MERRSMACK RIVER
WATERSHED F
PDi
c
PAST, PRESENT, FUTURE
E
nvsronmental Protection Agency
Region i, Boston, MA
Michael R. Deland, Regional Administrator
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J. F. KENNEDY FEDERAL BUILDING. BOSTON. MASSACHUSETTS 02203
Dear Friends of the Merrimack:
The Merrimack is a portrait of the New England environment.
It is an environmental success story and, at the same time,
a river at risk.
In the 1960s the Merrimack was considered among the ten dirtiest
rivers in America. Today, two decades and a half-a-billion
dollars in federal and state expenditures later, the Merrimack
provides drinking water to well over a quarter-of-a-million
people and serves as an unparallelled recreational resource for
the region.
As the new-found attractiveness of the Merrimack River sparks
new growth and development within its 5,000 square mile basin,
we must continue our vigilance both in the water and on the land
lest we loose the gains that have already been made.
This action-oriented watershed protection initiative will allow
us to step back and examine the Merrimack watershed not as a
collection of discharge permits or a list of construction grants,
but as a single ecological system. This precedent-setting,
holistic approach will expand our understanding of the watershed,
and allow us to more intelligently focus our pollution control
efforts.
It is with great pride that EPA's New England office joins with
the citizens of New Hampshire and Massachusetts in launching
this important initiative. The concerted efforts of local gov-
ernment, environmental groups and state agencies are critical
to its success. We can only gain by working together to better
understand and protect the environment that sustains us.
Michael R. Deland
Regional Administrator
-------
MERRIMACK RIVER WATERSHED PROTECTION INITIATIVE
PAST, PRESENT, FUTURE
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ViATER MANAGEMENT DIVISION
BOSTON, MASSACHUSETTS
in conjunction with
NEW HAMPSHIRE
DEPARTMENT OF ENVIRONMENTAL SERVICES
and
MASSACHUSETTS
DIVISION OF WATER POLLUTION CONTROL
NOVEMBER 1987
-------
TABLE OF CONTENTS
List of Tables ii
List of Figures ii
Preface 1
Introduction 2
Summary and Recomendations 4
Water Quality 7
Construction Grants 22
National Pollutant Discharge Elimination System 25
Municipal Permits 26
Pretreatment 28
Industrial Permits 29
Compliance 34
Mater Supply Surface and Groundwater 38
Superfund and RCRA 47
References 51
Appendix A, Construction Grants Funding in Remaining Merrimack A-l
Sub-basins
Appendix B, NPEES Dischargers in the Merrimack Basin B-l
Appendix C, Massachusetts Construction Grants Priority System C-l
Appendix D, State of New Hampshire Water Supply and Pollution Control D-l
Comiission Project Priority System
-------
LIST OF TABLES
WQ-1 Geographical Information 12
WQ-2 Use Support Status 13
WQ-3 Potential Non-point Sources of Pollution in the Merrimack 17
River Basin, MA
WQ-4 Land Use in the Merrimack River Basin, NH 18
WQ-5 Key to Major Dischargers Map 21
OG-1 Estimated Grant Funding Since Inception of PL 92-500 24
CG-2 Estimated Future Funding Needs 24
M-l Municipal Dischargers into the Merrimack River Mainstem 26
M-2 Municipal Dischargers into Selected Merrimack Tributaries 21
M-3 Total Loadings to the Merrimack River and Selected Tributaries 27
1-1 Summary of Industrial Dischargers 32
DW-1 Present and Future Public Water Supply Users 44
DW-2 Potential Drinking Water Contaminants 45
DW-3 Organics to be Monitored 46
DW-4 Synthetic Organic Contaminants 46
SR-1 RCRA Facilities along the Merrimack River 50
LIST OF FIGURES
WQ-1 Designated use Support Status, NH 15
WQ-2 Designated use Support Status, MA . 16
WQ-4 Land Use in the Merrimack River Basin, NH 19
WQ-5 Major Dischargers Map 2U
ii
-------
PREFACE
The Merrimack River basin is the subject of much discussion among citizens'
groups, politicians, and environmental agencies in New Ha-npshire and Massachu-
setts. Issues which draw attention to the basin include combined sewer over-
flows, use of the river as a drinking water supply, and equitable waste load
allocation. The Water Management Division of the US EPA, Region I assembled
several of its members along with representatives of the Hazardous Waste Divi-
sion and Regional Administrator's Office to compile data r«jgarding construction
grants funding allocations and needs, present and past quality of the water
and availability of drinking water in the basin, and to list hazardous waste
sites in the basin. This report is to be used both within and out of the EPA
and is designed to address current issues regarding the Merrimack River, dis-
cuss the significant improvements in the water quality, and suggest recommenda-
tions regarding the remaining needs of the basin.
To achieve these goals, potential threats to water quality that would imperil
existing uses of recreation, fish habitat, and water supply were examined. The
river was evaluated from a cross-media perspective to identify areas where fur-
ther water quality protection strategies could be targeted to ensure that the
goals of the Clean Water Act are achieved. By developing a geographical initi-
ative of the basin, resources could be optimized in implementing an approach
that diverged from the traditional single violation response. A long-term,
prioritized initiative would ensure that the Merrimack continued the prosperity
it began in the 1970's and early 1980's. Findings of this report will be used
to identify activities for resolving current or emerging environmental protec-
tion problems.
(For more information regarding the Merrimack River and the status of the ini-
tiative to improve its water quality, contact Corrine L. Kupstas, United States
Environmental Protection Agency, JFK Federal Building, Boston, 617-565-3538.)
-------
INTRODUCTION
The Merrimack River is formed by the confluence of the Pemigewassett and
Winnepesaukee Rivers in Franklin, New Hampshire. It flows southward through
New Hampshire's three most populated cities - Concord, Manchester, and Nashua,
enters Massachusetts at Tyngsborough, then flows northeast from Lowell until
it empties into the Atlantic Ocean at Newburyport, MA. The Merrimack River
drainage basin is the fourth largest basin in New England and drains about 3800
square miles in NH and 1210 square miles in MA. The estuary at the river's
mouth drains 4,208 acres (approximately 6.6 square miles) and has a maximum
length of nine miles. The river itself is approximately 116 miles long (66
miles in NH and 49.8 miles in MA). Wetlands located along the river from its
headwaters in Franklin, NH to Lowell, MA and along direct tributaries in this
river reach are included in EPA's Priority Wetlands Listing for New England.
These wetlands are particularly valuable for their waterfowl and anadromcus
fish habitat and for flood storage capacity. The flow of the Merrimack is
measured at three different gaging stations along the river. The seven-day
average low flow which occurs with a ten-year frequency (7Q10 flow) increases
from 551 cubic feet per second (cfs) at Franklin Junction, NH to 667 cfs near
Goffs Falls below Manchester, NH to 930 cfs at Lowell, MA. The average flow
of river at the last gage is 7,529 cfs. A comparison of the river flow to that
of several others offers an idea of its size. The Merrimack is much larger
than the Charles River which averages 368 cfs at its gaging station in Waltham,
or the Blackstone River which enters Rhode Island at an average flow rate of
758 cfs. The size of the Merrimack is dwarfed by the Connecticut River which
averages 16,180 cfs as it leave Massachusetts.
During the early settlement days, the river played a significant role in trans-
portation, water supply, fishing, and recreation. In the years that followed,
the Merrimack became a convenient conveyor of industrial and domestic wastes.
By the mid 1900's, the river was considered one of the nation's ten most
polluted due to raw sewage, paper and textile mill wastes, and tannery sludges.
Contaminants from polluted tributaries heightened the problem. Pollution
impacts were not restricted to the river alone. The tidal flats of its estuary
suffered such drastic reductions in shellfish productivity that by the 1960's
the shellfishing industry was nearly non-existent in the estuary.
The Merrimack River Basin presently has 24 major permitted industrial dischar-
gers as well as 71 municipal dischargers, of which four are drinking water
purification plants and 52 are secondary or advanced wastewater treatment
plants. The remainder are primary treatment facilities. There also still exist
some untreated sewage discharges. The federal government provides funding
through the construction grants program for the construction of municipal
wastewater treatment facilities, sewer interceptors, pump stations, and force
mains. Since the inception of Public Law 92-500 in 1972, the federal govern-
ment has granted $426,310,558 to 32 municipalities. New Hampshire, Massachu-
setts, and the communities also provided extensive funding. Still, the esti-
mated future funding need for 19 of these communities is $247,148,000, much of
which is for projects to intercept combined sewer overflows (CSOs). Construc-
tion of wastewater treatment facilities at the river's headwaters in Franklin,
NH, numerous facilities along the mainstem of the river and tributaries, and
several industrial treatment facilities contributed to the noteworthy water
quality improvements in the Merrimack River.
-------
Pollution abatement activities have resulted in at least partial achievement
of water quality standards (the states' definitions of water quality require-
ments necessary to support designated uses) in 94.3% of the New Hampshire
portion of the basin and in 68% of the Massachusetts portion of the basin. The
entire Massachusetts portion of the mainstem of the river is at least partially
supporting designated uses. The Merrijnack River is the drinking water source
for several Massachusetts and New Hampshire communities, supplying over 237,000
people in Massachusetts alone. The use of the river as a drinking water supply
intensifies the need to protect the integrity of the Merrimack's water quality.
Possible contamination by toxicants from past or present industrial sources,
municipal facilities to which industries are connected, non-point sources, and
hazardous waste sites needs further study. Though many priority pollutants
would not affect the suitability of the water for use as a fishery, they could
affect its suitability for swimming and drinking because of potential risk to
public health. In order to protect these uese, contamination from such sources
must be investigated and averted. Toxics screening should be carried out to
determine if contamination has already taken place.
While striking improvements have been made in the quality of the basin's sur-
face water, less has been done to address groundwater concerns. Groundwater
protection programs in both states are young and implementation of site-
specific restoration activities has begun only recently. However, the states
have identified municipal and industrial landfills as the major sources of
groundwater contamination and prepared a list of sites where groundwater con-
tamination has already occurred. Detailed groundwater studies have, thus far,
been limited to known hazardous waste sites. Several Superfund sites are in
proximity to the river. Five of these sites are known to have contaminated
groundwater. The extent to which groundwater pollution affects surface water
quality has yet to be studied.
Because potential sources of pollution to the Merrimack River have not been
eliminated, clean-up efforts need to continue. Water quality improvement
activities accomplished to date have re-established the Merrimack River as a
high quality, valuable resource to the abutting and surrounding communities.
-------
SUMMARY AND RECOMMENDATIONS
The quality of the Merrimack River has improved dramatically in the last twenty
years. This improvement has been the result of the construction of many Pub-
licly Owned Treatment Works funded, in part, by the federal construction grants
program; ever-improving treatment by industrial dischargers in the basin; and
planning activities by Massachusetts, New Hampshire, and the US Environmental
Protection Agency. One of the nation's ten most polluted in the 1960's, the
river now fully or partially meets fishable/swimmable standards in 94.3% of its
New Hampshire miles and 68% of its Massachusetts miles.
It is a record to be proud of, yet much remains to be done. A rapidly growing
river basin population is increasing the environmental stress on the river
while demanding ever more from it. The Merrimack serves as a drinking water
supply for some quarter million people in both states. The Merrimack has also
become a valuable centerpiece for recreation. Maintenance and further improve-
ment of the quality of the river will require a concerted and cooperative ef-
fort by federal, state, and local officials as well as concerned citizens and
industry. Many of the more obvious pollution problems in the basin have been
or are now being addressed, leaving a second generation of environmental chal-
lenges to confront.
Based on the information contained in this report and conclusions drawn from
it, the following recommendations for continuing and expanding results-oriented
activity in the Merrimack River basin have been developed. These recommenda-
tions have been categorized into an agenda for EPA action to be carried out
within one year and an agenda for cooperative action consisting of issues to
be addressed by the states, communities, interested citizens and environmental
groups. EPA intends to monitor the recommendations and use them to evaluate
further the success of the restoration of the Merrimack to full support of its
designated uses.. The lessons learned from such an initiative, both technical
and organizational, will prove useful in tackling similar problems faced by
other river basins throughout New England.
AGENDA FOR EPA ACTION
-EPA will assist watershed organizations in providing education/workshops to
citizens and local governments to encourage land use decisions which will pro-
tect groundwater and surface water, especially in areas of anticipated growth
and in the vicinity of wetlands listed in the Priority Wetlands Listing for
New England, and strengthen cooperation of the communities to continue the
delivery of safe potable water and to protect the river's recreational and
fish habitat value.
- EPA will conduct sanitary surveys for the six communities with drinking wa-
ter supply intakes in conjunction with all of the involved regulatory agencies,
water suppliers, and private organizations dealing directly with the water
supply of the Merrimack.
- New Hampshire, in conjunction with the EPA, will place Nashua and Manchester
on enforceable, court-ordered schedules to provide a minimum of secondary treat-
ment at Nashua and eliminate raw discharges at Manchester.
-------
- EPA will work with communities to establish a drinking water monitoring
program to determine if the intake water is of consistently high guality. The
sampling program should include varying the time of day and river depth and
should be assessed after one year to determine if the frequency of monitoring
and, perhaps, the number of parameters measured could be decreased. Data
generated will also be available for water quality assessments.
The Commissioner of the Massachusetts Department of Environmental Quality Engi-
neering and the Commissioner of the New Hampshire Department of Environmental
Services have met with EPA officials to establish an interstate task force.
The task force, with representatives of basin communities and local watershed
associations, as well as both states, will examine the agenda for cooperative
action in the basin, including those actions which are also applicable on a
statewide basis, and consider cooperative strategies for managing improvements
in the quality of the Merrimack River.
AGENDA BDR COOPERATIVE ACTION
- Analyses of the susceptibility of the water supplies to degradation from
episodic, short-term, and long-term events are needed. Analyses consist of
either manually inspecting the area or creating mathematical models to simulate
the impact of contaminants in the water or both.
- Activated carbon should be used at all drinking water supply intakes in addi-
tion to conventional treatment in order to ensure the purity of drinking water.
Nashua, NH is the only community with an intake which does not use activated
carbon. Communities should have a policy for determining when to replace spent
carbon and requiring its replacement because contaminants adsorbed from the
water have the potential to desorb once the carbon is spent.
- EPA and the states should continue efforts to evaluate the effects of com-
bined sewer overflows, including assessment of the magnitude and quality of
loadings. States should continue to determine the priority of combined sewer
overflow abatement and to develop means to fund remedial action. Communities
where combined sewer overflow abatement actions are known to be necessary for
the river to meet its classification are Nashua, Manchester, Lawrence, Lowell,
and Haverhill.
- Existing and potential contamination sources, including but not limited to
landfills, hazardous waste sites, underground storage tanks, and groundwater
discharges need to be identified and monitored. States need to complete aquifer
mapping and indicate areas presently being used for water supply, potentially
useable, and vulnerable to contamination in order to develop and implement
groundwater classification systems or other strategies.
- Addressing non-point source pollution concerns along the Merrimack River will
require implementing programs to be designed on a statewide basis. The EPA
will encourage the states in the development of Non-Point Source Implementation
Programs which will encompass the following: assess non-point source problems;
prescribe site-specific best management practices; set priorities; identify
responsibilities; arrange financing and scheduling; establish coordination
-------
procedures involving the states, local agencies, and the private sector, in-
cluding the highway, soil conservation, pesticide, and forestry agencies and
the construction industry.
- States need to emphasize high standards of operation and maintenance of all
wastewater treatment plants to provide design levels of treatment.
- Surveys of industrial dischargers need to be conducted in order to determine
which communities presently not implementing a pretreatment program need one.
Surveys should be followed by necessary enforcement actions to ensure that the
ccranunities develop such programs and that industries meet at least categorical
limits. Compliance with pretreatment programs needs to be diligently maintained
in all applicable communities.
-------
WATER QUALITY
The Merrimack River basin covers a total of 5010 square miles (see Table WQ-1
for geographical information by state). The state water pollution control
agencies have divided the basin into a number of tributary sub-basins. The
Merrimack River basin consists of the mainstem sub-basin, which includes the
Piscataquog, Suncook, Souhegan, Soucook, Powwow, Spicket, and Little Rivers,
Black Rock Creek, and Beaver Brook and the Pemigewasset, Winnepesaukee, Contoo-
cook, Concord/Sudbury/Assabet, Nashua, Stony Brook, and Shawsheen sub-basins.
The Assabet and Sudbury Rivers empty into the Concord River which, in turn,
enters the Merrimack much further downstream. Because ot the limited scope of
this report, the Assabet, Sudbury, Concord, Pemigewasset, and Winnepesaukee
Rivers will not be discussed further. See Table WQ-2 for use support status of
tributaries. Instead, attention will be focused on the mainstem and those
tributaries which are located in the Merrimack River mainstem sub-basin.
The quality of the Merrimack River has undergone significant improvement in
the last twenty years. Both states carry out river surveys in sections of the
basin believed to have water quality problems. Waters not assessed by the
states are believed to support designated uses. In the New Hampshire, 433.1
miles of the 488.3 which were assessed (88.7%) presently meet water quality
standards.14 All 49.8 miles of the Massachusetts portion of the mainstem at
least partially support designated uses (see Table VJQ-2 for complete information
on use support status).8 Of those miles not supporting uses in New Hampshire,
5.1 miles, or 9.2%, are impaired by non-point sources (NPS).16 In the Massachu-
setts portion, the overwhelming input of pollutants from CSOs and point sources
precludes an accurate determination of the extent of NPS impact on the river.
