteriological sampling must also be correlated
with sewage treatment plant operation, and
evaluated in terms of the minimum treatment
which can be expected with a realization of the
possibility of malfunctioning, overloading, or
poor operation.
The presence of radionuclides in growing
area waters may also have public-health sig-
nificance since shellfish, along with other marine
organisms, have the ability to concentrate such
materials (31) (32) (83) (34). The degree to
which radioisotopes will be concentrated de-
pends upon the species of shellfish and the
specific radioisotope. For example, it has been
reported that the Eastern oyster has a concen-
tration factor of 17,000 for Zn05 whereas the
concentration factor in soft tissues for Sr80 is
approximately unity (31) (33). The distribu-
tion of the radioisotope in the shellfish and the
biological half-life are also variable. Sources
of radioactive materials include fall-out, indus-
trial wastes, and tmclear reactors. Limiting
maximum permissible concentrations of radio-
active materials expressed in terms of specific
radioisotopes and unidentified mixtures in
water and food have been established (35) (36).
The current standard should be consulted in
evaluating the public-health significance of de-
^ted radioactivity in market shellfish.
See footnote 8 on page 13.
JUNE 1965
The bacterial quality of active shellfish will
ordinarily be directly proportional to the bac-
terial quality of the water in which they grew;
however, considerable variation in individual
determinations may be expected. The coliform
MPN's of the shellfish usually exceed those of
the overlying water because shellfish filter large
quantities of water to obtain food, thereby con-
centrating the suspended bacteria. This rela-
tionship will depend upon the shellfish species,
water temperature, presence of certain chemi-
cals, and varying capabilities of the individual
animals.
4. Conditionally Approved Areas.—The
suitability of some areas for harvesting shellfish
for direct marketing is dependent upon the at-
tainment of an established performance stan-
dard by sewage treatment works discharging
effluent, directly or indirectly, to the area. In
other cases the sanitary quality of an area may
be effected by seasonal population, or sporadic-
use of a dock or harbor facility. Such areas
may be classified as conditionally a.pprorfd.
State shellfish control agencies shall establish
conditionally approved areas only when satisfied
that, (a) all necessary measures have been taken
to insure that performance standards will be
met, and (b) that precautions have been taken
to assure, that shellfish will not be marketed
from the areas subsequent to any failure to meet
the performance, standards and before the shell-
fish can purify themselves of polluting micro-
organisms.
Kiitixftirtory compl'mt>cc.—This item will bo
satisfied when—
a. The water quality requirements for an
nppro red- area are met at all times while the area
is approved as a source of shell fish for direct
marketing.
b. An operating procedure for cut-h condi-
tionally tipprored area is developed jointly by
the State shellfish control agency, local agencies,
including those responsible for operation of
sewerage systems, and the local shell fish indus-
try- The operating procedure should be based
on an evaluation of each of the potential sources
of pollution which may affect the area. The
procedure should establish performance stand-
ards, specify necessary safety devices and meas-
ures, and define inspection and check proce-
dures. (These procedures are described in
15
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112
more detail in the following public-health
explanation.)
c. A closed safety zone is established between
the conditionally approved area and the source
of pollution to give the State agency time to
stop shellfish harvesting if performance stand-
ards are not met.
d. Boundaries of conditionally appro red
areas are so marked as to be readily identified
by harvesters.
e. Critical sewerage system units are so de-
signed, constructed, and maintained that the
chances of failure to meet the established per-
formance standards due to mechanical failure
or overloading are minimized.
f. There is a complete understanding of the
purpose of the conditionally approved classifi-
cation by all parties concerned, including the
shellfish industry. Successful functioning of
the concept is dependent upon the wholehearted
cooperation of all interested parties. If such
cooperation is not assured the State should not
approve the area for direct harvesting of mar-
ket shellfish.
g. Any failure to meet the performance
standards is immediately reported to the State
shellfish control agency by telephone or messen-
ger. In some instances States may find it de-
sirable to delegate the authority for closing a
conditionally approved area to a representative
of the agency located in the immediate area.
h. The State immediately closes condition-
ally approved areas to shellfish harvesting fol-
lowing a report that the performance standards
have not been met. The area shall remain
closed until the performance standards can
again be met plus a length of time sufficient for
the shellfish to purify themselves so that they
will not be a hazard to the public health. (See
section D-l, "Relaying," for information on the
length of time required for self-purification of
shellfish.)
i. The State shellfish control agency makes at
least two evaluations during the shellfish har-
vesting season of each conditionally approved
area including inspection of each critical unit
of the sewerage system to determine the general
mechanical condition of the equipment, the ac-
curacy of recording devices, and the accuracy of
reporting by the operating agency.
j. It is discovered that failure to meet per-
formance standards have not been reported by
the operating agency, or if the performance
standards are not met, the area will imme-
diately revert to a restricted or prohibited
classification.
k. All data relating to the operation of a
conditionally approved area, including oper-
ation of sewerage systems, are maintained in a
file by the State shellfish control agency.
Public-health explanation.—The condition-
ally approved classification is designed pri-
marily to protect shellfish growing areas in
which the water quality might undergo a signifi-
cant adverse change within a short period of
time.1" The change might result from over-
loading or mechanical failure, of a sewage treat-
ment plant, or bypassing of sewage at a lift
station.
Water quality in many growing areas in the
more densely populated sections of the country
is, to some degree, dependent upon the operation
of sewage treatment plants. For example, the
boundaries of an approved shellfish area might
be determined during a period when a tributary
sewage treatment plant is operating at a satis-
factory level. If there, is some interruption in
treatment it follows that there will be some deg-
radation in water quality in the growing area,
which may justify a relocation of the bound-
aries. The degree of relocation would depend
upon such items as the distance between the pol-
lution source and the growing area, hydrog-
raphy, the amount of dilution water, and the
amount of pollution.
The concept is also applicable to other situa-
tions in which there may be a rapid or seasonal
change in water quality. Examples of such
situations include—
a. A growing area adjacent to a resort com-
munity. During the summer months the
community might have a large population which
might, have an adverse effect on water quality.
However, during the winter when there are few
people in the community the water quality
might improve sufficiently to allow approval of
the area. In some States this is known as a
seasonal Closure.
b. A protected harbor in a sparsely settled
area might provide anchorage for a fishing fleet
10 A natural disaster may also cause many sewage treat-
ment plants to be out of service for an extended period of
time. The conditionally approve/I nri'ii concept is not ordi-
narily concerned with such emergency situations.
16
JANUARY 1959
-------
several months a year. When the fishing fleet is
in, the harbor water would be of poor sanitary
quality; however, during the remainder of the
year the quality of the harbor water might be
satisfactory. The area would be approved for
shellfish harvesting only when the fishing fleet
is not using the harbor.
c. The water quality in an area fluctuates with
the discharge of a major river. During periods
of high runoff the area is polluted because of
decreased flow time in the river. However, dur-
ing periods of low runoff the area might be of
satisfactory quality and thus be approved for
shellfish harvesting.
The establishment of conditionally approved
areas might be considered whenever the poten-
tial for sewage contamination is such that the
limiting water quality criteria for an approved
area might be exceeded in less than one week
due to a failure of sewage treatment, or other
situations as described above.
The first, step in determining whether an area
should be placed in the conditionally approved
classification is the evaluation of the potential
sources of pollution in terms of their effect on
water quality in the area. Potential sources of
pollution include the following:
(1) Sewage treatment plants.
(a) Bypassing of all or part of sewage
because of mechanical or power failure,
hydraulic overloading, or treatment over-
loading.
(6) Reduced degree of treatment due to
operational difficulties or inadequate plant.
(2) Sewage lift, stations.
(a) Bypassing during periods of maxi-
mum flow due to inadequate capacity.
(6) Bypassing because of mechanical or
power failure.
(3) Interceptor sewers or underwater out-
falls.
(a) Exfiltration due to faulty construc-
tion.
(5) Leakage due to damage.
(4) Other sources of pollution.
(a) Sewage from merchant or naval
vessels.
(6) Sewage from recreation use of area.
The second step in establishment of a condi-
tionally approved area is the evaluation of each
source of pollution in terms of the water quality
JANUARY 1959
113
standards to be maintained, and the formulation
of performance standards for each installation
having a significant effect on the sanitary qual-
ity of the area. Examples of performance
standards might include:
(1) Bacteriological quality of effluent from
sewage treatment plants. This might be
stated in terms of chlorine residual if the
bacteriological quality of the effluent can be
positively related to chlorine residual. The
following is an example of a performance
standard (37): "The median coliform MPN,
in any one month, shall not exceed 500 per
100 ml., based on not less than 16 composite
samples per month, and not more than 10 per-
cent of the samples shall have an MPN in ex-
cess of 10,000 per 100 ml. Determinations of
the chlorine residual of the effluent should be
made hourly and recorded in the permanent
plant records."
(2) Total quantity of sewage which can be
discharged from any given unit, or from a
combination of units, without causing the
basic water quality standards to be exceeded.
(3) Amount of shipping in the area and
the amount of sewage which can be expected.
Design criteria which may be useful in formu-
lating an opinion on the quantity of sewage
which can be discharged into an area without
exceeding the desired water quality standards
include: Population equivalent (coliform) of
sewage; predicted survival of coliform in sea
water, effectiveness of chlorination, and the total
quantity of clean dilution water in an area. Re-
sults of many studies on the survival of bacteria
in sea water have been summarized in An In-
vestigation of the Efficacy of Submarine Owtfall
Disposal of Sewage and Sludge; Publication
No. 14, California State Water Pollution Con-
trol Board, 1956.
The mechanical equipment at critical sewage
treatment or pumping units should be such that
interruptions will be minimized. Wherever
possible operations should be automatically re-
corded on charts. Examples of the require-
ments which might be imposeds depending upon
the importance of the unit in terms of water
quality, include:
(1) Ample capacity for storm flows.
(Storm water should ordinarily be excluded
from the sanitary system.)
17
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114
(2) Standby equipment to insure that
treatment or pumping will not be interrupted
because of damage to a single unit or to power
failure.
(3) Instrumentation of pumps and equip-
ment to allow the regulatory agency to de-
termine that performance standards have
been met. Examples include:
(a) Recording scales to indicate rate of
chlorine use. Chlorine flow can be inte-
grated with hydraulic flow to establish a
ratio.
(b) Liquid level recording gages in over-
flow channels of sewage treatment plants
and wet wells of lift stations to indicate
when overflow takes place. Charts should
be dated and initialed by the operator.
Gages should be calibrated so that dis-
charge can be estimated.
(c) Automatic devices to warn of fail-
ure or malfunctioning at self-operated
pumping stations or treatment plants.
(4) The effect, of storm sewage can be cal-
culated by multiplying the total estimated
flow by the observed coliform content. The
result can be expressed in terms of popula-
tion equivalents (coliform).
Design and operation of equipment should be
such that closure provisions should not have to
be invoked more than once per year under
ordinary circumstances.
A closed safety area should be interposed
between the conditionally approved area and the
source of pollution. The size of such area should
be based on the total time it would take for the
operating agency to detect a failure, notify the
State shellfish control agency, and for the latter
agency to stop shellfish harvesting. 11 is recom-
mended that the area be of such size that the
flow time through the safety area be at least
twice that required for the notification process
to become effective. Due consideration should
be given to the possibility that closure actions
might be necessary on holidays or at night.
The type of marking which will be required
for conditionally approved areas will vary from
State to State depending upon the legal require-
ments for closing an area.
The length of time a conditionally approved
area should be closed following a temporary
closure will depend upon several factors includ-
ing the species of shellfish, water temperature,
purification rates, presence of silt or other
chemicals that might interfere with the physio-
logical activity of the shellfish, and the degree
of pollution of the area. (See section D-l of
this manual for additional information on the
natural purification of shellfish.)
5. Restricted Areas.—An area may be clas-
sified as restricted when a sanitary survey in-
dicates a limited degree of pollution which
would make it unsafe to harvest the shellfish
for direct marketing. Alternatively the States
may classify such areas as prohibited. (See
section C-6, this manual.) Shellfish from such
areas may be marketed after purifying or re-
laying as provided for in section D.
Satisfactory compliance.—This item will be
satisfied when the following water quality cri-
teria are met in areas designated by States as
restricted.™ 12
a. The area is so contaminated with fecal
materials that direct consumption of the shell-
fish might be hazardous, and/or
b. The area is not so contaminated with radio-
nuclides or indxistrial wastes that consumption
of the shellfish might be hazardous, and/or
c. The coliform median MPN of the water
does not exceed 700 per 100 ml. and not more
than 10 percent of the samples exceed an MPN
of 2,300 per 100 ml. in those portions of the
areas most probably exposed to fecal contami-
nation during the most unfavorable hydro-
graphic and pollution conditions. (Note: this
concentration might be exceeded if less than
800,000 cubic feet of a coliform-free dilution
water are available for each population equiv-
alent (coliform') of sewage reaching the area.)
d. Shellfish from restricted areas are not
marketed without controlled purification or
relaying.
Public-health explanation.—In many in-
stances it is difficult to draw a clear line of de-
marcation between polluted and nonpolluted
areas. In such instances the State may, at its
11 It is not mandatory that States use this classification.
A roil K not meeting the approved classification mny he closed
to nil harvesting for direct marketing.
"Routine sanitary surveys nnd reappraisals of restricted
areas slnill be made ou the same frequency as for approved
areas. (See section C-l.)
18
JANUARY 1959
-------
115
option, classify areas of intermediate sanitary
quality as restricted and authorize the use of the
shellfish for relaying, or controlled purification.
6. Prohibited Areas.—An area shall be clas-
sified prohibited if the sanitary survey indicates
that dangerous numbers of pathogenic micro-
organisms might reach an area. The taking of
shellfish from such areas for direct marketing
shall be prohibited. Relaying or other salvage
operations shall be carefully supervised to in-
sure against polluted shellfish entering trade
channels. Actual and potential growing areas
which have not been subjected to sanitary sur-
veys shall be automatically classified as
prohibited.
Satisfactory compliance.—This item will be
satisfied when:
a. An area is classified as prohibited if a sani-
tary survey indicates either of the following
degrees of pollution:
(1) The area is contaminated with radio-
nuclides or industrial wastes that consump-
tion of the shellfish might be hazardous
and/or
(2) The median coliform MPN of the wa-
ter exceeds 700 per 100 ml. or more than 10
percent of the samples have a col i form MPN
in excess of 2,300 per 100 ml. (Note: This
concentration might be reached if less than
800,000 cubic feet of a coliform-free dilution
water are available for each population equiv-
alent (coliform) of sewage reaching the
area.)
b. No market, shellfish are taken from pro-
hibited areas except by special permit as de-
scribed in section D.
p. Coastal1 areas in which sanitary surveys
have not been made shall be automatically
classified as prohibited.
Public-health explanation.—The positive re-
lationship between enteric disease and the eat-
ing of raw or partially cooked shellfish has
been outlined in section C-l. Prevention of
the interstate transport of shellfish containing
sufficient numbers of pathogenic microorga-
nisms to cause disease is a primary objective of
the National Program. Therefore, areas con-
taining dangerous concentrations of microor-
ganisms of fecal origin, or areas which may be
slightly contaminated -with fresh fecal dis-
charges, should not be approved as a source of
shellfish for direct marketing.
7. Closure of Areas Due to Shellfish
Toxins.—The State shellfish control agency
shall regularly collect and assay representative
samples of shellfish from growing areas where
shellfish toxins are likely to occur. If the
paralytic shellfish poison content reaches 80
micrograms per 100 Drains of the edible portions
of raw shellfish meat, the area shall be closed
to the taking of the species of shellfish in which
the poison has been found.1" The harvesting of
shellfish from such areas shall be controlled in
accord with the recommendations of sections
K-l and E--2 of this manual.
The quarantine shall remain in effect until
such time as the State shellfish control agency is
convinced the poison content of the shellfish in-
volved is below the quarantine level.u
Ratixfuctory compliant e.—This item will be
satisfied when—
a. The State shellfish control agency collects
and assays representative samples of shellfish
for the presence of toxins from each suspected
growing area during the harvesting season.
(See section B-2 for assay methods.)
b. A quarantine is imposed against the taking
of shellfish when the concentration of paralytic
shellfish poison equals or exceeds 80 micrograms
per 100 grams of the edible portion of raw
shellfish.
Public-health explanation.—In some areas
paralytic poison is collected temporarily by bi-
valve shellfish from free-swimming, one-celled
marine plants on which these shellfish feed. The
plants flourish seasonally when water conditions
are favorable.
Cases of paralytic poisoning, including sev-
eral fatalities, resulting from poisonous shell-
fish have been reported from both the Atlantic
and Pacific coasts. The minimum quantity of
poison which will cause intoxication in a sus-
ceptible person is not known. Epidemiological
investigations of paralytic shellfish poisoning
in Canada have indicated 200 to 600 micrograms
of poison will produce symptoms in susceptible
13 This value is based on the results of epidemiological in-
vestigations of outbreaks of paralytic shellfish poison in
Canada in 1954 and 1957 (38) (39).
" The provisions of this item apply only to shellfish which
will be marketed us a fresh or frozen product as properly
controlled heat processing will reduce the poison content of
the shellfish.
JUNE 1965
19
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116
persons and a death has been attributed to the
ingestion of a probable 480 micrograms of poi-
son. Investigations indicate that lesser amounts
of the poison have no deleterious effects on hu-
mans. Growing areas should be closed at a
lower toxicity level to provide an adequate mar-
gin of safety since in many instances toxicity
levels will change rapidly (38) (39). It has
also been shown that the heat treatment af-
forded in ordinary canning processes reduces
the poison content of raw shellfish considerably.
A review of literature and research dealing
with the source of the poison, the occurrence
and distribution of poisonous shellfish, physi-
ology and toxicology, characteristics of the poi-
son, and prevention and control of poisoning
has been prepared (40).
In Gulf coast areas, toxicity in shellfish has
been associated (IS) (76) with Red Tide out-
breaks caused by mass bloomings of the toxic
dinoflagellate, Gymn-odinhim breve. Toxic
symptons in mice suggest a type of ciguatera
fish poisoning rather than symptoms of para-
lytic shellfish poisoning.
20
JUNE 1965
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Arthur Newhall
MR. KLA3HMAN. Are there any other representatives
of the Federal Government that wish to be heard?
(No response.)
MR. KLA3HKAN. If not, this concludes our statement
at this time.
CHAIRMAN STEIN. May we have a 10-minute recess and
#
then we will hear from the States.
(Short recess.)
CHAIRMAN STEIN." Let us reconvene, please.
Before we go on with the continuance of the New
Hampshire presentation, we are going to call on Mr. Newell
with a statement from New Hampshire on the development of
the anadromous fishery.
Will you please give your full name and title?
STATEMENT OF ARTHUR E. NEWELL, SUPERVISOR
FISHERIES RESEARCH
NEW HAMPSHIRE FISH AND GAME DEPARTMENT
CONCORD, NEW HAMPSHIRE
MR. NEWELL: Ladies and gentlemen, iny name is
Arthur Newell. I am Supervisor of Fisheries Research for
the New Hampshire Fish and Game Department.
connection with the previous talk by Mr. Schrader
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William A. Healy
I simply would like to add that the Massachusetts Depart-
ment of Fisheries and Game and the New Hampshire Fish and
Game Department have been cooperating on an anadromous fish
restoration program in the Merrimack Basin for approximately
two years.
We have established a time schedule. We have not
progressed at this point as far as we have on the Connecticut,
but at the present time we believe that somewhere between
1975 and 1978 that we should be having anadromous fish up?
at leastjinto the New Hampshire section of the river. This
would be American Shad and^perhaps, not quite so soon, we
anticipate having Atlantic Salmon up into the Pemigewasset
and its tributaries.
I believe that is all I have.
CHAIRMAN STEIN. We will now call on Mr. Healy for
the rest of the New Hampshire presentation.
STATEMENT OF WILLIAM A. HEALY
EXECUTIVE DIRECTOR
NEW HAMPSHIRE WATER SUPPLY AND POLLUTION
CONTROL COMMISSION
CONCORD, NEW HAMPSHIRE
MR. HEALY. Mr. Chairman, New Hampshire intends to
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James A. Sweeney
enter a policy statement on behalf of th* Commission.
This will be done by Mr. James A. Sweeney, the Vice Chair-
man of the Commission, who is sitting on my left.
In addition to his prepared statement, our Director
of Municipal Services, Clarence Metcalf, will make a brief
statement indicating what changes are proposed in the way
of the legislation at the upcoming 1969 session of the General
Court so as to accommodate the various criticisms or recom-
mendations outlined in Secretary Udall's letter of approval
of our water quality standards. He did stipulate in a number
of areas that changes would be required in the New Hampshire
statutes and its program so as to meet the Federal objectives.
So I will ask Mr. Sweeney to make his statement now.
STATEMENT OF JAMES A. SWEENEY, VICE CHAIRMAN
NEW HAMPSHIRE WATER SUPPLY AND POLLUTION CONTROL
COMMISSION, CONCORD, NEW HAMPSHIRE
MR. SWEENEY. Thank you, Bill.
Mr. Chairman, in appearing before you today with
regard to the pollution control measures which the New
* .
4
Hampshire Water Supply and Pollution Control Commission has
Planned for the Merrimack River, I would like to offer a
opening statement so that these proposals will be
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James Sweeney
clearly understood by all parties concerned.
As you know, the New Hampshire Commission had its
water quality standards approved by the Secretary of the
Department of the Interior under date of August 16, 196S.
In indicating his approval of the submission the Secretary
inserted a number of reservations, one of which excluded
approval of the standards for the Merrimack River. His
letter went on to express concern that the New Hampshire
compliance schedules for the cities of Manchester and
Concord were not compatible with the schedule established
by the Commonwealth of Massachusetts for this particular
watershed.
In response to this criticism, I would have to say
that careful consideration was given by us to the fact that
some disparity in time did exist between the project
schedules in the two States. However, such a situation is
inevitable, because in developing the construction schedule
we had to take into account the availability of Federal and
State grant money to fund the various projects which would
be needed to satisfy the control needs along the New Hampshire
portion of the Merrimack River.
It is significant to note here that the Federal
appropriations are already in default of the amounts
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121
James Sweeney
authorized in the Federal Water Pollution Control Act,
and this can only have a damaging effect on the schedules
which were contained in the water quality standards earlier
approved by the Secretary. Undoubtedly, the same unfavorable
impact will be felt in other States, since, to the best of
our knowledge, the vast majority, if not all States, have
counted upon full Federal appropriations in preparing project
construction schedules for your review and consideration.
Returning to the difference in time which does exist
between New Hampshire and Massachusetts schedules, it should
be pointed out that we did consult with the Commonwealth of
Massachusetts authorites and they still have no objection
to the limits which have been established in the implementa-
tion plan prepared by New Hampshire. They are aware of the
many pressing projects which must be constructed along other
interstate streams within the boundaries of this State and
recognize the financial commitments which are represented
therby. In other words, there is a complete appreciation of
the fact that the schedules which have been developed
Statewide are fair and equitable in every instance; giving
due regard, of course, to the grant funds which can be
anticipated over the next several years.
Incidentally, it may be well to indicate at this
time that a considerable amount of control has already been
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James Sweeney
established in the Merrimack Basin. For example, in the
Pemigewasset River watershed, which your agency considers to
be the main stem of the Merrimack River, sizable pollution
control projects are well under way in Lincoln, Ashland,
Plymouth, Bristol and Hooksett. In addition, communities
such as New Hampton, Goffstown, Derry, Salem and Nashua
have completed construction of control facilities. These
plants have resulted in improvement of water quality in
the watershed, and when the others which I mentioned are
finished within the next year or so, other significant
improvements in water quality will be realized. Major com-
munities likft Manchester and Concord are actively planning
for similar control measures and, thus, it has been estimated
that the entire river will be cleaned up by 1977. This
estimate, as indicated earlier, was prepared on the basis
of full Federal appropriations.
The State Legislature has continued its policy of
•
making adequate funds available to meet its obligations, and
there is every expectation that this will continue to be the
case over the next several years. When we examine what has
been done to date and review realistically what can be done
in the light of Federal funds currently available to us, the
New Hampshire program must be regarded as a highly satisfactory
one. V;hat is needed now, and needed badly — is a drastic
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123
James Sweeney
upturn in Federal appropriations to relieve the bottleneck
which has been created by the unfortunate curtailment in
funding at the Federal level.
The prospects of some relief through the contract
provisions incorporated in S.3206 held some promise of
relief, however, because the formula for allocating contract
capacity to the several States was based strictly upon
population, we understand that only something in the neighbor-
hood of $750,000 in contract capacity would have been made
available to New Hampshire if the legislation had been passed.
This, of course, is far less than what is needed, when viewed
in the light of grant funds needed in the City of Manchester,
to say nothing of Concord and the other major projects, which
will be necessary to establish full control over pollution
in the river.
Thus, Mr. Chairman, I would suggest in the strongest
terms possible that the most Important contribution this
conference could make is in the area of focusing attention
upon the critical shortage of Federal grant funds and the
necessity for bringing about an immediate solution in this
regard in order that all communities within the basin —
New Hampshire and Massachusetts alike — may proceed forthwith
\
n the construction of the required abatement facilities.
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124
James Sweeney
Any delays in achieving established construction
schedules is regrettable, since we all recognize that this
can only result in higher costs to everyone, inasmuch as the
cost of construction continues to rise markedly from one
year to another.
I would like to close by pledging our best effort to
complete the secondary treatment program for the watershed
at the earliest feasible time, but the funds to do this must
be forthcoming.
There is one other brief comment on conservation to
be made regarding compliance with construction schedules.
This is that I most heartily agree with the position stated
by Assistant Secretary for Pollution Control, Max Edwards,
during the appearance before the Water Pollution Control
Federation sessions in Chicago on September 24, 1968. In
part he had this to say:
"We believe that the Federal Government must
help our cities and towns meet their tremendous water
pollution expenditures. And we believe that it must
be done now. How can we insist that the States adopt
tough water quality standards and, at the same time,
fail to commit the necessary Federal dollars?"
Putting it another way how can the Federal Water
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125
Clarence Metcalf
Pollution Control Administration expect a State to Improve
upon Its compliance schedules, in this Instance the Merrlmack
River, unless there is a parallel and substantial increase in
the amounts of money made available to accomplish the objec-
tive?
I would like nothing better than to finish the Job
Instantly, but this we know cannot be done. We must work
together and do the best Job possible within the funds
available to complete the work.
CHAIRMAN STEIN. Thank you, Mr. Sweeney.
Are there any comments or questions?
(No response.)
CHAIRMAN STEIN. Thank you very much for your state-
ment, sir.
Mr. Healy.
MR. HEALY. Next is Clarence Metcalf, please.
CHAIRMAN STEIN. I would suggest that all people that
have statements, as a first priority, give their copy of the
statement to the Reporter and then possibly the conferees.
STATEMENT OF CLARENCE W. METCALF
DIRECTOR OF MUNICIPAL SERVICES
NEW HAMPSHIRE WATER SUPPLY AND POLLUCTION
CONTROL COMMISSION, CONCORD, NEW HAMPSHIRE
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126
Clarence Metcalf
MR. METCALF. Mr. Chairman, conferees, ladies and
gentlemen, the purpose of my remarks is to indicate in a more
specific way, than has been possible in Vice Chairman Sweeney's
comments, the various approaches which the Commission has
authorized to satisfy the recommendations which Secretary Udall
outlined in his letter of August 16, 1968, to Governor King, in
which he indicated approval, in principal, of the State of
New Hampshire Water Quality Standards.
You have heard Mr. Sweeney emphasize in considerable
detail the need for realistic Federal appropriations to meet
construction schedules which were submitted for the Merrimack
River and several other interstate waters which flow from
New Hampshire to other States. Perhaps,there is no other
single individual on the Commission staff who appreciates
the need for adequate appropriations more than myself, since {t'"
in ray position, I have had the unfortunate duty, at times,
of recommending which out of several worthy projects can be
funded because of the Insufficient Federal allocations.
Thus, in order to overcome this handicap and to obtain
Federal approval of our Standards, it was necessary for the
Commission and Governor King to agree to the introduction of
prefinancing legislation In the 1969 session of the General
Court. This legislation Is now in process in the Office of
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127
Clarence Metcalf
Legislative Services and, if enacted, will provide for
advancing the Federal share grant funds for secondary
treatment projects at Nashua, Manchester and Concord.
To cope with another request for an exception in
the control program, we are asking that the Office of
Legislative Services give consideration to inclusion of
the town of Plymouth in the secondary treatment, prefinancing
effort. In considering secondary treatment for this town,
it is necessary to Include the work as part of a prefinancing
i
program as recent reductions in authorized Federal allocations
i
of better than 50 percent make it impossible to finance the
project from any other source. It can be mentioned also at
this point that the Interim Legislative Committee for Water
Pollution Abatement has also been evaluating the desirability
of introducing legislation to establish a broad prefinancing
program for the entire State.
