BOSTON HARBOR SUPPLEMENTAL
DRAFT
ENVIRONMENTAL IMPACT STATEMENT
EVALUATION OF SATELLITE
ADVANCED WASTE WATER TREATMENT FACILITIES
APPENDIX B
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION I
ENVIRONMENTAL EVALUATION SECTION
JOHN F. KENNEDY FEDERAL BUILDING
BOSTON, MASSACHUSETTS 02203
May 16, 1984
Prepared by:
CE MAGUIRE, INC.
ONE DAVOL SQUARE
PROVIDENCE, Rl 02903
**.
\m)
THE MAGUIRE
GROUP
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BOSTON HARBOR SUPPLEMENTAL
DRAFT
ENVIRON IENTAL IMPACT STATEMENT
Evaluation of Satellite
Advanced Wastewater Treatment Facilities
APPENDIX B
U.S. Environmental Protection Agency
Region I
Environmental Evaluation Section
John F. Kennedy Federal Building
Boston, Massachusetts 02203
May 16, 1984
Prepared by:
CE Maguire, Inc.
One Davol Square
Providence, Rhode Island 02903
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APPENDIX B
FEASIBILITY OF SATELLITE TREATMENT FACILITIES
TABLE OF CONTENTS
SECTION TITLE PAGE NO .
I. CONCLUSIONS AND SUMMARY B-i
B1.1. Recommended Satellite Facilities B-i
Bl.2. Satellite Facilities with Wetlands
Discharge B-3
II. HISTORICAL BACKGROUND B-S
B2.1. EMMA Concepts B-S
B2.2. EMMA Recommended Satellite Facilities B—9
B2.3. 1978 Draft EIS Conclusions B-i2
III. DESCRIPTION OF SDEIS SATELLITE OPTIONS B-24
B3.l. EMMA Study Satellite Facilities Update B-24
B3.2. Quincy Shores Association Wetlands
Disposal Option B-26
B3.2.i The Weymouth Fore River Basin B-28
B3.2.2 The Neponset River Basin B-30
B3.2.3 The Charles River Basin B-31
B3.3. Relationship of SDEIS Satellite Options
with On-Going Facilities Plan in the
Southern NSD B-38
IV. EVALUATION OF SATELLITE OPTIONS B-41
B4.i. EMMA Satellite Evaluation B-41
B4.1.i Flow Augmentation B-41
B4.i.2 Water Quality B-42
B4.1.3 Water Supply B-Si
B4.2. Wetlands Disposal Option B-54
1.
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ATTACHMENT A WATER QUALITY MODELING CORRESPONDENCE B-Si
ATTACHMENT B WETLANDS DISPOSAL BIBLIOGRAPHY B-123
ATTACHMENT C WETLANDS DISPOSAL-DEQE CORRESPONDENCE B-126
ATTACHMENT D I/I PRELIMINARY REPORT TO PROF. CHARLES N. IIAAR B-140
11
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List of Tables
Page
Bi. Satellite Facilities General Description B-6-7
B2. Treatment Alternatives B-8
B3. Summary of Other Treatment Options B- 13
B4. Comparison of AWT Effluent and Charles
River Quality B-15
B5. Revised Flow Estimates - Satellite Plants B-25
B6. Co t Update - ENMA Satellite Facilities B—27
B7. Wetland Acreage Requirements - Satellite
Facilities B—34
B8. Cost Summary: Wetlands Disposal Satellite
Facilities B—36
B9. Charles River Water Quality Survey Data Summary:
1973/1978 B—46—48
BlO. Neponset River Water Quality Survey Data Summary:
1973/1978 B—52—53
Bil. Preliminary Estimate of Wetland Availability for
Wetlands Disposal Treatment Facilities B—55
List of Figures
Bi. EMMA Recommended Plan B-b
B2. Satellite Facilities with Wetlands Discharge B-29
B3. Conceptual Design of AWT - Wetlands Discharge
Facility B—37
B4. Charles River Average Dissolved Oxygen DWPC Surveys:
1973, 1978, 1980 and 1981 B—49
111
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I. CONCLUSIONS AND SUMMARY
Based on the enclosed detailed evaluations, the following conclusions can
be stated regarding previous and new proposals to locate satellite
facilities in the South MSD:
Bi.i. Recommended Satellite Facilities on the Charles and Neponset
Rivers
a. Based on structural and hydrological analysis of the High Level
Sewer (HIS) and revisions to wastewater flow projections as reported
in the MDC Nut Island Site Options Study (MDC, June 1982, #4), the
HIS was found to be of adequate capacity and condition to accommo-
date flows up to 310 MCD without any relief requirement. Based on
available I/I data, the HIS could see occasional peak flows higher
than 310 MCD, which have been estimated to reach up to 420 HGD. The
development of the two proposed satellite AWT facilities to remove
approximately 59 MGD from the south MSD system would not, in and of
themselves, reduce these HiS flows sufficiently to a level whereby
harbor treatment facilities could be reduced in size.
b. Following the completion of necessary upstream interceptor relief
projects, removal of limiting hydraulic factors in terms of pumping
capacity at Nut Island, implementation of a flow monitoring program
in the southern MSD, and a more realistic assessment of I/I reduc-
tion alternatives, the development of satellite treatment facilities
in the south system versus other flow reduction/management options
should be reevaluated as a priority in determining a cost effective
and equitable solution to future system expansion needs.
c. Based on current updated facility plans of the MDC and their imple-
mentation time frame, it is our view that major interceptor relief
projects currently proposed downstream of the sites investigated for
AWT facilities would still be required to alleviate overflows and
other surcharging conditions created by constrictions and other
B-i
-------
structural or hydraulic problems presented in the system, irrespec-
tive of a decision regarding satellite facilities.
d. The discharge of the AWT facility effluent to the Neponset River
will have an adverse impact on water quality, particularly upon the
dissolved oxygen resources of the river. Additionally, during
periods of low stream flow, potential public health/water supply
impacts pose significant problems to public water supplies, based on
stream f1ow—ground ater relationships under low flow conditions and
groundwater pumping close to the river. Potential public health/
water supply impacts outweigh any potential benefit in terms of
low-flow augmentation of the Neponset River. A satellite facility
on the Neponset River is not recommended for further consideration.
e. The discharge of an AWT facility effluent to the Charles River may
have a beneficial impact on the dissolved oxygen resources of the
river, even though water quality standards might be violated during
certain periods. Increased phosphorus loads may exacerbate nuisance
algae conditions in downstream reaches of the river. During periods
of low stream flow, potential public health/water supply impacts may
pose significant problems to public water supplies based on stream
flow-groundwater relationships under low flow conditions and ground-
water pumping close to the river. Potential public health/water
supply impacts may outweigh any potential benefits in terms of
low-flow augmentation of either the Charles River or, via the Mother
Brook diversion, the Neponset River.
In accordance with Conclusion b. above, at such time as satellite
facilities are determined to be a possible option to limit flows to
the Harbor treatment system to the design limit of the HLS and
treatment system, a satellite facility on the Charles River should
be reconsidered, incorporating consideration of possible in-stream
and other impact mitigation measures as may be determined necessary.
B-2
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B1.2. Satellite Facilities with Wetlands Discharge
Satellite AWT treatment facilities proposed by Quincy Shores Associates,
to be located on the Charles, Neponset, and Weyinouth Fore Rivers with
discharge to adjacent wetlands, are not recommended for further consid-
eration as part of the current facility siting analysis for the following
reasons:
a. Development of these AWT facilities, which would treat approximately
97 MGD of wastewater, would not provide sufficient flow relief, or
otherwise reduce the volume of flows in the MSD southern system in
order to reduce the size of a harbor-sited treatment facility. This
is largely due to the existing adequate capacity of the High Level
Sewer to handle all flows reaching it, and sufficient excess volume
wastewater flows to deliver a projected 310 11GB to a southern MSD
harbor treatment plant.
b. All currently planned MDC interceptor relief projects are downstream
of the proposed sites for these three AWT facilities and would,
therefore, still be required, offering no offsetting capital outlay
savings.
c. The potential water supply/public health dangers associated with the
impacts of discharge to a wetlands/watershed area are significant.
The state has reviewed this proposal and has found sufficient
elements of uncertainty and/or detrimental effect that they do not
support this proposal’s feasibility. In particular, the issues
raised about potential dangers from such a siting location include
the expected pass-through of untreated organics and other poten-
tially harmful materials, the more stringent groundwater/surface
water standards that would be applied to such a facility’s effluent
essentially resulting in drinking water standards, and other related
concerns outweigh any potential low-flow augmentation benefits.
B-3
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d. The limited availability of wetlands in close proximity to the
proposed systems of sufficient size to accept effluent volumes of
10, 35, and 52 !IGD as proposed, as well as limitations of the
hydraulic and renovation capacities of the existing wetlands,
suggests that facilities of such magnitude would be difficult to
site. Required hydrologic and wetland ecology evaluations are also
expected to require a substantially longer implementation time
frame.
e. The major capital costs of developing three AWT facilities, esti-
mated to be considerably in excess of $238 million, coupled with
major O&M costs annually, do not appear to be justified by the lack
of potential benefits of such facilities relative to the need to
site harbor treatment facilities.
B-4
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II. HISTORICAL BACKGROUND
B2.1. EMMA Concepts
Five broad-scale wastewater management concepts were developed for
evaluation in the Eastern Massachusetts Metropolitan Area Wastewater
Management EHMA Study (MDC, Oct. 1975, #3). Although the concepts
themselves were not necessarily formulated with the intention of any one
being selected for implementation in its entirety, it was intended that
the evaluation of these broad-scale concepts would establish the design
criteria, system limits, and other conditions and considerations required
of an implementable, recommended plan.
Brief general descriptions and important features relative to satellite
facilities of the five original concepts are shown on Table Bi. An
extensive rating system was employed to evaluate and rank the concepts by
the Technical Subcommittee. This evaluation led to the elimination of
concepts 3 and 5 from further consideration. As stated in the EMMA Study
Main Report (pg. 4—27):
“Upon evaluation of all the factors affecting the plan selection
process, and because of the closeness of the rankings for Concepts
1, 2 and 4, it was decided by the Technical Subcommittee that a
moderately decentralized system would be the best overall solution
considering river flows, increasing demand and decreasing oppor-
tunities for water—oriented activities, and the difficulties associ-
ated with extensive interceptor construction through urban areas and
the filling of Boston Harbor.”
Four satellite treatment alternatives were developed for further evalua-
tion. The satellite systems and communities to be served under each
alternative are summarized in Table B2. The wastewater flows from
remaining communities tributary to the Nut Island Treatment Plant would
continue to flow to Nut Island for treatment and discharge to Boston
Harbor. The following excerpt from EMMA Study Main Report summarizes the
evaluation of the four alternatives:
B-5
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TABLE Bi
SATELLITE FACILITIES GENERAL DESCRIPTION
Satellite Facilities Design Communities Served
Concept Description ( River Basin) ( Plant Location) Flow By Satellite Plants
Upgrade existing facili- None
ties, minor system expan-
sion (addition of 7 com-
munities), no satellite
plants
2 Limited decentralization, Sudbury R. Framingham 19.0 MGD Ashland, Framingham,
creation of five regional Hopkinton, Southborough
satellite systems
Charles R. Dedham 29.0 PIGD Brookline (25%), Dedham,
Dover, Natick, Needham,
Newton (8%), Sherborn,
Wellesley, Boston (West
Roxbury)
Charles R. Watertown 45.0 1 1GD Lincoln, Newton (92%),
Waltham, Watertown,
Weston
Neponset R. Canton 25.0 MGD Canton (70%), Norwood (90%),
Sharon, Stoughton, Walpole
Neponset R. Canton 5.5 ! 1GD Canton (30%), Dedham (10%),
Norwood (10%), Westwood
3 Maximum expansion of MSD None
treatment of all flows at
expanded harbor facili-
ties
B-6
-------
4 Maximum decentralization
of MSD, creation of six
regional satellite sys-
tem
Sudbury R.
Charles R.
Framingham
Dedham
19.0 MGD Same as Concept 2
22.0 MGD Dedham (40%), Dover,
Natick, Needham, Sherborn,
Wellesley
Charles R.
Watertown
45.0 MGD Same as Concept 2
5 Land application of five
of the six satellite
facilities as proposed
in Concept 4 - otherwise
identical to Concept 4
30 MGD Canton, Norwood, Sharon,
Stoughton, Walpole,
Westwood
31.0 MGD Burlington, Reading,
Stoneham (85%), Wakefield
(10%), Wilmington,
Winchester (45%), Woburn
30.0 MGD Arlington, Bedford, Belmont
(90%), Lexington, Medford
(20%), Winchester (55%)
Neponset R. Canton
Mystic R. Woburn
Mystic R. Medford
Same as Concept 4 (Sudbury
River - Framingham Facility
would not employ land appli-
cation)
B-i
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TABLE B2
TREATMENT ALTERNATIVES
Satellite Facilities Design
Alternative River Basin Plant Location Flow Communities Served by Satellite Plants
A Charles R. Middle Charles 31 MGD Ashland, Dover (60%), Framingham,
Area Hopkinton, Natick, Sherborn, South-
borough, Wellesley (80%)
Neponset R. Lower Neponset 31 MGD Canton, Norwood, Sharon, Stoughton,
Area Walpole, Westwood
B Charles R. Lower Middle 57 IIGD Ashland, Brookline (15%), Dedham (40%),
Charles Area Dover, Framingham, Hopkinton, Natick,
Needham, Newton (54%), Sherborn, South-
borough, Wellesley
Neponset R. Lower Neponset 31 IIGD (Same as Alternative A)
Area
C Charles R. Middle Charles 31 MGD (Same as Alternative A)
Area
Charles R. Lower Middle 27 MGD Brookline (15%), Dedham (40%), Dover
(60%), Needham, Newton (54%),
Wellesley (20%)
Neponset R. Lower Neponset 31 MGD (Same as Alternative A)
Area
0 Sudbury R. Upper Sudbury 19 MGD Ashland, Framingham, Hopkinton, South-
Area borough
Charles R. Lower Middle 39 IIGD Brookline (15%), Dedham (40%), Dover,
Charles Area Natick, Needham, Newton (54%),
Sherborn, Wellesley
Neponset R. Lower Neponset 31 MGD (Same as Alternative A)
Area
B-8
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“Upon further analysis of the Neponet River, the Massachusetts
Division of Water Pollution Control recommended that if a satellite
treatment plant is located for discharge to the Neponset River, the
plant should be located as far upstream as possible to provide
maximum benefits to the river, particularly during the dry summer
months.
“A plant in the middle Charles area was considered vital to provide
effluent for low-flow augmentation. As mentioned earlier, investi-
gations (by the Corps of Engineers and the United States Geological
Survey) for other means of flow augmentation in the Charles River
were found not feasible and the need for conserving river flows was
shown to be critical (by the United States Geological Survey). In
terms of location, the lower middle Charles plant would be undesir-
able due to the flat, slow flowing river in that location. However,
an upper middle Charles plant discharging at the Cochrane Dam near
Charles River Village would be in a location where the discharge
would benefit from the over one mile long rapids section.
“In addition to these considerations, the plants will also serve to
reduce flows to the Nut Island Treatment Plant and will reduce the
need for relief lines along the Wellesley Extension Sewer, the New
Neponset Valley Sewer, and the High Level Sewer.
“Providing a 2 mgd wastewater treatment plant in the Aberjona River
area would cost on the order of $9.7 million to construct and about
$0.7 million per year to operate. These costs represent the com-
plete treatment process shown [ in Figure 3-4]. On the basis of
operating costs alone, this would be in excess of three times the
cost of using MDC water for augmentation (which would be an un-
acceptable alternative). In addition to this, other alternatives of
flow augmentation should be considered such as groundwater pumping
during low flows and recharge during high flows.
“A wastewater treatment plant discharging to the Sudbury River in
the Frainiugham area was considered as not providing a significant
improvement in flows due to the large storage potential in the flat
swampy areas downstream.”
Based on the evaluation of these alternatives, a modified Alternative A
was selected as the Recommended Plan.
B2.2. EMMA Recommended Plan - Satellite Facilities
The Recommended Plan included satellite treatment facilities discharging
to the Middle Charles and Upper Neponset Rivers. Figure Bi portrays the
system under this plan. The Middle Charles Treatment Plant would serve
Ashland, Framingham, Hopkinton, Natick, Sherborn, Southborough and
8-9
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•‘ ‘
NUø OLI
LI GINO
I EXISTING FACILITIES NOT REQUIRING RUIEF OR
UPGRADING AS PART OF THE RECOMMENDED PLAN
A. EXISTING MSD SEWERS
O EXISTING CITY OF SOSTON FACILITIES
II MAJOR PROiECTS IN RECOMMENDED PLAN’•
A EXISTING MSO SEWERS ___________
REQUIRIN3 RELIEF
S. PROPOSEC EXTENSION SEWERS ___________
O TREATMENT PLANTS
NEW)
(INCLUOES CNGOING PROJECTS)
III SERVICE ARIAS UNDER THE RECOMMENDED PLAN.
A. DEER ISLAND PLANT
S. NUT ISLAND PLANT
C. MIDDLE C4A ILES PLANT
0. UPPER NIPONSET PLANT
*
1
[ i
FIG.Øt TREATMINT PLANT
SFRV ICE ARE\S AM) M%JOR PROJECTS
I S TIlL RECO 1 1FNIWD PLAN
rt SSu v
AIab*’
COWCOM
pI* ODy
MA SO NO UGH
sUoSu N ’—-
AOL LIS? 0$
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SOC ML AM 0
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our e EMMA &tudv, u sma y epM
Mav i 1sii ,.
eMULSION
-------
portions of Dover and Wellesley and would have a design flow capacity of
31 MGD. The Upper Neponset Treatment Plant would serve Canton, Norwood,
Walpole, Sharon and Stoughton and would have a design flow capacity of 25
IIGD.
The anticipated benefits associated with these proposed facilities were
summarized as follows:
Neponset River -- This facility would reduce the service area of the Nut
Island Treatment Plant and keep reclaimed wastewater as far upstream in
the Neponset River Basin as possible. The highly treated effluent should
help the Neponset River by increasing flows in dry summer months.
Restoration of clean water will also depend on the abatement of nonpoint
and other sources of pollution.
Charles River -— This facility would treat 31 mgd in the year 2000,
reduce flows to the Nut Island plant, and help retain reclaimed waste-
water in its immediate basin. Adding these flows to the Charles River
will be helpful to water quality in dry seasons. However, there can be
no assurances of achieving intended water quality in the Charles River
unless nonpoint and other sources of pollution are eliminated. The
treatment facilities which are in various stages of implementation in the
Medfield, Medway, and Milford areas should also benefit the river. It is
worthwhile to note that, in recommending the implementation of both
treatment facilities, it was recognized by the Technical Subcommittee and
by those who participated in the public review process that water quality
in both the Charles and Neponset Rivers might not be improved. There
appears to have been, however, an implicit assumption that water quality
problems would not worsen as a result of the discharges from these
treatment facilities.
The Middle Charles and Upper Neponset facilities were scheduled as
sequence numbers 10 and ii respectively in the Construction Staging
Program for MDC Wastewater Management Projects under the EMMA Study. The
total cost of both facilities was $90,700,000 based on January 1975 (ENR
2200) costs.
B-li
-------
The Construction Staging Program also listed interceptor relief in lieu
of sequence numbers 10 and 11 as sequence numbers 1OA and hA if the
satellite plants are not implemented. The total cost of additional
interceptor relief for the Wellesley Extension, New Neponset Valley and
High Level Sewers was listed as $64,700,000 (January 1975, ENR 2200).
Finally, four optional treatment scenarios were presented in the EMMA
Main Report which were intended to provide an economic perspective of the
impacts of major changes from the Recommended Plan such as timing of
implementation of major facilities (i.e. satellite plants); and policy
changes such as primary treatment with deep ocean discharge versus
secondary treatment. These “Other Treatment Options” and their assciated
capital and O&N costs are summarized in Table B3.
B2.3. 1978 Draft EIS Conclusions and Recommendations
The Draft EIS concluded that neither the Charles nor Neponset River
satellite plants should be constructed. This conclusion was based on
negative water quality impacts projected to occur or to be maintained at
the 7Q10 design flow condition.
Based on the application of a basic Streeter-Phelps dissolved oxygen
analysis in the Neponset River, the Draft EIS concluded that:
“Any discharge to Neponset in the area proposed by the EMMA report
would result in a significant detrimental impact on the Neponset
River’s dissolved oxygen resources and overall water quality. In
addition, all the discharge points analyzed are upstream of a major
group of water supply wells (See Figure 2.5-18). It is very likely
that these wells draw from the Neponset during low flows, given
their proximity to the River and the nature of the aquifer. The
potential for significant adverse health effects is created by
utilizing any of these discharge point. In order to mitigate these
impacts it would be necessary to move the discharge point downstream
of point C. Such action reduces potential flow augmentation bene-
fits considerably.
B- 12
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TABLE B3
SUMMARY OF OTHER TREATMENT OPTIONS: MDC - EMMA S1)Y 1113
Operation &
Capital Cost, 1 ) Maintenance Cofl)( 2 )
Option Description millions of $‘ millions of $/yr
Recommended plan 855.3 25.6
Total ocean discharge No satellite treatment plants. 737.9 16.9
All flows discharged in deep
waters after receiving primary
treatment at the Harbor plants.
Ocean discharge in Satellite treatment plants con— 755.7 22.3
lieu of secondary structed. Primary treatment at
treatment the Harbor plants with deep
ocean discharge.
Deletion of satel- No satellite treatment plants. 872.4 20.9
lite plants All flows receiving secondary
treatment at the Harbor plants.
Postponing of satel- Delayed construction of satel- 884.8 20.3
lite plants lite plants. Upgrade primary
treatment at the Harbor plants.
Extend treatment capabilities at
the Harbor plants to secondary
along with construction of
satellite plants.
1. Costs shown are in millions of dollars based on January 1975 (ENR 2200) prices.
2. Costs on the basis of future flows (year 2000).
(#13) See Bibliography, Appendix B.
B- 13
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“In light of the great potential negative impact upon water quality,
implementation of a Neponset River Satellite Plant is not recom-
mended.”
A fairly rigorous analysis of the Charles River was undertaken by Alan
Ikalainen (at that time of EPA Region I Systems Analysis Branch staff)
employing a computer model developed for the ?lassachusetts Division of
Water Pollution Control (MDWPC) known as the STREAII model. Based on this
analysis, the Draft EIS concluded that:
“A satellite plant represents a major new pollutant source for the
Charles River, which will increase point source mass input the River
of BOD 5 from 329 to 586 kg/d (725 to 1293 ibs/d) and nitrogenous
oxygen demand from 311 to 535 kg/d (685 to 1181 lbs/d) (See Table 7,
Appendix 3.2.2). In addition, the following table compares the
proposed discharge with River quality just upstream of the dis-
charge. Impositionof this additional load upon the already
stressed river system may effectively preclude the Charles from
recovering from its present stressed condition. If River conditions
improve such that standards are met, the satellite discharge is
indicated to cause violation of standards unless an extremely high
level of treatment is achieved on a consistent basis. As the result
of this analysis, a satellite plant discharge is seen as not improv-
ing water quality in the Charles River and contributing to the
maintenance of its present condition. The implementation of a
satellite plant discharging to the Charles River is not recom-
mended.”
The conclusions and recommendations of Mr. Ikalainen’s report are stated
here as follows:
“ Conclusions
“1. The physical characteristics of the Charles River are such that
it has a very low assimilative capacity for oxygen demanding
wastes at the seven-day, ten-year low flow.
“2. This analysis reveals a very major likelihood that the Charles
River, at the seven-day, ten-year low flow, when receiving year
2000 wasteloads (5 mg/i CBOD 5 and 1 mg/l NR - N) from existing
treatment plants in Milford, Medfield, and Millis and the
Charles
“River Pollution Control District Plant, will not attain the 0.0.
level of 5.0 mg/i for long stretches. This condition will prevail
with or without an MDC Satellite plant discharge at any of the
locations considered in this analysis.
B-14
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TABLE B4
COMPARISON OF AWT EFFLUENT AND CHARLES RIVER QUALITY*
I . . 2
Charles River Satellite Discharge
Flow, m 3 / 0.89 1.353
(ft /s) (31.4) (47.7)
Dissolved Oxygen, mg/i 3.1 6.0
BOD 5 mg/i 0.6 5.0
(kg/d (lbs/d) 67 (148) 478 (1494)
Nitrogenous Oxygen Demand
mg/i 0.005 1.0
kg/d (lbs/d) 17.5 (38.5) 535.8 (1181.5)
Total Oxygen Demand
mg/i 1.1 11.9
kg/d (ibs/d) 84.6 (186.5) 1231.4 (2675.5)
‘River conditions as modelled at river kilometer 80.3 (river mile 50),
just upstream of Medfieid State Hospital discharge point, during 7 day,
10 year low flow. All upstream point sources have effluent quality of 5
mg/i BaD 5 and 1 mg/i NH 3 -N.
recommended discharge and effluent quality.
3 This represents an increase of 152% in the flow of the river at the
point of discharge.
*Froin Ikalainen as noted previously.
B- 15
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“3. If future discharges at Milford, Medfieid and Millis and the
Charles River Pollution Control District can be reliably
treated and the river can be reliably treated such that D.0.
levels in the river upstream of an MDC satellite plant dis-
charge are at 5.0 mg/i at the seven-day, ten-year low flow,
then an MDC satellite plant discharge containing 5.0 mg/i of
CBODç would not lower D.0. levels below 5.0 mg/l if it is
ioca ed upstream of the South Natick Dam. However, this
condition would be true only if no other oxygen demanding
phenomena such as algal die off and non-point source pollution
occur during the low flow periods.
“4. It is understood that the “STREAM” model does not simulate all
of the physical and biochemical processes that occur in the
Charles River and which determine part of its water quality and
biotic condition. However, these processes, such as algal
growth and death dynamics, land-surface runoff dynamics, septic
and solid waste leaching-—all of which are known to occur in
the Charles River, can further worsen D.O. conditions at
critical periods beyond those processes which are simulated by
the “STEAM” model. Such critical conditions would probably be
during periods of high temperature, low river flow and between
periods of short duration, intense rainfall. The occurrence of
base flow (groundwater flow) into the river has not been
considered and its effect on water quality is not known.
“5. An MDC satellite plant discharge under the anticipated year
2000 wasteloads (5.0 mg/i CBOD 5 and 1.0 mg/i Nil 3 - N at all
upstream discharges) will significantly improve D.O. levels in
the Charles River only if the discharge is located upstream of
the South Natick Dam or near the Medfield Hospital. The
improvement will be 1 to 2 mg/i increase in D.0. along several
miles of river. However, the improved condition will be
significantly below the desired level of 5.0 mg/i.
“6. This analysis indicates that benthal oxygen demand is a signi-
ficant oxygen loss to the Charles River. For example, at the
seven-day, ten-year flow, without sediment oxygen demand
and without any treatment plant flow or wasteloads, the Charles
would meet the D.0. level of 5.0 mg/i except for a short
stretch upstream of Milford where background loads would cause
D.0. to fall to 2.5 mg/l. Current wasteloads (1978) added to
the river under these same conditions cause D.O. levels to fall
to zero below Milford and within the South Natick Dam and
Cochrane Dam impoundments. If these wasteloads receive ad-
vanced treatment (5.0 mg/i CBOD 5 and 1.0 mg/i NH 3 - N) and the
Charles River Pollution Control District Plant receives ad-
vanced wastewater treatment, at year 2000 wastewater flows, the
zero D.0. levels are raised to greater than 5.0 mg/i below
Milford and to about 2.5 mg/i in the South Natick Dam and
Cochrane Dam impoundments.
B-16
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“If an MDC Satellite plant discharge is added to the river at
Medfieid with year 2000 flows with advanced treatment, D.0.
levels are raised by 1-2 mg/i within the South Natick Dam
impoundment and lowered by 1.0 mg/i to about 4.0 mg/l within
the Silk Miii Dam impoundment. If the Satellite plant dis-
charge is located below the Cochrane Dam, thre will be no D.0.
increase within the South Natick Dam impoundment and there will
be an additional decrease in D.0. of 1.0 mg/i to about 3.0 mg/i
within the Silk Mill Dam impoundment.
“In comparison, with sediment oxygen demand at the levels used
in this analysis, as the volume of wastewater discharged, not
including the proposed satellite plant, increases from no plant
wastewater discharged to 1978 flows to 2000 flows, at the
respective levels of treatment, the D.0. levels of the river
increase successively. The result is that the D.0. levels will
be significantly better in the Charles at the year 2000 flows
at Milford, CRPCD and Medfieid-Miliis, receiving advanced
treatment, than at present flows and treatment levels. How-
ever, there will be long stretches with D.0. very much less
than 5.0 mg/i within the South Natick Dam and Silk Mill dam
impoundments. Adding the MDC Satellite plant flow at Medfield
will further raise D.0. by 1-2.5 mg/i within these impound-
ments, but it will remain 1-2.5 mg/i below the 5.0 mg/l level.
Adding the MDC Satellite plant flow below the Cochrane Dam will
raise D.0. about 1.5 mg/i at the discharge point and lower it
about 1.0 mg/i within the Silk Mill Dam impoundment.
“ Recommendations
“1. An MDC satellite plant should not be located on the Charles
River unless:
“a. it can be shown through further data collection and
analysis that those river processes not considered in this
analysis will not increase D.O. deficits during low flow
periods;
“b. it can be shown that treatment plant facilities can be
reliably operated to provide the pollutant removals as are
shown to be required by this analysis to maintain 5.0 mg/i
D.0. in the Charles River at low flow;
“c. the public is willing to bear the economic and environ-
mental impact costs of a satellite plant at the required
location and level of treatment.
“2. Treatment applied to wastewater discharges should not reduce
levels of all pollutants below those occurring in runoff and
other non-point pollution sources of the Charles River unless
it is proven through detailed analysis that further treatment
is cost effective in terms of significantly improving in stream
water quality.
B-17
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“3. The water pollution control planning process for the Charles
River should include, as a possible control for future waste-
water from Milford, CRPCD and Medfield-Millis, the limiting of
sewer service area and wastewater loadings, such that waste—
water loadings to the Charles River are minimized.
“ NOTE :
“These recommendations are based upon the premise that the water
quality standard for dissolved oxygen (5.0 mg/i) has to be met at
the seven-day, ten-year low flow. Therefore, new discharges to the
Charles must be such at D.O. levels of 5.0 mg/i will be met at low
flow and they will be discharging to a river which is meeting
standards at low flow.
I
As a result of the conclusions stated regarding the negative water
quality impacts associated with both the Charles and Neponset satellite
facilities, the site selection process was abandoned for both facilities
prior to the selection of a recommended location for each plant.
Detailed evaluations of flow augmentation impacts of the satellite
facilities were conducted for each river and reported in the Draft EIS.
The conclusions of these evaluations, which also reflect potential water
quality impacts previously described, are summarized as follows:
Charles River
“The future low flow hydrology of the Charles River will be influ-
enced by a number of factors not previously considered. The most
significant of these is the presence of point source discharges
upstream of the MDC service area. Dischar e 3 from these sources is
expected 3 tg increase approximately 48.lxlO d (12.7 mgd) - from
19.68x10 in /d (5.2 mgd) in 1973 to 67.76x10 in /d (17.9 mgd) in 2000.
These upstream communities draw groundwater from public wells
scattered throughout the Upper Watershed (see Figure 2.5-13b) and
many private wells. Groundwater withdrawals from wells distant from
the river will adversely influence the Charles only after a signi-
ficant time lag. Conversely, the water will rapidly reach the river
via the sewer systems. The net effect can be considered as augmen-
tation of river flow by pumping groundwater storage. These upstream
sources roughly balance the export volume and the flow situation in
the Charles can be anticipated to remain relatively constant. In
addition, implementation of water conservation methods, reduction in
I/I and more effective management of the Mother Brook diversion are
techniques which can be utilized to ensure low flow problems in the
lower Charles watershed do not develop.
B- 18
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“In summary, it is felt that the benefits of flow augmentation to
the Charles River by an additional point source discharge, are not
sufficient to warrant the degradation in water quality that such a
discharge would cause. Given the option of Harbor discharge, the
risks involved with a Charles River satellite discharge are not
offset by the benefits to be derived.
“While recycling of water within a basin is a worthy objective of a
wastewater management plan, it should not be done at the expense of
water quality considerations. Indeed, recycling is occurring in the
Charles upstream of the study area. As a result of this, water is
conserved during times of drought and wat r 3 quality is frequently
degraded. Adding an additional 120.24x10 m /d (31.77 mgd) point
source to the river does not appear to be environmentally sound.
The expenditure of resources on advanced waste treatment would be
best applied to existing point sources in the river to maximize the
water quality and quantity benefits of their operation. The water
quantity/flow augmentation issue is extremely difficult to project
and is by no means closed. However, it is felt that a system
without satellite plants will best protect the overall environmental
concerns within the study area.”
Neponset River
“The Neponset River is actively regulated for industrial water
supply and this controls its low flow characteristics. In addition,
the only upstream discharges are industrial cooling waters. Sources
of water to make up for export to the Harbor are not readily avail-
able as in the Charles watershed.
“Between 1970 and 2000, export of Nepons t water to Boston Harbor
would increase by approximately 45.42x10 m /d (12 mgd). The loss of
this water is a negative impact associated with non—satellite
alternatives. However, as previously discussed, significant water
quality impacts will be caused by a Neponset discharge. Major water
supply wells lie immediately downstream of the most likely discharge
points, creating public health concerns. The water quality related
impacts are more severe than the water quantity impacts and, there-
fore, an all harbor alternative is preferable.
“The potential to mitigate those impacts through an alternative
augmentation system should be investigated. The active regulation
of the Neponset for industrial water supply could be coordinated
with flow needs such that both are satisfied during drought condi-
tions. In addition, major I/I reductions and water conservation
should be emphasized as methods to mitigate quantity related im-
pacts. Such actions will have greater long term benefits for the
Neponset River Watershed than augmentation with wastewater.”
A comparison of the Recommended Plan which evolved as the result of the
Draft EIS process based on the EMMA Recommended Plan was presented in the
Draft EIS in Section 3.5.9 which summarized the major impacts and costs.
B-19
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This section is reported here in its entirety as it represents an impor-
tant link between the prior Draft and current Supplemental Draft EIS
review process.
“3.5.9 Conclusion [ Draft EIS, 1978]
“With respect to water quality considerations, the non-satellite
system (the Deer Island Plan) is the only system alternative which
will meet water quality standards. This system will not affect
water quality in inland streams and will greatly improve the quality
of the existing effluent discharges. The EMMA Plan will similarly
improve the quality of the harbor discharges and will reduce their
volume somewhat. The EMMA Plan, however, will cause degradation of
water quality in the Charles and Neponset Rivers. A Neponset River
discharge will cause its dissolved oxygen standard to be violated,
while the Charles River discharge will significantly increase the
magnitude of projected water quality violations. The No Action
alternative will result in the continued degradation of harbor
waters. Modified No Action will cause an improvement in ambient
water quality conditions but degradation in the vicinity of the
existing primary discharge will persist. Overall, the Deer Island
Plan is the best of the four system alternatives with respect to
water quality.
