Final
Environmental Impact Statement
For The
French River Cleanup
Program In
Massachusetts
And Connecticut
January 1987
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United States
Environmental
Protection Agency
Region 1
JFK Federal Building
Boston, Mass. 02203
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Final
Environmental Impact Statement
For The
French River Cleanup
Program In
Massachusetts
And_Connecticut
January 1987
Michael R. Deland
Regional Administrator, USEPA
Prepared For:
U.S. Environmental Protection Agency
Region 1
JFK Federal Building
Boston, MA 02203
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FINAL ENVIRONMENTAL IMPACT STATEMENT
Proposed Action: French River Cleanup Program in Massachusetts and
Connecticut
Charlton, Oxford, Dudley and Webster, Massachusetts
and Thompson, Connecticut
Date: January, 1987
Summary of Action: This Environmental Impact Statement examines several
alternatives to improve water quality in the French
River. The river is beset with extreme low flow and
several dams entrapping polluted sediments
exacerbating dissolved oxygen levels. The ElS
examines sediment control and sources of flow
augmentation and their impacts to improve water
quality in the river basin. The following proposed
activities maximize benefits to the river: low flow
augmentation from Buffumvilie Lake, channel excavation
and wetlands isolation at Perryville and Langer’s
Pond, sediment excavation at the North Grosvenordale
impoundment and instream aeration at the North
Grosvenordale impoundment.
Lead Agency: U.S. Environmental Protection Agency, Region I, JFK
Building
Boston, Massachusetts
For Further Mr. Ronald G. Manfredonia
Information: Water Management Division
U.S. EPA, Region I
JFK Federal Building
Boston, MA 02203
617 223—5610
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TABLE OF CONTENTS
Page
List of Tables v
List of Figures viii
CHAPTER 1 - INTRODUCTION
Projeet History & Need 1-1
Project Objectives 1-3
CHAPTER 2 - ALTERNATIVES FOR WATER QUALITY IMPROVEMENT
General 2-1
Screening of Alternatives 2-1
Point Source Modifications 2-1
Low Flow Augmentation 2-3
Sediment Control 2-8
Instream Aeration 2-10
Selection of Alternatives For Further Evaluation 2—11
CHAPTER 3 - AFFECTED ENVIRONMENT
Physical Setting 3-1
Topography 3-1
Geology 3-1
Climate 3—3
Hydrology 3-3
Water Quality Classification & Designated Uses 3—7
Point Source Discharges 3-9
Leicester Wastewater Treatment Plant 3-10
Worcester Tool & Sampling 3-10
Oxford-Rochdale Wastewater Treatment Plant 3—10
Massachusetts Turnpike Authority Westbound Facility 3—12
Dudley Wastewater Treatment Plant 3—12
Webster Wastewater Treatment Plant 3-13
Sanitary Dash Manufacturing Company 3-13
Other 3—1 4
Existing Water Quality Conditions 3—V4
Temperature and pH 3-15
Dissolved Oxygen and BOO Biochemical Oxygen Demand 3-15
Nutrients 3—25
Bacteria 3—28
Priority Pollutants 3—31
Water Quality at Buffuniville Lake 3-33
Sediment Quality 3—36
Physical Distribution of the Sediments 3—36
Priority Pollutants 3—HO
Sediment Oxygen Demand 3.J45
1
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TABLE OF CONTENTS (Continued)
Page
Water Quality Model . 3_149
Hydrology and Hydraulics 3- 49
Model Calibration 3—50
Simulation of Existing Low Flow Conditions 3-51
Biological Conditions 3-55
Phytoplankton 3-55
Vegetation 3-59
Benthic Invertebrates 3-69
Fisheries 3-77
Wildlife 3-81
Summary of Environmental Quality 3-86
Socioeconomic Conditions and Recreational Resources 3-87
Introduction 3-87
Population 3-88
Economic Resources 3-88
Land Use 3-90
Archaeological and Historic Resources 3-93
Recreational Resources and Uses of the River 3—95
Institutional and Regulatory Framework 3-102
Town Plans 3-102
Town Zoning and Land Use Bylaws 3-103
Town Wetlands and Floodplains Restrictions 3_10A4
Riparian Rights 3—105
Water Quality Plans and Regulations 3-105
Massachusetts General Laws and Regulations 3-106
Connecticut General Laws and Regulations 3-110
Federal Laws 3-112
CHAPTER 14 - IMPACTS OF ALTERNATIVES
Introduction 41
Impacts of the No Action Alternative 4-1
General ‘ 4-1
Water Quality Impacts of No Action ‘4-2
Biological Impacts of No Action 14_7
Socioeconomic Impacts of No Action 4-8
Impacts of No Action on Recreational Resources and
Use Attainability ‘4-8
Impacts of No Action on Archaeological and Historic
Resources ‘4-10
Regulatory and Institutional Constraints of No Action ‘4-10
Impacts of Low Flow Augmentation from Buffumville Lake ‘4-10
General 14 10
Engineering Issues Associated with Low Flow Augmentation 4-11
Water Quality Impacts of Low Flow Augmentation ‘4-19
11
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TABLE OF CONTENTS (Continued)
Page
Biological Impacts of Low Flow Augmentation 4-22
Socioeconomic Impacts of Low Flow Augmentation 14_2)4
Impacts of Low Flow Augmentation on Recreational
Resources and Use Attainability 4-25
Impacts of Low Flow Augmentation on Archaeological
and Historic Resources 14 27
Regulatory and Institutional Constraints of Low
Flow Augmentation 4-27
Impacts of Sediment Control in Perryville, Langer’s Pond,
and North Grosvenordale Impoundments 4-28
General 4-28
Engineering Issues Associated with Sediment Control 4-28
Water Quality Impacts of Sediment Control 4-40
Biological Impacts of Sediment Control
Socioeconomic Impacts of Sediment Control 4- 48
Impacts of Sediment Control on Recreational Resources
and Use Attainability 4-50
Impacts of Sediment Control on Archaeological and
Historic Resources 4—51
Regulatory and Institutional Constraints of Sediment
Control 4-51
Impacts of Instream Aeration in Perryville, Langer’s Pond,
and North Grosvenordale Impoundments 4-52
General 4—52
Engineering Feasibility Associated with Instream Aeration.... 4-53
Water Quality Impacts of Instream Aeration 4-59
Biological Impacts of Instreani Aeration 4-61
Socioeconomic Impacts of Instream Aeration 4-61
Impacts of Instream Aeration on Recreational Resources
and Use Attainability 4—62
Impacts of Instream Aeration on Archaeological and
Historic Resources 4-62
Regulatory and Institutional Constraints of Instream
Aeration 4-62
CHAPTER 5 - COMPARISON OF ALTERNATIVES AND SELECTION OF RECOMMENDED PLAN
General 5-1
Comparison of Alternatives 5-2
Alternative Selection 5-12
No Action 5-12
Sediment Control 5-12
Low Flow Augmentation 5-17
In-Stream Aeration 5-17
Summary 5-18
Description of the Recommended Plan 5-18
Implement Advanced Wastewater Treatment 5-19
111
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TABLE OF CONTENTS (Continued)
Page
Implement Low Flow Augmentation 5-19
Isolate Wetlands at Perryville and Langer’s Pond 5-20
Excavate Sediment in Channels at Perryville and
Langer’s Pond 5-20
Excavate Dry Sediment in North Grosvenordale Pond 5-21
Install Two Aerators in North Grosvenordale Pond 5-21
Impacts of the Recommended Plan 5-21
Mitigation Measures 5-23
APPENDIX A - References A-i
APPENDIX B - Supplemental Biological Data B-i
APPENDIX C - Responsiveness Siininiry C-i
iv
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LIST OF TABLES
Table Title Page
2—1 Comparison of Impacts at Hodges Village and Buffuinville
Due to Low Flow Augmentation at 22 cfs 2-5
2—2 Summary of Existing Water Level Variation at
Buffumville Lake 2-7
3-1 French River Dams Below Burncoat Brook Confluence 3-6
3-2 Minimum Water Quality Criteria for All Waters of
Massachusetts 3-8
3—3 Water Quality Criteria for Class B Inland Waters in
Massachusetts and Connecticut 3-9
3 .M French River Flows During MDWPC Water Quality
Data Collection Surveys 3-15
3—5 Dissolved Oyxgen Criteria for the Protection of
Freshwater Aquatic Life 3 2 4
3—6 Ammonia Criteria for the Protection of’ Aquatic Life 3—31
3—7 Metals Concentrations in the Waters of the French River.... 3_3)4
3—8 U.S. EPA Ambient Water Quality Criteria for Metals 3-35
3—9 Sediment Quality in Perryville Pond 3— 41
3—10 Sediment Quality in Langer’s Pond 3- 42
3—11 Sediment Quality in North Grosvenordale Pond 3_143
3-12 Sediment Quality in Grosvenordale Pond 3_1414
3—13 Metals EP Toxicity in Sediments - Connecticut
Impoundments 314)4
3-1 4 SOD Rates From Various EPA Surveys of the French River 3_147
3—15 Phytoplankton Data - August 18, 1982
Perryville Impoundment, Webster, MA 3—56
3—16 Phytoplankton Data - July 9, 198 4
Perryville Impoundment, Webster, MA 3-57
3—17 French River Dominant Plankton Data - August 19814,
Connecticut Impoundments 3-58
V
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LIST OF TABLES (Continued)
Table Title Page
3-18 Taxonomic Listing of’ Aquatic and Wetland
Vascular Plants and Associated Habitats in
Perryville Pond, July 198)4 3-61
3-19 Macrophyte Analysis in Connecticut Impoundments -
August 198)4 3—65
3—20 Perryville Impoundment Invertebrate Analysis,
July 9, 1984 3-74
3-21 Percent Occurrence of Dominant Macroinvertebrate Taxa
at Langer’s Pond - October 1984 3-75
3-22 Percent Occurrence of Dominant Macroinvertebrate Taxa
at North Grosvenorda].e Pond — October 198)4 3-75
3-23 Percent Occurrence of Dominant Macroinvertebrate Taxa
at Meehanicsville Pond - October 198)4 3-76
3-2)4 Invertebrate Analysis, Town Meadow Brook, Leicester,
Massachusetts - October 198)4 3-78
3-25 French River Fish Data - August 19814 3-79
3—26 Perryville Fish Tissue Metals Analysis — August 19814 3-82
3-27 Langer’s Pond Fish Tissue Metals Analysis (Wet Weight) -
September 19811 3-83
3-28 North Grosvenordale Pond Fish Tissue Metals Analysis (Wet
Weight) —September 198)4 3 8 14
3—29 Wildlife Likely to Occur in French River
Impoundment Areas 3-85
3—30 Population Characteristics of French River Study Area 3-89
3—31 Municipal Finance — 1984 Figures 3-91
3-32 Land Use in French River Study Area — 1980 Figures 3-92
3-33 Existing Uses of the French River and Impoundments 3-96
3-34 Factors Restricting Attainment of Desired and
Designated Uses of the French River 3-98
vi
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LIST OF TABLES (Continued)
Table Title Page
4-1 Webster/Dudley Advanced Wastewater Treatment Estimated
Average Annual Cost J 4 _ 9
4—2 LFA Storage Requirements 14_14
4-3 Stage-vs-Storage for Buffuniville Lake 4-17
14...14 Low Flow Augmentation Costs 4-25
14_5 Alternative Sediment Control Methods 4-28
4—6 Evaluation of Sediment Control Methods 4-29
4—7 Site-Specific Feasibility of Sediment Control
Alternatives ‘4-39
4-8 Costs of Sediment Control 4- 49
14....9 Instream Aeration Costs 4-62
5—1 Engineering Features — Comparison of Alternatives 5—3
5—2 Water Quality Impacts — Comparison of Alternatives 5-6
5—3 Biological Impacts - Comparison of Alternatives 5-14
5—4 Socioeconomic and Recreational Impacts -
Comparison of Alternatives 5-15
5-5 Channel Dimensions 5-21
5—6 Cost of Instream Improvements 5—23
vii
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LIST OF FIGURES
Figure Title Page
1—1 Thames River Basin 1—2
3-1 French River Basin 3-2
3-2 French River 7Q10 Low Flow Profile of Water Surface
and Channel Bottom 3-5
3—3 Location of Point Source Discharges 3—11
3_)4 Average pH Levels in the French River:
1982, 19814 and 1985 MDWPC Surveys 3-16
3-5 Average BODç Concentrations in the French River:
1974 and ¶976 MDWPC Surveys 3-18
3-6 Average BODç Concentrations in the French River:
1982, 198 and 1985 MDWPC Surveys 3-19
3—7 Dissolved Oxygen Concentrations in the French River:
19714 and 1976 MDWPC Surveys 3-20
3—8 Range of Dissolved Oxygen Concentrations
in the French River: 1982 MDWPC Survey 3-21
3-9 Range of Dissolved Oxygen Concentrations
in the French River: 1 9 8t4 and 1985 MDWPC Surveys 3-22
3-10 Average Total Phosphorus Concentrations
in the French River: 197 4 and 1976 MDWPC Surveys 3-26
3.-li Average Total Phsophorus Concentrations
in the French River 1982, 19814, and 1985 MDWPC Surveys... 3-27
3-12 Average Nitrate—N Concentrations in the French River:
1982, 19814 and 1985 MDWPC Surveys 3-29
3-13 Average Ammonia-N Concentrations in the French River:
1982, 19814, and 1985 MDWPC Surveys 3-30
3 1 14 Fecal Coliform Concentrations in the French River:
1982, 19814, and 1985 MDWPC Surveys 3—32
3-15 Sediment Distribution in Perryville Pond 3—37
3-16 Sediment Distribution in Langer’s Pond (Wilsonville, CT)... 3-38
3-17 Sediment Distribution in North Grosvenordale Pond 3-39
viii
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LIST OF FIGURES (Continued)
Figure Title Page
3-18 Sensitivity of SOD to DO in Overlying Water
at Start of In-situ Analysis, Sediment Cores
from Perryville Pond, May 1985 3- 48
3-19 Calibration to 1982 Data: Sensitivity to
Photosynthetic Oxygen Production 3-52
3—20 Calibration to 1982 Data: Sensitivity to
Measured Sediment Demand Values 3-53
3-21 Dissolved Oxygen Concentrations Under Low Flow (7Q10)
Conditions 3_514
3-22 Aquatic and Wetland Vascular Plants in
Perryville Pond 3-63
3-23 Aquatic and Wetland Vascular Plants in
Langer’s Pond (Wilsonville) 3-66
3_2t Aquatic and Wetland Vascular Plants in
North Grosvenordale Pond 3-67
3-25 Aquatic and Wetland Vascular Plants in
Grosvenordale Pond 3-68
3—26 Habitats at Buffumville Lake 3-70
4-1 Sensitivity of Dissolved Oxygen to Advanced Wastewater
Treatment Under Low Flow (7Q1O) Conditions 14_4
Sensitivity of Dissolved Oxygen to Flow From Webster-Dudley
Wastewater Treatment Plant Under Low Flow (7Q10)
Conditions 14_6
J4_3 Spiliway and Outlet Works of Buffumville Dam
(Plan and Logitudinal Section)
Spiliway and Outlet Works of Buffumville Dam
(Section View)
4—5 Outlet Rating Curves for Buffuinville Lake 4-15
4-6 Buffuinville Lake Stage - Storage Curve 4-18
4-7 Sensitivity of Dissolved Oxygen to Low Flow Augmentation
From Buffumville Lake Under Low Flow (7Q10) Conditions 4-20
Sensitivity of Dissolved Oxygen to Sediment Control at
Perryville Impoundment Under Low Flow (7Q10) Conditions.... 4-43
ix
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LIST OF FIGURES (Continued)
Figure Title Page
14 9 Sensitivity of Dissolved Oxygen to Sediment Control at
Perryville and Langer’s Impoundments Under Low Flow
(7Q10) Conditions
Sensitivity of Dissolved Oxygen to Sediment Control at
Perryville, Langer’s and North Grosvenordale Impoundments
Under Low Flow (7Q10) Conditions 14_! 5
14_il Oxygen Transfer Rate Conversion Factor
14_12 Sensitivity of Dissolved Oxygen to Instreain Aeration Under
Low Flow (7Q1O) Conditions 14-57 ’
14. . .13 Schematic of Instream Aeration Diffuser System
5-i Sensitivity of Dissolved Oxygen to Low Flow Augmentation
From Buffuinville Lake and Sediment Control at Perryville,
Langer’s and North Grosvenordale Ponds Under Low Flow
(7Q10) Conditions 5—10
5-2 Sensitivity of Dissolved Oxygen to Sediment Control
at Perryville, Langer’s and North Grosvenordale Ponds and
Instream Aeration Under Low Flow (7Q10) Conditions 5—11
5-3 Sensitivity of Dissolved Oxygen to Low Flow
Augmentation From Buffumville Lake, Sediment Control
at Perryville, Langer’s and North Grosvenordale Ponds
and Instream Aeration Under Low Flow (7Q10) Conditions 5—13
x
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Chapter 1
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CHAPTER 1
INTRODUCTION
The French River originates in southern Worcester County,
Massachusetts, and flows southward into northern Windham County,
Connecticut, where it joins the Quinebaug River and subsequently the
Thames River (Figure 1—1). The Thames River discharges into Long Island
Sound at New London, Connecticut.
Project History & Need
Over the past decade, the environmental quality of the French
River has drawn the attention of several federal, state and local
agencies. Problems have been cited, studies conducted, and a variety of
water quality improvement projects have subsequently been proposed, some
of which have been or are currently being implemented. Most of the
cleanup efforts to date have focused on individual point sources, and
particularly on upgrading the treatment of industrial and domestic
wastewater flows to the river. However, a long history of heavy
industrial development and the associated construction of numerous mill
dams along the French River have compounded the degradation of
environmental conditions in the river to the point that even the planned
treatment plant improvements will not be sufficient to achieve the Class
B water quality desired. Specifically, low dissolved oxygen
concentrations (< 5.0 mg/i), and high nutrient concentrations (total
phosphorus > 0.1 mg/i) persist in impounded stretches of the lower half
of the river, particularly during low flows. The dissolved oxygen levels
are in violation of State standards for fishable/swimmable water quality
in the river. In addition, sediment deposits behind the dams contain
high levels of heavy metals and other potentially toxic contaminants, and
are subject to noxious odors when exposed. Data indicate that the
aquatic biota in these portions of the river have been negatively
impacted by the poor water quality. Desired recreational activities in
downstream impoundments are similarly curtailed.
1—1
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FIG. 1.1 THAMES RIVER BASIN
FRENCH
RIVER
BASIN
MASS.
CONN. —
MASS .
R.I.
8
SCALE IN MILES
NEW
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In 1983, the Army Corps of Engineers’ New England Division studied
the feasibility of seasonal low flow augmentation storage at the Hodges
Village Flood Control Dam project, located in the upstream portion of the
French River basin. The study was based on using the stored water to
augment natural low flows in the river in order to alleviate downstream
water quality problems. In February 198)4, the Corps of Engineers issued
the “Draft Environmental Impact Statement for Low Flow Augmentation at
Hodges Village Dam, Oxford, Massachusetts”. This project would involve
the removal of 130 acres of wetland, 36 acres of upland, 11 acres of
river and 3 acres of disturbed land. This would be replaced, in part,
with a 155 acre augmentation pool which would be seasonably drawndown to
a 113 acre permanent pool exposing 7 acres of’ non-vegetated shoreline and
lowering the water level in 35 acres of new wetland on the western side
of the pool (see U.S. Army Corps of Engineers, 19814 for a more detailed
description of the project). Based on the significant environmental
impacts associated with the project and the lack of review of other
alternatives, the decision was made by EPA to supplement the Draft Hodges
Village EIS with a comparable evaluation of other alternatives for
achieving water quality goals.
In September, 1985, the Draft Supplemental EIS for the French
River Cleanup Program in Massachusetts and Connecticut was completed. In
May, 1986 the Final Supplemental EIS was issued. The Final EIS (January,
1987) includes incorporation of comments from various Federal and State
agencies and local organizations.
Project Objectives
The objectives of the “Environmental Impact Statement for the
French River Cleanup Program in Massachusetts and Connecticut” are to
rigorously evaluate feasible alternatives for achieving water quality
goals in the French River, as they have been identified through agency
and public input, and to identify an environmentally and economically
sound plan for implementation of the recommended alternatives.
1-3
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Chapter 2
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CHAPTER 2
ALTERNATIVES FOR WATER QUALITY IMPROVEMENT
General
In order to develop an appropriate list of reasonable alternatives
to be evaluated in the French River RIS, EPA held several scoping
meetings with the general public in the study area, and participating
federal and state agencies and local officials. A number of alternative
actions to clean up the French River were identified during this
process. Generally, the alternatives can be grouped into four basic
categories: point source modification; low flow augmentation; sediment
control; and instream aeration.
Once identified, the alternatives were given a preliminary screening
based on their potential effectiveness in meeting water quality
standards, engineering feasibility, relative cost, environmental impacts,
and institutional constraints. Alternatives which were judged
unacceptable on the basis of any of the criteria were eliminated from
further evaluation. Alternatives involving a multiplicity of viable
options (e.g. surface water sources for flow augmentation) were narrowed
down to one or two of the “best” options.
Screening of Alternatives
Point Source Modifications . As will be discussed in more detail in
the next chapter, several municipal wastewater treatment plants and
industries currently discharge wastewater to the French River. It has
been proposed that modification of these point source discharges, either
by further treatment of the wastewater or reduction in effluent flow to
the river (at least during critical periods), could relieve some of the
water quality problems which persist in the river.
At present, all of the treatment plants on the river perform at
least secondary treatment of wastewater flows during the summer months.
Of these, the only discharges which directly affect water quality in the
stressed segments of the river are those located in Webster and Dudley,
2-1
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Massachusetts. A facilities plan recommending the upgrading of these
plants to a 6.0 mgd consolidated advanced treatment facility (M&E, 198 4)
has already been presented to EPA (EPA Suniniary of Findings on AWT,
1985). EPA has approved funding eligibility for the proposed treatment
plant. Implementation of AWT is assumed as a “base case” in this
evaluation of additional actions required. The Webster-Dudley combined
facilities plan thoroughly addressed various other treatment alternatives
and found them to be unfeasible, primarily due to cost limitations and
space constraints at the sites. Any additional level of treatment at
Webster-Dudley, beyond that already proposed, could only be achieved at
considerable cost, for relatively little incremental improvement in
effluent quality.
The reduction of effluent flow at Webster-Dudley in order to
minimize adverse impacts on the river is an alternative for achieving
desired water quality. Options for achieving flow reduction include
restrictions to the service area or industrial discharges to limit
influent flow; seasonal land application of effluent; and detention of
discharge during critical low flow periods in the river. All of these,
however, are limited either by land availability or by institutional
factors. As part of the evaluation of point source modifications the
sensitivity of the French River water quality to the volume of discharge
from the Webster-Dudley treatment plant was evaluated. The feasibility
of storing Webster-Dudley wastewater flows during critical water quality
periods was also examined. Webster-Dudley f1o ::j of zero, 3.25 mgd, 14 5
mgd and 5.145 mgd, flow were evaluated. Reducing the effluent flow would
not necessarily improve water quality conditions in the river. Computer
modelling of instreain dissolved oxygen concentrations with a 25 percent
lower effluent discharge at the Webster—Dudley advanced treatment
facility reveals little to no sensitivity to flow. This is probably due
to the fact that, although BOD loads to the river would be less with the
reduced discharge, the lower effluent flow (which represents a
significant component of river discharge under low flow conditions) would
result in an increased residence time in the impoundments downstream,
thereby decreasing dissolved oxygen levels.