The Massachusetts 305(b) Report tentatively ascribes 20% of the non-support of
uses to NPS.8
In New Hampshire 12.2 of the 433.1 miles are designated class C, while in
Massachusetts the entire river is classified B except the estuary and tidal
portion of the river which are SB. Class B is comparable to the EPA design-
ation of fishable/swimmable (F/S). Waters in this class are designated for the
uses of protection and propagation of fish, other aquatic life, and wildlife;
and for primary and secondary contact recreation. Waters of class C are
designated fishable, but not swimmable, although they are to be suitable for
secondary contact recreation. In Massachusetts, the only distinction in the
minimum criteria between classes B and C are the pH range and the fecal coli-
form bacteria limit. In New Hampshire, the differences between standards for
classes B and C are the pH range and the absence of a coliform bacteria limit
for class C.y'15
STATE WATER QUALITY STANDARDS
Designated Uses
PH
NEW HAMPSHIRE
Class B Class C
F/S Fishable,
Secondary contact
6.5-8.0 6.0-8.5
Fecal Coliform 240/lOOml
MASSACHUSETTS
Class B Class C
F/S Fishable,
Secondary contact
6.5-8.0 6.5-9.0
200/lOOml
1000/lOOml
-------
While the differences in written standards may appear subtle, the difference in
the actual condition of the water can be quite significant due to standards
violations. Massachusetts designates Class SB waters for the same uses as B,
plus for shellfish harvesting after purification (Restricted Shellfish Areas).
Waters are considered to be "meeting standards" or "supporting designated uses"
if all of the numerical criteria are met and the uses are being carried out.
Waters may be "partially supporting designated uses" if some, but not all, of
its uses can be carried out. If periodic violations of standards occur, the
water may be considered to partially support uses. Class B waters "not sup-
porting designated uses" violate numerical standards and/or negatively impact
aquatic life and preclude swimming.
Water quality standards violations throughout the basin are almost exclusively
due to high coliform bacteria levels, but in some instances are due to low
D.O. in the tributaries, high phosphorus and nitrogen levels, or high solids
concentrations. Pollutants which cause water quality standards violations are
related to domestic wastes. They enter the waters from municipal treatment
plants, combined sewers, and individual septic systems. The lower quality of
the waters is aggravated by urban runoff and, in the case of Spicket River in
MA, industrial phosphorus input.
Other pollutants are presumed to be present, but are not in sufficiently high
concentrations to be the cause standards violations. Some research has been
done on the presence of toxic metals and organics in the Merrimack. Effluent
data for metals in Massachusetts POTWs has been collected periodically since
1977. In the summer of 1986, the states carried out water quality surveys of
the river which included testing for metals in the water column and in shell-
fish flesh. Results of these surveys are being compiled into the 1986 Merri-
mack River Water Quality Data and Analysis report to be published in 1987.
Testing of metals in fish flesh has been conducted by US Fish and Wildlife.
Little data on toxic organics have been collected at drinking water intake
locations; however, volatile organic screenings were carried out in 1981 and
1986. Information presently available is not sufficient to determine whether
or not a toxic contamination problem threatens the water supplies. Though pre-
sent concerns about the water quality are serious, the recent improvements in
water quality - due largely to construction of publicly owned treatment plants
(POTWs) - give promise that the remaining problems due to conventionl pollu-
tants will be resolved. Routine toxics screening at the intakes would provide
the necessary information to determine if toxic pollutants are present and the
degree of contamination. Pretreatment programs at the municipal facilities are
one means of averting toxic contamination.
In 1938, the entire New Hampshire portion of the river was considered too con-
taminated to be used as a drinking water supply. Some pollution of the Massa-
chusetts portion was observed as early as the turn of the century, but it was
not until the 1960's that the severity of the water quality problems became
apparent. In 1965, rafts of decomposing organic material floated along the
Contoocook River (a major tributary); very little benthic fauna and no pollu-
tion-sensitive species were found along portions of the river near Concord;
bottom sediments were primarily sewage sludges downstream of Concord. Further
downstream, raw sewage discharges overburderled the river with nutrients causing
-------
severe vegetative growth problems and total coliform densities as high as 20,000
per 100 ml. A stretch of only 35.6 miles the river was subjected to a combined
biochemical oxygen demand (BOD5) loading of 65,000 to 75,000 pounds per day
from Lowell, Lawrence, and Haverhill. Because of lower flow rates during
summer, the river was particularly susceptible to the elevated levels of nitro-
gen and phosphorus which caused a significant diurnal D.O. fluctuation. The
850 acres of estuary flats were negatively impacted by the same type of sources
to the extent that by the 1960's annual shellfish harvesting had decreased fron
the turn of the century levels of approximately 100,000 bushels to a few hun-
dred bushels per year. Despite an abundance of shellfish inhabiting the flats,
worsening water quality conditions began affecting the shellfishing industry
as early as 1925 when the first shellfish flats were closed and continued to
the 1960's when the industry was virtually non-existent.8 The 1986 water qual-
ity survey included shellfish sampling and testing for pesticides and metals.
Analysis of the sampling will be included in the report to be published early
in 1987.
Today, a stretch of 36.4 miles of the river from its start in Franklin to
northern Manchester meets water quality standards for class B waters with
coliform concentrations of 240 per 100 ml or less, drastically reduced total
organic loadings, suspended solids levels reduced by one third, and a much
higher DO. The river has exhibited marked improvement in physical appear-
ance as well as biological and chemical makeup. For example, these significant
reductions in the input of pollutants have resulted in the replacement of
sewage-laden sediments by re-established benthic fauna. Numerous improvement
projects accounted for the tremendous increase in water quality in New Hampshire.
These projects included the Winnepesaukee basin plant in Franklin, the Boscawen
WWTP, a secondary waste treatment facility in Hooksett, two facilities in
Concord Penacook and Hall Streets, a secondary facility at Alienstown/Pembroke,
six facilities along the Pemigewassett River and six on the Contoocook, a secon-
dary facility in Manchester, another on the Souhegan, and a primary treatment
plant on the Piscataquog.
In Massachusetts, similar efforts were underway to upgrade the river's water
quality. Secondary wastewater treatment facilities were built in six conmuni-
ties along the Merrimack mainstem. Operation of three of those plants - Lowell,
Lawrence, and Haverhill - reduced the amount of BOD5 on the river from these
three towns by an estimated 80%.8 Also significant has been the increase in
D.O. and decrease in coliform bacteria counts. Today, four drinking water
collection sites are in operation in Massachusetts and one in New Hampshire.
These sites are in Lowell, Andover, Methuen, and Lawrence, MA and Nashua, NH.
A sixth withdrawal site is under construction in Tewksbury. Upgraded treatment
has also led to a relaxation of the prohibition against shellfishing in the
estuary. A recent upgrade of the Newburyport waste water treatment facility is
expected to yield even further improvements in the estuary.
Remaining point source concerns along the New Hampshire portion of the river
are pollutant loadings in the Nashua and Manchester-Goffstown areas and inputs
of contaminants from the Nashua River. New Hampshire has determined abatement
projects needed to upgrade the river segments to meet their classifications.
The improvement of 28.8 miles.of the river and several tributaries (52% of
-------
those miles violating standards) is contingent upon the construction of inter-
ceptor sewers and upgrade of the Manchester wastewater treatment facility
eliminating overflows from 33 combined sewers (some of which also discharge in
dry weather) in the Manchester region of the Merrimack and Piscataquog Rivers.ib
The Manchester abatement program will include connecting the sewers in Goffs-
town and West Side to the Manchester facility and building interceptors along
several segments of the river. Non-attainment of standards in the Contoocook
River (which contributes loadings to the Merrimack) is expected to be abated by
construction of the treatment plant in Hillsborough and an upgrade of the plant
in Jaffrey, both of which are near completion. The Nashua River below the
Route 3 bridge and the portion of the Merrimack south of its confluence with
the Nashua extending to Massachusetts are not meeting class C standards (and,
therefore, are significantly below class B standards). Violations in the
Merrimack result from CSOs in Nashua and the low quality of the effluent from
the Nashua STP which provides only primary treatment and is the single largest
pollutant source in New Hampshire. Upgrading the Nashua treatment facility is
expected to help this situation, but separation of combined sewers will prob-
ably be necessary before any significant long-term improvements in these seg-
ments occur. Smaller tributaries in New Hampshire are also suffering from
untreated discharges. Industrial discharges into the Little River aggravate
CSO pollution impacts. The river violates the water quality standards for D.O.
and fecal coliform bacteria.
In Massachusetts, other concerns are largely due to the five tributaries to the
Merrimack - Beaver Brook (Massachusetts portion), Spicket River (Massachusetts
portion), Little River, Powwow River, and Black Rock Creek - which are not sup-
porting their designated uses due to high fecal coliform bacteria counts and
somewhat to Stony Brook which only partially supports designated uses. These
rivers discharge into the Merrimack and impact water quality at and near the
confluences, causing several segments of the mainstem to only partially support
their designated uses. Still of great concern are the CSOs in Lowell, Lawrence,
and Haverhill causing high coliform bacteria counts in these areas as well.
Improvements in the Massachusetts tributaries not supporting uses require
intercepting presently untreated discharges and connecting them to existing
plants. Stony Brook, however, suffers primarily from industrial sources and
urban runoff which elevate coliform levels. These sources acting in conjunction
with many wetlands diminish D.O. levels. The best way of addressing these
concerns is to re-evaluate NPDES permit limits for the industries and upgrade
storm water management practices.°
Plans have been completed for an interceptor CSO and pretreatment project for
Little River. This project should eliminate pollution caused by untreated
discharges and CSOs in Haverhill. Beaver Brook is suffering from both urban
runoff and untreated discharges in Lowell. Untreated discharges are presently
being connected to the Lowell POTW. Construction of a plant in Salisbury is
also needed (and is being planned) to solve the problens on Black Rock Creek.
Untreated discharges in Salisbury are also affecting the mainstem in the estu-
ary. Spicket River is suffering from depleted D.O. and increased nutrient
levels as well as high bacteria counts because of municipal and industrial
discharges in Lawrence. Connection of the Spicket River interceptor to the
Greater Lawrence POTW will alleviate these water quality concerns. Completion
10
-------
of this project is expected in 1988. The Powwow River presently violates fecal
coliform standards due to untreated discharges in Araesbury center and to urban
runoff. Improvements in the Powwow are contingent upon expansion and improve-
ment of sewage systems in Amesbury. Other segments of the Merrimack which only
partially support uses suffer from surface runoff impacts, CSOs, and untreated
discharges in Lowell. CSO abatement work is being planned for Lowell and is
also needed in Haverhill to achieve use support in the remaining segments of
the Merrimack River.
The extent of contamination of the river due to non-point sources (NPS) of
pollution is very difficult to determine. The most likely type of NPS to
impact the river is urban runoff. Stormwater runoff from urban centers may
contain such things as litter, oil and grease, animal wastes, herbicides,
pesticides, and, in winter, chemicals such as road salt from melting snow and
ice. Some other potential non-point sources are landfill runoff, underground
storage tanks, and infiltration of contaminated groundwater. Individual homes
with sewage pipes discharging directly into the river and tributaries are
still scattered throughout the basin and need to be addressed. Non-point
sources include runoff, sedimentation, and erosion from construction sites.
Development poses a potential threat to wetlands along the Merrimack. Priority
wetlands located from Franklin, NH to Lowell, MA are susceptible to general
residential and industrial development pressure as well as hydropower develop-
ment. Wetlands may be threatened not only by NPS, but also by dredging and
filling associated with such projects.
The Massachusetts CWPC has identified some incidences of potential nonpoint
sources of contamination.19 These can be found in Table WQ-3. The degree of
impact caused by these sources is yet to be determined. In an attempt to
determine likely NPS of pollution in New Hampshire, the Water Supply and Pollu-
tion Control Commission (WS&PCC) has compiled land use information in the basin
and has mapped known potential NPS for each community. Agricultural land
occupies 392.4 square miles (10.3%) and roads and highways occupy 123.9 square
miles (3.3%). These are the types of uses that are most likely to contribute
NPS pollutant loadings to the river. Table and Figure WQ-4 give a further
breakdown of the basins land uses.5
When the extent of pollution from NPS has been determined, abatement needs
will be investigated. Nonpoint sources are likely to continue to be a concern
when the river fully supports designated uses as the threats from NPS will
probably not diminish and may even increase. These concerns will remain be-
cause of population growth, increased recreational use, and increased drinking
water withdrawal which are likely results of cleaning the river. Thus, when
water quality improvement activities are complete, water quality maintenance
activities must continue.
The US EPA, Massachusetts Division of Water Pollution Control,and New Hampshire
Water Supply and Pollution Control Commission have determined the point source
problems in the river and are investigating causes of non-point source pollu-
tion and the extent of its contamination. Proposed abatement actions should
improve the quality of the Merrimack to the extent that the entire river and
its tributaries meet fishable/swimmable standards.
11
-------
TABLE WQ-1
GEOGRAPHICAL INFORMATION
MA NH
AREA OF MERRIMACK
BASIN, SO. MI. 1210 3800
AREA OF SUB-BASINS, SQ. MI.
SUDBURY/ASSABET/CONCORD 406
NASHUA 530
STONY BROOK 51
SHAWSHEEN 72
PEMIGEWASSET 1021
WINNIPESAUKEE 486
CONTOOCOOK 766
MERRIMACK MAINSTEM 141 1537
MERRIMACK MAINSTEM BASIN
ASSESSED MILES 72.8 168.5
MERRIMACK MAINSTEM LENGTH 49.8 78
12
-------
TABLE WQ-2
USE SUPPORT STATUS
BASIN
MILES NOT
SUPPORTING USES
MILES PARTIALLY
SUPPORTING USES
MILES
SUPPORTING USE
NEW HAMPSHIRE
1 PEMIGEWASSET
2 WINNIPESAUKEE
3 CONTOOCOOK
4 SOUHEGAN
5 PISCATAQUOG
6 SUNCOOK
7 NASHUA (NH)
8 SPICKET (NH)
9 BEAVER BROOK (NH)
10 POWWOW
11 LITTLE (NH)
12 MERRIMACK (NH)
NH SUBTOTALS
0
0
4.2
5. 9%
0
5.7
18. 8S
0
2
i9.as
0
o
0
0
27.9
42. 3S
39.8
1O. 9X
0
0
11
15. 5*
0
0
3.8
9. 9*
O
0.6
£0. 7*
O
0
0
0
15. A
4.2%
63
100*
17
100%
55. 8
78.6%
31
100%
24.6
81.2%
34. 5
90. 1%
8. 4
80.8%
2.3
79. 3%
22. 2
100%
11.2
10O%
3. 4
10O%
33. 1
57.7%
311.5
84. 9%
13
-------
TABLE WQ-2 (CONT.)
USE SUPPORT STATUS
BPSIN
MILES NOT
SUPPORTING USES
MILES PARTIALLY
SUPPORTING USES
MILES
SUPPORTING USE
1 BEAVER BROOK (MA)
2 POWWOW (MA)
3 BLACK ROCK CREEK
4 LITTLE (MA)
5 SUDBURY/CONCORD
6 ASSABET
7 NASHUA (MA)
8 SPICKET (MA)
9 MERRIMACK (MA)
MA SUBTOTALS
TOTALS
4.2
70*
6.4
100*
1.7
100*
4.3
100*
16.7
28.8*
30
96.8*
11.3
12.7*
6.4
100*
0
81
32. 1*
120.8
19.5*
0
0
0
O
6. 1
10.6*
1
3.2*
35.9
40.4*
0
34.2
68.7*
77.2
30.6*
92.6
15. O*
1.8
3O*
0
0
0
35
60.6*
0
41.6
46.9*
0
15.6
31.3*
94
37.3*
405.5
65.5*
14
-------
Figure WQ-1
DESIGNATED USE SUPPORT STATUS
z
»
;v
60-
50-
40-
30-
20-
10-
ft-
/
!
/
i
f.
t
i
y
y
/
/
y
y
y
/
/
r
y
y
y
^
/
r1
t
y
/
y
7
fl
/
7
y
7
fi
7
1
1
F
\
\
\
F5
^
f.
/.
ftf
\
i
f
(
f t
t
t
tj
1
/
i
/
/
i
/
/
x
7
\
y
/
y
y
y
y
|
X
7
K
/;
i
X
/
s
j
!
F
/c
f
t*
\
X
/
x
J
/
?
p j
V,
I
r»l
1
|
^ 1
1 ! \
n1, M •', >< 0
/
/
/
/
/
y
,»
;
X
/
1
(
x
1
MIE
P/RT9UFPORHNS
15
1 I I
10 11 11
-------
Figure WQ-2
DESIGNATED USE SUPPORT STATUS
ID
4&-
40-
35-
30-
25-
20-
15-
10-
5-
A -
r
7
/
PI
r
i
r
/
/
/
/
/
A
T
\
\
\
7.