It has been clear to the members of this Committee,
which has maintained continuing surveillance of the abatement
Program throughout the State, that a full scale prefinancing
system similar to that in effect in the neighboring States, such
as Massachusetts, Maine, Connecticut, New York, etc., has
considerable merit, especially when due recognition is given
to the prpblem of skyrocketing costs. Most recently construe-
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128
Clarence Metcalf
tlon costs have been advancing at a rate approaching 10
percent per year. The consequence of splraling costs has
Impressed the Committee to the extent that it recently voted
to introduce and support general prefinancing legislation.
This, coupled with the other bill which I mentioned earlier,
will, if successful, help us to accelerate- control measures
to some extent in the tributaries to the Merrimack River.
These are, for the most part, intrastate waters, but never-
theless a balanced abatement program is essential.
To compensate for the exception which the Secretary
took in regard to temperature criteria, I should like to
indicate that legislation is being developed to meet this
criticism. It will consist of language supplanting the
present provision that will allow the Commission to follow
•*%*.'
numerical criteria recommended by the Pish and Game authorities,
the National Technical Advisory Committee or the New England
Interstate Water Pollution Control Commission recommendations,
whichever of these three will provide for the most effective
control. This arrangement, we feel, will provide for more
flexibility than the suggestion offered by the Secretary.
Another piece of legislation which will be introduced
to satisfy the conditions of the Secretary's approval is one
calling for the creation of salt water criteria in the New
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129
Clarence Metcalf
Hampshire statute. It is mentioned at this time only to
indicate the Commission intention to conform to the objectives
of the Secretary's letter of approval to Governor King.
It was also brought out as a recommendation in
Secretary Udall's letter that it would strengthen the program
to establish bacteriological limits for Class C waters. Inas-
much as waters in this category are sometimes used for
secondary contact,recreation, such as fishing, boating or
wading, our approach to the need for exercising some degree
of control over the bacterial quality of Class C waters of
necessity must come through careful and diligent supervision
of disinfection practices of waste treatment plants discharging
to such streams. This is a much more direct and, in our
Judgment, more significant means for guarding against infec-
tion than is being suggested through the creation of coliform
limits for Class C waters. The problem of overflows from
combined sewers is a difficult one in dealing with any attempt
to control limits of bacterial densities in Class C waters.
On the other hand, the results of disinfection of sewage
effluents can be very carefully controlled and evaluated by
frequent inspection and analysis of the treatment plant
operation^.
Some concern has also been expressed by the Regional
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•Clarence Metcalf
Office in its supplementary report on the Merrimack River
as regards the phenol level. At the present time we know
of only one potential source of waste discharge which could
contain phenol material, and this arises because of plant
scale treatment of wooden timbers and pollution with creosote
and associated oils. We know of no reason why this needs to
result in contributions of phenol to the river and whatever
control measures which might be necessary to prevent pollution
from such an operation will be imposed.
At this time I think it is in order to assure the
participants at this conference that the New Hampshire
Commission will make every effort to insure full compliance
with the classification requirements of the Merrimack
River as it flows through New Hampshire to the Commonwealth
of Massachusetts.
Thank you.
CHAIRMAN STEIN. Thank you.
Are there any questions or comments?
MR. KLASHMAN. I have a couple.
Mr. Metcalf, on the compliance dates, you know, in
the schedule, what are the dates that you are talking about
for Manchester, Concord and Plymouth? Do you have a copy
of this? (Indicating.)
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Clarence Metcalf
MR. METCALF. I have a copy.
MR. KLASHMAN. Mr. Pahren has given a recommen-
dation
Will you strike my question, please. I am sorry.
Are you going to take that up?
MR. HEALY. Yes, we will.
CHAIRMAN STEIN. Let us hold that.
Off the record.
(Discussion off the record.)
CHAIRMAN STEIN. May we go back on the record, please.
MR. KLASHMAN. There are a couple of more questions
I wished to ask on this statement. I will raise them now,
but you may want to answer them later.
First, the statement was made in talking about the
temperature criteria that you follow the numerical criteria
recommended by the Fish and Game authorities, the National
Technical Advisory Committee or the New England Interstate
Water Pollution Control Commission, whichever of these
three will provide for the most effective control. Do I
understand correctly that when you say "the most effective
control" you mean the most restrictive of these three,
whichever is the most restrictive0
MR. METCALF. As a matter of defining which you
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Clarence Metcalf
feel is the better type of control, effective or
restrictive. I feel "effective" is a good word myself.
MR. HEALY. What I think he is saying, if I could
add my voice to his, is simply this: That we expect that
any of these numerical criteria should be supported with
adequate backup information. This has been lacking up to
this time.
We are taking the best judgment of the experts and
certainly we should do this. But there are investigations
now under way to provide us with supporting information so
that we will know which set of numerical data we should
follow.
Now, we want to draw on what we regard as the
experts- the Fish and Game authorities in our own State,
the Advisory Board at the Federal level and the New England
Interstate - because we must work with the neighboring
States and we want to select of those three sources the
one that will provide us with the optimum control.
MR. KLASHMAN. Let me be specific. The National
Technical Advisory Committee, for example, as I recall, has
a maximum figure for a warm-water fishery of 83 or £6.
MR. PAHREN: I believe it is 83.
MR. KLASHMAN: They also have a figure where the temperate
rise cannot be more than five degrees, and that is based on
the Committee that the Secretary set up.
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Clarence Metcalf
Let us suppose that New Hampshire Fish and Game
Authority When you say "Fish and Game authorities,"
you mean the Fish and Game of New Hampshire?
MR. HEALY. I mean the Fish and Game Department.
MR. KLASHMAN. Of New Hampshire?
MR. HEALY. Yes.
MR. KLASHMAN. What if they came up with a difference
of opinion, say between the national experts, and came up
with, let's say, #4 degrees and 5-1/2 degrees rather than 5-
Do I understand that you would accept Well, I thought
that what you said was that you would accept the national
figure in that case; or if vice versa, if the New Hampshire
people came up with &2 degrees and the 4 degrees, then you
would accept the New Hampshire one. That is not true?
MR. HEALY. This is just the problem. I am hopeful
that the experts will get together and develop one common
set of standards, but meanwhile we ought to be able to
take the one that suits us best. Biologist Terrence Frost
is here. Do you want to comment?
MR. FROST. I do not believe we want to comment
anymore on what we said.- We want the best standards. We
could be less restrictive beyond the 5.
MR. KLASHMAN. You could be less restrictive?
MR. FROST. I cannot say now.
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Clarence Metcalf
MR. KLASHMAN. I will accept that. As far as you
can see, you cannot see yourself being less restrictive than
the national. I have nothing further to say. That is good
enough for me.
CHAIRMAN STEIN. Do you have another question?
MR. KLASHMAN. I have one other question.
I notice in the statement you say that you believe
in supervising the disinfection of waste. In other words,
you have an effluents standard in effect rather than a
stream standard. But when you talk about disinfecting a
waste, it is my understanding that you are talking about
insisting on a maximum level of 240 coliform per hundred ml in
the effluent. Is that correct?
MR. HEALY. This is in Class B waters. Yes.
MR. KLASHMAN. What about Class C?
MR. HEALY. To do a thorough job, it has been our
experience that we will produce that result whether it is
a Class C water of Class B water.
MR. KLASHMAN. When you are talking about an effluent
standard, you are talking about 240 per hundred in effluent.
So, therefore, while you do not accept the stream standard
that we are talking about I believe it is 5,000 per one
hundred you are going to put something in the stream that
is way below that. So I do not see that there is any problem
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Clarence Metcalf
here.
CHAIRMAN STEIN. Except the stormwater. I think
we got both of these problems. We are not going to solve
every problem in every case. These are the emerging problems
in pollution.
I may not be right on both these cases, but I have
heard considerable testimony throughout the country on both
these problems - one being the temperature business on the
fish. What we are dealing with here is the best expert
opinion we can get.
The point is, and my experience has always been,
that the fish really do not listen to the experts too much
as to what is good or not good. If it is no good, they do
not reproduce. If it is they will.
The point Mr. Healy made is well taken - that we
have to base this on experience. Since we are basing our
notion on where we are going, in my opinion, we should keep
ourselves flexible and as loose as possible. We should
make adjustments on that, but have the facts speak for them-
selves.
On the next issue we have somewhat the same situation.
Here is the key. The key is that what we are not here to do
is spend millions and millions of dollars and just put in
industrial or municipal waste plants at monstrous expense
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136
Clarence Metcalf
for pollution although we have to have clean water- Too
often in the past, in various parts of the country, all that
has been done is we build a plant and then we forget it. The
check is to get into this.
Two ways to work at this is to get in a river standard
or a water quality standard and an effluent standard. I have
heard people argue for hours on which is the more important
and I think they both are.
Now, here, as far as I see the situation on that, in
some places where we have checked this maybe the results
have not been too good. For example, we have spent hundreds
of millions of dollars in the lower Lake Michigan area. We
are not through with the program yet. But, in checking the
waters, we find that the waters are about what they were in
1965 when we started. Perhaps, this is all we can do now
because they have not gotten worse. At least, they have
tapered off and when the program finishes they will be set.
However, what we have to do, once you check these
waters and get out there and find the high coliform or a
high anything else, you do not automatically have the control.
Because of all the waste discharges you have, you do not
know where that is coming from and you have to trace it back.
For a regulatory agency, I think it has been
demonstrated by most of them that the best control that they
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137
Clarence Metcalf
can have is on the operations of the effluent so that
they know each one is running correctly.
Now, as I see it by Mr. Metcalf's statement?here
is what we have: If we are going to have disinfection,
the only kind of control, really - the rigid kind of
control - you can expect a regulatory agency to have,
whether they have a stream standard on the conforms or
not, is controlling and managing the application of the
chlorine, the retention time and the quality that comes
out.
You are not really going to check that back
through the streams. If you find a high count, this may
give you a clue that maybe something is wrong and you
are going to have to do that anyway. But the next point
is that we have the stormwater overflows and there are
times when this count is going to be high.
Now, the question that we really have to face is
that if the stormwater overflows create some problems and
they continue to create problems in Class C waters —
and this is a significant number of times during the
recreation season or. when people come into contact with
the water — we are Just going to have to, I guess, meet
that and get at it. Because if you go from a count that is
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Clarence Metcalf
too high, say over the 5,000 limit - again, the human body
does not read these criteria, either- you get sick or you
do not - the point is we are going to have to meet that.
I would say that from the New Hampshire program,
given what we are doing now and from a regulatory agency
point of view, this view of reducing coliforms or reducing
bugs or pathogens by checking on the operations of the
plants and the application of the chlorine and the retention
time, is probably the most effective way to get at this.
Recognizing again that with the stormwaters that
we have here we may have a problem in the future where we
cannot guarantee that those waters are going to be below
5»000 all during the summer, but we will have to get at
that. That is another problem.
Again coming to the temperature business, it seems
to me, since we are dealing with opinion, that the best
thing that anyone could do now is take the best opinion;
remain flexible; see what the effect on the fish is, if
any; see if the biologists come up with hard, factual
information, proved out, not only in the laboratory but
in the field and if necessary modify it.
In other words, what I am saying is in various
aspects of the program we will not have the last word here.
I think New Hampshire will be the last one to admit it will
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139
Clarence Metcalf
have the last word. The reason we do not is that the
art is always developing and we just do not know all the
answers. What we are doing is setting up a broad program
and in certain areas we are sort of feeling our way toward
solutions.
Are there any other comments?
MR. KLASHMAN. I have one other thing that I wanted
to raise.
In your statement you indicate, as I read it, that
as the water flows across the State line you are going to
have full compliance with the classification plans of the
Merrimack. As you know, the Secretary in his letter to the
Governor raised the question. What we said was:
"To fully protect public water supply use of
interstate waters-, criteria should be established to
prevent radiological and chemical contamination. Many
States have found it appropriate to reference the U. S.
Public Health Service Drinking Water Standards (1962) in
•
this^regard."
It is my understanding, by your statement, that you
are going to meet whatever is necessary; that as far as the
chemical and rediological need of the water supplies down-
stream from you are concerned, that if there were any problems
I don't believe there are now — you would meet the United
States Public Health Service drinking water standards. I am
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140
Clarence Metcalf
talking about the raw water standards.
MR. HEALY. All I can make here is a general
observation, and it is this: That New Hampshire is fully
aware of the water supply uses at Lowell and Lawrence, and
we intend in our operation to do our very best to safeguard,
even though we recognize, too, that these are conflicting
water uses in a sense because we are discharging a Class C
water in that State. Nevertheless, we will make our very
best effort to take whatever steps have to be taken to
protect the raw water quality in the stream, giving some
recognization to the fact that it is a water supply use.
There also has to be a dual recognition in the
State of Massachusetts by its local officials and others
in charge of water supply activities that they will apply
whatever treatment measures are necessary in regard to the
fact that this stream does have a multiplicity of uses.
There is no present standard.
MR. KLASHMAN. There is none. But if one were tU
develop you would limit it? That is my question.
MR. HEALY. I believe that there is not one now
and it is not germane to the discussion.
MR. KLASHMAN. Well, the Secretary raises it in his
letter and that is the reason I bring it up. There is no
problem now, as far as I know and you know, and you will
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Clarence Metcalf
prevent one from developing.
MR. HEALY. I will say this: New Hampshire
recognizes that we have to operate under the standards
and criteria that the Legislature establishes. It has
now established a Class C water for the Merrimack River
as it flows into Massachusetts. There are certain classifi-
cations in that law that relate to classification, and we
intend to meet them. We intend to move the control program
just as rapidly as possible, having in mind, as we must,
the amounts of State and Federal aid that are available to
assign to municipalities to do the necessary job.
I think that is a very reasonable assurance of what
New Hampshire's intention is, and that is the best I can do.
MR. PELOQUIN. Mr. Chairman, on that comment on the
criteria, New Hampshire has, as a signatory State in the
Interstate compact, pledged to abide by the standards
developed by the New England Interstate Water Control
Commission. These standards are being considered. Whether
or not they are revised will depend upon the final decision
of the Commission's Advisory Board. But this is under act
of consideration at the present time. I can state that
there is among the criteria one relating to radiological
standards. I think it would be premature to agree to any
quality criteria at the present time, because we feel
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14?
Clarence Metcalf
that whatever is adopted should be applicable to the North-
east and will necessarily subscribe to the national protective
criteria. We feel that it is
MR. KLASHMAN. You do not take any exceptions to
the United States Public Health Service radiological
drinking standards?
MR. PELOQUIN. These are under consideration and we
have been discussing these with the radiological consultant
with the Public Health Service, and we will be discussing
them again on January 13-
CHAIRMAN STEIN. I hate to bring this up, but as a
procedural matter, while we all feel ourselves competent
to handle the standards in radiation, I do not think the
conference really has the authority, even if we were to make
a decision. That is another process. I believe Mr. Klashman
and Mr. Peloquin have pointed that out.
I am sure there is going to be no problem, but
just as a fair statement, particularly if we deal, wjyfcfi ^me^,
thing like radiation, either the State or the Interstate
Commission is going to handle that adequately. Or if there
is a radiation problem in any field, I can assure you I am
going to be right here, and this will not be a choice of
mine because someone is going to tell me to come right up.
Now, in dealing with problems on radiation because of
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Clarence Metcalf
its being such a hazard, I know of no case where we have
not come into complete agreement with the State and worked
it out. This is not the kind of hazard you can fool around
with very long.
So I would suggest that we just put that in the
back corner, at least for this conference.
MR. HEALY. I think that is a very fair comment.
We have also under consideration legislation which
will allow us to do precisely what Mr. Peloquin has indicated
here - to conform in complete harmony with the New England
Interstate standards, as and when it is nec*«?sary. But as
of the moment there are no discharges of this sort here and
we see no reason to make a commitment at this time, and it
would be immature.
CHAIRMAN STEIN. Thank you.
Mr. McMahon.
MR. McMAHON. Mr. Chairman, I would just like to
say, as far as Massachusetts is concerned, we have been
working together with New Hampshire for a number of years
under the New England Interstate Water Pollution Control
Compact and I am certainly confident New Hampshire will
honor their commitments on interstate waters and we, in
Massachusetts, plan on doing the same thing. If there are
Problems that do develop such as radiological contamination,
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Honorable Maurice Bouchard
this is something that certainly the two States can work out
together.
MR.KLASHMAN. I have nothing further.
CHAIRMAN STEIN. May we go on, Mr- Healy?
MR. HEALY. Thank you. Time is escaping us.
There are a number of local officials and members
of various groups that have spoken to me indicating; they
do wish to make brief statements for the record so their
position will be made known. I know from my conversations
with these people from time to time that they are all
recognized supporters of the program. There is no difference
in objective here. It is a question of timing and financing,
really, that troubles us.
The city of Nashua has three representatives here.
Nashua has been outstanding in its voluntary efforts to
comply with the control program, and I would ask first that
Representative Maurice Bouchard speak to you.
STATEMENT OF MAURICE L. BOUCHARD, REPRESENTATIVE,
GENERAL COURT ALDERMAN, DISTRICT 14 OF NASHUA
NASHUA, NEW HAMPSHIRE
REPRESENTATIVE BOUCHARD. Thank you, Mr. Healy.
Mr. Chairman, members of the Committee, ladies and
gentlemen, I am Maurice Bouchard, Representative of the
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145
Honorable Maurice Bouchard
General Court from District 14 in Nashua, and I am also
a member of the Nashua River Water Pollution Commission
which was created in the 196? legislative session.
I wish to extend Mayor Sullivan's best wishes for
the success of this conference. He is very sorry and
regretful that he could not attend here today.
My statement is of a general nature, not being an
expert in this particular field. I have worked on the
problem. I have tried to come to some solutions on it and
I hope you will bear with me. It is not too lengthy a
comment.
A few days ago, or a short while ago, my wife and
I were standing on the bank at the Nashua River and at
our feet was an incredible amount of industrial waste,
but looking down at the graceful curve of the river and
the trees along its banks the eye found much that was
pleasing and my thoughts drifted back to a similar scene.
A few years ago we were visiting some good friends
in Wisconsin and while there we were taken on a boat ride on
the Fox River. It was lovely, as our Nashua and Merrimack
Rivers.
However, along the banks of the Fox are located the
Prime residential homes of Neenah and Menash in Appleton,
Wisconsin, with private docks, motor launches and also
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146
Honorable Maurice Bouchard
much land set aside for the beautiful parks for all to
enjoy.
I thought of the beauty, the recreational facilities,
the enjoyment, and, as Alderman at large of the city of
Nashua, of the potential revenue that would accrue to the
city if it would realize the-full potential of this river-
front property.
At one time these rivers of ours teemed with salmon
and other fish. Within the memory of many of Nashua residents,
we can remember the canoe rentals on the Nashua River, where
many a young man courted the lady of his choice.
Now residents of the Northwest section of our city
of Nashua, through which flows the Nashua River, complain,
and rightly so, of the permeating stench of pollution.
It is well known that the industries and municipalities
• Oy/' 1 i5 .
in the Commonwealth of Massachusetts, which constitutes the
major sources of pollution, are now embarked on a program of
engineering and construction to abate water pollution in
this watershed. Both Massachusetts and New Hampshire have
classified the main stem of this watershed. We have both
classified this as Class C waters as it enters and flows
through the State of New Hampshire. The Commonwealth of
Massachusetts has recently established a prefinancing law,
which will allow an accelerated construction schedule -
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147
Honorable Maurice Bouchard
despite the current shortage of Federal funds - to the
further cost of grants to which the various municipalities
are normally entitled.
The Nashua River Pollution Control Commission was
assured by the Massachusetts authorities that all projects,
industrial and municipal, to abate in the Nashua River
Basin will be in operation not later than the spring of
1972. The New Hampshire control in this basin, which, for
ail practical purposes, involves only the city of Nashua,
was scheduled for completion in the spring of 1976 and is
dependent upon the availability of Federal funds to support
the cityfs effort to reduce the pollution flow to the
natural river. Residents in the basin can take the position
that municipal, State and Federal Government, together with
industry, should work together and cooperate in providing
the answer of and solution of water pollution projects which
has plagued the river for years. The only barrier is the
lack of adequate financing.
Statutes now in effect are adequate to control
pollution and the control agencies of the two States are
operating effectively. The Commission does not recommend
N
any new or special legislation to control pollution in the
Nashua River. It does, however, strongly urge that the
General Court enact legislation to prefinance needed pollu-
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148
Honorable Maurice Bouchard
tion control projects, not only in the Nashua River Basin
but also in other areas of the State where such measures
are required to return the State surface waters to a useful
condition.
The Commission recognizes the extreme urgency of
prefinancing because of the rapid increase in construction
costs. Construction costs are now increasing at a rate
approaching 10 percent a year. Thus, any delay in construc-
tion of needed facilities will certainly result in higher
costs to Federal, State and local governments. Since the
cost of pollution control facilities is obviously going to
require substantial financial investment by the State and
its municipalities, it seems only logical that very serious
consideration be given to any means of combating the problem
of escalating construction costs. Prefinancing is a reason-
able answer to this dilemma, and the members of Nashua
Water Pollution Control Commission strongly recommend that
it receive careful consideration and support from the 1969
New Hampshire General Court.
CHAIRMAN STEIN. Thank you.
Are there any comments or questions?
(No response.)
i"IR. BOUCHARD. Thank you for your consideration,
Mr. Healy.
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149
Bertrand Bouchard
STATEMENT OF BERTRAND BOUCHARD, ALDERMAN
CITY OF NASHUA
CHAIRMAN, NASHUA RIVER WATER POLLUTION COMMITTEE
NASHUA, NEW HAMPSHIRE
MR. HEALY. Alderman Bertrand Bouchard.
ALDERMAN BOUCHARD. Thank you, Mr. Healy and
Chairman and ladies and gentlemen?
My name is Bertrand Bouchard. I am appearing here
as Chairman of the Nashua River Water Pollution Control
Commission and as Alderman of the city of Nashua and also,
if I may, as a citizen of the State, member of the Audubon
Society, family man, etc. In other words, as a person
interested in conservation, not simply as an expression
but as a pragmatic idea - something we have to put through
because we need it.
Now, just taking one second if I may because I am
not a pro at this — I do not have any objective data to
refer to — I, too, would like to point out why this problem
is so important to me. If I may just for one second
personalize here, I became interested many years ago in
water pollution because I take for granted by now a lot of
the pollution, for example, going on the Merrimack River
going through Nashua, because all my life I can remember
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Bertrand Bouchard
being told you should never go and bathe in the Merrimack
River because it was so dirty, and I am 40 years old. So
this has been going on for sometime.
However, as I say, a few years ago, I read the
Thoreau on boating in the Concord and Merrimack River,
and I read about the beautiful Merrimack River and about
his going through Nashua. I was really stunned by this,
because it seemed unbelievable that someone on his own
would go down the Concord and Merrimack Rivers and say it
is beautiful. You know, it is something that you just cannot
conceive of today.
So I think we have got to do something for preser-
vation and conservation of our resources and of our natural
beauty, and it is not easy. Therefore, I would like to urge
increased Federal participation. That is to say, 1) the
W--= •- .
Federal Government meeting its financial schedule of the
needed funding and 2) as pointed out by Alderman at large
Bouchard, the preceding speaker — we are both Bouchards
by the way — I would like to point out that I, too, share
100 percent his view for the need for State participation
through an adequate prefinancing program.
Thank you.
CHAIRMAN STEIN. Thank you, Mr. Bouchard. I do
not believe the statement that you are not a pro. Your
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151
Donald Ethier
sentiments about pollution control is just what it is all
about.
MR. HEALY. Alderman Donald Ethier, also from
Nashua.
STATEMENT OF DONALD L. ETHIER, ALDERMAN,
DISTRICT 1 OF NASHUA,
NASHUA, NEW HAMPSHIRE
ALDERMAN ETHIER. My name is Donald Ethier, Alderman
in the city of Nashua and the Ward 1 District, which is
basically to the far right of the yellow block all the way
to the Massachusetts line.
Now, I live in that district which smells. As you
come along the New Hampshire highway, the Route 3 bypass,
you know you are in my area when you go by a shopping center
9fi*
and you drive over the Nashua River because it stinks; it
is slimy and it is terrible. I am frank. That is the truth.
I wish I could push it away and say, "Please, problem go
away," but it is not going to go away very easily.
We are faced in Nashua with a very serious problem,
and it is one in which I ask the General Court, the Legisla-
tures, the Secretary of the Interior and this Committefe to
strongly urge that Federal funds be given to the State
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Donald Ethler
I look at it from the Nashua point of view, and
that is that our population has exploded from the I960
census to what we project in 1970 wherein our population
will increase approximately 30 percent. With this we have
experienced the problems of a 121-room school addition
every year, plus the additional classrooms for the other
schools, because in the outlying areas we are having a
tremendous growth; namely, in the Northwest part of the
city and the Soutwest part of the city.
Now, we have a budget of $11 million a year. We
are anticipating an outlay of approximately $25 million in
securing a loan in the next five years.
Now, with this we have our budgeted or anticipated
sewage treatment plant and the entire project is going
to cost us between $16 million and $20 million.
Gentlemen, the dollars have got to come from some-
where. In all honesty, I don't know where they are going
to come from.
Now, unless we get additional Federal aid and State
aid through maybe a prefinancing program, I do not know how
these projects are going to materialize.
Coupled with all of these, we have additional streets,
firemen and policemen and these are services that are expen-
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Donald Ethler
give. Along with the new schools we have the teachers
that you have to pay and we are all experiencing the
fact that teachers are looking for additional salaries.
Therefore, I ask all of you people who can do
your little effort to exert that effort and see that both
the State and additional Federal funds are made available
to the city of Nashua.
You people, wherever you come from, I am sure you
are here because you are sincerely interested and not because
you are looking for something to pass the time. It is a
serious problem and it is one that merits a lot of consider-
ation. We are doing this not only for ourselves, but,
hopefully, so that our children can benefit from this.
Therefore, I ask and humbly urge that everyone who
can do their little effort do so, so that we can seek a
good useful end to this entire program.
Thank you
CHAIRMAN STEIN. Thank you very much.
Are there any comments or questions?
(No response.)
•*
CHAIRMAN STEIN. I would like to make a comment to
all three. Someone has been following this rather closely
and found out that what we were doing through the years as
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Donald Ethier
compared to the attitude now, the contrast is tremendous.
Let's take, for example, the participation we had in the first
Federal conference on the Androscogan. As I have pointed that
out, the contrast is great, and whatever the differences we
may have had between State and Federal authorities in the early
cases have been the participation of municipal officials who
have increasingly become aware of the problem, come to grips
with it and given it some thought. This, in my opinion, is
really what has made the difference.
However, I would like to call your attention to
one fact that I see coming through here. You have heard
this again and again. As we keep talking, construction
costs keep rising inexorably. I remember we had a conference
in a rather large city In Indiana and they were battling
the State order. By the time they got through building
the plant, It cost them double the original estimate of
the contract. I am not deprecating anything about State or
Federal funds. Here Is the situation as I see it: Everyone
in the cities and the industries should realistically look
at what Is happening and determine when It might be best to
go forward. Too many times I have heard that we have to
have Federal financing; we have to have State financing; we
have to have State prefinancing. That all may be fine and
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155
Donald Calderwood
I cannot argue with it. But if you are going to wait and
keep shaking that tree until that public money comes down,
in the long run, it may cost you Just as much fighting the
rising-costs operation. Meanwhile you have lived your
lifetime with the State, as you said.
When you talk about the long run, I think The Lord
or Cain said, 'In the long run, we are all dead." In the
short run, however, we all must recognize the kind of
resources we have available and can reasonably expect, try
to set up a realistic time schedule and requirements and
get on with the programs, so that we can all do a little
better Job.
Are there any other questions or comments, Mr.
Healy?
MR. HEALY. Before we go to Mayor Mongan of
Manchester, there is one other gentleman here from Nashua
that we want to hear from briefly. He happens to be a
Commissioner of mine. He has been on the Commission
'ince its inception in 19^7* and that is Donald Calderwood
from the Pennichuck Water Works of Nashua.
STATEMENT OP DONALD C. CALDERWOOD, MEMBER
NEW HAMPSHIRE WATER SUPPLY AND POLLUTION CONTROL
COMMISSION, NASHUA, NEW HAMPSHIRE
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156
Donald Calderwood
MR. CALDERWOOD. Mr Chairman, conferees, ladies
and gentlemen, I believe that there is probably no one in
this room that appreciates clean water and wants it anymore
than I do. My main Job is to provide water for the city of
Nashua and its approximately 50,000 residents, and we are
also being asked at the present time, in fact they are
knocking on our door, for about three and a half million
gallons a day for an adjoining town. So with the problems
that go with such an operation, I think you realize that I
do know what clean water means.