2—2
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In addition to Webster-Dudley, it is possible that the level of’
treatment or effluent flow for the other point source discharges to the
French River could be altered. Most of these discharges, however, are in
the upper half of the French River basin and are relatively remote from
the problem areas downstream. It is expected that the effects of higher
levels of treatment from upstream sources would be dissipated in the
intervening stretches, and have relatively no impact in the stressed
areas. Data obtained in the water quality modelling effort support this
conclusion.
Low Flow Augmentation . Low flow augmentation, the release of water
from storage in order to improve downstream water quality during low
natural flow conditions, has already been shown to be a potentially
viable option for meeting water quality standards in the French River.
The Hodges Village EIS addressed one such scheme, that of maintaining a
minimum flow of 22 cfs in the river by supplementing natural low flows
with water retained at the Hodges Village flood control dam. Although
that particular project had significant environmental impacts associated
with it, including the removal of 130 acres of wetland, the study did
show that low flow augmentation could be used to improve dissolved oxygen
concentrations in the river during critical periods. Alternatives for
flow augmentation, therefore, revolve around various other locations for
flow storage in the upper basin. Both groundwater and surface water
resources (other than Hodges Village) have been recommended for
evaluation.
Depending on the hydrology of the drainage area, the use of surface
storage sources for flow augmentation can be accomplished either by
drawing down the existing pool level as needed during summer low flows
and then refilling it with fall runoff, or by storing up spring runoff
and drawing it down as needed during the summer. A combination of the
two approaches is also feasible. As a result of the Hodges Village EIS
which found that 500 acre-feet of additional storage or LFA to 22 cfs was
required to meet water quality standards, low flow augmentation to 22 cfs
was considered a reasonable flow to begin with in the analyses of varying
augmented flows in the French River.
2—3
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One screening criterion assumption used to evaluate potential low
flow augmentation sources was that minimal expansion would occur in the
surface area of the impoundments due to increasing water level. For
screening purposes, the total rise in water surface elevation was
therefore conservatively estimated to equal the maximum increase
possible.
On the basis that a potential fluctuation in water level in excess
of 6 feet would have too great an impact on the area surrounding the
pond, only the surface impoundments in the upper French River basin which
are greater than 80 acres in area were reviewed for potential use for
flow augmentation storage. Smaller ponds were not considered unless they
could be grouped with other impoundments to provide sufficient area. In
all, 18 different impoundments, or combinations thereof, were
evaluated. Available hydrologic information was reviewed, and town
engineers, consultants, and industries were contacted for further
information regarding physical characteristics of the ponds and dams and
existing uses of the water.
Those ponds which are so shallow that additional storage could
potentially flood surrounding houses, or that sufficient drawdown to
provide the necessary flow would affect well levels and significant
aquatic habitat, were eliminated from further consideration. Hodges
Village was also eliminated as a viable option due to the severe
environmental impacts that would occur (see Table 2-1). Also eliminated
were those impoundments from which flow is already strictly controlled by
an existing industry, e.g. Webster Lake, for which Cranston Print Works
owns water rights to 2 feet above and below a specified benchmark.
Finally, hydrologic calculations were performed for each of the remaining
alternative surface water sources, to assess the capability of the
respective drainage basins to provide the additional flow without
significantly altering existing pool levels and natural releases from the
impoundments.
As a result of the screening process described, alternatives for
flow augmentation were narrowed down to 8 feasible options: Burncoat
Pond; Cedar Meadow Pond; Burricoat and Cedar Meadow Ponds; Stiles
2—It
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TABLE 2-1. COMPARISON OF IMPACTS AT HODGES VILLAGE AND BUFFUMVILLE DUE TO LOW FLOW AUGMENTATION AT 22 CFS
Parameters to be
impacted Hodges Village Buffumville
Substrate 265,000 cubic yards of organic and May cause some shore erosion during draw
surficial sediments removed within down although water level variation would
120 acre area of the reservoir (with be within normal operational range.
average depth of removal <1.5 feet).
Change in surface sediment quality
to 2/3 gravel size and 1/3 sand
by weight.
Suspended Cofferdam activity would intermit- No impact since water fluctuation will be
Particulate tently increase suspended solids during within normally occuring range.
Turbidity construction. Heavy sedimentation will
occur in Augultenback Pond 600 feet
downstream of the dams.
Water Quality Construction activity would increase No significant construction required;
turbidity and nutrients in water downstream D.0. would increase over
column which could also result in a baseline conditions
decrease in D.0. levels downstream.
Following construction downstream D.0.
improvements would occur.
Normal Water Fluctuations beyond normal range Fluctuation will be within range that
Fluctuations will occur. normally occurs
Threatened No Impact No impact
and Endangered
Species
Benthos Benthic invertebrates will be buried No significant impact in lake; downstream
from sedimentation in impoundment and there will be slight increased diversity
downstream during construction and density.
activities; following construction
downstream diversity and density
should increase.
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TABLE 2-1. (CONTINUED) COMPARISON OF IMPACTS AT HODGES VILLAGE AND BUFFUMVILLE
DUE TO LOW FLOW AUGMENTATION AT 22 CFS
Wi 1 dli fe
Wetlands
Recreation
11 acres of upstream riverine habitat
within 180 acre Impact area would be
removed. Diversions would be created
using cofferdams. 37 habitat units
for the 14 species evaluated with HEP
would be lost. Sedimentation in down-
stream areas could smother benthic plants
invertebrates and fish nests. Decreased
D.0. in impoundment may stress fish.
Construction activities would disrupt
and destroy wildlife habitat within
the 180 acre Impact area as well as
disrupt the surrounding area. Wetland
associated species would be most
impacted while upland species would be
marginally impacted.
Removal of 130 acres of wetland and
11 acres of’ riverine habitat
No impact on recreation at Rocky Hill
and Greenbriar Recreation Areas.
Creation of seasonal pool will offer
opportunity for development of
recreation activities
No impact on lake. Positive impact
downstream due to Increased D.0.
No impact
6 acres of periferal wetland will
experience water level fluctuations;
however, these fluctuations are
within the normally occuring range.
No impact downstream. Minor impact
at lake during summer; may require
mitigating measures; decreased
headroom at culvert under-road; and
minimum flooding of beach, although
these impacts currently occur due to
fluctuating water level.
Archeology
No impact
No impact since water fluctuation will
be within normally occuring range.
Fisheries
Parameters to be
impacted Hodges Village Buffurnville
-------
Reservoir; Slaters and Robinson Ponds; Buff’umville Lake; Pierpoint Meadow
Pond; and Buffumville Lake and Pierpoint Meadow Pond. Of these,
Buffumville Lake is by far the most preferable option, since it is the
largest single impoundment and has the largest drainage area; its
periphery is relatively steep and undeveloped; the outlet control works
are in excellent condition; and it is federally owned and operated.
Also, the change in water level that would occur at Buffumville due to
LFA to 22 cfs is within the range of water level variation that currently
exists. Water level variation at Buffumville is summarized in
Table 2—2. The existing operating pool level elevation is 492.5, and one
of the proposed maximum operating pool levels (for LFA of 22 cfs) is
495.O, which allows for over 500 acres-ft. of’ additional storage. As is
shown in Table 2—2, the water level in Buffumville Lake currently
frequently exceeds elevation 1495.0, and it is not uncommon for elevations
well over 500 ft. to occur.
TABLE 2-2. SUMMARY OF EXISTING WATER LEVEL VARIATION
AT BUFFUMVILLE LAKE
Water
Year
Maximum Pool
Elevation
(NGVD)
No. of Days
Pool Elevation
Exceeded 1195.0
No. of Days
Pool Elevation
Exceeded 492.5
1980
501.0
15
205
1981
499.6
10
185
1982
506.3
31
280
1983
5014.0
142
232
1984
506.0
30
227
A review of the available hydrogeological data for the study area
indicates that the use of groundwater for flow augmentation is far less
feasible an option than some of the surface water alternatives. Most of
the aquifers in the area are hydrologically connected to the streams that
overlie them, so that groundwater removal could induce infiltration and
decrease groundwater discharge, thereby depleting streamfiow and the
amount of actual augmentation. Most known areas of high aquifer
2-7
-------
transmissivity in the French River basin are beneath the river or its
tributaries. Also, the known permeable areas are already developed to
some extent for public water supplies. The areas that could be
considered for groundwater development for flow augmentation are thus
limited.
Since increased low flow augmentation might result in water quality
improvements without the need for other measures, the assessment of low
flow augmentation greater than 22 cfs from Buffumville Lake was evaluated
in terms of impact on water quality in the French River as well as
impacts at Buffuinville Lake due to increased storage.
Sediment Control . Sediment control is a particularly important
consideration for the lower portions of the French River, where several
old mill dams impound water and extensive deposits of sediments high in
metals, nutrients, and organic content. It is in these impoundments that
occasional water quality problems persist, largely due to the oxygen
demand exerted by the sediments. In the EPA AWT review of the Webster-
Dudley facilities plan (EPA, 1985) it was estimated that, subsequent to
the initiation of advanced treatment, 50 percent of the sediment oxygen
demand (SOD) would have to be eliminated from the impoundments downstream
in order to achieve water quality standards for dissolved oxygen. In
order to address the most severely impacted areas, on the assumption that
small amounts of water quality improvements would carry over to
impoundments downstream, sediment control alternatives would be
implemented in the impoundments in Perryville, MA, Wilsonville, CT, and
North Grosvenordale, CT only. Potential approaches to sediment control
in the impoundments include sediment removal; in situ sediment
deactivation; physical and/or chemical stabilization of the sediments;
and dam removal or modification.
Although costly and time consuming, sediment removal with subsequent
dewatering and disposal is probably the most effective method of reducing
SOD and potential toxicity in the impoundments. It also provides the
added benefits of improving bathing and boating activities and
controlling macrophyte growth. A discussion of disposal options for the
removed sediment is provided in the Alternatives Evaluation section of
this report. Preliminary information indicates that the sediments are
2-8
-------
not hazardous by Resource Conservation and Recovery Act (RCRA) standards,
and thus will not require a hazardous material disposal area by these
standards. Further documentation of sediment characteristics and
identification of specific disposal sites will be required prior to
sediment removal. Additional information on sediment characteristics and
disposal alternatives is provided in Chapters 3 and 14
Sediment deactivation, in the sense of rendering the material
chemically inactive, is not a realistic alternative for the deposits in
French River impoundments. There are presently no known chemical agents
which can be added to the sediments in situ to actually “treat” the
oxygen demand and potential toxicity exerted. Metals in particular are
not degradable. In addition, any biological agents which could deplete
the oxygen demand would probably be inhibited by the more toxic
components of the sediments.
Stabilization of the sediments is a more conceivable method for
dealing with at least some of the sediment deposits in the river. The
objective of stabilization would be to render the sediments and their
associated contaminants both immobile and isolated. This can
theoretically be accomplished by any one of a number of biological,
chemical, and physical methods. Not all, however, are appropriate for
use in the French River. In fact, biological stabilization through
uptake of contaminants by organisms is part of what any remedial action
would seek to avoid.
Chemical stabilizers work on the principle of bonding the sediments
to immobilize the contaminants within them. Various forms of lime,
asphalt, concrete, and polymeric resins can be used to stabilize soils.
However, their application to sediments which are submerged or high in
water content is limited. From a practical standpoint, chemical
stabilizers could only be used in situ in the French River on surface
layers of drained sediment deposits. The environmental consequences,
logistical difficulties, and economic cost of doing so generally make
this an undesirable option. The application of chemical stabilizers in
the treatment of dredged slurry is more feasible.
Physical stabilization entails the installation of a barrier between
the contaminated sediments (e.g. lining, containing, or covering them)
2—9
-------
and the surrounding environment. For the French River, one of the most
applicable forms of physical stabilization would probably be sediment
capping. This method would be used to isolate the contaminants from the
water column and provide a clean substrate for bottom dwelling organisms.
Depending on other alternatives implemented, slope stabilization may
also become an integral part of cleanup measures in the impoundments.
This would be especially necessary in situations where channel excavation
is conducted but backwater and wetland areas are left undisturbed.
Crushed stone, clay, timber or metal sheeting, earthen enbankments, and
concrete retaining walls are all viable alternatives for slope
stabilization. The selection of one alternative over another is
dependent on a number of’ factors, ie. slope, flow, velocity, desired
permeability, etc. and is best done on a site—specific basis when more of
this information has been established.