“In terms of water quantity, the Deer Island Plan and both “No
Action” alternatives will have a similar effect. That is, they will
result in the export of water from the Charles and Neponset water-
sheds in the form of sewage. For the Charles River watershed, this
loss will be approximately offset by additional point source dis-
charges to river. For the Neponset River, an estimated export
of 45.42x10 m /d (12 mgd) per day has been projected. The EMMA
Plan, since it will result in the discharge of treated effluent to
the rivers, will have a lesser impact on low river flows. In fact,
the EMMA Plan will result in substantially higher dry weather river
flows than have occurred in the past, but at the expense of water
quality.
“The effects of the No Action alternative on the area’s biotic
communities will represent a continuation of present trends. That
is, organisms associated with polluted waters will remain. In-
creased degradation of water quality as a result of increased
pollutant loads will continue to damage the harbor’s flora and fauna
as well as the public’s use of them. Modified No Action will
improve the situation except in the vicinity of the existing primary
outfa].].s. Both the EMMA Plan and the Deer Island Plan will further
improve biotic conditions.
“The EMMA Plan and the Deer Island Plan will further improve biotic
conditions.
B-20
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“The EMMA Plan will require the use of two additional sites for
facilities construction and specifies the filling of Quincy Bay to
expand the Nut Island plant and the filling of Boston Harbor to
expand the Deer Island plant. This is considered to be a major
impact. The Deer Island Plan avoids filling the harbor but requires
the complete use of Deer Island plus a major bay crossing. Also,
additional interceptor relief is required for the Deer Island Plan.
“In terms of construction-related impacts, both the Deer Island Plan
and the EMMA Plan will cause more disturbance than either No Action
alternative. While each of these systems will produce its own set
of characteristic construction impacts, they cannot be easily
separated on this basis in terms of a value judgment.
“As far as air quality characteristics are concerned, the No Action
alternative would result in the least air emissions followed by the
Modified No Action alternative. The Modified No Action alternative
represents an increase in emissions to the ambient air due to the
incineration of the primary sludge, but it would not include the
incineration of the secondary sludge. Comparisons of the emissions
from primary to secondary sludge incineration at the Deer Island
Plan and EMMA Plan sites, indicates the Deer Island Plan would have
less air quality impact. This is based upon the lower quantities of
emissions and the site location of the Deer Island Plan. This
differential is offset, however, by the need to establish a landfill
for disposal of digested sludge under the Deer Island Plan.
“On the basis of the preceding comparison, the best of the four
system alternatives can be selected. The No Action alternative,
while it is economical and impacts upon air quality the least, is
not considered feasible. Existing primary sludge discharges to the
Harbor, poor operation of existing facilities, gross and visible
pollution from the Nut Island facility, and persistent bacterial
contamination of the Harbor render this alternative untenable.
“The modified No Action alternative will improve water quality
conditions and benefit the harbor’s biota in a general sense, but
the gross pollution from the existing primary outfalls and bypasses
will persist. Pollution from sludge discharges will be abated,
however. This plan is significantly less expensive than either the
Deer Island plan or the EMMA plan and will be more favorable in
terms of air quality impacts and primary construction—related
impacts. The alternative is rejected, however, on the basis of
permitting unacceptable water quality conditions to persist.
“The EMMA plan and the Deer Island plan both further improve water
quality conditions in the Harbor. As described previously, these
alternatives vary in terms of their specific impacts, but they can
be separated on the basis of several significant parameters. These
include:
“1. The violation of water quality standards in the Neponset
River and a further deterioration of the Charles under the
EMMA plan.
B-21
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“2. The need for 42 acres of fill in the Harbor under the EMMA
plan.
“3. The need for a major harbor crossing, additional inter-
ceptor relief and drumlin removal under the Deer Island
plan.
“Beside these factors, the other levels of impact are generally
similar with some trade—offs existing between the alternatives.
Costs are approximately equal. While Item #3 above represents
significant impacts, they can be justified in light of the magnitude
of the problem and its solution. Except for drumlin removal, these
effects are short term. Items #1 and #2, however, represent long
term impacts which are considered unacceptable. The solution to a
wastewater management problem should not be resolved by causing
other water quality problems. The loss of 40 acres of the Harbor
likewise represents an irreversible impact which should not be
accepted if there exists any alternative. We therefore, select the
Deer Island Plan as the best of the four system alternatives.”
In its role as Technical Consultant to EPA Region I in the preparation of
the Supplemental Draft EIS, CE Maguire was asked to evaluate the techni-
cal basis which led to the conclusions previously discussed regarding
satellite treatment facilities and to update the evaluations to reflect
additional data, analytical procedures or changes in technology. In this
regard, EIS documents and references from the Draft EIS were reviewed;
meetings were held with EPA, MDC, MDWPC, DEQE, Division of Water Supply
and other pertinent agencies; and data collected in intervening years
(e.g. water quality) was assembled and incorporated into the review
process.
With respect to the Draft EIS itself, the water quality analysis of the
Charles River was found to be the major unresolved issue. This issue is
identified in a package of correspondence between MDC, Metcalf & Eddy,
EPA and MDWPC over the period of 5/18/77 to 7/25/79, culminating in a
letter from Martin Weiss, then Chief Engineer of the MDC to Thomas C.
McMahon, Director of the MDWPC dated 7/25/79. This letter established a
scope of work expected to be conducted by the NDWPC to respond to con-
cerns raised regarding the water quality modeling of the Charles River as
presented by Mr. Ikalainen. With the exception of the water quality
B- 22
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survey carried out by the MDWPC in 1978, no documentation was found to
indicate that the MDWPC responded to Mr. Weiss’ letter or that the MDWPC
has any plans to respond to these items at present. The complete text of
the referenced correspondence is contained in Appendix A.
The other issue left unresolved in the Draft EIS is that of the siting of
the satellite faclities. Although it is pointed out that the issue of
siting was apparently considered moot following the presentation of
findings regarding water quality impacts, it is unclear as to why a
siting decision was preempted at that point in the EIS process.
B-23
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III. DESCRIPTION OF SDEIS SATELLITE OPTIONS
As a result of the joint NEPA/MEPA scoping process for this supplemental
draft EIS, EPA was required to reevaluate the original satellite facili-
ties proposed in the EMMA Study Recommended Plan (MDC, Oct. 1975, #3), as
well as a new satellite facilities proposal submitted by the Quincy
Shores Association incorporating wastewater reclamation/reuse via wet-
lands effluent disposal in critical water supply recharge areas in the
metropolitan area. Both satellite options are described in the following
sections incorporating wastewater flow projections reflecting revisions
generated in the MDC Nut Island Site Option Study (MDC, June 1982, #4);
updated facilities design criterit and costs, and identification of the
benefits projected to be associated with each option.
B3.l. EMMA Study Satellite Facilities Update
Wastewater flow projections for both the Middle Charles and Upper
Neponset 1 satellite facilities were updated using flow projections revised
in the NI-SOS. The revised flow estimates are summarized in Table B5.
Based on these projections, the Middle Charles facility would be designed
to treat 15.27 MGD average flow and 37.13 MGD peak flow in the design
year 2010. The Upper Neponset would be designed based on average and
peak design flows of 9.00 MGD and 22.26 ?IGD, respectively, in the year
2010.
Capital and operation and maintenance costs for the Charles and Neponset
facilities were updated from 1978 (ENR 2654) to 1983 prices based on an
ENR of 4200. As the differences in design flows relative to the overall
size and complexity of each facility are small with respect to the
updated vs. the original flow estimates used as the basis of design in
the draft EIS, no adjustments in costs were made based on the updated
flow projections for each facility. Further, it is important to note
that the costs do not include sludge pumping, sludge processing (e.g.
B- 24
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TABLE B5
REVISED FLOW ESTIMATES - CHARLES & NEPONSET SATELLITE PLANTS
Charles River
Projected Flows
Source: MDC Nut Island Site Options Study, 1982, M&E.
Community
Ave.
1980 1990 2010
Peak Ave. Peak Ave. Peak
Ashland
0.39
1.12
0.55
1.56
0.93
2.49
Framingham
5.72
13.32
6.86
15.97
7.72
18.00
Natick
2.67
6.64
2.98
7.36
3.34
8.19
Southborough
0.00
0.00
0.00
0.00
1.06
2.75
Wellesley
1.73
4.24
1.75
4.28
1.85
4.49
Dover
0.00
0.00
0.00
0.00
0.09
0.32
Hopkinton
0.00
0.00
0.00
0.00
0.22
0.65
Sherborn
0.00
0.00
0.00
0.00
0.06
0.24
Totals
Neponset River
10.51
Ave.
1980
25.32
Peak
12.14 29.17
Projected Flows
15.27
2010
Ave.
37.13
Peak
1990
Ave. Peak
Community
Canton (30%)
Norwood
Sharon
Stoughton
Walpole
0.49
3.03
0.00
0.78
0.92
Totals
5.22
13.18
7.21 18.00
9.00
22.26
1.26
7.35
0.00
2.08
2.47
0.62
4.21
0.00
1.15
1 .23
1.59
10.29
0.00
2.91
3.21
0.79
4.78
0.26
1.62
1.55
1.98
11 .65
0.78
3.92
3.93
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thickening, dewatering), incineration and ash disposal which are pre-
sented as the sludge processing and disposal operations in the draft EIS.
(Draft EIS, pg. 3-232, “The sludge produced at the satellite plants would
undergo incineration at each plant.”) Updated costs are presented in
Table B6. It was further determined that the level and type of treatment
projected to be provided at each facility should remain as proposed in
the EMMA Recommended Plan and as described in the draft EIS. Proposed
effluent limits of 5.0 mg/i CBOD 5 and 1.0 mg/i NH 3 - N at the design year
flows can be reliably expected to be achieved via the proposed treatment
facility process configuration which represents current state-of-the-art
in wastewater treatment technology.
As previously stated, from both the EMMA and Draft LIS documents, the
major benefits anticipated to be derived as the result of the imple-
mentation of satellite facilities are summarized as follows:
1. Satellite facilities would maintain water in its basin of
origin and thus provide reliable sources of low-flow augmenta-
tion.
2. Satellite facilities would reduce treatment capacity and size
requirements at Nut Island.
3. Construction of satellite facilities would result in cost
savings for interceptor relief in the southern MSD.
4. Satellite facilities would provide additional opportunities for
feasibility on sludge treatment and management.
B3.2. Quincy Shores Association (QSA) Wetlands Disposal Option
A detailed proposal recommending the implementation of three satellite
facilities in three different river basins in the south NSD was prepared
and submitted to EPA for evaluation in this SDEIS during the NEPA/MEPA
scoping process. (See the main report for a further discussion of the
scoping process.)
B-26
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TABLE B6
COST UPDATE - EMMA SATELLITE FACILITIES
Annuat 2 9&rl Total f ual
(1) Capital Cogt’ / Cost 6 Cost 6
Satellite Amount x 10 ) ( $ x 10 ) ( 5 x 10 )
Middle Charles 70.5 5.57 12.82
Upper Neponset 61.3 4.74 11.04
1 Cost of facilities based on wastewater treatment plant with diffused
, 2 air aeration and post aeration.
‘Capital and O&N costs updated from 1979 to present day based on ENR =
(3 $4 2OO.
‘ ‘Total annual costs computed based on 8-1/8% over 20 years Cct r =
0.1028).
B-27
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The specific facilities recommended in this proposal are shown in the
attached Figure B2 and are presented as described below.
B3.2.1 The Weymouth Fore River Basin
A regional advanced wastewater treatment plant is proposed to be built on
the 42” ? C Braintree-Randoiph Extension Sewer on Section 128A downstream
of the Braintree Cranberry Brook trunk sewer. This plant could have an
8—10 million gallon per day (mgd) capacity. It would discharge into the
Broad Meadow wetlands along the Cochato River where it could replenish
critical water supply resources for the Towns of Braintree, Randolph, and
Holbrook.
A plant located at that point could remove the following flows from the
Nut Island plant:
1990 2010
Municipality Peak Peak*
Braintree (15%) 0.42 0.97 0.44 1.01
Holbrook 0.14 0.46 0.38 1.12
Randolph 1.83 4.43 1.92 4.62
2.39 mgd 5.86 mgd 2.74 mgd 6.75 ingd
*A].1 flow values from June, 1982, Nut Island Wastewater Treatment Plant
Facilities Planning Project (NI-SOS).
Braintree, Holbrook, and Randolph all share a common surface water
supply, Great Pond Reservoir and Richardi Reservoir. Surface waters of
the Cochato and Farm Rivers are diverted during peak flow periods to
supplement the reservoirs. There have been recent water shortages and
the dry-year safe yield of this system is marginal to meet the current
demands. All three communities are included in the current MDC water
study as potential future connections to the MDC water system.
B-28
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B3.2.2 The Neponset River Basin
A regional advanced wastewater treatment plant is proposed to be built on
the 54” MDC New Neponset Valley Sewer on Section 113, downstream of
Westwood, Walpole, and Stoughton extension sewers. This plant could have
a 35 mgd capacity. It would discharge through a dispersion pipe laid
along 1-95 to the extensive Fowl Meadows, which is underlain by high and
medium yield aquifers, which are critical to the area’s water supplies.
Such a plant could intercept the MDC New Neponset Valley Sewer at Section
No. 113. That sewer is a brick interceptor 54” x 60”. Again, using
Facilities Planning Report Data, it could recharge flows as follows:
1990 2010
Municipality Peak Average Peak
Canton 2.08 5.30 2.62 6.60
Norwood 4.21 10.29 4.78 11.65
Sharon 0.00 0.00 0.26 0.78
Stoughton 1.15 2.91 1.62 3.92
Walpole 1.23 3.21 1.55 3.93
Westwood 0.54 1.49 0.82 2.16
9.21 mgd 23.20 mgd 11.65 mgd 29.04 mgd
Allowing for infiltration, as was done in the Facilities Planning Study,
the plant would have an average flow design capacity of approximately 35
mgd. If such a daily flow were to be recharged in the Fowl Meadow, say
along Route 95 upstream of the proposed plant site, it would provide a
dramatic increase in water resources in the Towns of Canton, Norwood,
Westwood, and Dedham. The major well fields of the Dedham Water Company
are directly downstream of the suggested plant location. The Dedham
Water Company has had shortage in the past and has recently lost some
capacity due to contamination; they are actively attempting to join the
MDC water system.
B- 30
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B3.2.3 The Charles River Basin
A regional advanced wastewater treatment plant is proposed to be built by
intercepting the Wellesley Extension Sewer and the Wellesley Relief Sewer
at the Easterly Connection Chamber, and pumping to the plant located at
the edge of the nearby City of Boston landfill on Gardner Street in West
Roxbury. It would discharge to the Cow Island Meadows along the railroad
and Route 128, where they are underlain by high and medium yield aquifers
serving water supplies in Dedham, Needham, Wellesley, and Weston. Based
on Facilities Planning Report Data, it could recharge:
The plant size would have an average daily capacity of approximately 50
mgd. Such a plant could recharge water to aquifers containing wells of
the Dedham Water Company, and the Towns of Needham, Wellesley, and
Weston. Also, the recharge could take place in part upstream of the MDC
diversion structure on Mother Brook. This would provide much greater
dry-weather stream flows for management of water quality in the lower
reaches of the Charles and Neponset Rivers.
The following excerpt from the QSA proposal highlights the benefits
perceived by the authors to be associated with the facilities described
above.
1990
2010
Municipality
Average
0.55
Peak
1.56
Average
0.93
Peak
2.49
Ashland
Dover
0.00
0.00
0.09
0.32
Framingham
Hopkinton
Natick
6.86
0.00
2.98
15.97
0.00
7.36
7.72
0.22
3.34
18.00
0.65
8.19
Needham
2.17
5.30
2.24
5.41
Sherborn
0.00
0.00
0.06
0.24
Southborough
Wellesley
0.00
1.75
0.00
4.28
1.06
1.85
2.75
4.49
14.31
mgd
34.47 mgd 17.51
mgd
42.54 mgd
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These facilities could:
• Reduce the size of the presently planned wastewater and sludge
treatment facilities at Deer and Nut Islands;
• Allow for future growth and expansion in the western suburbs of
the !IDC district;
• Provide economic reduction in the I/I and CSO problems in the
Harbor area by flow reduction in major conduits; and
• Enhance recreation and water supply resources in the Weymouth
Fore River, Neponset River, and Charles River Basin.
The recommendation that the satellite facilities, recommended in the QSA
proposal, utilize natural wetlands for effluent renovation and ground-
water recharge to existing and potential public water supply aquifers
required a multi-level evaluation of effluent discharge criteria in order
to develop a basis for conceptual design and costing of the proposed
facilities. A review of available literature on wetlands discharge -
wetlands treatment capabilities was performed to define suitable hydrau-
lic, organic, and nutrient loading criteria for wetlands to serve as a
basis for determining wetland acreage requirements, for various levels of
treatment to be provided at the proposed satellite facilities. A com-
plete bibliography of literature reviewed in this regard is included in
Attachment B.
Based on this literature review, it was decided to employ the organic and
phosphorous loading criteria used to develop wetland area requirements in
a feasibility study of wetland disposal of wastewater treatment plant
effluent conducted by IEP, Inc., under a research grant for the MDWPC
(Ref. #12). This report employed a BOD loading rate of two gallons per
day per square foot (2 gpd/sf) which is based on a loading rate equi-
valent to a dual media filter and a phosphorus loading rate of 1.5 pounds
per acre per day • . • “based both on preliminary review of the litera-
ture (108) and the desire not to hydraulically overload the wetland,
B- 32
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resulting in adverse effects to ecological and hydrogeological environ-
ment.” Applying these criteria to the proposed facilities, assuming
effluent BOD and phosphorus loadings for both secondary (conventional
activated sludge) and advanced wastewater treatment processes, yield the
wetland acreage requirements presented in Table B7.
In recognition of the proposed discharge locations relative to ground-
water recharge areas in or near existing public water supply well fields,
the Massachusetts DEQE, Divisions of Water Supply and Water Pollution
Control, were contacted to ascertain effluent limits and discharge
requirements in light of revised regulations promulgated by DEQE in late
1983. The response from the Division of Water Pollution Control, dated
December 29, 1983, which is included in its entirety in Appendix C,
included the following remarks:
“On October 15, 1983, the Division of Water Pollution Control
promulgated a set of comprehensive water pollution control regula-
tions (Title 314 of the Code of Massachusetts Regulations) which
included detailed groundwater quality standards. These standards
define groundwater into these classes (1, 2, and 3); Class 1 being
defined as:
“fresh ground waters found in the saturated zone of unconsoli-
dated deposits or consolidated rock and bed rock and are
designated as a source of potable water supply.”
“Since all three proposed discharges will be tributary to ground-
water currently being utilized as public water supplies (Class 1),
all discharges to said groundwater will be required to meet very
strict discharge limits; see Attachment 1 (in Appendix C.1).
“The discharge limits would basically require that the effluent
entering onto the wetland meet or exceed the Primary or Secondary
Drinking Water Parameters; see Attachment 2 (in Appendix C.1). In
addition, the Division is concerned with the periodic “pass
through” of materials such as oil, heavy metals, solvents,
phenols, and other highly toxic or contaminating materials
which are not substantially removed with conventional waste-
water treatment processes and which could cause severe impacts
upon these aquifers.
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TABLE B7
WETLAND ACREAGE REQUIREMENTS - QSA SATELLITE FACLITIES PROPOSAL
Wetland Area Phosphorus Wetland Area Phosphorus Wetland Area
Flow Required(1) Load-CAS(2) Required Load-AWT(3) Required
( MGD) ( Acres) ( #/Day) ( Acres) ( 11/Day) ( Acres)
Charles River
Average Daily Design Flow 20.0 230 2002.0 1335 167.0 iii
Peak Design Flow 50.0 574 5004.0 3336 417.0 278
Neponset River
Average Daily Design Flow 12.0 138 1200.0 800 101.0 67
Peak Design Flow 35.0 402 3502.0 2335 292.0 195
Weymouth Fore River
Average Daily Flow 3.0 34 3000.0 200 25.0 17
Peak Design Flow 10.0 115 1000.0 667 83.0 55
(1)Thls acreage represents the minimum requirements based on hydraulic loadings of wastewater
effluent. The acreage shown under AWT would, therefore, have to be adjusted to be consistent
with this minimum acreage shown.
2 CAS - Phosphorus loadings based on assumed effluent phosphorus concentration of 12.0 mg/i for
typical conventional activated sludge treatment facilities in New England.
3 AWT - Phosphorus loadings based on assumed effluent phosphorus concentration of 1.0 mg/i from
advanced waste treatment facility.
B-34
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“ The Division is of the opinion that proper safeguards necessary
to continuously meet Class 1 effluent limitations and to protect
these valuable public water supplies cannot be provided. There-
fore, the Division strongly discourages the continued review of
such subregional facilities as proposed by the Quincy Shore
Associates. ” [ Emphasis added.]
Similar conclusions and recommendations were stated in a memorandum from
the DEQE Division of Water Supply to the DWPC, dated December 16, 1983,
including the following:
“Aside from the problems associated with determining the
assimilative capacity of wetlands for pollutants, this
proposal does not address other potential water quality
problems. For instance, the proposal does not address the
fact that very little control exists over the nature and
quality of sewage. Presently, the regulatory manpower does
not exist for monitoring illegal or haphazard industrial
waste disposal. Many industrial contaminants cannot be
detected, let alone treated, in standard wastewater treat-
ment facilities. As a result, it is very likely that
discharges from the proposed ‘satellite’ plants would
ultimately result in the degradation of existing water
quality in the receiving wetlands/aquifer. All things
considered, water quality degradation is likely to occur
either over the short term through problems associated with
seasonal flooding/freezing of the wetland, and/or the
undetected discharge of a hazardous substance or over the
long term by the gradual saturation of the assimilative
capacity of the wetland.
“Because of these uncertainties and the problems that may
ensue, the DWS must conclude that the Citizens Plan proposal
for wastewater discharge into wetlands is an unacceptable
risk for potentially degrading these vital existing drinking
water supplies.”
The complete text of the DWS memorandum is included in Appendix C. There
is also included in Appendix C a further letter from the Massachusetts
Department of Environmental Quality Engineering (DEQE, April 23, 1984)
which reviews the above issues and restates its support for the con-
clusions made.
Although the statements of the DWPC and DWS strongly suggest that the
facilities proposal of QSA not be implemented, a preliminary conceptual
facilities design was outlined for the purpose of providing a basis for
cost comparisons between the two satellite options. The conceptual
B-3 5
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design shown on Figure B3 incorporates advanced wastewater treatment
operations, including primary settling phosphorus removal via chemical
additions, conventional activated sludge secondary treatment, nitrifica-
tion—denitrification and final settling advanced waste treatment pro-
cessing. Treatment beyond AWT levels theoretically leading to wastewater
reclamation includes mixed media filtration, carbon absorption, chlorina-
tion-dechlorination and post-aeration prior to discharge. Grit, sludge
and scum processing and disposal operations are also shown on the sche-
matic.
Costs for each facility were developed using costs per gallon of waste-
water as derived from the updated cost estimates prepared for the EMMA
satellites. Capital costs were escalated by 25 percent, and O&N costs
were escalated by 40 percent to account for the increased level of
treatment provided. These increases are not considered to include sludge
processing and disposal. Generalized costs for each of these facilities
are summarized in Table B8. While it is recognized that no accuracy can
be assigned to these cost estimates due to their conceptual nature, it is
felt that the estimates nonetheless reasonably reflect the level of
treatment provided under the conditions stated above.
TABLE B8
COST SUMMARY: QSA WETLANDS DISPOSAL SATELLITE FACILITIES
Total
Annua4 d
Design Capital gost Annual 0 M Cost’ 6 ’
Flow ( $x lO) ( $xlO) ( $xlO )
Charles River
Wetlands Satellite 50 NGD 115.8 11.14 23.04
Neponset River
Wetlands Satellite 35 MGD 81.1 7.80 16.14
Weymouth Fore River
Wetlands Satellite 10 MGD 30.6 2.65 5.80
(1)Total Annual Costs based on 8-1/8 percent over 20 years (CRF = 0.1028).
Costs are ±25%.
B-36
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PAGE NOT
AVAILABLE
DIGITALLY
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B3.3. Relationship of SDEIS Satellite Options With On-Going Facilities
Planning in the Southern MSD
As a result of the decision to delete the EMMA recommended satellite
facilities from further consideration, based on the conclusions of the
draft EIS, facilities planning was initiated for relief of critically
surcharged interceptors in the southern MSD including the following:
Wellesley Extension Sewer (WES)
Framingham Extension Sewer (FES)
New Neponset Valley Sewer (NNVS)
Braintree-Weyinouth Extension Sewer (BWES)
In addition to the interceptor relief plans, a major infiltration/inflow
(I/I) analysis of the south MSD was conducted by Fay, Spofford and
Thorndyke. I/I studies were also prepared for the MDC in the communities
of Ashland, Natick, and Framingham, and for the area tributary to the
proposed Weymouth Fore River Siphon. An evaluation of the hydraulic
capacity of the High Level Sewer was conducted in conjunction with the
Nut Island Site Options Study which incorporated the I/I reports men-
tioned above, in addition to revised wastewater flow projections pre-
viously discussed.
Additional studies and reports which must be taken into account include
the preliminary report on I/I removal submitted to Professor Charles N.
Haar, Court Appointed Master in the suit brought by the City of Quincy
vs. the MDC, by the Executive Office of Environmental Affairs in response
to Procedural Order, Item No. 5, entitled “Banking/Trading and Greater
Than 2 for 1 Program.” An overview of MSD I/I is currently being con-
ducted by Camp, Dresser and McXee for the MDW’PC.
Consideration of these reports in the evaluation of satellite facilities
is of considerable importance relative to the following issues:
Implementation of time frame relative to on-going impacts of
presently surcharged sewers.
B-38
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Impacts of uncertainties in present I/I studies on flow pro-
jections, design capacity evaluations for interceptors and
treatment facilities, and the projected or assumed reduction in
the required capacity of the harbor treatment facilities.
Based on the current state of completion of Step 1 and Step 2 facilities
planning for the major interceptor relief projects (e.g. WES, FES, NNVS,
and BWES), it would appear reasonable to project that construction of
recommended relief components can be completed within the next three to
five years, contingent upon available levels of State and Federal fund-
ing. It is estimated that the time frame from Step 1 facilities plan-
ning, to start up of operation for any of the satellite advanced waste
treatment facilities proposed, will range from ten to twelve years. If
the elimination of overflows of untreated wastewater, due to surcharging
conditions and the water quality degradation presumed to result from such
overflows, is to be considered a primary objective of the wastewater
management programs of MDC, DWPC, and EPA being evaluated in this SDEIS,
then it would appear prudent at this time to recommend that the relief
projects proceed to construction regardless of a decision to reject or to
proceed with the proposed satellite facilities.
The issue of the relationship between projected reductions in the re-
quired capacity of harbor treatment facilities as a result of satellite
facilities implementation, and the effects of estimated and measured
quantities of I/I on the capacity of the sewerage and treatment facili-
ties has not yet been resolved. Several factors have contributed to the
lack of consensus or understanding surrounding this issue.
Both revised wastewater flow projections and the evaluation of the
capacity of the High Level Sewer (HLS) presented in the Nut Island Site
Options Study (SOS) state that the results of the I/I studies in the
south MSD system prepared for the MDC and community-specific evaluations
were taken into account in their development and analysis. Flow esti-
mates project a peak flow of 305 MGD in the year 2010 design year.
Hydraulic evaluations of the HLS under previous conditions conclude that
B-39
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the HLS can adequately handle up to 310 MGD. Flow measurements taken by
FST and reported in their I/I study included values up to 420 MGD.
The conditions under which the extreme of 420 MGD were measured are not
clearly defined. It is important to note that, although the capacity of
the I lLS is 310 MGD, the available pumping capacity at Nut Island is only
280 MGD. This constriction, in combination with extreme high tide
conditions (e.g. spring high tides), or other factors such as extreme
precipitation and/or seasonal high groundwater, could produce a “stack-
ing” effect in the HLS which may have introduced large errors in flow
measurement in the system. Further, the manner and extent to which the
I/I data was incorporated into the revised flow estimates developed in
the SOS is not clear. As a result of a meeting held at DWPC, Metcalf &
Eddy has agreed to provide more detailed explanation of the incorporation
of the I/I report into the flow projections.
The issues raised point to the need for additional information, including
systematic flow monitoring at several locations throughout the south MSD.
Also, it would appear necessary to remove the constriction imposed by the
pumping capacity at Nut Island by increasing the pumping capacity to
equal the design hydraulic capacity of the IlLS. This, in turn, suggests
that the peak design capacity of the treatment facility serving the south
MSD should also be equal to the capacity of the IlLS as recommended in the
SOS. Although the implementation of satellite facilities would theoreti-
cally reduce flows to the harbor facilities equal to the design flows of
these satellite plants, it does not appear to constitute a safe, reliable
basis for reducing the design capacity of the harbor treatment facilities
by an equivalent amount. This, in turn, suggests that the implementation
of satellite faclities should be delayed until it can be clearly and
reliably be demonstrated that flows in the south MSD exceed the capacity
of the I lLS and treatment system, and that these excess flows cannot
otherwise be economically removed from the system.
B-40
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IV. EVALUATION OF SATELLITE OPTIONS
Both of the satellite options were evaluated with respect to the major
environmental issues and perceived benefits which have been identified
for both options. These include flow augmentation, water quality and
water supply recharge. Issues and impacts relative to siting of any of
the satellite facilities have not been addressed at this stage of the EIS
process, as the satellite issue has not progressed beyond the level of a
conceptual component of the wastewater management program of the MDC.
B4.1. EMMA Satellite Evaluation
B4.l.1. Flow Augmentation :
A detailed analysis of water quantity impacts of the EMMA satellite
facilities was presented in Section 3.5.1 of the Draft EIS. The analysis
concluded that the satellite facilities would provide significant stream-
flow augmentation to the water resources of both the Charles and Neponset
Rivers. However, the analysis also evaluated the future low flow condi-
tions of the Charles River without the additional future flows of the
proposed middle Charles satellite facility. This analysis incorporated
consideration of two major factors, which had not previously been con-
sidered with respect to flow augmentation, which are the net water
quantity exported from the Charles River Basin to Boston Harbor, relative
to the projected flow of the satellite plant and the impacts of projected
increases in flow volumes from existing wastewater treatment facilities
on streamflow during low flow periods.
As reported in the Draft EIS, only 13.0 MGD of the projected design flow
of the middle Charles satellite plant originates within the Charles River
Basin. The remainder originates in the Sudbury River Watershed, or is
supplied to the contributing communities from the MDC water supply system
originating in the Quabbin Reservoir. The Draft EIS analysis further
indicates that the projected increases in discharge volumes from existing
wastewater treatment plants in the Charles River Basin, totalling ap-
B-41
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proximately 12.7 MGD, nearly equals the net projected exported flow of
13.0 MGD, thereby offsetting the effect of exporting that flow to Boston
Harbor. Although we concur with the analyses with respect to projected
streamfiow conditions without the implementation of the Middle Charles
Facility, it must still be recognized that the addition of this satellite
plant will result in substantially improved streamflow conditions.
Questions raised in the Draft EIS, with regard to water quality condi-
tions and potential impacts on downstream water supply resources, are
discussed in subsequent sections of this report.
The Draft EIS acknowledges the potential streamflow benefit of the upper
Neponset satellite facility on the Neponset River, but concludes that
significant negative water quality impacts offset any potential benefits
to streamflow and water supply resources. Based on our review of the
water quality assessment of the Neponset River, we concur with the
conclusions of the Draft EIS.
B4.1.2 Water Quality :
The assessment of water quality impacts of the EMMA recommended satellite
facilities on the Charles and Neponset Rivers Consists of a review and
analysis of previous modeling conducted for the 1978 Draft EIS, and a
review of water quality data collected during intervening years for both
rivers.
As previously described, an extensive water quality modeling effort was
undertaken by EPA (Ref. #14) to assess the impacts of the Middle Charles
satellite facility discharge on the dissolved oxygen (D.0) resources of
the Charles River under the prescribed 7Q10 flow conditions. A low flow
version of the MDWPC from surveys was conducted in 1973 by Erdmann et al.
The low flow model was then used to evaluate the dissolved oxygen res-
ponse of the river to the projected waste flows, and loads from the
Middle Charles satellite and other wastewater treatment facilities
projected to be discharging to the Charles River in the design year 2000.
The effects of the discharge from the satellite facility were also
examined with the discharge occurring at different locations in the
B-42
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Middle Charles. The conclusions drawn from these modeling analyses were
presented in Section II. B2.3 of this report.
In general, although the modeling indicates that the Class B water
quality criteria for dissolved oxygen of 5.0 mg/I may be violated over
some river segments, overall dissolved oxygen conditions would be im-
proved at specific critical locations under certain specified conditions
as a result of the discharge of a satellite facility as compared to
project conditions it. The facility would be required to provide
advanced levels of waste treatment bordering on the limits of reliable
technology. While it can be argued that the proposed satellite facility
will not result in attainment of Class B, D.O. levels at projected low
flow conditions, the analysis suggests that the proposed facility could
represent a potential benefit to the Charles River, as D.O. levels were
observed to increase under certain conditions with the addition of the
satellite facility as opposed to without it. The modeling suggests that
non-attainment conditions are beyond the ability of point source treat-
ment measures alone to achieve. The analysis provides limited evaluation
of the issue of other residual pollutants from a satellite effluent
discharge.
The concerns raised by Metcalf & Eddy and the MDC in the correspondence
found in Attachment A, and the responses of EPA staff to these concerns,
were reviewed with respect to model formulation, coefficient selection-
computation, use of data within the model framework, and the limits
within which the available information was employed within the Stream
model to project impacts of conditions for which no data is/was avail-
able. Model formulations were reviewed with respect to the model des-
cription contained in the “STREAII 7A USER’S MANUAL,” prepared for the
MDWPC in 1978 by Resource Analysis, Inc.
No major changes in model formulations were found between the version of
the Stream model employed by Erdmann and Ikalainen, and those described
in the 1978 User’s Manual. Based on our review of the work that was done
B-43
-------
by EPA and reported in the Draft EIS, we conclude that the modeling
reasonably and adequately reflects proper utilization of the available
data within the model framework and within the range of sensitivity and
variability tested.
Other issues were raised in the text of the Draft EIS which played a
substantial role in reaching the conclusion stated on page 3-155 that:
“The implementation of a satellite plant discharging to the Charles River
is not recommended.” These issues relate to the ability of the unit
treatment processes envisioned to provide the advanced levels of treat-
ment required to result in improved D.C. conditions reliably and consis-
tently, given the variability of influent flow and pollutant loading
conditions, and the limited degree of control obtainable over these
conditions. These are still valid concerns, although there presently
exists a significantly increased amount of experience in the operationof
advanced waste treatment facilities than was available in 1978.
Another issue, with respect to the water quality modeling raised by both
EPA and MDC/M&E, concerned the parameters and in-stream processes not
accounted for in the Stream Model. Phosphorus is a particular parameter
of concern, in this regard, due to its potential impact on algae and
aquatic weed production, which in turn would be expected to impact on the
magnitude and severity of D.O. variability. A satellite facility even
providing phosphorus removal to maintain effluent phosphorus concentra-
tions on the order of 1.0 mg/i represents a significant increase in
phosphorus loading from point sources in the Charles River. Incorporat-
ing these concerns with the considerations offered by the water quality
modeling (i.e., that under certain conditions, some degree of benefit may
be derived), leads us to conclude that a satellite treatment facility
discharging to the Middle Charles River will be of limited, if any,
benefit to water quality in the Charles River. Based on available data,
however, it is not expected that such a discharge will, in or of itself,
contribute noticeably to degradation of water quality conditions beyond
present conditions.