To substantiate Mr. Bouchard's statement regarding
the tremendous growth in Nashua, the company I work for has
been in business for 116 years. During those years they
have spent a lot of money developing sources of supply,
building dams, distribution systems and reservoirs, etc.
But when you realize that within the last five years alone
that they have doubled their net in-plant investment or
had to double it to meet the demands, it shows you the
tremendous growth in the Nashua area alone.
Now, the next statement that I am going to make
probably will make me about as popular as a skunk at a
lawn party, but that is that I feel that rather than the
State going to prefinancing, the Federal Government should
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Donald Calderwood
meet Its obligations and come through with their portion
of the grant.
Now, this money that we get from the Federal
Government is not made by the wave of some magic wand. It
is your money and mine that goes to Washington, and they
send it back and let us use it.
I believe that if the State of New Hampshire is
willing — and they have proved that they are willing and
able to do their proportionate part of funding these projects;
the various communities are proving that they ar<=* willing,
able and want to do their proportionate part in getting
this cleaned up-I think it is only fair that the Federal
Government should take their part and "ome through with
their Federal grants and funds as needed to meet the demand.
It is quite possible that by a change in the
formulas or in some other way that these areas that are older
sections of the country and have these larger amounts
proportionately rather than population formula tnat is now
used could be changed in some way so that we could get a
greater portion for this particular area.
Thank you.
CHAIRMAN STEIN. Thank you, Mr. Calderwood.
I would like to take the opportunity to charade or
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158
Donald Calderwood
those comments. I do not mean to pick on you, but I
think we should at least make one statement for the record.
There has been a lot of talk from various partici-
pants about Federal obligation. I think most of you know
that there is a Federal appropriation and an authorization.
The fact that something is authorized does not mean it is
appropriated.
I do not think that the Congressional members, or
more particularly the members of the Appropriations Committee
would consider or be in complete agreement with that word
"obligation." This is not a contractural obligation. When
you have a contractural obligation, in effect, you have a
hunting license and you go out for it. If this were an
obligation and we had an appropriation in the Federal Govern-
ment for all the funds that were authorized it would probably
shake your teeth, and I am not sure how happy you would be in
New Hampshire or anywhere else.
So we have to recognize these limitations that we
have in the Congress as well as anyone else.
MR. CALDERWOOD. If I used the wrong word, I
apologize.
CHAIRMAN STEIN. No. No.
Let me make another point and I will make this clearly*
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159
Donald Calderwood
There is legislation coming up. As you know, it did not
pass in the last Session. Maybe you want to do a lot of
thinking on this, because we are limited in the Federal
funds in the way we can distribute the money according to
formulas specifically set out in the Federal formula.
Someone like me who has been observing the grants
field for, oh, practically a whole career, I would not say
that the Congress accepted the formulas which were Recommended.
You know when you recommend legislation every bright young
boy thinks he can put out better legislation than anyone
else. But there is a tendency, unless you get this formula
tempered by, l) population, 2) it seems to me financial need
and 3) the extent of the problem - and these things have to
be multiplied by each other.and not Just added on - you are
going to get areas where you have sort of inequitable distri-
bution. I don't want to get into the complicated grants
field.
Now, there are many areas in this country that they,
obviously, cannot use their grant funds — they have too much
allocation — because either they don't have the problem or
they have met it and maybe it is outside the continental
Umits, etc.
Now, this might be an idea: if what you people are
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160
Honorable John Mongan
saying about the kind of cut that you expect Vermont to get —
MR. CALDERWOOD. New Hampshire, please.
CHAIRMAN STEIN. New Hampshire. I am sorry. I
understand the thing, the statement that your sister State
may be getting too large a share of the pie compared to
you, that is why that stayed in my mind. But I think if
you are going to do that, you should pay very careful atten-
tion to the formula.
Now, I have one more tip on it on the basis of experience,
When any formula is reached, what you should do is have some-
one run it through the list of States and see what your cut
is going to be before you go along, because they can get very
complicated. I do think you have a point on that. Thank you.
MR. HEALY. Mayor John Mongan, Manchester.
STATEMENT OP JOHN C. MONGAN, MAYOR
MANCHESTER, NEW HAMPSHIRE
MAYOR MONGAN. We are the third layer of government
Involved here. The regulations are made by the other two
layers of government, and the position of the city of Man-
chester is quite simple: We will do what is expected of us
with the money available.
Now, there is no great incentive for Manchester to
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161
Honor Jab le John Mongan
invest its money in the Merrimack River. The area north
of the dam is the only recreational area, and it is very
interesting to read in the report that that is already safe
for body contact and sports such as swimming and water skiiing.
The river below the dam is downhill and it is quite rocky.
Whether the river is clean or dirty does not make much
difference, because you are never going to go boating in
that river anyhow. So it Just goes back to that it is for
the benefit of those downstream.
We wish to proceed with the engineering for our own
reasons. That the engineering involving the Merrimack Mill
Yard where we will have our retention basins, we want to
know exactly where those retention basins will go and what
size they will be. So Manchester is eager to proceed with
the engineering.
In that regard, we offer to refinance the total
engineering costs and found out from our Bond Council that
we could not finance it by bond financing. The other thing
was that Manchester had, in fact, bond financed engineering
and so had the town of Lincoln, and we are going to look
into that further to'dee what means they were able to do this.
In the meantime, we got down to contract negotiations
°? the engineering and it has become an impasse between the
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162
Honorable John Mongan
State and the engineering firm. The city of Manchester is
somewhat of a bystander here in that we feel that the State
being one of the signers to the contract should do the negotia-
ting, and with this impasse I would favor at this time that
the Federal Government or some other agency step in at the
request of both parties, I would hope, to help with the
negotiations. Then we will be able to get back to our problem
of prefinancing. I would hope that by the time that we get
to the problem of prefinancing the bill is already introduced
into the Legislature and that, perhaps, the State will pick
up the prefinancing and relieve us of the problem of about
whether we can legally or not bond the engineering.
Actually, the question of prefinancing the engineering
I do not think holds up in particular the schedule, as out-
lined here, when it comes to the construction. The time
for construction is still quite a ways away, and I would
hope by that time that the Vietnam war is over and that the
Federal funds come through on schedule.
Just one comment that I thought was quite interesting.
Mr. Urie made the statement — I do not know if it is
accurate or not — that the State would raise its share from
40 percent to 50 percent. The way we have it figured now,
we get 40 percent from the State and all the other benefits
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163
Honorable John Mongan
oeing in the regional plan and the Federal share being
55 percent, with Mr. Uries additional 10 percent we will
be making 5 percent. We are all for it.
CHAIRMAN STEIN. Are there any comments or
questions?
(No response.)
CHAIRMAN STEIN. You know, there is a favorite
Washington story about three fellows who went to lunch
and one fellow said, "You know, you better let me pick
up that check. I am in the 50 percent bracket." Another
guy reached over and said, "Oh, don't you pick it up."
He said, "You know, I am in the 90 percent bracket. It
will just cost me a dime on the dollar to pay this."
The third guy said, "Both of you fellows stop that. I
have a Cost Plus contract with the Government and I
will make six percent."
(Laughter.)
CHAIRMAN STEIN. Thank you.
MR. HEALY. The next man is a well known con-
servationist in the State of New Hampshire, John Dodge,
who was so helpful in the last session of the Legislature
in the advance of water pollution control. John.
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164
John Dodge
STATEMENT OF JOHN E. DODGE, COORDINATOR,
NEW HAMPSHIRE COMMITTEE FOR BETTER WATER,
CONCORD, NEW HAMPSHIRE
MR. DODGE. Mr. Chairman, conferees, ladies and
gentlemen, some of the remarks which I have prepared here
have been answered by Mr- Stein already, but I will still
read the prepared statement.
My name is John E. Dodge and I am a coordinator for
the New Hampshire Committee for Better Water. We are a
committee of the New Hampshire Natural Resources Council
and includes more than a dozen State-wide organizations,
a large number of local organizations such as conservation
commissions and planning boards and many others, and more
than 350 individuals. Actually, this amounts to reaching
many thousands of people of the nature of these State-wide
organizations with whom we correspond.
We attempt to serve as a two-way channel of communica-
tion between our members, on the one hand, and the Legislature,
the Congress and appropriate departments of State and Federal
Government on tne other.
The Committee for Better Water has consistently
supported and continues to support the standards for water
quality and program for pollution abatement recommended by
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165
John Dodge
our Water Supply and Pollution Control Commission, and
enacted by our Legislature in the last session as Senate
Bill No. 83. We have gone along with the commitments made
by this Commission and by the State's administration to
seek specific additional legislation in the 1969 session to
further tighten and advance the control program on the
Merrimack watershed. Our Steering Committee has agreed to
support the principle of State prefinancing for secondary
treatment plants where these will be required.
As I have said, we try to listen to both sides and
to be realistic in our recommendations. We feel that any
attempt to go faster than the program of abatement endorsed
by out Commission would bommerang, unless and until there
is a substantial increase in Federal funding.
We believe that it should not only live up to the
commitments originally endorsed by the Congress, but it
should give New Hampshire parity with her sister State,
Vermont, in terms of Federal dollars provided for the work
each has to do to accomplish her approved program.
Our Legislature has a fine record of supporting an
orderly series of steps toward pollution abatement, but
there are limits beyond which it cannot be expected to go
this year. To attempt to exceed these might well result in
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166
John Dodge
no increase at all in the coming session.
Thank you very much.
CHAIRMAN STEIN. Are there any comments or questions?
(No response.)
CHAIRMAN STEIN. If not, thank you very much.
MR. HEALY Before we go to the next person who
wants to speak, I merely want to identify my most recent
Commissioner, Mr. Richard Buck of Hancock and who has now
been appointed to the Commission within the last few days
to represent the vacation home or private recreation sector
of our economy. Mr. Buck also is identified with conserva-
tion activities. He is well informed in the field. He is
associated with Trout Unlimited and a number of other worthy
enterprises, and we are very fortunate, we believe, to have
him with us.
Will you simply stand up so they can see you.
(Commissioner Buck arose.)
MR. HEALY. The next individual I would like to
ask to come forward is Vice President and Chief Engineer
of the Public Service Company of New Hampshire, Eliot
Priest. His firm has been doing, as he will expand and
tell us in greater detail, a great deal of work in the
field of thermal pollution activities.
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167
Eliot Priest
STATEMENT OP ELIOT PRIEST, VICE PRESIDENT
AND CHIEF ENGINEER
PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE
MANCHESTER, NEW HAMPSHIRE
MR. PRIEST: Thank you.
Mr. Chairman, members of the Conference, ladies and
gentlemen, my name is Eliot Priest and I am Vice President
of Public Service Company of New Hampshire. I am responsible
for the Company's Engineering projects, both from a standpoint
of planning and of construction. I appear before you
today because natural resources such as the Merrimack
River are an integral part of a utility's engineering
projects.
Before speaking with you about the river, however,
I believe this agency should know a little about Public
Service. Basically, the Company generates, transmits
and distributes electric power for nearly 200 New Hampshire
communities. In addition, we provide electricity at
wholesale for resale to several other electric companies
and agencies in New Hampshire. In total, we furnish
electric power to more than 200,000 homes and businesses,
°r about 90 percent of the Granite State. Obviously, we
have tremendous responsibility to those dependent upon us
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Eliot Priest
for their electricity and we make every effort to provide
them with the best possible service.
It follows, then, that Public Service has a vital
interest in the subject of this public hearing, not only
because the Company has thermal and hydro generating plants
on the Merrimack River, but also because the Company believes
that an orderly abatement of misuse of the river is in the
best interest of the public. Only when this has been
accomplished can the river serve the majority of the citizens
of New Hampshire. We further believe that only with the
cooperation of all users of the river will its value as a
natural resource to meet the needs of modern society be
maintained. By this we mean that all uses of this natural
water resource must be evaluated in terms of the total needs
of the State citizens and industries.
The river serves many purposes. For Public Service
it provides electric energy to meet the ever-increasing
demand for electric power in New Hampshire. The Company has
three hydro plants along the Merrimack located at Garvins
Falls near Concord, Hooksett and Amoskeag Falls in Manchester.
It also provides a source of cooling water for the stream
condensers for two thermal generating units at the Merrimack
Station in Bow, and one in Manchester.
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Eliot Priest
The basic point of discussion that we wish to bring
before this hearing has to do with the release of heat to
the river as a result of passing cooling water through the
thermal plants known as Merrimack I and Merrimack II in Bow.
The first unit at this station was constructed in
the period 1957 through I960 and placed in service in late
I960. Its rating of 120,000 kilowatts requires that approxi-
mately 59»000 gallons of water per minute pass through the
condenser with a temperature rise through the condenser of
20 degrees to 25 degrees Fahrenheit. In 1964 it was decided
to erect a 350,000 kilowatt unit at this site known as
MK-II which, when operating at full load, would pass about
140,000 gallons per minute through the condenser with a
similar temperature rise.
In discussions held with the New Hampshire Water
Pollution Commission and the New Hampshire Fish and Game
Department in 1965, it was pointed out by them that an
adverse effect might take place by releasing this heated
water to the river. After several conferences, it was
decided that neither the New Hampshire Water Pollution
Commission nor the New Hampshire Fish and Game Department
had sufficient data to know whether the release of the
heat to the river would be detrimental. As a result, it
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Eliot Priest
was decided to undertake a joint study of the river ecology
by the two State groups and Public Service. Public Service
retained the Institute for Research and Services at St.
Anselm's College to assist in making the study and for inter-
pretation of its results.
The plans were formulated so that actual field data
would be gathered during the summer and fall of 1967 using
the heat as released by MK-I, which had been operating since
I960 without any apparent adverse effect on the river, as a
natural laboratory. It was agreed that all data collected
would be made available for review and interpretation by
all participants. The New Hampshire Fish and Game Deparment
assigned a biologist to the job on a full-time basis during
the months the study was in progress. They also provided
the necessary boats and other miscellaneous equipment
required for taking an in-depth population and specie study
of the fish in the river- Public Service provided all
other manpower, which included five summer students, a
supervisor and staff of the Institute for Research and
Services assigned to the project. In addition, Public
Service supplied nets for catching fish, and metering and
sensing equipment for measuring temperature, dissolved
oxygen and many other organic and chemical parameters.
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Eliot Priest
A repeat of the study of 196? was made during 1963
inasmuch as MK-II, the second unit, was placed in service
in May of this year.
To provide continuous monitoring, Geodyne digitizing
equipment was installed to provide temperature and dissolved
oxygen readings on a 24-hour basis. Readings were recorded
every 30 minutes at a station located above the intake to
the plant, one at the point of discharge into the river and
another two to three miles downstream. Supplementing this
data, spot readings were taken to completely profile the
river. Complete chemical and biological samples were taken
each of the two years to determine the complete ecology of
the river.
?i
The total investment for both labor and materials
to date by Public Service is $92,900. In addition, several
thousands of dollars have been expended by the State, making
a total cost of the project to date at least $100,000.
To explain in detail the vast coverage of the study
would take too much time; however, several points can be
'Hade at this hearing that are extremely important and
should be considered:.
1. This study is the most comprehensive study ever
performed on the Merrimack River, and no definite
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Eliot Priest
conclusions by the Interstate, Federal, or State
Commissions should be drawn without careful review
of this data.
2. The study covers many aspects of the river other
than thermal, and these are of extreme importance.
3. The study can be of significant use in evaluating
other rivers having similar characteristics.
4. The data collected has not been fully analyzed
and no conclusions as to the effects of heat
release upon a river should be drawn without full
analysis of this large amount of data.
5. For study purposes, the river had an excellent
flow pattern during 196S. Both high and low flows
were experienced as well as very high, ambient
temperatures. It might be added that the river in
its natural state had temperatures as high as #3
degrees to #4 degrees Fahrenheit thereby clearly
establishing it as a warm-water fishery. This" was:
fully supported by the fish catch conducted by the
New Hampshire Fish and Game Department. Over 15,000
fish were caught and tabulated over the past two
years, and the species caught clearly established
the river as a warm-water fishery.
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Eliot Priest
6. It becomes rather apparent that arbitrary standards
can severely penalize users of the river. Much
has been written about allowable temperature rises
and mixing zones. This study can demonstrate that
there is no such thing as a mixing zone in a free
flowing river unless mixing is forced in some
manner. This one point is of sufficient significance
to indicate that careful consideration must be given
to all data collected before valid basic conclusions
can be drawn.
Public Service Company of New Hampshire, as stated
earlier, is interested in and committed to the proper
development of the State natural resources. However, the
Company believes strongly in basing controls and criteria on
facts, as demonstrated by the Companyfs willingness to
expend large sums of money to obtain the facts. It stands
prepared to spend additional funds to reduce the effect of
heat upon the river if, after careful study, it can be
determined that such discharge does cause a change in the
river to the degree that it prevents other desirable uses
of the river. It agrees with the New Hampshire agencies
responsible for the riverfs control that if the Merrimack
by some means can support Atlantic salmon, shad, or cold
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Eliot Priest
water trout, it will take whatever steps are required to
reduce the effect of the heat released to the river so
that these uses can go forward.
In essence, we request that final conclusions
pertaining to thermal releases be held up pending the
full review of the vast amount of data collected. We
specifically wish to reserve the right to file a copy of
our Findings with your agency to be incorporated as part
of this statement. We believe this work can be completed
within six months.
Thank you very much.
CHAIRMAN STEIN. Thank you, Mr. Priest. You know,
I knew that would come up sooner or later. I knew this
question would come up sooner or later. I guess what
Mr. Priest is proposing is that we put monitors on the
Merrimack before we come up with ironclad requirements.
(the above-mentioned Findings, to be furnished
for the record, will be marked Exhibit 2 and be on file
at the Northeast Regional Office and FWPCA Office,
Washington, B.C.)
Any questions or comments?
MR. KLASHMAN. Mr. Priest, what was the temperature
that you said - the temperature rise?
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John Henchey
MR. PRIEST. We actually said that the actual
ambient temperature, meaning the natural state of the
river, was as high as S3 or 64 at the highest point.
MR. KLASHMAN. Going through the condensers?
MR. PRIEST. Twenty to 23 degrees rise in the
condensers.
CHAIRMAN STEIN. Any other comments or questions?
(No response.)
CHAIRMAN STEIN. Thank you very much.
MR. HEALY. We are approaching the end of the
New Hampshire people that wish to make a statement. There
are just two more.
The first one is Mr. John Henchey, the City
Manager for Concord.
STATEMENT OF JOHN E. HENCHEY, CITY MANAGER,
CONCORD, NEW HAMPSHIRE
MR. HENCHEY. Mr. Chairman and members of the
Conference, this statement is quite brief and I think it
does clearly state our feeling in regard to the water
pollution and the abatement of pollution in the Merrimack
*
River and in Concord.
The city of Concord is, and has for some time, been
aware and concerned about the pollution of the
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John Henchey
Merrimack River. Presently Concord expects to sign
an agreement with the town of Boscawen which would encompass
planning and eventual construction of a $3 million
sewage treatment facility in the Penacook area of Concord.
In fact, the city of Concord has already entered into an
agreement with its consultants for the plans and specifica-
tions of'this plant pending the signing of an agreement
between the two communities.
With the availability of State and Federal funds
Concord and Boscawen are prepared to move forward immediately
with this project. Once this Concord-Boscawen treatment
facility has been funded to the extent that the State and
Federal programs now provide, Concord would be in a position
and would be willing to have the plans and specifications
for the $£ million main Concord sewage treatment
facility drawn up and submitted for approval to the necessary
agencies.with the completion and approval of these plans and
specifications, Concord will be prepared to enter into the
construction phase of this second and final project when
State and Federal funds are made available.
At the risk of being repetitious, I would like to
reiterate that implementation of the $11 million sewage
abatement program depends on the availability of State and
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Mrs. Selwyn Taylor
Federal funds.
In addition to this, I would like to say two things:
First, I think Concord is fully aware of the fact
that primary treatment is most essential and would like
to have secondary treatment set off until such time as
primary treatment was completed on most of its streams.
Secondly, I have already projected this cost to
$11 million when completed, and had we been in position to
construct these facilities a year or two ago the cost would
have only been .$£ million.
Thank you.
MR. KLASHMAN. $11 million is now for secondary
treatment?
MR. HENCHEY. It would be proposed for both forms
of treatment, yes. I could stand to be corrected.
MR. KLASHMAN. I think that is correct. Thank you.
MR. HEALY. The last speaker that I am aware of is
Mrs. Selwyn Taylor of Nashua who speaks for the League of
Women Voters and who has also been, in previous legislative
sessions, very much interested in pollution control.
STATEMENT OF MRS. SELWYN TAYLOR, CHAIRMAN,
* .
* . ™
*
WATER RESOURCES COMMITTEE,
LEAGUE OF WOMEN VOTERS OF NEW HAMPSHIRE,
NASHUA, NEW HAMPSHIRE
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Mrs. Selwyn Taylor
MRS. TAYLOR. Mr. Chairman, members of the United
States Department of the Interior, the New England Interstate
Water Pollution Control Commission, the Massachusetts
Department of Natural Resources and the New Hampshire Water
Supply and Pollution Control Commission, I am Mrs. Selwyn
Taylor, Chairman of the Water Resources Committee of the
League of Women Voters of New Hampshire.
We wish to thank Mr.Healy for the invitation to be
here today to express some of our views on the pollution
abatement program for the Nashua and the Merrimack Rivers.
For some time now, the League of Women Voters of
New Hampshire has been concerned about the condition of the
Merrimack and Nashua Rivers. We believe it is evident from
the testimony at the hearings on the subject of pollution
in our State that the people of New Hampshire want to be
able to use the waters in these rivers for various recreational
pursuits.
For the most part, the League feels that water
quality standards as proposed by the New Hampshire Water
Supply and Pollution Control Commission and approved by the
1967 New Hampshire Legislature show consideration of the
expressed desires of those people who are concerned with
obtaining the highest quality water to allow maximum use of
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Mrs. Selwyn Taylor
the rivers. There are a few areas where the League would
have liked to see higher standards set. However, we feel
that for the present the goals are realistically attainable.
We shall hope to have an opportunity In the future to work
toward further improvement in these areas.
Nashua, for instance, has indicated that they
would like to create a recreation area along part, of the
Nashua River and would like to be able to permit swimming
in this area at some future date. We understand that this
will require higher quality standards of water in the Nashua
River from Massachusetts and also possibly further treatment
than planned at Nashua. We believe that in order to attain
the standards presently set for the Merrimack River it is
imperative that there be secondary treatment in the larger
communities. We feel that planning of secondary treatment
facilities, and construction wherever feasible, should be
done simultaneously with the work on the primary facilities.
This should be more economical in planning costs and, with
the rising costs of construction, there should be considerable
savings over the long term by completing the task as quickly
as possible.
Financing, it seems, is the biggest factor looming
behind the reluctance of some of the New Hampshire communities
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Mrs. Selwyn Taylor
to proceed as quickly as they should toward adequate
waste treatment. It is extremely unfortunate that Just
at the time when New Hampshire communities were ready to
proceed with pollution abatement Federal funds for the
purpose were so very limited. It is also unfortunate
that the demands for services — for example, funds — in
most areas at the State level seem to far exceed antici-
pated revenues. However, we think that the 19&9 New
Hampshire Legislature, when faced with the reality of
the situation as regards the needs for pollution abatement
funds, will certainly approve prefinancing at the State
level to allow New Hampshire to proceed more quickly
toward completion of its abatement program. We believe
that the funds to do the Job can oe found. They have been
found in other states.
The Pollution Con^-nol Commission in our State has
accomplished much, hampered by two major obstacles: the
lack of both State and Federal funds and also the slowness
of many communities in getting on with the task.
The State contribution is 40 percent towards construc-
tion costs of approved municipal waste treatment plants. We
feel this is very generous.
Coupled with the Federal share of 40 to 50 percent,
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Mrs. Selwyn Taylor
the burden on the communities is considerably less than in
many other States. But the actual amounts appropriated at
the Federal and State level are not sufficient to enable
all communities to proceed with construction. Thus^there
has been no great pressure on the communities to move quickly.
Our Pollution Control Commission is also hampered by the lack
of State funds for adequate personnel to do the State share
of the task. The communities, too, seem reluctant to commit
themselves to a large expenditure of money.
The solution to these problems has been to spread
construction and costs over several years as funds can be
expected to be available. The League feels that the urgency
of the problem requires a more rapid solution.
New Hampshire has been faced with the problems of
pollution as long as other States. It is embarrassing that
ourt plans to alleviate the problems lag so far behind.
With a prefinancing plan to provide the Federal
share of funds to the community until such time as Federal
funds are available for reimbursement, which we surely hope
is soon, and with adequate funds appropriated now for the
State share of the costs, we think New Hampshire could expect
•
cooperation from the communities towards real progress
an early date. Communities with serious financial problems
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Mrs. Selwyn Taylor
could request further assistance from their Industries to
ease the burden. They should certainly expect their industries
to pay their share of the costs they create.
The people of New Hampshire have indicated that they
want the Merrimack and New Hampshire rivers cleaned up quickly.
Massachusetts people have demonstrated that they Intend to do
their share. We feel New Hampshire has a clear duty to do its
share at a faster pace than originally planned. The Job needs
to be done and done quickly. We feel New Hampshire can find
the means to do it at the State and local level.
If the cities of Lawrence and Lowell on the Merrimack
in Massachusetts can find the means to complete their task in
1973, it would certainly seem that any New Hampshire city on
the Merrimack could find the means to move faster than planned
to meet the required standards. We would think that the two
Massachusetts cities would have a legitimate complaint at
completing their construction yet having to receive New
Hampshire wastes for several additional years. Their uses
of the river would be limited for a longer period of time in
spite of their own efforts.
Our task in New Hampshire seems to be to speed
construction with prefinancing and more State funds now to
give our Pollution Control Commission the means to urge local
communities to comply. We urge full commitment at the State
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Donald Calderwood
level. We feel this commitment can be met. Pull Federal
funding Is also needed urgently and we look forward to
considerable Increases In Federal appropriations In the
future.
We are confident that New Hampshire will accept Its
responsibilities to the people of neighboring communities and
to its own people by providing the means and the plans to
attain suitable standards at an early date.
Thank you.
CHAIRMAN STEIN. Thank you, Mrs. Taylor, for a very
excellent and comprehensive statement.
MRS. TAYLOR. Thank you.
CHAIRMAN STEIN. Are there any comments or questions?
(No comment.)
CHAIRMAN STEIN. If not, thank you.
Would you come up and let us have your name for the
Reporter.
STATEMENT OF DONALD C. CALDERWOOD, MEMBER,
NEW HAMPSHIRE WATER SUPPLY AND POLLUTION
CONTROL COMMISSION,
*
NASHUA, NEW HAMPSHIRE
MR. CALDERWOOD. Donald Calderwood of Nashua. As a
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Sheldon Merrill
member of the Nashua Water Supply and Control Pollution
Commission, I think we should recognize the fact that New
Hampshire can hold its head high among other States as far
as the Commission is concerned and the progress it has made
during the some 20 years it has been in existence. I do
not wish to take issue with my fellow townsman regarding
her statement, but if I understood her remarks correctly, I
obtained the inrerence, at least, that New Hampshire was
lagging behind other states. If I am in error, I apologize.
If I am not, I would like to have the statement corrected.
MRS. TAYLOR. I was referring to time rather than
money.
MR. HEALY. Are there any others from New Hampshire
that would like to offer some remarks?
STATEMENT OP SHELDON MORRILL, CITY COUNCIL,
FRANKLIN, NEW HAMPSHIRE
COUNCILMAN MORRILL. My name is Sheldon Morrill.
I am a Councilman from the city of Franklin.
It is a city at the confluence of the Pemlgewasset
and Wlnnipesaukee, a city of about several thousand population,
The city of Franklin saw fit to meet their obligation
when this Clean Water Act and State legislation was passed.
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Sheldon Morrill
We have gone ahead and have a final planning and engineering
completed at this date. The city is waiting at this time
for the necessary funds from the State and Federal Government.
Now, once you have sold the people of a city on a
program, whether the Federal Government is obligated or not
to these funds, the people have been sold that the Federal
Government has certain participation and the State has a
certain participation. The city has gone ahead and met their
obligations, and then the program is set on a table and it is
laying dormant.
So now the city officials, as they are re-elected,
had i. go back and resell their community on their obligations
over and over again, whether the Federal Government is obligated
or otherwise.