Due to the high buildup of sediments behind the dams, dam removal
could only be considered as a cleanup alternative in conjunction with
complete sediment removal in the impoundments. Thus, the costs
associated with this option are high. In addition to the benefits
associated with removing the sediments, the elimination or breaching of
the dams would increase the velocity of flow in the river, thus reducing
residence times in the impoundments. However, it would reduce the
reaeration which presently occurs over the dams. Most importantly,
removal of the dams would eliminate any potential uses of the
impoundments for recreational use, hydroelectric power generation, and
wildlife habitat, all of which are desired uses of the lower French
River.
Instream Aeration . Artificial stream aeration has historically been
used in riverine systems as a partial solution to depressed dissolved
oxygen levels. It is a particularly appropriate alternative when an
increase in dissolved oxygen concentration is required for short periods
of otherwise adverse wastewater assimilative capacity, such as is the
case in the French River during low flows. The application of this
alternative to the present situation in the French River would entail the
installation and seasonal operation of mechanical surface aerators or
submerged air diffusers at several locations within the presently
2-10
-------
stressed segments of the river. The aerators would disperse air
throughout the water column, increasing the rate of oxidation and aerobic
decomposition of sediment organics. Pure oxygen could also be used, but
would be prohibitively expensive. Based on projects conducted in similar
systems (Whipple et al., 1971), properly designed and located aerators
should be able to maintain the ambient dissolved oxygen in the river at a
concentration above the 5 mg/i standard. They would not, however,
address other water quality problems in the river such as SOD, nutrient
concentrations or other pollutant concentrations, and could even
contribute to mobilization of contaminants in the sediments.
Selection of Alternatives for Further Evaluation
As a result of the screening of alternatives described above,
cleanup alternatives in four categories were selected for more
comprehensive impact evaluation in the FEIS. These alternatives are as
follows:
1. No Action Beyond AWT. The no action alternative assumes the
implementation of a consolidated advanced treatment facility at
Webster—Dudley. Although it is not expected to result in
achievement of water quality goals by itself, the no action
alternative was evaluated for purposes of comparison. The
sensitivity of the French River to Webster-Dudley flows was
assessed by evaluating AWT flows of zero, 3.25 mgd, 4.5 mgd and
6.0 mgd. In addition, feasibility of storing Webster-Dudley flows
during critical water quality periods was also assessed under this
alternative.
2. Low Flow Augmentation. Flow augmentation from Buffumville Lake
was evaluated as a means of improving water quality in the French
River during periods of low flow. The impacts of augmented flows
of 22 cfs and greater were evaluated.
3. Sediment Control. Sediment control measures were evaluated as a
means of improving water quality conditions in the impoundments at
2—11
-------
Perryville, MA, Wilsonvil].e, CT and North Grosvenordale, CT.
Alternative methods evaluated for controlling sediments are:
Sediment removal. This could be accomplished by either
dredging or by drawdown followed by excavation. This method
would also entail dewatering and transport of the sediments,
location of a suitable disposal site, and potential treatment
of the disposed sediments.
Sediment capping. Those areas capped would first be excavated
to the depth of the cap before the capping material is placed.
Sediment slope stabilization and wetlands isolation. This
method would isolate the wetland sediment deposits from the
main segment of the impoundments, thereby leaving the wetland
areas undisturbed and reducing the sediment impacts in the
impoundments.
For alternatives involving sediment control the effectiveness of
each option in reducing SOD was evaluated and quantified.
4. Instream aeration. Options for increasing dissolved oxygen
through aeration in the impoundments in Perryville, MA,
Wilsonville, CT and North Grosvenordale, CT have been evaluated.
Further detailing of these alternatives is presented in Chapter ,
together with a discussion of the consequences associated with each. A
more detailed description of the French River environment as it currently
exists is presented in Chapter 3.
2-12
-------
Chapter 3
-------
CHAPTER 3
AFFECTED ENVIRONMENT
Physical Setting
The French River drainage basin is approximately 112 square miles
in area, and includes portions of the towns of Leicester, Auburn,
Douglas, Charlton, Dudley, Oxford, and Webster, Massachusetts and
Wilsonville, North Grosvenordale, Grosvenordale, and Mechanicsville, all
within the town of Thompson, Connecticut (Figure 3-1). The basin is
approximately 2 4 miles long, (north to south) and 8 miles across at its
widest point.
Topography . Topography of the basin is generally uneven, with
many small hills 100 to 200 feet high, and open, sometimes swampy,
lowlands. Numerous small ponds and wetland depressions are scattered
throughout the area. Slopes range from zero to 25 percent, with the
steeper gradients occurring in the upstream portions of the basin.
Geology . Local soils are mostly composed of glacial till, water-
sorted sand and gravels, and clay, silt and fine sands. The principal
bedrock materials underlying the region are granite, gneiss, schist,
sandstone, shale, slate, phyllite and limestone. Geologically speaking,
the soils of the basin are relatively young, the result of a cold New
England climate which retards the development of soil from the parent
glacial material. Some organic material has accumulated, and the soils
have derived a brown coloration, due both to the organic content and the
oxidation of iron in the soil minerals.
The well-drained upland soils in the basin are classified in the
Gloucester-Charlton--Paxton-Brookfield series. Those soils which have
developed under high moisture conditions are principally of the Sutton
and Whitman series, and those developed under deficient moisture
conditions are in the Hinckley (hills) and Merrimac (plains) series.
Soils in areas of recently deposited alluvium, e.g. along stream beds,
are grouped in the Ondawa series. In addition, small areas of mucky
soils occur throughout the basin.
3—1
-------
WENCER (
I
I ,
“I’
L
It
LESCESTER
I
2
0
2
SCALE IN MILES
USGS STREAM GAGES
AUBURN
DIARL TOW
V
OXFORD
MILL&JRy
-
HODGES
VILLAGE
DAM
4- -
JTTOW
/
DUDLEY
/
-
SOUTH
I
DOUGLAS
DAM
FIG. 31 FRENCH RIVER BASIN
-------
Climate . Typical of southern New England, the climate in the
French River basin is variable, with warm summers and cool winters. The
mean annual temperature is approximately 147 degrees F, with average daily
temperatures ranging between 10 and 80 degrees F. Mean annual
precipitation is 42 to 145 inches. Precipitation is fairly evenly
distributed throughout the year, although runoff may be retained in the
snowpack for up to four months due to subfreezing temperatures. Although
the basin lies within the prevailing westerlies, its weather is more
influenced by the occasional coastal storms, known as “northeasters”,
which move up the New England seaboard. These storms are characterized
by heavy rain, snow and fog. Some storm events, generally those of
tropical origin, have caused historic flooding in the French River basin.
Hydrology . The northernmost headwaters of the French River
consist of two small brooks which drain Elliot Hill in northern
Leicester, converge, and flow into Sargent Pond. From there, the stream
continues southward as Town Meadow Brook for approximately four miles
through several more small ponds and a marsh, picks up flow from Barton’s
Brook (draining Stiles Reservoir), and enters Rochdale Pond. Rochdale
Pond also receives flow from Grindstone Brook, which drains Henshaw Pond
and Great Cedar Swamp. The combined flow out of Rochdale Pond is the
start of the mainstem of the French River. The river continues to flow
southward into Oxford, through several palustrine forest areas, small
ponds and former impoundment areas. Several tributaries enter the river
in Oxford, including the Little River (draining 27.7 square miles which
includes Gore Pond, Granite Reservoir, Buffumville Lake, and Buffum
Pond); an unnamed brook draining several small ponds from the east; and
Mill Brook, flowing out of Webster Lake. Below Oxford, the river flows
through downtown Webster and several impoundments therein, picks up flow
from a brook draining a five pond network to the west, and continues
between southern Webster and Dudley into Perryville Pond. Within 100
yards downstream of the Perryville Dam, the river crosses the State line
into Thompson, Connecticut and, for the next 7.1 miles, passes through
impoundments at Wilsonville, North Grosvenordale, Grosvenordale, and
Mechanicsville before reaching its confluence with the Quinebaug River.
3-3
-------
In all, the length of the river from its headwaters in Leicester
to its confluence with the Quinebaug is approximately 30 miles. The
total elevational drop of the river is around 600 feet, more than
80 percent of which occurs within the first 10 miles. As shown in
Figure 3-2, the river’s gradient differs significantly between the upper
and lower portions of the basin. Above the Hodges Village dam in Oxford,
the channel is generally steep and the river fast flowing, with shallow
rocky rapids in some stretches. Downstream of Hodges Village, the
gradient flattens out and the river follows a deeper, more meandering
channel. Some exceptions exist in both sections, i.e. there are several
sluggish river segments in the upper basin, and a series of shallow
rapids do exist in the downtown Webster segment.
Several severe flood events during the 1950’s precipitated the
construction of two large U.S. Army Corps of Engineers flood control dams
in the French River basin. The Buffurnville dam on the Little River was
completed in October 1958, and two years later a second darn was completed
at Hodges Village, on the mainstem of the French River. While the
Buffumville darn has a permanent pool (Buffurnviile Lake) behind it, the
Hodges Village darn only impounds flow during a flood event. Numerous
mill dams were also constructed along the French River, especially during
the heavy industrial development of the textile era. Each of these dams
had or has a small impoundment behind it. Although many of the dams have
been removed or breached in more recent years, at least fourteen are
still in existence on the French River, and remnants and sediment sills
from others remain. Table 3-1 lists all the dams which have been known
to exist on the river, and their current status. The cumulative effect
of the large number of dams has been to cause sluggish flow in many
portions of the river, contributing to high sediment deposition and poor
water quality.
The U.S. Geological Survey (USGS) maintains four flow gages in the
French River basin. The gage furthest upstream in the basin is located
on the French River just below the Hodges Village darn. It monitors flow
from a 31.0 square mile drainage area, and has been in operation since
1962. The average discharge at the gage is L 7.2 cubic feet per second
3.. .L
-------
4
0
MILES UPSTREAM OF CONFLUENCE WITH OUINEaAUG RIVER
FIG. 3-2 FRENCh RIVER LOW FLOW PROFILE
700
0
I . .
4
0
-J
0
>
I .,
z
I II
>
0
4
I-
w
w
U-
600
500
WATER SURFACE
I
400
0
ELEVATION
4
0
w
-a
-J
>
4
0
w
-J
4
0
0
z
l i i
0
I,
z
4
0
4
0
‘U
-a
4
0
0
z
‘U
>
0
I,
24
20
18
12 10 8 6 4 2 0
-------
TABLE 3-1.
FRENCH RiVER DAMS 1 ELOW BURNCOAT
BROOK CO*JFLUENCE (1)
River mile
(above
Quinebaug
Drainage
Impound-
Current
River
Location confluence)
area
(miles 2 )
ment area
(acres)
Status
1. Greenville
2. Below Greenville
3. Above Hankey Pond
4. Hankey Pond
5. Rochdale Pond
6. Rochdale Mills
7. Above Cominsville
8. Cominsville
9. Thayer Woolen
10. Lamb’s Privilege
11. Protection Mills
12. Rockdale Mills
Sigourney Pond
Huguenot Mills
White Village
Hodges Village 3
17. Howarth’s Mills
18. North Village
19. South Village
20. Chaseville
21. Perryville
22.41
NA
21.79
20.48
20.06
19.75
19.33
19.02
18.70
18.64
15.77
15.63
10.29
9.59
8.39
7.10
river
river
mill
rerouted
rerouted
built
1. Adopted from: Dams of Worcester County, Worcester County Engineers,
County Courthouse, Worcester, MA (As cited in Hubbard, 1979)
2. NA Not Available
3. Hodges Village is currently used for flood control storage only.
23.64
23.59
NA
NA
22.64
13.
114.
15.
16.