B-44
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A summary of water quality data from DWPC surveys in 1973 and 1978 is
presented in Table B9. Partial surveys of the Upper Charles (above the
South Natick Dam) were also conducted in 1980 and 1981. The more recent
surveys (1980 and 1981) reflect major upgrading of municipal treatment
facilities, including the construction of the Charles River Pollution
Control District AWT Facility serving the Franklin-Medway area and the
Millis—Medfield facilities. Average DO levels for all but one survey
period from all survey years are shown in Figure B4. Note the consistent
improvement in DO recovery downstream of River Mile (RN) 60, with suc-
cessive years of operation of recently constructed facilities. Note also
the generally unchanged conditions upstream of RN 60, reflecting the con-
tinuing problems observed in the Milford area with respect to the muni-
cipal sever and treatment systems, in addition to nonpoint sources in the
head water areas of the river.
Comparisons between the six survey periods (June 1973; September 1973;
June 1978; July 1978; July 1980, and June 1981) on a parametric basis are
of limited value based on reported differences in stream flow conditions,
water, and air temperatures, rainfall and other climatic factors prior to
and during each survey period. Generally, although average and minimum
D.O. values have increased over the period covered by the data record,
violations of the Class B criteria still occur. Violations of the Class
B bacterial criteria of 200 colonies/100 m l continue to occur. Although
the fecal coliform data for the June, 1981 survey period show a signi-
ficant improvement over the portion of the river surveyed, the limited
scope of the survey precludes assessment of improvement in downstream
reaches. Nutrient loadings, particularly phosphorus, are of potential
B-45
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TABLE B9
CHARLES RIVER WATER QUALITY SURVEY DATA SUMMARY — 1973/1978
6/73 9/73 6/78 7/78 6/73 9/73 6/78
7/78 6/73 9/73
6/78 7/78 6/73 9/73 6/78 7/78 6/73
9/73 6/78 7/78
Gauge Station
FLOW SUMMARIES DURING SURVEY PERIODS (FLOWS IN CPS)
7/78
USGS Gauge, Dover
USGS Gauge, Wellesley
USGS Gauge, Waltham
149.2
134.0
170.8
105.2 199.8
111.2 198.2
141.6 257.4
73.3
79.4
98.6
Dissolved
Oxygen (mg/fl
Temperature
(°F)
BOD
(mg l)
NH
-N
(m /1)
NO
-N
( g/l)
CHO1
8.3
7.5
7.4
7.1
71.3
77.0
64
77
1.7
3.6
5.1
1.9
0.07
0.04
0.01
0.04
0.2
0.5
0.2
0.1
CR02
3.9
4.7
8.0
7.9
74.2
78.0
67
77
3.1
1.6
4.9
3.1
0.29
0.09
0.02
0.04
0.1
0.0
0.1
0.0
CHO3
4.4
4.2
6.1
4.9
70.8
75.0
64
73
6.3
2.7
4.8
2.4
0.20
0.32
0.03
0.10
0.3
0.3
0.4
0.3
CHO4
3.9
1.1
4.6
1.2
70.7
75.0
63
73
21.6
12.3
7.9
5.4
3.85
4.45
3.6
4.9
2.1
2.4
1.6
2.1
CHO5
1.8
1.4
3.0
0.9
71.0
76.0
63
73
4.8
7.8
5.4
4.6
3.45
6.2
3.6
4.3
1.4
2.0
1.4
0.6
CR06
11.5
4.5
8.7
5.3
74.7
80.0
68
78
9.5
4.9
6.4
29.5
2.85
1.01
1.6
5.6
1.0
1.4
0.8
0.6
CHO7
3.3
1.9
5.3
2.6
70.8
76.0
66
75
5.0
4.9
5.1
6.6
2.00
0.92
0.88
0.89
1.1
0.7
1.4
1.2
CR078
---
---
7.5
5.2
--—
---
66
78
---
---
3.1
3.3
---
---
0.04
0.19
---
---
1.1
0.5
CHO7C
---
---
7.2
5.8
---
---
65
74
---
---
1.9
2.5
-——
---
0.02
0.10
---
---
1.1
0.6
CR08
6.7
5.5
7.4
6.3
71.1
77.0
64
75
2.6
1.8
2.7
1.6
0.13
0.13
0.04
0.08
0.4
0.7
0.8
0.5
CRO8A
7.3
5.5
6.7
6.0
71.9
77.0
64
79
4.4
2.4
2.5
2.4
0.13
0.36
0.10
0.38
0.6
0.4
0.7
0.8
CHO9
6.0
4.3
7.2
5.6
71.6
77.0
64
74
3.4
3.2
2.4
1.6
0.52
0.58
0.11
0.34
0.7
1.1
0.8
0.8
CR10
7.3
6.7
8.0
6.7
71.8
77.0
64
76
5.3
3.4
2.4 -
2.0
0.18
0.10
0.06
0.17
1.1
1.2
0.8
1.0
CHI1
7.0
7.4
7.2
10.7
73.7
79.0
65
70
4.0
3.6
5.0
3.6
0.07
0.25
0.03
0.01
0.8
0.5
0.6
0.0
CR12
6.4
5.1
7.1
9.0
71.0
74.0
65
75
2.6
2.1
4.3
4.5
0.06
0.20
0.02
0.00
0.7
0.5
0.6
0.0
CR13
6.1
4.8
5.3
8.4
71.3
74.0
66
76
2.3
2.8
2.2
6.3
0.09
0.17
0.02
0.01
0.6
0.5
0.5
0.0
CH I4
4.9
4.4
4.9
5.9
71.8
74.0
66
77
2.3
2.4
2.7
5.1
0.14
0.27
0.03
0.05
0.6
0.4
0.5
0.1
CH I5
5.1
4.7
5.0
7.9
72.1
76.0
66
77
3.3
6.5
2.4
6.3
0.14
0.24
0.04
0.01
0.5
0.3
0.5
0.0
CR16
6.2
5.7
5.4
8.1
72.4
76.0
67
77
4.1
6.0
2.5
5.5
0.07
0.16
0.04
0.01
0.5
0.3
0.6
0.0
CR17
7.0
5.9
6.5
7.6
72.7
76.0
68
74
5.4
4.6
2.4
4.0
0.06
0.14
0.02
0.05
0.5
0.1
0.4
0.0
CHI7A
---
---
6.4
7.1
---
---
67
78
---
---
2.1
4.0
---
---
0:03
0.08
---
---
0.4
0.0
CR18
7.2
7.0
7.4
6.6
72.4
76.0
67
77
4.1
4.6
2.7
4.5
0.09
0.12
0.02
0.12
0.4
0.1
0.4
0.1
CR19
6.9
7.0
6.9
7.3
72.6
76.0
67
77
4.2
6.0
2.7
3.9
0.07
0.06
0.02
0.12
0.4
0.0
0.4
0.0
CR20
7.3
8.4
8.4
12.3
72.8
76.0
68
80
4.8
6.3
3.1
6.6
0.25
0.05
0.05
0.59
0.4
0.0
0.4
0.1
CH21
6.9
7.8
8.3
11.2
72.2
76.0
68
79
6.6
8.0
3.9
7.2
0.25
0.05
0.02
0.30
0.4
0.0
0.4
0.1
CR22
7.4
6.8
8.3
7.8
72.6
75.0
67
78
4.4
7.1
4.0
6.1
0.28
0.07
0.04
0.38
0.4
0.1
0.4
0.2
CH22A
---
---
8.2
8.0
---
-—-
67
77
---
---
3.9
6.3
-—-
--—
0.02
0.34
--—
---
0.4
0.2
CH23
7.1
7.8
8.3
10.2
73.5
76.0
67
79
5.9
7.2
4.0
7.0
0.24
0.06
0.01
0.09
0.4
0.0
0.3
0.2
CR24
7.4
6.6
7.8
8.0
72.1
74.0
67
73
4.1
5.1
3.7
5.8
0.27
0.08
0.01
0.08
0.4
0.1
0.3
0.3
6/73 9/73 6/78
-------
CHARLES RIVER WATER QUALITY SURVEY DATA SUMMARY - 1973/1978
Total Kjeldahl Nitrogen
(mg/i)
6/73 9/73 6/78 7/78
Total Phosphorus
(mg/i)
6/73 9/73 6/78 7/78
Suspended Solids
(mg/i)
6/73 9/73 6178 7/78
Total Solids
(mg/i)
Turbidity
(NTu)
6/73 9/73 6/78 7/78 6/73 9/73 6/78 7/78
CR01
---
---
0.29
0.97
0.03
0.02
0.04
0.73
1.0
18 5.5
1.0
---
---
125
68
---
---
1.3
1.3
0102
---
---
0.34
1.2
0.06
0.04
0.05
1.0
1.0
19 1.8
1.0
---
—--
116
137
---
—--
2.0
1.9
CR03
---
---
0.72
1.4
0.17
0.21
0.09
1.6
5
34 5.0
6.0
---
—--
179
183
---
—-—
2.3
3.9
CR04
---
---
4.3
5.8
3.55
4.60
2.1
4.3
4
22 16
1.5
---
—--
241
256
---
--—
3.0
3.9
CR05
---
---
4.3
4.4
3.10
4.00
1.3
4.2
1.0
37 5.8
5.2
---
—--
271
220
---
---
2.9
3.6
CR06
---
---
2.7
6.6
2.90
3.15
0.92
4.2
5
25 12
51
-—-
—--
216
305
-—-
---
2.5
5.7
CR07
---
---
1.8
2.9
1.75
1.85
0.84
2.2
3
27 6.0
17
---
—--
190
202
-—-
-—-
2.6
4.3
CHO7B
---
---
1.4
1.2
---
-—-
0.60
1.5
---
--- 7.0
6.2
---
---
169
186
---
—--
2.4
3.5
CHO7C
---
---
0.72
1.4
---
-—-
0.57
1.2
---
-—- 6.0
4.2
---
---
169
262
-—-
—--
1.7
3.6
CR08
---
---
0.84
1.5
0.75
0.90
0.47
1.0
1.0
19 5.2
0.5
---
---
170
157
---
——-
2.0
3.1
CHO8A
---
---
0.45
1.6
0.48
0.35
0.59
1.0
6
32 6.0
2.2
---
---
165
172
---
---
2.4
3.1
CR09
---
---
0.89
1.4
0.93
0.93
0.68
1.0
1.0
17 4.5
2.5
---
---
170
170
---
---
2.4
2.7
CR10
---
---
0.84
1.1
0.85
0.95
0.54
0.94
4
31 8.2
3.2
---
---
174
179
---
-—-
2.3
2.4
CR11
---
---
0.72
1.6
0.88
0.63
0.40
0.44
5
22 10
28
---
---
149
129
-—-
---
2.1
5.0
CR12
---
---
0.35
1.2
0.58
0.38
0.37
0.38
1.0
20 10
6.0
---
---
274
113
---
---
2.0
5.1
CR13
-—-
---
0.38
1.2
0.44
0.33
0.39
0.40
8
26 12
11
---
---
145
129
-—-
—--
1.4
4.7
CR14
---
---
0.98
1.5
0.45
0.35
0.34
0.44
6
33 10
18
---
---
177
130
---
-—-
1.9
4.9
CR15
---
---
0.88
1.4
0.45
0.35
0.34
0.41
3
25 8.2
7.5
-—-
---
162
133
---
---
1.5
5.3
CR16
---
---
0.88
1.3
0.50
0.32
0.30
0.35
4
29 8.5
12
---
---
160
171
---
---
1.4
3.5
CR17
---
---
0.85
1.2
0.37
0.24
0.16
0.27
3
30 8.5
21
---
---
141
150
---
---
1.3
2.7
CH17A
---
---
0.88
1.2
---
-—-
0.18
0.26
---
--- 6.2
8.7
---
---
140
146
---
---
1.4
2.7
CR18
---
---
0.83
1.3
0.36
0.23
0.21
0.29
4
27 6.7
8.2
---
---
189
152
-—-
---
1.5
2.2
CH19
-—-
---
0.91
1.4
0.36
0.20
0.17
0.28
5
36 8.5
16
---
——-
137
152
-—-
——-
1.2
3.1
CR20
---
---
1.1
2.0
0.39
0.16
0.17
0.25
5
40 -18
14
---
---
153
156
---
---
1.4
6.1
CR21
---
---
1.0
2.0
0.33
0.18
0.17
0.22
4
42 11
17
---
---
142
157
---
---
1.6
6.7
CH22
---
---
0.95
1.9
0.28
0.17
0.16
1.2
3
31 20
22
---
---
171
184
---
---
1.5
5.3
CH22A
---
---
0.90
2.3
---
---
0.16
0.24
---
--- 18
26
---
---
156
180
---
—--
1.5
5.5
CR23
---
---
0.88
2.4
0.26
0.16
0.20
0.20
7
28 16
14
---
---
160
169
---
---
1.6
12
CR24
---
---
0.89
2.0
0.27
0.16
0.24
0.18
6
25 14
14
---
---
176
168
---
---
1.8
9.3
-------
CHARLES RIVER WATER QUALITY SURVEY DATA SUMMARY - 1973/1978 (Cont’d)
pH
(mg/i)
.
(Std. Units) (#/lOOmi)(Geo. Mean) (#100/mi)(Geo.Mean)
6/73
9/73
6/78
7/78
6/73
9/73
6/78
7/78
6/73
9/73
6/78
7/78
6/73
9/73
6/78
7/78
CHO 1
6.8
7.0
6.9
6.3
9
29
11
9
740
19800
550
350
---
---
17
5
CH O2
6.9
6.9
7.4
7.4
19
31
20
29
630
29900
220
80
---
-—-
7
7
CHO3
6.9
6.5
7.3
7.2
23
37
31
38
23000
52300
12000
12000
---
——-
650
390
CHO4
6.9
6.6
7.3
7.1
37
53
57
68
32000
134000
34000
54000
---
—-—
3900
6200
CH O5
6.8
7.0
7.3
7.2
37
71
30
67
16000
56100
9000
1200
---
---
1100
54
CHO6
7.4
7.0
7.5
7.1
37
45
38
58
630
13400
370
280
---
-——
16
5
CHO7
7.1
6.8
7.3
7.4
31
35
30
40
350
30000
2000
3300
---
---
150
240
CH O7B
---
---
7.3
7.3
---
--—
23
36
---
---
610
1600
---
-—-
110
14
CHD7C
--—
---
7.3
7.6
---
—-—
22
37
---
---
1100
320
-—-
---
160
24
CH O8
7.1
7.0
7.2
7.4
19
30
19
32
2000
34600
1200
3400
---
-——
300
550
CHO8B
7.2
7.5
7.2
7.3
16
28
20
33
490
8500
730
1200
---
--—
130
150
CH O9
7.1
6.9
7.2
7.4
21
30
20
29
3000
40000
1600
1300
---
---
270
63
CH1 O
7.2
7.2
7.2
7.5
21
26
19
27
22000
29200
1400
1800
---
---
380
240
CH 1 1
7.2
7.3
7.1
8.4
18
27
19
25
1600
2400
1200
280
—--
---
100
24
CH12
7.2
7.3
7.2
7.9
17
24
18
26
1700
25900
2400
420
---
---
290
100
CH13
7.1
7.1
7.0
7.1
17
23
21
33
22000
16700
650
320
---
-——
89
23
CH14
7.1
7.0
7.6
7.4
18
26
21
28
39000
52500
6920
84000
—--
--—
140
89
CH15
7.1
7.3
7.6
7.7
18
28
22
28
35000
77500
4700
7600
—--
---
56
28
CH16
6.9
7.1
7.5
7.4
18
25
21
28
26000
13300
1900
740
---
-—-
75
14
C1117
7.1
7.0
7.6
7.5
18
27
24
28
3300
34500
650
170
—--
-——
51
20
CH17A
---
---
7.7
7.3
---
--—
22
27
---
-—-
200
710
---
-—-
20
20
CH18
7.1
7.3
7.6
7.4
19
27
23
28
2000
23100
720
710
-—-
-——
63
34
CH19
7.2
7.1
7.6
7.4
18
27
20
27
850
28800
690
600
—--
-——
55
56
CH2O
7.1
7.4
7.5
---
21
29
23
35
1800
22000
940
240
---
-—— -
130
60
CH21
7.2
7.6
7.7
8.7
22
29
24
33
5800
140000
1900
260
---
-—-
180
74
CH22
7.3
7.6
7.5
7.7
21
31
25
31
1700
40600
8800
3700
---
---
220
1000
CH22A
---
---
7.5
7.7
---
---
24
31
---
---
2200
4600
——-
-—-
400
460
CH23
7.4
7.3
7.4
7.7
24
32
22
31
5200
34600
1400
4800
---
---
80
400
CH24
7.3
7.0
7.5
7.6
25
32
23
32
20000
48600
9500
990
---
---
240
320
-------
FIGURE B4
CHARLES RIVER
AVERAGE DISSOLVED OXYGEN
UW. PC. SURVEYS -1973,1978,1980, & 1981
0 ’
z
Ui
x
0
0
U i
0
(I ,
C l)
0
RIVER MILES
-------
concern based on a review of chlorophyll-a data at stations common to all
surveys as presented below:
CHLOROPHYLL- a (mg/rn 3 )
River 1973 1980 1981
Mile Sta. Concentration Sta. Concentration Sta. Concentration
76.5 CHO1 2.5 CHO1 0.81
72.0 CHO5 7.9 CHO5 3.32 CR03 3.74
60.1 CR10 5.0 CH14 1.66 CHO9 1.08
44.6 CH15 19.8 CR19 27.07 CH14 50.76
33.0 CR18 29.2
22.1 CR20 92.2
18..3 CH22 90.0
9.8 CR24 60.8
Note: Chior. -a data was not reported for the 1978 survey periods.
Substantial increases are observed over the sampling periods covered at
the sampling stations identified at RN 44.6. As chlorophyll-a is indi-
cative of the productivity occurring in a water body in response to
available nutrient supplies, additional sampling over a wider area of
stream coverage appears warranted. As indicated in earlier discussions,
the potential impacts of increased nutrient loads from a satellite
facility can be expected to be reflected in increased productivity and
chlorophyll-a levels. An area which has not been addressed, with respect
to a satellite facility, is that of possible instream mitigation measures
to reduce or offset the potential impacts of the discharge, such as
instreain aeration, use of artificial wetlands for nutrient removal (and
subsequent harvesting), or other alternative measures.
The impacts of a satellite facility discharge to the Neponset River were
evaluated using a Streeter-Phelps analysis. The conclusions of this
analysis were presented in Section A.3 of this report. Based on our
review of the modeling discussion contained in the Draft EIS and Appendix
3.2.3-2, we concur with the conclusion that a satellite discharge would
negatively impact the dissolved oxygen resources of the river. Further,
based on discussions with DWPC and TSB staff, it was determined that more
sophisticated modeling was not warranted due to the severity and magni-
B-SO
-------
tude of the projected inpacts. Again, although instream mitigation
measures were not considered in the evaluation, the projected impacts are
sufficiently severe on the Neponset River that any such measures may not
be capable of providing a reliable degree of improvement.
Water quality data for surveys conducted in 1973 and 1978 by the MDWPC
are summarized in Table BlO. Summaries of flow data during each survey
period are also shown on Table BlO, together with the 7Q10 low flows for
each gauging station. As shown, the August, 1978 survey period flows are
very close to the 7Q10 flows. Although D.O. levels generally appear to
increase (both average and minimum values reported), periodic violations
of the Class B criteria still occur. Much of the river is also in
violation of the fecal coliform criteria, based on data reported in the
1978 survey. (Fecal coliforni were not enumerated in the 1973 survey.)
The imposition of a satellite facility to the upper Neponset River may be
expected to reverse any trends toward the gradual improvement of water
quality conditions in the river as are suggested to be occurring based on
the available data.
B4.1.3 Water Supply :
Potential impacts of the satellite facilities on water supply wells
hydraulically connected to the main stem rivers, downstream of the
proposed discharges, were identified as major concerns in the Draft EIS.
The principal concerns relate to pollutants not removed by the treatment
processes, and the inability to control influent quality to the treatment
facilities. Under low stream flow conditions, when discharge volumes
would comprise a significant proportion of total stream flow, it is
possible that wells located near the mainstem of both rivers could result
in drawing surface water in the river channels into the groundwater
regime of the wells, resulting in potential health impacts to the popu-
lations served by those wells.
B-5 1
-------
TABLE BlO
NEPONSET RIVER WATER QUALITY SURVEY DATA SUMMARY — 1973/1978
Dissolved Temperature ROD NH —N NO -N Total Phosphorus
Oxygen (mg/i) (°F) (mg/i) (m4/ l) (m4/l) (mg/i)
7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78
r oi 8.9 5.4 7.5 79.5 76.2 72 6.15 4.20 4.0 0.00 0.270 0.02 0.00 0.00 0.0 0.085 0.125 0.10
NEO2 7.7 3.5 6.8 79.0 72.7 71 4.50 2.95 6.3 0.015 0.400 0.08 0.35 0.20 0.1 0.280 0.335 0.14
NEO3 7.4 6.1 7.0 76.8 71.9 71 3.70 4.05 5.0 0.020 0.265 0.09 0.40 0.40 0.2 0.170 0.205 0.12
NEO4 4.9 3.0 5.1 75.2 71.0 69 2.40 2.10 3.0 0.040 0.190 0.05 0.25 0.15 0.2 0.185 0.160 0.09
NEO5 6.7 6.5 7.8 74.8 71.8 69 3.20 2.60 5.0 0.030 0.150 0.01 0.30 0.30 0.2 0.165 0.135 0.08
NEO6 3.8 3.9 7.8 75.5 71.7 69 2.80 6.20 3.2 0.065 0.080 0.01 0.20 0.20 0.2 0.130 0.170 0.10
NEO7 4.8 4.5 6.7 82.5 78.0 77 3.50 1.80 3.3 0.085 0.190 0.02 0.25 0.30 0.1 0.100 0.105 0.06
NEO8 6.7 6.8 8.1 79.8 76.6 74 3.20 2.50 3.8 0.040 0.200 0.03 0.25 0.25 0.1 0.105 0.100 0.05
NEO9 7.8 7.8 8.0 76.0 72.8 71 1.70 1.70 2.8 0.065 0.110 0.01 0.45 0.35 0.1 0.090 0.040 0.10
NE1O 6.7 6.9 7.4 77.7 74.1 71 2.50 1.30 4.5 0.025 0.115 0.01 0.35 0.35 0.2 0.100 0.095 0.05
NEll 5.6 5.7 6.5 76.2 73.1 70 2.00 2.20 2.7 0.090 0.175 0.07 0.35 0.65 0.4 0.105 0.085 0.06
NEI2 6.9 6.8 6.5 76.3 73.4 72 1.90 1.80 3.9 0.030 0.145 0.06 0.35 1.15 0.6 0.055 0.055 0.06
NE13 5.0 5.2 5.8 75.6 72.6 70 3.00 1.80 2.8 0.080 0.110 0.06 0.35 0.45 0.2 0.095 0.090 0.05
NE14 5.6 5.6 6.7 77.0 73.2 70 3.15 2.50 2.4 0.135 0.175 0.08 0.45 0.35 0.2 0.170 0.135 0.06
NE15 6.5 6.6 6.9 76.5 73.3 70 3.45 2.00 3.2 0.120 0.120 0.19 0.45 0.45 0.4 0.180 0.085 0.12
NE16 5.7 5.6 7.8 76.3 72.2 70 2.10 1.70 2.8 0.100 0.140 0.10 0.45 0.45 0.2 0.170 0.085 0.09
NE17 5.3 6.0 5.2 68.3 68.4 69 1.45 1.40 3.2 0.370 0.340 0.28 0.05 0.05 0.0 0.130 0.080 0.22
FLOW SUMMARIES DURING SURVEY PERIODS
Average Fiow (CPS) Average Fiow
7/73 8/73 8/78 Gage Record 7Q10
Neponset River USGS Gauge at Norwood 36.0 46.8 11.08 51.8 4.9
East Branch USGS Gauge at Canton 45.8 47.8 12.08 50.6 3.4
-------
NEPONSET RIVER WATER QUALITY SURVEY DATA SUMMARY - 1973/1978 (Cont’d)
Total Alkalinity pH Total Coliform
(mg/fl (Std. Units) (#/lOOml)(Geo. Mean)
7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78
NEUl 19.0 24.0 24 7.4 7.0 7.0 300 300 500
NEO2 22.0 25.0 24 7.5 6.6 7.0 3000 2500 5000
NED3 24.5 24.5 26 7.4 6.6 7.1 21000 26000 16000
NEO4 24.5 23.5 26 7.4 6.3 7.1 6500 5300 2400
NEO5 23.0 23.5 26 7.4 6.6 7.1 24000 5000 6000
NEO6 21.0 25.5 28 7.5 6.8 7.2 34000 5000 15000
NEO7 21.0 28.0 29 7.3 6.9 7.3 11000 3500 3000
NEO8 21.0 27.0 30 7.4 6.6 7.2 9000 1900 1400
NE O9 20.5 22.5 23 7.4 6.8 7.3 35000 13000 4800
NE1O 22.0 27.5 27 7.3 6.9 7.2 23000 11000 27000
NEll 23.5 29.0 30 7.4 6.7 7.3 12000 1000 9700
NE12 22.0 23.0 30 7.4 6.8 7.2 3700 15000 6000
NE13 22.5 24.5 30 7.6 6.6 7.2 7700 81000 1700
NE14 24.5 26.0 30 7.6 6.6 7.2 29000 79000 21000
NE15 22.5 24.5 33 7.6 6.5 7.3 33000 62000 84000
NE16 23.5 25.0 33 7.5 6.8 7.3 12000 25000 50000
NE17 70.0 85.0 92 8.0 7.3 7.4 34000 12000 38000
-------
While the concern for potential public health impacts is certainly a
valid one, the assessment of risk associated with the proposed satellite
facilities is difficult, given the long history of discharges of both
treated and untreated wastewaters to both the Charles and Neponset
Rivers. Given that there are no existing wastewater treatment facilities
discharging to the Neponset River, it can reasonably be argued that the
satellite facility proposed represents an unacceptable risk with respect
to the protection of water supply resources.
Given both the existing and projected wastewater flows from existing
treatment facilities discharging to the Charles River, it cannot be
clearly established that the discharge from the proposed satellite
facility would represent an increase in the degree of risk of public
health impacts, in addition to the risk that must be associated with
existing facilities. Detailed hydrogeological investigations would be
required to develop a reliable basis for defining the incremental risk
associated with a satellite facility on the Charles River.
B4.2. Wetlands Disposal Option
An initial step in the evaluation of the QSA—Wetlands Disposal Satellite
Option involved in the determination of available wetlands within rea-
sonable close proximity to the proposed sites for the three satellite
facilities included in the proposal. Wetland maps for the Weymouth,
Charles, and Neponset River Basins prepared in 1976 by the Metropolitan
Area Planning Council (MAPC) “208” water quality project were used to
determine the acreage of inland wetlands located within 1000 feet radius
and within a 1 mile radius of the proposed location of each facility.
Table Bli summarizes the estimated wetland acreage available within these
two zones, and compares the “available” wetland acreage with the previous
estimate of wetland acreage required for each discharge, as presented in
Table B7. The estimated wetland acreage required is based on the phos-
phorus and BOD loading criteria as previously described.
B-54
-------
TABLE Bil
PRELIMINARY ESTIMATE OF WETLA1 DS AVAILABILITY
FOR WETLANDS DISPOSAL TREATMENT FACILITIES
Inland Wetland Inland Wetland
Treatment Wetland Acreage Area Within Area Within
Facility Required 1,000’ (Acres) 1 Mile (Acres )
P BOB
Charles River 278 574 232.5 593.9
Neponset River 195 402 116.9 269.3
Weymouth Fore
River 55 115 69.2 189.5
‘Based on phosphorus and BOB loading criteria as per Table 6.
As can be seen, the extent of “available” wetlands is dependent upon the
selection of loading criteria used in the cases of the Charles and
Weymouth Fore Rivers. The Neponset River does not appear to have a
sufficient amount of available wetlands within 1,000-foot radius to
satisfy either criteria. The available wetlands within 6 miles of the
Neponset facility would satisfy only the phosphorus loading criteria. It
is important to recognize that this estimate of “available” wetlands is
based on available mapped information only and has not been confirmed by
any level of field investigation of the wetlands identified. Nor has the
estimate considered the ownership or other aspect of allowable or re-
stricted uses which may affect the actual availability of a particular
area. Finally, the costs which might reasonably be associated with an
effluent pumping and distribution system which might be required under
any of the treatment plant-wetland disposal area combinations possible
are not developed beyond those figures presented in Table B8.
Based on the responses of the DEQE-DWPC and DWS to the subject proposal,
which are presented in Appendix C and which reflect preliminary assess-
ments of the proposal conducted by Maguire staff, additional evaluations
were not conducted. The major areas of concern with regard to impacts
are summarized below.
B-55
-------
The development of the proposed wetlands discharge satellite facilities
presents an unacceptable risk to public health and important water supply
sources in the metropolitan region. As in the discussion of risk asso-
ciated with the ENMA satellite facilities, the risks associated with
placing a wastewater treatment plant discharge in intimate contact with
existing clean sources of public water supply are unacceptable from a
State regulatory perspective.
Actual versus estimated wetland areas available and limits posed by the
selection of loading criteria suggest that the scale of the wastewater
facilities proposed is excessive for the safe application of wetlands
disposal technology. Also, the use of wetlands for effluent disposal on
a year-round basis could preclude the flow regulating function of natural
wetlands which is an important aspect of flood storage hydrology in an
urbanized area. This aspect may further negate any potential benefits
with respect to groundwater recharge.
As pointed out by the DWPC and DWS, the renovation aspect of wetlands
disposal is one of uptake and release. Experience with small-scale
wetlands disposal projects, relative to this aspect of facility operation
and maintenance, has led to the more prevalent practice of artificial
wetland systems which can periodically be renovated by harvesting or
dredging accumulated vegetation and decaying organic matter.
B-56
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ATTACHMENT A
WATER QUALITY MODELING CORRESPONDENCE INDEX
7/25/79 Martin Weiss, Chief Engineer, MDC, to Thomas C. McMahon,
Director Mass. DWPC, re: tasks remaining to be carried out
under DWPC basin planning.
4/26/79 Libby Blank, Director of Environmental Planning, MDC, to
Kenneth Johnson, U.S. EPA, re: EPA and MDC responsibilities
in conducting Charles River Watershed Analysis.
3/29/78 Jekabs P. Vitt nds, Vice President, Metcalf & Eddy, Inc., to
Libby Blank, Director of Environmental Planning, MDC, re:
comments on Dissolved Oxygen Modeling, Charles River,
Massachusetts .
4/28/78 Daniel W. Donahue, Project Engineer, Metcalf & Eddy, Inc., to
John Elwood, Environmental Planning Division, MDC, re:
review comments on Mr. Polese’s memorandum on Charles River
1978 survey (attached).
3/1/78 Wallace E. Stickney, Director, Environmental and Economic
Impact Office, U.S. EPA, to Libby Blank, Director of Envi-
ronmental Planning, MDC, re: Allen Ikalainen’s “Comment on
Memorandum on the Review of Dissolved Oxygen Modeling ,
Charles River, Massachusetts” (both attached).
7/27/77 Mary E.Shaughnessy, Environmental Impact Analyst, U.S. EPA.
to Libby Blank, Director of Environmental Planning, MDC, re:
Charles River water quality modeling.
B- 57
-------
8/5/77 Allen J. Ikalainen, Acting Chief, Systems Analysis Branch,
U.S. EPA, to Libby Blank, Director of Environmental Planning,
MDC, re: Charles River water quality modeling, responses to
Metcalf & Eddy questions.
7/6/77 Jekabs P. Vitlands, Metcalf & Eddy, Inc., to Libby Blank,
Director of Environmental Planning, MDC, re: questions on
Charles River water quality modeling.
7/18/77 Libby Blank, Director of Environmental Planning, MDC, to Mary
Shaughuessy, U.S. EPA, re: comments on Charles River water
quality modeling.
5/18/77 R.W. Chapin, Environmental Assessment Council, Inc., memoran-
dum to Mary Shaughnessy, Project Officer, U.S. EPA, re:
location of Mid-Charles River satellite plant discharge.
B- 57a
-------
/( ,
- // ‘ /,.; ,‘,?i ( J h’, /.‘,‘/ jj/f.//
1” I’ /1
...‘C.J’rrm,rj,f Jt,”i’/. -7)’ .Jn ( .. ‘(J
C:FICE or - E
Cr \C T L - -.
July 25, 1979
Mr. Thomas C. Mc!ahon, Director
Division of Water PoUution Ccntrol
110 Tren3nt Street
Boston, MA 02108
Dear Mr. McMahon:
Pursuant to our discussions of July 3, relative to the DWPC
co 1rnitr,ent to do a Phase II Basin Plan for the Charles River, and
in l•ight of recent discussions between Mr. Al Cooper an of your
office and Mr. Jekabs Vittands of Metcalf & Eddy, we find that the
following tasks remain to be carried out under the D PC basin planning
proc rain.
1. Coi.duct a detailed review of the Charles River model input
values and develop their ranae of confj ence . For example,
the. )S modelling effort assume4certain_values for_non 9 nt
source impacts and sediment deposit_impact ich each
resuT in using up abouT 40 p T of the River’s oxygen
resources. Therefore, assumed values played the most
significant role.
2. Conduct a detailed revie _oL mod j parameters anj_d€ve p their
range of confidence. For example, the reaeration coefficients
used by the E]S modelling effort in certain reoc es .ere about
ten percent of those used by the DWPC Easin Plan. Yet, both
efforts reflect similar model calibration results.
3. Conduct on parameters and input data
relative to their impact on satellite plant discharges.
4. Conduct field measurements to narrow the confidence ranges of
those parameters and input data that impact ater quality
modelling based decisions on satellite plants.
-------
•: -. r.:r C. Mc ahci , Director - 2 - July 25, 157
5. Make model runs and conduct analyses to provide the water quality
modeilina bases for determining the desirability of satellite
plants addressing questions 1 such as:
- Do dissolved oxygen violations occur with and without satellite
plants?
- If so, how often do they Occur and how severe are they?
- What water quality goals can be achieved with and w tho t
satellite plants?
Mr. Cooperrnan further indFcated two additional relevaflt points.
First, the modelling formulations for the Charles River have been carried
out by the DWPC and have been verified. Secondly, DWPC plans to conduct
the remaining tasks when new members of his staff have been sufficiently
trained, but that results would not be available in the near future.
Our interest is to insure that the necessary work will be reasonably
scheduled so that future wastewater treatment . decisions can properly be made.
At such time that Mr. Cooper-nan’s staff resun e activities in tns matter
I suggest they contact and visit with Metcalf & Eddy personnel who have been
involved with Cha es River modelling revie . I enclose for your staffs use
a copy of some of this w3rk as it rela t i ô EPA’s EIS i odelling on the Charles
River. -
If we have your concurrence the above tasks will be included in the
Phase II Basin Planning, there will be no need for DC to do this work in
the ut Island Facilities Planning.