I think that the Federal representatives here see
the problem that the city officials have by letting these
Programs lay dormant. The time to act is when the Initial
Program is incorporated, State and Federal, and get the people
Interested and go along. We have done this in Lincoln and now
the interest is to let's stay there anc1 wait and see what
happens to this Federal funding.
CHAIRMAN STEIN. Are there any comments or questions?
(No response.)
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186
Sheldon Morrill
f-
CHAIRMAN STEIN. Are there any others?
MR. HEALY. No, sir.
MR. KLASHMAN. Could I ask you, Mr. Morrill, the
grant that you are talking about, the funding, is that a
H.U.D. project that you are talking about?
COUNCILMAN MORRILL. No. This is a regular water
pollution grant.
MR. HEALY. No. 66l?
COUNCILMAN MORRILL. Yes.
MR. HEALY. Clarence can tell you, if you want to
know, the details of Just what has transpired at Franklin
and when it may be financed under certain circumstances. I
know they have completed their planning.
MR. METCALP. I think this is not going to be this
next year but the year after. I believe it is in 1970.
CHAIRMAN STEIN. Is that a State priority?
MR. METCALP. Yes; that is, our priority which we
have established.
CHAIRMAN STEIN. I repognlze your problem and your
remarks are very pertinent. However, again, we do have this
provision in the Federal law and this is one that I think is
a good one. The priority for going with the project rests
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Sheldon Morrill
with the State. Like many other things, you may look for a
panacea if you want from the Federal Government, but the best
way that we can really set the priority is have the States
and localities within that State work it out themselves.
Now, as far as I know, the New Hampshire priority
system is a completely equitable one. Again, looking at the
other programs throughout the country, obviously — and this
would deal with any program, and I want to make this clear —
unless we had all the money in the world, if you have more
applications than there are moneys available, someone is going
to have to set the priority. This is something we Just have
to really live with.
With that, let us recess for lunch and let us try
to be back at two o'clock.
(Whereupon the Conference recessed until 2:00 p.m.)
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188
AFTERNOON SESSION
CHAIRMAN STEIN. Let us reconvene.
May we call upon Massachusetts. Mr. McMahon.
STATEMENT OP THOMAS McMAHON, DIRECTOR,
WATER POLLUTION CONTROL,
MASSACHUSETTS WATER RESOURCES COMMISSION,
DEPARTMENT OP NATURAL RESOURCES
BOSTON, MASSACHUSETTS
MR. McMAHON. Mr. Chairman, the Massachusetts
presentation, with your permission, will be two different
categories. I will begin and Mr. Cassaza, Supervising
Engineer, will follow.
Mr. Chairman, ladies and gentlemen. My name is
Thomas McMahon. I am Director of the Water Pollution
Control, under the Massachusetts Water Resources Commission,
in the Department of Natural Resources. Our agency was
created under Chapter 685 of the Acts of 1966 with the
responsibility of enhancing the quality and value of the
water resources of the Commonwealth and to establish a program
for the prevention, control and abatement of water pollution.
Three companion pieces of legislation provided for a
State bond issue of $150 million to assist cities, towns and
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Thomas McMahon
districts in the construction of waste treatment facilities
and two tax inducement provisions for industries construc-
ting their own treatment works.
Since the passage of these Acts, Massachusetts has
adopted standards of water quality in all interstate, intrastate
and coastal and marine waters. The interstate portions have
been approved by the Federal Department of the Interior, thus
making these Federal standards as well as State and providing
to this State the maximum Federal grant percentages on
eligible projects throughout the Commonwealth.
An implementation schedule for corrective action has
been established for some 230 industries and 130 communities
within the State, and Letters of Intent indicating willingness
to comply have been received from 95 percent of those contacted.
The total estimated price tag on a Statewide basis is estimated
at $1/2 billion with approximately one-half to be cost-shared
by the Federal Government, one-quarter by the State and the
remaining one-quarter by local financing.
During the past fiscal year, Chapter 21 of General
Laws, which encompass the previously referred to Acts of 1966,
was amended by Chapter 873 of Acts of 1967 and Chapters
611 and 648 of the Acts of 1968. The major features of these
amendments are as follows:
1. Clarifying amendments to allow the Division to
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190
Thomas McMahon
Give construction grants to cities, towns' and districts from
the $150 million bond issue authorized in 1966.
2. A prefinancing clause to allow the State to
advance moneys to cities, towns and districts in anticipation
of future Federal reimbursements and to advance up to 7
percent of .the total estimated construction cost of eligible
projects for the preparation of final plans and specifications.
3. An oil pollution control act to permit this
Division to contract with private organizations to clean up
oil spills on an emergency basis, to issue rules and regula-
tions for protection of the Commonwealth waters, to license
all oil terminals and to establish a permit system for waste
oil collectors.
4. A scholarship and intern program to attract
outstanding high school graduates into the field of Sanitary
Engineering. This Act provides free room, board and tuition
to candidates who will work summers for the Division and to be
employed for three years with the Division upon graduation.
Prom January 1968 to June of 1968 the Division has
obligated the authorized maximum of $15 million for State
grants in aid to communities and districts including the
prefinancing of some $4 million of State funds in anticipation
of future Federal reimbursements. It is anticipated that this
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Thomas McMahon
will continue in this fiscal year without materially affecting
the implementation schedules for corrective action throughout
•
the Statfe. Nevertheless in looking toward the future, if
federal cutbacks in grant appropriations are continued
beyond the current and next fiscal year, the Massachusetts
program, as well as many other States programs, will more
than likely be slowed down.
This statement is based on an elementary mathematical
analysis of the costs involved in our Implementation program
which features a number of major projects coming'due in the
next two or three years. We have communities such as Lowell,
Lawrence, the Greater Pitchburg area, Worcester and other South
Essex sewerage districts, many of these projects ranging any-
where from $16 to $18 million apiece up to $30 million.
The State is limited to expending only $15 million in
one year, so it is fairly simple from a mathematical basis
to understand that we will need additional Federal moneys. It
may well even be necessary that we will have to go back to our
own Legislature for additional grants funds.
We can preflnance. As you can well imagine, when you
» V
get into $30 million projects, the prefinancing clause will wipe
out in one project the entire money allotted for one particular
year.
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Thomas McMahon
Much has been said here today on the lack of Federal
funds. I would like to make one point clear insofar as
Massachusetts is concerned. We are insisting that all
municipalities and industries, regardless of the anticipated
shortage of Federal and State funds, go all the way through
the preliminary planning stage and also the final plans.
Remember if they have accomplished this and it comes to pass
there is not State or Federal money available, that is some-
thing else. But, in our opinion, there is no excuse for
anybody not going right through the final planning stage in
municipalities. Of course, we finance the 70 percent of
the plans and specifications as well.
Regarding the Merrimack River Basin, on the Merrimack
we have established a schedule for 14 municipalities, 38
Industries, 1 miscellaneous, for a total of 53. Out of this
total of 53* ^5 have indicated they will comply, 36 are
presently on schedule, 2 are under Consent Orders and 1 Is
under an order.
Under the Nashua River the schedule includes 2
municipalities, 23 industries, 1 miscellaneous and a total
of 26. Nineteen of these intend to comply, 23 are on
schedule and 2 are presently under Consent Orders.
Consent Orders, just for a brief explanation, the
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Thomas McMahon
civil portion of our law requires that prior to issuing an
administrative order we have to hold what we call an
adjudicatory hearing. This, many times, can be somewhat
cumbersome, so we invite the polluter in and have a pre-
hearing conference upon presentation of evidence that
indicates that theyjare polluting.
Now, we request them to sign what we call a Consent
to Order or Consent Decree.
What this essentially does is waive the right to a
public hearing by the particular polluter and has essentially
the same effect as holding the hearing by the issuance of
an \dministratlve Order.
In conclusion, I would like to emphasize that
Massachusetts has an on-going progressive program of
r •• '-. -
financing and enforcing water pollution control on a State-
wide basis. It is a program to enhance the quality of water
Mcnin our own State and to render waters flowing into
neighboring States of a quality satisfactory to the agreed-
wpon classifications of the signatory States and approved by
the New England Interstate Water Pollution Control Compact.
It is Important that the progress and momentum of
the past two years be amplified In the years to come in order
to provide the necessary water quality improvements reflected
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194
John Cassaza
•
in our standards of water quality goals and needed so
badly by future generations.
Thank you.
CHAIRMAN STEIN. Thank you, Mr. McMahon.
Are there any comments or statements?
MR. McMAHON. Mr. Chairman, I might suggest letting
Mr. Cassaza go ahead with the second part of our presentation
Then we will be happy to answer any questions.
MR. KLASHMAN. I would like to wait until Mr.
Cassaza is done.
STATEMENT OP JOHN B. CASSAZA
SUPERVISORY SANITARY ENGINEER
DIVISION OP WATER POLLUTION CONTROL
MASSACHUSETTS DEPARTMENT OP NATURAL RESOURCES
BOSTON, MASSACHUSETTS
MR. CASSAZA. Mr. Chairman, I am John Cassaza
from the Division of Water Pollution Control in the State
of Massachusetts.
I have here the Implementation Schedule for the
Merrimack River and for the Nashua River. I would like
to submit this schedule to the Commission as If read. I
would further like to make certain comments on this schedule.
(the above-mentioned schedule follows.)
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-------
MASSACHUSETTS DIVISION OF WATER POLLUTION CONTROL
196
MERRIMACK
/ -J. • _/ x /
J~ocQT/cr> p AS0s??e
LOWELL
Municipal - Proiect ^1
Municipal - Proiect #2
Ames Textile Corp.
Byfield
Fel ting
Commodore Foods
United
Conant B
a J a stic Corp.
oughton Div.
Jean Alan Products
Lawrence Mfg. Co.
Middlesex Worsted Spinning
Pell on Corp.
Robinson
Suffolk
Vert i pie
Top Yarn & Dye Work
Knitting
Inc.
. MERRIMAC
Municipal
Merrimac
METHUEN
Metal Finishing
Municipal - Proiect ffi]
Municipal - Project #2
Essex Chrome Plating
Methuen International liin s
Rex Potato Chip
NEWBURYPORT
Municipal
NORTH ANDOVER
Municipal
Western Electric
Wipex. Inc.
SALISBURY
Municipal
Salisbury
TYNGSBORO
Municipal
Water Co.
W3STFORD (Force Village}
Murray Printing Co.
'fflfi/cjrttrf/CwtoiA £-/9^&f^L/*f*tt
\^C,f? f Cfi//£
rrW
!
/?o£/
-&J/8
'*£%'
Pa£.
*tffi>//'CC(fi/30/6
6/6P
12/6c
2
tef
JcW
12/68
12/68
3/69
19/6*
9/67
12/69
12/6?
1.0/31 1
7/67
3/7n
/#c/
a9
ft£#
5d
-------
MASSACHUSETTS DIVISION OF WVTOR POTT.UTTON CONTROT
197
MERRIMACF.
(£jg
&*»''d.
'
SSWBUKXPORT
The Chase Shawmut Co.
3/69
5/70
Tow1 e Silversmiths
3/69
t/6?
"" 0/6<
5/70
SALISBURY
.iT'en Drive Subdivision
5/69
6/69
e/69
-------
MASSACHUSETTS DIVISION OF WATER POLLUTION CONTROL
198
NASHUA
y
FITCHBURG
I.unicj •y-i"1
F-J."" u"1 ih Pa oer
Fitchburr P'ivjer
Simons S.iw c Stee"1
Wey firh'-user-Crocl-- er Burbink
GROTON
Groton Tieatherboard
Hoi -i ingsworth i, Vose
L.iNOiST3R
Atlantic Union College
T 30MINSTER
Borden Inc.
Foster Grant
PMPPERELL
Municipal
Bemis Company, Inc.
St. Regis Paper
FITCHBURG
Great .unerican Plastic Corp.
The Jennisen Company
Art Photo Service, Inc.
Fitchburg Gas L Light Co.
Hedstrom Associates
Vogue Wan Coverings, Inc.
Iver Johnson Co.
Wachusett Potato Chip Co.
Independent Lock Co. (II .CO Coi
LUXEMBURG
Rogers Brothers
WSSTMINST3R
The Old Mil"1 Restaurant
Advance Coatinpq Tnr»
Decotone Products i)iv.r
Fitchburg Paper Co.
^
Jr*>/
P)
~g
/>&£/
fity&ce/re'f/
Dak
^*/tc,Te0
AfCUHt
Pah
fyfi/
/&
-------
MASSACHUSETTS DIVISION OF WATER POLLUTION CONTROL
199
CONCORD
(Inc1 . .issabet £ Sudbury)
l~OCQT/cs? ^ /v£7s??e
.,CTO;<
liunici -lai
.iSHT,ANi)
iMyanza Chfimc.il Co.
BITT-SRICx
Municipal
(Corenco Corp. )T.oweii Renderinp
North Bi"1 n erica Coimariv
FRU-il-JGHA-.:
General kotors
1-iunicioa"1
Roxbury Carpet
kiYfl*RJ
l-'unicipai
Digital I-jauio. Com.
NORTH BFJ iRlUA
Taibot :ii-ns
MORTHBCROUGH
Jluniciv.i
Machinery rPectrifi cation
I.awrence Candi e Co .
HU.JS03
liunici i:ii
i-L-.RT.BORO
i-iunicipa-' ('.'esteriy STP)
r/TM/e*
•~>C-A
Jt*»/
7$
flck/
«t
y
»ce/vt*j*
0a^
^
A/aMt
tee/"
Pab
fy#
£#
g/TDIs'd
*£
ScJ)
12/61;
3/70
3/70
3/70
•"2/67
5/68
3/72
3/72
6/6?
r//Kr^
'&**
$K
cr n.
Jc/ft/
6/70
5/70
4/6P
6/69
5/72
O/ff
*£
fat-
$»
sji#j.
7/70
10/6F
'•£
/5tX
/7J7G
&a*
JcAtd
2/71
7/68
3/71
3/71
3/7T
7/&
n/6f
n/6^
2/70
3/73
3/73
3/73
2/6c
7/6?
y
tr
fld.
*
Sc
JtJd.
A/71
?/6
5/71
5/7^
5/7"1
f/6f
4/69
4/69
4/70
5/73
5/73
5/73
4/6<-
9/6F
^,
/*•/
£*WJ
3dlU!/
/,/72
•«/6c
5/72
5/72
5/72
4/69
1 0/69
1 0/69
4/71
5/7/,
5/74
5/74
""0/69
iQ/60
Uy£<
'rAff
&/••
&»**£>
No inunici-ial sTrstem
,
I-' 3 n i ei osed
-------
200
John Cassaza
These schedules, or the dates that we have es-
tablished in this schedule, are, to all intents and purposes*
the same dates that we have submitted to Secretary Udall
back in 1967.
In addition to the dates and the Industries and
municipalities which we listed In that original submission,
we have Included in this plan and schedule additional
relevant sources of pollution.
During the last year we have been able to disclose
in these two river valleys in the case and on Sheet 1
MR. KLASHMAN. Excuse me.
Mr. Stein, I just wanted to clarify something in my
own mind.
Mr. Cassaza, as I understand it, these sheets are
the dates that were submitted to the Secretary and approved
by him, and then what you are going to point out now are
those dates where there have been minor adjustments proposed
by you?
MR. CASSAZA. Or additions to the schedule.
MR. KLASHMAN. And these are things that you are
going to point out that differ from the schedule as approved
by the Secretary?
MR. CASSAZA. Right.
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201
John Cassaza
In the case of the town of Dracut, you will note
on this sheet that the J. P. Stevens Company has been deleted,
This deletion should not be made and the dates listed here
stand as solicited.
MR. KLASHMAN. These are the dates that were made on
the original plan?
MR. CASSAZA. Right. The notes were made on the
plan of original implementation.
On Page 2 the Merrimac Metal Finishing Company has
been deleted in that it is being discharged to the municipal
drainage system. Therefore, it is not subject
MR. KLASHMAN. Will you hold it one moment. On
J. P. Stevens Company, they will be finished by June, 1971?
MR. CASSAZA. That is what their schedule calls for.
MR. KLASHMAN. I am sorry. The next one is Dracut?
MR. CASSAZA. No. The next one is under Merrimac,
The Merrimac Metal Finishing Company has been deleted, and
rightly so in that that system is being discharged to the
town of Merrimac system and, therefore, our action will be
against the town of Merrimac for treating this.
MR. .KLASHMAN. Are they already connected to the
town?
MR. CASSAZA. Yes.
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202
John Cassaza
Under the town of Merrimac you will note that
there has been changes in the dates. These dates were
changed following a hearing in our office relative to the
matter of pollution by the town of Merrimac• We have
issued orders, and the dates listed here are the dates
that are now in the ensuing order.
MR. KLASHMAN. Would you mind reviewing those
dates?
MR. CASSAZA. The town of Merrimac is to
appropriate funds for final plans and specifications or
acquisition of the site and for construction by 3/69. These
plans are to be completed by 4/70 and construction to be
started by 7/fO with an estimated completion date of 7/71.
Under the town of Methuen
CHAIRMAN STEIN. That is a two-year extension?
MR. CASSAZA. Two years. It was scheduled to
start and be completed in 1969.
CHAIRMAN STEIN. You are suggesting moving it to
July of 1971?
MR. CASSAZA. I beg your pardon?
CHAIRMAN STEIN. You originally had the date of
June 1969, and your new date is July 1971* two years.
MR. CASSAZA. Right.
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203
John Cassaza
MR. KLASHMAN. But what he has said, I believe,
and I would like to get this clear, Is that they were unable
to get the community to move so they had to call them in on
starting legal action. Is that correct?
MR. CASSAZA. Yes.
CHAIRMAN STEIN. By the way, I am not saying there
is not a good reason for this. What we are saying Is this
is going to be completed two yearn later.
MR. CASSAZA. This is our standard procedure: If
the community meets Its dates and It cannot get itself back
up on a schedule, then we will issue a complaint and call
them in for an adjudicatory hearing. After all the evidence
is in, we will then consider it and issue orders to proceed
with the pollution abatement program. Of course.we do not
get these people in until after the starting dates, so It
necessitates an extension.
CHAIRMAN STEIN. That is right.
MR. CASSAZA. Under the town of Methuen we had
adjusted these dates from the original dates to bring them
in tune with what the rest of the region was proposing, what
we were proposing to do in the rest of the region. It is
almost immaterial as to what the particular dates are now,
because the town of Methuen, Andover and North Andover and
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204
John Cassaza
the city of Lawrence are not in a sewerage district. This
district was Just established this last year and became
effective by law approximately six weeks ago. As soon as
this district meets, we will sit down with them and establish
new dates for the district. So any dates we have now for
these communities is because the district is responsible for
the construction of pollution abatement facilities.
MR. KLASHMAN. Do you anticipate that the dates for
the district will be much beyond the July 1972
date or the June 1972 date that you have for Lawrence? I
am sorry. The first project was June 1972, and the second
one was July 1973.
MR. CASSAZA. I do not expect that the Lawrence
dates call for the final plans to be completed by 1/70. I
anticipate that this district will be formed within a month,
something like that.
They will have to negotiate with consulting engineers
for the preparation for final plans and specifications. We
are talking about perhaps a $30 million project in this
particular area. I do not anticipate that final plans for
*his project can be completed in any time shorter than perhaps
Id months. I think that will be very optimistic.
MR. KLASHMAN. So it might be. six months beyond
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205
John Cassaza
this date?
MR. CASSAZA. Yes, six months beyond, I think,
that date.
MR. KLASHMAN. The people in the districts are
Lawrence
MR. McMAHON. Andover and Methuen.
MR. CASSAZA. This, of course, is quite consistent
with Federal requirements and wishes and desires, and this
has actually resulted in a saving, or will result in a
savings, because of the piping costing approximately $15
million on this project for this metropolitan area.
We have deleted under the Methuen the Methuen
International Mills because they are in the municipal sewer-
age system and, therefore, we have deleted them.
MR. KLASHMAN. When will they be connected to the
system?
MR. CASSAZA. They are connected to the system now.
MR. KLASHMAN. Do you know when this happened?
MR. CASSAZA. I do not have the information as to
the date when they were connected.
MR. KLASHMAN. I wonder if on these industries that
are being deleted if we could get the date for the record of
when the connection was actually made?
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206
John Cassaza
MR. CASSAZA. Yes. We have that data. We do not
delete these things.
MR. KLASHMAN. Could we hold this until we get
this, Mr. Stein?
CHAIRMAN STEIN. Yes.
. Let me cite a procedure that was used in other
places. Obviously, as the program moves we are going to
": ave to make and approve adjustments all the time. Now, of
course, we have the standards and enforcement operation.
I would suggest that if these things are reasonable,
we probably are going to have to have a status meeting every
six months. This is Just to correct the record, indicate the
adjustments we have made and see that we both can go along
with you.
These are the type adjustments that you are talking
about, Mr. Cassaza - not where the State or Federal Govern-
ment has really changed the policy, or someone does not go
along, or wants to go along, but the force of the fact of
the situation and Just the administration making it necessary
for us to adjust the dates. I think that that is inevitable
in any complicated problem like that and we are Just going to
have to have a continuing,record of how we do that.
MR. CASSAZA. We anticipate that this is what we will
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207
John Cassaza
be doing - submitting periodic a1"1" such data to you
personally.
CHAIRMAN STEIN. Yes.
MR. CASSAZA. Also under Methuen, their Rex Potato
Chip has been deleted because they are now out of business.
I will also ascertain the date when they did go out sub-
sequently and send them to you.
Under Page 3* in Newburyport we have added to this
schedule the Chase Shawmut Company and the Towle silversmiths,
and as a result of surveys we have found that they are contribu-
ting pollution to the Merrimack, so we have listed them. I
do believe these dates are in there and they are consistent
with the other dates that we have in the Merrimack River
Valley.
MR. KLASHMAN. Those two are to be done by May 70?
MR. CASSAZA. Right.
Under the city of Haverhill we have made certain
oa •
changes in their dates whereby
MR. KLASHMAN. What page is Haverhill on?
MR. CASSAZA. This is Page 1 again.
MR. -KLASHMAN. Where is it?
MR. McMAHON. It is on Page 1.
MR. CASSAZA. We have changed the dates of Haverhill.
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208
John Cassaza
The end results are practically the same I think. As a
matter of fact, they have updated. We had originally called
for Haverhill to complete Its first project by 1/11, and the
end result now Is to complete Its project by 4/fl.
Also on the same page we have made certain adjust-
ments on the Continental Can schedule and we have given them
a little later date, This ties In with the Haverhill
date, because the Continental Can Company now is negotiating
with the city of Haverhill — and I believe these negotiations
have been completed — for their waste to be discharged to
the municipal system. So we have made these adjustments
accordingly.
Only one comment on Page 2. Under the town of
Salisbury we have changed Well, we have called the town
of Salisbury in for a hearing. They have signed what we
call a Consent Order to proceed and have agreed to proceed
with an implementation schedule. These dates are the, sajme.
We ended up with the same dates that we had originally
established for the town. They were in the process of
becoming delinquent, so we called them in and we have them
back on a schedule, but they are now under a Consent Order.
We have a Consent Order pending for the Salisbury
Water Company. We have had them in for a hearing, and they
-------
209
John Cassaza
have agreed to —
MR. KLASHMAN. Excuse me. On Salisbury, In other
words, they met this July 1968, date of acquiring the site?
MR. CASSAZA. Yes. They already own the site.
MR. KLASHMAN. The final plans will be out by
March 1969?
MR. CASSAZA. Yes.
MR. KLASHMAN. Thank you.
MR. CASSAZA. We do anticipate, in view of your
latest recommendations made today relative to ocean out-
falls and discharging waste from Newburyport and Salisbury
to the Atlantic Ocean, that of necessity any dates that we
have originally established with Salisbury will be delayed.
This is additional information from your recommendation.
The Salisbury Water Supply Company, we have also
had them in for a hearing. They have agreed to sign a
Consent" Order. This has not been received as of this date,
but, again, the end result of their work will not be any
later than what we originally anticipated.
That concludes the remarks on the Merrimack River.
MR. KLASHMAN. Mr. Cassaza, may I very quickly
review a couple of things.
As I see it, you have asked for a delay in the
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210
John Cassaza
completion date of the Haverhill project. Well, the
Haverhill project you have actually stepped up by three
months. You have asked for a delay for about a year in
the connection of Continental Can?
MR. CASSAZA. Yes.
MR. KLASHMAN. About a year for Merrimack Metal
Finishing Company?
MR. CASSAZA. Well, they are in the municipal
sewerage, so
MR. KLASHMAN. They will be delayed?
MR. CASSAZA. The treatment will be delayed, but by
virtue of their now being in the municipal system we have
\
no Jurisdiction over them.
MR. KLASHMAN. What is the longest delay that you
have asked for, about two years?
MR. CASSAZA. We have two years for the town of
Merrimac*
MR. KLASHMAN. Merrimac, and that is the one that
is going
MR. CASSAZA. No. They are under orders now.
MR. KLASHMAN. But that is the only one that is
two years?
MR. CASSAZA. Yes. And in addition, like North
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211
John Cassaza
Andover, for example, if they had proceeded on their own
they would have probably been completed by 1970.
MR. KLASHMAN. But going into the district —
MR. CASSAZA. Going into the district the whole
project is delayed.
MR. KLASHMAN. In general, then, with the
exception of the district and these, it is about 12 months?
MR. CASSAZA. Right.
MR. KLASHMAN. So it is 12 to 14 months?
MR. CASSAZA. Yes.
MR. KLASHMAN. I have no further questions.
MR. McMAHON. These are only changes, Mr. Chairman.
MR. CASSAZA. I am following through now with the
Nashua River. I have not completed.
MR. KLASHMAN. I am sorry.
MR. CASSAZA. On the Nashua River, under Leominster
we have changed the Borden Chemical dates and the Foster
Grant dates. I believe that the original dates for these
two industries was 4/69. We have now changed these dates
so that their work will be completed by 7/TO which, of course,
(is a year and three months, something like that, delay.
Now, these two companies have now signed Consent
Orders, and they have agreed to proceed with the dates that
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212
John Cassaza
we have now given you. This was done after a hearing
relative to the matter of pollution by these two industries.
MR. KLASHMAN. Isn't that 12/69, the Borden Company?
MR. CASSAZA. 7/fO, Borden Company and 12/69 for
the Poster Grant.
MR. KLASHMAN. I see. Thank you.
MR. CASSAZA. The Poster Grant was delayed less than
a year because of this action.
Under the town of Fitchburg we have disclosed two
additional sources of pollution and have listed them with
their dates being the cleanup of their pollution, being the
same dates, approximately.
MR. KLASHMAN. Which are the two new ones?
MR. CASSAZA. The American Plastics and the Iver
Johnson Arms & Cycle Works.
These dates, they are on the same schedule as the
umiclpal program.
Under Pltchburg we have also listed the Art Photo
Services, the Pltchburg Gas and Light, the Hedstrom
Associates and the Vogue Wall Coverings, Inc. We have also
listed Iver Johnson Company in Pitchburg, the Wachusett
Potato Chip Company and Independent Lock Company.
These dates are also consistent and in no case
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213
John Cassaza
later than any other date we have established for any
other municipality or industry In this area.
Under Lunenburg we have listed the Rogers Brothers
with a completion date as of 4/71. As you can see, it is
consistent with all the other dates.
In Westminster we have listed the Old Mill Restaurant,
the Advance Coatings, Inc., and the Decotone Products Company.
I might comment, under the town of Lancaster that
here we have listed the Atlantic Union College. The town of
Lancaster has now formed a district which is going to pick
up the Atlantic Union College, so these dates here will be
after we have got the district under way. They are going to
be discharging through the Clinton Sewerage treatment plant,
which will eliminate one treatment facility In that area,
i
which is, of course, what we are looking for0
That concludes my remarks on Nashua and the
tferrimack River.
MR. KLASHMAN. Mr- Cassaza, In the original
conference I understood that we were supposed to include
the Intrastate sources, and there were about 15 of those
* •*
that you have not mentioned, when we were asking for the
compliance dates, we had gotten some of those from you. I
wonder If you could update those?
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214
John Cassaza
MR. McMAHON: May I comment on this, please, Mr. Chairman?
CHAIRMAN STEIN: Yes.
MR. McMAHON: We are not taking exception to this. In
fact, we have come prepared to give the intrastate sources. There
is perhaps a little bit of procedural question here in the sense
that in the letter from the Sacretary of the Interior to Doctor
Frechette no reference was made to intrastate as far as the
conferees were concerned. Despite this, we will be most happy to
present this information, but I would sort of like to qualify
this on the record because I am not too sure that from a legal
point of view this is proper .