14.3 44 In place, recent
construction
NA Removed
NA 1/16 Removed,
15.2 3 Removed,
18.6 42 In place,
over dam
19.5 10 Removed
NA NA Removed, location
unknown
20.1 1 -2 In place, reconstructed
1956
21.8 145 Breached 1955 (Texas
Pond)
22.1 3 Removed for road
relocation
23.0 2-3 Breach completed 1955
211.3 8 In place, mill race
blocked
214.6 10 Breached 1955; removed
214.8 2 Washed away 1955
211.8 Darn intact; pond drained
31.1 0 Flood control; through
flow
31.1 52 Removal completed 1955
84.7 20 In place, reconstructed
1936
85.14 15 In place, reconstructed
1939
90.8 12 East spiliway removed
1958
93.1 9 In place, present darn
1870
96.4 19 In place
97.9 35 In place
100.5 3 In place
110.7 142 In place
22.
23.
24.
25.
Langers Pond
N. Grosvenordale
Grosvenordale
Mechanicsville
6.00
4.17
2.60
0.20
-------
(cfs). Another USGS gaging station is situated on the Little River,
immediately downstream of the Buffumville dam and 0.6 miles upstream of
its confluence with the French River. The gage has been operative since
1939, however, the dam has been regulating flow since 1958. The average
flow at this station is 145.9 cfs, from a drainage area of 27.7 square
miles. A third gaging station on Brown’s Brook monitors flow into
Webster Lake from a 0.5 square mile drainage area. Many of the daily
flow records from this station, dating back to 1962, show no flow. The
fourth and final gage in the French River basin is located on the
mainstem of the river in Webster, downstream of both flood control dams
and most of the major tributaries. Its drainage area is 85.3 square
miles, or 76 percent of the total watershed. Average flow there is 159
cfs. Discharge is less than 200 cfs almost 75 percent of the time.
Average annual runoff in the French River basin upstream of the Webster
gage for the period from 1950 to 197 1 was 214.89 inches (1.814 cfs/sq mi),
or approximately 52 percent of the average annual rainfall. The USGS
gage at Webster was discontinued in 1981, and is no longer active.
The two flood control dams, Hodges Village and Buffumville, do not
significantly affect either the monthly or annual mean discharges of the
French River, however, they do tend to dampen the peak discharges which
would otherwise occur. Both reservoir projects are regulated to attempt
to limit French River flows to 1000 cfs, which is considered to be
nondamaging channel capacity.
Water Quality Classification & Designated Uses
The entire length of the French River in Massachusetts and
Connecticut is designated by each State as Class B, inland waters.
Waters assigned to this class are designated for use in the protection
and propagation of fish and other aquatic life and wildlife; primary and
secondary contact recreation; agriculture; certain industrial processes
and cooling; and aesthetic value. The French River is specifically
designated as a warm water fishery. Table 3-2 lists the minimum criteria
which must be met in all waters of Massachusetts, except when the
criteria specified for the designated classification are more stringent
3—7
-------
TABLE 3-2. MINIMUM WATER QUALITY CRITERIA
FOR ALL WATERS OF MASSACHUSETFS
Parameter Criteria
1. Aesthetics All waters shall be free from pollutants in
concentrations or combinations that:
a) Settle to form objectionable deposits;
b) Float as debris, scum or other matter to
form nuisances;
c) Produce objectionable odor, color, taste
or turbidity; or
d) Result in the dominance of nuisance
species
2. Radioactive Substances Shall not exceed the recommended limits of
the United States Environmental Protection
Agency’s National Drinking Water
Regulations.
3. Tainting Substances Shall not be in concentrations or
combinations that produce undesirable
flavors in the edible portions of edible
organisms.
14 Color, Turbidity, Total Shall not be in concentrations or
Suspended Solids combinations that would exceed the
recommended limits on the most sensitive
receiving water use.
5. Oil and Grease The water surface shall be free from
floating oils, grease and petrochemicals and
any concentrations or combinations in the
water column or sediments that are
aesthetically objectionable or deleterious
to the biota are prohibited. For oil and
grease of petroleum origin the maximum
allowable discharge concentration is 15
mg/l.
6. Nutrients Shall not exceed the site specific limits
necessary to control accelerated or cultural
eutrophication.
7. Other Constituents Waters shall be free from pollutants in
concentrations or combinations that:
a) Exceed the recommended limits on the
most sensitive receiving water use;
b) Injure, are toxic to, or produce adverse
physiological or behavioral responses in
humans or aquatic life; or
c) Exceed site-specific safe exposure
levels determined by bioassay using
sensitive resident species.
3-8
-------
stringent. The criteria for Class B inland waters in both states are
presented in Table 3-3. The minimum flow to which these standards apply
is the 7Q10 flow, or the minimum average daily flow for seven consecutive
days that can be expected to occur once in ten years. For the French
River, the 7Q10 is 1 4.8 cubic feet per second (cfs) at the Webster gage
(period of record 1950 to 1980).
TABLE 3-3. WATER QUALITY CRITERIA
FOR CLASS B INLAND WATERS
IN MASSACHUSETTS AND CONNECTICUT
Parameter Criteria
1. Dissolved Oxygen Shall be a minimum of 5.0 mg/i in warm water
fisheries and a minimum of 6.0 mg/l in cold
water fisheries.
2. Temperature Shall not exceed 83 deg. F (28.3 deg. C) in
warm water fisheries (85 deg. F is the
standard in Connecticut) or 68 deg. F
(20 deg. C) in cold water fisheries, nor
shall the rise resulting from artificial
origin exceed 4.0 deg. F (2.2 deg. C).
3. pH Shall be in the range of 6.5-8.0 standard
units and not more than 0.2 units outside of
the naturally occurring range.
14• Fecal Coliform Shall not exceed a log mean for a set of
samples
Bacteria of 200 per 100 ml, nor shall more than 10%
of the total samples exceed 1400 per 100 ml
during any monthly sampling period.
Point Source Discharges
A total of four wastewater treatment plants and three industries
presently hold NPDES permits allowing them to discharge to the French
River. In the past there have been other point source discharges, but
these plants have either been tied into local municipal treatment plants
or have ceased operation. The following summarizes those discharges
currently located along the French River, beginning with those located at
the upstream end of the river in Leicester MA, and ending with the
3—9
-------
disehargers in Thompson CT. Figure 3-3 shows the locations of these
point source discharges.
Leicester Wastewater Treatment Plant . The Leicester Wastewater
Treatment Plant receives flow from the l. 4 square mile sewer district in
the center of Leicester. The plant has a 0.27 mgd design capacity and
discharges an average flow of 0.118 mgd into Rawson Brook and Dutton
Pond. According to its discharge monitoring reports, the Leicester
Wastewater treatment plant meets secondary limits. The plant was built
in 1967 with a 20 year design life. The plant’s NPDES permit was
reissued on June 27, 1986 and requires advanced wastewater treatment.
The NPDES permit requires effluent limits for BOD and TSS of 12 mg/i and
20 mg/i, respectively, from April 1 through October 30; the effluent
limit on NH 3 -N is 2 mg/i from June 1 to September 30; and the effluent
limitation for total an P is 1 mg/i from April 1 to October 30.
Construction of the AT facilities began on June 2, 1986. Completion is
scheduled for November 2 , 1987.
Worcester Tool & Stamping (formerly CWM Electroplating) . The
Worcester Tool & Stamping Company is a small tool manufacturing
industry. The plant’s effluent, which results from the industry’s
plating processes, undergoes chemical treatment and lagoon settling
before being discharged to the French River about one mile downstream of
the Leicester treatment plant. The industry’s NPDES permit limits the
concentrations of’ suspended solids, pH, cyanide, nickel, zinc, copper,
oil and grease, and total toxic organics. Although there have been
periodic violations of nickel and copper limits in the past, the company
is currently in compliance with its permit. Worcester Tool & Stamping
has noted copper as being especially difficult to remove from its
effluent, since their building’s tap water contains 0.5 mg/I of copper.
The industry’s NPDES limit is 0.3 mg/i.
Oxford-Rochdale Wastewater Treatment Plant . Located in Oxford,
the Oxford—Rochdale WWTP is a secondary treatment plant with a design
capacity of 0.18 mgd. It serves the Rochdale section of Leicester and
the northern section of Oxford. The effluent is discharged into an
unnamed tributary to the French River. Since this tributary acts in a
3-10
-------
It
_______
SCALE IN MILES
USGS STREAM GAGES
I
I
I
/
)
/
(
WWTP
I
WORCESTER
TOOL & STAMPING
COMPANY
I
‘I
/
I
OXFORD-
ROCH DALE
WWTP
MASS. TPK.
AUTHORITY
FACILITY
(WESTBOUND)
‘4
HODGES
VILLAGE
DAM
I
/
NORTH
DAM
SOUTH
SANITARY
DASH MFG.
COMPANY
FIG. 3-3 LOCATION OF POINT SOURCE DISChARGES
-------
manner similar to a lagoon, much of the discharge never reaches the
river. The plant’s effluent is well within its NPDES discharge permit
limits of 30 mg/i for both BOD and suspended solids, usually occurring at
approximately 10 mg/i each. Actual flow through the plant is much less
than the design capacity.
Massachusetts Turnpike Authority Westbound Facility . A package
plant secondary facility with a design capacity of 0.072 mgd is operated
by the Massachusetts Turnpike Authority on the westbound side of
Interstate 90 in Charlton. The plant’s effluent is discharged into an
unnamed tributary to Pike’s Pond, which ultimately enters the French
River through the Little River. The plant operates well within its NPDES
discharge permit limits. BOD and suspended solids, which have upper
permit limits of 30 mg/i each, rarely exceed 20 mg/l. Measurements of pH
remain within the allowable range of 6.0 to 8.5, and flow is
significantly below design capacity, ranging from 0.011 to 0.031 mgd from
May 19814 to April 1985.
Dudley Wastewater Treatment Plant . The original Dudley wastewater
treatment plant constructed in 19149 was a primary treatment facility.
The plant discharges its effluent approximately 1 miles downstream of
the USGS stream gage located in Webster. This plant was designed to
remove 50 percent of suspended solids and 30 percent of BOD, and had a
design flow of 0.375 MGD. In 1973, the treatment plant was upgraded to a
secondary plant designed to remove 90 percent of suspended solids and 90
percent of BOD at a design flow of 0.7 MGD. The Dudley NPDES
permit was reissued by EPA and Massachusetts in September, 1986. The
NPDES permit requires seasonal monthly (from April 1 to September 30)
effluent limitations of 10 mg/i for CBOD 5 and 15 mg/i for TSS. The
permit requires NH 3 -N to be as low as 2 mg/i between June 1 and September
30. Dudley must provide additional treatment to meet its limits. The
Dudley wastewater treatment plant has not regularly met secondary
treatment limits during recent years.
In April 19814, a facilities plan for an upgraded treatment plant
was prepared and submitted to the Massachusetts DEQE and U.S. EPA. The
plan recommended advanced wastewater treatment at a regional plant which
would serve the towns of Webster and Dudley, at the existing Webster
3—12
-------
treatment plant site directly across the French River from the Dudley
site. In addition, it was proposed that sludge would be disposed of at a
land disposal site, thus eliminating the discharge of sludge into the
French River from both plants. It was recommended that further studies
be conducted to define specific sludge disposal site alternatives.
Webster Wastewater Treatment. Plant . The original Webster
wastewater treatment plant was constructed in 1950. Its effluent is
discharged directly across the French River from the Dudley wastewater
treatment plant. The plant provided primary treatment and was designed
to remove 50 percent of suspended solids and 30 percent of BOO at a
design flow of 3.0 MGD.
In 197)4, a secondary treatment plant began operating at the
Webster site. It has a design flow of 6.0 HGD. Secondary treatment was
to produce an effluent with BOD and suspended solids at monthly average
concentrations of 30 mg/i each. During the past several years, the
Webster treatment plant has not consistently complied with its secondary
treatment effluent limitations. The Webster permit requires seasonal
monthly (from April 1 to September 30) effluent limitations of 10 mg/l
for CBOD 5 and 15 mg/i for TSS. The permit requires NH 3 —N to be as low as
2 mg/i between June 1 and September 30. Webster must provide additional
treatment to meet its limits.