Please advise this office as soon as possible as to your concurrence
so that we can finalize the scope of work for the Nut Island Facilities
Planning contract.
Yours truly,
2 &
Martin Weiss
Chief Engineer
RGJ : mmw
Enclosures (1 — 8, inclusive)
cc: Al Coooerrrianw/o enclosures
it3’ö 2 1979
J,V
:: T. :.
-------
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20 ,ierje S’Zree4 £ e z, 0& 8 / 7/7ç/
Environmental
Planning Office ______________________
r 0 rr r i i ,’
MLTCALr ô LULl!, Ii: .; .
FILE......
D IC
April 26, 1979
Mr. Kenneth Johnson
Special Assistant
Environmental Protection Agency
JFK Federal Building
Roston, Mass.
Re: Charles River Water Quality Analysis
Dear Ken:
I am Titing because I believe some clarification of EPA and C responsibilities in
conducting the Charles River Water Analysis is needed.
Attached is the Charles River Analysis section from the Site Options Investigation
scope of services, which outlines MDC’s work items. Also enclosed is a rnemora.ndirq,
which we asked Metcalf Eddy to prepare, outlining the tasks to be performed by
EPA.
We would appreciate your reviewing the meinoranthnn and scope to assure that we
are in accord on our mutual responsibilities.
Yours truly,
Libby Blank
Director of Environmental Planning
LB/co
cc: D.O’Brien, EPA
J.Vittands, M E 1
Enc: 2
-------
— $ . • :i . e the b .i r tLe selection
— t’C ’:1er: C i!”flflCtS,
— CflV i’oniicntal impncts,
— .;ocial im icts,
— •‘ l 1 C:)l ii flct: , and
— institutional inpacts.
23. . l ,t!1c l inv ti ption of Charles River U .tcr uaUty
The purpose of’ this investiCation is to determine .hcther
there is any opportunity for the discharge from an EDC
satellite treatment plant into the Charles River in
conformance with The Clean Water Act such that the potential
for reclar ation of wastewater, as well as the deployment
of innovative technologies, can be considered. The
investigation is intended as a continuation of the effort
made by EPA during preparation of the EIS on the E A
study.
lthough the continuation is to be a joint EPA—F DC effort,
the major work is expected to be conducted by EPA wIth MDC
participating in a program guidance, review and decision—
making role. To this end, it is expected that EPA will
carry out the following:
— Update the EIS data base on the Charles River studies,
especially with new information on wastewater discharges
and recent field measurements. Prepare a file on that
data base and provide a copy to MDC.
— Review modeling formulations especially considering the
results of such an effort carried out on behalf of the
1 ’
-------
cc’tt P vi oi of U Lcr roll ut o: ’Cc: :‘. i (“
‘d I tient. t i lCl c!n C ; tj L :-:‘be i cCr
— ;odi ‘y the ‘oa1mLI.’d y EPA as nccc: .nIv and ; ‘e ’d
tij’oii with !‘ DC, i nclud inc ch ri c nc d d to n ’crare c !’uL
iii ncrc ii ablc f’ormnt
— ; pp in roz’ rind conduct a phy iica1 in pcct ion (by boat,
:hcze ! i’o; riaLc) of’ the Charles River, a]so inclwnr.
pei onncl selected by 1DC.
- Conduct a detailed evaluation of all pa tersue n
the modeling effort and jointly with MDC develop the
range of confidence for each.
- Arrange for free access for the project participants to
special experts where such are necessary for decision—
making.
— Conduct sensit .vity analyses of parameters as necessary
by supplementing computer runs made during the EIS and
provide copies to MDC.
— At locations where it is jointly agreed that further
field information Is required for decision—making,
conduct field measurements. Such may include measurement
of stream reaeration capacity.
— Following development of...a final agreed upon model of the
Charles River, conduct model runs of jointly agreed upon
conditions needed for decision—making and provide copies
to MDC.
- Prepare and print a jointly agreed upon report on study
findings.
Metcalf & Eddy’s function in this effort will be to assist
2.
-------
1. .)C in this thy LiC tion s fo] lo.:s
- 1 i’viC : the Charic ivcr d:ta ba5e filc cve1C
and advi c flDC of’ os U)le needed o be fi) d.
— 1 1L2c pJ tC in the physical jnapectjOfl cf the Charics
]Uvcr icr nurposes of aiding jn model p rarncter electiOi.
— Anstht 1’ DC in evaluating the review of modcUng
Cor; ntLitions and of modeling done to date.
— . dvise DC on model changes that are neccs arY or that
•:ill facilitate the review of’ results.
— Assist MDC in the selection of’ a range of parameters
for sehsitivity analysis.
— Review results of sensitivity analyses and advise on
final model adoption, including the conduct of’ discussiOr 5
with special consultants and participation in the
development of special field measurements.
— Assist MDC in the development and evaluation of
alternatives and in the development of recommendations .
— Conduct reviews of reports and attend meetings as
requested by MDC.
114. Assessment of Existing Nut Island Treatment Plant Conditions
— Compile and review existing data and studies on the plant
conditions and operations.
— Make field Investigations of physical features of the
existing facilities including hydraulic and treatr ent
capability, and equipment and structural work, as
applicable.
— Conduct detailed Investigations and, If necessary, field
testing of the condition and adequacy of major equipment
that is pertinent to the site selection process.
‘3
-------
cs•:on
Jz_o868 L /5/7 9
MEMORANDUM FOR THE RECORD
The following presents a more detailed explanation of the work
tasks expected to be conducted by the EPA as part of the
analytical investigation of the Charles River water quality.
— Update the EIS data base on the Charles River studies especially
w .th new information on wastewater discharges and recent field
measurements. Prepare a file on that data base and provide a
copy to MDC.
This task involves the collection and analysis of
previous data and reports related to the Charles River.
Included would be data from physical and water quality
surveys conducted 6y the MDWPC and others; data from
treatment plant discharges and industrial discharges;
data on river flows; data from previous water quality
modeling efforts; and any other pertinent information
related to .the river’s water quality. The data
should be analyzed to identify any treads, either
beneficial or adverse, in the rivers water quality
that may be evident upon review of the data. The
history of the level of treatment and discharge
location for all point sources should be investigated.
The extent and frequency of low flow conditions on
the river should be analyzed.
— Review modeling formulations especially considering the results
of such an effort carried out on behalf of the Massachusetts
Division of Water Pollution Control (MDWPC) and identify model
changes that may be necessary.
This task involves a thorough analysis of modeling
formulations used in the computer simulation. An
understanding of how the model uses the various input
data should be developed. Recommendations would be
made identifying model changes that may be necessary
to properly represent the various processes occurring
in the river.
— Modify the program used by EPA as necessary and agreed upon with
MDC, including changes needed to prepare output in a more usable
format.
This task involves the implementation of the needed changes
identified in the previous task along with any format changes
desired to enchance the readability of the computer output.
-------
— Arrange for and conduct a physical Inspecticn (by bcat, where
appropriate) of the Charles R!ver, also Including personnel
selected by MDC.
This task involves a physical inspectIon of sections of
the river to develop a better understanding of the river’s
characteristics. Possible limited spot checks might include
cros , . , ctIon measurements,, velocity, measurements, depth
jni urements, extent. of sediment deposits, and the
collection of grab samples. A detailed field log would
be maintaIned and any necessary changes to the various
modeled river segments would be identified.
— Conduct a detailed evaluation of all pararnèters used in the mode l ng
effort and Jointly with MDC develop the range of confidence for
each.
This task involves a review of the state—of—the—art
r lated to the various paramëtèrs used in water quality
modeling. Included would be parameters related to
such processes as BOD removal, nitrification, reaeration,
sediment demand, and photosynthesis. Ar g _p,ç,
confidence would be Identified for each parameter.
— Arrange for free access for the project participants to special
experts where such are necessary for decision-makIng.
This task involves making arrangements for the MDC
to have free access to technical experts in areas
where this is needed, such as the areas of deoxygeriatlon
and reaeration in river systems.
— Conduct sensitivIty analyses of parameters as necessary by
supplementing computer runs made during the EIS and provide
copies to MDC.
This task involves conducting computer simulations to
determine the sensitivity of the results to the range
of values identified previously for critical parameters.
In this manner tj e parameters most a,ffecting the
simulation results will be Identified.
— At locations where it is JoIntly agreed that further field
information Is required for decision-making, conduct field
measurements. Such may include measurement of stream reaeratlon
capacity.
This task would involve making arrangements for the_conduct
of special field measurements, where such have been
identified as critical to the decision—making process due
to the output from the previous tasks.
MCTCA .F & CODY
-------
— Following development of a final agreed upon model of the Charles
IUver, conduct model runs of joIntly agreed upon cor.d tions
needed for decision—making and provide copies to MDC.
This task would Involve the conduct and analysis of computer
simulations representative of conditions selected by the
MDC.
— Prepare and print a jointly agreed upon report on study findings.
• This task would involve the preparation and printing of
a report presenting the results of this Investigation as
agreed upon with the MDC.
Throughout the conduct of the tasks described above, the MDC and
Metcalf & Eddy would be involved In the Investigation both
directly In the technical analysis and functioning in a program
guidance, review and decision—making role.
Daniel W. Donahue
DWD:dd
6
METCALF & EDO
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Sa-.::’e : : _5 _:
3’T . :2 e: Z :
a . a a a _ —
• — a — •——. —
2 ._ — _. —‘
Consulting Engineers
March 29, 1978
J—5 50
Ms. Libby Blank
Director of Env ronmenta1 Planning
Metropolitan District CommissIon
20 Somerset Street
Boston, Massachusetts 02108
Dear Ms. Blank:
Following our brief review of the materials submitted to you by
Mr. Wallace Stickney, EPA, dated March 1, 1978, on Dissolved
Oxygen Modeling, Charles RIver, Massachusetts , and our attendance
with you at a meeting with EPA on Z arch 21, 1978, on the same
subject, we felt it necessary to summarize our comments herew th.
In general, the above—mentioned materials and meeting do not
change the comments made in our Memorandum on the Review of
Dissolved Oxygen Mode1in , Charles River, Massachusetts , sub-
mItted to you on January 10, 1978.
In order to be brief, we will only touch on the more important
points to provide further clarification.
Model Formulation Accuracy
As mentioned before, we have not checked the correctness of the
program. However, we do suggest checking, for example, the
temperature correction formulation for the upstream reach inflow.
AWT Performance Reliability and Deoxygenation Rates
We suggest checking the performance capability of the Marlboro
Easterly plant to achieve the S mg/L BOD 5 and 1 mg/L NH 3 —N.
NEWYORK PALOALTO CHICAGO
-------
xE. Libby 3 lank
March 29, 1978
S n larly, we suggest checkIng thIs plant’s effluent character-
istics to determine the approprIate deoxygenatlon rates for A
effluents. For further references on the change in deoxygena Ion
rates with increasing levels of treatment fcr plant effluents and
receiving streams, we suggest reading Professor Schroepf r’s
pIoneering work on the Mississippi River*, as well as recent wcrk
by the Geological Survey on the Willamette River in Oregon**.
Documentation of Assumptions and Handling of Dam Reaeration, Tine
of Flow, etc . -
Again we suggest that the sources of nfor nation be documented.
For example, the sources of the data in Table 5 of the EPA Report
need to be shown, to identify where such are from the BasIn Plan
and where such are from other references.
In our earlier memorandum we commented on some of the formulatior.
used. Our concern was with the correct use of these and not with
the answers they may produce.
PhotosynthesIs and RespiratIon
In developing the photosynthesis and respiration terms for water
quality modeling, a set of selected K rates was used for the
purpose of oxygen budgeting in the DItURV2 Program. Then a dIf-
ferent set of K 2 values was used in the actual water quality
modeling. This cannot be considered as a process leadIng to model
calibration.
Further, the photosynthesis/respiration information derived from
the above calibration process was not used in the low flow
sImulations. The input reflecting photosynthetic oxygen
production was greatly reduced while the oxygen consumption due to
respiration was held constant.
Figure 6 of the EPA Report shows a curve labeled ALGPO = ALGRA.
This represents a conditlon where photosynthesis and repiratlon
are modeled to in effect zero each other. Such a condition is
more favorable to the oxygen resources of a stream than can be
expected at night, when the respiration load is not canceled.
However, the curve as shown falls below the range of measured DO
values over most of the Charles River. Since these measurements
*G J. Schroepfer, N. L. Robins and R. H. Susag, “ReappraIsal of
Deoxygenation Rates of Raw Sewage, Effluents and Receiving
Waters”, Journal WPCF, Vol. 32, No. 11, November 1960.
* R. A. Rickert, W. G. HInes and S. W. McKenzie, “Methodology for
River — Quality Assessment with ApplicatIon to the Willamette
River Basin”, Oregon, Geological Survey Circular 715—N, 1976.
-------
Libby 3 lank
Narch 29, 1978
Include nIghttime readings WhiCh are representatIve of river con-
ditIons where there Is a respiratIon load but no photosynthesIs
addition, calIbration should be adjusted to allow the curve to
fall wIthin the range of field measurements;
Reaeratlon Coefficients
Undoubtedly the whole reaeration approach is a most thportant
factor In thIs modeling effort.
Again, one cannot use a different basis of reaeration in the
development of photosynthesis and respiratIon budgeting then one
would use In modeling the same data In the River. One cannot use
the wrong formulation to represent darn reaeration IrrespectIve of
the results.
WIth respect to selecting a formulation for stream reaeratlon, as
stated In EPA’s latest submittal, there is no one formula capable
of adequately predicting reaeration capacity in any stream. Thls
includes the Tsivouglu—Neal formulation as well as the O’Connor
Dobbins formulation. The Tsivouglu—Neal formulation is an attempt
at this. Covar’s paper (see EPA Memorandum, March 1, 1978 for
reference) recommends a set of three equatIons, including the
O’Connor—Dobblns formulation, for three conditions but does not
recommend the use of the Tsivouglu—Neal formulation due to a
??conslderable scatter ifl the data.TT As an objectIon to the use of
the O’Connor—Dobbins formulation (used by DWPC In the Charles
River BasIn Plan), the EPA Memorandum, apparently using Covar’s
paper as a basis, cites that the data used for its development
were under conditions where velocities were greater than 0.1 feet
per second —— a condition not occurring in the Charles River
during low flows. Perusal of the Tsivouglu—NeaJ. data base, as It
is published, did not show any data points with velocities less
than 0.1 feet per second either.
It should be pointed out that we do not necessarily subscribe to
any of these formulas as being the most appropriate for the
Charles River. Our feeling is that the impact of this parameter
is sufficiently significant to warrant a sound basis for its
determination.
Impacts on Oxygen Resources
Again, as modeled, the most significant impacts result from as-
sumed data. On the basis of a limited review of the available
data and without the ability to obtaIn computer runs we would have
liked to see as input to our revlew, the following numbers can be
only consIdered as crude approximations of impacts.
-------
:•: . Li b:’ Blank
:arch 29, 1975
Cause
Impact on DO
in rn /L Basis
Sed nent oxygen demand
3
Rept. Fig. 15.
Eli and Gil.
Cases
Phctosynthes s/
resp rat on
6
Rept. Fig. 16.
D2 and E2.
Cases
Upstream plants
Unknown
MDC satellite plant
1.5
Rept. Fig. 12.
El and B].]..
Cases
Nor.po nt sources
Unknown
Following the March 21st meeting, at which the last paragraph on
Page 11 of EPA ’s March 1st memorandum was discussed, we reviewed
the EPA computer run No. 368 which had been submitted as the basis
for the conclusions in that paragraph. As stated, the purpose of
the run was to test the significance of the oxygen demand from all
of the treatment plants by reducing CBOD 5 to 1 mg/L and NEOD to 0.
The run showed DO values significantly lower than those quoted n
the paragraph. A spot check of the input data showed that the
NBOD values had not been set to zero. A further check showed that
the input data had been further changed by raising upstrean
background water quality, by increasing K 2 In five segments, by
decreasing K 2 in three segments, and by elImInating a small point
source.
Very truly yours,
y f
ekabs P. Vittands
VIce Presldent
JPV:jfj
-------
Metcalf & Edd ,Inc .
S aiiforC S ’ee Sos c assa: e’;s C1 i
617 523. 19O TWX 71 C 321 6355 Ca e Aoore s METE OD Boston
/ pr11 28, 1975
.r. John Elwood
._ J) E vIronnenta1 P1annir D1vis on
Netropolitan District Cor IssIon
20 So erset Street
Boston, ;Iassachusetts 02108
Dear r. Elwood:
As you requested, we have reviewed fr. Polese’s nenorandu on
the Charles River 1978 Survey. The memorandum Inplles that this
year’s survey will resolve some of’ the problems encountered ir.
the computer modeling of the river. AssumIng this to be one of
r the goals of the sampling program, the fol1owIn com ents are
made.
1• The sampling program should be conducted under
conditions similar to those used In the modeling
effort. That is, since the river modeling is for
\ fi low flow conditions, the measurement program
‘ should be conducted during dry weather under low
flow conuitlons. Also, the timing should be
flexible so that the program can be rescheduled
If sIgnIficant rainfall occurs prior to..planned
program.
2. In order to obtain dependable results from the
modeling effort, it Is essential to have all com-
ponents sampled at the same time. Therefore, when
the main stem is sampled, the point sources and at
least the major tributaries, such as lane Brook,
Stop River, and Sugar Brook, should also be sampled.
Ne YOrA Palo Alto Chicago
rC 5 .
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r. John 1wood 2
r—-. i -‘
“2_ d1
3. Ulth regard to additional sampling stations, it
could be desirable to establish a station somewhere
between river mIle 70.3 and 66.1, where rnode1In of
the 1973 data indicates no dissolved oxygen.
Stations should also be established above and below
jor point source discharges to aid in assessing
their impact on the river’s water quality. (Eince
no advanced plants are operating on the river,
perhaps monitoring an existing advanced plant,
such as liarlborough, would provide valuable data in
determining the effects these plants will have on
river water quality.)
4 Time of travel studies should be conducted in con—
junction with the sampling program.
5. Supplemental flow gases should be installed and oper-
ated before and during the sampling program.
6. Dam reaeration should be measured by measuring dis-
solved oxygen concentrations immediately above and
below the darns.
7. Sediment samples should be taken and analyzed to
determine benthic demands. It is not necess y,
however, that these samples be taken during the
sampling program. For convenience, they could be
taken either before or after the pro ran.
8. Ileasu.rements should be taken from which determinations
can be made of instrearn carbonaceous decay rates,
nitrogenous decay rates, and reaeration rates.
9. The sampling program should include both daytime and
nighttime measurements to aid in assessing the
diurnal variation in dissolved oxygen concentrations
and to ascertain the level of alga]. photosynthesIs
and respIration.
10. Groundwater samples should be analyzed to aid in
determining the water quality characteristics of
base flow under extreme low flow conditions.
-------
:r. Job; ulwood
April 28, 1978
In suzunary, we believe that a considerable effort is required
to re3olve all the probleris that have been encountered in
the PA :ater quality mocic-ling effort. Ue recorn end that the
sai,ling pro rar be caref z1ly desIgned and carrIed out so that
the data collected will be useful in further studies of the
Charles I iver water quality.
If you should have any questions regardIng these co en;s, please
do not hesitate to contact us.
Very truly yours,
)•‘ ,
a: iel :. ona ue
? ojec: - 1 n er
.‘ r .
-, .Y j. 0
:t3
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O DU FOR THE RECORD
BY: A. Lawrence Polese
DATE: April 14, 1978
SUBJECT: Charles River 1978 Survey
The Charles River 1978 Water Quality Survey has been scheduled by the
Division for the week of July 17 — 21. The last intensive survey was
conducted in 1973 in which both main stem and major tributaries to
the Charles were included in the sampling runs.
During March and April of this year personnel from the Division conducted
two preliminary spring surveys, one on the main stein and one on the
tributaries. The purpose of these was to collect background data and
to investigate possible pollutant loads carried in runoff from snowmelc,
and leechate resulting from high water tables. Results from chemical
and bacteriological analysis are not yet available.
This year’s survey will differ somewhat from the 1973 study. For
modeling p o g the entire main stein (minus tributaries) will be
sampled in one run, whereas in 1973 the run was divided into Upper
and Lower Charles runs. This was done in order to keep the runs from
being too time consuming i.e., seven hours. By postponing the tributary
stations a few days one complete run on the Charles can be accomplished.
This was not possible in 1973 with the Upper and Lower Charles arrange-
ment. Again complete runs should make modeling both easier and more
representative of actual river conditions.
The sampling stations for the current year are identical to those used
in 1973 (see The Charles River Part A, ! WPC 1973). Since tributaries
are being sampled separately, a more comprehensive survey is allowed.
A list of tributaries to be sapled is attached along with a list of
main stem stations.
The selection of sampling stations and time of survey is not yet final.
Addition/deletion of stations will be considered to make modeling as
accurate as possible. This memorandum is to provide interested parties
with an idea of how the Division is handling this year’s survey.
Coimnents and questions should be directed to Larry Polese at the Division’s
Water Quality and Research Section, Westborough, MA (617—727—6983 Boston)
or (366—9181, 9182 Westborough).
ALP / ro
Attachment
cc: A. Akalainen
L. Blank
H. Shaughnessy
J. Vittands
74
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CHARLES RIVER NAIN STEN STATIO
CHO1 Dilla St., M.ilford
CHO2 Cedar Swamp Pond Dam, Milford
CHO3 Howard St., Milford
CHO4 Mellen St., Hopedale
CHO5 Hartford Ave., Bellingham
CHOÔ Box Pond Darn, Bellingham
CHO7 Rte. 126, Bellingham
CHO8 Pond St., Franklin—Medway
CHO9 Elm St., (Shaw St.), Franklin—Medway
CH1O Bent St. (Walker St.), Medway
CH11 River Rd., Norfolk
CH12 Forest Rd. — Orchard St., Millis—Medfield
CH13 Dover Rd. — West St., Millis—Medfield
CH14 Rte. 27, Sherborn—Medfield
CH15 Bridge St., Sherborn—Dover
CHI6 South Natick Dam, Natick
CH17 Central Ave. — Centre St., Needham—Dover
CHI8 Chestnut St., Needharn—Dover
CH19 Ames St., Dedham
CH2O Kendrick St., Needham—Newton
CH2 1 Elliot St., Needham—Newton
CH22 Walnut St. (Wales St.), Wellesley—Newton
CH23 Moody St., Waltham
CH24 Watertown Dam, Watertown
CHARLES RIVER TRIBUTARY STATIONS
1 Godfrey Brook — Depot Rd., Milford
2 Beaver Brook — Taunton St., Bellingham
3 Hopping Brook — Rte. 109, Bellingham
4 Chicken Brook — Rte. 109, Iledway
5 Sheppards Brook — Elm St., Franklin
6 Mine Brook
a) Rte. 140, Franklin
b) Near Rte. 495, Franklin
c) Pond St., Franklin
7 Mill River — River Rd., Norfolk (CH11)
8 Stop River
a) Pond St., Norfolk
b) Winter St., Norfolk—Walpole
c) Campbell St., Norfolk
c) South St., Medfield
9 Sugar Brook — Of f Dover Rd., Millis
10 Vine Brook — Rt. 109, Medfield
11 Bogastow Brook — Rte. 115, Millis
12 Fuller Brook — Dover Rd., Wellesley
13 Waban Brook — Rte. 16, Wellesley
14 South Meadow Brook — At Charles River, Newton
15 Beaver Brook — River St., Waltham
TOTAL STATIONS 19
74
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UN ED STATES ENV PONMENTAL PROTECTION A3E CY
REGIC’
J F E’ NEDY FEDERAL BUILC!NG, BOS O . P.iAS .Cr USETTS c::
flarch 1, 1973
!s. Libby Blank
Director of Environmental Planning
::etrapolitan District Commission
20 Somerset Street
Boston, MA 02108
Dear Ms. Blank:
Upon receipt of your January 11, 1978 letter containing your comments
prepared by Metcalf and Eddy on the Draft Report —— “Dissolved Oxygen
!ode1ing — Charles River, Massachusetts”, Mr. Allen Ikalainen reviewed
the comments closely. He has prepared remarks concerning each point
addressed by Metcalf and Eddy.
I have enclosed a copy of Mr. Ikalainen’s remarks. It is evident that
there are soie misunderstandings of what the report says. In particular,
your comments concerning temperature correction for reaction rate con-
stants which are temperature corrected, photosynthetic oxygen production
and respiration rates used in the model calibration, nitrification rate
constants in simulations at low flow and the discussion of dam reaeration
reflect these misunderstandings. The attached remarks explain these points
in detail.
In addition to the specific misunderstandings mentioned above there are
several items in your comments which deserve further attention. For
instance, your comments on variations in river flow during the time of
travel survey in 1973 and differences in river flow between the September
1973 calibration and projected flows in the year 2000 are discussed in
the attached remarks. Also, your comments on sediment oxygen demand and
the magnitude of their effect are considered in some detail.
Your comment on in—stream reaeration raises Tsivoglou and Neal’s caution,
concerning use of their method in impoundments. However, they raise the
r.ote of caution because the procedure may predict reaeration rates in
e4cess of what they may actually be impoundments. The opposite is mdi—
c ited by the language of your comment. Again, the attached remarks
explain these points in detail.
1
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Your reco .endatiCflS raise an important consideration in understanding arid
interpreting mode1in results. Sensitivity analyses should be done_to
detertirie which modeling parameters most greatly affect the results, in this
case, predicted river dissolved oxygen levels. As mentioned in the attached
renarks concerning your conclusions and recommendations, sensitivity tests
on sediment oxygen demand, photosynthetic oxygen production and in—stream
nitrification rates are included within the report. We also point out
subsequent to the modeling report and receipt of your comments, sensi-
tivity tests have been done on deoxygenation rates of plant discharges,
bioche ical oxygen deriand loads in runoff, treatment plant loadings and
in—stream reaeration. These sensitivity tests are not rigorous and have
not been done to determine the effect on results from varying percent
changes in model input, but have been done over wide ranges to determine
the most sensitive input parameters in terms of their effect on results.
It is evident that in order in—stream reaeration, treatment plant loadin s,
and sediment oxygen demand
Although not yet tested, time of flow is undoubtedly an important para ecer
also. -.
Ii-. your recommendations, you have suggested confidence testing of each
“factor”. In this case this cannot be done because the field data collected
by the Division of Water Pollution Control in 1973, 1972, and other data
developed by EPA does not contain any duplicate samples or replicate
analyses or is not available in its original form. We agree that further
investigation of assumed values or field sampling could provide more
information to us. However, we question if the time and expense involved
in time of travel measurement, sediment oxygen de: nd measurement and
tracer measurement of reaeration will provide information which will change
our understanding of the river’s dissolved oxygen resources. We still
believe there is a major doubt that the Charles River can assimilate the
projected waste loads for the year 2000, after advanced treatment, and main-
rain D.0. levels of 5.0. mg/i consistently during the suter_ g
Therefore, we question the advisability of discharging any more waste—
loads_to the river than is absolutely necessar .
I:r. Alan Cooperman of the Division of Water Pollution Control informed us
that he is planning a water quality survey of the Charles River next sumner
and that he would like all parties involved in this modeling to decide upon
any specific field measurements which we need to further calibrate and
verify the model. I suggest that once you review the attached remarks
we meet with Mr. Cooperman to discuss the need for additional field
measurements.
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Las:ly, t several points in r. Ikalainen’s renar .s h h 1n i n:ed t - :t
he would review and consider any information th3t you or Netcaif ar 1 d Eddy
might have to further elaborate on the points of discussion concerning
deo ygenation rates of wastewatcr after advanced treatment, in—scream
reaeration predictive methods and in—stream deoxygenation rates for streams
receiving effluents after advanced treatment. In this regard please contact
Mr. Ikalainen directly.
Sincerely,
wallace E. Stickney, P.E.
Director
Environmental and Economic Impact Office
Enclosures
cc: Mr. Alan Cooperman (MDWPC)
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Car en:
on
‘cmorandum on the Revicw of Dissolved O vce
Ddeli . Charles River, 1 ssacrws cts ”
(Co— -.ents refer to paragraphs in sequence—first to last
of the above lenorandum)
Paragraph 1. -
On February 9 and 11, 1977 I met with Mr. Alan Cooper an, TC at
Wes:boro, MA. We discussed modeling of the Charles River for purposes
of analyzing the effect of a proposed C Satellite treatrent plant
d charge on dissolved oxygen. The EPA — Environmental Impact Office
and their consultants were interested in the effects of the proposed
discharge if the discharge points were located at points other than
just downstream of the Cochrane Darn. This interest developed because
of difficulty in finding a site for the satellite plant near the E - 1A
recomz’ ended location.
Mr. CooperTnan explained that Mr. John Erdmann had modeled the June
and September, 1973 water quality conditions with the STREAM and DICL’RV2
models, but h4d not developed a low flow simulation with the STREA.M model
prior to his leaving the ? mWPC. Mr. Cooperman and I agreed that low flow
conditions should be simulated with the STREAM model to analyze the effect
of alternative satellite plant discharge locations. The Division did not
have the resources at that time to develop the low flow model. However,
r. Cooper an provided to me card decks of Mr. Erdmann’s September 1973
simulation, the DICURV2 program and its input data for June and Septenber
1c73, a memorandum on the use and development of DICURV2 and computer
printout of the September 1973 simulation of the Charles River with the
STREAM model. He provided this information so that I might develop a low
flow simulation. Mr. Erdrnann and Mr. Coope an were planning on using
the STREAM model and DICURV2 to determine wasteload allocations under
drought flow conditions for inclusion in the Charles River 1976 Water
Quality Management Plan. (Ref: Part C, Water Quality Analysis, the Charles
River and Charles River Basin 1973, 1976 Page 65.) However, Mr. Erdmann’s
leaving precluded this.
In my report I have referenced this prior work by Mr. Erd ann in the
ACK C LEDGENI? T and on page 17 — last paragraph. Also in the model
calibration procedures discussed on pages 13—32 of my report, Mr. Erdmann’s
and thus the Division’s work is referenced repeatedly although each
parameter is not specifically indicated as being developed by Mr. Erdmann.
I have modified Mr. Erdmann’s model calibration input data for the September
1973 simulation in two major areas, in—stream reaeration and sediment oxygen
demand. Reasons for and the details of these modifications will be discussed
under co ents on paragraphs relating to those subjects, specifically.
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2.
Th D ’C has reviewed the report in dotail. Frt L r re tr ;: s: -
cff (War r Quallcy Section) has scheduled a water qual:tv sLr ey for t.
Ch rlcs River Basin for the su -rier of 1976. The purpose of the survey is to
e 3te the past water quality info ation and to provide current infor a:
fcr development of a Phase 2—Water Quality Iana emenc Plan. The Phaze 2
Plan is intended to review and update wasteload allocations for point sourc
and to develop wasceload allocations for new point sources and non—point
sources. The Plan is scheduled for completion in early C.Y. 1979 and s
being developed in coordination with MAPC and EPA.
paragraph 2.
The i pecus for this modeling did come from the EIS preparation.
1 o aver, under the requirements of the Federal Water Pollution Control
Act facilities planning cannot be funded by EPA unless there is an EPA
approved basin plan among other require ts. 3asin plans which apply
to streams and rivers which are designated as water qulity lir.i
cannot be approved by EPA unless wasteload allocations for point source
discharges will meet water quality standards as set by the states and
approved by EPA. Therefore, this modeling of the Charles which is
considering the current approved wasteload allocations is part of the
continuing water quality managenent process including facilities planning
and wasteload allocation. It is also part of the EIS preparation which
reviews the water quality impact of facilities planned to meet waseeload
alloca: ions.
Paragraph 3.
Recommendation 1 c. is based upon the pure logic that treatment
plants which would provide effluent quality as seems necessary according
to this analysis would be very costly to construct, operate and maintain.
Also, it is y understanding that there are very few large municipal
treatment plants operating at levels producing effluents of S r’g/i CBOD 5
and zero Wd 3 —N and therefore one can only question the reliability of a
plant to do so. One of the reasons that an EIS is in preparation is
because a satellite plant will have a significant environmental im3art.
Recommendation 3 does not recommend that sewer service areas be
limited. It recommends in fact that “the water pollution planning process
for the Charles River should include, as a possible control for future
wastewater from MILFORD,..., the limiting of sewer service area and
wastewater loadings,...”
Conclusion 4 says leaching from solid waste is known to occur in
the Charles River. This statement is based upon Part D, Water Quality
Management Plan — WPC 1976 — Charles River Basin, pages 17, 24.
Paragraph 4.
If the MDC and Metcalf and Eddy will recall the meeting at which
they w are present in Westboro, MA at the Division Offices on May 27, 1977.
-------
t t : reetin; Mr. Cooper an exrlained to all present that t ir con :. —:,
cs :r:c . r.alysis, Inc., wa revie in; the nodel f rru1a:ior.. As of t
writing F_Al has not co lc:ed their a a1vsis, but recent conversa:ion
chem indica:es that the model is corrcct in the stead :—state form.
constants input to the model in this analysis are tcrperature corrected
by the model as e: plained on page 16. Reaeration rates have beer’. adjusce
upward outside of the model by the temperature correcclon factor specified
by Tsivog!ou and aa1 and have also been temperature corrected (an upward
adjus:men:) within the model. This is explained in footnote (1) on page
30 of the report. - - —
In the year 2000 low flow simulations the Mother Brook diversior. was
inadvertently located at the downstream end of Reach 26 when it shou1 be
located at the head end of the reach. A low flow simulation has been run
with the diversion located at the head end of Reach 26. The difference in
downstream D.0. conditions as a result of this error is less than 0.1 mg/i
for the case tested.
Paragraph 5.
The assumptions made in the model calibration and the low flow —odel
development are stated in the report. Also, many of the assumptions are
the sate as those in the modeling portion of the approved Water Quality
Management Plan for the Charles — Part D — WPC 1976.
Paragraph 6.
If one looks closely at the time of travel study data from April —
May 1973 it is seen that river reaches between river mile 76.5—75.5 and
72.0—70.3 were surveyed on May 8. All of the remaining main stem reaches
were surveyed between April 30 and May 4, inclusive. Flow variations at
the Charles River Village, Wellesley and Waltham USGS gaging stations were
22 , ll and l3 of the minimum daily flow, respectively for the period
April 30 to Nay 4, inclusive.
Again, if one looks closely, the 2000 projected low flow with an C
satellite plant is seen to be about 7 times less than the average flows
during the time of travel study. This is based upon the projected and
measured flows at the three USGS gaging stations.
The time of travel—flow relationships used in the Septerrber 1973 and
low—flow simulations are the same as those used in the modeling of Part D—
Water Quality Management Plan, Charles River, 1976 C Table VI—3 and are
essentially the sane as those in Appendix E of Charles River Water Ou 1itv
Study EPA—? egion I, September 1971, except as noted in Table VI—3. As
explained in the Report on page 18 the work of Leopold and Haddock is the
basis for determining the tine of travel—flow relationships. This is a
widely accepted procedure for predicting river velocity at varying flows.
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4.