CHAIRMAN STEIN: Your objection is noted. I think the
assumption we were proceeding on and the opening statement indicates
that in Massachusetts we were considering the intrastate as well as
the interstate, but that should not prejudice your exception.
MR. McMAHON: I do know that the Governor recommended
intrastate as well, but in the Secretary's letter there was no
reference. Nevertheless, we will be most happy to give you
this information.
CHAIRMAN STEIN: All right.
MR. CASSAZA: I have passed out to you a list of the
polluters on the Concord River Basin and its tributaries
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215
John Cassaza
thereto, excluding the Assabet and the Sudbury. This
listing here, In all eases^does not represent relevant
sources of pollution.
The first community listed here is the town of
Acton. Now, the town of Acton is not a polluter of any of
our waterways.
We have listed the town of Ashland because the town
is ambitious. They have an active planning group there.
They, for municipal planning, are hoping to proceed to get
a sewerage treatment plant in the town.
They do have local problems with subsurface
disposal. They wish to bring Industry into the community,
so they are proceeding with hopes of eventually bringing
in a municipal or having a municipal waste treatment facility.
CHAIRMAN STEIN. They do not have a sewerage system
there, do they?
MR. CASSAZA. They do not have any municipal sewer-
age system at this time. We have not listed them in this
because they are not a polluter.
In the town of Acton we have the Chemical Company
«e have listed.
Under Billerica we have listed Municipal Sewerage
System. They have already constructed their own municipal
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216
John Cassaza
waste treatment facility, but this relates to sewer exten-
sions that have to be up along the Concord River to pick
up certain portions of North Blllerica and to pick up
certain of the industries that are in that area which
eventually will be discharged to the municipal system, one
of the main polluters up here. There are two, Lowell Rendering
Company and the North Billerica Rendering Company which are
listed and they have hopes of going into the municipal sewerage
system.
MR. KLASHMAN. Your list is a little bit different
from ours.
MR. CASSAZA. Let me proceed with this and then you
can ask me questions of any of the others that you have a
mind to.
Under Pramlngham we have listed the General Motors
Company.
Under Maynard, the town of Maynard has an inadequate
secondary facility. They are proceeding, they are going into
town meeting for appropriations of funds. We again are going
to be running into a problem in this particular area because
we are going to look into the matter of regionalization
between them and surrounding communities, so we may have to
delay there.
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217
John Cassaza
In Northboro, again, they do not have a municipal
sewerage system, but they have local problems in our planning
to be in with the regionalization of the city of Marlboro.
So they should not be considered as a polluter- We have
listed the Machinery Electrification Company in that community,
In Pramingham, again we have listed the Roxbury
Carpet Company who is a polluter. They are going into the
municipal sewerage system as soon as the town of Pramingham
builds a larger pumping station in which to take them.
We have listed Pramingham Municipal here because
they do need an enlargement of their pumping station, but
they should not be considered as a relevant source of pollu-
tion.
In the town of Hudson, we have listed the town of
Hudson. It is a municipal responsibility, but this is
again for a pumping station in the community which needs to
be rehabilitated and somewhat enlarged and should not be
listed as a real source of pollution.
We have also listed Marlboro, the Westerly sewerage
plant. They are not polluting but they are developing and
with 495 in the area they are quite anxious to proceed with
bringing industry into that area.
That concludes what we have listed under this river
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218
John Caasaza
basin. If you have any areas which are not listed there,
I will be glad to comment.
MR. KLASHMAN. I had a view here that we would want
to have the dates if we could get them. In Ashland we had
a chemical manufacturing company?
MR. CASSAZA. Those have been tied into the sewers,
so we have not listed them as contributors to pollution.
MR. KLASHMAN. In other words, they are tied into
Ashland?
MR. CASSAZA. Right.
MR. KLASHMAN. The General Electric Company in
Ashland?
MR. CASSAZA. Either tied in or they put in their
own treatment facility there I believe. They are not a
source of pollution.
MR. KLASHMAN. Could we get whatever
MR. CASSAZA. Well, you have it here. You have the
G. E. there, that they are neutralizing and chlorinating
their waste. So they are now treating their own waste.
The same with Ashland Chemical. They are using sand
filtration and they are not treating them properly, so we
did not list them on this.
t
MR. KLASHMAN. I see. You have the rest of our list.
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John Cassaza
Are there any others? For example, Westboro, the secondary
treatment plant Is satisfactory?
MR. CASSAZA. Right.
MR. KLASHMAN. The Hudson Combing, they have
settling facilities?
MR. CASSAZA. Right. Right. There are many places
here you are listing, but they are places wnlch have settling
facilities which are not pollution. There is a difference.
MR. KLASHMAN. Do you have any comments to make on
the list, Mr. Pahren? We have solicited here places that
have treatment facilities. Is there any question about it?
MR. PAHREN. Is Hudson Combing Company okay?
MR. CASSAZA. Yes. You asked if Hudson Combing
Company is all right. We have investigated that, and we find
that there was a problem of a broken line which they repaired,
but they are not polluting.
MR. PAHREN. Would you like to comment on Marlboro
with a discharge into Hop Brook?
MR. CASSAZA. Well, yes. The Marlboro, early through
its agreement plan, has reached its capacity. As a matter
of fact, it probably is overloaded. They have put in sandbeds
and lagoons there to offset this.
The overall efficiency of this facility, it is well
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John Cassaza
over 90 percent, as reported by their consulting engineers
and checked out by us. With that, they are going to have a
tertiary treatment, but the point is the effluent is being
discharged down to Hop Brook, which is a very small stream.
It cannot take it, so they have had problems with odor
conditions down there.
Now, that odor condition down in that area may be
due to the lack of oxygen down in the water, but it is
probably due to algae growing rapidly. In certain areas
there, In order to overcome this, they have put in these
aerators to eliminate this problem. But the solution is
not to put In these aerators but to remove these nutrients.
In that respect, our Division, we gave the very
first grant to the town of Marlboro for a research project
on the removal of the nutrients from their sewerage treat-
ment facility. Upon the completion of this study, the
town is planning to move ahead to implement what this pilot
grant research plant does. In the end, we will remove the
nutrients so that the condition will no longer exist at
Hop Brook.
This Is another reason why the westerly plant is
being constructed, because the easterly plant Just cannot
take anymore.
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John Cassaza
CHAIRMAN STEIN. Let me make a suggestion here.
I think we are coming to the stage of the case that we
always get when we move ahead to this completion operation.
What I suggest we do, because we are likely to
get into this problem again and again in various cases
As I see it, the Massachusetts program is moving ahead on
schedule with certain modifications you had to make, you
believe either for administrative reasons when they came
in or largely because there was a switch in plans and they
decided to consolidate in one district. I will ask Mr.
Klashman, and maybe you should do it now, do you think that
these proposals are reasonable in each case?
MR. KLASHMAN. Well, on the interstate part I
think that the proposals they made certainly are reasonable.
On the intrastate also the ones I see here appear
to be reasonable, but I would like to get the record complete
between our list and theirs. I think we can do that very
simply by getting together afterwards.
CHAIRMAN STEIN. This would have to be done.
Just technically for the record, if this is in the
standards which have been approved in another conference and
*
If we make a recommendation that this is all right, we are
going to have to spotlight the ones for which we made a
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John Cassaza
recommendation. I would suggest that from here on out,
within the next month, at least no longer than that and
hopefully before that, so we can get these agreed upon
and put in the Summary - that we will agree on a master
list of the sources. The list can be added to or subtrac-
ted from as you have with this.
Now, a lot of the cases are going to say that the
work is completed, and I do not think we should eliminate
those from the list. Because if we are going to indicate
the progress we are making, we should indicate the ones
where the work is done.
Again, I would suggest that these work sheets are
fine and they should be used by you. But for the conference
possibly the only place where we should take them up is
where there is a deviation from programs or several main
dates. Possibly for the Federal recommendations you have
three things and I might suggest a fourth.
l) This may be crucial here and you may want to
spotlight it in the conference - the final plans and
specifications.
2) start construction.
3) complete construction.
And I would say the fourth operation is to arrange
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John Cassaza
for financing, which very well may be the key, particularly
with municipalities.
MR. CASSAZA. In our presentation, we listed this
at the beginning.
CHAIRMAN STEIN. I understand. But I am saying
when we have this for the Federal-State relationship that
these are possibly the four things we should have. The
technical staff and the people in the States should agree
on the list. Then if we ever have a progress meeting or
something again, it seems to me that all we will have to do
is go down the list and check the ones which are meeting
the schedule or where you would suggest an adjustment on
the date. Unless the Federal people or your neighboring
State had a question, we would consider those in compliance
with the program. I think we have done that in other cases.
If we are going to simplify this, in a sense, for
some administrator who is reviewing it, he will have to go
backwards and try to understand it. We should have that
straightened out. I do not anticipate any difficulty.
MR. KLASHMAN. As I see it from your list, everybody,
all the intrastate sources, will have treatment by May of 1972,
except for the North Billerica Talbot Mills and Northboro,
which is May of 1972*. Is that right?
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John Cassaza
MR. CASSAZA. Yes.
MR. KLASHMAN. But everything else will be done
by May of 1972. We can get this list. There is no problem
here.
CHAIRMAN STEIN. No. I think this is just a
mechanical problem, but I think it will simplify this and
highlight the operation when you indicate this.
By the way - and let me Just say this - the problem
or difficulty of a list like this, as soon as one complies
and is off the list and it does not give an indication of
the successes, my experience in this is that we better list
those if we are going to see It. For example, we were in
Chicago last week or the week before and there were three
steel companies that everyone was concentrating on because
they felt they might not be complying on time, but we had
about 30 cities and about 20 other industries which would
all comply. When you looked at the whole picture you got
quite a different view than if you Just concentrated on ?
those which some people might have felt were still in non-
compliance.
I think it would be helpful for all concerned if
we got this boxscore and the list, then when people have
completed they remain on the list but you put down that
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John Cassaza
their work Is completed and we are all set. I think this
can be worked out. Hopefully, we should be able to have
this possibly to issue as an appendix to the summary so
we are all in shape. I look for this as a mechanical
problem and no problem other than that.
(SEE APPENDIX A)
As far as you are concerned, Mr. Klashman, your
recommendation for the extensions that they might want
to have in those cases, for those few cases, is reasonable?
MR. KLASHMAN. These do not appear unreasonable.
MR. McMAHON. Mr. Chairman, may I make a point? We
have been discussing delays here, and I think I would like to
make one more point here.
Generally speaking, delays are caused by several
reasons. Number one, I think it was pointed out that in
reglonalization or in trying to get certain communities
together that do have different dates, the most common
denominator is usually town, and to form a district and build
a larger facility usually takes longer.
Now, this is taken into consideration, benefits to
water quality.and also cost savings. I think all of us
generally agree in the regional concept if you do get better
water quality and If the costs are less. In the meantime, it
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John Cassaza
does mean in certain cases there will have to be certain
delays.
A second reason, and this is quite apparent in
our Consent Orders, as these polluters miss dates, then
you have to go back and put them under Consent Orders or
call them in for adjudlcatory hearings, and this means
revising the dates and extensions. We try to compress it,
if at all possible, so that the construction dates can
remain the same if at all possible. In many cases this
does not happen.
There is a third point here, and I do not say it
is the major one, but it is one of the problems we have
run into. In many cases we get poor engineering reports
or final plans that are not adequate from the State point
of view. When you reject these, this again causes a delay.
Yet, on the other hand, I do not think any State regulatory
agency is in business to approve inferior engineering or
something that really does not do their Job.
One other point, and this has not been brought
out — and I think it should for the people in the Nashua
River Basin — is that the city of Pitchburg has completed
a regional report which includes most of the major industries
within the Pitchburg area. This is going to involve two
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John Cassaza
sewage treatment plants, one handling the bulk of the
municipal waste and one paper company, and another Is going
to be primarily an Industrial plant handling two paper
companies and a possibility of taking in another town. This
is essentially about a $17 million project.
They also have recommended a program for separation
of combined sewers within the Pitchburg area over the next
few years. We think this is an excellent project. It has
been approved, at least conditionally, by our office and we
are making every effort to see that this is implemented as
quickly as possible.
CHAIRMAN STEIN. Thank you. Those remarks are well
taken. I do not care whether it is a waste facilities
construction or you are building a subway or you are building
your house, we are doing all this within the limitations and
vicissitudes of our general American society and you have the
same problems that you have in any society with any project -
you have to make the adjustments.
I know we have had cases all over from bond issues
being voted down by the voters to mayors being indicted, and
anytime that happens you are going to have a delay in the
project. Therefore, I do not believe this is peculiar to
water pollution. This is Just what you have to get. These
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Richard Young
are the type adjustments we are going to have to make.
The reason we get together is that it is the best
thing we could do. By doing this in public the people can
make a Judgment on whether we are making the right determina-
tion or not with this and we can do this also in the best
possible way. You know when you talk about these plans and
other things that are rejected, I guess Winston Churchill
summed it up when he said, "Democracy is the worst form of
government, except those others that have been tried from
time to time." I think we Just have to put up with this.
Do we have any other questions?
MR. KLASHMAN. No.
CHAIRMAN STEIN. Massachusetts, do you have anything
more to present?
MR. McMAHON. We have a number of people here from
Massachusetts.
CHAIRMAN STEIN. Yes, please proceed.
MR. McMAHON. I would like to call first Mr. Richard
Young, who is a Director of the Central Merrimack valley
Regional Planning District.
STATEMENT OP RICHARD H. YOUNG, EXECUTIVE DIRECTOR
CENTRAL MERRIMACK VALLEY REGIONAL PLANNING DISTRICT
LAWRENCE, MASSACHUSETTS
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Richard Young
MR. YOUNG. Mr. Chairman and Conferees, ladies and
gentlemen, I apologize for not preparing my remarks before-
hand. I would have liked to have done so, much rather than
*
spend the time in bed last week with you know what, so you
will have to take it from my penned notes today.
The Central Merrimack Valley Regional Planning
District was formed in I960 for not only the water pollution
purpose but for a general regional planning in the central
portion of the Merrimack Valley in Massachusetts. At that
time, it consisted of the communities of Lawrence, Andover,
Methuen and North Andover. By 1964 the District investigations
and considerations had progressed in the field of water
pollution abatement to the point where one of the policies
in the regional plan called for abating pollution by the
four communities in the Greater Lawrence area through the
construction of one treatment facility.
Since 1964 the District has been expanded gradually
until we now include the 15 cities and towns of Lawrence,
Haverhill, Newburyport, Andover, North Andover, Methuen,
Georgetown, Groveland, Boxford- West Newbury, Merrimac,
Amesbury, Salisbury, Newbury and Rowley.
The regional plan and policies of the District are
being expanded currently and will, when adopted tomorrow
*Hong Kong flu
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Richard Young
night, call for treatment facilities individually by the
city of Newburyport and the Town of Amesbury and Merrimac,
and joint facility use by the city of Lawrence, the Towns
of Andover, Methuen, North Andover, and by Joint facilities
to serve Haverhlll and Groveland.
Beyond this, the District has attempted to
categorize intercommunity action by offering assistance
and encouragement to its member communities.
We have also programmed the necessary regional
planning actions to make the member communities eligible
for maximum State and Federal grants, including all available
bonuses.
Even more specifically, the District has been active
in promoting local actions leading towards Joint undertakings.
Unless your questions reveal an interest, I will
omit the gory details and summarize our progress by saying
that after two years of effort the four Greater Lawrence
communities have formed a Greater Lawrence Sanitary District.
The principal officials of these communities have been
invited to meet on January 8, 19&9* to organize the District.
In the Haverhill-Groveland situation we have met
with both communities and I am pleased to report agreement
in principle. We and they will attack the problem of legal
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Richard Young
agreement In the near future, and I have every reason
to anticipate success similar to that produced in the
Lawrence area.
Do not misunderstand my remarks as I am implying
there is great enthusiasm for spending the money to do
the job, but I take great personal pride in reporting that
I think the communities in the Central Merrimack Valley
Regional Planning District are organized to get the Job
done in the most economical fashion.
As I see it, the organizational and intercommunity
problems which threatened the accomplishment of the Job In
1964 have been resolved as of this date.
CHAIRMAN STEIN. Thank you very much, Mr. Young.
Are there any other comments or questions?
MR. McMAHON. I would Just like to add that Mr.
Young has worked very closely with our Division in setting
up meetings with these communities and getting them together
on this water pollution abatement district and we thank
you very much, Dick.
CHAIRMAN STEIN. Any questions?
MR. KLASHMAN. I have no questions.
MR. McMAHON. Next I would like to call on Mr.
John Pobst who Is representing the Greater Lowell Planning
Commission.
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John Pobst
STATEMENT OF JOHN J. POBST, STAFF CONSULTANT,
GREATER LOWER PLANNING COMMISSION,
LOWELL, MASSACHUSETTS
MR, POBST. Mr. Chairman, ladies and gentlemen,
my name is John Pobst. I am Staff Consultant to the Greater
Lowell Area Planning Commission, Lowell, Massachusetts.
We have been working in similar manner to Mr. Young'a
program in a regional planning commission such as this.
We are not a State agency; we are not a local agency.
We are in between, and we have close ties to our particular
communities.
Our Commission is representing a region adjacent to
Mr. Young's commission on the Merrimack River at the New
Hampshire border. The communities in our region are Lowell,
Dracut, Tewksbury, Billerica, Westford, Tyngsboro, Dracut
Pardon me. I named that before. Dunstable and Pepperell.
The community of Pepperell, of course, is on the
Nashua River, so we have the two major streams within our
region.
Our programs which impinge on the Clean Waters
Program are utility planning, which has been going on for
a year now, open space and recreation planning and studies
of economic development. We see the development of sewers
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John Pot: at
both in terms of cleaning up the rivers and in terms
of making greater economic growth possible through
industrial development, which is also very important to
our region.
At the present time our major priority is with
the city of Lowell in our region. This city has a popula-
tion of about 90,000 and has never had any form of sewage
treatment. They have plans to develop moving ahead.
There have been problems in coordination with
adjoining communities. We are working toward a possible
Sanitary District and have hopes of developing something
in this direction during the next year.
Thank you.
CHAIRMAN STEIN. Thank you.
Are there any questions of Mr. Pobst or comments?
(No response.)
CHAIRMAN STEIN. If not, thank you very much.
~ MR. McMAHON. Next I would like to call Mrs. Mary
Anne Stoddart, who is the Coordinator of the Nashua River
Clean Up Committee from Groton, Massachusetts. As most
of you know, Mrs. Stoddart has been sort of a driving force
within Massachusetts within the Nashua River Basin, and we
think she has done an outstanding Job.
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Mrs. Hugh Stoddart
STATEMENT OP MRS. HUGH P. STODDART
MASSACHUSETTS COORDINATOR,
NASHUA RIVER CLEAN UP COMMITTEE
GROTON, MASSACHUSETTS
MRS. STODDART. Thank you.
Chairman Stein, Conferees, ladies and gentlemen,
I am Mrs. Hugh P. Stoddart, the Massachusetts Coordinator of
the Nashua River Clean Up Committee and I represent the
155*000 people in the Nashua River Watershed who want the
maximum number of uses for the Nashua River attained as
expeditiously as possible.
I want to thank Mr. Zabriskie, who is Acting Commission-
er of the Department of Natural Resources for cordially
permitting members of my Committee and me to attend this
reconvened Conference today to present a statement for the
majority of residents in the Nashua River Watershed.
The Nashua River Clean Up Committee was formed in
the summer of 1966 in response to the intolerable condition
of the Nashua River which had become septic and putrid due
to the combination of pollution, draught and hot weather.
The condition of the River was so bad that its stench and
sight were nauseating. It sickened the people who lived
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Mrs. Hugh Stoddart
near it, kept business away from stores, made the river
and its adjoining land useless for any purpose and caused
some property to lose all of its value. We determined
to no longer endure this correctible situation, but vowed
to work ceaselessly to restore clean water to our river.
It is no longer summer and the draught has passed.
The river looks and smells about the same as it has for the
past 30 or 40 years — real sick, but not quite dead, as it
was in the summer of 1966. We are still sorely affected by
this ribbon of gray filth (sometimes salmon, milky white or
pea green) that snakes its way through our beautiful country-
side. Although there is no visible improvement in the quality
of water in the Nashua, we are cognizant and appreciative of
the unseen progress taking place on Federal, State, local
and private levels to clean this river.
We are grateful for the Federal Water Quality Act
of 1965 which was the necessary forerunner to all subsequent
water pollution abatement action. The passage of the Massa-
chusetts Clean Waters Act of 1966, as amended, was a most
important milestone towards the cleanup of the Nashua River.
The establishment of criteria for water quality standards and
the modified C classification of the main stem of the Nashua
River with a 5-year time schedule for compliance were equally
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Mrs. Hugh Stoddart
important milestones towards the cleanup of the river. The
Committee had hoped that we would be successful in having
the river classified B for its future highest use, and have
been encouraged by an indication of this possibility by
former Commissioner Yasi in a letter sent to us dated
July 13* 1967. We are submitting a copy of Mr. Yasi's letter
to this conference as a part of our statement. As an added
incentive for a B classification, we note that the cities
and towns testified at the March 28, 196?, Nashua River
Classification Hearing that they would like to use the land
adjoining the river for recreational purposes. It is the
present position of the Department of Natural Resources that
they will not acquire land along the Nashua River for open
space or outdoor recreation unless the river is of B quality,
or is assured of becoming B quality. Therefore, the Nashua
River Clean Up Committee requests periodic reevaluation of
the Nashua River and its tributaries with the expectation
of having its future highest use upgraded.
The passage of the 1966 Federal Clean Water Restora-
tion Act was significant. We have been disappointed, however,
in the failure of Congress to appropriate sufficient funds
to adequately implement this Act. In fact, we are greatly
i
concerned that the river cleanup program may be slowed because
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Mrs. Hugh Stoddart
of insufficient funds. We believe that it would be difficult
for Massachusetts to prefinance the whole Federal share.
The announcement by the Corps of Engineers that they
plan to incorporate the Federal Water Pollution Control Adminis-
tration water storage requirements for water quality improve-
ment in the North Nashua Reservoir system is important. We
would like for the Conferees to take special note of this
plan and to encourage and assist the Corps in every possible
way so that the plan will become a reality. Low flow augmenta-
tion could provide substantial increased flows to raise the
quality of water after all treatment facilities h^Lve been
put into effect and assist in the future maintenance of high
quality water.
Now, I had expected, Chairman Stein, that the Corps
of Engineers might be here today to present a statement. I
was told by a person in their office that this was to be so.
I hope that they will have an opportunity to present statements
or their plan to you.
MR. KLASHMAN. For the record, Mr. Chairman, if I
may, we did Invite them and we anticipated they would come,
but I have not heard from them.
*
MRS. STODDART. I was told that they would be here
today to present such a statement.
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Mrs. Hugh Stoddart
On local and private levels, we are pleased that
the Division of Water Pollution Control time schedules
approved by Secretary Udall are being met. We are particularly
pleased that Mayor Flynn, City Council President Albert, and
the City Coucil of the city of Pitchburg and Pitchburg's
industries, by far the most serious polluters of the river,
have moved fastest to meet their time schedules. We hope
that the State will be able to decide quickly on a funding
program that will be acceptable to both the city, State and
Federal Governments and that Congress will make adequate funds
available, so that Pitchburg, its industries, and the affected
adjoining towns can move ahead and have their facilities
constructed and in operation by April 1972 - the announced
time schedule deadline. We are also pleased that Mayor Grossman
of Leominster, the City Council and Department of Public Works
Director Rasicot are working out an agreement with Poster
Grant and Borden Chemical to treat their wastes. It also
pleases us to know that Lancaster and Atlantic Union College
have formed a sewage abatement district to prepare plans for
the treatment of their wastes. We are concerned, however, that
with the exception of Pitchburg and its industries, all other
polluters with 1968 time schedules to meet are running a little
late.
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Mrs. Hugh Stoddart
We would like the Division of Water Pollution and
Control to adopt the policy of checking periodically with
polluters to determine their progress well in advance of
their deadlines, so that if they are coasting a little,
they can be cranked up and speeded along the way rather than
waiting for their deadlines to come and then checking on
their compliance, thereby setting the program back several
months, a year, or perhaps even more.
We also wish to recognize the educational efforts
of the Associated Industries of Massachusetts, particularly
those efforts of Mr. William McCarthy, to inform industrial
managers of the work they must do to meet State and Federal
water pollution control requirements.
We are gratified that the Massachusetts Division of
Water Pollution Control has been forceful in applying its
authority to cause delinquents to meet their schedules. I
cite the Consent Orders issued Borden Chemical and Poster
Grant as examples. We hope that the State and the Federal
governments will be absolutely strict in forcing complete
compliance with these schedules. We view the proper discharge
of this responsibility and authority as absolute essentials
.*
for the river cleanup.
We are concerned that the State has indicated
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240
Mrs. Hugh Stoddart
satisfaction with the treatment of municipal wastes In Ayer,
Clinton and Leominster, whereas these municipalities do not
chlorinate their effluent after secondary treatment before
discharging it into the Nashua River. Approval of secondary
treatment for discharge without disinfection does not seem
consistent with the State standards for water quality.
Clinton's unchlorinated effluent creates a special problem
for Lancaster, as they propose to use the land just below
the Clinton outlet for park purposes. It does seem to us
that the stretch of the river on the South Branch between
the Clinton outlet and the confluence of the North and South
Branches could, at this time, justifiably be reclassified B
from C as its future highest use.
We are anxious that the State also begin to identify
polluters to the river and its tributaries, other than the
primary ones, and serve them with notices to abate their
pollution.
And I was very pleased to hear Mr. Cassaza's remarks
concerning identification of some of the additional polluters
on the river and new time schedules for their compliance. We
certainly favor this action and we hope it will continue.
The establishment of an adequate monitoring program i
to determine the efficiency of treatment is another concern of
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241
Mrs. Hugh Stoddart
our Committee.
We are worried, too, about the sludge deposits,
algae and duck weed which all constitute a nuisance condition
to the Because the river is slow moving, suspended
solids from the paper mills on the North Nashua do not fall
out significantly until they reach areas such as Still River,
the Ayer Ice House and Pepperell Pond. We would like for
the paper mills to consider the removal of even more suspended
solids than are normally removed in secondary treatment in
order to minimize the formation of these sludge deposits. We
hope that the Conferees will give some thought to the control
of these problems.
An Impressive start has been made to clean up the
Nashua River. However, it is only a beginning, and a vast
amount of work has yet to be done to reclaim this river.
£ --' V
«<
This will require continuous pressure and strict adherence
to established schedules, as well as the good will and
cooperation of all of the agencies involved.
I would like at this point to thank you very much,
Mr. McMahon, and, also, Mr. Slagle of your Division, both
of whom have been very helpful to the Committee, and we
*
appreciate your cheerful assistance. (Mr. Yasi's letter follows.)
CHAIRMAN STEIN. Thank you, Mrs. Stoddart. In
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242
^J
fi& (9&imn&nu
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243
Mrs. Hugh Stoddart
reading it, Mrs. Stoddart repaired two split Infinitives.
I think she should have the advantage of the repair.
Are there any questions or comments on this?
(No response.)
CHAIRMAN STEIN. One, Mrs. Stoddart, I think you
indicated and you know the Corps was not here, but this
notion — and I say this because we have Mr. Yasi's letter —
the notion that he says, "Should the Corps of Engineers or
ether agency studies reveal an economic justification for
flow regulation and subsequent water quality improvement
to the B class, we would be most happy to reclasslfy these
subject waters at that time." Well, these water pollution
control agencies you know have nothing to prevent the
Federal Water Pollution Control Agency if we do that or
the Massachusetts authorities, to ask the Court to provide
low flow augmentation for quality purposes. In other words,
I do not think we have to necessarily rely on one of these
cross studies to come up with what is considered in the
traditional rules as the economic Justification. That is
something you people might keep in mind if that is what you
are looking for in the B classification.
*
MR. KLASHMAN. We have, that is, the Federal Water
Pollution Control Administration has. When commenting on
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Mrs. Hugh Stoddart
the Corps1 projects when they are submitted to us under
the law, we have asked for stream flow augmentation in
cases like this. As a matter of fact, in the project it
did come to us. We did ask for stream flow augmentation.
MRS. STODDART. This is why I made the statement
regarding the Corps, that they have, in fact, included in
their plans water storage requirements which were provided
by the Federal Water Pollution Control Administration. I
was only anxious that the Corps be present today to present
to you their plans so that you would officially know about
it.
CHAIRMAN STEIN. Anything further, Mr. McMahon?
MR. McMAHON. I have a question, and perhaps you
or Mr. Stein can answer this.