'/,
/
V
k
ft>
1
I
s
!
i
j
i
/
i
i
/
/
/
/
/
/
/
P
/
r^
/
^ /
•^
\
\
\
\
\
\
^
\
\
\
\
\
\
\
\
\
\
\
\
\
\
?
y
I
y,
y
%
I*
ft
i
i
ft
i
\
T
'<
n
\
\
\
\
\
\
\
\
\
\
\
\
\
\
\
\
\
\
\
\
i
/
//
I*
fl>
/t
/t
MUS
9UFPOR1NG
16
-------
TABLE WQ-3
POTENTIAL NON-POINT SOURCES OF POLLUTION TO
THE MERRIMACK RIVER BASIN, MA
AMESBURY
ANDOVER
BOXFORD
CHELMSFORD
DRACUT
DUNSTABLE
GROVELAND
HAVERHILL
LAURENCE
LOWELL
MERRIMAC
METHUEN
NEWBURY
NEWBURYPORT
NORTH ANDOVER
SALISBURY
TEWKSBURY
WESTFORD
WEST NEWBURY
X
X
B
1
1
X
1
1
X
X
X
X
X
X
s
X
1
1
1
X
1
1
1
1
c
X
F
3
1
X
X
X
4
1
4
£
KEY: A STORM WATER/URBAN RUNOFF
B SANITARY LANDFILL (LEACHATE)
C SUBSURFACE DISPOSAL SYSTEM FAILURES
D INCINERATOR
E DUMP
F MARINA
G FARM
X PRESENT, BUT NUMBER NOT KNOWN OR NOT APPLICABLE
17
-------
TABLE WQ-A
LAND USE IN THE MERRIMACK RIVER BASIN, NH
PERCENT SQUARE MI
A FORESTS AND OPEN SPACE 78.7 2998.5
B AGRICULTURAL LAND 10.3 392.4
C INLflND WfiTER 4.5 170.7
D ROADS AND HIGHWAYS 3.3 123.9
E RESIDENTIAL 2.5 95.9
F INDUSTRIAL 0.2 8.8
Q COMMERCIAL, PUBLIC BUILDINGS, ETC. 0.5 19.8
18
-------
FIGURE HQ-4
h
u
0
fit
u
D.
A B
D
UNO USE
19
-------
FIGURE WQ-5
MAJOR
DISCHARGERS
-------
Table WD-5
KEY TO MAJOR DISCHARGERS MAP:
101 MA0002984 Vemon Planstics
102 MA0003077 Nye's Japenamelac
104 MA0021628 Coastal Metal Finishing
108 MA0000281 Gould
109 MA0001261 AT&T Technologies (W)
110 MAOOQ2208 Microfab
M14 MA0100447 Greater Lawrence
M15 MA0100633 Lowell
M16 MA0101427 Newbucyport
M17 MA0101621 Haverhill
M18 MA0101745 Amesbury
113 MA0024414 Westford Anodizing
M20 NH0100030 Bay Sewage District
M21 NH0100005 Ashland WTP
M22 NH0100595 Jaffrey
M23 NH0100706 Lincoln
M24 NH0100781 Waterville Valley
121 NH0001015 Surrette Storage Battery
122 NH0001023 Interlake
M25 NH0100960 NH WS&PCC - WRB#1
M26 NH0100331 Concord - Penacook
123 NH0001511 Hoague-Sprague
M27 NH0100901 Concord - South
M28 NH0100102 Henniker MTP
124 NH0001465 P. S. Co. of NH
M29 NH0100714 Allenstown
125 NH0001325 GTE Products
M30 NH0100129 Hooksett WTP
126 NH0001341 General Electric
M31 NH0100081 Goffstown
127 NH0000230 Monadnock Paper Mills
M32 NH0100447 Manchester
M33 NH0100471 Milford
M34 NH0100056 Derry
M35 NH0100650 Peterborough WPCF
129 NH0001571 Hendrix Wire and Cable
M36 NH0100161 Merrimack WTP
M37 NH0100773 Salem*
M38 NH0100170 Nashua STP
130 NH0001376 Hitchiner Manufacturing Co.
131 NH0000591 WR Grace (South Nashua)
* The treatment plant in Salem has ceased discharge as of this writing,
KEY TO WATER QUALITY DESIGNATIONS
Bold Printing = fully supporting designated uses
Pale Printing = partially supporting designated uses
Dotted = not supporting designated uses
21
-------
CONSTRUCTION GRANTS
The Water Pollution Control Act Amendments of 1972 (PL 92-500) mandated that
pollution was to be controlled at its sources. The Federal Water Pollution
Control Act provided funds for the construction of municipal wastewater treat-
ment facilities and the elimination of direct river discharges of untreated
sewage. The majority of funding has gone to the abatement of municipal dis-
charges. The U.S. Environmental Protection Agency (EPA), the DWPC in Massa-
chusetts and the WS&PCC in New Hampshire administer a Construction Grants Pro-
gram whereby federal and state funds are made available to cities and towns for
the construction of publicly-owned wastewater treatment facilities. Prior to
fiscal year 1984, allotments had generally amounted to federal participation of
75 percent and state participation of 15 percent (Massachusetts) or 20 percent
(New Hampshire) of the costs of treatment facilities construction to be supple-
mented with a municipal share for the remainder. Beginning with fiscal year
1984, the federal portion of the project funding was reduced to 55 percent.
Each fiscal year, EPA informs the states of tt>e;-amount of construction grants
money they will be receiving. Within that tbt^l, each state develops a prior-
ity list of which projects can receive funding, (see Appendices C and D for
states' priority systems). There is never/enough money to cover all the pro-
jects, but the states make their funding 'determinations on the basis of the
severity of the pollution problems, number of. the people affected, and testi-
monies made at public hearings. Table CG-1 .identifies the construction grants
funding status (as of August 12, 1986) of'municipalities within the scope of
this report that have either direct discharges; to the Merrimack River or to one
of its tributaries. Table CG-2 indicates the type of wastewater treatment
facilities that have been or are being constructed and those that are expected
to be constructed and their funding status. ~
Almost all of these municipalities have constructed or are constructing waste-
water treatment facilities which will meet at least the level of secondary
treatment. There are municipalities that still need to construct facilities
to either eliminate raw sewage discharges or upgrade their treatment facilities
from primary to secondary treatment. The City of Manchester, NH, for example,
began operating a 26 million gallon per day (MGD) facility in 1976, but it
needs to be enlarged in order to accept the wastewater from the nearby towns
of Bedford, Goffstown and Londonderry. Upgrade plans include interceptors to
eliminate raw sewage discharges from the City's west side. Construction of
interceptors is scheduled to begin during fiscal year 1988, but the expansion
project is not expected to be undertaken for several years. The City of
Nashua, NH has completed most of its interceptor sewers, but the wastewater
treatment plant provides only primary treatment. The construction of a new
secondary wastewater treatment plant is scheduled to commence during fiscal
year 1987.
Even when the above cities and towns have completed construction of wastewater
treatment facilities for providing secondary treatment, either on their own or
through intermunicipal arrangements, a number of municipalities will still have
the task of dealing with pollution discharges from combined sewer overflows
(CSO). For example, the cities of Lowell and Haverhill, MA are served by
relatively new secondary wastewater treatment facilities that are connected to
22
-------
complex sewerage collection systems. The older portions of the sewerage col-
lection systems were designed to transport both stormwater and sanitary waste-
water for disposal to the Merrimack River without treatment. Today most dry
weather sewage flows are transported and treated prior to discharge to the
river. During rain storms, however, runoff collected in storm drains enters
the combined sewerage system, mixes with sanitary wastewater and, when flows
exceed the capacity of the sewerage collection system, discharges without
treatment to the Merrimack River, causing the most significant water quality
problems that the river experiences.
From a water quality standpoint, complete separation of sanitary wastewater
and stormwater is usually the most desirable alternative for eliminating the
impacts of CSOs. However, due to high costs and major construction impacts,
complete sewer separation is not always feasible. A possible drawback to
complete separation may exist in large cities where urban runoff can be seri-
ously contaminated by metals and other pollutants. Other alternatives include
the storage and treatment of combined wastewater at the overflow point and/or
remedial repairs to the existing sewerage collection system. The magnitude
and quality of CSO loadings should be assessed as well as water use impairment
and any associated economic losses due to CSOs whenever possible.
KEY TO TABLES ON FOLLOWING PAGE;
* Estimated Federal Grant Amount
**Estimated Project Cost
WWTP = Wastewater treatment plant
P.S. = Pump station
F.M. = Force main
Fac. = Facility
CSO = Combined sewer overflow
Int. = Interceptors
= Municipality has facilities that were not funded under PL 92-500 (Table
CG-1), or no additional funding has been identified (Table CG-2)
23
-------
Construction Grants Status of Municipal Facilities
TABLE CG-1
ESTIMATED GRANT FUNDING SINCE PASSAGE OF PL 92-500 (OCTOBER, 1972 ).4
Municipality Grant Funds Type Facilities
Amesbury, MA
Ayer, MA
Fitchburg, MA
Greater Lawrence S.D., MA
Haverhill, MA
Leominister, MA
Lowell, MA
MDC-Clinton, MA
Newburyport, MA
Salisbury, MA
West Fitchburg, MA
Allenstown S.C., NH
Concord, NH
Derry, NH
Goffstown, NH
Henniker, NH
Hooksett, NH
Jaffery, NH
Manchester, NH
Merrimack, NH
Milford, NH
Nashua, NH
N.H.W.S. & P.C.C.- WRB #1
Peterborough, NH
Salem, NH
3,171,444
11,442,000
1,407,323
47,577,695
23,968,138
18,255,978
65,882,339
1,120,009
14,830,692
8,207,566
4,076,250
41,304,374
7,705,851
359,346
1,954,561
32,366
3,760,219
26,334,602
19,353,940
12,758,147
4,607,908
48,537,456
1,431,779
TABLE CG-2
WWTP, Int., P.S.,F.M,
Interceptors
WWTP, Int., P.S.
WWTP, Int.
WWTP
WWTP, Int., P.S.
WWTP, Int., P.S.
WWTP, Int.
WWTP, Int., F.M., P.S.
WWTP, P.S.
Interceptors
WWTP, Int.
Interceptors
WWTP, Int.
WWTP, Int., P.S., P.M.
n ii n ••
n
n
WWTP, Interceptor
WWTP, Int., P.S.'s, P.M.
Interceptor
ESTIMATED FUTURE FUNDING NEEDS4
Municipality
Greater Lawrence S.D. , MA
Haverhill, MA
Leoninster, MA
Lowell, MA
Newburyport, MA
Salisbury, MA
Derry, NH
Goffstown, NH
Hooksett, NH
Jaffery, NH
Manchester, NH
Merrimack, NH
Nashua, NH
N.H.W.S. &P.C.C.-W.R.B.#1
Proposed Costs
1,995,000*
3,640,000*
630,000*
17,390,000*
70,000*
350,000*
4,240
7,900
10,900
2,500
79,006
28,000
56,400
16,530
,000**
,000**
,000**
,000**
,000**
,000**
,000**
,000**
Type Facilities
WWTP Improvement
Sludge Fac., CSO
Interceptor
Int., CSO, P.S.
CSO
Int.
Interceptors
Interceptors
WWTP Additions, Int.
Interceptors
WWTF, Int., Separation
Treatment Additions & Int.
WtfTF, Int., Separation
Interceptors
24
-------
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
All point sources of pollutants which discharge to surface waters of the United
States are required, by law, to have a permit under the National Pollutant
Discharge Elimination System (NPDES). Permittees are categorized as municipal
or industrial. These two categories are both further divided into "manor" and
"minor" permits. J
Determination of major industrial status involves a rather conplex process. A
point system is used with various factors given different weights. Those plants
with sufficient points are considered major; all others are minor. The points
are based on toxic pollutant potential (according to industry type), wastewater
£low rate, type of wastewater (non-contact cooling water, process wastewater,
sanitary wastewater, etc.), amounts of conventional pollutants, heat load, pre-
sence of downstream water supply, and water quality limitations of the stream.
Municipal treatment facilities, also called Publicly Owned Treatment Works
(POTWs), are operated by a town, city, or state. POTWs are considered major if
tney (1) have a flow equal to or greater than one million gallons per day,
(2) impact downstream uses, or (3) discharge upstream of a public water supply.
All other municipal permits are classified as minor. Funding is available for
the construction of municipal wastewater treatment facilities through Public
Law 92-500 which was passed by Congress on October 18, 1972, to amend the Fed-
eral Water Pollution Control Act. A key element of the Act was a substantial
increase in the amount of federal funding available for the construction of
municipal treatment plants. Those treatment plants constructed with federal
funds since passage of the Act are called P.L. 92-500 plants and are closely
monitored to ensure that they are properly operated and maintained and are in
compliance with their NPDES permit limits.
Despite these monitoring efforts, some dischargers still violate permit limit-
ations. These concerns are further discussed in the Compliance section of the
report. The National Municipal Policy (NMP) which was published in the Federal
Register on January 30, 1984, is a national initiative requiring that all muni-
cipal dischargers be in compliance with the mandates of the Clean Water Act
by July 1, 1988. In most cases this requires that the municipality provide
secondary treatment for its discharge. However, in some cases, advanced treat-
ment beyond secondary is required to protect the water quality of the receiving
stream. Under the NMP, those treatment plants which do not appear to be advanc-
ing toward this goal may be issued an Administrative Order with a legally
binding schedule for meeting treatment requirements. Any municipalities which
are not expected to comply with the requirements of the CWA by the deadline
are placed on court-ordered schedules of compliance. These discharges become
priority enforcement cases.
Within the Merrimack basin as a whole are 24 major industrial dischargers.
There are 71 municipal wastewater treatment plants, of which 35 are major dis-
chargers. Eleven of the majors are located on waters which have been deter-
mined not to be negatively impacting the river. Only those on the mainstem
and on tributaries believed to have a significant impact on the mainstem will
be addressed further.
25
-------
MUNICIPAL PERMITS
There are 71 discharges fron municipal sources in the Merrimack River Basin.
Of these, 24 are major discharges which will be addressed in the report.
These will be addressed because they discharge either into the mainstem or
into a tributary which significantly impacts the mainstem (those discussed in
the Water Quality section of the report ). Twenty-six of the discharges go
-into tributaries which significantly impact the river, but of these only 11 are
major. Of the 22 which discharge directly into the Merrimack, only 13 are major
dischargers.
The degree of impact that any given discharge has on the receiving water is
related to several characteristics of the treatment plant and of the effluent.
Dischargers with toxicity testing requirements, pretreatment programs, and/or
combined sewer overflow limitations are expected to have more significant
impact because of the probable presence of toxics entering the POTWs from
industries and the higher levels of fecal coliform bacteria and BOD associated
with CSOs. At the present, there are 16 treatment plants impacting the Merri-
mack River which have pretreatment programs and only eight with toxicity test-
ing. Because of the ever-present potential of toxicity in an industrial
effluent, all municipal plants with pretreatment programs will be required to
conduct toxicity tests within approximately one year. For example, permits are
presently being written for Derry and Concord-South which include toxicity
testing. Municipalities with active permits that do not contain toxicity test-
ing requirements will be notified pursuant to Section 308 of the CWA that they
will be required to submit toxicity information. Tables M-l and M-2 give infor-
mation on toxicity testing and pretreatment program requirements and CSO limi-
tations for major dischargers into the mainstem and tributaries, respectively.
( Note: A "Y" in the CSO column indicates permitted CSOs. Any CSOs not in the
municipality's permit are illegal.) The mainstem dischargers are listed in or-
der from the mouth upstream.
TABLE M-l
MAJOR MUNICIPAL DISCHARGERS INTO THE MERRIMACK RIVER MAINSTEM
Municipality Permit No. Level of Toxicity Pretreatment CSOs
Treatment Testing Program
Newburyport WPCF MA0101427 SEC Y Y Y
Amesbury MA0101745 SEC N Y N
Haverhill WTP MA0101521 SEC N Y Y
Greater Lawrence SD MA0100447 SEC N Y Y
Lowell MSS MA0100533 SEC N Y Y
Nashua STP NH0100170 PRI Y Y Y
Merrimack WTP NH0100161 SEC N Y N
Derry WWTP NH0100056 SEC N Y N
Manchester NH0100447 SEC Y Y Y
Hooksett WTP NH0100129 SEC N N N
NHWS&PCC - WRB#1 NH0100960 SEC Y Y N
Concord-Penacook NH0100331 SEC Y Y N
Concord-South NH0100901 SEC Y Y Y
Note: NH WS&PCC conducts annual biotoxicity testing at each major POTW.
KEY TO LEVEL OF TREATMENT; PRI = primary
SEC = secondary ADV = advanced
26
-------
TABLE M-2
MAJOR MUNICIPAL DISCHARGERS INTO SELECTED MERRIMACK TRIBUTARIES
Municipality
Ayer WTF
MDC-Clinton
Leominster DPW
Fitchburg WTP
West Fitchburg WTP
Milford
Alienstown Sewer
Henniker MTP
Peterboro WPCF(T)
Jaffrey STP
Goffstown STP
Permit No. Tributary Level of Toxicity Pretreatment CSOs
Treatment Testing
N
N
N
Y
N
N
Y
N
N
N
N
MA0100013
MA0100404
MA0100517
MA0100986
MA0101281
NH0100471
NH0100714
NH0100102
NH0100650
NH0100595
NH0100439
Nashua
Nashua
Nashua
Nashua
Nashua
Souhegan
Suncook
Contoocook
Contoocook
Contoocook
Piscataquog
SEC
SEC
ADV
ADV
PPJ
SEC
SEC
SEC
SEC
SEC
PRI
Program
N
Y
Y
Y
N
Y
N
N
N
N
N
N
N
Y
Y
N
N
N
N
N
N
N
The Merrimack River mainstem receives a total of 120.2 MGD of direct municipal
discharges as well as 54.94 MGD effluent from discharges into some of its tri-
butaries ( see Table M-3 ) fron both major and minor facilities. These volumes
are based on the design flows of the treatment plants; therefore, actual input
from the treatment plants is probably less. However, actual pollutant input
from CSOs is unknown as flow rates from these outfalls are not monitored. Their
input is significant because of the the extremely poor quality of the water
they discharge. Potential impact from the combination of the pollutant sources
can best be imagined when the flow rate is compared to that of the river. The
total loading of municipal sources into the river of 172.8 MGD is 29% of the
river's 7Q10 of .601 MGD (measured at Lowell, MA). It is, however, a much small-
er fraction of the 4,900 MGD average river flow.