A roze in the co: ents Leopold arid 1addock d ve1oped the proced’jre
fron d :a collected on “freely—flowing streams withcut da-s’. If this
s in fact the case, then it is very possible that the relationship may
predict v 1ocities chat are too high in the inpounded reacnes. The
relationship sonawhat underpredicts time of travel as reasured in April—
:!av 1973. (See Attached Table 1) Additional testing of the relationship
at flows approaching those of the projected low flow with a satellite plant
would be us fu1. However it will require a great deal of luck to schedui.e
a tine of travel survey to coincide with low flows bing stead:: throughaut
the river and approaching the projected lowflows. -
.1 presune Metcalf and Eddy’s reference to “hydraulic efficiency” of
impoundments is an attempt to explain that large, recent man—made impound—
ments nay retain the original river cross section along the bottom surface
profile and that at extremely low flows the river will flow within its
original channel causing lower times of flow. I don’t believe this is the
case in the Charles River because I observed the river on August 16, 1977
when the daily average flow at the Charles River Village Gaging station was
58cfs or 28 less than the projected seven—day 10 year low flow as shown in
Table 8 of my report. On that day the impoundments behind the So. Natick
Dan and Cc hrane Dam were fully impounded and velocity of flow was extremely
slow. Floating algae were barely distinguishable as moving downstream.
Further, I don’t believe the concept of “hydraulic efficiency” is applicable
to rivers flowing through wetlands and lowlands, as does the Charles, with
impoundments formed by run of the river dams.
Paragraph 7.
The September 1973 calibration includes pollutant loadings from Sugar
Brook as measured on 9/4/73. The ?Iillis wastewacer treatment plant
discharges to Sugar Brook. In this particular case the model includes the
loading from Sugar Brook which carries the loads from Millis and Cott Corp.
via the Millis treatment plant.
I have not reviewed and compared the operating procedures in 1973 and
1974. Perhaps Mr. Erdmann did in preparing the model for calibration.
Mr. Erdmann’s conclusion number 2 from Part C Water Quality Analysis,
1973—1976, Charles River and Charles River Basin points out that non—point
sources ‘undoubtedly degrade the quality of many more miles of stream than
do the waste discharges and the sewer overflows, but in more moderate degree”.
Paragraph 8.
The second sentence in this paragraph partially reiterates a point
discussed at length in the report on page 36 and 38. Non—point sources
contribute much more CBOD 5 to the river than do point sources. The
calibration simulation under predicts CBOD 5 loads in the river. For
example, the total river CBOD 5 mass loading in pounds per day for the
surface runoff, as assumed, is 83 percent of the total CBOD 5 mass loading
from tributaries and point sources. Yet the CBOD 5 profile as simulated
and shown in Figure 8 is consistently lower than the rreasured CBOD 5 in
82
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5.
: e r:ve: for th river reaches below river rulc 70. Figure 9 further
C ?USiZCS t C magnitude of non—point source 1oad ngs to the river as
cCn? aQ to point source loadings.
The last sentence of paragraph S is not very meaningful and grossly
misrepresents the benthal oxygen demand used in the calibration. If one
looks clo e1y at Table 5 and computes the sediment demand values in te s
of mg/i—day it is seen that the maximum demand rate is 3.28 mg/i—day only
in Reach 2. Further ’ore, of the remaining reaches, three have sed nent
d ands of 1.66 to 1.0 and the last 18 have sediment de ands of 0.80 to
0.15. m /l—day. The discussion of sediment oxygen demand on page 29 of
the report explains and justifies the sediment demand inclusion in the
calibration modeling.
The D.0. simulation of September 4, 1973 conditions as shown in
Figure IV—5, Part C, Water Quality Analysis, Charles River and Charles
River Basin apparently includes a sediment oxygen demand of 2.5 gm/m 2 /day.
This rate seems much too high, but may result in a predicted profile close
t3 the mean of measured values if reacration rates are also too high.
Paragraph 9.
The photosynthesis discussion in this paragraph is totally rong .
The calibration simulations as shown in Figures 6 and 7 represent average
photosynthetic oxygen production and respiration and average photosynthetic
oxygen production set equal to average photosynthetic respiration. This is
e:.:plainad in detail on page 32 of the report and is indicated on Figure 6.
Thus photosynthesis is represented only as having a net D.C. production
over a day or having no net D.O. production. No simulations are presented
in the report with “zero respiration”.
The discussion presented in Paragraph 9 of weather conditions :s
no: a complete representation of river flow conditions on September 4, 5
and 6, 1973. The river system car.not be viewed as simplisticly as in
the comments. For example, the streanflow data presented in Table 1 of
the ccm ents indicates that daily average river flows at Charles River
V llaga were higher by 31 percent on September 4, 1973 than on September
6, 1973. However, if we look at USGS recorded river flows on those days
at :el1esley and Waltham we find that river flows were 15 percent higher
and l7 lower, respectively on September 4 and September 6. The cor.Irents
fail to present this further information which indicates that higher river
flows resulting from rainfall in the upper Charles Basin cannot necessarily
be associated with higher D.O. conditions during daylight hours.
In addition, the comment fails to point out or rccogni:e that the
higher DO’s referred to on page 36 of the report occurred predominantly
during daylight hours. Looking at the data further in Appendix B the
higher DO’s on September 4 occurred as peaks in diurnal D.0. variations
-------
6.
cn.th r day, while diu al variations wore significantly lower on
Se zcmber 6. This bears out the conclusion in p3ra;raph 5 of page 36
in the re art that photos T.:hetic D.C. pro ucticn on Septenber 4
exceeded that on September 6. This conclusion is also supported by
the observation that at all but one location peak photosynthetic oxygen
production rates, as determined by the DICIRV2 analysis of John Erdnann,
occurred on September 4, 1973.
Lastly, as shown in Figure 8 and as discussed in the second and third
paragraphs on page 38 runoff in the lower reaches of the Charles may contain
si nifjcant CBOD 5 which would offset its dilution potential, even though
the mpjority of D.O. demand effect of the runoff BOD would not be exerted
until some days later.
Table 1 of the comments contains two errors. First, there is no
rainfall recorded on September 7, 1973 at the Boston WSO location. The
Table indicates .44 inches as being recorded on that day. Second, the
Data Sourac 1 as listed should be dated September 1973, not January 1973.
Paragraph 10 — “Biochemical Deoxygenation Rates”
The background loadings as input to the September 1973 calibration
siulation and the 2000 low flow simulation are about 5 pounds per day
of CBOD . The concentrations of ultimate and 5—day carbonaceous biochemical
oxygen emand, respectively are 10.6 and 4.2 mg/i. This total mass loading
is input to the river only at r.m.76.5 and is based upon the CBOD 5 loadings
measured at r.m.76.5 in September, 1973. This is a natural background
loading and there is no information or implementation plan to indicate
this loading will change by 2000.
As stated on page 43 of the report the deoxygenation rate for the
treatment plant loadings is a normal rate for biochemical oxidation. If
Metcalf and Eddy and/or the C has data available on deoxygenation rates
for advanced treatment plants I would like to review the data for further
consideration of the rate constants.
It should be noted, however, that the rate constant within the range
of .1 to .4 will not affect the results of the modeling analysis to a
significant degree. Copies of simulations pointing this Out are attached.
I see no justification for decreasing K 2 rates in the river between
1973 and 2000. In 1973 the river’s water’ bality was predominantly
affected by non—point sources, in particular below r.m.40. As stated in
Mr. Erdmann’s conclusions as referenced on pages 11—12 and as discussed on
page 38 of the report non—point sources affect the D.0. balance in the
Charles River over many more miles of river than do point sources but to
a zore moderate degree and BOD loads in the river are attributable to
algal mass and or ROD in runoff with D.O. increasing as BOD increases.
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7.
dso. ac they are indicated on page 43 in Tab1 7 th trca i rates
(5ioc ie ical reaction rates) range between .09—.23. These ar not high
races ior streams of low to moderate pollution _I have seen and
c:: erienced. Furthermore, if one does sore simple calcula:ions, it car. b
seen from the data in Table 8 that the Charles River at low flow in 2000
would consist of between 50 and 80 percent treatment plant effluent with
the effluent containing 5.0 mg/i CBOD 5 . This level of CBOD 5 is not analgous
with high quality water or clear rivers, in my mind. Therefore, lower
deo: .:ygenacion rates in the river are not justifiable.
Par graph 11 — Nitrogenous Oxidation Rate
The discussion in this paragraph is not meaningful to the analysis of
the report because the discussion in item 4 on page 56 under Cases A, B,
E, C and H simulations and the D.0. profiles of figure 15 indicate that the
simulation results are not very sensitive to nitrification rate constants
of 0.6—0.2.
With regard to the com:nenc concerning “certain forms of algae” aking
“great inroads upon the aimnonia supply”. Such a phenomenon has not be.en
studied in the Charles River and is beyond the scope of this analysis.
Also, as will be considered under the discussion of Paragraph 12 it is
probably not sound thinking from a water qu3lity protection standpoint to
count on highly variable algal populations, which are one of the Charles’
water quality problems, to mitigate the effects of oxidation of amnonia.
Lastly, I don’t believe water quality simulation has advanced far
enough in the understanding of algal and plant growth and death dynamics so
that anyone could definitively quantify algal consumption of ammonia.
Paragraph 12
The discussion in this paragraph has not mentioned at all the material
presented in the report on page 28 which considers both the Quirk and Eder
and Mastropietro dam reaeration prediction procedures. To reiterate that
material, a comparative analysis of D.O. values downstream of each dam
on the Charles as predicted by the two procedures and cor pared to measured
values indicated little difference.
At low flQw, with an MDC Satellite plant located downstream of the
Cochrane Dam, the Mastropietro procedure gave significantly higher
( 1.0 mg/i), DO’s due to dam reaeration at three dams, slightly higher
DO’s (.2—.6 mg.i) at six dams, equal DO’s at one dam, and lower DO’s
(up to 0.6 mg/i) at four dams. Here again there appears to be less than
significant difference between the two procedures as applied in this
B5
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S.
analV5iS. Fbwever, the r.odel will he odified to pr d:cr P.O. by
as:rop1etro procedure and the impact of the change evaluated ca se thc
NaszropietrO procedure is more logical and was developed from mp .: ca1
analysis of measured dam reaeratiori.
Paragraph 13 — Stream Rcaeration K,
The first paragraph of this comment has taken the work of Tsivoglou
and Neal out of context giving the authors’ reco ’a endations an incorrect
interpretation. Conclusion number 15 in the article referenced in the
re;ort says in full:
“15. Certain limitations of the foregoing predictive trodels should be
emphasized, notably those that relate to scream segments in which rnixiria is
poor. Thus, although the pools that occur as the result of natural
topography are incorporated in the results sut _ arized here, the predictive
models have not. been derived for, and do not apply to, major man—made
impoundments. In general, very small slopes and small rates of energy
dissipation imply less turbulence and poor mixing and, consequently,
relatively low values for the escape coefficient C.”
As can be seen by observing the relationship as given on page 28 of
the report, a low escape coefficient results in a low K, value. Thus the
relationship may be predicting K2 values which are too high for the long
impounded reaches of the Charles.
With regard to the second comment on stream reaeration it is useful to
look at the facts of how and when K 2 s were predicted by the WPC in
Part D — Water Quality Management Plan — 1976 and Part C — Water Quality
Analysis — the Charles River and Charles River Basin.
Page 71, Part D, indicates that the equation of O’Connor and Dobbirts
developed for channels having isotropic turbulence was used with the
relationship (referenced to EPA) for a minimum These were applied
such that the higher K 2 yielded by either method was used in the modeling
in this Basin Plan. Tables VI—5 and VI—6 indicate which K values were
adjusted upward to a minimum value of 2.0/depth.
If we first look at the O’Connor Dobbins relationship as described
by Covar (1976) and Rinard (1976) we see that it was developed and
tested on streams in which velocities ranged from 0.2 to 4.0 feet/sec
and depths from 2 to over 30 feet. Table VI—6 showsthat velocities in
25 of the 33 reaches are between .17 and .001 ft/sec and 18 of those 25
have velocities less than 0.1 ft/see. Also, if we look at the depths in
Table VI—6 we see that most are near the lower limit of the range of
depths over which the O’Connor—Dobbins relationship was developed and
tested.
a’
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0
xe:::, 1oo ing at the EPA relationship (dev 1oped by Hydro;ci nce
unier con:ract to Mitre Corp. and EPA) in Appendix A of S fiuied ‘ath
> :ndelinz , 1971, we see that the reference says chat the reacraciori race
:<7 is equal to a transfer,coefficient K 2 divided by the average dep:h.
“In the lover range, a minimum value in the order of 2 feet per day is
an appr ximace limit” for the transfer coefficient. Thus = 2.0 ft/day
is the minimum reaerat ion coefficient predictable by this method. h
There are two major deficiencies in this relationship. First, it
is not logical that all streams of the same depth have the same reaeration
chracter stics. Second, the more recent work of Tsivoglou in icaces
ch3t reacration is not directly related to depth, but is only influenced
by depth as it is related to crcss—sectional area and time of flow for a
particular scream geometry.
Now, if we look at reaeration rate coefficients as developed.iri
Part C — Water Quality Analysis Charles River 1973, 1976, we see on page
25 that the estimated values of 2 on 9/4 and 9/6 are considerably lower
than those of Table VI—6, Part D in sixteen of the 33 model reaches. As
computed in Part D the 2 values in sixteen river reaches are higher when
river flows are lower, when velocities are lower and when depths are lower
than in September 1973. This emphasizes inconsistencies of the O’Connor—
Dobbins relationship and the EPA relationship in reaeration prediction.
The last part of the Stream Reaeration comment suggests that “alternative
methods of computing 2 which have been developed for conditions more
similar to the Charles River should be investigated as part of a sensitivity
analysis.”
I agree that methods of computing ½ which have been developed for
depths, velocities and flows similar to those of the Charles River should
be used in modeling the Charles. This is precisely why the Tsivoglou—Neal
relationship was used. Covar (1976) and Rinard (1976) have examined the
conditions under which relationships by O’Connor—Dobbins, Churchhill, Owens
Thackston and Krankel, and Tsivoglou and a1lace were developed. Their
work reveals that none of these more prominent relationships were developed
for velocities less than about .2 feet/sec.
Tsivoglou and Neal have tested, in their Energy Dissipation ?Iodel
paper, the accuracy of the predictive r.odels of O’Connor—Dobbins,
Churchhi].l, Langbein—Durum, Thackston—Krenkel and Owens by comparing
predicted K 2 ’s with K 2 ’s measured by tracer studies. “None of the
models tested proved capable of predicting reaeration capacity within
acceptable limits of error.”
B’?-
-------
10.
I would be happy to review any predictive procedures for uh ,ch
e: alr an Eddy and the ‘DC have information describir.g the r develop—
nenc under velocity conditions sinilar to those of the Charles River
and based U O actual tr3cer ne3sur_:. :f r 3eration.
Para;raph 14 — Photosynthetic 0>:ygen Production and Respiration
As described in the report on pages 31 and 3 photosynthetic oxygen
production and respiration rates used in the September 1973 calibration
simu1at on are those developed by John Erdmann utilizing his DICURV2
model. Thus, the K 2 1 s used in deterrtining the gross rate of photosynthetic
ox; gen production via DICURV2 are those estimated by Mr. Erdnann and
reported by the Division in Part C.
r— K 2 1 s as predicted by the Tsivoglou—Neal relationship were not used
‘with DICURV2 to give new photosynthetic oxygen production rates for
incorporation in the calibration simulations of the report because there
was no purpose to do so. It would have the effect of giving higher oxYgen
roduction rates which would raise the entire solid line profile in
Figures 6 and 7 of the report. This would indicate that the STREAN model
with these higher photosynthetic oxygen production rates more closely
predicts axiium D.0. as measured on September 4—6, 1973 than it does
mean or minimum D.O. as measured.
;ith regard to the comment concerning “future projected conditior.s”,
there again is evident an incomplete review of the report. Page 57
last paragraph describes a low flow simulation in which the peak
photosynthetic oxygen production rates are incorporated. This sinulation
as shown in Figure 16 indicates that photosynthesis can cause near saturation
D.O. conditions throughout the river. However, the discussion points out
that this source of oxygen “occurs only during periods of sunlight, is not
reliable and requires abundant algal populations to sustain it”. In this
case, as in the case of algae utilizing ammonia thereby lessening oxygen
consumption in oxidation of ammonia in the river, a water quality problem
(high algal populations) should not be considered as a reliable oxygen
resource to the river.
Paragraph 15 — Conclusions and Recor nendacions
As explained in the previous comments the major differences between
John Erdnann’s September 1973 simulations and those of this report are
in reaeracion rates and sediment oxygen demand rates. D.0. simulation
results in the report show a somewhat higher D.0. profile for the September
conditions than do Mr. Erdmann’s (See Attached Figure IV—5 from Part C—
I PC, as modified) I believe that the work in the report properly represents
the oxygen resources of the Charles River whether or not it is “unfavorable”
to planning for utilization of the river for wastewater assimilation after
advanced treatment such that some eighty percent of the river will be
wascewacer during low flow conditions.
-------
1 —MOTIIER UK. OIVEflSIOfl
1 —SJW.MILL 01<.
I r t .ICIIDQ’.’,
L I 5IOPJY
L J 1 —UCAVFfl
T
(‘2) (? i( t) •‘) ‘ )
DISSOLVED OXYGEN on SEPTEMEi [ R 1, V .
CHARLES RIVER
C
rn
CM
z
w
(9
>-
><
0
0
IL l
>
-J
0
(I)
U)
a
RIVER MILES
sampling itations
-------
11.
? :es 55—57 of zh rc?3rt ex:i3ifl why alternative st ac r 1oa :- :
an aiter iacive river c dt:ions were si:iulated. If ercalf a Ed nd
: e :- jc will recall a :ing with the PC and EPA at as:b r:’, . c
.;u; sz 10. 1977, it was c;reed at that time that year 2000 low flo :
sinulations would include alternative wascewacer 1oad n and r:ver co d z:c-. -.
slmula :iOns.
The scor:ng systern was developed to evaluate the relative differencc
between alternative simulations and was applied uniformly to all low flow
simulations.
The following comments relate specifically to the four reco iendations
onthe last page of the iemorandum.
The low flow simulations have been tested for their sensitivity both
within the work which is described in the draft modeling report and in
continuing modeling subsequent to completion of the draft report.
First , within the report simulation Cases A B, and E demonstrate the
effects of varying the nitrification rate constant from 0.6 to 0.2 day —1.
Figure 15 on page 61 and Table 12 indicate that the simulated D.O. profile
is not vety sensitive to varying the nitri.Eication race constant from 0.6
to 0.2 day . (Cases All and Eli). Simulation Cases G and H demonstrate
the effects of the sediment oxygen demand. Figure 15 and Table 12 point
out that even with zero sediment oxygen demand a D.O. level of 5.0 mg/i
cannot be maintained throughout the river. Simulation Case D demonstrates
the effect of having a net D.0. production due to photosynthesis at the
rates of September 4, 1973. This is discussed on page 57, last paragr: -.
Second , since completion of the draft report additional sensitivity
test simulations have been run. Deoxygenation rates of treatment plant
discharges (Kjp) were set at 0.4 in the report; rates of 0.2 and 0.1 have
been tested with conditions of Case E simulations as defined in the re ort.
These lower deo: ygenation rates yield a higher ultimate or initial CRUD
•thus producing significantly lower D.0. profiles than with a rate of 0.4.
This is sho in the attached printouts of the low flow simulations.
The sensitivity of the simulated D.0. profile to CBOD 5 loads in the
uniform distributed flow was tested under Case E conditions by reducing
the CBOD 5 loads to 1.0 mg/i in all reaches. This resulted in no appreciable
change in the D.O. profile as indicated in the attached printout.
In order to test the significance of the oxygen demand of the treatment
plant loadings a simulation was run with CBOD 5 loadings at 1.0 mg/i and with
N3OD loadings at zer This resulted in a D.0. profile which reached minimum
values for D.O. of 3.5 mg/i behind the So. Natick Dam, 3.7 mg/i behind the
Cochrane Dam and 4.9 mg/i behind the Silk Mill Dam. (See enclosed printout).
This points out chat the plant loads are a significant oxygen denianding source.
-------
1,
:: 1t:Dn rates were duubled as input to E s 1it1c ns t3
test th :r se sitivi:y. D.0. profiles resultinS fron this reveal :ha:
reaerati is a major deteri inant of D.O. levels in the Charles River.
H ’wever. even with doublthg of the rates predicted by tr.e Ts voglou— ai
-ethod, there re 3ins long stretches of river with D.0. levels very mUL
below 5.0 r ;/l. (See enclosed printout).
Comi ent Prepared By
Allen J. Ikalainen
-------
TA5LE I
Tthe of Travel C 1ibratiort
Char1 s River April 30 to May 4, 1973
FL0 ME?.SLR 1ENT RIVER FLO J MEASUR.ED2J SI 1ULATED2J
LOCATION cfs TI 1E OF TIME OF
•(USGS GAGE) TRAVEL, hours TRAVEL, hours
C . LES RIVER
VILLAGE—r.z . 34.3 545 129 113
:.aT:- I—r.m. 18.3 463 164 145
E..LESLEY—r.i. 12.0 453 184 163
it Average of mean daily flows for 4/30 through 5/4, 1973.
Tioe of travel between r.m. 76.5 and gaging stations.
-------
R f e r en cc S
Cov r, A.?.; “Se1ectin the Proper Reaeration Coefficient for Use in
1 ter Ou 1ity Models’; Proceedir.;s of the Conference on Envircn en:al
del g and Sit u1ation — April 19—20, 1976, Cincinnati, Ohio; EPA
603/9—76—016.
Rinard, I.H.; HCT DOSAC. River Oualitv Simulation Model, User’s Manual ;
Falcon Computer Technologies, Inc., New York; Janua:y, 1976.
13
-------
L TIC CF S SITIVITY TEST SL iL TIO S
The besic si J. tton upcn ..hlch the tcsts ere made is Identical
to :L t of Case E conditions as described in the report (page 5l-Ta ie io)
Inthis case all plants era disc rgin at 5.0 /i CBOD 5 and 1.0 r..;/1
Sedizent oxy;cn de nd is included as in the Sept. 1973 calibratlcn
sir. .atIoo and in-stream nltrification rates are 0.20 day 1 (bese e).
JC ;o. SSITI Tf TEST
05 CLOD loacinj in ifcr 21. .flCf Is 1.0 n;/l.
356 K 1 of plant wastes is 0.20 day (base e).
of plant wastes is 0.10 day 1 (base e).
3 J 1l plant loadin&s to the river are 1.0 ii only.
353 In-stream reaeretjcn rates are doubled in all reaches.
-------
• ‘ ‘• r ’
—— .— . __fl I.
DIS LVED o:i GEN iODELING
C: A LES RIVER, r .A SACH JSETTS
A significant part of the matertal presented in the report
was developed by the Commonwealth or Massachusetts DivIsion of Water
Pollution Control (DW?C) as part of Its Charles River Eas n Water
uality ianagement Plan. Some of It was acknowledged explIcItly an
some was not. It would serve the Commonwealth and the readers if
he material that was taken from the DWPC work were referenced ex-
plicitly. On the other han , the departures’ from the 3asln Plan and
the basis for them should also be Identified because the asIn Plan
is presently the approved document for pollutIon contrcl and waste
load allocations in the Charles River BasIn. Therefore, any changes
ust be explicitly shown so that the Plan can be amended accordIngly
where such changes are adopted.
The report Preface identifIes the purpose of the report as
beIng “part of the wasteload allocatIon, facilItIes plannIng and en-
vironmental impact assessment procedures underway” in the Eastern
: :assachusetts MetropolItan Area (ET &k). However, wasteload alloca—
tlcn Is the responsIbIlity of the DWPC through Its basin plannIng
process for which a resulting approved basin plan exists for the
Charles River Basin. FacilItIes plannIng wIth its envlronnental
impact assessment, on the other hand, Is the responslblllty of the
C and the E! 1A municipalities. In the case of TWC, thIs process
is not beIng carried out at this tIme due to the prerequIsIte EIS
being prepared by the EPA. The document under review here Is a part
of the EIS and not any of the above.
The report Conclusions and Recommendation do not follow the
data base reported upon ln dIscussIng treatment relIabIlity and
economic and environmental impact costs. These are not addressed
In the report itself. As an example, a recommendaticn is made to
llmit future service areas without an analysIs of alternatives or
ccnsequences, yet a conclusion is also made that septIc leaching oc-
curs Into the Charles RIver.
The following review has not included a check of the model-
ling formulation and the input data base whIch should be made. As
examples, some of the rate constants used In the mcdel are tempera-
ture corrected while others are not, and the Mother 3rook DIversion
Is Incorrectly located in the runs representing projected conditIons
whereas It is correctly located for callbratlon runs.
In evaluating the calibratIon effcr:s and flnd!rigs, it nust be
understood that hydrologIc condItions were quite varIable durIng t .e
calIbration erIod, that data fcr discharges used In calibration are
for conditions one year later than the stream water qualIty survey
-------
sed, and : -.at a si car.; component of the input da:a baze used
‘or cal!bra:±cn Is assumed.
During the water qualIty survey period used for calibration,
stream flows were ten times those of the low flow period. During this
time, the average daily flows varIed by more than thIrty percent as
a result of signIficant upstream raInfall that occurred just prlcr
to the survey period. The time of flow in various parts of the river
Is a significant modelIng parameter and, in thIs case, it was devel-
oped from relatIonships formulated for freely flowIng streams wi:hcut
dams. The constants for this relationship were developed under flow
conditions that were about three to four times those during cal bra—
zIon, but about thirty times those later used for modeling of prc—
jected future conditions. DurIng the extremely low flow regIme In
an area with impoundments the time of flow must also incorporate the
hydraulIc efficiency of the impounded areas. WIthout such an analy-
515, a larger time of flow may result.
With respect to the waste discharges used, the dIfferences in
operating procedures between 1973 and 19714 must be revIewed. For
example, ifl 1973 Cott Corporation discharged its wastes to the MIl—
lis wastewater treatment plant. In 19714, however, It dIscharged
dIrectly to Sugar Brook.
A number of values Incorporated in the callbratlon process
were assumed. Assumed values for nonpoint sources total to 140 percent
of the total wastewater point source discharges. SimIlarly assumed
are sludge deposIts which are formulated to take up as much as 3 mg/1
of dissolved oxygen, or nearly 40 percent of the river T s oxygen re-
sources.
Another sIgnificant factor in the calibration is the photo-
synthetic oxygen production and algal respiratlon phenomena. As
modeled, In some locations of the Charles River, this, combined with
sludge deposits mentioned above, can take up as much as the entire
riverTs oxygen resources. The basic fcrmulatIon assumptions of this
and other parameters are dIscussed later. Here the dIscussion cen-
ters around theIr use in the calIbration process as presented on
pages 32 through 36 of the report. Figure 6 (page 314) presents the
sImulatIon of zero photosynthesis and zero respiratIon (dashed lIne)
superimposed on the range of four measurements (two night tIme and
twc day time). WIth zero respiration, the simulatIon should show a
favorable DO conditIon as compared to DO measurements at night time
which Include resolration. As shown on FIgure 6, the sImulatIon
generally falls below the measurement range IndIcating the need for
a review of the modelIng parameters used. A further need Is to re-
view weather conditIons surroundIng the 1973 survey period to insure
that all factors are consIdered In the evaluation of the photosyn-
thesis and algal respiratIon phenomena. For example, the weather
conditIons discussed on page 36 of the report do not fully cover the
survey condItIons as shown in Table 1. For example, the favorable
water cuality In the Charles River on September 14 can also be at-
tributed to its Increased lcw resulting from the September 1 rain-
fall as well as favorable sunlIght condItions on that day.
-------
TABLE 1
AVERAOE DAILY RAINFALL AND RIVER FLOWS IN TIlE ChARLES RIVER BASIN AREA,
SEPTEMBER 1 TO SEPTEMBER 10, 1973
Location
Boston WSO
Blue hills
Fram Ingham
Walpole
West Medway
Franklin
Milford
Charles River
at. Charles
River Village
98
115 120
TIme 1 days in
- IF__
T(2) ‘r
1.30 —
— .18
— .08
103
• 39
.78
.80
— 1.80
.68
99 125
(1) no ratnfall
(2) trace
3ource i:
1. United tate3 Department or Commerce, U.S. Weather Bureau Cilinatological Data: Iluw
1!.ng)an(1 , Vol. 85, No. 1, Asheville, N.C. , January, 1973.
2. Un I Led St.at;e Department or the Tnterloi’ , Geol ogica) Survey, Wa Ler Resource flaL;i rni•
Manrmchuaetts , New hlaiiipshi re Rhode 1 ;]amid 1 Vermont , Uo ;toii , Maas . , 1 9(3
I. -
Item
Rainfall
(inches)
River Flow
(cfs)
September. 1973
.111 1 .1 11 1
• i i —
2 3
_(1) .01 .02
— — .07
.27
.60
1.311
• 36
- - 13 9 i eT
116
88
‘I
1311 — I ‘‘•
-------
: h&—:cal :x nation sates
In the co putcr modelIng effcrt, deo: nation rate :cn—
stants, K 1 , are input in associatIon with the wastelcad chara::eris—
tics of t e fol1cw ng fIve areas:
1. background K,
2. stream K 1
3. treatment plant dlscharge K 1
L • tributary K 1
5. uniformly distributed flow K 1
W th n the model, all of these K 1 rates, except the stream K 1 , are
used only to compute the ultimate BOD. All decay occurs at The
stream K 1 rate. ThIs results In the following ultimate 30D concen—
trations entering the Charles River in the year 2000:
Source tilt. SOD m /1
background 10.7
treatment plant 5.8
tributary flow 5.1
uniform flow
above r.m. 6.0
below r.m. 111.1 9.0
The background conditions reflected above were used in bc:h the
1973 calIbratIon run and the 2000 low flow runs. These loadings seem
exceedingly high, particularly for year 2000 condItIons.
In regard to treatment plants, in the year 2000 simulatIons
the report used a decay coefficient of 0. 1 0/day. SInce these plants
would be advanced, the organic material remaInIng wIll be resIstant
to decomposItion and therefore a lower K, rate can be justIfied.
As mentioned previously, all deoxygenation is carried out at
the stream K 1 rate. In the computer simulations, the same K 1 rates
used 1 n the yea 2000 runs as In the 1973 calibratIon run. I;
nas oeen shown that as water quallty cor.c t1cns imprcve, tne ae x —
genation rates decrease. Therefore, with the anticipated upgrading
of the Charles River water quality, K 1 rates should decrease under
2000 condltlons.
-------
: :i:o:encus O:.:i a:icr. sate
In the modeling effort, the report assumed the :r:n:us
decay rate to be .6 day l (or .2 day —1 in some cases). The 0.6
value is extremely high. All treatment lants consIdered in the
Investigation discharge dlslnfected effluents to the river. Chic—
rination effectively kIlls all nltrifylng bacteria in the discharge.
Effluents not carrying theIr own seed of nitrlfylng organisms are
sutject solely to the natural seed occurrIng In the rIver water or
ifl attached growths on the bottom and on submerged objects. In
addition, ammonia is a prime nutrIent for certaIn fords of algae.
; iI:h chlorinatIon of effluents, these algae will possibly make
great inroads upon the ammonIa supply and thereby reduce the amount
of ai= onia avaIlable for oxidation by nitrlfylng bacteria. Also,
the range of oxIdation rates found In the reference cIted by the
report is actually .1 to .6 day —J..
Dan Reaeratlon
The report chose to represent this Dhenomenon by arela:i
ship developed by Quirk and Eder. This relationship was develcped
to represent reae ation through a vented turbine and not for free
fall over a dam. Due to the lack of data, the authors used a linear
relatIon between Fd(Q) and Q which passes through the origIn. This
assumption results in low reaeration rates under low flow condItIons,
which is not correct for a free fall over a darn when more cf the
overflowing water mass is exposed to the air and subject to reacra—
tion. A representation of darn reaeration WhiCh relates reacratlcri
to the height of fall over the dam, such as that developed by
Mastropietro or Foree, would give a better representation of actua:.
darn reaeration under low flow condItIons. Such a formulation was
also used by the DWPC in their Basin Plan.
Stream eaerat!on K 2
In—stream reaeration was computed using a relationship deve.—
oped by Tsivoglou and Neal. The relatIonship states that the
reacratlon rate in a reach Is a functIon of the chanze In water sur-
face elevation along the reach and of the time of travel :hrcugh the
reach. The authors caution users of their formulatIon In applying
It to rivers whose physical characteristIcs are predc•mInantly con-
trolled by dams.
As an example, for the projected future condItIons, the K;’s
computed under thIs method are on the order of ten percent of those
used by the DW?C In a number of reaches. Therefore, alternati;e
methods of computing K 2 which have been developed for condItIons
more similar to the Charles River should be InvestIgated as part of
a sensItIvIty analysis.
-------
Ph:::Zi ::y e ?‘ uc:ion a d :irati r
The e:hod of accountIng for pho:o yr ;hes s ar .d re ; ra: .:r.
used in the report modeling was based on work perfcr ed by : p:
using the systematic diurnal curve analysis. The basic fcaticri
is:
= K 2 (C 5 —C) ÷ P —
ir. whIch:
DC
= the tlme rate of change of DO concentration,
= the rate of atmospheric reaerat on,
K 2 = the atmospheric reaeration constant,
= the DO .saturatlon concentration,
C = the DO concentration,
P = the gross rate of photosynthesis by the community
of algae and plants in the rIver locale,
= the gross rate of deoxygenation, includIng res-
piration and nitrification, by the entire community
of organisms In the river locale.
In 1973, the IWWPC conducted DO measurements on the Charles
iver. These measurements, together with the determination of K 2 ,
resulted in a relationship from which P and R could be determIned.
As can be seen, the value of R — P is dependent on the value of K 2
used i.n the analysis. The value of R, so determined, is a total
deoxygenatlon rate which Includes C3OD, NBOD, and sedIment demand.
Therefore, in going from the total deoxygenatlon rate to that rep—
resentati h of algal respiration, all other oxygen demands must be
subtracted. This process Is in turn a function of the CBOD and OD
decay rates and the sediment demand.
In the model calibration process used in the report, the values
of photosynthetIc oxygen production and oxygen consumption due tc
algal respiration appear to be those as determined by the D PC using
their estimation of K 2 t s. Rowever, when the photosynthesis value5
were Incorporated into the rIver basin model for callbratlcn and ftr
sImulatIng future projected conditions, the report used the lower
values as dIscussed earlier. ifl addItion, under the future prc ec:ed
conditIons, the input values of algal respIratIon are the same a f:r
the 1973 calIbratIon runs, but the values representlng phozosyntbe:I
oxygen production have been greatly reduced. If anythIng, it would
seem that the photosynthetic oxygen production would Increase under
the culescent low flow conditions. The basIs for the manipulatIon of
D PC’s data In the 1973 calIbratIon run, and the basis for the ras—
:10 reduction in :ho:csynthetlc oxygen production while cxy en
sun:tIcn by algal respiration is not reduced in the pro ec;ed
cbndi:ion simula:ior.s; need to be determIned.
(00
-------
._J__
The iS epcr: has resen:ed res’ it of cde ca:ra: :
forts for the Charles River DO resources which are s lar :c res :
of a lIke effort by the DWPC 3as±n Plan; however it uses f .ca :—
ly dlfferir.g factors. In the EIS Report, these factors are selec:e
on the sIde of an unfavorable oxygen resources represenatlcn In zne
river.
The calIbration effort also includes a number of assumed val-
ues whIch have a sIgnIfIcant impact on results.
Several alternative projected future condItIons, as well as
some changes in factors, have been simulated. The basis for their
selection is not exDlalned. A scoring system was used to measure
:ne alternatives whIch appears to be rather arbitrary.