At one time under Section 3 of the Federal Act —
this is the low flow augmentation of the Federal Act — it
was felt that if the benefits were long-term or national
in scope —
CHAIRMAN STEIN. General?
MR. McMAHON. Right.
— the full amount could be paid by the Federal
Government. However, I had heard in recent months, although
I had not seen this officially, that the Secretary had i
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Mrs. Hugh Stoddart
indicated that this would have to be a cost-sharing
arrangement either with the local or, perhaps, the State
agencies. Is this correct, or Is there a policy decision
on this matter?
CHAIRMAN STEIN. I had not heard that. He may
have made that in reference to a specific case.
I think the law is clear, unless it has been changed —
we are getting into a very visceral subject here — but to
answer you, this has nothing to do with the economic benefits.
In other words, there can be generalized economic benefit for
everyone and we can have storage for low flow augmentation.
Once we decide or the Federal Government decides to put those
features into water resource projects, then we come to another
problem and that is the problem of whether Uncle Sam picks up
the whole tab or is reimbursed. Unless that can be identified
for helping certain people, this is not reimbursable and
this becomes a different set of figures.
Generally speaking, water quality for recreational
uses as you are talking here is considered a generalized
benefit and you cannot tack anyone with the cost of that and
make it a reimbursable feature of the project.
That still throws us back to the first operation,
and we have to show that at least it is going to pay its way
-------
246
Mrs. Hugh Stoddart
and It is going to be worth putting the money in for water
quality improvements. I do not believe the law has been
changed on that. I know of no general policy statement,
and any statement that he made which may have related to
a particular case where this might have been so.
• MR. McMAHON. I think it would be interesting to
find out from the Corps Just what their plans are. I would
also suggest that perhaps the recommendations of the Conferees
could indicate the extensive possibilities of flow regulation
in that particular level.
CHAIRMAN STEIN. We may bring that up. If it is
agreeable to the Conferees, we may want to get together
have the States get together with the Corps or get together
themselves and we can invite the Corps. If we believe that
low flow augmentation is needed, then we come up with that.
I think Massachusetts may be the key people, because
you know what kind of minimum flows you are going to need to
ask for or to consider upgrading the classification. We
have done that before in other areas of the country - make
a recommendation, then if the Secretary adopts this he will
just present this to the Corps and anyone else as part of
our Federal operation.
If we have the States with it, of course, we at
-------
247
Donald Boucher
least are in the batters box and we are off and running.
Sometimes we make it. Sometimes we don't.
MR. KLASHMAN. I have no further questions.
CHAIRMAN STEIN. Do you have any other people from
Massachusetts?
MR. McMAHON. Yes, I do.
I would like to call on a Mr. Donald Boucher who
is representing the town of Lancaster.
STATEMENT OF DONALD E. BOUCHER
LANCASTER REPRESENTATIVE FOR
CLEAN UP OF THE NASHUA RIVER
LANCASTER, MASSACHUSETTS
MR. BOUCHER. Mr- Chairman, Conferees, ladies and
gentlemen, my name is Donald Boucher and I represent the
.. 't:-:
town of Lancaster in the matter of pollution, and I am also
on the Planning Board.
Before I get into this statement, I just read the
paper, the Worcester paper, that they met in Lancaster on
the Sewer District Commission just last night, which Atlantic
Union College is part of, and I believe I seen $850,000
was put together to get this program under way.
We, the citizens of Lancaster, are appreciative of
-------
248
Donald Boucher
the efforts to clean up the Nashua River. We welcome
the opportunity to restate our wishes for the uses of the
Nashua River.
Lancaster is situated where the north and south
branches join together to form the main stream of the Nashua
River. Therefore, we have many miles of the river flowing
through our town.
Looking to the future, the comprehensive plan lists
many possibilities to use the river for recreational purposes.
Some of the suggestions have been a park for young people's
recreation, greenways for walking, horseback riding, bicycle
riding, picnics, skiing, snowmobile trails. None of these
could become a reality if the river is not cleaned up. We
hope that all responsible agencies will continue their efforts
and that passing time will not see the drive for cleaning •
the river relaxed at all.
Our town seal bears the words "Lancaster on the
Nashua." We would once again like to be proud that we are
on the Nashua.
Thank you.
CHAIRMAN STEIN. Thank you, Mr. Boucher.
Any comments or questions?
(No response.)
-------
249
Thomas McMahon
CHAIRMAN STEIN. If not, Mr. McMahon?
STATEMENT OP THOMAS McMAHON, DIRECTOR,
WATER POLLUTION CONTROL,
MASSACHUSETTS WATER RESOURCES COMMISSION,
DEPARTMENT OF NATURAL RESOURCES,
BOSTON, MASSACHUSETTS
MR. McMAHON. Mr. Chairman, I believe this is all
of the people that intend to speak today. However, I would
like to introduce two gentlemen who are representing their
respective paper companies and who have worked very closely
with the city of Pitchburg in getting this regional scheme
under way.
The first gentleman is Mr. Peter Hughes who is
representing the Weyerhauser Paper Company and Mr. Prank
Pendelton who is representing the Pitchburg Paper Company.
I might ask if there is anyone here from Massachu-
setts that would like to speak that I have overlooked?
(No response.)
CHAIRMAN STEIN. I think, Mr. Klashman, if that
concludes the .Massachusetts presentation, you might consider
putting your material in on the Federal installations.
MR. KLASHMAN. ME. Stein, before I do that, I just
-------
250
Thomas McMahon
want to ask Mr. McMahon just a couple of questions before
we leave Massachusetts.
CHAIRMAN STEIN. Yes, Mr. Klashman.
MR. KLASHMAN. Mr. McMahon, I understand that at
Fitchburg the municipality working with the industries have
had a consulting engineering firm develop a plan providing
for secondary treatment. What type percentage of removals
of sludge, solids and BOD when it goes into effect?
MR. McMAHON. There are two levels of both BOD and
-suspended solids removed. The first, which was recommended
for the additional phase, was 90 percent and the second was
95 percent removal. This was also correlated with certain
limitations on the effluent as well.
I might add that within the standards of Massachu-
setts we recommended BOD and similar perameters will have
between 80 and 95 percent BOD removal, again depending on
the stream classification.
If it is a large stream, of course, the-necessity
for higher removals come to 95. This is not required.
On small streams such as the Nashua you do have
to require a high degree of treatment.
MR. KLASHMAN. In the definition of "secondary
treatment" you are saying that in many cases you are going
-------
251
Thomas McMahon
to achieve 90 percent removal. What you are talking
about IB 90 percent removal?
MR. McMAHON. Yes.
MR. KLASHMAN. In what cases would you go below the
90 percent?
MR. McMAHON. That Is a poor question. I really
cannot answer that offhand. I think Mr. Cassaza indicated
one project that we have here in Massachusetts now, and this
is on a research grant, and that is to really determine the
present and, also, the future of trickling filter plants
within the Commonwealth of Massachusetts.
The trickling filter operation does a good job in
the summertime, but in the wintertime the deficiencies get
down below or minimum 80 percent. So we are quite interested
in trying to see what additional form of programs of phosphate
removal or recycling, if we can, to upgrade these trickling
filter plants.
Generally speaking, I cannot really give you one
right now that is below 90. I think there may be some.
MR. KLASHMAN. In general, would it be fair to say
that when you are talking about secondary treatment, what
you are really saying is that you are requiring 90 percent
unless the standards can be met with something like a
-------
252
Thomas McMahon
trickling filter in which you might get 85 percent?
MR. McMAHON. I will give you two that Mr. Cassaza
just informed me about.
On the Merrimack we have two, not huge communities,
but we have two communities which we figure BOD removal of
about $5 percent.
CHAIRMAN STEIN. I think this is one of the questions
we are going to have to probably consider in the conclusions.
Maybe I have a suggestion for doing this.
Mrs. Stoddart raised this question, too, on the pulp
and paper waste, again with solids - suspended solids with
secondary treatment. The difference is that when you talk
about secondary treatment no one knows precisely what that
means.
Now, I think if we are going to come up with
recommendations here, we will have to be a little more precise.
I think the time has come when we are dealing with this
problem and not just taking out mass pollutants as we were
in the past. This notion of just saying "primary" or
"secondary" or "tertiary" treatment is not enough. We are
going to have to be more consistent. Because throughout the
country, for example, we can run primary pollutants, just
using BOD as a measure, anywhere from at least 75 in one State
-------
253
Lester Klashman
to 95 in other places. Between 75 and 95 is a big spread.
That may be the whole difference whether a river is polluted
or not.
In primary treatment we run all the way sometimes
from 25 percent up to 50, 60.
Again, if we are talking about trying to regulate
this with any precision and you are talking about these
water quality standards, where you have terms with a spread
like that, you do not have very much. I hope we will be
able to get at that possibly a little.
Are there any other comments?
STATEMENT OF LESTER KLASHMAN, DIRECTOR, NORTHEAST REGION,
U. S. DEPARTMENT OF THE INTERIOR,
FEDERAL WATER POLLUTION CONTROL ADMINISTRATION,
BOSTON, MASSACHUSETTS
MR. KLASHMAN. I am finished. I would just like to
make one thing clear though.
I would like to enter into the record a status report
on the Federal installations, and I have given to the Conferees
and the Reporter a list of the Federal installations in the
*
Merrimack River Basin and Nashua River Basin.
(The above-mentioned Status Report follows.)
-------
FEDERAL INSTALLATIONS IN MASSACHUSETTS - MERRIMACK RIVER CONFERENCE AREA
\
Discharge Quantity in GPP
254
Instn.lj-ation Agency Location
Army Housing Area
Research Annex
L.G. Hans comb Field
L.G. Hanscomb Field
Fort Devens
ReseETe-? Training Centei
Maynard Q.M. Text Activi
Q.M. Research &
Engineering Center
t*
Nike Boston Site 73CL&H
Nike Boston Site 83 CL&fi
Veterans Admin. Hospital
Parker River Hq. Unit
Parker River Rec. Area
Merrimack R. Lifeboat Sti
1
Army
Air Force
Air Force
Air Force
Aray :
Havy
ty Army
Army
Bedford, Middlesex Co.
Bedford. Middlesex Co.
Bedford, Middlesex Co.
Bedford, Middlesex Co.
""crt Devens. Middlesex Co.
Lowell, Middlesex Co.
Maynard, Middlesex Co.
Natick, Middlesex Co.
" ii ii
i
i
Lincoln, Middlesex Co.
ii
Rllfl •? nrr+<->n M-i /^/ll AO AV ' fr*
V.A. (Bedford. Middlesex Co.
i
Bureau of Sport
Fisheries&Wildlife faewburyport , Essex Co.
i
V V
i. Coast Guard
n
i
i
i
i
i
] \
I \
i i U
Sanitary Industrial
9.600
7sn
800,000
1.7«50.0on
900
13,500
23U.OOO
10,000
n QQQ
S , v w
2^0.000
600
75
1,100
- C
f
3.000 N
2.000 £
s? nnn
Discharged To Comments
Jround
I-rrmnri
let. District Sever
>hawsheen River
r.Tr\-\\f\e\
Ground
Ground
Natick Tovn SPVPT
.oVp Pp»r*V> *i ^V>no"f" ^
flyonnfl
Ornunfi
Potash Brook
Ground
Ground
Ground
feptic tanks & .leaching
ifelds: Plans are being
developed to tie into
Bedford Sewer System.
Septic tank & leaching
field.
goagulation. Aeration,
cum Removal & Settling
Tmhnff t.nnVs t.r. c^nfl "h»ds
Septic tanks & leaching
fields .
it
PVll /IT*! not or) P/~i/~i"l •? n rr rjo4-^-^
Septic tanks & leaching
field.
Primary settling.activatffll
sludge&leaching drain fleJds
Primary settling ? trickling
'liter, sec. settling, sand
filters , & chlorination
Septic tank & leaching field
3 pit privies
Septic tank & leaching field
-------
FEDERAL INSTALLATIONS IN NEW HAMPSHIRE - MERRIMACK RIVER CONFERENCE AREA
Discharge Quantity in GPP
255
instri.lla-cicn Ardency Location
Nashua Nat. Fish Hat.
ii
n
Franklin Falls Flood
Control Reservoir
tr
Blackwater Flood
Control Reservoir
ii
Fish&Wildlife Service
n
ii
Corps of Engineers
n ,
ti
n
Prop, without City Ident.
Hillsboro Co.
n
n
Franklin, Merrimack Co.
n
Webster, Merrimack Co.
tt
!
t
i
i \
Sanitary Industrial
200
150
600
1» people /day
300
k people/day
2,500,000
1
*
Discharged To Comments
Nashua City Sewer
Ground
Nashua River
Ground J
Ground
Ground
Ground
X
Jeptic tank & leaching field
Overflow water from fish hath.
sptic tank & leaching field
2 pit privies, used intermittaa
tly by visitors to the dam
Septic tank & leaching field
1 pit privy, used intermittent
ly by visitors to the dam
-------
256
Lester Klashman
The only Federal installation where we do have a
problem is the first one, which is the Army Housing Area
at Bedford, and in that case there are some septic tanks
serving some individual homes where the leaching fields are
not doing a proper job. Plans are being developed to tie
into the Bedford sewer system.
CHAIRMAN STEIN. When is that going to happen?
MR. KLASHMAN. We do not have a date. We will have
to get one and submit it for the record.
(SEE APPENDIX B)
CHAIRMAN STEIN. What would we have done if the State
came with an answer like that on one of its municipalities?
MR. KLASHMAN. We would have had to give them time to
get a date.
CHAIRMAN STEIN. I hope you do not expect reciprocity
on that one,-
MR. KLASHMAN. Thank you, Mr. Stein.
CHAIRMAN STEIN. Do you have anything, Mr. Healy?
MR. HEALY. No. I am having trouble keeping up with
these exchanges.
-------
257
Closing Statements
CHAIRMAN STEIN. Yes.
Let me try to get this in. If we have nothing else,
we have to try to get into the summary of this.
Possibly we have one thing to resolve. We have to
get a precise listing from both States and the Federal
Government of all the sources that we have listed here, with
the additions we have, and, at a minimum, the dates or the
type of treatment that we are going to ask for, i.e., both
industrial and municipal. Also I would suggest when financing
is to be arranged, final plans and specifications, start of
construction and complete construction. Is that reasonable?
I suggest we do that for everyone, including the Federal
installations — and there is just one that is outstanding with
a date — so we will have those dates for all people to see.
Now, in addition to that, as a writeup, at least in
the briefing memorandum to the Secretary, we will have to
come up with an explanation on the deviation from the dates
that we have had so far from the approval of the standards.
As I take it, the recommendations, certainly of the Federal
Conferee, will be to approve those that Massachusetts has
submitted?
MR. KLASHMAN. On Massachusetts I have no objection.
I would recommend that those dates be approved.
-------
258
Closing Statements
As far as New Hampshire is concerned, the dates that
they submitted with the standards which the Secretary approved
we think are good dates, with the exception of the dates that
he took exception to, and that was Manchester, Concord and
Plymouth.
CHAIRMAN STEIN. I wonder if we could come to an
agreement on that?
MR. KLASHMAN. I would like to have Mr. Healy talk
to this.
CHAIRMAN STEIN. How did the other dates run, generally
I mean, except for the other communities?
MR. KLASHMAN. They were consistent with Massachusetts.
In other words, the outside date I recall was 1974 or 1975•
MR. HEALY. The outside date was 1977-
MR. KLASHMAN. That was for Manchester, but for the
other communities
CHAIRMAN STEIN. Except for Manchester, Concord and
Plymouth, the other dates are to be completed in the early
seventies. Is that correct?
MR. KLASHMAN. It was before 1975 if I recall correctly.
Is that right, Mr. Pahren?
MR. PAHREN. Boscawen is 1975-
MR. KLASHMAN. My recollection is that they were all
1975 or less that the Secretary approved.
-------
259
Closing Statements
CHAIRMAN STEIN. Then the only three we have to do
I hope we can resolve this. If we can, what we can do is
resolve the situation for the enforcement dates. Also we
can make a recommendation whereby we can move forward, hope-
fully, by making a recommendation that the Secretary approve
the standards on the Merrimack for New Hampshire. Because
you cannot very well approve a date for the enforcement dates
without doing the other two simultaneously.
Now, we have the dates in the recommendation. Do
you have any suggestions or alternatives on the dates for
Manchester, Concord and Plymouth?
MR. HEALY I would like, if possible, Mr. Chairman,
to make a broader statement than just these three communities,
because there are many others in the watershed. In order for
you to achieve your objective and for us to likewise reach a
successful conclusion for the State of Massachusetts, which is
downstream, we ought to have some understanding of what the
whole program or what the target date for which we are shooting
for is.
We indicated in the submission of our water quality
standards that 1977 would see the completion of the Merrimack
River pollution control program in New Hampshire. As I said
this morning, in doing so we anticipated full Federal appropri-
-------
260
Closing Statements
ations, because our experience leads us to know that
communities will not proceed without their fair share of
all sources of funds. Now, there has already been a delay
in receiving funds at that level.
I might insert this, too, Mr. Chairman: That the
Secretary indicated in reviewing our standards that he would
like to see us shoot for 1976 as a completion time rather
than 1977> and we, in good faith, would like to do this. I
think we have suggested that if we possibly can meet the 1976
date we will.
Now, from what was said this morning, too, by many
of the spokesmen from New Hampshire, there is in process
legislation to begin a prefinancing system to assist us in
overcoming the difficulty and inadequate Federal funds. We
would like to add here to the original time schedule. In
fact, we think we must do so. We think even with prefinancing,
if we can assume it is enacted by the Legislature, that this
will be required to satisfy those initial dates.
What I am saying is I think we ought to stay with
the 1977 dates for the whole watershed. If we can make it in
1976, fine. If we Well, I will not make any further
guesses, but I think that is where we stand.
We have examined this schedule with the State of
-------
261
Closing statements
Massachusetts authorities. So far as we are aware, they
are quite satisfied with the New Hampshire submission.
If I can leave it at that point, I would like to.
I would say, too, that as far as Plymouth is concerned,
we had suggested in our original submission that the necessity
for secondary treatment at Plymouth is not compelling. We
want secondary treatment in all sources of pollution as a
necessary item to make our waters as clean as possible, but
we have got to also utilize our funds to the greatest advantage,
We thought that Plymouth could be delayed for some long time
into the future, but the Secretary, apparently, does not agree
with us in this matter. So it has been inserted now in the
record, and I suppose we will have to take that into account.
I could add, Mr* Chairman, we have in the legislation
now in process included four communities in this watershed for
special prefinancing by the Legislature. Those are Nashua,
Manchester, Concord and Plymouth. Does this help any?
CHAIRMAN STEIN. Yes. We do not have a problem on
the date in Nashua.
MR. KLASHMAN. The Manchester date we had was 1974.
Bo I understand what you are proposing is that the completion
date for Manchester would be 1976?
MR. HEALY. We said 1977.
-------
262
Closing Statements
MR. KLASHMAN. I know you said 1977, but you said
you thought you might be able to do it in 1976.
MR. HEALY. Yes. BUT; we said that not only for
Manchester but the entire program.
MR. KLASHMAN. But what we really have to come up with
is Concord and Manchester. On Manchester what would be the
date for final plans and specs in starting construction?
MR. HEALY. Right now, as was indicated to you by
Mayor Mongan this morning, there is a question about the
engineering fees as to what is a fair fee. This, incidentally,
involves the preparation of final plans and specs for the
initial project.
MR. KLASHMAN. When do you think, though, that they
will be done?
MR. HEALY. I would think, being as optimistic as we
can, we should still say 1977 for Manchester, with the rare
possibility that 1976 might be in prospect if we get pre-
financing .
MR. KLASHMAN. What would be the date of final plans
and specs?
MR. HEALY. For this initial phase, I think that the
final plans would be completed in 1970.
MR. KLASHMAN. So that would be December 1970. What
-------
263
Closing Statements
about starting construction?
MR. HEALY. They would start construction then on
the first project, which would be completed by 1972.
Now, we had anticipated
MR. KLASHMAN. Excuse me. The first project for
Manchester, what would that consist of?
MR. HEALY. This would consist of the primary
treatment facilities and the first phase of the interceptor
program, but we want to incorporate the design of the
secondary treatment along with the primary system because
we think that is the best way of proceeding.
MR. KLASHMAN. That would be done by 1972?
MR. HEALY. This first phase, yes.
MR. KLASHMAN. I mean the construction would start?
MR. HEALY. Would have to begin in 1971.
MR. KLASHMAN. 1971?
MR. HEALY. Yes.
MR. KLASHMAN. And it would be done in 1972?
MR. HEALY. 1972. That is what we have discussed
with the city, and I think we have assured your office of
this.
*
MR. KLASHMAN. In other words, by January 1971, it
would start, or I guess it would be
-------
264
Closing Statements
MR. HEALY. Well, probably a little later on.
MR. KLASHMAN. Probably May of 1971?
MR. HEALY. April or May of 1971.
MR. KLASHMAN. It will be completed when?
MR. HEALY. By the end of 1972.
MR. KLASHMAN. That is primary. That is the first
project. What is the second project?
MR. HEALY. Then you begin a long or a series of
several projects to complete the interceptor system. We
have the notion that it is far better to invest the money in
primary treatment and complete interception for the city
sewerage and industrial waste problems and, therefore, place
all waste under treatment, a minimum level of treatment,
rather than to focus attention to getting secondary and still
be treating only a very small portion of the flow.
MR. KLASHMAN. Your second phase then, when will the
interceptors be done? The completion date I mean.
MR. HEALY. I would have to look this up.
MR. KLASHMAN. I just want to get one thing. The
third phase would be the secondaries. Is that right?
MR. HEALY. The secondary, we think, is the last
thing we do.
Mr. Lacava is the Chief Engineer for the Commission.
MR. LACAVA. The secondary phase will not be constructed
-------
265
Closing Statements
until after the city is under full primary treatment.
CHAIRMAN STEIN. As I understand this — let us try
to work this out — if your philosophy is that you are going
to have primary treatment in,.you will have primary treatment
in by the end of 1972, at least as to Manchester?
MR. HEALY. We will have the primary treatment plant
built. That is, the beginning of the primary treatment. It
will not all be built at one time.
MR. LAVACA. It will be up to a capacity of 20 million
gallons.
MR. HEALY. Twenty million gallons of the initial
project and the final is 40 million gallons.
CHAIRMAN STEIN. When will that be done?
MR. LACAVA. It will all be done by 1977-
CHAIRMAN STEIN. The primary by 1977?
MR. HEALY. No. We are talking about the complete
program.
CHAIRMAN STEIN. When will the primary program be
completed in Manchester?
MR. LACAVA. The 20 million plant will be completed
by 1972. That will be built along with the first phase
interceptor.
, MR. KLASHMAN. What is the flow now?
-------
266
Closing Statements
MR. LACAVA. Something in the vicinity of 16 million.
MR. KLASHMAN. That will take care of the immediate
problem. The 40 million is for the future?
MR. LACAVA. les.
CHAIRMAN STEIN. In other words, you probably will
have to build more interceptors, but you feel that by the
end of 1972 in Manchester you will have relatively the complete
flow — and I am not talking about stormwater — the complete
flow interceptor and primary treatment?
MR. HEALY. No.
CHAIRMAN STEIN. How much will go in bypassing the
plant by the end of 1972, dry weather flow?
MR. LACAVA. This is just an estimate, but I submit
that probably six to seven million will be under treatment
at that time. It might go as high as 10 million.
CHAIRMAN STEIN. In other words, about half your flow
will be handled by 1972 and the other will not?
MR. LACAVA. That is true. There is a question of
more interception you see.
CHAIRMAN STEIN. I understand that. If I understand
your theory correctly, you want to get all this stuff under
primary treatment but you are only putting half of it in.
I do not quite follow this. If we are going to go along with
-------
267
Closing Statements
this theory
MR. LACAVA. It is no theory, Mr. Stein. It is
just a matter of funds and capacity to meet
CHAIRMAN STEIN. No. No. I did not mean the theory
in the sense that you are going ahead with the theoretical
operation. If your philosophy is to get a whole city
covered with primary treatment and put in secondary treatment,
this may be a line of approach that I wanted to explore. But
if what we are coming up with is just half the city flow
being given primary treatment, then really we are not following
through on that, are we?
MR. HEALY. I think you misunderstand.
What he is saying is the first project and the reason
we had to approach it in this fashion was because of the
relative amounts of- Federal aid that we received dictates
that if we are going to have more than Manchester under way
at any one time, well, we have got to not funnel all the funds
at that point and leave others destitute of the system. So
we have to try to keep work going in different watersheds.
As has been indicated, 1972 would see about half the flow
under treatment.
Then we continue right on with one project following
another to extend the interceptor system to pick up other
-------
268
Closing Statements
increments of the flow so that by, approximately, 1975 we
will have everything under control as far as
CHAIRMAN STEIN. Primary?
MR. HEALY. primary treatment is concerned.
CHAIRMAN STEIN. In other words, what you are going
to do is put in the primary facilities, and let me see if I
can state this, primary facilities to handle your present
flow — that is, without the expansion — by 1972. But
because of the interceptor problem, only about half of that
will receive primary treatment in 1972. You do not expect
the primary, the interceptors, to be completed until 1975 when
the whole city should be getting primary treatment. Is this
a fair statement of what you are doing?
MR. HEALY. That is correct. Then we would go right
ahead at that point with construction of secondary treatment
and complete the entire project by 1977-
CHAIRMAN STEIN. All right. Now, how do you expect
to do this in Concord? Is that about the same? ° 9cf
MR. KLASHMAN. No. Concord is less.
CHAIRMAN STEIN. You had less time?
MR. KLASHMAN. I think they did, too.
MR. LACAVA. Concord is already behind schedule
because of an intercommunity difficulty at the Boscawen-
-------
269
Closing Statements
Concord line and due to the fact that there is a common
industry there, a tannery operating within the confines of
both communities. I think this question has been resolved.
I think they will be going into plans and specifications for
that section of town immediately. These plans and specifica-
tions should be completed within a year and
MR. KLASHMAN. So that would be 12/69?
MR. LACAVA. Yes, that sounds reasonable. They
should go into construction the following spring.
CHAIRMAN STEIN. Do you have the same kind of inter-
ceptor problem at Concord? When you finish your primary
plant in Concord, will you be receiving substantially all
of the city sewage in the system? Is it the same kind of
problem that you have, in Manchester?
MR. LACAVA. No, it isnft. This is a two-system
setup. The system I am speaking about is at the north end
of the community serving the town beside Concord. That
will be completed within two years.
MR. KLASHMAN. In other words, they start construc-
tion April, 1970, and they will be done by December of 1972?
MR. LACAVA. Yes, assuming, of course, that there
are funds available.
CHAIRMAN STEIN. No. We understand that assumption.
\
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Closing Statements
What I am getting at, Mr. Lacava, is how much of the waste
from the sewe raged population in Concord will be served by
•\
that plant in 1972 when it is completed? Will you cover it
all?
MR. LACAVA. No, not at all.
CHAIRMAN STEIN. What percentage will be covered when
this plant is finished?
MR. LACAVA. Because of the industry, which is a
wet industry, a tannery, I'd say perhaps 40 percent - 30,
40 percent.
CHAIRMAN STEIN. How will you pick up the rest of the
waste? Are you going to have to build another plant or more
interceptors?
MR. LACAVA. Yes, there will be more interceptors
at the south end of the town.
CHAIRMAN STEIN. You are going to pick up 40 percent.
How much more of the waste will go into the first plant that
we are talking about with the interceptors when you finally
get completed? In other words
MR. LACAVA. There will be no more, sir. There will
be just the 30 or 40 percent.
CHAIRMAN STEIN. The south plant will take care of
60 percent of the waste. Is that right?
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Closing Statements
MR. LACAVA. Right.
CHAIRMAN STEIN. When will that be completed?
MR. LACAVA. I really do not remember what the
schedule is for the remainder.
v^
MR. HEALY. I would have to look at it, too.
CHAIRMAN STEIN. That is just primary treatment,
right, so far that we are talking about?
MR. LACAVA. Yes.
CHAIRMAN STEIN. When you intend to put secondary
treatment in Concord, are you going to have two secondary
treatment plants—one at the north and one at the south end
of town?
MR. LACAVA. That will be necessary.
CHAIRMAN STEIN. This is as far as we can go.
In Plymouth what is your situation when you build
your primary treatment plant?
MR. HEALY: They are building that now.
CHAIRMAN STEIN: When will that be completed?
MR. HEALY: It should be completed next fall.
CHAIRMAN STEIN: Next fall in Plymouth, how much of
the town will that cover?