TABLE M-3
TOTAL LOADINGS TO THE MERRIMACK RIVER AND SELECTED TRIBUTARIES
River (state) Flow, MGD
Powwow River (MA) 0.085
Beaver Brook (MA) 4.37
Merrimack mainstem (MA) 94.2
Nashua River (NH) 39.5
Souhegan River (NH) 2.41
Piscataquog River (NH) 0.52
Suncook River (NH) 1.45
Contoocook River (NH) 2.4
Merrimack mainstem (NH) 30.2
BOD, Ib/day
360
23,160
3,850
428
504
360
754
48,300
TSS, Ib/day
21.2
720
23,181
Number of
Dischargers
1 minor
1 major
major, 7 minor
4,700
608
314
360
817
32,640
5
1
1
1
3
8
major,
major,
major,
major,
major,
major,
3 minor
2 minor
2 minor
1 minor
5 minor
3 minor
27
-------
PRETREATMENT
Pretreatment programs are developed to control the industrial contribution
being discharged into the sewers of the Publicly Owned Treatment Works (POTWs).
The industrial pretreatment program limits these discharges to eliminate inter-
ference with the operation of the treatment plant, control toxicants from
passing through the treatment system unremoved, reduce the toxicity of the
discharge by reducing the concentration of pollutants, and ensure against
violating the water quality standards. Each municipality develops a program to
meet its site-specific needs. There are several requirements in establishing
pretreatment programs. These requirements are legal evaluation of the POTW
prior to operation and enforcement of the pretreatment program, an industrial
survey, the establishment of procedures for controlling and monitoring the dis-
charges, and necessary resources of personnel and funding to run the program.
There are 19 POTWs in the Merrimack River Basin that are required to have in-
dustrial pretreatment programs. Of these, 16 are located either on the main-
stem or on tributaries which have a significant impact on the Merrimack. The
breakdown is as follows:
Massachusetts New Hampshire Totals
Main stem 5 7 12
Tributaries 314
Total 8 8 16
Part of the program approval requirements is the stipulation that the POTW
establish local limits for the discharges into their sewer systems. These
limits are the levels determined not to cause adverse effects that the POTW
will allow to be discharged into the sewers. The industrial discharges are
required to discharge at the lower of the local limits or the federal cate-
gorical standards established by the US EPA based on industry type. The pro-
cedures for determining these local limits are being refined as toxicity infor-
mation is discovered, removal efficiencies are improved, and waste load allo-
cations are performed.
Presently, local limits are based on allowing each pretreatnrent community 50%
of the river capacity based on a 7Q10 low flow and the National Ambient Water
Quality Criteria limits. This preliminary effort, which was needed to initiate
the programs, allocates more than 100% of the river capacity at some locations.
The next phase of modeling should be based on the actual capacity of the river
to assimilate the pollutants. The mathematical modeling for this effort can be
quite complex. Each Merrimack community with a municipal treatment plant will
be seeking the largest allocation possible and needs to be involved from the
initiation of such efforts.
28
-------
INDUSTRIAL PERMITS
Presently, EPA maintains a listing of 24 major active industrial permits in the
Merrimack and Concord/Sudbury sub-basins. Eight of the 24 either discharge to
the main stem of the river or to lesser tributaries which impact the Merrimack.
The permits for the main stem discharges are listed below starting upstream
from the mouth of the Merrimack. See Table 1-1 for more discharge information.
Gould Inc., Newburyport MA0000281
AT & T Technologies - Western Electric, N.Andover MA0001261
W.R. Grace and Company, Nashua NH0000591
Public Service Company of NH, Merrimack NH0001465
The permits for the lesser tributaries are issued to the following industries.
Coastal Metal Finishing Inc., Merrimac MA0021618
Vernon Plastics, Haverhill MA0002984
Microfab Inc., Amesbury MA0002208
General Electric Company, Hooksett NH0001341
The largest discharger of this group, and in fact, the largest discharger
volume-wise in the entire basin is the Public Service Company of NH. The
company's primary discharge is 190 MGD of once-through cooling water from the
electrical generators. The company also discharges a large volume (5 mgd) of
water from an ash settling pond. Gould, Microfab, Coastal Metal Finishing,
AT&T Technologies and General Electric, all in the category of metals form-
ing, electroplating, and finishing, are dischargers of metals including cya-
nide, copper, silver, zinc, tin, chromium, iron, lead, nickel, aluminum and
cadmium. The companies also use various organic solvents in degreasing and
stripping metal. The AT&T permit includes a treated sanitary discharge of
200,000 GPD. Noncontact cooling waters are also provided for in the Coastal
Metal and the GE-Hooksett permits. W.R. Grace is a manufacturer of organic and
inorganic chemicals for agricultural and domestic uses with a discharge of
0.35 MGD. The Grace permit, which was issued in 1985, requires the completion
of in-situ and laboratory bioassays during the late summer of 1986 in order to
establish what effects the permitted effluent might be having on aquatic life
in the Merrimack during low flow conditions. The results are not yet available.
Vernon Plastics is a former of plastic materials and resins.
Three active major industrial permits are maintained in the Concond/Sudbury
watershed.
NYE Japenamelac Inc., Chelmsford MA0003077
Silicon Transister Corp., Chelmsford MA0025241
Raytheon Company, Wayland MA0001511
All three industries are dischargers of metals. Japenamelac is a metal coater
with a 3,000 GPD discharge. Silicon Transister is a maker cf semi-conductors.
Raytheon1s Wayland Lab is an electroplating firm.
29
-------
Stony Brook receives treated process wastewaters from Westford Ancdiziny,
another metal finisher.
Westford Anodizing, Westford MA0024414
The Nashua River receives discharges from seven major industries.
Colorcraft Corp. of New England, Fitchburg MA0000221
Polysar Inc., Leominster MA0000442
Suprenant Wire and Cable, Clinton MA0001783
Hollingsworth and Vose Company, Groton MA0004561
Shell Oil Company, West Boylston MA0004863
James River Corporation, East Pepperell MA0005185
Advance Coatings Company, Westminster MA0024686
Colorcraft is a photo finishing laboratory. Polysar is a former of plastic
materials and resins. Suprenant Wire maintains a permit which includes four
outfalls for contact and non-contact cooling waters. Hollingsworth and Vose
Co. and James River Corporation are paper makers with average discharges of 2 to
3 MGD and 1 to 2 MGD, respectively.
The Shell Oil petroleum bulk storage terminal in West Boylston is permitted to
discharge stormwater runoff after oil/water separation. Their present permit
expired in 1978 and is under review for reissuance. The reissuance is in dis-
pute because the discharge leads to the Wachusett Reservoir, an MDC water
supply source. A high degree of treatment would be required in order for the
discharge to meet water quality-based limits. Advance Coatings is a former of
plastic materials and resins.
There are two active major industrial permits issued to dischargers on the Sou-
hegan River. These facilities are located on adjoining sites in Milford, NH.
Hitchiner Manufacturing Company, Milford NH0001376
Hendrix Wire and Cable, Milford NH0001571
Hitchiner is a steel foundry which discharges both process and cooling water.
Hendrix is a non-ferrous wire drawing, coating and insulating facility.
Both the Hitchiner and the Hendrix permits require toxicity monitoring.
There are three NPDES major permits issued to industrial facilities on the
Contoocook River.
GTE Products Corp - Sylvania, Hillsborough NH0001325
Monadnock Paper Mills, Bennington NH0000230
Hoague-Sprague Corp., Hopkinton NH0001511
GTE makes electrical lamps. The company discharges a process wash and rinse
wastewater and a treated sanitary wastewater. Monadnock is a 1.0 MGD paper
mill and Hoague-Sprague is a smaller paper mill (less than 50,000 GPD).
30
-------
Summary of Major Industrials
»L^e 24 f^ industrial NPDES permits issued for the Merrimack River basin,
GIQilL. cHT6 -LOCcktOCi in NGW H3HTT"\Qh i yo arwH *-J^^^ W-*^T«-%-i »* -i —.—. i /~ • .. .
^^ "%-" **w*ii^/Ol i-i-i-C CIJ1VJ UlC CTcITiq 1 J] LfjQ ^Q 31TG IF! MSR^rif^hl IQOf" f" C
source by far is from non-contact cooling water discharg-
n Ic ^ no mr^& 4- £*^*^s*t \*+.MI. .^*»..__-___*-.^ • i _ _
M scarg-
Metal finishing is the most frequent source of discharge and paper mills
are second In addition to the 24 major permits, there an? !41 mSS 4us-
trial permits presently issued in the Merrimack Basin.
31
-------
TABLE 1-1
SUMMARY OF INDUSTRIAL DISCHARGERS
Company Type of Discharge
Coolin
Water
Merrimack River
Gould Inc.
AT&T Technologies
W. R. Grace & Co.
Public Service Co. NC
Lesser Tributaries
Coastal Metal NC
Vernon Plastics NC
Pollutants Regulated Toxicity
Microfab Inc.
G. E. - Hooksett
NC
Concond/Sudbury
NYE Japenamelac Inc.
Silicon Transister
Raytheon Co. X
Stony Brook
Westford Anodizing
Nashua River
Colorcraft Corp. X
Polysar Inc.
Suprenant Wire X
& Cable
Hollingsworth
& Vose Co.
Shell Oil Co.
James River Corp.
Advance Coatings X
Souhegan River
Hitchiner Mfg. Co. X
Hendrix Wire &
Cable
Contoocook River
GTE - Sylvania
Monadnock Paper
Hoague-Sprague
ng Process Treated
ir Water Sanitary
X
X X
X
X
X
X
X
X
X
X X
X
X
X
Metals
X
X
X
X
Cr
X
X
X
X
X
X
<
Organics
TTO
TTO
X
TTO
Phthalate
esters
TTO
TTO
TTO
TTO,PCE
TTO
styrene,
Conven-
tionals
TSS, O&G
TSS, O&G
BOD, TSS
TSS, O&G
BOD,
TSS, O&G
TSS, O&G
TSS, O&G
TSS, O&G
TSS, O&G
BOD,TSS,
Cl Other
X F
X F
X
X F
X F
X F
F
X
NH3
Testing
X
X
X
stormwater
X
X
X
phenol,acetone, 0&G,SS
ethyl benzene
X phenol
BOD,TSS,SS
TCE,EDB,benzene
BOD,TSS,SS
toluene,TTO, O&G
styrene
X tetrachloro-
ethylene,acetone
1,1,1-trichloroethane
acetophenone TSS,O&G
methyl stryene
TTO BOD,TSS >
0&G,SS
BOD,TSS,0&G,SS
BOD,TSS,0&G,SS
32
-------
KEY TO ABBREVIATIONS;
BOD = Biochemical Oxygen Demand
Cr = Chromium
EDB = Ethylene dibromide
F = Flourides
NH3 = Ammonia
O&G = Oil and Grease
P = Phosphorus
PCE = Perchloroethylene
TCE = Trichloroethylene
SS = Settleable Solids
TSS = Total Suspended Solids
TTO = Total Toxic Organics
Metals include any or all of the following:
Cadmium
Aluminum
Nickel
Lead
Iron
Chromium
Tin
Zinc
Silver
Copper
Cyanide (Although not actually a metal, it is grouped with them.)
All discharges are regulated for pH.
All cooling water discharges are regulated for temperature.
33
-------
COMPLIANCE
There are currently 17 major sources that discharge directly to the main stem
of the Merrimack River. Twelve of the sources are municipalities and five are
industries. Below are listed the seventeen major sources with the current
compliance status of each. The sources are listed in order by location from
the mouth of the Merrimack in Massachusetts to the headwaters in New Hampshire.
MUNICIPAL TREATMENT PLANTS
The City of Newburyport, MA owns and operates a 2.4 MGD secondary plant which
currently discharges about 1.4 MGD. The existing plant, which was constructed
with PL 92-500 funds, became operational in 1984, replacing a primary treatment
facility. After a long startup period during which there were numerous viola-
tions with effluent limits, the plant has achieved compliance with its effluent
limitations. The permit allows wet weather discharge from four CSOS and re-
quires the city to submit a program of abatement or elimination of the CSOs.
Newburyport is required to use best practicable treatment such that water qua-
lity standards are not violated. The City was issued an administrative order
in October, 1985 for deficiencies in implementing its pretreatment program.
The City complied with the order and is now carrying out the program.
The Town of Amesbury, MA owns and operates a 1.9 MGD secondary plant which cur-
rently discharges about 1.7 MGD. The plant came on line in 1976. The effluent
from the plant consistently violates the limitations established in its permit
primarily due to severe I/I, industrial wastes, and operational problems caused
by solids overloading. The Town's pretreatment program is presently being re-
viewed by the EPA. The MDWPC issued an order to the Town on December 31, 1985
which established a sewer connection moratorium and required the Town to remove
excessive I/I from its collection system, to dispose of excess sludge, and to
develop a pretreatment program. The Town is permitted to discharge through
four combined sewer overflows subject to the Town's provision of treatment
necessary to meet water quality standards.
Haverhill, MA owns and operates an 18 MGD secondary plant which serves the City
of Haverhill and the Town of Groveland. The plant, which was constructed with
PL 92-500 funds, began operating in 1977 and currently discharges about 10 MGD.
The plant rarely has effluent violations. Those which do occur are usually
due to high flows from the combined sewer system. The City has a pretreatment
program which is progressing with little problem. The City is permitted to
discharge through 16 combined sewer overflows subject to the City preparing a
monitoring program to demonstrate whether the overflows need treatment to meet
water quality standards. The program has been developed and submitted to EPA.
The Greater Lawrence Sanitary District owns and operates a 43 MGD secondary
treatment plant with a design flow rate of 52 MGD which serves Lawrence and
the Towns, of North Andover, Andover, Methuen, MA, and Salem, New Hampshire.
Because it receives industrial effluents, it is required to have a pretreatment
program which it is implementing. The plant also provides septage disposal and
PCTW sludge disposal for numerous cities and towns in eastern Massachusetts.
The plant, which was constructed with PL 92-500 funds, came on line in 1977 and
currently discharges about 35 MGD. The plant only rarely violates its effluent
34
-------
limitations. There are no current enforcement actions by either EPA or the
MDWPC against the District. The District is permitted for five combined sewer
overflows subject to meeting water quality standards. The District is required
to perform a CSO study to demonstrate whether treatment is needed at the over-
flow points within one year of completing the Spicket River interceptor. The
interceptor will eliminate five other combined sewer overflows permitted to the
City of Lawrence (MA0102041) and will affect the amount of flow discharging
through the GLSD overflows.
Lowell, MA owns and operates a secondary treatment plant with a permitted flow
of 26 MGD and a maximum design flow of 32 MGD. The plant serves the City of
Lowell and the Towns of Dracut, Tyngsboro, and Tewksbury. The permit allows
discharges through 15 combined sewer overflows which are subject to meeting
water quality standards. A monitoring program is to be developed which will
demonstrate whether treatment is needed at the overflow points. The city also
has untreated dry weather discharges of about 5 MGD. These discharges will
be eliminated upon completion of two interceptor projects currently under
construction. The interceptor projects are scheduled to bi completed by the
end of 1987. The plant, which was constructed with PL 92-500 funds, came on
line in 1980 and currently discharges about 15 MGD. The plant frequently
violates its effluent limitations. Also, due to chronic problems with its
influent raw sewage pumps, the City frequently bypasses the plant at flows
within the design capacity of the facility. Lowell does not presently have an
approved pretreatment program and, thus, is in violation of its permit's pre-
treatment program requirements. The City was issued an administrative order
by EPA on April 22, 1985 requiring the City to perform an evaluation of the
facility, to recommend solutions to any problems identified, and to submit
implementation schedules for the recommended solutions. The City completed
an acceptable report but failed both to submit the required plan and schedules
and to correct the deficiencies identified by the report. The MDWPC has also
taken formal enforcement action against the City by issuing an administrative
order on July 16, 19.86 requiring the City to submit a schedule for rehabilita-
tion of the treatment plant and to hire a contractor to operate and maintain
the plant. The City has not complied with the state order.
Nashua, NH which owns and operates a 22.4 MGD primary treatment plant including
11 CSOs to the Merrimack River has not been able to comply with the secondary
effluent limits contained in its NPDES Permit. As part of the NMP initiative,
an administrative order was issued to Nashua on July 11, 1985 requiring that
by October 1, 1986 the city submit a Step III application for grant assistance.