As mentioned above, a facilities plan for a regional advanced
wastewater treatment plant for the combined flows from Webster and Dudley
has been submitted to EPA. The 6.0 mgd treatment plant is anticipated
to be completed by 1989.
Sanitary Dash Manufacturing Company . Sanitary Dash Manufacturing,
located in North Grosvenordale CT, fabricates and plates tubular brass
plumbing supplies. The plant discharges its effluent into the French
River about one mile upstream of the North Grosvenordale dam. Pollutants
which are associated with these processes include alkaline cleaners,
nickel plating wastes, and chrome plating wastes. A small plant,
Sanitary Dash has a design flow of’ 0.02)4 MGD and an average daily flow of
0.016 MGD. The plant’s effluent is monitored for metals concentrations,
suspended, floating and settleable solids, and pH. No violations of the
NPDES permit limitations have been recorded, with the exception of an
occasionally high measurement of pH or suspended solids.
3—13
-------
Other . In addition to the point source discharges described
above, there are also two non—contact cooling water discharges located in
the French River basin. Asoma Polymers, Inc. discharges into the Little
River, near Buffuinville Lake and Deran Confectionary Co., Inc. discharges
into the French River in Thompson, Conn.
Existing Water Quality Conditions
Water quality data pertaining to the French River have been
collected on several occasions over the past decade. The Massachusetts
Division of Water Pollution Control (MDWPC) performed intensive river
water quality surveys in the river during the sununer months in 1972,
19714, and twice in 1976 (MDWPC, 1973; MDWPC, 19714; MDWPC, 1976). Recent
data collected by the MDWPC has included two 3-day surveys, one in
August, 1982 and another in July, 19814 (MDWPC, 1982; MDWPC, 19814), and
one-day grab sampling surveys in April and June 1985. Most of the MDWPC
data, however, pertain to portions of the river in Massachusetts;
riverine water quality data for Connecticut portions are more limited.
The U.S. Geological Survey (USGS) and the Connecticut Department of
Environmental Protection (CT DEP) cooperatively maintain a monthly water
quality sampling station in the Mechanicsville CT impoundment, 0.7 miles
upstream of the confluence with the Quinebaug River. Additional French
River data are available from the U.S. Army Corps of Engineer water
quality records at their two flood control dams in the upper portion of
the basin.
River flows measured in the French River during the MDWPC surveys
are presented in Table 3 14. Three of the surveys were conducted during
relatively low flow conditions, while the others were conducted at flows
only slightly below and above average for that gaging station. No
surveys were conducted under very low flow conditions (e.g. the 7Q10 low
flow at Webster of 14.8 cfs). The stream flow must be taken into account
when evaluating the data, as the latter can change significantly with the
flow regime in the river.
3—114
-------
TABLE 3 It. FRENCH RIVER FLOWS DURING MDWPC
WATER QUALITY DATA COLLECTION SURVEYS
Survey
Flow at Webster gage (cfs)
July 197)4
27
June 1976
30
August 1976
80
August 1982
July 198)4
April 1985
35
18 ) 4(a)
37 (a)
June 1985
)46
a.
Flow data at the Webster gage were not available for this period.
The flow presented here was measured at the Hodges Village Dam gage
which is 6 miles upstream of the Webster gage and above where the
Little River enters the French River.
Temperature and pH . The 197)4 MDWPC survey of the French River
showed several violations of the Class B water temperature standard
(K 83°F for warm water fisheries), however, the more recent surveys
conducted by the agency (1976, 1982, 198)4, 1985) have shown compliance
with this standard throughout the river. River water temperature
measured in July, 19814 ranged from 67 to 75°F. The April 1985
temperature measurements also show no violations, largely due to the
colder season of the year during which measurements were made.
The Class B standard for pH is a range of 6.5 to 8.0. As shown in
Figure 3-14, the 1982 I4DWPC French River survey data showed compliande
with this standard. However, the observed pH at most stations surveyed
in the 198)4 MDWPC program was 6.2 to 6.14. Assuming that the high flows
during the latter survey resulted from a rainfall event, it is possible
that the lower p 1- I levels were due to acidic deposition. These low values
might also have been caused by excessive organic leachate from the
wetlands, which are naturally acidic. The April 1985 data indicate no
violations of the standards.
Dissolved Oxygen and Biochemical Oxygen Demand . Dissolved oxygen
(DO), or the amount of uncombined oxygen held in solution and thereby
3-15
-------
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E
0
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E
E
>
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0
0 ,
0
cE
0
0)
0
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0,
r
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I 0
0
0)
0
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-------
made available to aquatic organisms for respiration, is a critical
parameter directly affecting the health of the biological community.
Dissolved oxygen affects the release of nutrients, microbial respiration,
and organic matter decomposition, and is frequently the determining
factor affecting species survival and competition. The amount of oxygen
required to decompose the organic material in the water is reflected in
the biochemical oxygen demand (BOD). BOD 5 concentrations in untreated
sewage typically range from 150 to 300 milligrams per liter (mg/i), while
the BOD 5 of an unpolluted water rarely exceeds 2 mg/i (MDWPC, 1982).
As shown in Figure 3—5, the 197 4 MDWPC survey BOD 5 concentrations
in the French River ranged between 60 and 80 mg/l. In the MDWPC study
two years later, the water quality surveys reflected a BOD 5 range of 2 to
7 mg/l. The primary reason for this dramatic decrease in BOD 5 was the
conversion of the Webster and Dudley wastewater treatment plants to
secondary treatment and the removal of several industrial discharges from
the river by connecting them to the treatment plants. As shown in
Figure 3-6, the 1982 MDWPC water quality survey reflected BOD 5 levels of
2 to 7 mg/i as weil, and the 198 )4 and 1985 MDWPC surveys showed BOO 5 no
greater than 3 mg/i. The highest BOD 5 levels occurred downstream of the
Leicester wastewater treatment plant and the Webster and Dudley treatment
plants. Thus, in terms of biochemical oxygen demand, a major improvement
in water quality was achieved between 19714 and 1976 and again between
1982 and 19814.
Dissolved oxygen concentrations in the French River also improved
dramatically between 19714 and 1976, and have exhibited less change
since. As seen in Figure 3-7, average DO concentrations measured by the
KDWPC in June 19714 were as low as 1.0 mg/i. Overall averages in 1976
were higher. Figures 3-8 and 3-9 show the range of DO’s measured during
the 1982, and the 19814 and 1985 MDWPC surveys, respectively. In 1982,
the lowest average DO measured (for each station) was 5.3 mg/I, and in
198 4 it was 5.9 mg/i. The lowest DO level measured in 1982 was 3.2 mg/i,
which occurred above the darn in North Grosvenordale Pond, In 19814, the
minimum DO measured was 14.9 mg/i at Webster. The April 1985 data all
reveal high DO levels, due largely to the colder water temperatures.
3—17
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FIG. 3-5 AVERAGE BOD 5 CONCENTRATIONS iN THE FRENCH RIVER
1974 & 1976 MDWPC SIRVEYS
0
0
E
0
0
I
I
£
E
0
0
C
9
0
£
z
E
0
0
I-
E E
‘V ‘V
0 0
C
‘V
C
-------
1
MILES UPSTREAM OF CONFLUENCE WITH OUINEBAUG RIVER
FIG. 3.6 AVERAGE BOD 5 CONCENTRATIONS IN THE FRENCH RIVER
1982, 1984 AND 1985 MDWPC SURVEYS
C,
E
Lt)
0
0
-------
cnIz
<0
MILES UPSTREAM OF CONFLUENCE WITH QUINEBAUG RIVER
FIG. 3-7 DISSOLVED OXYGEN CONCENTRATIONS IN THE FRENCH RIVER
1974 & 1976 \IDWPC SURVEYS
z
w
x
0
0
w
>
24
20
/16 I
12
E
0
S
>
I
EE2
I
-------
However, in June 1985, concentrations as low as 2.0 mg/i were measured in
the Perryville impoundment.
Diel variations in DO were very strong in the 1982 MDWPC survey
and iess pronounced in the 198k survey, most likely due to the higher
streainfiow. The diel variations in the 1982 survey reflected super-
saturated DO levels in the upper reaches of’ the river above Greenville
Pond and again downstream of the Webster and Dudley treatment plant
discharges. The super-saturated DO’s indicate that photosynthetic
activity was significantly contributing to DO concentration in certain
reaches of the river. The lower DO measurements were probably due in
part to plant respiration at night, and in part to sediment oxygen demand
in the impoundments. The USGS water quality records for Mechanicsville
CT, indicate consistently high DO concentrations at that station, even
though the sampling station is in an impoundment. These measurements,
however, are all made during the day and would not reflect the effects of
plant respiration.
Many aquatic organisms can withstand DO concentrations as low as
3 mg/l for at least short periods of time. (U.S. EPA, EPA
)4140/5_86 ..0O1.) However, water quality standards are set much higher
(5.0 mg/i for Class B) to account for: organisms’ long-term exposure to
depressed oxygen levels; critically sensitive periods in organisms’ life
stages, such as egg development; vertical variation in the water column;
and a margin of safety to protect against any unexpected short-term
reduction of DO. As is evidenced by the data presented above, dissolved
oxygen concentrations in the downstream sections of the French River
sometimes violate the Class B standards for warmwater fisheries, even
during average flows. It is likely that during periods of extreme low
flow (e.g. at the 1Q10 of 1 4.8 cfs), or during nocturnal plant
respiration, DO concentrations in the river drop to significantly lower
levels. According to EPA dissolved oxygen criteria for freshwater life
(Table 3-5), the DO levels in the French River can cause moderate to
severe production impairment to the non—salmonid (warmwater) fishery in
the river. Although no sampling has been conducted during extreme low
flows (e.g., 7Q1O), it may be deduced that DO concentrations in the
impoundments occasionally sink low enough (e.g., below EPA’s “absolute
3—23
-------
TABLE 3-5. DISSOLVED OXYGEN CRITERIA FOR THE
PROTECTION OF FRESHWATER AQUATIC LIFE (mg/i)
Salmonid
Criteria
Non—Salmonid
Criteria
Embryo
Embryo
and
Other
and
Other
Larval
Life
Larval
Life
Criterion Effect Stages
Stages
Stages
Stages
No Product io
Impairment’ 11 8 6.5 6
Slight Produ 9 t 4 on
impairment b1 9 6 5.5 5
Moderate Pro uçtion
Impairment °‘ 8 5 5 4
Severe Produç on
Impairment’ ‘ 7 14 14.5 3.5
Absolute Minimum 6 3 14 3
a. No Production Impairment . Representing nearly maximum protection of
fishery resources.
b. Slight Production impairment . Representing a high level of
protection of important fishery resources, risking only slight
impairment of production in most cases.
c. Moderate Production Impairment . Protecting the persistence of
existing fish populations but causing considerable loss of
production.
d. Severe Production Impairment . For low level protection of fisheries
of’ some value but whose protection in comparison with other water
uses cannot be a major objective of pollution control.
SOURCE: U.S. EPA, Quality Criteria for Water 1986, EPA 4’40I5-86-OOi,
May 1, 1986.
3 2L4
-------
minimum” criterion of 3 mg/i DO) to cause fish kills and mortality in all
but the most pollution-tolerant organisms.
Nutrients . As discussed previously, there is evidence that a
significant amount of photosynthetic activity is occurring in the French
River, which is probably attributable to the presence of excess
nutrients. Extensive macrophyte growth occurs in several of the
impoundments, and some algal activity is also expected.
Typically in freshwater systems, phosphorus is the nutrient in
shortest supply, and thus, is the factor limiting plant growth. In most
lakes, total phosphorus concentrations of 0.01 to 0.02 mg/l are
sufficient to support normal plant growth, while concentrations above
0.10 mg/I are considered characteristic of lakes exhibiting excessive
plant growth (Wetzel, 1975) and thus are termed eutrophic.
The 197k and 1976 MDWPC survey data for total phosphorus
concentrations (Figure 3-10) show that since 19714, total phosphorus
concentrations have decreased significantly in most segments of the
river. However, wastewater treatment plant effluents still impact the
instream phosphorus concentrations in some reaches. Figure 3 —il shows
total phosphorus data for the 1982, 1984 and April 1985 MDWPC surveys.