MR. HEALY: Ail of the town. The town has a lagoon
serving a small portion of the community, probably less than
\
20 percent and the remainder is going to be treated in the
plant that is under construction now.
\
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Closing Statements
MR. KLASHMAN. Mr. Healy, the date in the standards
for Concord was December of 1975. That was the date that
you had proposed. That was for secondary?
MR. HEALY. That was for secondary.
MR. LACAVA. That sounds very much like it.
MR. KLASHMAN. So do I understand that when you
buildjthe south end of the town, is that going to be a
secondary plant or is that going to be a primary plant,
too?
MR. HEALY. The initial proposal was for a primary
treatment plant. Now, of course, we have had to modify those
plants to include secondary.
MR. KLASHMAN. So, ultimately, the December 1975.
date is secondary?
MR. HEALY. Those four communities I referred to -
Nashua, Manchester, Concord and now Plymouth because this
has been an added requirement - are all going to have to
be secondary plants.
MR. KLASHMAN. Let me just make sure I understand
now. The Concord, the north end primary plant, that first
phase in the north end plant, is that going to be a secondary
plant or primary?
MR. LACAVA. The first phase will be primary.
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Closing Statements
MR. KLASHMAN. And that will be the 12/69 and 1972
dates that you gave, completed by 1972. But by December of
1975 you will have completed secondary for the north end and
for the south end of town?
CHAIRMAN STEIN. In Concord?
MR. KLASHMAN. Yes, that is the date.
MR. LACAVA. That will have to be —
CHAIRMAN STEIN. December of 1975?
MR. KLASHMAN. Yes. And the dates for planning and
starting construction will have to be worked out.
CHAIRMAN STEIN. The date is for 1975 in Concord
for secondary.
What is the last date for secondary, December 1975»
in Plymouth?
MR. KLASHMAN. That is Concord. Plymouth I did not
not get the dates.
MR. HEALY. There was never one established for
Plymouth.
MR. KLASHMAN. What would they be? Do you think you
could meet December of 1975?
MR. HEALY. If the Legislature accepts our proposal.
MR. KLASHMAN. Could you start in 1975?
MR. LACAVA. The planning could start.
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Closing Statements
MR. HEALY. The planning could start, but not until
1970.
MR. KLASHMAN. By April of 1970?
MR. HEALY. Yes.
MR. KLASHMAN. And it could be finished in Plymouth
by December of 1972, right?
MR. HEALY. Yes.
MR. KLASHMAN. And the plans and specs would be done
by December of 1969?
MR. LACAVA. We would need more than eight months.
MR. KLASHMAN. Why not leave it December 1975.
MR.HEALY. I would think so.
CHAIRMAN STEIN. When is the completion date of the
secondary?
MR. KLASHMAN. 1972 for Plymouth.
CHAIRMAN STEIN. On secondary?
MR. KLASHMAN. Yes. In other words, he is doing
better than what we had recommended.
•
CHAIRMAN STEIN. December of 1972?
MR. KLASHAMAN. Yes.
MR. HEALY. All of this we are saying pyramids here,
because this is all based on the Legislature doing certain
things.
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Closing Statements
CHAIRMAN STEIN. Let me say we recognize this. It
is the same as the problems that they have in Massachusetts.
Let us do this: We are setting the tentative plans
and we will give in the Summary the notion of what you have
to have, certain prerequisites, in your opinion, of legislative
financial action.
In Plymouth we are sure to have the secondary facility
built by December of 1972; in Concord by December 1975- Is
that correct?
MR. KLASHMAN. Yes.
CHAIRMAN STEIN. The only one we have to arrive at
is Manchester, and I think you talked 1975.
MR. KLASHMAN. No. We had 1974.
CHAIRMAN STEIN. He had 1974. You had 1975-
MR. KLASHMAN. He had 1977.
MR. HEALY. 1977, yes.
CHAIRMAN STEIN. Do you think we can make that with
a prayer, December of 1977, and let you work these dates out
on the other three and set this to rest with your
MR. KLASHMAN. I think he can accept the 1976, and if
Massachusetts has no objection with what he has to do, I
would be willing to recommend that we accept it.
MR. LACAVA. They are talking about a $20 million
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Closing Statements
plant, Bill, and there are many problems in that city.
These problems take time to resolve.
MR. HEALY. I am willing, with the appropriate
reservations, to attempt to make the 1976 date in Manchester —
but I am doing it with tongue in cheek 1'
CHAIRMAN STEIN. We recognize that. I think we are
going to have to have several things here. Let me try to
summarize this.
The Conferees, we will come up with a time schedule on
what has to be done with cities and industries. We will indicate
New Hampshire reservations - that it has to be contingent in
New Hampshire on legislative action by the State Legislature
and the provision of financing. We also will indicate that
this is a very complex problem.
I would hope that we would get these dates, and I will
say I am just giving the conclusion of the last date:
For Plymouth, December of 1972.
The secondary treatment of Concord, December 1975-
Manchester, December of 1976.
I think, in order to work this out, and we have had
this in other areas of the country and I want to suggest this:
That what we are going to have to do is plan on about a six-
month progress meeting where the States and the Interstate
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Closing Statements
Agency will come in and report to everyone in the Federal
Government on developments. As we go along, we will be
able to mark more and more industries and cities completed.
But we will have to make refinements and adjustments in the
dates or recommendations, because I do not know if the
Secretary is going to accept it, and I surely do not know
the next Secretary. But we will have to make recommendations
the way we made it in Massachusetts on these dates.
The reason I say this to get started, and I state it
candidly, he had one that he is two years behind. I do not
think there is any point in belaboring that; but I think we
have to get a frame of reference to set this up community by
community so we know what we are doing.
MR. KLASHMAN. That is what I wanted to find out,
what Massachusetts has to say.
CHAIRMAN STEIN. Yes, both States, because we are in
agreement with this.
MR. HEALY. Before you consult with Massachusetts —
and I want it to be taken in the proper spirit, because it is
intended in the vein of cooperation and not to frustrate
anybodyfs efforts; and I think we all have to be on the same
wave length here, we here; and I am sure if you attended any
of our legislative hearings you would see what I mean — the
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Closing Statements
State reels that this is a three-party obligation, State,
Local and Federal. Now, we are going to make our very best
effort to obtain prefinancing because of the inadequacy of
Federal funding, but we regard that as an obligation. If
we are unsuccessful, the only alternative that we see -- and
it is not very palatable to us — is a slowdown in the program.
We know that that does not help anybody, because, as
you said this morning, Mr- Chairman, the costs are increasing
all the time and we do not want any delays because it just
meai. ; more expense for everyone. But that is the ultimate,
and we might as well face it — that if we cannot obtain pre-
financing, then we are going to have to consider a change in
the schedules. This has already been recognized by our people,
by Mr. Edwards and others at that level; and -nch as we dislike
the prospect, there it is. This is not, however, going to make
us deviate from a real strong effort for prefinancing this/y^ ,
session.
MR. PELOQUIN: I was going to add, Mr. Chairman, along
this line that I would like to suggest that the Summary show
the State and Interstate Conferees urged Federal support of the
appropriations in the full amount as authorized for construction
purposes.
CHAIRMAN oTElN: That will be done, but under law we
cannot do that.
MR. KLASHMAN: Do I understand, Mr. Peloquin, that you
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Closing Statements
have no objection to the differences in the dates between
Massachusetts and New Hampshire?
MR. PELOQUIN: I do not object to the dates. They are close
enough. There is only one community here, Manchester, where there
is a gap - the largest gap of any community. I think this is
something we can live with.
MR. KLASHMAN: And you, Mr. McMahon?
MR. McMAHON: Mr. Chairman, if Mr. Healy believes he can
meet these dates and he is convinced that this program can move
along, I certainly would agree.
"ow, I would just certainly like a little confirmation on
this. I think what we are doing here is perhaps trying to compromise
on something that is maybe unrealistic, and I think we would be
doing everyone a disservice if we »**«» ^oing that. I would go back
to Bill Healy and say that if this is unrealistic, perhaps, we
should look at it a little more.
This is probably something the Secretary would accept, but —
CHAIRMAN STEIN: Well, let me try to do this: I do not
think this is done in a spirit of compromise. We know the way the
various laws are written. Goodness knows, I wish we would implement
all the laws.
Now, the question here is we have an enforcement date and we
have to have standards. With these things not approved, we find an
inhibition of moving ahead in getting a grant and so forth. I do not
thi'pk you have that prrblcr in Massachusetts vis-a-vis New Hampshire.
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Closing Statements
We do have that problem in New Hampshire.
Now, operating on this in good faith and what we can stand,
I think what we need is a base line to move from. I think that in
the absence of that base line we are going to have certain things
not resolved. Now, I do not think that helps either the Federal
program or the New Hampshire program until that is resolved. I
think we have a formula where we have a good chance of getting this
resolved with the notion that we are going to have, as we had with
your program, even when it was resolved, periodic meetings to make
adjustments in those dates as you have problems.
Now, unless we resolve it there may be a technical limitation
on eligibility of certain communities for maximum grants in
Massachusetts in certain cases, and unless we update
MR. McMAHON: I agree with New Hampshire statement.
CHAIRMAN STEIN: All right.
Briefly, do you have another point?
MR. KLASHMAN: Yes, there are three other communities that I
wanted to discuss before we leave the schedule.
CHAIRMAN STEIN: All right.
MR. KLASHMAN: I understand that Pembroke and Alienstown
were not in the original standards submission but that they are
sources of pollution?
MR. HEALY: They are on tributaries.
MR.KLASHMAN: They are not on interstate streams?
MR. LACAVA: They are on the Suncook River. That has
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Closing Statements
not been declared an interstate stream.
MR. KLASHMAN. That does not affect the main stream?
MR. HEALY. This was reviewed with your office.
MR. KLASHMAN. Do you have any comment, Mr. Pahren?
MR. PAHREN. No. We have not made any changes, Bill.
The information you sent to us on March 15, 1965 $ indicated
that there were sources of pollution to the Merrimack and
our staff has seen the pipes.
MR. KLASHMAN. What do you mean? Do they discharge
to the Merrimack or Suncook?
MR. PAHREN. Merriraack.
CHAIRMAN STEIN. Well, we have had this before. Let
me suggest the solution that we have worked out with the
Great Lakes States here.
This is a factual situation. Obviously, sitting in
the room we can't resolve this. I think the areas we had
today were expanded on by Mr. McMahon with several sources
he did not list before. I would suggest that to get this
program under way and get these rough edges down - and we
always come to this point - between now and the next few
weeks, hopefully before the next progress meeting, come to
>
a factual determination on whether they should be included or
not.I I am sure there will not be a difference because I
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Closing Statements
never heard of one of these factual things that could not
be resolved by the technical staff. But if there is we can
hear the different points of view.
MR. KLASHMAN. If these are intrastate, then we have
no concern.
MR. HEALY. Both of them, I can say this, Mr. Chair-
man, have completed their preliminary planning. They are
in the process of getting final plans and specs under way.
So they are both going to have projects, anyhow.
Now, the exact status of whether they should be in
the interstate package or intrastate, they will be in the
program.
MR. KLASHMAN. But' in the early part of 1970?
MR. HEALY. I wish you would not keep prompting me.
MR. KLASHMAN. What I meant is those are not 1977
projects.
MR. LACAVA. Well, they will be no later than 1977.
CHAIRMAN STEIN. I think those communities will be
waiting for «, le first list. I know that the engineers love
to dissect BOD's, but let us try to get out if we can.
MR. KLASHMAN. One other thing. On the Hudson there
were some dates where the final plans were supposed to be
done in August of 1968 but that was not met.
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Closing Statements
MR. HEALY. They are a special case.
MR. KLASHMAN. Will you be able to submit new dates?
MR. HEALY. I think we will be able to put in new
dates. There is a question whether they are going to connect
to the city of Nashua system or build a plant of their own,
but there is an engineering study under way.
MR. LACAVA. They should be in now but it isn't.
It is overdue.
CHAIRMAN STEIN. We will do this, but again I think
this list system will handle this.
Let me again say, for those people that are not familiar
with this, that in dealing with waste pollution it is something
like going to the zoo. When you go to the zoo two days in a
row you never see the same animals because some die and some
are born. You have the same thing here, the situation always
keeps changing.
Now, unless we get a firm, basic list at this stage
that we can go over, with a boxscore, and we go down the roll
and where there are changes they will be noted, we will be
spending a lot of time going around and around. I think once
we get that boxscore lined up, not only the technical people
but the other people will be able to judge progress - judge
what,the regulatory agency, State, Federal and Interstate are
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Closing Statements
doing, what the communities are doing, what the industry is
doing and then this will become clear. But, as in many games,
v
you cannot tell the players without a scorecard. I think our
next job is to get that scorecard laid out abundantly clear,
so when we come in next time we will be able to follow it.
Now let me go down these other comments very briefly
because I think there was agreement. I do not know how far
we are going to do this.
Are we in agreement that both States and the Merrimack
system on issue 1 will require that sewerage systems, with
collection sewers terminating in adequate treatment plants,
shall be provided in those areas along the stream where sewers
do not now exist and where homes discharge either raw wastes or
septic tank effluent to the watercourse and where local treatment
facilities will not suffice? How are we going to follow up on
that? Do we get a report on activities on that or is that just
a pious statement?
MR. McMAHON. I think we made the statement earlier,
Mr. Stein, that as far as every one of these recommendations is
concerned, other than No. 13, we consider these as an inherent
part of our program, or that there is an appropriate agency in
the State that is handling this. Everything except No. 13,
which is the situation involving a boat pollution control law.
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Closing Statements
CHAIRMAN STEIN. Well, I find it difficult, unless
we are going to assign a task group and unless these are just
statements of policy, to come up with a report on these.
How are we going to know what these mean? What are these
meant for
MR. McMAHON. I would say these are statements of
policy, because, as you know, it reads: "Consideration shall
be given in the water pollution control program as necessary
to the following." I think you do agree with this, Bill, in
New Hampshire as a matter of policy.
MR. HEALY. Yes.
MR. McMAHON. But as far as a task force, I think this
would be completely unnecessary.
CHAIRMAN STEIN. I have no objection to that. I want
to clarify a few points, then, on this. I raise this now so
we will not get into difficulties or squabbles later, because
this can be one of the most vexing things. We have to make a
judgment, it seems to me, all municipal and industrial waste
in the Merrimack River Basin ought to receive a minimum of
secondary treatment or equivalent.
Now, the question is, what do we mean by "secondary
>
equivalent?" From the discussions here, I take it that you
both mean that "secondary treatment" means a minimum of 90
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Closing Statements
but it could be designed on the 85 percent level.
MR. HEALY. If you are questioning the design, if
you think this is the time to raise this issue, if you think
the filter is undersized, the time is when it is planned.
But I object and I want the record to show my objection to
any 95 percent efficiency level as being a general requirement.
CHAIRMAN STEIN. No, this is not a general requirement.
The point is what lawyers talk about, the term of "burden of
proof."
If you come up with a design less than 90 percent, the
question is going to be asked or the burden of proof is going
to be on the State agency to indicate why less than a 90 per-
cent plant is appropriate. By the same token, if the Federal
Government, when a plant comes in and they say, as I doubt
they ever will, they want 9# and 99 percent, I think the rule
that they use is the burden of proof is on us to present to
you why that extra stuff is needed. This does not mean that
you cannot have plants above or below 90 percent, it is just
the question of when you ask the question.
Let us move on, because I think we have done this
enough. Let me ask just one question. This is No. 4. When
you say, "All effluents containing domestic wastes are to
receive adequate disinfection," does that mean year-round
disinfection?
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Closing Statements
percent reduction of BOD, unless it can be demonstrated in
a particular plant that the water quality of the stream will
be met at something less than that, as authorized for that
community. But the justification otherwise
MR. McMAHON. We phrase it somewhat differently in
the sense that we say "secondary treatment is #0 to 95 percent
BOD removal," and in that range whatever is necessary to meet
the water quality criteria. In other words, if you need 95»
you put in 95-
CHAIRMAN STEIN. I see. At least 90?
MR. HEALY. Do you do this as a tertiary treatment
effort?
MR. McMAHON. We have not tried to associate, Bill,
tertiary treatment with BOD removal.
MR. HEALY. We are speaking specifically of the
conventional primary and secondary treatment?
MR. McMAHON. Yes.
MR. KLASHMAN. I think what you said is more or less
what I said, I feel, Mr. Chairman.
CHAIRMAN STEIN. I want to get at an operating judgment
on this. I have no brief or any formulation on this. What I
want to do is set up a ground rule so we do not get on these
interminable squabbles.
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Closing Statements
The notion that I have said is "If you have;" and
the way I put it is "If you have less than 90." Then if
anyone asks you for an explanation, you should be able to
give the explanation. Under your system, you would give
an explanation in any case up to 95» from 80 to 95•
Now, the notion as far as the ground rule — and I
know this from sad experience in dealing with our technical
people — if you are providing 90 or more, I think the burden
will be on the Federal people to indicate why that is not
enough. If you are providing less than 90 and they ask why,
I think that part of your operation will facilitate things if
the State can give us a reason why this is the case and that
it is protecting water quality standards.
If that is satisfactory, we will move on. That is a
procedural operation. Just on that, is that agreeable?
MR. HEALY. I do not want to get into any long-winded
debate on it. What we intend to do is have secondary facilities
at these locations and operate them to the very best of their
ability, their capacity, properly size them so they take care
of present and future loads and then get the maximum effort
out of the plant. Whether it is BO or 95 percent is really
unimportant, because if it is 86 percent and your goal is 90
percent, well, you have failed. I do not think this is what
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we are talking about.
I think we are going to operate these facilities to
the very best of our ability. In fact, if we do not, then
the communities that are being assisted^ will be deprived of
their State aid.
MR. KLASHMAN. Could we say it in another way? What
we are talking about, really, is that activated sludge
facilities would be put in for communities requiring them,
and in those cases where you had special cases where activated
sludge was not indicated, where you went to a lesser degree of
treatment, there would be a reason for that. But, in general,
like at Manchester
MR. HEALY. Well, you have the situation that Tom was
pointing up - the deficiencies depending on the season of the
year. He spoke of trickling filters, that they are not as
satisfactory in winter operation as in warm-weather operation.
MR. KLASHMAN. We are talking about a design. If a
trickling filter plant is designed properly, it is capaole
of achieving 35, or at least that is what we have found.
MR. HEALY. Right.
MR. KLASHMAN. However, if it is not designed properly,
you cannot get the £5.' What we are saying is that in those
cases where you are going for activated sludge it will be
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Closing Statements
designed for 90 percent at least, which is what they are
capable of doing. In those cases where you go in for not
activated sludge because the size of the community is such
that you feel
MR. HEALY. A lagoon, for example?
MR. KLASHMAN. Well, a lagoon or trickling filter
plant is indicated because of the particular situation, that
there you would go for maybe a design of #5» This is what
we are talking about.
I recognize that when you get down to the operation
that we have another problem. Even if you design it for #5»
we are going to have a problem of getting up to that.
MR. HEALY. You are right. The treatment has to be
tailored to meet the need. There is no doubt about that.
But that selection is going to be made at that very outset.
Then your system, you are fixed, and you have to be careful
in the capacities that are built into the plant so that you
are going to be able to accommodate to yourself the present -
and future loading.
MR. KLASHMAN. So what Mr. Stein said was that by
secondary treatment we were talking about 90 percent except
in those cases where the State standards could be met with a
lesser degree.
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Closing Statements
MR. HEALY. Are we going to start speaking in terms
of plant deficiencies, too?
MR. KLASHMAN. We are talking about the design of it.
MR. LACAVA. Does Mr. Stein mean that we are all going
to have activated sludge plants?
CHAIRMAN STEIN. V/ait. Wait. All I tried to do here
was try to get an operating rule understood by you fellows
to facilitate the grant applications. The reason I brought
this up is to try, at the beginning, to do away with the
problems we have had in other cases with the question.
Now, presumably we are not together on this, and I
will just let a few cases come up. If they are then not
resolved you will be looking for a rule. As far as I can
tell, what are people to do if you put in a grant or put in
an application for a construction grant? As far as I can see,
what our people do, they are supposed to have 90 percent, and
if you have 90 percent treatment and everything else is okay,
to let it go by. If there is less than 90 percent they will
probably ask for an explanation.
We do not have to put this down, but I am telling you
that that is what is going to happen. This is necessary for
the operation. I think" everyone here is in agreement on what
we are doing is just a question of a mode of operation that is
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Closing Statements
going to happen anyway. So let us go on with this.
MR. LACAVA. I would like to add one more thought.
What the Chairman just said is completely incompatible with
what Mr. Klashman said.
CHAIRMAN STEIN. I do not think so.
MR. LACAVA. He said 90 percent is activated sludge,
85 percent is trickling filter.
Is that not what you said? f
MR. KLASHMAN. Yes. What I just said
MR. LACAVA. Let me finish my statement.
If 90 percent is the cutoff level, the level at which
questions are going to be asked, and this is going to be used
for a basis of design, well, the trickling filter is ruled
out as a device.
MR. KLASHMAN. No.
MR. LACAVA. This is what it means* Please clarify.
MR. KLASHMAN. What I understood Mr. Stein to say is
if your standard, if the river quality could be met with a
trickling filter, you know — and this is going to be on the
smaller communities, of course — that you would design that
trickling filter plant.
What I was saying was you would design that trickling
filter plant on 85 percent. You could design it on 75 or 80,
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Closing Statements
MR. KLASHMAN. That is what we meant.
MR. HEALY. In New Hampshire it means year-round
disinfection.
CHAIRMAN STEIN. In Massachusetts?
MR. McMAHON. In Massachusetts it is a policy within
our State In fact, it is not a policy. It is within
our standard of quality approved by the Secretary. It indicates
that the Division may approve seasonal chlorination rather than
year-round chlorination.
CHAIRMAN STEIN. Let me ask the next question for
clarification, and I do not have many more on this.
What does "Maximum removal of nutrients, including
phosphates" mean? Does that mean that we are going to require
something like chemical treatment in addition to the ordinary
sediment treatment?
MR. KLASHMAN. No. Do you want to let me finish?
CHAIRMAN STEIN. All right.
MR. KLASHMAN. What that means, in this initial phase
it does not mean we are going to require something beyond an
activated sludge plant which, properly operated, can remove
sludge, but that in those cases where phosphate removal
becomes necessary in the future, then it will be required.
Thi? is what we are saying.
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Closing Statements
MR. PELOQUIN. Mr. Chairman, I think we are going
beyond the intent of the second session of the conference.
I would like to read a section or a paragraph from the
Secretary1s letter calling the conference. The Secretary
says, "I believe it necessary to set compliance schedules
that are more compatible with the intent of the Enforcement
Conference and with the approved Massachusetts schedule."
This is what we have done. And the recommendation,
I concur with Mr. McMahon, that the report will define
nothing.
I feel also that the States have submitted implemen-
tation plans which will achieve the classifications which
have been approved. There are additional considerations here
included in the recommendations, and these additional considera-
tions, for the most part, are standard procedure in the
policies and routine activities of the State Water Pollution
Control Agencies and I do not think it is necessary to take
these item by item.
We agreed that we will consider these in all of our
activities, but the intent of the conference, as specified in
the Secretary's letter, was to reconcile the dates. I think
we are going beyond that at this point.
MR. LACAVA. Mr. Chairman, there is also
-------
295
Closing Statements
CHAIRMAN STEIN. Just one moment. One at a time.
The point is that you know that the Secretary is my
boss and I read his letters, too.
In the letter to Governor King he said, "While the
primary attention may be placed on time schedules, as I have
discussed above, these sessions will provide an opportunity
to review the entire situation."
I think that is clear. We are not taking up every
point. If this is standard procedure, we sure do not have
an agreement on the standard procedure. I think the issues
that we are making here, making at the conference, are very,
very clear.
Now, the last one, a very small one, is just a case
in poiD* -*»d that is if Massachusetts does not suspend chlorin-
ation during the winter - and I think this is in the record -
that this in their program and a view from us is not in order
unless that is specifically taken up.
Now, in view of the Governor1s letter to Secretary
Udall and considering when the past situation is to be
reviewed, if you believe that statement and your view prevailed,
you would have saved us all a lot of time without waiting
until now to make your comments. I also believe Mr. Peloquin,
that if you wished to make that comment, that it was pertinent
-------
296
Closing Statements
early this morning when Mr. Pahren read this statement.
MR. PELOQUIN. It was our understanding at that time
that these were being presented for consideration and only
for consideration and were not to be made a part of the
SecretaryTs recommendations nor a part of the standards,
which apparently is what is being attempted here.
MR. LACAVA. It does appear here, Mr. Chairman, that
you are forcing commitments over and beyond what were intended.
CHAIRMAN STEIN. What commitment have I forced?
MR. LACAVA. You threw in a 90 percent in there, and
I do not see that anywhere in here.
CHAIRMAN STEIN. Mr. Lacava, let me repeat this and
repeat this very plainly: Mr. Klashman and I have consistently
said we are not asking for 90 percen* necessarily. If we
say that over and over and over again and you still persist
that we are asking for 90 percent, I do not know what we can
do.
MR. LACAVA. I think you have made the record clear.
You are not asking for 90 percent?
CHAIRMAN STEIN. That is right.
MR. LACAVA. No, you said it.
CHAIRMAN STEIN. "Not necessarily," that is right.
But if you
-------
2S7
Closing Statements
MR. LACAVA. You said, "Not necessarily"?
CHAIRMAN STEIN. Right. If you are going to ask for
than 90 percent, you may very well be asked why. That
is all we have said.
MR. HEALY. That is really, Mr. Chair-in ~ and I do
not intend to irritate you — in effect, you are saying, I
think, that if we are not seeking 90 percent, that we should
be prepared with an explanation?
CHAIRMAN STEIN. Right.
MR. HEALY. Then if that is so, then the 90 percent
is a standard?
MR. LACAVA. Sure. If it is 90 percent in each case,
is this what you mean, Lester?
MR. KLASHMAN. The point is we have two States involved
here down in the Massachusetts part of the basin, both in the
Nashua River and in the Merrimack. V/e are talking about in
most of the larger communities 90 percent. As a matter of
fact, in Fitchburg they are talking about 90 to 95 percent.
In Manchester, which is your largest community, we are talking
about an activated sludge. Is that what you are talking?
MR. LACAVA. We are not even sure, Lester, and I do
*
not see why through a conference you people should force us to
agrefe to 90 percent, which is essentially activated sludge, when
-------
298
Closing Statements
the plans and the studies and the Industrial waste involved
in these studies may lead to other devices for treatment.
This, we believe, or I believe, is entirely unnecessary.
This you can be assured of: That whatever plant goes in ,
there will work very efficiently, and w» are holding ourselves
to this.
MR. KLASHMAN. If a plant less than 90 percent will
meet the standards, then we will have no objection.
MR. LACAVA. Now what do you mean by "standards?"
MR. KLASHMAN. By the criteria which you establish
{
in the river.
MR. LACAVA. If they meet the river situation?
CHAIRMAN STEIN. Yes. I think this is outside —
MR. HEALY. Excuse me. May I Just explore that?
CHAIRMAN STEIN. Go ahead.
MR. HSALY: You say if the overall treatment meets the—
MR. KLASHMAN: If the secondary treatment you are providing
MR. HEALY: —meets the classification standards,
implying that this will satisfy you?
MR. KLASHMAN: In other words, if you are proposing
MR. HEALY: If this is so, we are all set.
MR. KLASHMAN: If you are proposing less than an
activated sludge plant, which wiii be a trickling filter plant
-------
299
Closing Statements
on the station and the river quality on the criteria you
submit, yes, this is acceptable.
MR. HEALY. Could I put it in a positive way? If
we are putting in a treatment of all locations of all discharge 5
and the criteria for the particular class of water that applies
here is being satisfied, then we will be meeting your require-
ments?
MR. KLASHAMAN. Yes.
MR. HEALY. Fine.
CHAIRMAN STEIN. Do you want a recess while you have
that conversation?
MR. KLASHMAN. I would like to recess for two minutes.
CHAIRMAN STEIN. I think we are at the end of the
conference.
MR. KLASHMAN. If you want to wait and let me tell him
something, fine. But I think we have to recess. I want to
talk to him for a few minutes.
CHAIRMAN STEIN. Mr. Klashmdn, I think we have to go
on with the conference. I should make the point that it is
the policy of the Federal Government to have open meetings as
a public agency, and I, as Chairman, deplore any private
• >s
conversations where the press and the public are not fully
advised of this. I do not think this is any way to do the
-------
300
Closing Statements
public business. >
Do we want to include in the terms of the conference
control over the ships or do you just want to let that go?
MR. KLASHMAN. Are you talking about No. 13?