We recommend that:
•a thorough evaluatIon be made of each factor and each
assumed value,
•;he range of confidence for each factor be developed
on the basis of present data,
•a sensitIvIty analysIs be conducted to identify those
values havIng a sIgnifIcant impact on decIsions and
requiring a narrowIng of their confIdence range, and
.Investlgatlons, IncludIng, if necessary, fIeld mea-
surements, be conducted to achIeve the necessary
narrowIng of that confIdence range.
t°I
-------
I UN TED STATES ENVIRONME 4TAL PROTECTiON A r
.1
J F E EW FE E &L eUILONG. BOSTON.
July 22, 1977
I’s. Libby Blank
Director of Environ enta1 Planning
etro o1itafl District Corr nission
20 Somerset Street
3oston, 02108
Dear Ms. Blank:
Thank you for your letter and comments of July 18, 1977
with regard to the Charles River water quality rodeling.
e will respond in detail to each question raised by
Metcalf and Eddy by August 10, 1977.
Please understand, ho :ever, that the computer modeling
of the Charles River which we are performing is based
upon our understanding of the Charles River and our
determinations of proper mathematical representazicnS of
river processes affecting water uality. Thus, our
final model simulations il1 incorporate any necessary
corrections to the model input revealed by 1etca1f and
Eddy after considering each of their com ents.
I have attached for your information a copy of the letter
which we sent to Dover, Framingham, riedfield, Natick, eed-
ham, Sherborn and ‘Te11esley requesting their participation
in an expanded site selection committee. We would welcome
your participation with us and the cor unities in the site
selection process. We will notify you as soon as we re-
ceive responses from the communities and set tho first
meeting date.
Sincerely yours,
£ Y k\CAL L kA\&p
Mary E. Shaughnessy
Environmental Impact Analyst
-------
S. I
; UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY FEDERAL BUILDING, BOSTON. MASSACkUSETTS 02203
Au unt 5, 1977
t... r ibby Blank
!)lr’ctOt oC invironi ental Planning
iLr( 1 iO1Lt .)fl t)iSttiCt Cc . issiOn
•‘,) ,u,ILtSCt Stre?t
I ;t gut, i\ i2li 8
t) L M . i3lank:
This is in response to your letter of July 18, 1977 to tis.
;•iary Shaugnnessy of tie viri,j .nr ntal and Economic Ir act
OLLic’ concerniny tn? water ‘ uslity r ode1ing of the Charles
River and effects of tn o: ; 3 — i ries aste ater
treatment plant. I ritin; tc you directly because I am
the person doing the modeling. 44’ r .iit 5 re used by the
cnvironn ntal an cor o ic Impact Office and their
consultants in oerfor i j . . ‘i. .. - t: i zsessment of
the pro7os d tr tn n . alternatives for the i• C system.
First, I will revie4 ou j.1 i ” ent in tne C.arl F .ver
i odelin’j and tn n res?c. i to the rjuestions by i etcalf and
Eddy, Inc.
In June an Se te ber, 1973, the assachusetts Division of
eter ?ollution Control, ( D C) , conducted water i 1it 2 ’
surveys of the Charles River between ilfori aterto4n,
assachus’ tts. .)ata fro,i these surveys was used to set u2
trie stream model of the ;: .•;pC Lor simulation of water
qpalitj ; t•. i .•:i )urin the June an E cpte: .ber surveys.
The strea i ocie1 is that :.escriied in Syst :i5 \ n 1ys s for
ater Poll .iticn Control b uirk, Lawler a 1atus y, June
1911.
iir. John Erdmann, fornerly of the .1D. PC cerfor.r i the model
set u2 ai.I i!1’J1ation of the June and Se te ber survey
conditions, a procesa tcr. ed model ca1i L tion. At tne
request of our -:n ,ir ntal an3 Economic I. pact Office and
with the cooperation of ;•ir. Alan Cooper ar. of the ID.S?C, I
obtained tne Charles Riv2r m .]’:l s calibrated by Mr.
Erdmann and d. ve1op d a sirrulatiOn of the Charle. RLv2r
unoer 7—day, l i—year recurring low f 104 CI)I1LIIL1OflS for
with dater quality standards. This si 1 ulatiori
was done using the PA version of the stream model progra’
which is analaQous to the i . D. PC ctrea:n model pro rarn.
At the ore5 nL ti r.2, the modelin j is being done with the
steady—state option of the model and we are si. ulating
(03
-------
aitcrr. t ve tre t ?nt plant locatior. ar.d io :n cr
criL1C L’ r cju. lity condlticnz. The .ty—St.e :
is be1r u3e5 because tne port Ion of tnc 1rOU i pr re .
L• oiurr. 1 Ji. s )lved oxygen v riat on due to
oLo. ynt 1OS15 Was found to be incorrect. Ti5_nOJ Jj
snould be cu,n.:ilcted by the end of tne month and the final
results will b rejorteJ in detai —t afl concerne p3rtie .
Now, fl respondin to th rjuestions by Metcalf and Eddy,
inc., I will comment on each as presented by them.
QuestiOn 1: Projected Upstream water Qua1it ConditiOr.S
Water quality conditionS upstrea of the iouth Natick
Dam, .5 ;i ulated, are tho5e resulting from stream
conditions as we predict them to be and e5tim e
wtc4ut’ r loadings from th’ various treatment plants
discharging to the rjv’ r in the year 2033. me
wastewater loadings for ijitord, the proposed Charles
River Pollution District, rer tham State School.,
NorfOlk—. alpOle i CI and :edf eld—:1illiS are tfl.p j
estimated to be disc’ ar’jed with the respective
treat! ’1er r . )l nt configurations producing their highest
quality effluent achievaole. Loa 1r Js ani f!o. were
deterrnine.i by c e 6nvironment3l .: essment Council,
Inc. and Greeley and Hansen, Inc. after revie ;ing
information on tne Eacil ties currently being planned
for the various co nmunities. Results of rnodeli’g ur. cr
tnese conditicns indicate that it will be very likc-ly
that certain stream reaches upstream of the South
Natick Darn will not meet water . ality standards for
dissolved oxygen under year 2000 conditions. riere—
fore, it is erroneous to assu:ne t &c water quality
standards for dissolve I o y;9n will be met under
critical low flow conditions in .ll upper river
reaches. -
Question 2: Projected astew ter Flows
The anticipated Medfield— illiS facility was initially
simulated witn a waste .zat!r flow rate of 1.5 million
gallons per d y (ngi) beraj e that is the desi;n flow
capacity of t e existinj ?ie.ifi li treatnent plant. The
proj ecte 3 t ter flow for b t.i co.n uriities c3rb1ne
in the year 20C is estimated to be 3.0 nyd. Tne model
has been •:. ivjed to reflect t ’ etfects of the entire
3.0 mgd.
Question 3: Stream Reaer t1on
In reviewing the calibrated nodel by Mr. Erdmann and
t04
-------
triO s 1ifie : i’: re c’te i t e 1976 C:ie
River ter n:’ r• nt ?1 r’. it
seen ti at tne re.crt tion cocffic . r.t as co tec
the O’Connor—Dcbt :ns 1sotrc ic T -h ii- ce relation .-.i .
Tnis relationenip is most valid for use witn strea s
having aeptns of 7.3 to 12.3 feet 1L) : l ’cit es of
ø.5 to 2.5 feet p r second. Under con i ons of
10—year recurring low flow the water c3eo .hs iQny t.- e
entire river are co; 1 puted by the model to be between
1.0 and 10.5 feet 4ith velocities of C.C5 to ci.55 feet
per second. Thercfore, the Tsivoglou—:eal ner
Dissipation re1at on hip was used to cc pute the
re eration coefficient. The re3.stionship is valid for
str f.low and ss ci t d ie tns and velocities in
ran je of 1.0 to cubic f t per sscond, which
icludes th’ ran’Je of flows along the entire har1es
River duriny 1o flow conditions.
The Tsivoglou—Neal relationship includes the change in
water surface eie iation along the 1on; tu ina1 stre
profile, the time of flow within the s re r and a
coefficient tern related to flow rate. Reaeration
rates itIiin each river reacn ere co te using the
proper coefficient for stream flow, the cnanye in water
surface elevation as taken from Coros f n.iieers
profiles of the river at low flc and tne tir e of flo
as co.nputed by the r odel. These and o:i r terms for
river reaches 17 tnrough 22 are snown n tne attacne5
table.
Regar’iin’j etca1f and Eddy’s cor ent on the “choice” of
reaeration coefficient values and ass tions of
sediment oxygen der.and rates; the reasration rates are
co puteJ ac by reach as pr vi us1y explained ‘. hil
sediment oxygen dend rates zere ass ei cori i3er n;
available data. 3. :j a Cflt demand is assu eä to
present in the ri’. er within reacnes upstrea o the
da!as and where strea r. bo to material analysis
indicates organic sediment is present. As sho..:i in i C
attached table, sedi 1 i ent oxygen demand s ioc t
behind the Soutn tick and Coczrarie a s and in lo er
velocity reaches.
In the table, note that the reaeration coefficients for
reaches 20, 21 and 22 as lnjUt in the si:nulations
reviewed by i’ietcalf an i Eddy were in error as computed
and ha ie since been corrected.
Question 4: Dam Receration
The value of the model input variable for dam
-------
rcacratlon ( ) c.t the Sc t . iatick D wc-r.
rj ifl3llj L J into the model as O. i6’-. Tne Va1 e
shOUld fl3VO en 1 .UG88. odel input has beer
correCt2 t value. The discrepancY CC’’J e fa
the 1 r’j difference in dam rearation between tne Sout
NatiCk and Cachrarv.
Question 5: DeoxY enatiOn Coefuiciertt or witrogenous
qen Denafld
The modeling described in the Charles River 3t r
Qu.311tY 4anage eflt Plan is a sinplifie l roceauro wr.icn
considerS car )3flaC )U hiocncnical oxygen deina:;i ni
nitrO flOuS Oxy cfl aemand a one proc’ uccurrin a
one rate and t ref.orc both rate constants must be tn
same. stream model co z 1icrs the’5e )roccc:c5
separately as they actually occur in nature. The
deoxy.3cnation coefficient for nitrificatiOn of .6O at
2(°C is a hign value which results in the ammonia
concentration simulation cor pariflg e11 with the
Septe’ ber 1973 a. imonia concentratiOns as rneasurei in
the river. Also, the higi v U’? iS logical
asc’i;nptiOfl consider in tnat when the four major
treatment plants on t e river ar operating as advanced
biological syst .r s the river should continue to have a
well estabiisfled population of nitrif n J organiSmS.
Because the r.adel is well calibrated for ar. on1a and
high po7ulatiCnS of nitrityir.’3 organi3• S can be
expected in t e river in the future, the assuied rate
of 0.6 is valid.
In summary, the modeling is conticing as explained herein.
when final results are availa)le, tney will be sent to all
involved parties for review.
I hope this explains my position with regard to the ode1ing
and s ou1d you have any further uesti0flS please do not
hesitate to Co!ltCCt me.
Sincerely,
Allen .3. Ikalainen
Acting Chief
Systems Analysis Branch
cc: h. ShaughneSSY EPA
A. Cooperfl fl. 1) PC
A . Gitto, EPA
ij . Vittands, iietcalf and Eddy, Inc.
L. Polese, MD PC
R. Chapin, EAC
-------
c; RL’S RIvr.R ‘TDEI,
YSTE S VM.YSIS !3RA.CiI
CP,\ - RZGIO:; I
RIVFR RC1 CIIES 17 TIIRU 22
Low
Sediment Flow Time of ! Change in clan Reacration ”
Oxygen Demand Velocity / Depth Flow of water Surface Rate
Reach ’ Grams /m /dav Ft/Sec Ft. Hours Ft. — Day
17 3.46 .07 4.8 10.6 0.5 0.06
18 3.46 .08 5.1 53.6 2.0 0.05
19 0 .19 2.5 12.5 0.25 0.03
20 1.38 .12 7.5 56.2 1.45 0.04
21 0 .45 2.8 5.2 1.0 0.27
22 1.38 .32 7.0 14.9 2.0 0.19
a/ Reach 17,— flogastow Brook to Medfielcl hospital — 0.5 miles
Reach 18 ‘ ec1fie1d hospital to South Natick Darn — 6.7 miles
Reach 19 — South Natick Darn to Waban Brook — 1.7 miles
Reach 20 — Waban Brook to Cochrane Dam - 4.8 miles
Reach 21 — Cochrane Dam to Chestnut Street, Nccdham — 1.6 miles
Reach 22 — Chestnut Street, Needham to Long Ditch Inlet — 3.2 miles
h/ Proposed MDC plant located at head of Reach 18
c/ Coefficient for Tsivoglou relationship — 0.060 @ 25.5°C
-------
:, —: i
—
irector of vironnerital ?ann!ng
: •:e:rcpcli:an District C.ission
20 So erse: Street
cs: n, : .: o2loS
— ‘—.
. .•.s. Lan .
: res:cnse to the recuest by ! DC we have ccnduc;e a brief
‘eview of EPA’s ZIS Consultant’s Charles iver odelin efforts
associated with the location of the Middle Charles Satellite
; •:ast •;at r Treatnent Plan:. Spec fical1y, we have reviewed the
f:llc :in dccu en:s:
a. A andu fr r. r. F. i. Thapir. of the Environ-
en:al : ess en; Cou’.cil, IflC. (::s Ccr.sul:anz)
c Mary Sha hnessy of EPA, describing six ode:.irg
cases and reccending that the discharge Cf : e
sut ect tlan:be located as far u s:rea:- of the
cu n as tcss: e.
:. Cc zuter ou::u; frc the cdeling of Case 3A described
:i the I Consultant : :e cran um.
r ana:.ysis has focused on the assumptions and parar.eters used
in :ne cc ;uter mcde.ing effort. :n :h s review, we have assumed
:na: the :ara e;ers used in Case 3A are the same as those used in
:he ctner five :ases described in the EIS Consultant e orandtu
ma: ftr the :asis fcr tneir reccru endation. cwever, ins ec:i:n
:c :_c: :— : Cc’ s .l:a ’ t LercranC -‘a’ es :-_s as—
s::icn : stimable s:ecifically because of the peculiar :lc:s
for Cases and 3 between river •iles 39.1 and puter
runs for other than Case 3A were not supplied for review. ase
our initial review, we raise ques:i n in the fcllc ing areas:
1. Prciec:ed cs:rea a:er ality cnditicns . in a
six of me cases considered oy me E5 C:nsultant, seri:._s
violations of Class :a:er cuali:y standards are :rc i
f:r several of the se;nen:s u:strea cf the South ::a:i:
_a i: ng me rea:nes :nne::ate y upstream c: : e
da :bere a 20 of :er is rc , ec;ed as a result of
s:rean effluent loads, i.e. • cxci’ ing the i •:ia :e Cha:’ss
:lan:. :t is iroor;ant to know the extent to w ic
:s c:nsu:tanz’s reccru endaticns relative to the ±dde
Cnarles :an: are inf e- ei t ::-is cde l ed u:rear
vo c . ‘•-
(os) - - -
-------
_:::y z_a r:
.... .. :, —;
; a:er Quality. In ncdeling the River under the year
2000 conditions, snoud it not be ex ec;ed that ut—
stream. dIscharges will be treated to the point wnere
water quality standards wlll be met?
2. ? ro, ected Wastewater ?lcws . In the EIS Consultant’s
modeling, the Charles River i assumed to receive
1.5 mIllion gallons per day (:ngd) of wastewater from
a combined Medfie1d— i11isfacility in the year 2000.
However, the DW?C in its basin planning has reported
flow projections of 1.0 mgd for each cor iun1ty in 19E5.
?rojectlons in the £Y!I’ A study also show larger values
for the year 2000. Ir. the £13 Consultant’s mcdeling
work, were changes made In the sewerage service con-
cepts In that location to warrant the reduced effuen;
dis charges?
3. Stream Reacration . The values of the coeffIcient cf
reaeration (K 2 ) used ifl the model are consideraoj .7 less
than reported in the 1976 Water uality 1ana ement PIan
cf the £ !assachusetts Division of Water Po lluticn Control
(JW?C). The attached table comoares these values for
the clever. reaches on the Charles RIver of interest to
the MIddle Charles plant analysis. In the nine reaches
no; considered to be “rapids”, the values of :<, used
in the model are i to 96 tercent less than those re-
ported by DW?. Reach 21, ir_ ediately below the
Cochrane Dam, value of •<2 was Increased to reflect
the higher reaeration rate exDected In this so—called
“rapIds” section. The value, however, is only aoout
or.e—half that used by the DW?C. However, in the other
“ra Ids” sectIon (Reach 19, just below the South Natlck
Dam), a K 2 value was used that is among the lo:.:est as-
sumed by the EIS Consultant anywhere. This choice Cf K 2
is lnconsIstent with the assumptions on ber.:hic oxygen
demand made in the £13 Consultant’s Memorandum. On :ne
other hand, in the long flat reach between the Sou:n
Natick and Cochrane dams (Reach 20), a K value was
used almost ecual to that used at the Co hrane Dam
“rapids”. What is the basis for significantly changing
the DW?C parameters?
1 . Dam Reaeration . The DW?C used fIeld samoling data to
conclude :na; the South Natick and Cochrane dams have
e:ual va ..es c’ tre reaera::cr cef:o.t ra: o -e £5
Consultant used a similar para ze;er, the reaera:Icn
f n :ion. Thus, one would expect the two dams to oe
(oq
-------
cnaracterized by equal values of P’d ( ). c JeVer,
the IS Consultant modeling won.: is based cn in u:
parameters that give the South Natick Dam a reaaticn
capability nearly nine times that cf the Ccchrane am.
What is the basis for this significant change?
. Dec.x:::ena:icn Coefficient for i:ro enCUS CXIZen
Demand . The mcdel outputs prodUcedDY t. e S
Ccnsultant are based on a value cf 0.67 for the
oge ous d oxyg ra on coeff 1 e t in all reaches.
S s ma kedly h 1 ghe t a the 0. value used by
DW?C. Again, the basis for this change neeos tO DC
determined.
t this time, we have identifIed fi e areas .•:here the séecti;r
of parameters are expected to impact Si !fi:antly the ccncl —
sicns cf the ElS Consultant’s Memorandum.
It is a parent that an item by item review of the mcdeling data,
and possibly the program fcrmulation is needed as tne ne::: step.
cr the siznificant model parameters, the range cf confidence
sncud be identified and theIr sensitivity should be de:er .ined.
Scne :aranc:ers can be field checked easily. An example cf s cn
is the reaenaticn capability at the critical d ns.
Due to the recent attention given to possible discharge locations,
it .s reco ended that MDC review with DW?C the following prcpose
next steps.
1. Detailed review of all input oarameters.
s;ablishment of a pcssible range for each signifi-
cant parameter.
3. ?.eview of the program formulation.
. Sensitiiity analysIs of parameter ranges wIth
respect to a decision fcr the desired locaticri and
requIred effluent quality for a Middle Charles plan:.
At a minimum, modeling runs should be made wIth the above—noted
changes, to determine the impact on the EIS Consultant’s ccncl
sion relative to the discharge location.
?e y trul ’ veurs,
ekabs P. Vittands
(%0
-------
COM PAI I ;ON 01 ” fl i•:n EU A’l’ I Oil ( < ) VA I A I i•: ; iJ lI)
1,0.
‘r(8
I I l . .1
39. II
3,’. 6
33.0
29.8
C.
2 11 . 2
71.2
L S • C.
I C )
1?
18
19
20
21
22
23
.) I
2 ‘
26
0.056
0.1115
0.056
0.033
0.5111
0.569
0.089
0.033
0.011
0. 022
0.1311
0 .311
0.35
0.33
Q.82
0.25
1..i
0.29
0.22
0.30
0 . 27
o . 2 l
vcr ——
:;La I l.on in lie No . Ei ; (1) F)WPC (2)
119.9
110 Ic
i ’ Ih’o(JIc
Hece] ve llac ha rge I ’ioiii
MedFieliJ-MI 1J I:i
Ii )j-’_,a LOW Drook
Med I I 01(1 110 api Lal
(Ia I. Ic k Dani
“Rapids” (Mole low E1 K 2 )
Wa han Ilibooll
( Hole hi l i :i S K )
Cueluane l)arii
“Rapids”
CItc ;I.iiiiL 3tr ct
l. ( ii ’ 1)1 Ich fiilet.
f •luLliei ’ I)i ’ook
Diversion 10 Neponsel RI v i
:; Will Ii .I_ Ut
I1.;_ , ,Iow I rc )c l(
;I 1k (II ii flaiii
1 . II:;e ,1 h y El Cona i I I.anl. fui’ Iwo.)ecled Veat’ 700(1 condl I; lona
hy l)WPC iii Clia ii eu H 1 vet’ Waler Qua] I I;y Ma iiageiiierit. Plan t ’or’ proj ec Lcd Year 1 9U
(:1)1 111 I I; I oii:;
-------
S.
•. —
-I.
F
f /1
-_,‘/ie (,t’_i’) )nc/e(?e’a((n /‘ .. f (7 . C(C ’i .” ’ .‘t: ;
( .JflC/
July 18, 1977
TEL. 7Z7-e eQ
.Dear Ms. Shaughnessy:
Re: EIS - Charles River Water
Quality
At
quality
plant.
our request, Metcalf Eddy, Inc. has reviewed the Charles River water
modeling data relative to the proposed Mid-Charles wa tewater treatiient
The following are counents provided to us by Metcalf and Eddy.
“Specifically, we have reviewed the following doci.m ents:
a. A memorandum from Mr. R.W. Chapin of the Environmental Assessr ent
Council, Inc. (EIS Consultant) to Mary Shaughnessy of EPA, describing
six modeling cases and recoimnending that the discharge of the subject
plant be located as far upstream of the South Natick Dam as possible.
b. Computer output from the modeling of Case 3A described in the EIS
Consultant Memorandum.
Our analysis has focused on the assumption and parameters used in the
computer modeling effort. In this review, we have assumed that the oarazneters
used in Case 3A are the same as those used in the other five cases described in
the EIS Consultant Memorandum that fonn.the basis for their reco endation.
However, inspection of the DO plots in the EIS Consultant Memorandum makes
this assumption questionable specifically because of the peculiar plot for
Cases 1 and 3 between river miles 39.7 and 40.5. Computer runs for other than
Case 3A were not supplied for review. Based on our initial review, we raise
questions in the follotdng areas:
1. Projected stream Water Quality Conditions . In all six of the cases
considered by the EIS Consultant, serious violations of Class B water
quality standards are projected for several of the segmer.ts upstream
of the South Nat±ck Da. in uding the rea hes i r’.edia e1y tr a i c’f the
SN VI RO ‘4 M ENT AL
PLA.NING 0FICS
2t9 ‘rne, / c. 9 ceee j ’. 4n O &IO8
1977
T .LF & ED DY
I. .’
1 FC10.
Ms. Mary Shaughnessy
Environmental Section
Environmental Protection Agency
J.F.K.Federa]. Building
Boston, Mass.
1
1i2..
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dam \%here a DJ of :ero is projected as a result of :pstr
cff1u nt loads, i.e., excluding the .Liddle Charles plant. it
is important to 1 iow the extent to ..hich the EIS Consultant’s
recorrrnendations relative to the Middle Charles plant are influenced
by this modeled upstream water quality. In modeling the Rive
under the year 2000 conditions, should it not be expected that
upstream discharges will be treated to the point where water
quality standards will be met?
2. Projected Wastewater Flows . In the EIS Consultant’s modeling, the
Charles River is assi. ed to receive 1.5 million gallons per d.ay
(mgd) of wastewater from a combined Medfield-Millis facility in
the year 2000. However, the DWPC in its basin planning has reported
flow projections of 1.0 mgd for each conununity in 1985. Projections
in the E’Mk study also show larger values for the year 2000. In
the EIS Consultant’s modeling work, were changes made in the
sewerage service concepts in that location to warrant the reduced
effluent discharges?
3. Stream Reaeration . The values of the coefficient of reacration (K 2 )
used in the model are considerably less than reported in the 1976
Water Quality Management Plan of the Massachusetts Division of Water
Pollution Control (D PC). The attached table compares these values for
the eleven reaches on the Charles River of interest to the Middle
Charles plant analysis. In the nine reaches not considered to be
“rapids”, the values of K, used in the model are 44 to 96 percent
less than those reported y DWPC. In Reach 21, inrnediately below the
Cochrane Darn, the value of K, was increased to reflect the higher
reaeration rate expected in this so-called “rapids” section. Tne
value, however, is only about one-half that used by the DWPC. Ho ever,
in the other “rapids” section (Reach 19, just below the South Natick
Dam), a K., value was used that is among the lowest assi ned by the FIS
Consultant anywhere. This choice of K 2 is inconsistent with the
assumptions on benthic oxygen demand made in the EIS Consultant’s
Memoran&zn. On the other hand, in the long flat reach between the
South Natick and Cochrane darns (Reach 20), a K, value was used almost
equal to that used at the Cochrane Darn t1rapidsr . What is the basis
for significantly changing the D PC parameters?
4. Dam Reaeration . The DWPC used field sampling data to conclude that the
South .atick and Cochrane dams have equal values of the reaeratiori
deficit ratio. The EIS Consultant used a similar parameter, the
reaerat ion function. Thus, one would expect the two darns to be
characterized by equal values of Fd (Q). However, the EIS Consultant
modeling work is based on input parameters that give the South
Natici: Da r n a reaeration capability nearly nine times that of the Cz :hr tie
Dam. l nat is the basis for this significant change?
ir
-------
5. De xv2enation Coefficient for Nitrogenous 0xv en D and . T -
model outputs produced by the EIS Consultant are based on a
value of 0.67 for the nitrogenous deoxygenation coefficient
in all reaches. This is markedly higher than the 0.2 value used
by DWPC. Again, the basis for this change needs to be detemined.”
We have discussed the modeling data with Messrs. Coopman and Polese
of the Division of Water Pollution Control and they concur with Metcalf and
Eddy’s corrments. At this time the C and the DWPC request that you rerun
the model with the changes indicated by Metcalf Eddy. If you have any
questions regarding these changes, please contact Jekabs Vittands of Metcalf
G Eddy at 523-1900 ext. 456.
When these model rerwis have been made, the MDC and DWPC staff would
appreciate the opportunity to discuss the outputs with you and determ.ine
whether additional analyses are required.
Yours truly,
Libby Blank
Director of Environnental Plannng
LB/co
cc: A.Coopman, DWPC
J.Vittands, M EV
A. Ekalainen, EPA
-------
H £ H C . P A
TO: Y.ary Shatchr.essv - —
E.P.A., Project Officer (j.i C 4 IP A
CC: I. Klein; C. Koch; D. Suler; D. Bartlett
FROM: R. . Chapin —
DATE: May 18, 1977
P IF: Location cf M d—Charlas S ver satellite :lant dischar2e
The DflA study recorrends dis:harti o the effluent frcr the rid—Charles
River satelli:e plant a: the Cochrane dr.. Our use of the Charles
River a:er çuality nodel has been ai ed at dece iniz: if this is the
“best” location for the dischsree. ?re’ ious nenoranda. 15 .t::il and 26
April, sur ri:e Tcdell:nc activities. This nercrzndtr etlua:es the
effects of the varicus cases ucon the orvcen balar.ce :n the Ch:rles
RIver. (Rasults are evaluated relative to Class 3 dissolved or:zen
standards. See rerorand z of 10 Y.ay 1977.)
The ECA reDcrt rezrnended a dischane of 31 rad containin: 5 rz’l 30D;
and 1 nz/. at the Cocnrane dan. arly nodellir.: runs indicated this
to violate -;ater :tzlitv stzndards for dissolved oxvzan and. :nerefcre,
the dischar2e effE.:zs of an “advanced” level of trea:nent, no a EC; of
5 g/1 and Z of 0 n;/l, -;ere investizated. :n addition, tvo a :erranve
discharge locations were rodelled: a: the S. atick dan: anc 6.7 :les uo—
strean of the S. ::a:i:k dan a: the he of n:de11iz rsach IS ( areaf:er
called Reach 12). Fisures 1 an: 2 :resen:, res;ec:ivCv, :lc:s st.-rari:ir.z
these treatrent levels and dischar:e Locations and :he r affects uoor dis-
solved oxygen levels in the Charles.
The E’2A recornended dis:harse resulted in a lar:e D.C. sn below the
Cochrar e dan, which violates the Class B standcrd of never less than
5 ng/l at an: ti—e. Dischar!e at the S. Nanck dan res 1ted in two sa;s
below the 5 ra.’l level, howaver, these were n:t as severe as the Cochrane
dai discharge sag. C.n’.’ersely, d:scharne at Reach 1S caused no “ blanc;:
of the 5 r!/1 standard below the S. Nat ck dan. Dissolved o::vgen levCs
above the dar are well below this class 3 lbic, althcu:h dischar2e a:
Reach .S generally ir:rcves ccndi:ions over ch:se predicted to ex:st
out a -TC disoharge.
tThen dischPr3ing the advanced effluont at the Cochrane darn a sag below the
Class B 5 r;/l ilni: occurs. This level of trea:nent does not violate t :s
standard whcn disc ar:ed at the S. ::ick dan, hcwe”er. the 16 hour class B
standard is vio1.a:ed by a S. azick dr d:s:harce. Reach IS dischzrze a.s:
does not violate the 5 n:!t stand:r .! bel:w the S. atick dan, while cissclved
oxygen levels above tne can fall below chat level. However, a discharse
here i—proves conditicr.s in this reach over the discharge condition. ACdi—
tionally the 16 hour stanc:r ::es n:t ao:ea: to be viclated the
IS dis:harcc.
I’g
-------
w—J- ‘ ‘
—
rake
.ay 1E, 157
ThIs analysis indicates the greatest benefit to the oxygen ba1a e cf
the river occurs vhen the 1d—Charles satellite plant sch rces . a-
vanced effluent placed above the S. Natick dan at river ile 47.8. The
political reality of placing such a discharge at that location is beyond
the scope of this discussion. Nevertheless, it is the position of EAC
that any discharge from a id—Charies satellite plant be placed as far
upstrean of the S. Natick dam as possible. Such a discharge appears to
provide the most benefit to the oxygen balance of the Charles River.
‘lip
-------
Char es F iv : ::e ::e-: _s
_o& t
Mode].llng Waste Waste C .arac .eris ::s
Plant Reach -. r1o ( ) 30D ( g/1) - (: j )
Yi1for i CHO3 6 5 1.1
CRPCD CH13 8.4 5 1.0
Wrenthe: State spOl 0.1 5 1
Scnoc].
Norfolk W 1po!e SPO5 0.4 5 1
MCI
Medfie1d— i11is C 1E 1.5 9 2
v!RO .F” TA.. E! T CL CiL
-------
‘ ‘•— —
case cr c- ?. .z5
eccr.-.er ed z:.: d.5::-arce a l i- at the Cochre .e dan. :ss:1-:e
oxycen SacS to 1.5 c/2. he : the .11 da..-’ (:: . e ie C.)
vio].atir ’.g C .ass 2 s:ada:ds (see at:ac -ed Fic re 1).
3 Recor er.de Z A discharce and ica i-.:s at t .e S. atick
sag to 4. r ,’1 de’.-elc s eh .r.d : -e :cc a dan (at r ;’er ie
while a secc d aac :o 4.1 .c/l e:ec:s : e £ k :: 11 .
This io1ates Cas3 3 D.O. cr ter a (see F c re 1).
4 Advanced disc :cea d lcad:ng at the Ccchrane . . . sac at 4.1
mg/i hind s :c :: il an which v:o lates Ciass 3 standards.
4E Advanced d:scharce and load:ncs at the 3. Natick da . 5 a.n. d scnar e
causes sa to : i —., wh ;: dces n z te
Class 2 1o e: 1 : ::er a. A :.:le of for a -r :er.cd
thdica:es s:an±ard :s v c1a:ed (see a.zle 1 and
Fic- re 2).
A:an:ed ::a:a:: an: lcadin;s : ::ee— cf S. atick — a: :i er
1e 47.5 (the : a: f t:- s. ..— reac:-). his :—:roves d .s—
solved a a:h : - r these c::r.—c ho : :ne
dis:ha: e :.c. :e’.e:s do no: : ae anove :ne 5 lc er 1 :
for Class 2 e:s. A sac to 5.7 c.’i de’:e:os s : ::i1 or—.
A cycle cf r a f:: a 4 hc r ;er::d :ndi:a:es tne :: s 2 i
standard .s : a: no: v1 :ed see a 1e 1 and : - e 2).
3A ?.ecc ended z::-a.: and 1:ao._ncs strea— cf S. :n: dan
at river i1e his also :oves .O. leve.s h:nd 3.
Natic dam. :: : : as ‘ ch as ase 4 . A sag to 5.4 /1 de’.’elc s
behir.d 3i :: d -, hc ever a 4 hour cycle has r.c: heen for
this case.
s;.f.e:, a1. _s at S a.r.
ENVIRONM!’T4L AS f.SS. E 7 COL.2U. !1C
-------
Charles River Be thic
Demand
Reach /m 2 fd Z Bottom Coverage Co=e:its
19 — S. Natick Dam to
Waban Brook 0 0 rapids
20 — aban Brook to -
Cochrane Dam 1.38 25
21 — Cochrane Dam to
Chestnut St. Needham 0 0 rapids
22 — Chestnut St. to Long
Ditch Inlet 1.38 75
23 — Long Ditch Inlet to
Mother Brook 1.38 75
24 — Mother Brook to Long
Ditch Outlet 1.38 75
25 — Long Ditch Outlet to
S. Meadow Brook 1.38 75
26 — S. Meadow Brook to
Sick Mill Dam 1.38 90
(ii EPJVIRONMEF .TAL A !Z S’. E?.T CL CIL
-------
S. 3 :c ::c. . e
Tin e Low D.O., “i
3am 5.7
5am 5.1
9am 5.5
12 pi’ 7.7
6pm 9.9
12 am 6.7
Reach 1! DiE: r;cs
Case 4
3am 6.2
5am 5.6
9am 6.0
12 8.2
12 am 7.2
Note: All low .O. . 3i es are dc s:: cf
Cochrar.e -. a: :i rer 1e ::.:
the Silk : i1. i .
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-------
ATTACHMENT B
WETLANDS DISPOSAL BIBLIOGRAPHY
B-123
-------
BIBLIOGRAPHY
1. Gersberg, R.M., Elkins, B.V., and Goldman, C.R., The Use of Artifi-
cial Wetlands to Remove Nitrogen from Wastewater , Ecological Re-
search Associates, Davis, California.
2. Kadlec, Robert H., Wetlands for Tertiary Treatment , University of
Michigan, 1978.
3. MDC, Wastewater Engineering and Management Plan for Boston Harbor-
Eastern Massachusetts Metropolitan Area, EMMA Study , October 1975
(Metcalf & Eddy, Inc.).
4. MDC, Nut Island Wastewater Treatment Plant Facilities Planning Pro-
ject, Phase I, Site Options Study, Vol. I , June 1982 (Metcalf &
Eddy, Inc.)
5. Mudroch, A. and Capobianco, J.A., Effects of Treated Effluent on a
Natural Marsh , Canada Centre for Inland Waters, Burlington, Ontario,
J.W.P.C.F., September, 1979.