The application has been submitted. The order further required that the City,
by March 1, 1987, start construction of the secondary treatment facilities;
by May 30, 1988, complete construction; and by July 1, 1988, achieve compliance
with the permit's effluent limits. The City, which is on the FY-87 construc-
tion grants priority list, has not violated the order to date; however, the
construction schedule is extremely ambitious for such a large project and the
City may not meet the July 1, 1988 deadline. A court ordered schedule would
then be required by the NMP. Although Nashua's pretreatment program was only
recently approved it appears that the program is being well implemented.
35
-------
Merrimack, NH owns and operates a 5.0 MGD secondary treatment plant that was
constructed with PL 92-500 funds and is generally in compliance with its NPDES
permit limits.
Derry, NH owns and operates a 1.2 MGD secondary treatment facility that is cur-
rently being upgraded with PL 92-500 funds. As part of the NMP initiative an
administrative order was issued to Derry on July 22, 1985 requiring the Town to
upgrade the treatment facility to comply with its permit limits by June 1987.
The Town has an approved pretreabment program which is being well implemented.
Manchester, NH owns and operates a 26.0 MGD secondary treatment plant that was
constructed with PL 92-500 funds. It is generally in compliance with its NPDES
permit effluent limits (which only regulate discharges on the east side of the
city), including implementation of its pretreatment program. However, the west
side of Manchester's sewage collection system is not connected to the treatment
plant and will not be until the necessary interceptors are constructed in several
years. Other interceptors are needed and are scheduled to be built in the north-
east and northwest areas of Manchester. The city has a combined collection
system which contains 33 combined sewer overflow points to the Merrimack and
Piscataquog Rivers. The permit requires that the discharges receive best conven-
tional treatment (BCT). BCT, at a minimum, is the most economical treatment
necessary so that the discharge does not violate the water quality standards of
the receiving water and contains no septage or holding tank waste. Despite this
requirement, until the construction of necessary interceptors, up bo 4 MGD of
untreated sewage is being discharged in to the Merrimack River. The City of
Manchester will be addressed by the NMP since it cannot provide secondary
treatment for the discharge from the west side. A schedule will be developed
for construction of the necessary interceptors.
Hooksett, NH owns and operates a 0.8 MGD secondary treatment plant which is
generally in compliance with its NPDES permit effluent limits.
Concord (South), NH is a 10.1 MGD secondary plant that was constructed with
PL 92-500 funds. It is generally in compliance with its NPDES permit limits.
Sewer separation projects have eliminated all but one of the former CSOs. The
remaining CSO will be eliminated by 1988.
New.;Hampshire Water Supply and Pollution Control Commission - Water Resources
Board operates an 11.5 MGD secondary plant that was constructed with PL 92-500
funds. It is generally in compliance with the NPDES permit effluent limits,
but is having some minor problems with the pretreatment program.
INDUSTRIAL TREATMENT PLANTS
Microfab Inc., which discharges to an intermittent brook to the Merrimack, was
issued an administrative order on July 16, 1985 requiring the company to upgrade
its treatment system to meet the permit effluent limits by December 15, 1986.
The company was bo begin construction June 15, 1986, but has not yet begun. The
plant has been in chronic non-compliance with its interim copper limit, but
returned to compliance in June. Microfab also has occasional violations of
fluoride limits, which are being investigated by the company.
36
-------
Gould Inc. has experienced frequent violations of its effluent limits for
copper, tin, and silver. The company has plans to install a polishing filter
in early 1987. Inspections by the state indicate that staffing is inadequate.
AT & T Technologies is generally in compliance, but with occasional violations
of pH and oil and grease.
W.R. Grace, in Nashua, produces organic and inorganic chemicals and discharges
0.35 MGD of treated wastewater to the Merrimack River. The discharge does not
comply with the NPDES permit limits and an administrative order was issued to
the company on May 21, 1986 requiring the company to install the necessary
treatment to comply with the permit limits by July 1, 1988.
Public Service Co. of New Hampshire - Merrimack which discharges 190 MGD of
cooling water from electrical power generation cooling equipment has experi-
enced problems in meeting the chlorine limits in its permit. The discharge
does not appear to be threatening the quality of the water. Permit modifi-
cation is planned for fiscal year 1987.
37
-------
WATER SUPPLY SURFACE AND GROUND WATER
Introduction
The Merrimack River basin is the water supply source for seven communities in
Massachusetts and three in New Hampshire, providing 33 MGD (some of which is
groundwater) to over 237,000 people in MA alone (Table DW-1). There are 11
communities using or considering using the Merrimack River as a water supply
source. The Massachusetts Water Resource Authority (MWRA), which represents
35 communities in the Boston metropolitan area is known also considering the
feasibility of using the Merrimack as a future drinking water source (Table
DW-1). The withdrawal from the Merrimack, if all of these communities do
S^o?? S^^u"9 ^ winter/sPrin9 "cod flows, would be approximately 350
MGD, 235 MGD for the MWRA alone (Table DW-1). MWRA estimates this to be a 2%
reduction in flow downstream in the Lowell area. The majority of the present
suppliers treat and the future suppliers plan to treat the water with a full
treatment scheme including activated carbon (Table DW-1). Despite the ability
of this type of treatment to remove a broad spectrum of contaminants the basin
area is faced with the challenge of providing a high quality drinking water
from a low quality surface source (from a drinking water perspective). Although
groundwater quality is generally quite good there are localized areas of conta-
mination from a variety of sources. Water quality of the Merrimack River and
its associated groundwater resources may deteriorate further due to the econo-
mic development and population boom the basin is experiencing presently which
is projected to continue into the future.
Contaminants found in drinking water are still being defined and, although 83
substances (Table DW-2) will be regulated within the next 3 years, there may
yet be many more identified and defined (Table DW-3 and DW-4) that are not
being sufficiently regulated to avoid potential health risks which may in
fact be health hazards. Toxic organics, in a very limited number of samples,
have been identified in trace amounts in the Merrimack. The low concentrations
of identified and to be regulated substances are of concern because of their
potential long term risks of cancer, mutagenicity and teratogenicity. Although,
the aggregate exposure and synergistic effects of such chemicals on those
subjected to a lifetime of water consumption are unclear, the scientific com-
munity is becoming increasingly concerned that prolonged exposure to these
contaminants in the environment (including food and air) is contributinq
significantly to these risks.
Increased economic activity and population growth may result in increased
contamination unless major efforts are placed on managing these potential con-
tamination sources. Groundwater resources must be protected and the surface
waters managed properly if communities and individuals looking for new drinking
sources are to obtain a high quality drinking water source.
Assessing Quality of Drinking Water Sources
Good engineering and public health practices emphasize the need for using raw
water of the highest possible quality when the source is to be used for drink-
ing water purposes. In addressing the source water in this manner, a greater
38
-------
factor of safety for the consuming public is established rather than if simply
marginal quality characteristics of that source are met. Despite the progress
made in the past decade in improving the quality of the Merrimack River water
according to Class B standards such as dissolved oxygen, temperature, pH and
fecal coliforms, there are still as yet many undefined and unmeasured para-
meters in the raw water that need to be identified and quantified. The fact
that a substance is not included in a list of criteria does not imply its
presence is innocuous. Potential concern is more than evident in the new list
of contaminants to be regulated for drinking water (Table DW-2). Although some
of these chemicals have been present in a number of drinking water supplies
throughout the United States for many years in minute quantities, only recently
have sufficiently sensitive detection and quantification equipment and methods
been developed for their isolation. Water quality of the river has gradually
improved and the readily observable contamination has vanished. Though the
water quality projections of expected continued improvement for the years
1990 through 2020 may be well founded for Class B water charateristics, the
increased population in the basin and subsequent activity along the river will
have inevitable effects on the attainment of public drinking water standards.
Potential exposure to carcinogenic, mutagenic and teratogenic risks posed by
different contaminants have not been fully explored. Exposure to these contam-
inants, particularly to organics, is cause for concern due to evidence impli-
cating them in these growth malfunctions. The specific causes of the diseases
are not currently understood but more and more evidence is accumulating that
singular exposure to each one of these chemicals via a lifetime of consumption,
including water, in the parts per billion may be a significant risk to human
health. Compounding the analysis of this threat is the synergistic interaction
among the chemicals which, even though less well understood than each discrete
chemical, is believed to be affecting the risk associated with the aforemen-
tioned diseases. Because of the threats posed by such contaminants (see Tables
DW-3 and DW-4), zero concentration in-stream is the only level known to be
safe. Maximum contaminant levels (MCLs) have been established for many of
these compounds and are continuously being reassessed, but they are merely
management risk concentrations based on the best available information. MCLs
will be modified appropriately as research clarifies the behavior of these
contaminants and treatment technology advances.
Unlike surface water systems, which are hydrologically well understood, the
intricacies of the groundwater system are more of a mystery. An understanding
of the groundwater environment and an assessment of the resource is a neces-
sary first step before it can be adequately protected and efficiently utilized.
Past and present efforts within the basin have focused on this need as a pre-
requisite for managing groundwater quality. Large scaled general information
has been compiled by the State of New Hampshire within the Merrimack basin.
High yielding areas - those areas which are underlain by very course sand and
gravel with ample quantities of water to meet or augment industrial and munici-
pal requirements - are scattered and are frequently located near the river due
to a hydraulic connection. Information is slightly more refined in the Mass-
achusetts portion of the basin due to hydrologic studies performed by U.S.
Geological Survey. Studies indicate that conditions are generally the same as
in New Hampshire.
39
-------
Present Situation
There are numerous ways in which unwelcome agents may enter surface water
supplies that are using the Merrimack River. One is via accidental spills. A
sudden contaminant invasion may not be detected promptly, thus overwhelming
the corrective measures either at the spill site or in the treatment scheme
of a water supply, resulting in public exposure to the contaminant. A trans-
port accident which could affect a water supply to some degree is possible due
to the intensively used local traffic arteries along with the Interstate High-
ways 495,3,93 and 89 which parallel and traverse the river and its watershed.
Also, there is the ever present possibility of industrial and/or municipal
waste treatment plant irregularities (including poor maintenance practices),
resulting in discharges not compatible with raw water drinking water sources.
Moreover, as the growth rate rises and the area becomes more commercialized and
industrialized with the consequence of more wastewater treatment facilities,
the chances of accidents of this nature will probably increase.
Simultaneously, greater urban runoff fron non-point sources flows into the
river or seeps into the groundwater carrying with it unspecified contaminants,
particularly organics that will degrade the quality of the raw drinking water
supplies. Another type of deleterious surface runoff from a nonpoint source is
the agricultural (farm & suburban) runoff that can carry with it many different
types of herbicides, pesticides, fungicides and fertilizers. Also the improper
and/or unauthorized disposal of various wastes in and around land disposal
sites and throughout the basin may have significant impact on the raw water
supplies. All of the above are inherent possibilities in a growing, populated
metropolitan area.
Issues specific to groundwater quality in the Merrimack basin are diverse.
Both Massachusetts and New Hampshire have identified the major sources of
contamination as municipal and industrial landfills, underground storage tanks,
hazardous waste sites and road salts. Inventories of many of these sites have
been made, but Federal and State regulatory programs are new and are are just
beginning to address not only present problems, but also problems due to past
activities which are surfacing frequently.
Although the application of the present coliform standard has adequately
protected the public heretofore, this surrogate indicator is an inadequate
measure by itself. Accordingly, the new regulations are attempting to address
this by incorporating other microbiological parameters that are listed in
Table DW-2. Even the inclusion of these parameters and setting a zero goal
does not guarantee the absence of disease-producing organisms, particularly
viruses. This is especially true for any source, treated and untreated, whose
microbial origins are human because the microbe is predisposed to use the human
host for its own survival. As with any microbiological or chemical sample, the
greatest deficency of evaluating the quality of the water is that the results
of the analysis are unknown until after the sampled water has already entered
the system and has been used to some degree. Such analyses and the correspond-
ing standards are adjuncts to and not substitutes for good quality raw water
and the appropriate treatment methods. It is, therefore, vital to the users of
40
-------
the raw drinking water source that the water be maintained as close to an
invariant high quality as is possible.
Addressing the Problems
The potential for contaminating the raw water source of the drinking water
supplies of the Merrimack River may be addressed using many approaches to the
problems associated with urbanization. A program to address this potential
would include but not necessarily be limited to analyzing degradation risk,
communities alerting one another to spills of any origin, installing deten-
tion basins in highly susceptible areas, interconnecting with surrounding
water supplies, training operators and organizations, monitoring the raw and
treated drinking water supplies, applying advanced water treatment techniques,
and conducting comprehensive sanitary surveys. This water supply approach is
independent of any Federal or State regulatory programs dealing with sources
of pollutants such as RCRA, Super-fund, etc.
The establishment of preventive measures dealing with the raw water supply is
a necessary component of the program. A risk analysis of river contamination
from an episodic event or short term or long term degradation in populated
areas should be done. An alarm network should be established so that, in the
event of spillage, communities can alert one another to the event and then
institute the appropriate action necessary to protect their consumers. Such a
system might include management coverage of one another's system when the sup-
ervisory personnel of that system are not present and/or are unavailable for
consultation by their staff. Also, impermeable detention basins situated at
critical transport sites or particularly hazardous industrial/commercial sites
would be of great aid in protecting the raw water supply. In the event of a
mishap or spillage, monitoring stations located at key points in the river
would offer the user communities another margin of safety. Sampling should be
frequent and varied with respect to time and river depth to representatively
describe the characteristics and concentrations of substances in the river.
Since organics are of particular concern regarding long term health effects, a
gas chromatograph/mass spectrophotometer is essential in assessing the Merri-
mack River water quality for water supplies. Another preventive measure would
be training members of the organizations which use the river. Such traininq
would include instruction of the consequences of spillage into the river, how
to address these situations, operation of treatment systems under these unusual
situations, and constraints such incidents would place upon the systems.
Mutual aid is another preventive measure that would establish water supply
interconnections with surrounding communities in the event a river supply
became unusable for a period of time.
The treatment of the Merrimack River water for potable water use will probably
require a multiple treatment scheme including a conventional full treatment
plant (disinfection, rapid mix, flocculation, sedimentation and filtration,
or other equivalent techniques), activated carbon to remove a broad spectrum
of organic contaminants, ozone and possibily other methods. As with any
treatment method, a long term pilot study is warranted in order to ascertain
the applicability of the method to the particular water in question. Most
communities on the Merrimack who presently use the river for their water
41
-------
supply do employ a full treatment scheme using granular activated carbon (GAC)
in the filter beds (refer to Table DW-1). These types of filter beds were
installed by most of the ccmmunities to remove taste and odor (primarily due to
organics), yet these beds remove some of the toxic organics now being called
into question regarding human health. For the GAC beds to be effective they
must be monitored frequently as to their ability to remove organics. Although
most ccmmunities analyze this ability every six months, there are no require-
ments to replace spent carbon unless consumers complain about the taste and
odor of the water. Furthermore, some of the substances that are adsorbed by
the carbon may be desorbed once the carbon is spent, thus releasing unwanted
contaminants into the water. The frequency of testing and a minimum acceptable
level of adsorption should be formalized. Another possible control measure is
the use of ozone, Ozone, depending on where it is placed in the treatment
process, is capable of reducing trihalomethane concentrations, reducing the
organic loading on the GAC filter beds, removing assimable organics through
biologically activated carbons, and destroying all microorganisms, including
viruses. There are other treatment methods and variations of those discussed
that should be given consideration depending on further investigations of the
applicability of these processes to remove contaminants from drinking water.
Some of these processes include natural open air impoundments which will hold
the water for a sufficent period of time previous to an appropriate treatment,
which may include coagulation-sedimentation and/or filtration impoundments,
powder activated carbon, a type of disinfectant other than chlorine or ozone
(there should be a minimum of a dual disinfectant scheme in the treatment
process), series filtration (through rapid sand filters first, then through GAC
filter beds), or blending with groundwater sources not dependent on the Merri-
mack for their recharge. Intrinsic to this whole process would be a sanitary
survey of each water supply system at a minimum of every three years. As
always, the main purpose of the survey would be to conduct an onsite review of
the water source, facilities, equipment, operation and maintenance of a public
water system in order to evaluate the adequacy of the site to produce and
distribute safe drinking water. The survey would allow the involved regulatory
agencies and the suppliers to review all of the aforementioned facets of the
program, address any deficencies the program may have, and/or implement new
strategies to aid the water supplies.
The true issue surrounding protection of groundwater is the development of a
protection strategy based on a good understanding of the local groundwater
conditions. A good understanding of the resource requires extensive field
work, hydrologic and geologic studies, mapping and modelling. The federal
government, through U.S. Geological Survey, provides a contract service in
mapping of groundwater resources. This mapping has been done for the Massa-
chusetts section of the Merrimack and is currently being done in New Hampshire.
Mapping groundwater resources is strongly encouraged. Modelling of highly
utilized aquifers would be another important activity to predict impacts of
present and future uses. The Wellhead Protection program within the newly
amended Safe Drinking Water Act is another means by which the federal govern-
ment can help the states develop groundwater strategies. Massachusetts has
developed a state strategy with a three-tiered aquifer classification system
and a policy of groundwater protection to levels necessary for projected future
use. New Hampshire has a policy of no degradation, rather than a system of
42
-------
classification. States are developing and implementing strategies through the
administration of federal grant money to the States. Continued effort is
being placed on locating potential contaminant sources (key industries, waste
sites, etc.). NH has mapped NFS of pollution on a town-by-town basis along
with treatment plants, water quality classifications, and locations«of aqui-
fers. Simultaneous federal, state, and local programs which regulate these
activities must be strictly enforced, especially in groundwater aquifer re-
charge areas.