CHAIRMAN STEIN. Yes.
MR. McMAHON. May I just make a comment here?
CHAIRMAN STEIN. Yes.
MR. McMAHON. Going back several months ago when we ,
first went over this report with members of the Regional
Office there were certain items that we felt, at least in
Massachusetts, should not have been included
in the Conference Report. However, after a certain amount of
negotiation it was felt that these recommendations, which
were general matters of policy with each of the States,
could be adopted in the proper light. Now, we had agreed to
these things, but it appears now that we are reading additional
commitments into this. If this is the case, I hate to put it
this way, but if we cannot accept this on the basis that we
went over this in Boston, then I think that at least Massachu-
setts as a Conferee would have to object to some of these.
MR. KLASHMAN. What is it you object to?
MR. McMAHON. First of all, I am not too sure that the
90 percent has been fully explored to our satisfaction. I
-------
301
Closing Statements
think there are a few other questions here. These are all
considerations and are general policy matters within each of
our agencies.
Now, if we can accept it as this and sort of wipe away
the cobwebs and in trying that we may perhaps be associated
with this, then I think everybody is going to be happy. But
I see no real purpose in dwelling on this and trying to make
something out of it that really is not there. This is my
feeling.
CHAIRMAN STEIN. I agree with you. But I think we do
not have an agreement on this 90 percent or any of that.
»•
MR. McMAHON. We agreed in Boston, as I recall. Bill,
would you not say that we had gone over this in a fair amount
of detail?
MR. HEALY. Yes. My recollection there, Mr- Chairman,
is that there was no real problem in this area. I do not
recall that we requested or achieved any particular percentage.
If I can, I will characterize it by saying that in the trade
amongst ourselves as engineers we certainly know what we can
expect of secondary facilities. If we did not, somebody should
fire us.
We willfully/of I can put it that way, select various
secondary methods to meet the needs of the industry or
-------
302
Closing Statements
municipalities. We do this to get the maximum benefit for
the dollars invested. I think that is all we can expect.
If we need treatment over and above this level, we must think
over other needs of treatment, tertiary treatment, certain
treatment to serve the particular situation.
I think it is going to be very uncomfortable for all
of us if we start working in terms of percentages, because the
plant will not operate at an established level of percentage
at all times, and I think you understand this, Mr. Chairman.
^ CHAIRMAN STEIN. I think your point is well taken.
The point is that I think it is clear we do not have all
specific agreements in these operations, and this, again, was
raised by the Chairman at his request.
I think we do have a mode of operation to go on and
go ahead with, and I think if we have any problems on secondan
treatment, we will just handle these on a case-by-case basis.
Now, there are two cases that Mr. McMahon had that
seemed all right when we had them this morning.
MR. McMAHON. Any of these we feel we will be able to
justify, and this should come up for review by the Federal
Grants people.
CHAIRMAN STEIN. I do not have a problem with that.
MR. McMAHON. I say this is a routine thing that is
-------
303
Closing Statements
handled without us spending a lot of energy here talking
about it.
CHAIRMAN STEIN. This has been done at various other
conferences, because this, in a sense, gets, as far as I
can see, to be a sticky and crucial issue. If it does not,
all right. What I suggested about this^about an hour ago
when this went on,was, hopefully, we are not going to have any
problem. If we do, we will meet it on an individual basis.
We surely do not have an agreement.
MR. HEALY. I think, Mr. Chairman, and I do not want
to extend this, but you have adequate remedies at your disposal,
and your people do, and we certainly cannot complain of any
exposure to these rules or compliances. That is, if we are
not operating these plants properly or to their maximum
advantage, then you can see to it that we do not get the funds
for their programs or plants. Many things can be done to see
that these things are met.
I think we ought to approach this by doing the very
best we can to operate at their highest level.
MR. McMAHON. Are we on recommendations now?
CHAIRMAN STEIN. No. Let us go ahead with one
question, and this was do you want to make a special point?
Do you want to leave this just as it is? You had a problem
-------
304
Closing Statements
on 13.
MR. McMAHON. I do not know if it is a problem. It
is something we are concerned about. We plan to file legis-
lation.
CHAIRMAN STEIN. Does the Conference have to do any-
thingjOr do we have to have a committee on 13>or can we just
let it stand this way?
MR. McMAHON. I would merely refer to my earlier
statement that this appears to be an excellent suggestion
and it is something that Massachusetts is planning on imple-
menting within the next 12 to l£ months.
CHAIRMAN STEIN. Are there any other questions or
anything else we want to add?
(No response.)
CHAIRMAN STEIN. I think we are on our way. I want
to again thank you all for coming.
MR. McMAHON. Mr. Chairman, could I make a recom-
mendation to the Conference?
CHAIRMAN STEIN. Surely.
MR. McMAHON. I would perhaps ask the other Conferees
from the States and the Interstate if they agree with this
particular statement, if they would perhaps endorse it. I
have just put Massachusetts in here now.
-------
305
Closing Statements
The Massachusetts Conferee, in reflection of the
existing and future detrimental effect caused by the lack
of Federal grant appropriations in the States implementation
programs, urge that the Federal Water Pollution Control Adminis-
tration and the Secretary of Interior recommend to the Congress
of the United States the adoption of a fiscal program consistent
with the anticipated construction schedules of waste treatment
facilities required throughou* *he Nation.
It is further recommended that any recommendation in
Federal finaiid . assistance be consistent with the present
grant percentage levels provided for in the Federal Water
Pollution Control Act.
I would further urge a separate 3ongressional appropri-
ation for reimbursement monies to States that have prefinanced
in anticipation of future Federal grant funds.
CHAIRMAN STEIN. Off the record here.
(Discussion off the record.)
CHAIRMAN STEIN. Back on the record.
Do you want to read this again for the Secretary or
do you want to submit this a little later?
MR. McMAHON. It probably could be improved as far as
the language.
MR. HEALY. I would like an opportunity to polish it
upi, but it is certainly acceptable to us.
-------
306
Closing Statements
CHAIRMAN STEIN. We will keep it open and when we
get that we will put a copy in to Mr. Klashman and send a
copy to Washington for the Secretary and a copy for the
Reporter to be inserted in the record as if read at this
point. (The above-mentioned statement follows; original appended.)
"STATEMENT of the State and Interstate Conferees at the
Reconvened Conference on the Merrimack and
Nashua Rivers - December 18, 1968
"In noting the detrimental effect of Federal construc-
tion grant cut-backs in appropriations on State water pollu-
tion control programs, the conferees from the State of New
Hampshire, the Commonwealth of Massachusetts, and the New
England Interstate Water Pollution Control Commission urge
that the Federal Water Pollution Control Administration and
the Secretary of the Interior recommend to the Congress of
the United States the adoption of a fiscal program consistent
with the implementation programs adopted by the States through-
out the Nation.
It is further recommended that legislative amendments
to the Federal Water Pollution Control Act do not vary the
present grant percentages to communities for construction of
waste treatment facilities or, if alternative means of financing
are introduced, the alternative financing measures be at least
the equivalent of the present percentages specified in the act.
"The conferees should also urge the passage of a separate
appropriation to finance the reimburseable clause of the Federal
Act to repay States that have or will pre-finance the eligible
Federal portions of treatment facilities in anticipation of
future Federal reimbursements."
MR. KLASHMAN. I understand, and correct me if I am
wrong, but in the summary that the Secretary puts out that it
-------
307
Closing Statements
will include these recommendations which the States have
accepted, with the exceptions made by Mr. McMahon?
MR. McMAHON. It is really not an exception but a
qualification.
CHAIRMAN STEIN. Yes, as consideration.
MR. KLASHMAN. Okay.
CHAIRMAN STEIN. As consideration.
MR. PELOQUIN. As confederation, right.
MR. McMAHON. That is what it says up there,
"Consideration shall be given."
CHAIRMAN STEIN. The reason I am getting at these is
for consideration.
As far as I can see, these may necessarily have been
written this way, but they are not the kind of thing you can
really go out and enforce. If they were to be enforced, this
might be one of the reasons it is exploited. It would have
to be at this time.
Obviously, this is not what the Conferees wanted to
do, so these are suggested recommendations. Because I do not
know anyone who could, you know, really enforce it on the
basis of that.
Again, does anyone else have something to say before
we wind up?
-------
308
Closing Statements
(No response).
CHAIRMAN STEIN. With all this, I am sure we have
really made tremendous advances today. We have a situation
now in which everyone - State, Federal, local municipalities
and industries - are committed to the cleanup of the Nashua-
Merrimack Basin.
The question now is not whether the basin is going to
be cleaned up, but when it is going to be cleaned up.
As everyone knows, the real key question here might
be likened to what makes the world go round? In a commercial
country like ours, it Is money. This is the essential question.
We recognize that the States, the localities, the
Federal Government all have severe financial problems that
must be met. This is a major factor In the cleanup of our
rivers. We have substantial agreement on what has to be
done and precisely who has to do it. All the sources are
Identified and have been presented with their program.
I believe that we have a time schedule. While it
might be at this time somewhat optimistic, depending upon
certain contingencies such as providing things happen right
and we are lucky in the forseeable future, we may be on our
way to a cleaner river.
I want to point this out: As you saw toward the end,
-------
309
Closing Statements
as we lifted the lid on certain future considerations,
there are still many problems to be resolved. We are entering,
really, a new phase on this one and that is compliance. I am
afraid that that has its sticky problems as well as the phase
that we have just gone through.
I hope this will take a direct answer?over and above
the remark before?that we were forcing New Hampshire to do
something at a conference. I have been coming up to New
Hampshire for many years. I never knew the Federal Govern-
ment to force New Hampshire to do anything by a conference
or any other means.
With that, I want to, again, thank you all for coming.
We stand adjourned.
(Whereupon the conference adjouned at 5:17 p.m.)
-------
APPENDIX A
TABLE 1 - DISCHARGERS TO THE MERRIMACK RIVER AND CERTAIN TRIBUTARIES IN NEW HAMPSHIRE
(As submitted for the record by the State of New Hampshire.)
Municipality or Industry
Location - Type of Waste
Franconia Paper Corporation
Lincoln - Paper
Municipal
Franklin - Sanitary
Municipal
Boscaven - Sanitary
Brezner Tanning Corporation
Boscaven - Tannery
Penacook Fibre Company
Concord - White Water
Municipal
Concord - Sanitary #1
- Sanitary 12
- Sanitary #3
Municipal
Hooks ett - Sanitary
French Brothers Beef Company
Hooks ett -
State Industrial School
Manchester - Sanitary & Indust.
Present
Treatment
None
None
None
None
None
None
None
None
None
-
None
Proposed Completion Completion Start
Treatment of Financing of Plans Construction
Secondary - - -
Secondary - - 3/69
Secondary -
Secondary - - -
Secondary -
Primary North - 12/69 U/70
Secondary North -
Secondary South -
Secondary - - -
Secondary -
Secondary - -
Finish
Construction
5/69
12/70
12/72
12/72
12/72
12/72
12/75
12/75
9/69
9/69
12/75
-------
TABLE 1 - DISCHARGERS TO THE MERRIMACK RIVER AND CERTAIN TRIBUTARIES IN NEW HAMPSHIRE
Municipality or Industry
Location - Type of Waste
Municipal
Manchester - Sanitary #1
- Sanitary #2
- Sanitary #3
M. Schver Realty Company
Manchester - Sanitary
Granite State Packing Company
Manchester - Packing
MKM Knitting Mills, Inc.
Manchester - Textile
Manchester Hosiery Mills
Manchester - Textile
Seal Tanning Company
Manchester - Tannery
Stephens Spinning Company
Manchester - Textile
Waumbec Mills, Inc.
Manchester - Textile
Foster Grant Company
Manchester -
Present
Treatment
None
None
None
None
None
None
None
None
Proposed Completion Completion
Treatment of Financing of Plans
Primary - 12/70
Interceptors
Secondary
Secondary
Secondary
Secondary
Secondary - -
Secondary
Secondary
Secondary
Secondary
Start Finish
Construction Construction
U/71 12/72
12/75
12/76
12/75
12/75
12/75
12/75
12/75
12/75
12/75
12/75
-------
TABLE 1 - DISCHARGERS TO THE MERRIMACK RIVER AND CERTAIN TRIBUTARIES IN NEW HAMPSHIRE
Municipality or Industry
Location - Type of Waste
Municipal
Merrimack - Sanitary
Merrimack Leather Company
Merrimack -
Nev England Pole Company
Merrimack -
Municipal
Nashua - Sanitary
Granite State Tanning Company
Nashua - Tannery
Sanders Associates
Nashua - Plating
Johns Manville Company
Nashua - White Water, Asbestos
Hampshire Chemical Company
Nashua -
Municipal
Hudson - Sanitary
Municipal
Derry - Sanitary
Municipal
Salem - Sanitary
Present
Treatment
None
None
-
Part
Primary
Settling
None
Settling
Ammonia
Recovery
None
Secondary
Secondary
& C12
Proposed Completion Completion Start
Treatment of Financing of Plans Construction
Secondary Complete 3/68 2/70
Secondary - 3/68 2/70
•r
Secondary -
Secondary -
Equivalent
to Secondary -
Equivalent
to Secondary ...
-
Secondary 7/70 8/68 2/71
-
• «• — —
Finish
Construction
11/71
11/71
Complete
12/7U
12/7U
12/71*
12/71*
Complete
9/72
Complete
Complete ^
-------
APPENDIX A
TABLE 2 - DISCHARGERS TO THE MERRIMACK RIVER AND CERTAIN TRIBUTARIES IN MASSACHUSETTS
(As*submitted for the record by the State of Massachusetts.)
Municipality or Industry
Location - Type of Waste
Municipal
Tyngsboro - Sanitary
Southwell Combing Company
Chelmsford - Scouring
Gilet Wool Scouring Corporation
Chelmsford - Wool Scouring
Municipal
Chelmsford - Sanitary #1
- Sanitary #2
J. P. Stevens & Company
Dracut -
Municipal
Dracut - Sanitary
Nyanza Chemical Company
Ashland -
Municipal (East)
Marlborough - Sanitary
Roxbury Carpet Company
Framingham - '
Present
Treatment
None
Grease
Recovery
None
None
None
None
None
Secondary
Secondary
& C12
None
Proposed
Treatment
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Tie to
Municipal
Phosphate
Removal
Tie to
Municipal
Appropriation Completion Start
of Funds of Plans Construction
3/70 12/70 U/71
2/69 U/69
2/69 V69
2/68 2/69 V69
2/69 2/70 5/70
2/70 6/70
6/70 7/71 9/71
7/68 8/68
Pilot Plant
11/68 U/69
Finish
Construction
U/72
V70
-/TO
5/71
6/71
11/72
1/69
10/69
VjJ
-------
TABLE 2 - DISCHARGERS TO THE.MERRIMACK RIVER AND CERTAIN TRIBUTARIES IN MASSACHUSETTS
Municipality or Industry
Location - Type of Waste
General Motors Corporation
Framingham -.
Municipal
Framingham - Sanitary
Municipal »
Vestborough - Sanitary
Municipal
Northborough - Sanitary
Lawrence Candle Company
Northborough -
Machinery Electrification
Northborough -
Municipal
Hudson - Sanitary
Municipal
Maynard - Sanitary
Digital Equipment Corporation
Maynard -
Present
Treatment
None
M. D. C.
Inadequate
Secondary
None
None
None
Secondary
& C12
Inadequate
Secondary
Tied to
Maynard
Proposed Appropriation
Treatment of Funds
Tie to
Municipal
Pumping
Station k/68
Secondary
Secondary 5/72
Secondary
Secondary
Pumping
Station 9/6b
Secondary 6/69
Pretreatment
Completion
of Plans
7/68
11/6B
• ••*
3/73
3/73
3/73
2/69
2/70
*•»
Start
Construction
8/68
V69
7/68
5/73
5/73
5/73
V69
V70
.
Finish
Construction
U/69
10/69
6/69
5/7*»
5/7U
5/7U
10/69
*»/71
.
-------
TABLE 2 - DISCHARGERS TO THE MERRIMACK RIVER AND CERTAIN TRIBUTARIES IN MASSACHUSETTS
Municipality or Industry
Location - Type of Waste
Municipal
Acton - Sanitary
Municipal
Concord - Sanitary
Municipal
Billerica - Sanitary
North Billerica Company
Billerica -
Lowell Rendering Company
Billerica -
Ames Textile
Lowell - Textile
Vertipile, Inc.
Lowell -
Jean-Alan Products Company
Lowell -
Lawrence Manufacturing Company
Lowell -
Pellon Corporation
Lowell -
Present
Treatment
None
Secondary
Secondary
& C12
None
Grease
Recovery
None
Centrifuges
None
None
None
Proposed
Treatment
Secondary
Chlorination
Interceptor
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Appropriation Completion Start
of Funds of Plans Construction
6/70 2/71 U/71
.
5/70 3/71 5/71
3/71 5/71
3/71 5/71
6/71
6/71
6/71
6/71
6/71
Finish
Construction
U/72
Complete
5/72
5/72
5/72
6/73
6/73
6/73
6/73
6/73
-------
TABLE 2 - DISCHARGERS TO THE MERRIMACK RIVER AND CERTAIN TRIBUTARIES IN MASSACHUSETTS
*
Municipality or Industry
Location - Type of Waste
Robinson Top & Yarn Dye
Lowell -
By field Felting Company
Lowell -
United Elastic Company
Lowell -
Vogue Silver Company
Lowell -
Middlesex Worsted Spinning
Lowell -
Suffolk Knitting Company
Lowell -
Commodore Foods, Inc.
Lowell -
Municipal
Lowell - Sanitary #1
- Sanitary #2
State Hospital
Tewksbury - Sanitary
Municipal
Andover - Sanitary
Present
Treatment
None
None
None
None
Company
None
None
None
None
Secondary
& Cl2
Part None
Part Secondary
Proposed
Treatment
Secondary
Secondary
Secondary
None
Secondary
Secondary
Secondary
Secondary
Secondary
-
Secondary
Appropriation Completion Start
of Funds of Plans Construction
6/71
6/71
6/71
-
6/71
6/71
6/71
12/68 1/70 6/70
12/68 3/71 6/71
-
U/68 1/69 3/69
Finish
Construction
6/73
\
6/73
6/73
•Insignificant
6/73
6/73
6/73
6/72
6/73
Complete
3/70
Vo
-------
TABLE 2 - DISCHARGERS TO THE MERRIMACK RIVER AND CERTAIN TRIBUTARIES IN MASSACHUSETTS
Municipalit/" or Industry
Location - type of Waste
Mead Corporation
Lawrence - Paper
Oxford Paper Company
Lawrence - Paper
Agawam Dye Works, Inc.
Lawrence - Dyeing
Merrimack Paper Company
Lawrence - Paper
Lawrence Wool Scouring Company
Lawrence - Wool Scouring
Municipal
Lawrence - Sanitary #1
- Sanitary #2
Wipex, Inc.
North Andover -
Western Electric Company
North Andover - Sanitary
Present
Treatment
None
None
None
None
Grease
Recovery
None
None
Neutralization
Proposed
Treatment
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Appropriation Completion
of Funds of Plans
. -
-
•
-
3/70
9/67 1/70
1/71
-
- Complete
Start
Construction
6/70
6/70
6/70
6/70
6/70
6/70
7/71
6/68
3/69
Finish
Construction
7/73
7/73
7/73
7/73
7/73
6/72
7/73
9/68
3/70
& Plating
Municipal
North Andover - Sanitary
None
Secondary
U/68
1/69
3/69
3/70
-------
TABLE 2 - DISCHARGERS TO THE MERRIMACK RIVER AND CERTAIN•TRIBUTARIES IN MASSACHUSETTS
"Municipality or Industry
Location - Type of Waste
Essex Chrome Plating
Methuen -
Municipal
Methuen - Sanitary 11
- Sanitary #2
Haverhill Plating
Haverhill -
L. H. Hamel Leather
Haverhill -
Continental Can Company
Haverhill -
Hoyt & Worthen Tanning Company
Haverhill -
Cowan & Shain, Inc.
Haverhill -
C. F. Jameson Company
Haverhill -
Municipal
Haverhill - Sanitary #1
- Sanitary #2
Municipal
Groveland - Sanitary
Present
Treatment
None
None
None
None
None
Grease &
Oil Recovery
None
None
None
None
Proposed
Treatment
Secondary
Secondary
Interceptor
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Interceptor
Secondary
Appropriation Completion
of Funds of Plans
1/69
9/67 1/69
9/67 1/71
3/69
3/69
U/68
3/69
3/69
3/69
8/67 3/69
3/70 3/71
12/68 12/69
Start
Construction'
V69
V69
V71
7/69
7/69
7/68
7/69
7/69
7/69
7/69
7/71
3/70
Finish
Construction
U/71
• 12/72
7/70
7/70
7/69
7/70
7/70
7/70
7/71
7/72
3/71
vO
-------
TABLE 2 - DISCHARGERS TO THE MERRIMACK RIVER AND CERTAIN TRIBUTARIES IN MASSACHUSETTS
Municipality or Industry
Location - Type of Waste
Municipal
Merrimac - Sanitary
Amesbury Tanning
Amesbury -
Amesbury Specialty
Amesbury -
Amesbury Fibre Corporation
Amesbury -
Merrimack Hat Company
Amesbury -
Amesbury Metal Products Company
Amesbury -
Municipal
Amesbury - Sanitary
Towle Silversmith
Newburyport -
Chase Shawmut Company
Newburyport -
Municipal
Newburyport - Sanitary
Present
Treatment
None
None
None
Out
None
None
None*
None
None
Primary
& C12
Proposed Appropriation
Treatment of Funds
Secondary 3/69
Secondary
Secondary
of Business
Secondary
Equivalent
to Secondary -
Secondary 8/68
Secondary
Secondary
Secondary or
Ocean Discharge 12/69
Completion
of Plans
*
V70
5/69
5./69
5/69
5/69
5/69
8/69
8/69
2/71
Start
Construction
7/70
6/69
6/69
6/69
6/69
6/69
10/69
11/69
U/71
Finish
Construction
7/71
x
6/70
6/70
6/70
6/70
6/70
5/70
5/70
U/72
-------
TABLE 2 T DISCHARGERS TO THE MERRIMACK RIVER AND CERTAIN TRIBUTARIES IN MASSACHUSETTS
Municipality or Industry
Location - Type of Waste
Present Proposed Appropriation Completion Start Finish
Treatment Treatment of Funds of Plans Construction Construction
Salisbury Water Company
Salisbury -
Municipal
Salisbury - Sanitary
None
None
Secondary
7/67
Secondary or
Ocean Discharge 10/69
6/6tt
12/70
7/68
U/71
7/69
-------
Appendix A
TABLE 3 - DISCHARGERS TO THE NASHUA RIVER AND CERTAIN TRIBUTARIES IN MASSACHUSETTS
(As submitted for the record by the State of Massachusetts.)
Municipality or Industry
Location - Type of Waste
Old Mill Restaurant
Westminster -
Advance Coatings, Inc.
Westminster -
Decotone Products Division
(Fitchburg Paper Company)
Westminster -
Art Photo Service, Inc.
Fitchburg -
Fitchburg Gas & Light Company
Fitchburg -
Hedstrom Associates
Fitchburg -
Vogue Wall Coverings, Inc.
Fitchburg -
Wachusett Potato Chip Company
Fitchburg -
Independent Lock Company
Fitchburg -
Iver Johnson
Fitchburg -
Present
Treatment
None
None
None
None
None
None
None
None
None
None
Proposed
Treatment
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Appropriation Completion Start
of Funds of Plans Construction
12/69 U/70
12/69 U/70
12/69 U/70
12/69 12/70
12/69 U/70
12/69 U/70
12/69 U/70
U/70 8/70
2/70 U/70
3/69 U/69
Finish
Construction
U/71
U/71
U/71
12/71
VT2
U/71
U/71
U/71
6/71
10/69 &
»o
-------
TABLE 3 - DISCHARGERS TO THE NASHUA RIVER AND CERTAIN TRIBUTARIES IN MASSACHUSETTS
-Municipality or Industry
Location - Type of Waste
Weyerhaeuser Paper Company
Fitchburg - Paper
Fitchburg Paper Company
Fitchburg - Paper
Simonds Sav & Steel Company
Fitchburg -
Falulah Paper Company
Fitchburg - Paper
Municipal
Fitchburg - Sanitary
Jennison Company
Fitchburg -
Rogers Brothers
Lunenburg -
Foster Grant Company
Leominster -
Bordon Chemical Company
Leominster -
Municipal
Leominster - Sanitary
Present
Treatment
None
None
None
Vacuum Sludge,
Chemical
Precipitation
Inadequate
Secondary
None
None
Lagoon
Lagoons
Secondary
Proposed
Treatment
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Appropriation Completion
of Funds of Plans
- -
12/69
13/69
12/69
10/68 12/69
3/69
12/69
11/68
6/69
— —
Start
Construction
U/70
U/70
VTO
U/70
U/70
U/69
U/70
3/69
7/69
Ml
Finish
Construction
U/72
U/72
U/72
U/72
U/72
10/69
U/71
12/69
7/70
Complete
W
-------
TABLE 3 - DISCHARGERS TO THE NASHUA RIVER AND CERTAIN TRIBUTARIES IN MASSACHUSETTS
Municipality or Industry
Location - Type of Waste
Atlantic Union College
Lancaster - Sanitary
Municipal
Clinton - Sanitary
Municipal
Ayer - Sanitary
Hollingsworth & Vose Company
Groton -
Groton Leatherboard Company
Groton -
St. Regis Paper Company
Pepperell - Paper
American Plastics
Fitchburg -
Bemis Company, Inc.
Pepperell -
Municipal
Pepperell - Sanitary
Present
Treatment
Part Primary
Part Secondary
Secondary
Secondary
Settling
None
None
None"
None
Primary
Proposed
Treatment
Secondary
Add Cl2
Add C12
Secondary
Secondary
Secondary
Secondary
Secondary
Secondary
Appropriation Completion
of Funds of Plans
U/68 2/69
3/69
3/69
3/70
3/70
3/70
3/70 12/69
3/70
U/70 2/71
Start
Construction
U/69
U/69
>/69
5/70
5/70
5/70
U/70
5/70
5/71
Finish
Construction
VTO
7/69
7/69
5/71
5/71
5/71
U/71
5/71
6/72
-------
325
Rj^trnqlcma/ drfowMsi U9altaa^^ Unrmu^ieri/
0 >^P^v
73 TREMONT STREET
BOSTON
MASSACHUSETTS 02108
ROBERT L. YAM, Chairman
WALTER C. ANDERSON, Vlc.-Cholrman
GEORGE L. BURKE, Tr.a.uc.r
ALFRED E. PELOQUIN, Ea.cirtlv. S.cr.tary
CONNECTICUT
MAINE
MASSACHUSETTS
NEW HAMPSHIRE
NEW YORK
RHODE ISLAND
VERMONT
January 20, 1969
Lester M. Klashman, Regional Director
Northeast Region FWPCA
JFK Federal Building, 23rd fl
Boston, Mass. 02203
Dear Mr. Klashman:
As you will recall, toward the end of the reconvened conference on the
Merrimack and Nashua Rivers at Concord, N. H., on December 18, 1968, the
State and interstate conferees concurred in introducing into the record a state-
ment requesting the support of the FWPCA and of the Secretary of the Interior in
the adoption of a fiscal program consistent with approved State implementation
programs. The statement has been finalized and concurred in by the State and
interstate conferees and a copy thereof is attached for inclusion in the Proceed-
ings of the Conference.
Very
AEP/efc
Enc.
c-McMahon
c-Healy
-------
326
STATEMENT of the Conferees at the Reconvened Conference on the Merrimack
and Nashua River - December 18, 1968
'' In noting the detrimental effect of Federal Construction grant cut-backs
in appropriations on State water pollution control programs the Conferees from
the State of New Hampshire, the Commonwealth of Massachusetts, and the New
England Interstate Water Pollution Control Commission urge that the Federal
Water Pollution Control Administration and the Secretary of Interior recommend
to the Congress of the United States the adoption of a fiscal program consistent
with the implementation programs adopted by the States throughout the nation.
It is further recommended that legislative amendments to the Federal
Water Pollution Control Act do not vary the present grant percentages to com-
munities for construction of waste treatment facilities or if alternative means of
financing are introduced the alternative financing measures be at least the equiv-
alent of the present percentages specified in the act.
The Conferees would also urge the passage of a separate appropriation
to finance the reimburseable clause of the Federal Act to repay States that have
or will pre-finance the eligible Federal portions of treatment facilities in antici-
pation of future Federal reimbursements."
*U. a. GOVERNMENT PRINTING OFFICE : 1969 O - 353-42S
------- |