In the 1982 survey, the phosphorus concentration rose to 0.5 mg/i in the
ponds downstream of the Leicester, Webster and Dudley wastewater
treatment plant discharges. These reaches also had the highest diel DO
variation during this survey, which again suggests significant instream
photosynthetic activity. Phosphorus concentrations measured in the 1984
survey were less than 0.2 mg/i, probably due to the higher river flows
during this sampling program. The 1985 data are very similar to the 1982
data. Since measured levels have consistently exceeded 0.1 mg/l in the
French River, it is likely that phosphorus levels in the water are at
least in part responsible for excessive plant growth and occasional algal
blooms in the river.
Nitrogen, in the form of’ nitrate, is also an essential nutrient to
aquatic plants. Nitrate—N concentrations in the French River decreased
from a maximum of 1.8 mg/i in 19714 to 1.0 mg/l in 1976, once secondary
3-25
-------
cn,z
<0
‘0
MILES UPSTREAM OF CONFLUENCE WITH QUINEBAUG RIVER
FIG. 3-10 AVERAGE TOTAL PHOSPHOROUS CONCE TRATIO S I THE FRENCH RIVER
1974 & 1976 1DWPC SURVEYS
1.00
.80
.60
‘I )
0
I
0
I
. 40
-a
4
I-
0
I-.
.20
E -;
S
> - E
.
E E
— S S
0 0
2 2
9
S -
E
•
o 2
S
r I
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MILES UPSTREAM OF CONFLUENCE WITH QUINEBAUG RIVER
0
FIG. 3.11 AVERAGE TOTAL PHOSPHOROUS CONCENTRATIONS IN THE FRENCH RIVER
1982, 1984 A D 1985 MDWPC SURVEYS
a,
E
U)
0
I
0 .
U,
0
I
0.
-J
I-.
0
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2:
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treatment was implemented at the Webster and Dudley treatment plants and
some industrial discharges were diverted to nearby treatment plants.
Figure 3—12 presents the average nitrate-N concentrations in the river
for the 1982, 19814, and April 1985 MDWPC surveys. In these more recent
studies, nitrate-N levels averaged less than 0.5 mg/i in the river
upstream of the Webster and Dudley plant effluent discharges. Below
these discharges, however, average low flow concentrations are closer to
1.5 mg/i nitrate—N.
Nitrogen in the form of anunonia exerts a high oxygen demand on the
environment due to processes of nitrification, and above certain levels
can be toxic to aquatic organisms. As with other parameters, ammonia-N
concentrations in the French River decreased significantly between 1974
and 1976 and have decreased further since, with occasional exceptions.
During the 19714 MDWPC survey, ammonia-N concentrations were as high as
3.0 mg/i and dropped to a minimum of 0.8 mg/i in the 1976 MDWPC
surveys. Figure 3—13 presents average ammonia-N concentrations measured
during the 1982, 19814 and April 1985 MDWPC surveys. In the 1982 survey,
concentrations varied from 0.01 to 0.141 mg/i and in 1984 the highest
measured concentration was 0.15 mg/i. Concentrations in the April 1985
survey were considerably higher downstream of the treatment plants,
probably because they were not yet following their summer treatment
regime. Based on the EPA Ammonia Criteria for the Protection of Aquatic
Life (Table 3-6), measured concentrations of ammonia in the French River
During the 1982 survey, the most significant diel DO variations
observed, in the impoundments downstream of the Webster and Dudley plant
discharges, coincided with the highest observed ammonia levels of 0.3 to
0.14 mg/i. These data further indicate that a significant amount of
photosynthetic activity is occurring in these ponds.
Bacteria . Bacterial levels in receiving waters are frequently
quantified in terms of coliform bacteria. While they are not a health
hazard themselves, fecal coliform bacteria are a good indicator of the
presence of other sewage—associated organisms. As shown in Figure 3-14,
fecal coliform concentrations in the 1982 MDWPC water quality survey of
the French River generally met the State standard of a log mean of
3-28
-------
L
E
Ca
C,
0
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- (5
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(5
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(5
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0
0
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0
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0
-c
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1.5O
1 .25—
:
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O.75-
0.50t-
0.
1982SURVEY
1984 SURVEY
— -— 1985 SURVEY
‘I
I
I
15
4.’
I’
Ii
I’
I
I’
‘! •‘
I --
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I_ ..(a =
. , ;
-1
0
> E
.
E
(0
0
a,
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a,
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0
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(a
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-------
TABLE 3-6. AMMONIA CRITERTh , FOR PROTECTION
OF AQUATIC LIFE a)
One-Hour Average
Four
Day Average
Allowed Concentrations
Allowed Concentrations
(mg/i Total NH 3 -N)
Temp (°C)
(mg/l
Total NH 3 -N)
Temp (°C)
15
20 25
pH
15 20 25
6.50
30 29 29
2.2
2.1 i. 46
6.75
27 27 26
2.2
2.1 1.117
7.00
211 23 23
2.2
2.1 1.147
7.25
19.7 19.2 19.0
2.2
2.1 1.148
7.50
114.9 111.6 114.5
2.2
2.1 1. 49
a. The criteria values presented here represent conditions typical of
critical summer conditions. A more complete list of criteria is available
in the criteria document.
Source: U.S. EPA, Federal Register: Water Quality Criteria for the Protection
of Aquatic Life and its uses - Ammonia, Vol. 50, No. 1145, July 29,
1985.
200/100 ml, with the exception of reaches downstream of the Leicester
(220/100 ml) and Webster and Dudley (1,000/100 ml) wastewater treatment plant
discharges. The highest fecal coliform count observed in the 198 4 MDWPC
survey was 2110/100 ml at Webster. Again, compliance with the standards in
these reaches is typical during average or higher river flows, as was the case
during these surveys, or during colder weather as occurred during the April
1985 survey. It is anticipated that the upgraded wastewater treatment being
planned for these reaches will eliminate violations altogether. Fecal
coliform concentrations measured at Mechanicsville revealed high (> 200/100
ml) levels for ten months of water year 1982, although previous data do not
reflect such problems. It is possible that there is a local sewage source to
this reach of the river.
Priority Pollutants . Metals and certain other priority pollutants have
been detected in the French River, both in the water column and in the bottom
sediments. Metals concentrations in the water were measured at three
locations along the river during the MDWPC 19814 summer survey; Figure 3-14 at
the headwaters in Leicester, in downtown Webster, and in the
impoundment in Perryville. These stations, in addition to those in
3—31
-------
z
E
to
V 3
a,
to
V
0
C
0
E .
to to
0
a, 0
= C
a,
9 2
0
z
E
Co
0
a,
>
U
C
to
-c
U
a,
-------
Wilsonville, North Grosvenordale, and Thompson, CT were sampled by MDWPC
again in April 1985. The monthly water samples collected by USGS in the
Mechanicsville impoundment are also analyzed for certain metals. The
most recent published records for this station are for water year 1982.
Metals data from all three sources are summarized in Table 3—7.
No measurable concentrations of copper, mercury, nickel, lead,
chromium, or cadmium were detected in the upstream reaches of the
river. However, the detection limits were in some cases higher than the
levels of chronic toxicity (Table 3-8) for these metals. There are no
published criteria documents for the metals that were detected in these
reaches, (including zinc, iron and manganese,) but EPA “Red Book” (1976)
values indicate that the zinc concentrations measured are sufficient to
cause chronic toxicity in brook trout.
Water column samples for metals analysis collected by the USGS in
Mechanicsville were analyzed using lower detection limits. The results
indicate that levels of copper, lead, and cadmium in the river do exceed
levels of chronic toxicity and may occasionally even be acutely toxic to
freshwater life.
Water Quality at Buffumville Lake . The results of a 1983 water
quality program by the U.S. Army Corps of Engineers indicate the waters
of Buffumville Lake were of good quality in 1983 and met the requirements
of Class B standards. The water quality standards for a Class B warm
water fishery were fully met at all sampling stations for dissolved
oxygen, temperature and fecal coliform bacteria. The pH levels ranged
from 6.1 to 8.2 which is slightly outside the desirable range of 6.5 to
8.0 for a Class B water; however, because pH values were due to naturally
occurring conditions in the watershed they did not constitute violations
of Class B standards. (U.S. Army Corps of Engineers, 19814).
3—33
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TAHLE 3-7. NETALS CONCENTRATIONS IN THE WATENS or THE FRENCH RIVEN (ug/1)
Leices
1984
ter(a)
1985
Webste
1984
r(a)
1985
Perryv
1984
ille(a)
1985
Wilsonville(b)
1985
N. Grosvenordale(b)
1985
Mechani
1982
csville(b)
1982
Thompson (b)
1985
Copper <10 <10 <10 <10 <10 <10 <10 <10 2 13 <10
Zinc 10 <10 60 <10 20 10 30 40 <10 20 <10
Iron 170 60 550 140 640 250 290 440 110 370 410
Manganese 10 — 70 — 70 — 18 36
Nickel <30 <30 <30 <30 <30 <30 <30 <30 <1 7 <30
Mercury <0.5 — <0.5 — <0.5
Lead <40 <40 <40 <40 <40 <40 <40 <40 <1 6 <40
Chromium <20 <20 <20 <20 <20 <20 <20 <20 <1 8 <20
Aluminum <100 120 <100 <100 130 (100 (100 <100 <100
Cadmium <20 <20 <20 <20 <20 <20 <20 <1 1 <20
Source: (a) MASS DWPC, 1984, 1985
(b) CONN DEP, 1982, 1985
-------
TABLE 3-8. Us EPA AMBIENT WATER QUALITY
CRITERIA FOR METALS (ugh)
Continuous Concentration Maximum Concentration
Metal ()1 Day Average/3 Years (1 Hour Average/3 Years)
As 190 360
Cd(a) e (0 7 8 52 in h - 3.149) e 12 8 in h - 3.828)
Cr 11 (hexavalent) 16 (hexavaient)
cuth) e(0 8 5 14 5 in h - 1.1465) e ( 9 14 22 in h - 1.14614)
Pb e 2 66 in h - 14.661) (1.266 in h - 1.1416)
Hg 0.012 e 2)4
Source: U.S. EPA Ambient Water Quality Criteria Documents for Arsenic;
Cadmium; Chromium; Copper; Lead and Mercury, Final. Federal
Register Vol. 50, No. 1145, July 29, 1985.
a. Based on hardness vaiues measured in the French River 1985 DWPC
survey (average 21 mg/i), corresponds to 0.33 ug/i Cd, for continuous
exposure and 0.67 ugh Cd for maximum exposure.
b. For French River, corresponds to 3.1 ugh Cu for continuous exposure
and 4.1 ugh Cu for maximum exposure.
c. For French River corresponds to 0.145 ugh Pb for continuous exposure,
and 11.5 ugh Pb for maximum exposure.
Nutrient levels at Buffumvilie Lake in 1983 showed a decline in
inorganic nitrogen and phosphorus levels. Total inorganic nitrogen
(NH 3 —N plus N0 2 —N plus N0 3 -N) was always less than 0.30 mg/i which is the
generally accepted threshold limit for algae blooms to occur. The
highest inorganic nitrogen level was in the South Fork which had a mean
concentration of 0.12 mg/i N. Biological uptake by plants in the lake
reduced the mean total inorganic nitrogen level at the discharge station
to 0.07 mg/i as N (U.S. Army Corps of Engineers, 19814).
Total phosphorus levels averaged 0.0214 mg/i at the inflow stations
in 1983. Uptake by aquatic plants reduced the effluent phosphorus levels
to an average of 0.0114 mg/i. The highest phosphorus level measured was
0.06 mg/i. The threshold level for algae blooms to occur in an
impoundment (as cited in U.S. Army Corps of Engineers, 19814) is 0.01 to
0.015 mg/i. Although the mean phosphorus level at the inflow station was
above this, the median phosphorus measurement was about 0.01 mg/i.