Summary
The contaminant risks and the methods employed to ameliorate these risks pre-
sent a series of complexities and challenges to communities attempting to
produce a potable water supply from the Merrimack River and associated ground-
water. There will have to be a substantial amount of understanding and dis-
cretion by those users in meeting not only the MCL's of the newly regulated
contaminants, but to reduce the contaminants further in order to minimize the
potential carcinogenic, mutagenic, and teratogenic risk posed by them, thus
assuring the public of a safe high quality potable water.
43
-------
TABLE DW-1
PRESENT AND FUTURE PUBLIC WATER SUPPLY USERS
COMMUNITY
TYPE
POPULATION*
WATER RIGHTS
(MGD)
MAXIMUM
USAGE
(MGD)
AVERAGE
USAGE
(MGD)
TREATMENT
MASSACHUSETTS
Haverhill **
(Future)
North Andover
(Future)
Lawrence
Methuen
Andover
Dracut
Tewksbury
(under
construction)
Lowell
MWRA/MDC
(Future)
surface***
surface
surface
surface
surface***
well (5)
surface
surface
surface***
52,000
21,500
64,000
38,000
30,000
25,000
27,000
96,000
2,500,000
25 ****
12
unlimited
10
unlimited
unknown
6
unknown
unknown
11
5.5
14
6.9
9.9
4.7
3
18
235*****
6.8
2.7
9
4.2
5.4
1.2
2
14
120 *****
averaged
per/year
full treatment
activated carbon
full treatment
activated carbon
full treatment
activated carbon
full treatment
activated carbon
full treatment
activated carbon
fluoridation
full treatment
activated carbon
full treatment
activated carbon
full treatment
activated carbon
NEW HAMPSHIRE
Nashua
Merrunack
Manchester
Future)
TOTALS
surface
wells(2)
surface
80,000
13,000
110,000
3,056,500
unknown
— — »
20 ****
21
__«
22
351
11.2
1
14
192.5
full treatment
no treatment
full treatment
activated carbon
*
**
***
****
Present population (as of 1980 census)
Tidal influence ends here; upstream of mile 21.9 it is a Class B water; down stream
it is an SB classification
Has or will have surface water impoundment with significant detention time before
treatment scheme
Estimated
***** Daily usage for 6 months out of the year 2013
[Note: Also considering eventual use of the river as a drinking water supply source are Dracut,
the seacoast of New Hampshire, and Southern NH Water Co. in Hudson.]
44
-------
Turbidity*
Total Coliforms*
Giardia lamblia
TABLE DW-2
POTENTIAL DRINKING WATER CONTAMINANTS
MICROBIOLOGICAL CONTAMINANTS
Viruses
Standard Plate Count
Filtration of Surface Water
Disinfection of All Water
Arsenic*
Barium*
Cadmium*
Chromium*
Lead*
Mercury*
Nitrate (as N)*
Selenium*
INORGANIC CONTAMINANTS
Silver*
Fluoride*
Aluminum
Antimony
Molybdenum
Asbestos
Sulfate
Copper
Vanadium
Sodium
Nickel
Zinc
Thallium
Beryllium
Cyanide
Trichloroethylene
Tetrachloroethylene
Carbon Tetrachloride
1,1/1 - Trichloroethane
1,2 - Dichloroethane
VOLATILE ORGANIC CONTAMINANTS
Vinyl Chloride
Methylene Chloride
Benzene
Chlorobenzene
Dichlorobenzene(s)
Trichlorobenzene(s)
1,1 - Dichloroethylene
cis - 1, 2 - Dichloroethylene
trans - 1, 2 - Dichloroethylene
Endrin*
Lindane*
Methoxychlor*
Toxaphene*
2, 4 - D*
2, 4, 5 - TP (Silvex)*
Total Trihalomethanes*
Aldicarb
Chlordane
Dalapon
Diquat
Endothall
Glyphosate
SYNTHETIC ORGANIC CONTAMINANTS
Carbonfuran
1, 1, 2 - Trichlorethane
Vydate
Simazine
PAHs (Polynuclear Aromatic
Hydrocarbons)
PCBs (Polychlorinated
Biphenyls)
Atrazine
Phthalates
Acrylamide
DBCP (Dibrotiochloropropane)
1, 2 - Dichloropropane
Pentachlorophenol
Picloram
Dinoseb
Alachlor
EDB (Ethylene Dibromide)
Epichlorohydrin
Dibromomethane
Toluene
Xylene
Adipates
Hexachlorocyclopentadiene
2, 3, 7, 8 - TCDD (Dioxin)
Radium 226 and 228 *
Gross Alpha Particle
Activity *
RADIONUCLIDE CONTAMINANTS
Beta particle and Photon
Radioactivity*
Uranium
Radon
* currently regulated
45
-------
TABLE DW-3
Chloroform*
Bromod ichloromethane*
Chlorodibronomethane*
Bromoform*
trans-1,2-Dichloroethy lene
Chlorobenzene
m-D ichlorobe nzene
D i chloromethane
cis-1,2-Dichloroethy lene
o-Dichlorobenzene
1,2,4-Trichlorobenzene
Fluorotrichloromethane
D ichlorod i fluoronethane
Dibromomethane
1,2-Dibrcmoethane (EDB)
1,2-Dibromo 3-chloropro-
pane (DBCP)
Toluene
ORGANICS TO BE MONITORED
p-Xylene
o-Xylene
m-Xylene
1,1-Dichloroethane
1,1,2,2-Tetrachloroethane
Ethylbenzene
1,3-Dichloropropane
Styrene
Chloronethane
Bromomethane
Brcmochlorcmethane
1,2,3-Trichloropropane
1,2,3-Trichlorobenzene
n-Propylbenzene
1,1,1,2-Tetrachloroethane
Chloroethane
1,1,2-Trichloroethane
Pentachloroethane
bis-2-Chloroisopropyl ether
2,2-Dichloropropane
1,2,4-TrimethyIbenzene
n-Butylbenzene
Napthalene
Hexachlorobutadiene
o-Chlorotoluene
p-Chlorotoluene
1,3,5-TrimethyIbenzene
p-Isopropyltoluene
1,1-Dichloropropene
iso-PropyIbenzene
tert-ButyIbenzene
sec-Butylbenzene
Bronobenzene
* currently regulated
PROPOSED MCL's FOR VOLATILE ORGANIC CONTAMINANTS
VOC
Benzene
Vinyl Chloride
Carbon Tetrachloride
1,2-Dichloroethane
MCLG**
(mcgm/L)
0
0
de 0
! 0
Proposed MCL
(mcgm/L)
5
1
5
5
VOC MCLG**
(mcgnv/L)
Trichloroethylene 0
1 , 1-Dichloroethy lene 7
1,1, 1-Trichloroethane 200
p-Dichlorobenzene 750
Proposed MCL
(mcgm/L)
5
7
200
750
sec
TABLE DW-4
SYNTHETIC ORGANIC CONTAMINANTS
Acrylamide
Alachlor
Aldicarb, aldicarb suIfoxide
and aldicarb sulfone 9
Carbonfuran 36
Chlordane 0
cis-1,2-Dichloroethylene 70
DBCP 0
1,2-D ichloropropane 6
o-Dichlorobenzene 620
2,4-D 70
EDB 0
Epichlorohydrin 0
Proposed MCLG**
(mcgnv/L)
0
0
SOC
Ethylbenzene
Heptachlor
Heptachlor epoxide
Lindane
Methoxychlor
Monochlorobenzene
Pentachlorophenol
Styrene
Toluene
2,4,5-TP
Toxaphene
trans-1,2-Dichloroethy lene
Xylene
Proposed MCLG**
(mcgm/L)
680
0
0
0.2
340
60
220
140
2000
52
0
70
440
**Maximum Contaminant Level Goal
46
-------
SUPERFUND AND RCRA
The Resource Conservation and Recovery Act (RCRA) program addresses Hazardous
Waste Management of current (post-1980) and new treatment, storage and disposal
facilities. The Comprehensive Environmental Response, Compensation and Liabil-
ity Act (CERCLA), also known as Super-fund, program deals with improper waste
disposal practices at non-RCRA facilities and uncontrolled sites. These
programs are aplicable at the sites discussed below and on Table SR-1.
RCRA Program
The RCRA program is designed to ensure proper management of hazardous waste by
creating a "cradle to grave" management system. The RCRA permitting program
requires all treatment, storage and disposal facilities (TSD's) to obtain an
operating permit. The TSD regulations establish performance standards that
owners and operators must apply to minimize the release of hazardous waste
into the environment. The permit requirements for land disposal facilities
incorporate groundwater provisions, including clean-up of any groundwater
contamination. The 1984 Amendments, called the Hazardous and Solid Waste
Amendments (HSWA) to RCRA, added components that are important to minimize
releases to the environment. The amendments added important areas relating to
releases at TSDs: the corrective action provision allows for issuance of orders
or conditions as part of ^jemits when there has been a release of hazardous
waste or constituents into the environment. Corrective action can be required
regardless of when waste was placed in the facility and may extend beyond the
facility boundary. The Agency has placed a high priority on permitting acti-
vities, particularly at land disposal facilities.
Table SR-1 is a list of RCRA TSDs in towns on the Merrirnack River. At present,
no corrective action is underway at any of these facilities. The facilities
will be prioritized based on type of activities and Agency and State resources.
In New Hampshire, W.R. Grace and Coating Systems, Inc. in Nashua are on the
banks of the Merrimack or in close proximity. Due to the newness of the cor-
rective provision and prioritization system for disposal sites, no information
is available on the potential discharge or impact of these facilities on the
Merrimack River.
Superfund Program
The Superfund Program is responsible for removal and remedial activities at
CERCLA sites. The current regulations require CERCLA actions to comply with
applicable and relevant environmental laws. This includes RCRA and the Clean
Water Act. CERCLA actions which impact groundwater must meet the RCRA re-
quirements that any discharges must be at background, Maximum Contaminant
Levels (MCLs), or Alternate Concentration Levels (ACLs). Surface water dis-
charges must meet the water quality standards and technical requirements of
the National Pollutant Discharge Elimination System. The Agency prioritizes
sites by a Hazardous Ranking System (HRS) which results in listing on the
National Priorities List (NPL). Once sites are placed on the NPL, remedial
investigations/feasibility studies (RI/FS) are performed to determine the
nature and extent of contamination and potential remediation. During the RI,
migration of contaminants is examined in detail.
47
-------
The following is a short status of the 7 Superfund sites that could have a
potential impact on the Merrimack River:
Groveland Wells 1 & 2, Groveland, MA - Further study is underway to supplement
the Remedial Investigation/Feasibility Study. The Groveland Well Site is
located along the Merrimack River. The wells were the main source of drinking
water for the Town of Groveland prior to their closure in 1979 due to tri-
chloroethene contamination. No sampling of the Merrimack has been done as
part of the study. Studies have indicated that the groundwater plume dis-
charges to tributaries of the Merrimack. Trace levels of volatiles have been
found in the tributaries but the absence of stream-bed sediment contamination
suggests that the contaminants volatilize and, therefore, do not impact the
Merrimack.
Haverhill Landfill, Haverhill, MA - Initially the landfill was part of the
Groveland Source area study. The Haverhill landfill has been added to the NPL
and will be studied in the near future for its impacts on the Groveland Wells
and Merrimack River. The RI will be underway in the near future.
Silresim Chemical Corporation, Lowell, MA - An RI/FS is underway. The site is
several miles from the Merrimack River but is hydraulically connected by River
Meadow Brook and the Concord River. Existing surface water quality data in
River Meadow Brook indicates minor contamination.
Charles George Land Reclamation, Tyngsborough, MA - This site is a 59-acre
mixed municipal/industrial landfill which is undergoing closure by capping.
Further study is underway to determine if offsite groundwater remediation is
necessary. Surface drainage and some over-burden groundwater flow is to
Flint Pond. Flint Pond drains to the Merrimack River via Bridge Meadow Brook.
The site is approximately one.mile from the river. Chemical contamination
detected in surface water samples in Flint Pond is at low levels (less than
100 ug/1) of organic contaminants. Some phthalate esters and a few polynuclear
aromatic hydrocarbons (PAHs) in sediment samples have been detected. Inorganic
substances were virtually undetected in surface water samples from Flint Pond.
However, some inorganic contamination in sediment samples was found. Due to
the lack of correlation between levels and distance from the site, contamina-
tion is thought to be due to a contaminated groundwater discharge farther from
the site or another contaminant source. Seme biota samples (fish and turtles)
were obtained from Flint Pond. This data revealed no significant site related
impact on aquatic organisms in Flint Pond.
Auburn Road Landfill, Londonderry, NH - Further study is underway. Onsite
contamination discharges to Cohas Brook which discharges to a wetland in the
Merrimack drainage basin. No contamination exists in the wetlands.
Tinkham Garage, Londonderry, NH - The study is complete. The remedy is to be
implemented. An unnamed tributary flows through the site and discharges to
Beaver Brook which eventually discharges to the Merrimack River. Surface
contamination offsite has not been found.
48
-------
Sylvester's, Nashua, NH - Remediation is underway. Slurry wall, cap, and
groundwater extraction and treatment system are being implemented. Clean-up
levels were set according to RCRA Alternate Concentration Levels (ACLs) - site
specific values that were determined to be protective of public health and the
environment. The clean-up levels were based on current and potential usage of
the groundwater and its discharge points. Potential of contaminated discharge
to tributaries and the Merrimack River has been mitigated.
Another site in the basin - one not expected to impact the river - is Ottati
and Goss/Great Lakes Container Corp., Kingston, NH. Drainage from the site is
into Great Pond which has an outlet to the Powwow River. There is no known
contamination in the Pond or the Powwow from the site, indicating that the site
is not threatening the Merrimack.
49
-------
TABLE SR-1
RCRA FACILITIES ALONG THE MERRIMACK RIVER
FACILITY NAME
TOWN
Auto Circuit Inc.
Chesterton, A. W. Co.
Circle Finishing Inc.
Geochem Inc.
Microfab Inc.
Mobil Chem. Co.
Plastics
North East Solvents
Reclamation Co.
Reichhold Chem. Inc.
Valley Manufactured
Products Co., Inc.
Vernon Plastics Co.
Wang Laboratories Inc.
Coating Systems Inc.
Grace, W. R. and Co.
Jones Chemicals Inc.
Kollsman Instrument Co.
Koppers Co., Inc.
N. H. Plating Co., Inc.
Oak Materials Group
Laminates Division
Column Desription Key
Activity Type:
GEN = generator
TRA = transporter
TSD = treatroent/storage/disposal
D = land disposal
I = incinerator
S = storage
UIC = underground injection control
ACTIVITY TYPE
GEN TRA TSD UIC
PERM
Lowell
Grove land
Newburyport
Lowell
Amesbury
Lowell
Lawrence
Andover
Groveland
Haverhill
Tewksbury
Nashua
Nashua
Merrimack
Nashua
Nashua
Merrimack
Franklin
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
S
S X
D
X S
S
S
X S X
S
S
S
S
X S
X
D
S
S
D
S
4
4
4
1
4
4
1
4
4
4
4
1
2
4
4
4
PERM STAT = permit status
Blank = no status/other
1 = interim status/permit candidate
2 = RCRA permit issued
3 = permit by rule
4 = Part A withdrawal candidate
50
-------
REFERENCES
1. Bourbiget, M. and Sibonv, J., "Providing Water for the He de France,"
Journal of American Water Works/ July 1986, (p. 62).
2. Delaney, D. and Gay, F., Hydrologic and Water Resources of the Lower Merri-
mack River Basin in Massachusetts from Concord River, Lowell to Plum Is-
land, Newburyport, U.S. Geological Survey. 1980.
3. Foss, G., Water Supply Study and Environmental Impact Report - 2020, Phase
II, Task 8; Merrimack River Alternative, Metropolitan District Conmission,
May 1985.
4. Grants Information and Control System data listing.
5. Inventory of Groundwater and Surface Water Potential Nonpoint Pollution
Sources, Draft Interim Report, #86CC, New Hampshire Water Supply and Pollu-
tion Control Commission, May 1981.
6. Manual of Instruction for Water Treatment Plant Operators, New York
Department of Health.
7. Massachusetts Federal Construction Grants Project priority list.
8. Massachusetts Summary of Water Quality, Massachusetts Division of Water
Pollution Control, April 1986.
9. Massachusetts Water Quality Standards, 1984, Massachusetts Division of
Water Pollution Control, December 1983.
10. Merrimack River Basin Plan, #56, New Hampshire Water Supply and Pollution
Control Commission, February 1972.
11. The Merrimack River Water Quality Management Plan, #8403-125-25-9-75-CR,
Massachusetts Division of Water Pollution Control, February 1975.
12. Merrimack River Water Quality Management Plan, #90, New Hampshire Water
Supply and Pollution Control Commission, October 1978.
13. The Merrimack River, 1981, Water Quality Survey Data, Wastewater Discharge
Data, Massachusetts Division of Water Pollution Control, 1982.