6. Odum, H.T., Ewel, K.C., Mitsch, W.J. and Ordway, J.W., Recycling
Treated Sewage Through Cypress Wetlands in Florida , Center for
Wetlands, University of Florida, 1975.
7. Reed, Sherwood C. and Bastian, Robert K., Aguaculture Systems for
Wastewater Treatment: An Engineering Assessment , U.S. E.P.A.,
Washington, D.C., June, 1980.
8. Spangler, Fred I., Fetter, C.W. and Sloey, William E., Phosphorus
Accumulation - Discharge Cycles in Marshes , American Water Resources
Association, 1977.
9. Tuschall, John R., Brezonik, Patrick L., and Ewel, Katherine C.,
Tertiary Treatment of Wastewater Using Flow-Through Wetlands Sys-
tems , Department of Environmental Engineering Sciences and Center
for Wetlands, University of Florida, Gainsville.
10. U.S. EPA, Draft Environmental Impact Statement on the Upgrading of
the Boston Metropolitan Area Sewerage System (August 1978).
11. Valielu, Ivan; Vince, Susan and Teal, John M., Assimilation of
Sewage by Wetlands , Woods Hole Oceanographic Institution, Woods
Hole, MA.
12. Valk, A.G. van der, Baker, James L., Davis, Craig, B., Beer, Craig,
E., Natural Freshwater Wetlands as Nitrogen and Phosphorus Traps ,
Iowa Agriculture and Home Economics Experiment Station, Ames, Iowa.
13. Weber, A. Scott, Tchobanaglous, George, Colt, John E., Aquatic
Systems for Secondary and Advanced Treatment of Wastewater , Depart-
ment of Civil Engineers, University of California, Davis.
B-124
-------
14. Whigham, Dennis F. and Bayley, Suzanne E., Nutrient Dynamics in
Freshwater Wetlands , Chesapeake Bay Center for Environmental Studies
and Maryland Coastal Zone Management, Department of Natural Re-
sources.
15. Yonika, Donald and Lowry, Dennis, Feasibility Study of Wetland Dis-
posal of Wastewater Treatment Plant Effluent , Massachusetts Division
of Water Pollution Control, 1979.
B—125
-------
ATTACHMENT C
WETLANDS DISPOSAL - DEQE CORRESPONDENCE INDEX
4/23/84 Thomas F. McLoughlin, Deputy Commissioner, Mass. DEQE, to Ron
Manfredonia, Environmental Evaluation Section, U.S. EPA, re:
DEQE review of “Evaluation of Satellite Advanced Wastewater
Treatment Facilities Volume II, Boston Harbor (SDEIS)” by CE
Maguire, February 1984.
12/29/83 Thomas C. HcMahon, Director, Division of Water Pollution
Control Mass. to Walter Newman, Acting Chief, Environmental
Evaluation Section, U.S. EPA, re: DWPC review of Quincy
Shores Association proposal for satellite treatment plant
disposal to wetlands.
12/16/83 Ilyas Bhatti, Director, Division of Water Supply, Mass. DEQE,
memorandum to Steve Lipman, Boston Harbor Coordinator, DEQE,
re: Division of Water Supply review of satellite treatment
plans.
B— 126
-------
- elk € ?wQuvea/€ Cf
( 7 of m nmentaI J fzc
1Øa n( of cfn rn.nta aah &y eee
2L 1 of 7V €o d
D. sse /4reet .qBoo&* 02108
April 23, 1984
Mr. Ron Manfredonia Re: MDC
Environmental Evaluation Section SDEIS, Siting of Wastewater
Environmental Protection Agency Treatment Facilities
J.F. Kennedy Building
Boston, Massachusetts 02203
Dear Mr. Manfredonia:
In response to a request from your agency, representatives from the
Department of Environmental Quality Engineering (DEQE) have reviewed a
report titled:
Evaluation of Satellite
Advanced Wastewater Treatment Facilities
Volume II
Boston Harbor Supplemental
Draft
Environmental Impact Statement
Prepared by C.E. Maguire, Inc.
February, 1984
C.E. Maguire evaluated two specific satellite options; EMMA recom-
mended facilities and Quincy Shore Associates proposal. The report pre-
sents a number of specific conclusions and reconmiendations for each option;
which are sumarized below:
1) the construction of the proposed satellite facilities for both
options will not reduce the size or complexity of necessary harbor
treatment facilities;
2) the use of satellite facilties should be reevaluated as a priority
in determining a cost effective and equitable solution to future
system expansion needs;
3) construction of the satellite facilities would not alleviate the
need for planned downstream interceptor relief;
4) direct discharge of AWl effluent to the Neponset River would adver-
sely impact water quality, particularly dissolved oxygen;
-------
Ron Manfredonia
April 23, 1984
Page 2
5) direct discharge of AWl effluent to the Charles River could have
potential beneficial impact upon dissolved oxygen but could cause
violations of water quality standards at certain times of the year,
would exacerbate nuissance algae conditions in downstream reaches
and could lead to significant public health impacts upon existing
and proposed public water supplies due to the interrelationship of
the surface and groundwater within this basin;
6) the discharge of AWl effluent to wetlands which are hydraulicly
connected to groundwater aquifers currently utilized as major sour-
ces of drinking water poses significant potential public health
risks;
7) there are only limited wetlands areas in close proximity to the
proposed AWT facilities of sufficient size to accept AWl effluent;
and
8) the high’ capital and O/M costs for these AWT facilities are
excessive and unjustifiable since there are very few benefits with
regard to siting of the harbor facilities.
DEQE concurs with these conclusions. Appendix C of this report also
contains two policy documents issued by the Department’s Divisions of Water
Pollution Control and Water Supply which present detailed analyses of the
Quincy Shores Associates proposal.
The Department is also in receipt of correspondence from David
Standley to EPA dated April 3, 1984, which takes exception to many of the
C.E. Maguire conclusions. In particular, Mr. Standley states, “It is
therefore, our opinion that ways will have to be found to render the sub-
regional approach feasible and acceptable. It appears on first blush that
the constraints suggested by DEQE are excessively stringent, and wholly
inconsistent with practices elsewhere in the state and nationally. It also
appears that aggressive control of non—point sources may be a requisite to
off—setting any otherwise unavoidable reductions in in-stream water
quality. One step which must be taken and which has been discussed by me
with the Massachusetts Division of Water Supply, is the re-evaluation of
the need for severely stringent limitations on the discharges from such
f ac lii ties •
The Department’s Division of Water Pollution Control (DWPC) strongly
disagrees with Mr. Standley’s statement that DEQE’s position is excessively
stringent and inconsistent with actions in other parts of the Comonwealth.
The DWPC’s December 28, 1983, letter (referenced previously) explains that
on October 15, 1983, DWPC promugulated a set of comprehensive water pollu-
tion control regulations (Title 314 of the Code of Massachusetts
Regulations) which includes detailed groundwater quality standards. The
Division’s regulatory strategy and requirements are very clear and expli-
cit as to how it must relate to the Quincy Shores Associates proposal.
(2
-------
Ron Manfredonia
April 23, 1984
Page 3
The Division is in the process of permitting all existing and proposed ground-
water dischargers and every applicant must comply with the same regulatory
requirements no matter where their discharge is located within the
Commonwealth.
Mr. Standley stated that he has discussed the possible re—evaluation
of the “severely stringent limitations on the quality of discharges from
such facilities” with the Division of Water Supply. It should be stressed
that the only State agency empowered to relax or modify the level of treat-
ment for a groundwater discharge is the Division of Water Pollution Control
and not the Division of Water Supply. The DWPC’s position has been very
clearly delineated in its December 29 correspondence — “The discharge
limits would basicly require that the effluent entering onto the wetland
meet or e ceed the Primary and Secondary Drinking Water Parameters...”.
If you have any questions concerning this correspondence, please con-
tact Steven Lipman of my staff at 292-5698.
Very truly yours, -
Thomas F. McLoughl
Deputy Comissioner
TFM/SGL/bd
cc: David Fierra, EPA
Sam Mygatt, MEPA
Noel Baratta, MDC
Dan O’Brien, MDC
Marjorie O’Malley, CZM
William Gaughan, DWPC
Steven Lipman, DEQE
-------
ecu4 CJ C 8 of £ o (a/ J c s
Ø ment of &vz o qne zAI c aah
9 AGI
ANTHONY D. CORTESE, Sc. D. / ‘ 02108
December 29, 1983
Walter Newman, Acting Chief Re: MDC
Environmental Evaluation Section SOEIS, Siting of
Environmental Protection Agency Wastewater Treatment
J.F.K. Kennedy Building Facilities
Boston, MA 02203
Dear Mr. Newman:
In response to a request from your agency, the Division of Water
Pollution Control, Permits Section has reviewed the proposal by the Quincy
Shore Association for subregional wetland application satellite wastewater
treatment plants. The proposal calls for the construction of three facifl—
ties, one each to be located in the Weymouth Fore River Basin, Neponset
River Basin and the Charles River Basin. All three plants would include
advanced wastewater treatment processes with discharge of their effluent to
major wetland areas which are hydraulicly connected to groundwater aquifers
currently being utilized by various municipalities as major sources of
drinking water. Information presented to the Division indicates that
during recharge periods up to 80% of the effluent discharged to the marshes
would enter the groundwater regime and recharçe the subject aquifers.
On October 15, 1983 the Division of Water Pollution Control pro-
mulgated a set of comprehensive water pollution control regulations
(Title 314 of the Code of Massachusetts Regulations) which included
detailed groundwater quality standards. These standards define groundwater
into these classes (1,2,and 3); Class 1 being defined as
“fresh ground waters found in the saturated zone of uncon-
solidated deposits or consolidated rock and bed rock and are
designated as a source of potable water supply 11 .
Since all three proposed discharges will be tributary to groundwater
currently being utilized as public water supplies (Class 1), all discharges
to said groundwater will be required to meet very strict discharge limits,
see attachment #1.
The discharge limits would basiclyrequire that the effluent entering
onto the wetland meet or exceed the Primary &nd Secondary Drinking Water
(30
-------
Walter Newman
December 29, 1983
Page 2
Parameters, see attachment #2. In addition, the Division is concerned with
the periodic “pass throughH of materials such as oil, heavy metals,
solvents, phenols and other highly toxic or contaminating materials which
are not substantially removed with conventional wastewater treatment pro-
cesses and which could cause severe impacts upon these aquifers.
The Division is of the opinion that proper safeguards necessary to
continuously meet Class I effluent limitations and to protect these valuable
public water suppltes can not be provided. Therefore, the Division
strongly discourages the continued review of such subregional facilities as
proposed by the Quincy Shore Associates.
Ver truly yours,
Thomas C. McMahon
Director
TCM/MP/pnim
cc: Sam Mygatt, MEPA
David Fierra; EPA
Steven Lipman, DEQE
William GaughaW, DWPC
Marjorie O’Malley, EOEA
Noel Baratta, MDC
Robert Daylor,Quincy Shores Associates
-------
ATTACH! ENT 1
!82
314 CMR: DIVISION OF WATER POLLUTtO; COt TROL
6.07: Application of Standards
(1) Ground Water Discharge Permits . No person shall
make or permit an outlet for the discharge of sewage
or industrial waste or other wastes or the effluent
therefrom, into any ground water of the Ccjnmonwealth
without first obtaining a permit from the Director
of the Division of Water Pollution Control pursuant
to 314 CMR 5.00. Said permit shall be issued subject
to such conditions as the Director may deem
necessary to insure compliance with the standards
established in 314 CMR 6.05. Applications for ground-
water discharge permits shall be submitted Within
times and on forms prescribed by the Director and
shall contain such information as he may require.
(2) Establishment of Discharge Limits . In regu—.
lating discharges of pollutants to ground waters of
the Commonwealth, the Division shall limit or prohi-
bit such discharges to insure that the quality stan-
dards of the receiving waters will be maintained or
attained. The determination by the Division of the
applicable level of treatment for an individual
discharger will be made in the establishment of
discharge limits in the individual ground water
discharge permit. In establishing effluent limita-
tions in the individual permits, the Division must
consider natural background conditions, must protect
existing adjacent and downgradient uses and must not
interfere with the maintenance and attainment of
beneficial uses in adjacent and downgradient waters.
Toward this end, the Division may provide a reaso-
nable margin of safety to account for any lack of
knowledge concerning the relationship between the
pollutants being discharged and their impact on the
quality of the ground waters.
(3) For purposes of determining compliance with 314
CMR 6.06(1)aa for toxic pollutants in Class I and
Class II ground waters,’ the Division shall use
Health Advisories which have been adopted by the
Department or EPA. Generally, the level of a
toxic pollutant which may result in one additional
incident of cancer in 100,000 given a lifetime expo-
sure (1O Excess Lifetime Cancer Risk) will be used
in determining compliance ñth that secticn of the
regu1at on .
1g..
-------
Attachnient ##2
liE;
314 CMR: DIVISION OF WATER POLLUTION CONTROL
Parameter Limit
1. Coliform ShaH not be
Bacteria discharged in
amounts sufficient
to render ground
waters detrimental
to public health,
safety or welfare,
or impair the
ground water for
use as a source of
potable water.
2. Arsenic Shall not exceed
0.05 mg/i
3. Barium Shall not exceed
1.0 mg/i -
4. Cadmium Shall not exceed
0.01 mg/i
5. Chromium Shall not exceed
0.05 mg/i
6. Fluoride Shall not exceed
2.4 mg/i
7. Lead Shall not exceed
0.05 mg/i
(33
-------
I ‘
I
314 CMR: DIVISION OF WATER POLLUTION CONTROL
8. Mercury Shall not exceed
0.002 mg/i
9. Total TrihalamethaneS Shall not exceed
0.1 mg/i
10. Selenium Shall not exceed
0.01 mg/i
11. Silver Shall not exceed
0.05 mg/i
12. Endrin (1,2,3,4,10, Shall not exceed
1O_hexachlOrO_1,7 -eP0xY 1 , 0.0002 mg/i
4,4a,5,6,7,8,9a OCtahYdr0—
1 ,4_endo,efldO_5,8 -dimethaflo
naphthal ene)
13. Lindane (1,2,3,4,5, Shall not exceed
6_hexachlorOCYClOhexafle, 0.004 mg/i
gamma isomer)
14. MethoxychiOr (1,1,1— Shall not exceed
Trichloro—2, 2—bis 0.1 mg/i
(p -methoxyphenYl) ethane)
15. Toxaphene (C 1 OH1OC18, Shall not exceed
Technical Chlorinated 0.005 mg/i
Camphene, 67—69 percent
chlorine)
16. ChlorophenoxyS
2,4_D,(2,4 —DiCh1Or0 Shall not exceed
phenoxyacetic acid) 0.1 mg/i
2,4,5-TP Silvex (2,4, Shall not exceed
5_TrichlOrOPheflOXY— 0.01 mg/i
propionic acid)
17. Radioactivity Shall not exceed
the maximum
radionuclide con-
taminant levels as
stated in the
National Interim
Pr ary Drinking
Water Standards.
I 3&f
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314 CMR: DIVISION OF WATER POLLUTION COr TROL
18. Toxic pollutants Shall not exceed
(other than those “Health Advisories .’
listed above) which have been
adopted by the
Department and/or
EPA. A toxic pol-
lutant for which
there is no avail-
able .‘Health
Advisory” and for
which there is not
sufficient data
available to the
Department for the
establishment of a
“Health Advisory”
will be prohibited
from discharge.
(b) Secondary effluent limitations for Class I
and Class II ground waters . In addition to the
effluent limitations in 314 CMR 5.10(3)(a) , the
following limitations shall also apply to any
discharge from a point source or outlet which
enters the saturated zone of, or the unsa-
turated zone above, Class I and Class II ground
waters.
Parameter Limit
1. Copper Shall not exceed
1.0 mg/I
2. Foaming Agents Shall not exceed
1.0 mg/ I
3. Iron Shall not exceed
0.3 mg/l
4. Manganese Shall not exceed
0.05 mg/i
5. Oil and Grease Shall not exceed
15 mgIl
6. pH Shall be in the
range of 6.5 to
8.5 standard units
7. Su1f e Sh l1 not exceed
250 mg/i
‘U
-------
.1.19
314 CNR: DIVISION OF WATER POLLUTION CONTROL
8. Zinc Shall not exceed
5.0 mg/i
9. All other None in such
pollutants concentrations
which in the opin-
ion of the Director
would, impair the
ground water for
use as a source of
potable water or
cause or contribute
to a condition in
contravention of
standards for other
classified waters
of the
Commonwealth.
Cc) Additional effluent limitations for Class I
and Class II ground waters . In addition to the
effluent limitations listed in 314 CMR
5.10(3)(a) and (b), the following limitations
shall apply to treatment works designed to
treat wastewater at flows in excess of 150,000
gallons per day:
Parameter Limit
1. Nitrate Nitrogen Shall not exceed
(as Nitrogen) 10.0 mg/i
2. Total Nitrogen Shall not exceed
(as Nitrogen) 10.0 mg/I
Cd) Additional effluent limitations for Class I
ground waters . In addition to the effluent
limitations in 314 CMR 5.1O(3)(a)(b) and (C)
the following limitations shall apply to treat-
ment works discharging to Class I ground
waters:
Parameter Limit
1. Chlorides Shall not exceed
250 mg/I
2. Total Dissolved Shall not exceed
Solids 1000 rag/i
-------
n
Jhe Uom ,ieo,z, 4 eeaJ1/i e / h ,lJJ17c// ,ae(/J ’
c e 0/ lV(2’C71fld(fl( lI iç
e/ ailrnent 0/ s uôeonnzentd aat 4 ’ 4Ze9zee2f( 7
.92 3eo 0/ /t te, e. Ji
O, . W u’e M, ee t 91a 4n. diLL 02/08
ME MORAN DUM
TO: Steve Lipman, Boston Harbor Coordinator
FROM: Ilyas Bhatti, Director, Division of Water Supply
DATE: December 16, 1983
SUBJECT: Metropolitan District Comission, Southern Sewerage
District Wastewater Treatment Facilities Planning Project:
The Citizens Plan.
The Division of Water Supply (DWS) has reviewed the proposed plan for
subregional “satellite” wastewater treatment facilities as part of the
general plan for rehabilitating the MDC wastewater treatment system. As
the agency responsible for ensuring safe drinking water supplies, we are
particularly concerned with the impact these treatment plants could poten-
tially have on the water quality of nearby aquifers and wetlands which
serve as public water supplies for many communities. Specifically, these
areas are:
1. Weymouth Fore River Basin — proposed 8—10 mgd discharge into
Broad Meadow, a wetlands of the Cochato River; Cochato and
Farm Rivers are diverted to reservoirs for use by Braintree,
Randolph, and Holbrook. -
2. Neponset River Basin - proposed discharge of 35 mgd to Fowl
Meadows which supplies Canton, Westwood and Dedham.
3. Charles River Basin - proposed 50 mgd discharge into Cow
Island Meadows, a wetland in an aquifer area which supplies
Dedham, Needham, Wellesley, and Weston.
With regard to these sites, the sponsors of the Citizens Plan cla rn
that there are several advantages to these projects as compared to the
current MDC proposal. The following comments reflect the Division’s con-
cern with claims in the proposal that the development of the sateflite
ANTHONY 0. GORTESE Sc. 0.
COMM,SI, ONER
In
-------
Memorandum
December 16, 1983
Page 2
plants will increase the water quantity and improve the water quality of
the water supplies in the 10 affected communities (Brairitree, Randoplh,
Holbrook, Canton, Norwood, Westwood, Dedham, Wellesley, Needham, and
Weston).
Although the Citizens Plan is an innovative proposal for solving the
extremely complex problem of dealing with wastewater treatment in the
Metropolitan Area and the associated water quality problems in Boston
Harbor, its claim with regard to increasing the water quality/quantity j
the aformentioned wetlands and aquifers is based on questionable
assumptions.
As noted in the proposal, wetlands have been studied by many agencies,
including DEQE, and are known to have significant capacities to attenuate
various types of pollution such as nitrates, phosphates, and heavy metals.
Although this feature of wetlands is well documented, the present proposal
assumes that wetlands have a limitless capacity to act as “sinks” for con-
taminants and that all discharges from the proposed wastewater treatment
plants will be “polished” by the assimilative capacity of wetlands. In
fact, wetlands have limited capacities to assimilate wastes; unlike treat-
ment plants which accelerate the process of waste removal , wetlands
recycle and absorb pollutants over a long period.
It is difficult o generalize about the capability of wetlands to
function as water purification systems. Ultimately, the diversity of the
many wetland charateristics will determine their net efficiency to assimi-
late sewage contaminants. The vegetative type, rate of flooding, and the
area of a wetland will determine: the rate at which pollutants are recycled,
the BOO loading tolerance, the sedimentation rate, and the level of bioche-
mical degradation. The geographical location of a particular wetland will
also markedly affect the seasonal capacity of wetlands to. assimilate
wastes. For instance, It is quite possible that the wetlands proposed for
discharge in the Citizen’s Plan would freeze during certain periods of the
year which would inhibit even the mechanical, primary treatment function of
plant screening and particulate sedimentation.
Aside from the problems associated with determining the assimilative
capacity of wetlands for pollutants, this proposal does not address other
potential water quality problems. For instance, the proposal does not
address the fact that very little control exists over the nature and
quality of sewage. Presently, the regulatory manpower does not exist for
monitoring illegal or haphazard industrial waste disposal. Many industrial
contaminants cannot be detected, let alone treated, in standard wastewater
treatment facilities. As a result it is very likely that discharges from
the proposed “satellite” plants would ultimately result in the degradation
of existing water quality in the receiving wetlands/aquifer. All things
considered, water qualit.y degradation is likely to occur either over the
-------
Memorandum
December 16, 1983
Page 3
short term through problems associated with seasonal flooding/freezing of
the wetland and/or the undetected discharge of a harzardous substance, or
over the long—term by the gradual saturation of the assimilative capacity
of the wetland.
Because of these uncertainties, and the problems that may ensue, the
DWS must conclude that the Citizens Plan proposal for wastewater discharge
into wetlands is an unacceptable risk for potentially degrading these vital
existing drinking water supplies.
-------
ATTACHMENT D
INFLOW/INFILTRATION PRELIMINARY REPORT
TO PROF. CHARLES M. HAAR
(submitted by Massachusetts Executive Office of Environmental Affairs)
B-140
-------
5Ae imcnc áa&/i c/c cicAa et’ i
I ? .1 9
cec(a i . (. i/cce C 7 (3ii i C) .GiI11ZC1lt ((t
. ;i! , ) (_12 / (j1
?j Y;ii 100 ‘l2’(VE Y((/9C J/i’ 1 cd
CONE g c :t ,fl, .,ac%u t6 02202
. GE’ ENT
Dec ber 2, 1983
?rc essor Charles . Haar
3C0 Griswald Hall
arvard Law School
C bridge, 02138
Re: Quiicv v MDC . Schedule Item:
Pro:ess r Haa::
closed is the prel inary report on 1/I r oval.
Sincerely,
Wiliia.. Lahevt
Counsel f
— ,- ‘- ! ::
—
L: be
r.
cc: Peter L. Koff L ’t
Ralph A. Child
E. :iichael Slo an
Steien C. Horowitz —
Jeiferv Fo 1ev L#s’” -—
.ls. Laura St irberg - , . . .. —
Willia C. Golden t 1
Stephen C. Karnas
SteDhen P. Eur av
- .-
Stev L an .
,N1
CC uL EL
141
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December 2. 1983
Procedural Order — Item #5.
BANKING/TRADING AND GREATER THAN 2 FOR 1 PR0 RAM
Item #5 of the Procedural Order requires that DEQE assess the feasibi-
lity of a Banking and Trading System and a greater than 2 for 1 sewer
extension permit program. This document not only provides the Court with
those feasibility assessments but attempts to develop a basis for an
expanded discussion of the need for an integrated approach to all iir
related items contained in the Procedural Order. It is our intention to
use this expanded discussion document to hopefully stimulate fresh
approaches to these technically and politically complex issues. This
document should not be viewed as a DEQE position paper but as a discussion
document and comments are not only welcomed but strongly requested.
In order to assess either of these programs adequately one must con-
duct such an assessment in the context of DEQE and MDC’s overall efforts to
deal with the entire sewerage system and its myraidof prQblems..
Within the MDC regional sewer system there currently exists 5,430
miles of municipal sewers, 228 miles of MDC sewers, approximately 3,000
miles of privately owned house laterals, over 70,000 manholes, 10 MDC
pumping stations and numerous municipal and privately owned pumping sta-
tions. Large sections of the North System have combined sewer/drain faci-
lities and literally thbusands of cross connections or interconnections
exist within the sewers and drains tributary to both the F orth and South
Systems. Also various exfiltrating sewers are underdrained with small
diameter perforated pipe which discharge to adjacent watercourses.
Extensive gauging or flow monitoring facilities currently do not exist
within eithe ’ the MDC or municipal sewerage systems and therefore tliire is
very little historical data concerning the distribution of wastewater
within this maze of pipes, pumping stations, diversion structures, treat-
ment plants and overflow facilities.
Due to the nature of the segmented ownership of these facilities,
management of flows into the system is extremely difficult to control and
monitor. Infiltration and inflow (I/I) within this system is a very signi-
ficant flow component (estimated to be over 50% of the average monthly
flow). It must be e iiphasized that I/I is not peculiar to the 1DC system
but also exists in large amounts in all sewer systems particularly older
systems. Others have statea that if I/I could be significantly reduced,
many of the system problems could be solved without the construction of new
relief sewers, pumping stations or expanded treatment plants. There is no
question that I/I reduction could aid in these efforts, particularly with
regard to localized surcharging and overflows, but it is ot a panacea to
the problems of the MDC system or pollution of Boston Harbor.
Iq 2
-------
I/I within the MDC system has been extensively investigated with
millions of dollars expended to date in •this effort. Due to the length of
time needed to complete the study and design phases of the I/I program,
very few communities within the MDC have actually begun the physical
reconstruction phase of the I/I program. Therefore, relatively little I/I
removal has been achieved to date even though a great deal of effort and
money has been expanded by local and federal agencies on this program.
Rehabilitation projects have been completed, are under construction or soon
to be initiated within seven (7) MDC municipalities and are expected to
remove 30 MGD of I/I from the sewerage systems (3.6 MGD within the South
System and 26.5 MGO within the North System).
Unfortunately I/I studies and rehabilitation programs are more of an
art than a science and this program is receiving extensive national reex—
mination by the EPA, consulting engineering firms, I/I gauging and rehabi-
litation firms,, major municipal sewer authorities, and state agencies.
This review is in large measure due to the demonstrated inability of com-
munities to reduce lit rates to those originally assumed to be realistic
(and often mandated). During 1979 and 1980 EPA funded a major study to
examine the level of success of it Construction Grants I/I Rehabilitation
Program. The results showed that of the nineteen (19) con nunities studied,
none had attained the assumed levels of I/I reduction and many had not
reduced 1,/I at all despite extensive reconstruction efforts. The study
concluded that current I/I determination and rehabilitation techniques
generally will not result in substantial system I/I flow reductions: This
study further recommended nine (9) major revisions to the EPA I/I program
(See attachment #1). —
During the past seven years numerous I/I studies have been performed
within the overall MDC system by various consulting fir as. It is very dif-
ficult to compare the results of the varoius studies to each other and
often impossible to even correlate the results of Phase I and Phase II I/I
studies within a single community conducted during consecutive years by the
same consultant. The MDC has performed 2 system—wide I/I studies,
(North System performed during 1978 by Camp, Dresser & McKee and the South
System performed during 1979 by Fay, Spofford, and Thorndike), plus 7
system component I/I studies by 6 different firms for individual projects
such as the Framingham Interceptor, Fore River Siphon, etc. Of the 43
member municipalities, 25 have already performed additional 1/I studies
utilizing 11 different consulting firms. All these studies were required
to comply with the EPA cost-effectiveness guidelines which resulted in
significant amounts of I/I not being cost-effective for removal due to
comparatively low transporation and treatment costs for the MDC system.
Therefore, projects which have progressed into the Phase II — Sewer System
Evaluation Survey Phase, Design Phase or construction Phase are skewed
towards removal of I/I to the point where the EPA regulations deem the I/I
com7onent of total flow to a treatment facility This
approach does not emphasize significant elimination or reduction of I/I
through continued and routine maintenance of a sewer system, but rather one-
time repairs or replacement of sewers which may or may not have a lasting
effect in reducing I/I system—wide.
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—3—
Problems in the MDC Sewer System can be classified as:
1) ACUTE — Conditions which can lead to direct public health
impacts such as sewage overflows into recreational areas, shellfish areas,
and public water supplies and back—ups into homes; and
2) CHRONIC — Conditions such as sewer surcharging leading to
flow restrictions, reduced pollutant removal efficiencies at treatment
facilities, and overflows to watercourses in non—critical areas.
DEQE believes that there is room for improvement fri the treatment of
both acute and chronic problems, but the appropriate remedies are not
necessarily the same.
Past practice : A) DEQE has utilized enforcement action (sewer bans,
monitoring, two for one, holding tanks, etc.) to address ACUTE problems.
It is our opinion that a degree of success has been reached but still more
can be done to identify problem areas and initiate enforcement action which
would utilize the existing array of possible remedies and tailor specific
remedies to particular situations.
B) DEQE has utilized a format of developing a
Memorandum of Understanding (orginally signed on April 13, 1982) between
its Division of Water Pollution Control and the MDC to prioritize major
water pollution abatement projects, develop compliance schedules and allo-
cate federal/state grdnts as a primary remedy for the CHRONIC problems of
the MDC system.
We now recognize that an effective remedy to the CHROIfiC problems must
also include other elements beyond the construction grants project list.
The remedy f r the CHRONIC problems must include an organized, structured,
long term approach to reducing extraneous flow of “clean water into the
entire MDC system.
During August and September the Division of Water Pollution Control
(DWPC) developed interim maximum I/I removal rates for each MDC member corn—
munityas required by the Court. Since these rates had to be developed
during a very short period of time, DWPC had to assume across—the—board—
removal rates (30% and 50% reduction in infiltration and inflow respec-
tively were chosen) for each corrmunity based upon the flow studies
available at the time. This analysis indicated that 110 - G0 and 80 MGI)
could possibly be removed from the South and North System respectively if
30% and 50% reduction could be obtained in each community along with a
source of monies to fund this extensive work (estimated at 5100 million).,
It was never the Department’s intent to indicate that this level of
I/I reduction was easily obtainable, cost effective, or could be instituted
within a short period of time. The following are some of the major
problems and uncertaintieswhich we believe stand in the way of instituting
any program to deal with the Chronic problems within the South System
(similar problems exist within the Uorth System):
! ‘!‘1
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-4 -
1) It has been estimated that total flows in excess of 450 MGD
enter various sections of the South System at any one time;
2) The theoretical maximum flow reduction within the system has
•been estimated at 110 MGD assuming across—the—board reduc-
tions of Infiltration by 30% and Inflow by 50%;
3) The major constriction within the conveyance and treatment
facilities are the High Level Sewer with a peak capacity of
310 MGO and the Nut Island Treatment Plant with a peak capa-
city of 250 MGD. Flows cannot be reduced to these levels
even if the theoretical maximum I/I reduction rates were
attained;
4) The estimated cost for removal of 110 MGO is $60 million, if
30% & 50% reductions could be obtained in afl con nunities;
5) Current state—of—the—art hI reduction practices indicate a
significantly lower I/I removal capability (15% total I/I
reduction);
6) It is uncertain whether current I/I reduction techniques
withstand the passage of time. Rehabilitated sewer lines rr.ay
quickly revert to prior conditions and other currently nan—
leaking sewer segments may begin to leak as the lines
detertGrate with age;
7) Current information indicates that as much as 50% ofall
infiltration within a sewer system originates from privately
owned 3 or 4 inch house connections (pipe connecting the
building to the street sewer);
8) Various Iii experts now belive that “allowable” non—cost—
effective I/I rates for a community may be as high as 10,000
gallons per day/inch/mile of pipe (gpd-.in—mi) instead of
6,000 gpd-in—mi currently being used by EPA and 1,500 gpd—in—
mi which was originally used by EPA. If the 10,000 gpd—in—rrii
figure is used as a cut—off point for further I/I work, a
review of the existing I/I rates for Southern System
Comnunities (attachment 2) indicates that only Boston,
Dedham, and Hingham would require I/I reduction.
9) Since all prior I/I studies were performed utilizing the EPA
cost-effectiveness program;many if not all the prior studies
will need to be revised. This may also require additional
flow monitoring to supplement prior monitoring data. This
monitoring work can only be performed during high groundwater
(“hunting”) periods and such revision to any of the existing
studies could add approximately two years to their completion
times; and
-------
—5—
10) We currently have• no methods of monitoring total system
flows, flows from each municipality, loss of flow due to
localized overflows, etc. Any attempt to develop maximum I/I
rates for each municipality in order to Hsolve all of the
many problems experienced in the MDC and local sewer systems
(i.e. surcharging and overflows, downstrean constrictions in
MDC trunk sewers, overloading of pumping stations, hydraulic
overloading of the treatment plant and pollution abatement
within Boston Harbor) with the existing information is like
trying to fine-tune a piano when half the keys are missing.
In order to resolve some of these uncertainties and to begin the deve-
lopment of an effective system-wide approach to the chronic problems of the
MDC, the Department is undertaking the following:
1) The DEQE sent two staff engineers to New Jersey during August
to attend a nationi EPA—sponsored seminar titled ANew
Concepts fl I/I Evaluation and Sewer Syste m Rehabilitation”;
2) DEQE has formed an internal task force to devise a consistent
statewide policy on I/I, specifically to address the recent
development of and revision to state—of—the—art rehabilita-
tion techniques as enumerated at the above discussed EPA
seminar;
3) DEQE is in the process of developing a Technical Advisory
Group to work with us to develo an acceptable and implemen—
table 1!rprogram for the MDC system. Our preliminary idea
for membership of this group is to have one representative
from the following: DEQE, MDC, BWSC, EPA, Quincy , a North
System Community, a South System Community, engineering con-
sultant, sewer rehabilitation company and developer/home
builder. This would provide for a workable 10 member tech-
nical committee. We would also be requestino that each
member representing a larger grouping develop an extended
corm ittee to whom they could report in order to ensure a wide
dissemination of data.
4) DEQE recently held an interagency seminar on I/I at which
Gerald Conklin, a well known expert on state—of—the—art Iii
rehabilitation techniques, explained the results of a study
the firm Dufresne — Henry performed for the EPA;
5) DEQE has sent letters to Region 1 and Washington EPA strongly
requesting that EPA hold the New Jersey seminar in Boston so
that a thorough discussion could be held with all parties to
the court suit. EPA recently indicated to DEQE that they
could probably fund this seminar;
6) DEQE has contacted Michael Bonk from the Washington South
Suburban Sanitary District requesting permission for members
of cur I/I Task Force to visit their facility and discuss
their extensive experience in I/-I rehabilitation programs.
This meeting has been tentatively sheduled for December 6 and 7.
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-6’
7) DEQE filed legislation seeking $100 million in state funding
for I/I rehabilitation programs which includes a section
which would allow DEQE to fund a system—wide flow gauging and
monitoring system for the MDC;
8) DEQE is in the process of entering into a S39,000 contract
with a well known consulting firm to review all I/I data
within the MDC’S South System and to recommend an action
plan with regard to I/I reduction for the MDC.