14. New Hampshire Federal Construction Grants Project priority list.
15. New Hampshire Standards for Classification of Surface Waters of the State,
New Hampshire Water Supply and Pollution Control Commission.
16. New Hampshire Water Quality Report to Congress, New Hampshire Water Supply
and Pollution Control Commission, April 1986.
17. Pojasek, R., Drinking Water Quality Enhancement Through Source Protection,
1977. ~~
51
-------
18. "Recommended Standards for Water Works," Ten States Standard, 1982.
19. A Report on Water Quality Conditions and Pollution Abatement in the
Merrimack River Basin in Massachusetts, Massachusetts Division of Water
Pollution Control, April 1985.
20. Safe Drinking Water Act, as amended 1986.
21. Summary Merrimack River Basin Water Quality Management Plan, #90A, New
Hampshire Water Supply and Pollution Control Commission, February 1978.
22. van der Veen, Cornelius, "The Amsterdam Water Supply," Journal of American
Water Works Association, June 1985 (p. 32).
23. Wallace, Floyd, Associates, Inc., et al., MWRA Water Supply and Environmental
Impact Report - 2020, March 1986 (p. 72).
24. Water Quality Criteria, Federal Water Pollution Control Administration,
April 1986.
25. Water Quality Management Plan Nashua River Basin, Camp, Dresser and McKee,
Boston, MA, December 1975.
26. Weterhoff, G. and Miller, R. Design of the GAC Treatment Facility at
Cincinnati, April 1986 (p. 147).
52
-------
Appendix A
CONSTRUCTION GRANTS FUNDING IN REMAINING MERRIMACK SUB-BASINS
SINCE INCEPTION OF PL 92-500 (OCTOBER, 1972)
Funding to Date Proposed Costs
Assabet River, MA
Westborough 23,348,676
Shrewsbury 581,855 350,000*
Marlborough 1,382,382 5,225,000*
Hudson 10,255,592
Maynard 4,369,856
Concord River, MA
Concord 10,210,505
Billerica 5,674,152 6,682,000 *
Pemigewasset River, NH
Lincoln 144,001 2,340,000 **
Plymouth Village Water & S.D. 2,263,672 3,000,000 **
Ashland —
Winnepesaukee, NH
Bay Sewage District
Mad River, NH
Waterville Valley —
KEY TO TABLE;
* Estimated Federal Grant Amount
** Estimated Project Cost
= Municipality has facilities that were not funded under PL 92-500
A-l
-------
Appendix B
NPDES PERMITTED DISCHARGERS IN THE MERRIMACK BASIN
MUNICIPAL TREATMENT PLANTS
New Hampshire
Massachusetts
Merrimack River
Newburyport WPCF *
Salisbury Sewer Commission
Atnesbury *
Merrimac
Haverhill WTP *
Greater Lawrence SD *
Lawrence
Methuen
Dracut
Tewksbury DPW
Lowell MSS *
Pentucket Regional School District
Powwow River
Amesbury WTP
Spicket River
Salem STP *
Nashua River
West Fitchburg WTF *
Fitchburg WTP *
Leoninster DPW *
MDC-Clinton *
Clinton (T) Bypass
Ayer WTF *
Pepperell
Gushing Academy
Nashua STP *
Merrimack WTP *
Merrimack County Home
Derry *
Manchester *
Hooksett *
NHWS&PCC - WRBtl *
Bow
Concord South *
Concord Penacook *
New Hampshire Industrial School
Souhegan River
Greenville MTP
Milford *
Whitman-Hanson Regional High School
Piscataquog River
Hillsborough County Home
New Hampton Village Precinct
Goffstown STP *
Suncook River
Pittsfield
Allenstown Sewer Coimission *
Contoocook River
Jaffrey STP *
Peterborough WPCF(T) **
Antrim MTP
Hillsborough MTP
Henniker MTP *
Kearsarge Regional High School WTP
Warner Village FD
Hopkinton
Notes;
(1) * indicates major facility
(2) The major facilities on this page were all addressed in the report. Minor
facilities are not addressed in the report. Facilities on the following
page are in sub-basins not addressed in the report.
B-l
-------
MUNICIPAL TREATMENT PLANTS (cont.)
Massachusetts New Hampshire
Shawsheen River Basin Winnepesaukee River Basin
Tewksbury Hospital WWTP Bay Sewage District
Epping MTP Gunstock Area
Bedford Municipal Well #7
Concord River Basin Pemigewasset River Basin
Billerica-Letchworth Ave WTP * Woodstock WTP
Concord MTP * Woodstock South WTP
MCI Concord Lincoln *
Billerica Jail and House of Correction Bristol WTP
Middlesex School Ashland MTP
Sudbury River Basin Mad River Basin
Marlboro STP (East) * Waterville Valley *
Assabet River Basin
Westhorough WTP *
Shrewsbury WPCF *
Marlboro WPCF (West) *
Maynard STP *
Hudson *
Other Tributaries
Groveland (Brindie Brook)
* indicates major facility
B-2
-------
INDUSTRIAL TREATMENT!1 PLANTS
Massachusetts
Merrimack River
Gould Inc. *
AT&T Technologies *
William Tonner Co.
Boott Mills
Merrimac Paper Co., Inc.
General Electric - Lowell Plant
Wannalancit Textile
Exxon Corp.
Bixby Int'l Corp.- Newburyport
Plastic Conpounders of Mass.
Bixby Int'l Corp.- Haverhill
Valley Manufactured Products Co.
Pheasant Lane Mall
Conpo Industries Inc.
Stony Brook
Fletcher Granite Co., Inc.
The Mill
Westford Anodizing *
Beaver Brook
Care Cleaners
Spicket River
Diversitech General Inc.
Proctor & Gamble Mfg. Co.
Nashua River
Tucker Casco
Doreen Brush Co.
Jmaes River - MA Inc.
Tucker Housewares
Siironds Cutting Tools
General Electric Co. - Fitchburg
St. Benedict Center
Shell Oil Co. *
Colorcraft Corp. *
Polysar Inc. *
Suprenant Wire & Cable *
Hollingfworth & Vose Co. *
James River - Pepperell, Inc. *
Advance Coatings Co. *
Tennessee Gas Pipeline
River Terrace Healthcare
Notes:
New Hampshire
Merrimack River
W. R. Grace *
Public Service Co. of NH *
Anheuser-Bush, Inc.
Chemical Fabrics Corp.
P. S. Co. of NH-Amoskeag Hydro.
P. S. Co. of NH-Hooksett Hydro.
Webster Value /Watts Regulator
Bow Plaza
Franconia Power and Light
P. S. Co. of NH-Garvins
P. S. Co. of NH-Manchester
M. M. Mades Co., Inc.
F. M. Callahan & Son, Inc.
Interlake, Inc., Arwood Corp.
Ohmite Mfg. Co.
Advanced Interconnections Corp.
Pheasant Lane Mall
Rolling Green
GTE Products Corp.
Beaver Brook
Hadco Printed Circuits, Inc.
Spicket River
Diamond Dairy Farms, Inc.
Nashua River
Nashua, NH Foundation
Mohawk Association
Irwin Toys
Sprague Electric Co.
Teradyne Connection Systems Inc.
Souhegan River
Hitchiner Mfg. Co., Inc. *
Hendrix Wire and Cable *
Abbott Machine Co.
Label Art Inc.
0. K. Tool Co., Inc.
Pilgrim Foods, Inc.
Fletcher Granite Co., Inc.
(1) * indicates major facility
(2) Rivers on this and the following page were addressed in the report.
B-3
-------
INDUSTRIAL TREATMENT PLANTS (cont.)
Massachusetts New Hampshire
Black Rock Creek Oontoocook River
Salisbury GTE Products Corp. - Sylvania *
Monadnock Paper Mills, Inc. *
Hoague-Sprague Corp. *
Contoocook Valley Paper Co.
Hillsboro Laundry and Cleaners
P. S. Co. of NH-Jackman Hydro
Bio-Energy Corp.
Suncook River
Cambridge Thermionics
Tim Co. Inc.
Piscataquog River
Connare Mfg. Co.
Little River
Process Engineering Inc.
Notes;
(1) * indicates major facility
(2) Above rivers were addressed in the report. Following facilities, including
those on the next page, are in sub-basins not addressed in the report.
Massachusetts
Concord River
Raytheon Corporation *
North Billerica Co.
Wood Fabricators Inc.
Nye's Japenamelac Inc. *
Silicon Transistor Corp. *
Sudbury River
Raytheon Co. - Wayland Lab *
Timex Clock Co.
Superior Printing Ink Co.
Rosenfield Concrete
Chiswick Trading Warehouse
Point West Place
1800 West Park Drive
Sperry Research Center
B-4
-------
INDUSTRIAL TREATMENT PLANTS (cont.)
Massachusetts
Assabet River
Digital Equipment Co.
W. R. Grace and Co.
State Properties of N. E.
River Road Industrial Park
Mass. Microelectronics
Shrewsbury Residue Landfill
Shawsheen River
Liquid Carbonic Corp.
Reichhold Chemicals, N. E. Div.
Shawsheen Rubber Co.
Tyer industries Inc.
303 Ballardvale Street
Other Tributaries
Microfab, Inc. *
Vernon Plastics *
Coastal Metal Finishing *
General Latex and Chemical Corp. *
Cambridge Bioscience Corp.
Baystate Abrasives
Fenwal Inc.
Dennison Manufacturing Co.
General Motors Corp.
Union Carbide Corp.
J. Melone & Sons, Inc.
Raytheon Co.
Quinn-Perkins Sand and Gravel, I
Millipore
Mitre Corporation
Highwood Office and Research Park
3 M Company Plant
Witt Equipment Co.
Aerodyne Research, Inc.
Astra Pharmaceutical Products, Inc.
Bourbeau Estates
Kenics Corporation
Tilton & Cook Co.
Valley Design Corporation
E. B. Kingman Co.
Kelly Co.
Stickney and Poor Spice Co.
Wiltec, Inc.
Tech Center Treatment Plant
* indicates major facility
New Hampshire
Winnepesaukee River
Surrette Storage Battery Co. *
Interlake, Inc. *
J. P. Stevens and Co., Inc.
Pemigewasset River
P. S. Co. of NH-Ayers Island Hydro
P. S. Co. of NH-Eastman Falls Hydro
Tru Tech Inc.
Polyclad Laminates, Inc.
Other Tributaries
General Electric - Hooksett Plant *
Atlantic Laminates - Dodge Ind.
J. C. Pitman & Sons
International Packing C p.
Concord Steam Corp.
Ingersoll-Rand Impco. Div.
Regency Park
ART Associates
Saunders Brothers
NH Ball Bearing Co.
Jordan Marsh
Plasma Materials Inc.
J. J. Cronin Co.
Sunset Ridge
300 North Ridge Road
Massachusetts
Other Tributaries
First Bank
Mi-lor Corporation
Boston & Maine, Fitchburg
P. J. Keating Co.
New England Apple Products
Holden Trap Rock Co.
ECC Corporation
Industrial School for Girls
Amidon Brothers Cider Co.
Alden Research Laboratory
Sears town Mall
Chelmsfotd Laundromat
Allen Drive Subdivision
B-5
-------
Appendix C
MASSACHUSETTS CONSTRUCTION GRANTS
PRIORITY SYSTEM
COMMONWEALTH OF MASSACHUSETTS DI-
VISION OF WATER POLLUTION CONTROL
CRITERIA FOR ESTABLISHING PRIORITIES
FOR GRANTS UNDER FEDERAL WATER POL-
LUTION CONTROL ACT AND THE MASSACHU
SETTS CLEAN WATERS ACT FISCAL YEAR
1917.
1. Eligible Projects
Projects which have been submitted to the
Division ol Water Pollution Control and meel me
requirements ol me Division and the rules and
regulations adopted by the Environmental Pro-
tection Agency snail be known as eligible pro-
jects.
Pursuant to the provisions ol P.L. 97-117.
Sec. 2 (a) ol me •'Municipal Wastewater Treat-
ment Construction Grant Amendments ol I98r
on and after October I. 1984. eligible categories
al projects will include wastewater treatment fa-
cililws. interceptors and appurtenances, and in.
liltration/inllow correction. Previously eligible
categories lor wastewaier collection sewers and
major sewer system rehabilitation are no longer
eligible after that date. However, projects pro-
viding correction ol combined sewer overflows
may be considered lor funding consistent with
the provisions ol said section.
The tundabie portion ol me priority list Iden-
tifies by project the estimated EPA grant assist-
ance based upon a Federal share ol 35 S. At the
time ol actual grant award, this amount will be
adjusted to lake into account the EPA require-
ment concerning reserve capacity in excess ol
existing needs. Applicants on me tundabie per-
lion ol the lilt when nave a (1) or (2) following
their name, are considered on a preliminary ba-
sis lor phase/segment designation or as a can-
didate, respectively, and as such may be exempt
from me EPA reserve capacity requirement.
At me time ot submntal ol an application for
funding of an eligible project tor whicn priority
has been estabtisned. me applicant must show
that funds have been appropriated to pay the
remaining costs ol me project over and above
tne grant amount.
2. C«rtllle»lk>n for Priority
To be considered lor funding priority, com-
pleted applications must be submitted to me Di-
vision at me earliest possible time, but not later
man June '.. 1987. A complete application must
•contain me local lunding authorization and com-
plete Imal plans and specifications. Any prelect
not submitted by June 1. 1917. •rill be auto-
matically considered lor bypassing and may
b* placed on the extended Mat.
Projects will be certified annually lor grants
in the maximum amount eligible as requested in
me application to me extent me funds are made
available to the Slate.
Priorities will be given to eligible projects
based on me criteria wnich are explained below.
Projects can be funded only il they are listed on
me tundabie portion ot the Project Priority List
or as otherwise provided herein.
All projects submitted lor funding are re-
viewed to assure coniormance with water Qual-
ity Management plans.
3. Criteria System lor Ranking Construction
Grants Protects
General
in evaluating different types ol projects, first
consideration will be given to protects mat will
provide a minimum ot secondary treatment or
are needed to meel water quality standards.
Projects ol this type are wastewaier treatment
systems, outlall sewers, major intercepting sew-
ers, major pumping stations ana force mains.
Projects mat correct miittration/inliow problems
wnere me projects are needed to maintain the
integrity ol an existing or proposed wastewater
treatment system project are generally to be
funded separately under Chapter 472. the
Slate's Si00 million bond issue. :
Projects tor me separation ol combined
sewers and treatment ot combined sewer over-
flows are considered next highest priority. This
will be rellected in me priority points assigned to
me project and will determine its relative rank-
ing on the Project Priority List.
Pro)«ct Priority List
A project priority list is an enumeration and
ranking ol potential municipal construction proj-
ects m me State. The priority list consists ol a
tundabie list which snows the projects wnicn can
be lunoed under the available funds during
FY87. Irom October 1. 1986 to September 30.
1987. and an extended list which shows projects
planned lor funding for FV&e. FY69. FY90 and
FY91.
The project list is derived from unfunded
projects from the previous FY86 construction
grants project list, from new applicants express-
ing an Interest to be included lor funding and
from project information available to the Divi-
sion.
The projects are then ranked by assionlno
points on the oasis ol the criteria shown on Ta-
ble A.
It should be noted under the section head-
Ing A. Type el Prelect that although several
point values may apply to a specific project, only
the highest value which pertains is applied. How-
ever, under the section heading B. Effect en
Uae* more than one numerical value can apply
since it Is possible mat a project may have bene-
ficial effects on more than one use for a particu-
lar waterway. The highest possible point value
that can be obtained is 235. Furthermore when
a request is evaluated wnicn contains several
projects, these may be ranked separately. Final-
ly, wiien a puOlic entity has accepted and com-
plied wim tne provisions of Chapter 275 of me
Acts of 1985 for water conservation, -a prefer-
ence may be granted to that applicant in tne
lorm of a lie-breaking capability.- should the
need arise. To receive this preference, formal
written documentation must be submitted in
writing to mis Division.
The tundabie and extended portions ol the
project priority list for FY87 will contain only
Step 3 construction projects, with no rombined
Stto 2 ana Step 3 projects for design and con-
struction. Tnis allows projects wnicn are ready
to receive Step 3 grant assistance to commence
actual construction, thereby correcting existing
water pollution and public heaim problems at
me earliest possible lime. Furthermore me
State Planning Grant Program under Chapter
786 allows me Division to provide financial as-
sistance lor tne planning as well as tor me de-
sign ol eligible projects.
The Clean Water Act ol 1977 together with
me Municipal Wastewater Treatment Construe-
lion Grant Amendments ol 1981 require certain
changes to me Priority System Including: a Proj-
ect Bypass Procedure, provision for Additional
Allotments, reserve lor Alternative and Innova-
tive Technologies, reserve tor alternative sys-
tems for small communities, exclusion or Step 1
and Step 2 projects, reserve lor Water Quality
Management Planning, reserve lor Step 1 and
Step 2 advances tor small communities. These
cnanges are described as follows.
Prelect Bypass Procedure
A project on the fundable portion ot me
Project Priority List may be bypassed it the Divi-
sion ot Water Pollution Control Determines mat
me bypassed project will not be ready 10 pro-
ceed during the funding year. Projects mat are
bypassed shall retain their priority point rating
tor consideration in the future year allotments
Projects bypassed will be replaced by me high-
est ranked priority projects on me extended
portion mat are ready to proceed during the
funding year. As previously staled, complete
project applications not received by the Division
by June 1. 1987. will be automatcaltv consid-
ered lw bypassing and may be p:_ed on me
extended list.
Additional Allotments
The Division ol Water Pollution Control
upon receipt ol additional Federal allotments, il
any. may move projects on the extended portion
ot me priority list onto the fundable portion. The
projects moved into me tundabie range will be
the hignest priority projects on the extended
portion ready to proceed.
Alternative and Innovative Technoioglae
The Clean Water Act ot 1977 and tne 1981
Amendments require grant recipients after Sep-
tember 30. 1978 to analyze anernative and inno-
• vative treatment processes and techniques lor
use m wasiewater treatment. The Act provides
lor a 20% bonus gram (up to 55 percent total
grant amount) lor allowable construction costs
lor treatment works met use alternative and in-
novative treatment processes and techniques
The Division of Waler Pollution Control is re-
Quired to use 4 percent ol the FY87 allotment to
fund the incremental cost ol increasing me l-'ed-
eral grant from 35 percent to SS percent lor al-
ternative and innovative processes or tech-
niques identified lor lunding by me DWPC A
line item has been indicated to set avd« the
funds tor projects using alternative and innova-
tive processes.
II n the event requests lor lunding under
alternative and innovative tecnno*og«s exceed
-------
funoii available in me 4 percent MI aside. lh*l
OWPC will UM in* following criteria to select me1
protects to be funded: I
1. Tru potential lor Beneficial UM of the'
process or technology throughout the
Slate in the future. .
2. Th* relative priority of Ihe project mat
will UM alternative and innovative pro-
easel and techniques. ;
3. The date upon wn.cn the application orl
the protect is submitted.
The OWPC must use the money MI aside
lor innovstrve or sitemative project! within one
year after the end of the fiscal year or the money
will be reallocated to other stales. BecauM of
thu, if there are insufficient projects on the fun.
dabie list to utilize in* 4 percent MI aside proj-
ect! on in* exended list utilizing alternative and
innovative processes may be moved to We fun-
dable (in using in* bypass procedur* to provM*
for utilization of these funds. j
Exclusion of Step 1 and Step a Fed*r*l Oranti >
The IM1 Federal Amendment! do not allow!
grants to be mad* lor th* purpose of providing)
financial assistance solely for preparation of la-.1
citlty plans, plans/specifications, nor estimates'
lor any proposed project lor the construction of
tr.atment «x«i. In in* event tnsi a protect re-
ceives s Steo J Federal grant tor construction1
EPA shall mate an allowance in such grant for
non-Federal lunds upended during preliminary
and final planning. *
ReMrve for Weler Quality Management
The 1M1 Amendment! also provide lor a
reserve of $100.000 or IS of Ihe allotment.
whichever amount is greater, which would allow
Ihe States to carry out water quality manage-
ment planning activities. This could include: de-
termination of water quality problems in varloul
areaa of the Hate, and/or evaluation of state-
wide pollution abatement programs.
Reeenre tor Step 1 end Step 2 Advene** ,
Under tne 1981 Amendment!, s Slste can
use up to 10% ol its Federal allotment to io-
vence funds to small communities lor pralimi-
nary and final planning. However, hi Massacftu-
Mtti. since the same goal can be accomplished •
lor any eiigibi* community through the provt.
lioni ol Chapter 786 of tne Acts of 1085 no
Federal funds have been MI aside for this pur-
pose.
TABLE A
CRITERIA FOR RANKING
CONSTRUCTION GRANT PROJECTS
A. Type of Prelect
i. Advanced Waaiewater Traat-
meni Project Required to Meet
Water Quality Standards in Areas
Where Secondary Treetment Tech-
nology li not Sufficient (Water
Quality Limned Segmenta).
2. Waste Treatment Projects
Wrier* Secondary Treatment Is Re-
quired (Effluent Limited Segment!)
or Primary Traatment Protects
wner* Secondary Treatment Waiv-
ers have been Obtained. Also, pro-
jects that Ullla* Alternatives lo
Conventional Wastew*t*r Treat-
ment Plants.
3. Outfall sewers, maior intercept-
ing sewers, maior pumping Na-
tions, and force mami. (if con-
itructed m contuction witn a
wastewater treatment plant, trtes*
protects will nave ine same priority
ranking as Ihe treatment plant)
t. Correction of inflitration/mfiow
problems mat ar* coit-«fiec!ive
and are needed to maintain the in-
tegrity of en editing or proposed
wastewater treatment system proj-
ect will receive Ihe same priority
rsnking as the trestment lysiem 100. gs
Project. o, gg
S. Protects for the Correction of
Combined Sewer Overflows. 80
6. Correction of infiltration/inflow
problem! where itudy anowt such
correction! to be cost effective but
win not iignilicsntiy aliect the
sizing ol waitewat«r treatment
facilities. 70
B. Effect on Urn
1. Project will improve
or protect a fresh-
water drinking water
supply.
2. Discharge is present-
. ly causing h«aitn haz-
ard or rtuiMnce.
3. Project will have
benelicia.' effect upon
liin and aquatic life.
4. Protect win nave
benelicial effect upon
recreation.
100
95
90
"I
10
10
20
20
10
10
30
30'
I
IS
15
10
15
•. Effect en Uee*
5. Prorect will improve
or protect an mdustn-
al water supply.
t. Existing Population
Served.
greater than
100.000 Upoinii
50-100.000 20 point!
less than
50.000 10 point!
DEFINITIONS
NPOES Permit no.: National Pollutant
Oracnarge Elimination System Number.
Meed! Survey Number:
This is the unique number assigned in con. j
tion with the Needs Survey which identities
tne faolity. If a facility number has not been as- I
signed. "NO NUMBER" is entered.
Project Step: . :
Step 1 • faciiiiiea planning !
Sl«p 2 - final design
Step 3 • construction •
Qreni Cenilication Date: Date Project is upect.
ed to be cenilled by OWPC to EPA lor funding
Project Description:
WWTP . wastewater Traatmcnt Plant
AT • Advanced Wsstewater Treatment
CSO • Combined Sewer Overflow Treat-
ment
I/I • Infiltration/inflow
Int. - Interceptor
P.S. • Pumping Station
P.M.. Force Main
Sep. - Separation
Inc. • Incineration
Alternative Systems for Small Communities-
For Step 3 protects, coding mdicsies an al-
ternative system lor a small community. The
letter "0" i* used H the project is lor a highly
dispersed section of a larger community or
•R- if tne project Is for a rural commu-
nity with a population el 3,500 or less.
Enforceable Requirements:
A — Project unifies the conditions or
limitation! of a 402 or 404 permit
which. If violated, could result In
the Issuance of a compliance order
or initiation of a civil or criminal ac-
tion under Section 309 of the
Clean Water Act. '
B — Permit nas not been Issued but
project satlsnn a condition or Umi-
latlon wnicn would be Included In
me permit when issued.
C — Permit is not applicable but protect
utisnn s requirement anticipated
to be necessary to meet applicable
criteria lor best practicable wast*
treatment technology (BPWTT).
0 — Project does not meet an enforce-
able requirement of the ACL
Y — The project in Its entirely satisttea
th« cnlorceaole requirements of
_ the Act ol in* condition stated in
trie preceding character position.
P — Portions ol m* project do not satis-
fy Ihe enforceable requirements of
Ihe condition stated in the preced-
ing character position.
innovative Eligible Coil/Alternative Eligible
Cost:
For Step 3 project!, that smount. H any. of
the eligible cost to be applied separately lo
alternative techniques and Innovative pro-
Eligible Cost by Needs Category:
For Step 3 protect! on lundable mi onry:
Category I • Secondary Treatment
Category II - Advanced Treatment
Category IIIA - Infiltration/inflow correction
Category IVB - New Interceptors and
appurtenances
Category V • Correction of combined sewer
overflows
Priority list/Wster Quality Management Plan
Relationship (WOM Code):
V State nas an approved WOM plan and
tne project is consistent witn this plan.
2. Stste does not have an approved WOM
plan but the project is essential to cor-
rect an eiisting wster quality program.
3. State hai an approved WOM plan but
this project in not consistent with the
plan.
-------
February 26, 1979
Revised March 6, 1979
Appendix D Approved EPA September 28,' 1979
Re-approved EPA September 25, 1980
Re-Approved EPA July 7, 1982
STATE OF NEW HAMPSHIRE
WATER SUPPLY & POLLUTION CONTROL COMMISSION
PROJECT PRIORITY SYSTEM
pn Hamp'hir? Pr°ject Priority System for award of grants
e allotments was developed to achieve optimum water quality manage-
nS 6nt rlth ^e ot)Jectives of N-H- RSA 149:3-a and the Federal9
Water Pollution Control Act, and in accordance with said Statutes and Act.
Pmri£y-SyStem, -S comPrised of: <]) ^oject Rating System anH
ia; (2) Priority List Development Procedures; and (3) Priority
List Management, Monitoring and Revision Procedures. Priority list manage-
ment procedures include procedures for the yearly list development and for
re-evaluation and revision throughout the fiscal year. These individual
elements are addressed below.
I. Project Rating System and Criteria
A numerical priority point total will be established for each project
based on evaluation of the following: M'ujeut
1. Severity of Pollution Problems:
(a or b + c) Maximum Points Project Points
a. Domestic Wastes Only . 4
b. Domestic & Industrial Wastes 5
c. Relationship by Volume of
Wastes to Receiving Waters 5
2. Population Affected:
(a or b) Maximum Points Project Points
a. Predominately Rural 3
b. Predominately Urban 5
3. Need for Preservation of Hioh-
Quality Water:
(a + b + c) Maximum Points
a. Receiving Water of High
Recreational Use 4
b. Receiving Water.Used as
Water Supply 5
D-l
-------
c. Receiving Uater Lake, Pond
or Small Stream, Requiring
Advanced Treatment
4. National Priorities:
(a or b or c + d or e)
a. Major Project Required to
Meet Enforceable Provisions
of the Law
b. Minor Projects Required to
Meet Enforceable Provisions
of the Law
c. Projects Required to Meet
Public Health Laws
d. No Discharge; Collection
Sewers, Collection for New
Treatment Plants, Recycling,
etc.
e. Priority Basins (Rating
Based on EPA Guidelines)
TOTAL PROJECT POINTS
Maximum Points
Maximum Points
40
Severity of Pollution is a measure of the amount and type of
wastes.. A greater quantity and strength (with consideration given
to the volume of flow in the receiving waters) determines the
increase in project points.
Population Affected is a measure of the number of-people in
the area covered by the project. The greater the population
determines the increase in project points. Areas are considered
Rural when the population in the project covered area is less
than 3500 and in PL 95-217, Section 205(h).
Need for Preservation of High Quality Water is a measure of
use, class and effect thereon of the waters where projects are to
discharge. The greater the need for purity of the receivina water
determines the increase in project points.
National Priorities is a measure of the need as indicated in
Federal and State permits and orders to promptly abate pollution
The greater the need determines the increase in project points
D-2
-------
Each year, subsequent to guidance by EPA on projected Federal fund-
ing levels, the Commission will prepare a project priority list. This
list will identify all projects that may be funded over a five-year period
with separate delineation of the projects proposed to be funded in the
first year of the five-year period (fundable year). There will be an
additional list prepared and maintained each year to include projects not
fundable within the five-year period but required to comply with the
enforceable requirements of the law.
„ The following concepts will be utilized in the preparation of the
1 ists-.
1. All steps of a project will be identified separately on the
lists.
2. The projected available Federal funds for grants each year
throughout the five-year period will be determined by sub-
tracting the following from the projected yearly State allot-
ment:
a. The deduction permitted to be used for the State Manage-
ment Assistance Grant.
b. The percentage required by statute for alternative/inno-
vative projects increase.
c. The percentage required by statute to be set aside for
grants to alternative systems in small communities.
d. Five percent for grant increases of all funds available
at time of list preparation.
e. The reserve for "Advances of Allowances".
f. The reserve for "Water Quality Management",
3. Selection of Step III projects proposed to be funded from
available funds in the first fiscal year and tentatively
proposed for funding in the remaining four years, will be
generally based on the concept of funding the highest pri-
ority rating projects that are ready to receive their Step
III grant within the fiscal year (October 1 to September 30).
The following also control the selections of Step Ill's.
a. Projects lacking or with unclear implementation ability
will be scheduled after implementable projects.
b. Where several projects of the same or nearly the same
priority rating are ready to proceed in a fiscal year
and represent the highest priority projects ready to
proceed, the following will be the order of selection:
D-3
-------
i) raw discharge elimination
ii) primary upgrade in critical water
iii) primary upgrade in non-critical water
c. Efforts will be made to fund Step Ill's for joint projects
not more than one fiscal year apart. projects
d. Efforts will be made to fund projects removed from the pre-
vious year's list in the subsequent fiscal year
e. Sufficient alternative or innovative projects will be
scheduled in each funding year to utilize the reserves
for alternative/innovative if they exist and are ready
to proceed. J
4. Planning and Design necessary to support the selected Steo III
projects will be scheduled, as appropriate, in earl ier fiscal
years Generally, Design will be scheduled within two f sea
years before the projected Step III.
5'
JSlJlJV**1! 5e consistent with the needs inventory and
with State and areawide Water Quality Management plans.
6. The list will contain the information required by EPA reaula
tions and guidance. «ywo
Once the list is prepared in draft form, public input will be snunht
t1iXh*n?ithe ?1or!tr.«yit« through direct corres onSe e and 9 '
£ ;;th-*11un"l"C!P"mies on the list and through the public hearina
i nntil? ^KHa?PSh re WaJer Supply and Pollution Control Commission
whprp rl °f VVe.heani?9 will be statewide and indicate the locations(s)
v?P*L hS *Vf ^5 P^ority system and the draft priority list may be
viewed by interested persons prior to the hearing. In addition news
w? iah!Sc2?Tn1?? W^'fl. the priority system and the Pro"jecTlist
w 11 be sent to all daily newspapers in the State. All Public Pa rtic na-
tion requirements of EPA will be complied with in the preparation 5f {he
th. n KV c°m s re«ived from the time of the notice to the close of
the public hearing will be responded to by the Coimiission; and, where
appropriate, changes will be made in the draft lists. A summary of ?he
public comments/testimony and Commission decisions will be prepared and
Jnf.'lJS-6 t0 th+ PUbl1'* 3ud wil1 also be forwai"ded to EPA with the request
for their acceptance of the priority list and system. EPA must accept the
1st before it becomes the official instrument to distribute the grant
allotment for the fundable year. 9
D-U
-------
Not less than quarterly, the Commission will re-evaluate the pri-
ority list in view of project slippage, cost increases experienced that
affect the actual number of projects that can be funded out of the current
fiscal year allotment, possible reductions in allotments, possible new
allocations, increasing current fiscal year funds available, etc. From
this evaluation, the Commission may propose a change in the list.
Priority list changes can be categorized as insignificant and
significant. Insignificant changes will not be subject to further public
hearitlg. The Commission must gain EPA acceptance of the list change and
must adequately document the reasons. For significant changes, a public
hearing may be held if required and requested by EPA.
1. Insignificant Changes
a. Removal of projects on the fundable (first year) portions
of the list which are not ready to proceed in the October 1
to September 30 time-frame and replacement with the highest
priority rating projects from the extended (next four years)
portion of the list that are ready to proceed. The pro-
jects removed will retain their priority rating and gen-
erally be proposed for funding the next fiscal year.
b. Removal of lower priority rating projects from the fund-
able portion of the list and placement in the extended
portion in order to balance the remaining projects with
the funds available. The projects removed will retain
their priority rating and generally be proposed for fund-
ing the next fiscal year. The reduction of funds availabe
will have been caused by higher project cost or by lower
Congressional appropriations. Should the removal of pro-
jects be caused by a Congressional appropriation in excess
of 10% of that assumed in the annual guidance furnished by
EPA and used in preparation of the lists, the 'change shall
be considered "significant".
c. Addition of the highest priority projects consistent with
the ranking criteria, ready to proceed from the extended
list to the fundable list to allow use of an additional
allotment applying to the current fiscal year made avail-
able during the fiscal year. Should the additional allot-
ment be in excess of 10% of that amount assumed in the
annual guidance furnished by EPA and used in the preparation
of the approved lists, the change shall be considered "sig-
nificant".
d. Addition of projects to the fundable list that were anti- •
cipated to be funded (at the time of list preparation) in
the prior fiscal year but slipped; thus, they did not show
on the fundable list when prepared. To accommodate these
projects, sufficient lower ranked projects originally
anticipated to be funded during the current fiscal year
D-5
-------
will be removed and added to the extended list in order to
balance the list to the available funds. The removed pro-
jects will retain their priority rating and generally be
proposed for funding the next fiscal year. This type of
change is necessitated by the fact that the original yearly
list is developed at a time prior to funding all projects
on the previous fundable list and a few projects may si ID
in the interim.
e. Removal of projects which have been funded, which are no
longer entitled to funding under the approved priority
system, which the Regional Administrator has determined,
are not eligible to comply with enforceable requirements
and which are otherwise ineligible.
f. Clerical and priority list information changes.
2. Significant Changes
a. Where funds available in the actual allotment to the State
are significantly less than or greater than 10% of that
assumed in the annual guidance from EPA.
b. Where changes other than those indicated as insignificant
are proposed.
D-6
------- |