9) DEQE plans to send correspondence to many of the MDC’s member
communities (letters already sent to Hingharn, Stoughton,
Westwood, Needham, Randolph, Quincy, Framingham, Natick,
Ashland, and Brookline) requesting their attendance at indi-
vidual meetings to discuss the additional I/I work that they-
will be required to perform.
DEQE believes that there must be a system—wide commitment for the
development and implementation of an integrated MDC sewer management
program. This program must include the provision for adequately sized
transmission and treatment facilities; a realistic I/I program; on—going
municipal sewer maintenance, effective sewer permit program and system—wide
flow monitoring. These five items will be discussed in greater detail in a
later section of this document. - .
These actions the Department has taken and plans to undertake are
based on our conclus4ons that the first priority in developing a new and
effective approach to solving the system—wide problems of the MDC is an
educational process for all concerned parties. The need for this educa—
tional process is a result of our review of our efforts, and those of EPA
and other major metropolitan sewer systems in dealing with I/I. By
recognizing past successes and failures, becoming familiar with new state—
of-the-art methods for dealing with I/I, and reviewing this information and
obtaining the advice of the Technical Advisory Group, we will have the
opportunity for the first time to devise an effective and workable system—
wide solution to the MDC’S problems.
Because we haven’t yet completed that educational process, or
formed of the Technical Advisory Group, which we feel is essential in deve-
loping a program which has the support and endorsement of all concerned in
the operation of the MDC system, we cannot now recommend a detailed
approach to solving the I/I problems, or what the mix of technical, funding
and administrative or enforcement mechanisms should be in such a program.
However, we have developed some basic concepts about what an effective
system must include and have reviewed the concepts of banking and trading
and expanded 2 for 1 program as they might be part of this overall solu-
tion. We offer our conTnents on banking/trading and 2 for 1 and our
thoughts on the minimal components of an integrated MDC system management
program for the consideration and use af the Technical Advisory Group, the
Court and all parties as a first step in devising an effective program.
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-.7—
Banking and Trading
DEQE has closely reviewed the feasibility of various types of
banking/trading systems, the two major catorgories being TM private capital
systems” and a “central bank”.
A workable banking/trading system must meet the following minimum
criteria: 1) Access to the system must be readily available to all who want
or need to participate; 2) I/I reductions for which credits are granted
should be verifiable; 3) I/I reductions should be permanent and enforceable;
and 4) I/I reductions should be exchangeable in a way that is meaningful
in terms of system-wide conditions. An examination of the MDC I/I
situation indicates that a private capital banking/trading system is unli-
kely to be successful in meeting these criteria.
A “private capital” system is one in which private developers
wishing to obtain sewer connection permits would either directly produce
reductions in I/I or purchase reductions from other private or public enti-
ties who had performed work necessary to remove I/I. Credits could be
“stored” in a bank or privately held under such a system. A “central bank”
system is one in which reduction credits are created by the bank (an
existing or new public entity or quasi—public entity) only, then sold to
developers who need connection permits.
A. Access to system . Perhaps the most fundamental barrier to a
private capital system is that access to that system is constricted and
complex. The sewerage system is made up of several layers of ownership:
MDC sewers; municipal sewers; and private laterals. Obtaining necessary
permission to perform work within such a system requires several steps:
site selection, ownership determination, and securing necessary approvals
from several sources. Municipalities may be unable or unwilling to grant
access under the terms of their easements; individuals may deny access
necessary to disconnect unauthorized laterals or remove sumnp pumps.
Apportioning potential tort liability will complicate the system further.
Finally, all of these barriers may be compounded by interjurisdictional
problems. In some municipalities reductions may be difficult or impossible
to achieve, causing developers to seek credits through reductions in other
jurisdictions. Some municipalities may be reluctant to encourage develop-
ment outside of their boundaries by allowing such work. Lack of technical
expertise may be another significant barrier. -
In brief, access to the reduction credit system would be con-
siderably constrained and many potential entrants may be excluded. The
same set of barriers makes it unlikely that their will be many
“speculators” who will produce credits for sale to developers.
By contrast, a central bank system does not necessarily pose such
barriers to access. To some extent, the same impediments to the creation
of I/I reduction credits exist; however, they are less severe because the
process could be centralized in a public or quasi-public entity which might
be able to secure necessar ’ access rights through specific enabling
legislation. More importantly, these barriers would not bar access into
the system by those iishing to purchase credits, as the purchase of credits
from the central bank requires only a cash exchange.
1*?
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-8-
B.•Verification : Verification issues, though chiefly technical,
have significant structural ramifications. The technical
problem posed by the preseiit condition of the sewerage syste n
are multifold, but for purpose of this discussion can be sum-
marized as follows. Because there is no effective flow moni-
toring facilities within either the MDC or its tributary
member system, it is extremely difficult to measure accurately
either a baseline for I/I removal in specific locations or the
amount removed. In addition, a gallon of Ill removed from one
point does not necessarily represent a gallon removed from the
system as a whole.
The impact of this situation on a private capital banking/trading
system is that realistic verification of I/I removal is virtually unob-
tainable and reductiop would be ephemeral. Realistic verification would -
require Department monitoring before and after each reduction, at all sites
selected by those attempting removal. The Department does not currently
have the staff or equipment to perform such monitoring tasks and the
required resources would be excessive compared to the potential benefits.
Even rough calculations based on total flow would be of little use because
it would be necessary to apportion specific amounts of reduction credit to
individual projects which would be occuring continually throughout the
sewerage system if the banking/trading system were to function properly. A
workable system with unverifiable reduction credits would be difficult if
not impossible to establish and certainly impossible to administer
equitably.
The same fechnical problems confront a central bank system, but
the structure of a central system offers the possibility that they-might be
manageable. Because credits would only be created through projects coor-
dinated centrally, baseline and post-project monitoring are more feasible.
Rather than isolated projects chosen by developers scattered throughout the
system, target areas can be selected for ru removal and some determination
made of the effects of the work on the system. Because afl credits created
go into the central bank, it is not necessary to apportion system—wide (or
sub—system—wide) credits among different projects. Credit allowances,
though not completely quantifiable would at least be more consistent;
making the system more equitable and more likely to obtain the desired
results.
C. Enforceability . The technical and structural issues con-
cerning the enforceability of I/I reduction are inextricably linked to
those of verification. Thus, the same problems outlined above affect this
criterion as well. Adding to these problems is the need for some sort of
permanence to the reductions obtained; i.e. removal of I/I must be effec-
tive for some specified period of time, or credits would be meaningless.
This concern requires the maintenance of that work, throughout the life of
the credit. A private capital system poses serious enforcement problems
from this standpoint. Quality assurance would require constant
Departmental presence at all projects. Requiring de elopers to return to
removal sites to perform maintenance work would be extremely difficult in
practical terms. The Department currently lacis the resources to perform
either of these functions.
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-9—
Again, a central bank system might be able to minimize some of
these difficulties. Both quality control and maintenance could be assured
more effectively by centralizing remova work. There is less likelihood of
either fraud or inadequate performance and as a result, such a system would
be more equitable and reliable.
0.. Credit exchange . The premise of the banking/trading systerri
is that I/I removal credits are both fungible and adequate to allow for
added new flow; in other words removal credits should be interchangeable
both with other removals and with added new flows elsewhere in the sewerage
system, regardless of time. A private capital banking/trading system assu-
mes that these units are interchangeable and in terms of the
banking/trading system only , this assumption is not unreasonable. However,
in terms of the sewerage system the assumption is false, and a system based
on it would be ineffective for solving the underlying problems of the
sewerage system.
Equal volume removal credits are not fungible for several
reasons, including timing of flow concentrationS, location within the system
or sub—system and likelihood that I/I removed from one point will enter (in
some proportion) at another or cause flooding.
If the effectiveness of removal measures deteriorates over time,
I/I reduction credits in the bank must also be devalued in the same ratio..
The wider the system and the more variation in conditions the greater the
likelihood of incompatibility of removal credits. Moreover, some of the
MDC component systems are fairly “tight”, while others offer good oppor-
tunities for I/I removal and still others may present flow problems that
should be solved in other ways . I/I removal actions also differ in cost—
effectiveness (in real terms, as opposed to EPA’s grant-related criteria
for cost—effectiveness).
The implications of the technical sewerage issues for the
banking/trading system strongly suggest that the only type of implementable
system is a central bank. A central bank system would focus I/I removal
efforts on target areas where I/I removal is most useful from a system—wide
viewpoint. The compatibility of removal credits with each other or with
proposed additional flows could be judged technically and adjustments in
the amount of credit allowed or needed for a particular project could be
made. It should be easier to establish sub—systems in which trading of
credits could occur. For example, credits neededfor North System connec-
tions should be based on North System removal. It may also be necessary to
further restrict the transfer area to sub—system levels.
Conclusions . Considering the four criteria of market access,
verification of removal credits, enforceability, and exchangeability of
removal credits from the standpoint of the sewerage system as a whole, a
central bank system seems to offer considerable advantages over a private
capital system of banking and trading I/I removal. The apparent advantage
of mobilizing private capital to address the I/I problem suggested by a
private capital banking/trading system is minimal, particularly since the
same amount of capital could be generated through the sale of removal cre-
dits created by a central bank and the resources could be directed more
effectivly with a centralized structure.
,s b
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-10-
Nevertheless, adoption of a centralized banking and trading structure
would not solve the underlying technica] problems. In particular, the
absence of effective flow monitoring capability within the system, and the
practical difficulties inherent in effectively removing I/I (see d scus io
below), seriously weakens any banking and trading system.
The central bank alternative would obviously require enabling legisla-
tion. This legislation would both establish the bank and the basic trading
rules and provide an initial funding resource. One major policy issue that
should be addressed if establishment of such a system is proposed is the
extent to which both start-up and future costs should be borne by the
public at large and what portion should be borne by those seeking to
purchase credits. Should the entire burden be placed on “new development”
or should some portion of the burden be shared by existing system users.
Greater Than 2 For 1 Program
There appears to be some confusion by the Court as to the intent of
the DWPC’s existing 2 for 1 program and whether that program could be used
to jjgnificantly reduce I/I in the MDC system. The program was never
intended to replace the Commonwealth’s Construction Grants Program which
has been providing large amounts of money to communities for work such as
sewer rehabilitation and I/I projects. The sewer ban and resultant 2 for 1
program was devised as an enforcement tool to get the particular
community’s “attention”. Some people have used the following analogy to
describe the program: “it is like hitting the community in the face with a
two-by—four to get their attention and then once their attention is
assured, develop a rasonably implementable method for reviewing, revising
and approving sewer extensions while not exacerbating flow problems within
the localized sewer system”.
To date there are 9 communities on the 2 for 1 program and several
others are under review. Since the implementation of the program in 1980
approximately 5.5 million gallons of flow have been listed as possibly
being removed from the sewer system. In affidavits presented to the Court,
DWPC stated that even if all I/I specified as being removed from the system
was in fact removed, it would take over thirty (30) years to reduce the
South System flows by 60 MGD using the same 2 for 1 format and assuming
similar numbers of yearly permit applications. The 2 for 1 program is even
less likely to significantly reduce flows to the sewer system as the town—
wide I/I rehabilitation programs previously attempted by the EPA. In fact
the “hunt and seek method” used by developers to find and repair isolated
sources of I/I to justify connection of a new building is precisely the
type of I/I rehabilitation procedure that all experts have denounced as
unworkable.
Professor Haar stated in his Masters Report the following with regard
to the current 2 for 1 program:
“The 2:1 reduction program is an interim remedy. Although it
will not result in the sane kind of significant flow reductions as will the
planned system- iide infiltration/inflow reduction program it will provide
relief since, without it, new additions will exacerbate the current
/5/
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—11—
failures of the system. While hot bringing about large improvements, it
will prevent the situation from deteriorating further in the near future.
It can be initiated immediately and can maintain the status quo or even
slightly lesson the frequency and/or the level of treatment bypasses while
the longer—term remedy of a planned system-wide infiltration/inflow program
can be increased by changing the present ratio 2:1 to require a removal of
three or even four units of infiltration/inflow for every new unit of flow
added to the system.
It is thus possible to design the program in an equitable and effi-
cient manner. The DWPC has the authority to impose such a program on MDC
member communities. Experience with jndividual communities has shown that
development typically does not stop and that infiltration/inflow is
removed as a result of the imposition of such programs. Therefore, the 2:1
reduction program is an appropriate interlocutory remedy to be imposed by
the Court.” -
DEQE believes that just increasing the percentage removals of I/I
from the current 2 for 1 to 3 or 4 for 1 will have no measurable impact on
bypassing and overflows into Boston Harbor. We do believe that the sewer
ban and 2 for 1 program is effective in forcing a corrniunity to deal with
its sewage problems and provides a framework for closer coordination be-
tween DEQE, the municipality and the development community.
Therefore, DEQE proposes to continue with the current 2 for 1 reduc-
tion percentage as part of its enforcement actions in cornnunities with
acute problems. However, the continued use and effectiveness of this
enforcement mechanism iill be closely reviewed in conjunction with the
development of a system—wide approach for dealing with I/I in the MDC
system, which is discussed below. If the system-wide approach offers more
effective alternatives to permanent removal of I/I, the use of the 2 for 1
program as an enforcement tool may be altered or discontinued.
Integrated Sewer Management Program
There must be a system-wide commitment for the develapment and imple-
mentation of an integrated MDC sewer management program. This program
must include at a minimum:
1) Provision of transmission, pumping and treatment facilities
with adequate capacity for the MDC system;
2) A realistic on-going I/I reduction program;
3) An effective sewer extension and permitting program;
4) An on—going municipal sewer maintenance/rehabilitation program
for all communities within the MDC system; and
5) A system-wide flow monitoring network.
We further believe that these five program elements can be implemented
and that much of it is currently on—going as specified below:
ici
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—12—
1) Capacity : The MDC. and many of its member communities are
.already implementing this program with such projects as the
Nut Island and Deer Island Primary Upgradings, East Boston
Pumping Station, Framingham Interceptor, Charlestown Pumping
Station, etc. The Procedural Order Item #23 tracks the
compliance for most of these ongoing projects.
2) I/I Reduction : The Departement plans to utilize the $100
million grants program (if enacted) to develop a state—of—the—
art I/I rehabilitation program which could remove DEQE from
the artificial cost effectiveness regulations required for the
expenditure of EPA grant monies. We would like to be able to
define major problem neighborhoods and rehabilitate all sewers
and associated facilities within the entire area with pre— and
post— flow gauging. Based upon the effectiveness of those
projects we would develop a priority rating system for the
entire MDC system and begin funding neighborhood reduction
projects.
3) Permits : DEQE has developed an interim program to ensure ade-
quate reviews of all permits within the MDC service area.
DWPC has sent requests to all South System municipalities
requesting copies of all building permits issued by them from
January 1982 to the present. This data will be cross—checked
against Sewer Extension Permit Applications to determine the
extent of compliance with our regulations. An extensive educ—
tional program has also been initiated by DWPC to help ensure
compliance with our permitting program.
4) Ongoing Municipal Rehabilitation : This is the most difficult
aspect to control and enforce since it is strictly a local
function with no state or federal regulations mandating the
nature and extent of such work and no outside funding sources
available to the municipality to offset the costs. A thorough
sewer maintenance program would require the expenditure of
significant amounts of local monies. Due to the current
financial constraints imposed upon the municipal governments
and the constraints upon new state regulations that increase
costs imposed by the Proposition 2 tax cap legislation, it
can almost be guaranteed that any type of elective expen-
ditures (preventive maintenance) will not take place. DEQE
believes that this type of work will become much more attrac-
tive to the municipalities if a method of assessment versus
flows is devised and implemented by MDC.
Also under existing regulations (MDC regulations and most local sewer
ordinances) it is presently illegal to discharge clean water (vooling
water, storm water, or groundwater) to the sanitary sewer systems. However
these regulations are not strictly or actively enforced in most cases. Any
preventive manintenance program should be “supported” by a strong enfor—
cent program conducted at the local, district (MDC) and state (DEQE)
levels aimed at eliminating to the maxir in extent feasible illegal connec-
tions of clean water into the 1 .100 and member communities sewer systems.
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-13—
Enforcernent activities would be cohducted by parties such as the MDC
Industrial Section; local public works departments, building and plumbing
inspection personnel; with general oversight by the DEQE — DWPC. The
system—wide monitoring capability would be used to target priority areas
for enforcement and investigations; to evaluate results and to monitor the
possibility or reconnection. Available penalties would be examined and
modifications proposed where appropriate.
5) Systenwide Flow Monitoring Network : The capability to monitor
and evaluate flow continuously throughout the MDC system and
at strategic locations within its member municipal systems is
essential to the proposed program of minimizing extraneous
flow in the system. The information gained through this capa-
bility could be utilized: a) in both the Federal and State
Grants Program for setting priorities for funding and eva-
luation of construction and rehabilitation work; b) in the
Enforcement Program to identify prime areas for investigation
of illegal connections; and c) on the Incentive Program in
establishing the flow upon which sewer charges will be based.
Continuous system-wide flow monitoring capability is a prere-
quisite for implementation of the proposed flow based sewer
charge system and for a realistic banking and trading system..
In summary we wish to again stress our belief that an intergrated
approach to the regional sewerage system difficulties is needed. The only
way to develop such an approach is to jointly educate all participants
(State Agencies, Municipal Officials, Area Legislators, etc.) in the
various facets of th. process. We do not want to blindly grab onto one or
a combination of quick—fix alternatives. Our own experiences with the 2
for 1 program is a perfect example . Our agency saw the program as a
readily enforceable and implementable method of reducing flows in the local
and MDC sewerage system to mitigate sewer overflows and surcharging while
allowing for reasonable continued growth to occur. DEQE, like EPA, assumed
that I/I reduction techniques used in the late 70’s and early 80’s actually
removed a significant percentage of I/I. We have recently learned that
such an assumption was incorrect to a large extent. The development of
our proposed Technical Advisory Group, can be used as a spring board to
begin this eductional process.
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,‘ tzacnment £
:v u ticm o? Infjltratjo:i/Infiow ina2 , ?c ort
July 1960
U.S. Erwiron enta1 Protection Age cv
C iAPTER 4
RECO &MENDATIONS
C N Z’ AL
The findings’of this.study indicate that Sewer Syste 4 -a Evalua-
tion and Rehabilitation generally does not result in sub—-
st r.tia1 system I/I flow reductions. The consecuence of
tnis s that returning I/I has used u all or substa a1
port onscz tne reserve capacity of new and u graded. treat
jtent facil tjes and thus, shortened the plants’ desjcn lives..
I/I is not going to ‘be removed., by i ’gnori it ’;-- Thus;—it. is -—
essantLal that it be evaluated in order that sewerage works
can b designed and operated effectively.
The following reconmandations are offered as possible courses
of action that EPA can undertake in order to ensure that
/: is effectively addressed in design and o era ions of
s : rage works. These recommendations ozzer a variety of
choices that could be implemented. Some recommendations
id be imole ented together while others could not_ A
dLscu sion is presented with each reco mend tion.
:2C -:Z DATION l
REVISE THE I/I PROGRP METHODOLOGY,
—k’ -
i J..
The existing 1/1 ?rogra methodology simply has not achieved
ex?ected results. It has become evident that successful
r ilitation is more of an exception than a general case;
ju3t the opposite of what was assumed when the I/I Pi’cgram
;.: s initiated. If the I/I Program is to be continues. the
th dology must be revised.
The follo :ing arc some of the possible changes to Ser
System Evaluations that would provide more realistic initial.
data, thus, resulting in more successful projects.—-
- Star,!ardize cuantificazion of system-vide I/I ..
Cr :1y, a :idc variety o para ctE .:s are uS2d in
design a cost ef ctiv€ czs analyses : or t- :7 1
flo.; c c t: i.e. wc-t on !/I, ak de..;
I/I, I/I at 10:2 v r - This
c’..’ t cc’ tllv C5 ifl- t-C . :stc . E nd.
tO DrOV1(F . e 1t .
‘ di c T c.o z effr. :iv- : a1”:.:
: ,:r .. . r’ cr I,’i ‘ :c. 1t : ‘.-l”.. -
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I/I flow monitoring and televisicn ins ectioa use
be rformed during wet weather and/or high ground-
water condItj n (I/I Hunting Season). This study
h z found that in many instances t l vjsjo inspec-
tion was not performed during peak high groundwater
conditions. Any leaks observed froni manholes, sewers
and house service connections were factored up to re-
flect. oeak flows. This practice has resulted in er-
roneous flow estimates from oinz Sources. It is
imperative that flow monitoring and television inspec-
tion be performed during a specific “hunting season”. -
This can be defined by using a specific systen total
flow parameter: for exa ple, three (3) tin .es -base
flow, or a system I/I rate greater than 6,000 gallons
per day per in-mile.
Establish a realistic system ItT rate to be used as
a cut-off for projects to proceed to Sewer System
Evaluation Surveys, ie., 6,000 gallons per day per
i nôh mile - -
s??. established an infiltration rate of 1,500 pd/i
mile including service connections in its P?2 i7 —lO -
Any rate be1o ; this value was considered non—excessive
This study has fo md that most of the projects had
pr -rehabilitatL n high week I/I rates exceeding
6,000 g dfin-rnile. Post rehabilitazjon high week
I/ rates were reduced from above to below 6,000
c /in-rnjje in only one (1) project. t may be pos—
sibi that cost-effective rehabilitation work can be
a hi ved in sewer syStems with ore—rehabilitation ii
: :z be2.ow 6,000 gpd/ n-znile, uz cnancas 0: SUCCeSS
be rninL- al. Establjshi ent of a cut—off-I/I
rate of, say, 6,000 cpd/in-mjle could sosed uo many
projects, and result in more successful rehabilita-
tion.
I c’ude lir it d t levjsjon insoaction and rain al1
sL - u1aticn work in the I/I Analysis Phase. -
In the I/I Analysis Phase, estirn3tes of I/I to be
rcmo;ed are made, rehabilita ion progr s projected
and cost—effectjvene s estimated. All this is done
withctut firm documantation of where the I/I is coming
fom. This stu:y has rour.a that a major source 01 -
i/I is house service connections, and the flow frotn
Is.’,
-------
this •sourco is not detectable i e:- x/z Ana1y is
Phase. In most instances, the :10w easured or
estimated during this Phase erronecuslv assu ries that
most of tha I/I .s fron manholes or sewer l saes, and
the resulting recoxr ended I/I. remcvals via sewer
line rehabilitation looks attractive: If limited
television insoection identit d s ecific sot rces, a
more rea1 .st .ce rehabiJ. tation pro;ra could e out—
lined. Performing limited television insoection of
say , 2 to 5% of the system,and possibly limited
rainfall simulation where inficu is suspeoted . during
the I/I Analysis Phase would result in more realistic
conclusions of this Phase of work.
Consider the impact of ±/1 from house sevice connec—
tion and groundwater migrationafte sewer line
rehabilitation.
This study h s found that estimates of I/I to be re-
duced by rehabilitation generally have been in the
60 to 90% range, while actual reductions have generally
been in the 0 to 30% range. In addition, during
cost effectiveness analysis no consideration is given
for m grat on oz groundwater to non-:ena 1 za ted
sources. The percent I/I reduction achievable by
r.ain barrel sewer line rehabilitation, including
test and seal programs, is dependent on one (1) par—
ameter more so than any other: the percentage of 1/I
coming fran rain barrel defects versus the pecentage
coming from house service connections. etelevisina
curing th .s stucy found tnat I/I aces c2grate to nOn—
rehabilitated sources, and that rehabilitated sewers
wi ere le ss than 60% of the pre-rehabilitetion I/I
was documented coming from sewer joint leaks (versus
:r ouse service connections) achieved reductions less
than 25%.
A rough estimate of this important parameter should
be ascertained as early as possible. Under the pre-
sent methodology, this parameter is not defined until
at least the SEES televising phase. In certain cases,
where S5ES televising was forecorie in lieu of ro—
posed test anc seal program, or en SS S televLslng
was done during low groundwatc:, the se :er line
joint lca percentage was not ascertained at all
I . order to more realistically oredict I/I ercentage
ro a1 , we have d velooed the curves oresanted in
r1 u e 4—1. sti: ating I/I c uczions. These curves
w :e dev lc ad fro- . actual re.ul: and :e 1i tically
corpc ra rctu:ning I/Z fror house s r-:ice connec—
and r r 1 tcr igr t1 .
is?
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CURVE A
U)
F—
0
‘jJ
Ii.
l U
C)
-J
-j
lii
ii:
‘C
(n
z
0
LL
Li.
0
• TEST a SEAL WITH LlMIT o
SERVICE CONNECTIoj REP !fl
C l )
t&I
C-,
>
a:
Lu
U)
0
a:
I L.
CURVE B
• REPLACEMENT
• SLIP LINE
• TEST Q SEAL WITH EXTENSIVE
WORK ON SERVICES.
LI.
0
.
0 25 50 75 100
% INFILTRATION REDUCTION
ESTIMATING
I/I REDUCTION
FIGURE 4-I
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Standardize television inspection flow estir ating
technique.
Visual flo : estir ation of leaks bserved during tele-
vision inspection can vary by as much as +5O .- This
data is.a significant element of any cost effective—
ncss analysis and resultant rehabilitatiofl pro r
A standardized technique should be developed_
. . ZNr .;TION 2
REQUIRE THAT REHABILITATION BE PERFOR ON A “PATCH” BASIS.,
SUCH THAT NO PIPE IS LEFT UNREHABILITATED 111 AU AREA CHOSEN
FOR REHABILITATION. THIS WILL MINIMIZE THE OPPORTU II1Y FOR
I/I TO MIGRATE FROM REHABiLITATED SEVIER SECTIONS TO ! ON—
PEHABILITATED SECTIONS.
sC:j3SION
T:.. notion of I/I mIgration from rehabilitated sewer sec—
ti.n to non—rehabilitated sections is widesoread. Rehabili—
t ticn ‘ ork can Lometnes take on a “little bit here, little
bit there” appearance; thus maximizing the opportunity for
I/I t igrate upstrea n or downstream of rehabilitated sources.
j.’ acceptance of test and seal grouting over specified
ja i ;rcuting wa based on resolving the I/I migration ef—
I -
::c e e :tensiVe test end seal, as well as other rehabilitation
t c u s ay be required to minimize the I/I migration
.— S,, —S• ’
DECREJ SE THE STANDARD DESIGN LIFE OF TRE TNENT PLANTS FRO1
20 YEARS TO 10-20 YEARS.. DEPENDING ON THE ABILITY OF LONG
RA E REUABILITATION TO REDUCE i/I.
r - ‘ -‘ —
_l_..1
T. :e rtt oitu tion, in part due to th failure be the I/I
P D:: . ’. iS new or racec t:e tr2 t pl n s are at or
d : gn c p oity afrer only on (1) or t o (2) years of
o:. zi’ . ‘i : CC.Z1 ar f c 3 ‘,ith planning now or
-------
ti c r.ear future for either substantial sewer line-rehab—-
ilitation id/or plant expansion. These corr unjtjes were, ii
fact, cxp ct.tng tO atcain 20 years of useful Life from
th e treat ient plants.
way around the present dileiiina is to be realistic and nOt-
ov rlv oPtimistic about the effectiveness of sewer-line re—
habi1it tion and tr atnent plant desig-i l e Th ol ow g
:o: a ion s ou!d s co si.de:ed during the planning and/or
o erat on of new sewerage works. -
- Recognize that generally a sewer system rehabilita—
tion program will reduce I/I from 10 to 3O . There,
of course, wifl be exceptions to this general r-Eile..
• “One shot” sewer systen evaluation and r habi1itatioa
will not identify and/or eliminate all the sewer
system I/I problems. n on—going operat on ax a a n—
tenanc program nust be L- p1ernented to include in—
vestigating new and old I/I sources and perfor aing
on-going rehabilitation.
• The actual effectiveness of rehabilitation in red c—
in; I/I flows in the system should be deteriüned,
afte rehabiLit €ion is coi tp1ete.
T: s, the approach to sizing treatment plants would be to
in iuc a larcer I/ flow co onent (than would be est s ated
a: - : rehabilitation under the present nethodology, which
t s to e::pact large reductions in I/I) a d a smaller re—
z ve capacity f. r base flow expansion. This would tend to
ee th a ;eraga treat ent plant size and cost about the
s e a under the present I/I methodology- By designing new
tlants to handle not-so—drastically reduced I/I flows. and
plyLna ror tn2s oy l mizing future reserve capac1ty the
actual changes in I/I and base flow can be monitored, and
thus, facilitate decisions on additional rehabilitation andf
0: ?l t expansion as the 10 year or more design lifeis
app :cached -
R C ’ ATICN 4
E FO CE SEWER LiNE OPERATION A D MALMTE A CE PROGRPS S.
r ir
Cp r tiOn tr d mai tenanc (0 i -i) proç ans on sewer syst s
are rc qui: td p r PR i78—1C.- This study -as fou that this
-------
is no being i pl nzeci. An.on—goinc 0 M rocra - t. will
djsco’ r n w I/I sources and often these will be easily re—
crcd- It is .in the best interest of the counity, fror t
a cozt effective perspective to continually evaluate arid re—
ve I/I th t.is less expensive to elirainate than to treat.
C0 4Z DATI0N 5
A RESS THE PRO3LE:1 OF I/I FROM PRIVATE SOURCES; SPECIFICALLY
THE DEIECT1ONJ DISCOW ECTION AND REP,41R OF PRIVATE I/I
SOURCES SUCH AS SUi ? PWIPSJ DRAINS, ROOF LEADERS A LEA}(—
ING SERVICE LATERALS,
DTSCC5SION
I/I contributed from rivate sources generally constitutes
o ar Q% of the system I/I. Thus, treatment plants will
c nti e to have hich I/I flows durinc wet eather and hi i
c:o : ater conditions if orivate I/I sources are ot re—
In orcer to reduce treatment plant sizes a! d main—
çcod treatment plant operation, corr unities shc ld ad—
c!:ess these private 1/ sources. Thcse co unitias that
ig c.re this major problem should be penalized
? DATI0 : 6
c; ;cTirAT . pr TT?*Ir A cIIt .InT .’r TD ;’TIl •rUAT J1 r nT.
Li r’ r..J J. i iI u r i iwihu .. IIJLsL,R . It iL L J;I
F?R ?::ASED REHA JLJTATiON WITH GO/NO-GO DECiSION POINTS
!: ,•,1-L! -
1 IL.. L LF
Sc . i0N
T e /I reduction achieved by rehabilitating a collection
svzte cannot be ascertained finally until after the work
iz cc lete and th system experiences design—level pre—
cipit ion/s ie1t conditior.s.
o 7 atter how veil-documented the pre-re- abilitatiorL I/I
so rc :s, it at .a s that ccuntin on an estii ted reduction
t cosr ef zive is anala’ ous to counting on a cood be
t c zhro gh. A phased proçra or rena 1 tat n. oul
the ctua2. re ction achieved by rehabilitating part
a collecticn sy ze to be used in datcr injnc t e ost
eff c i ;nss of :th r rehabilitation -
I,,’
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p a ed rch bilitation could be integra ed with service .pop
u1at d e: p ion; i.e. phased reduction of the i/I design
cc. one t co’ 1d f ee up treaLi ent plant design capacity
for bcse flow e:pansion
re arc probler s w .th .such an approach. Tb.e variability
o rainfall and snowrnelt from year to year could lead to
f e co c1usions about achieved reductions. A r di g
- ctur3 that allc s so/No-Co decisions after each pbase
cc :ld cc an adm n1strat3.ve nightrnare.. The problems i volved
;it ’ fu d g, i particular, would require detailed e-jalua—
af ore adopting any form of phased rehabilitation..
RECOXME DATION 7
WSTLTUTE A STUDY TO DETEP.J’UNE THE ACTUAL EFFECTS OF I/I
LO JiNG ON TR TMENT PL HT PERFORMANCE. USE THE RESULTS
TO ESTABLiSH GUIDELINES FOR DESIGNING FOR If I
DT SSION
T-e:c is currently no standard design practice for handling
£11 ot: : than the use of standard design hydraulic loading
r s dcveloped for raw s age A rational basis for treat—
i: j dii .:ted se :age is ç arly needed, based on the docuz entcd.
of I/I loading on plant perfor ar ce. The capacity
c t: ent plants to weather both short-term “inf1o ”
ar:d long—term “infiltration” should be deternined. as
: y p:esc t a significant “source” of I/I capacity in—
in standard treatrnent plant design practice
a
I :sflTUTE DISCHARGE PEPJ ’HT REQUIREIIENT VARtPJ CES DURING
P ODS OF HIGH I/I FLO ISJ TAKING ADVAUTAGE OF THE INCREASD
S!J1lL4TiVE CAPACITY OF RECEIVING iIATERS THAT GENERALLY
C3: ?A iES HIGH I/I FLOWS.
‘ .- —.— - S.
r .iL ’2 I/I loadings r v cause treatnant o iant efficiencies
t- r c d well bclcw the rec.iired 85% re iovais for Bio—
c iC Oxygen Demand 1 OD) and Suspended Solids (SS)
- cc . yina d ’uticn effect of the I/ ge e ’’v en bl s
: c :luent ch r ctc:ist1cs to re7r .ai.n e .cw 3 r .gra s
c. lite The toz:.l of these eff1ue t r etcrs
b i: as c3, ‘: t higher recc iv! g te: flc z z ay
v: the a ;i7’ilatiVC capac .tY.
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• CC : N .;TION 9
!: TITL’TE A (1O TORIUH ON ALL I/I ANALYSES AND SE 1ER SYSTEM
EVALUATiON SURVEY REPORiS THAT ARE UND WAY OR RECE LILY
C0i PLETEDI THESE PROJECTS SHOULD BE REVIEWED P D 3IJIFIED
ACCORDING TO THE FINDINGS OF THE STUDY,
DISCUSSION
I/I Analyses and Sewer System Evaluation Surveys are still
i g based on unreelistièally high expected red ictio s.
One (1) or two (2) years from now these projects wifl. be con—
szructed and the same findjnqs of effectiveness will be
made as in this study Thus, in the long run it would ba
beneficial to delay these projects for a short period now,
aid obtain more realistic results when sewer line re! bj1jta—
tion is Completed.
/1.3
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PEAK 1/I P ED C ICN
SO YI - O OL X DISTP IC
_________ t ated Exis ing I/I’ Proccse I/I
— VGD 2 -?DIM 3 .:GD G? IM
A hia d 0.63 3330 0.36 1900
125.0 20830 .66.0 11000
! , ai. tree 16.2 10750 9.05 6000
3 1ine* 8.8 9150 5.30 5500
aritor 5.1 7800 2.85 4330
10-3 i250 5.9 7150
7.1 3180 4.2 1900
.6.0 26500 1.0 4400
c1 rcok N/A N/A N/A 500
3.1 3500 2.2 2450
tick 3.45 3230 2.0 1350
4.]. 3100 2.65 2000
11.3 5530 6.5 3200
9.2 8310 6.0 5400
cy 22.4 9150 12.9 5250
2.6 3660 1.5 2150
St. -2tc 1.8 3860 1.2 2550
3.3 8350 1.2 31 0
i1es1ey 3.7 2370. 2.5 1600
1.2 2900 0.7 13 0
¶•: c th 8.1 5550 5.1 35 3
_, —-..— £.._. -‘ • _l U . ——
r ,:
-: s2d u : ir’r r t.t c: of c rr .-t icr t DE’E
2 . .
- . ; Y. = G:.1!c” :• - —.-. - ., , .: . . ii J
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