3—35
-------
Sediment Quality
Due to historical discharges, impoundment of the river in several
locations, and naturally occurring low flows, significant deposition of
contaminated sediments has taken place upstream of the numerous dams in
the river. Some of the most significant deposition has occurred in the
impoundments at Perryville MA and Wilsonville, North Grosvenordale,
Grosvenordale, and Mechanicsville CT, all of which are downstream of the
Webster and Dudley discharges.
Several studies of the sediment deposits in the lower French River
basin have been conducted in the past decade. In 1972, the U.S. Army
Corps of Engineers (U.S. ACE) investigated the physical distribution of
sediments in Wilsonville (Langer’s Pond) and North Grosvenordale CT, and
in 1977, they examined sediment metals concentrations (U.S. ACE, 1972 and
1977). In 1975, 1978, and 1985, EPA conducted sediment oxygen demand
(SOD) studies in the impoundments (EPA, 1975; EPA, 1978; EPA, 1985). The
1978 EPA study also included analysis of metals concentrations. In
August 19811, CT DEP conducted EP (extraction procedure) toxicity analysis
for metals in surface samples from Langer’s Pond and North Grosvenordale
Pond, in conjunction with biological sampling there (CT DEP. 19824). In
November of 19811, Metcalf & Eddy, under contract to EPA, collected
additional data on the location, depth, and physical and chemical quality
of sediments in Perryville, Langer’s Pond, and North Grosvenordale (M&E,
19811).
Physical Distribution of the Sediments . Figures 3-15 through 3-17
show the extent of sediment deposition in the three impoundments just
downstream of the Webster and Dudley treatment plant discharges. The
average depth of sediment deposition in the three ponds ranges f Q 3 to
feet. According to the 19811 M&E study, the material is mostly dark
brown to black organic silt and humus, approximately 50 percent water,
and contains approximately 50 percent silt and clay in the solid
fraction. The total volume of sediments in the three impoundment areas
is estimated to be approximately 357,000 cubic yards with 63,000 cubic
yards in Perryville, 511,000 cubic yards in Wilsonville, and 2140,000 cubic
yards in North Grosvenordale.
3—36
-------
SEDIMENT
DEPTH
0-1.9’
2’- 39’
LI 4 59
6’ - 7.9’
8’ - 9.9’
200 0 200
1
SCALE IN FEET
1 ’ i I
FIG. 3-15 SEDIMENT DISTRIBUTION IN PERRYVILLE POND
-------
KALE . FEET
FK. S- I SFAJI\1 E\T DISTRIBUTION
I’ L\\GER’’ POND (WILSONSILLE, CT.)
SEDIMENT
DEPTH
El]
El 7
U
4. 5.9 ’
6’ - 7.9’
U ‘
-------
SEDIMENT
DEPTH
LI 0-1.9’
f J 7-3.9’
4’ - 5.9’
6’-7.9’
8 -9.9’
250 0
—
250
SCALE IN FEET
FIG. 3-iT SEDIMENT DISTRIBUTION IN NORTH GROSVENORDALE POND
-------
Priority Pollutants . Tables 3—9 through 3-12 present the
concentrations of priority pollutants measured in the sediments during
the 1978 EPA and 198)4 M&E studies of the downstream impoundments. Some
of the most significant contaminants in the sediments are the metals,
specifically arsenic, chromium, mercury, copper, lead and zinc, and
polycyclic aromatic hydrocarbons (PAH’s). Generally, the highest
concentrations of metals occur in North Grosvenordale, where in some
cases, concentrations are one order of magnitude greater than in other
impoundments. The impoundment in Perryville also has consistently high
metals concentrations in the sediments, both in the vegetated areas and
in the open water areas. Metals concentrations in Langer’s Pond and
Grosvenordale Pond are lower than the other two impoundments, but are
still contaminated, particularly with arsenic, chromium, lead and
mercury. Extraction procedure (EP) metals toxicity tests conducted by
CT DEE’ (198k) on surface sediments from Langer’s Pond and North
Grosvenordale (using procedures described in U.S. EPA, 1982, Table 3-13)
indicate that these samples “pass” the EP Toxicity test and thus the
metals would not leach out of the sediments at reduced pH. Under normal
pH conditions the sediments are not presently a major contributor of
metals to the water column. Disturbance of the sediments, or a more
significant chemical change in the overlying water such as very low
dissolved oxygen or anoxic conditions, would be necessary to alter this
situation.
Although no EP toxicity data is available for the Perryville
sediments, indications are that these sediments will also pass the EP
toxicity standard. The bulk sediment test results for Perryville (Table
3—9) are similar in magnitude to that measured at Langer’s Pond (Table
3—10), and are generally lower in magnitude than that measured at North
Grosvenordale (Table 3-11). Since the sediments of Langer’s and North
Grosvenordale Ponds both pass the EP toxicity standard, it is expected
that the Perryville sediments will also pass this standard. Comparison
of bulk sediment and EP toxicity analyses for sediments from the Assabet
River in Acton, Massachusetts also supports the contention that the
Perryville sediments are not likely to be EP toxic. A comparison of
3-k0
-------
TABLE 3-9. SEDIMENT QUALITY IN PERRYVILLE POND
Vege-
South
North
tated
Open
end
Middle
end
area
water
Source
EPA,
EPA,
EPA,
EPA,
EPA,
Parameter of Data:
1978
1978
1978
19814
19814
Inorganics (ppm dry wt)
Arsenic 1 14 11 11 25 23
Beryllium (a) ND ’ ND
Cadmium 24 12 12 1.7 3.6
Chromium 600 141 10 6 140 220 630
Copper 1470 220 500 83 350
Mercury 1.14 2.9
Nickel 108 160 108 8.9 11
Lead 1400 130 350 81 220
Zinc 6140 270 500 180 ‘4110
Total Cyanide 3.9 6.7
Pesticides ND ND
Acid Compounds ND ND
Base/Neutral Compounds (ppb)
Acenaphthene 2,300 TR
Fluoranthene 14,700 15,000
Napthalene 1,000 TR
Benzo (a) anthracene 2,300 12,000
Benzo (a) pyrene 1,200 9,000
Benzofluoranthene 1, 1400 10,000
Chrysene 2,000 10,000
Anthracene 3,1400 11,000
Benzo (ghi) perylene 530 TR
Phenanthrene 8,000 22,000
Pyrene 8,100 23,000
Volatile Organics (ppb)
Acetone 160 ND
Toluene 10 130
Chlorobenzene ND 49
Ethylbenzene ND 12
Total xylene 10 15
a. Blank not analyzed for
b. ND not detected
c. TR present only at trace levels
3-141
-------
TABLE 3—10. SEDIMENT QUALITY IN LANGER’S POND
East
North
South
East
West
side
end
end
side
side
Source
EPA,
EPA,
EPA,
EPA,
EPA,
Parameter of Data:
1978
1978
1978
198 l
19811
Inorganics (ppm dry wt)
Arsenic 211 27 24 21
Beryllium (a) 0.58 0.57
Cadmium 12 12 12 1.1 1.2
Chromium 280 220 1,160 230 330
Copper 160 650 950 73 110
Mercury 0.82 0.97
Nickel 72 60 80 9.1 7.7
Lead 100 550 550 120 93
Zinc 250 1,050 1,020 3 24 Q 160
Total Phenolics ND ’ 0.28
Pesticides ND ND
Acid Compounds ND ND
Base/Neutral Compounds (ppb)
Acenaphthene ND TR
Fluoranthene TR 700
Napthalene ND TR
Benzo (a) anthracene TR 540
Benzo (a) pyrene TR 390
Benzofluoranthene TR 500
Chrysene TR 580
Anthracene TR 4110
Benzo (ghi) perylene TR TR
Phenanthrene TR 730
Pyrene TR 1,200
Volatile Organies (ppb)
Acetone 180 ND
a. Blank not analyzed for
b. ND = not detected
c. TR = present only at trace levels
3-42
-------
TABLE 3-11. SEDIMENT QUALITY IN NORTH GROSVENORDALE POND
North
South
end
Middle
end
Composite
Source
EPA,
EPA,
EPA,
M&E,
Parameter of Data:
1978
1978
1978
198 )4
Inorganics (ppm dry wt)
Arsenic 7 30 10 145
Cadmium 12 12 12 7.7
Chromium 2,560 1,6)40 1,520 1,900
Copper 1,980 1,260 610 600
Mercury (b) 14.9
Nickel 214 140 70 21
Lead 630 500 14140 1470
Zinc 1,680 1,680 1,190 1,000
Total Cyanide 3.9
Pesticides ND ND
Acid Compounds ND ND
Base/Neutral Compounds (ppb)
P cenaphthene TR c)
Fluoranthene 890
Napthalene TR
Benzo (a) anthracerie 500
Benzo (a) pyrene TR
Benzofluoranthene 530
Chrysene 510
Anthracene 650
Benzo (ghi) perylene TR
Phenanthrene 1,300
Pyrene 1,500
Volatile Organics (ppb)
Toluene 10
Chlorobenzene 26
a. All sediments were analyzed according to EPA methods in SW . 8146
b. Blank not analyzed for
c. TR present only at trace levels
3_143
-------
TABLE 3-12. SEDIMENT QUALITY IN GROSVENORDALE POND
Parameter
South End North End
EPA, 1978 EPA, 1978
Inorganics
(ppm dry wt)
Arsenic
10 20
Cadmium
12 12
Chromium
360 1,14140
Copper
190 810
Nickel
108 550
Lead
80 200
Zinc
180 560
Metal
TABLE 3—13.
CONNECTICUT
Langers Langers
Pond Pond
West West
METALS EP TOXICITY IN SEDIME,NT S
IMPOUNDMENTS (mg/i leachate) a,
Location
Max irnum
Concen-
N. Grosvenor- N. Grosvenor- r tion
dale South dale North
Arsenic
0.01 0.00
0.06 0.00 5.0
Cadmium
0.00 0.00
0.00 0.00 1.0
Chromium
0.02 0.00
0.00 0.01 5.0
Copper
0.05 0.014
-- -- --
Lead
0.17 0.19
0.16 0.09 5.0
Mercury
0.00 0.00
0.00 0.00 0.2
Nickel
0.05 0.014
-- -- --
Silver
0.00 0.00
0.00 0.01 5.0
Zinc
2.3 1.8
-- -- --
Source: CT
DEP, 19814
a. Analyzed according to EPA methods in SW_8146
b. Maximum concentration of’ contaminants for characteristic EP
Toxicity, 140 CFR 267.214
sampling results for selected metals i presented below (J. Perry, MDWPC,
personal communication, November, 1986):
Assabet River Sediments
Bulk Sediment EP Toxicity
Analysis (dry wt. ppm) Analysis (ppm)
Chromium 3200 0.22
Lead 1450 0.05
Copper 820 0.58
Copper 11900 11.00
3 .. .14 1 1
-------
These measurements indicate that the metals in the sediments are
not readily leachable, and that the bulk sediment metals concentrations
can be expected to be several orders of magnitude higher than the EP
toxicity metals concentrations.
No pesticides, PCBs, or acid-extractable compounds from EPA’s
Priority Pollutant list were found at other than trace concentrations in
the 19814 M&E sediment samples. Elevated levels of certain volatile
organics were detected, but there are no standards for sediment with
which these concentrations can be compared. These compounds generally
degrade or are dissipated readily in the aquatic environment, thus the
original concentrations of the volatiles may have been much higher.
Several PPtH (polycyclic aromatic hydrocarbon) compounds (priority
pollutant base/neutral organics) were present in elevated concentrations
in the sediments in the 198 4 M&E study, particularly in the samples from
the Perryville impoundment. Lower concentrations were found in the
western portion of Langer’s Pond and in North Grosvenordale, while the
eastern side of Langer’s Pond revealed no measurable concentrations.
According to the literature, sources of’ PP H compounds in water sediments
include oil spills, coke-oven effluents, road runoff and, air transport
from combustion engines (Black et al., 1981; Biorseth, 1980) and any
other combustion sources including wood stoves. Thus, the historic
operation of a coal gasification plant in Webster may be the cause of the
high PAH concentrations in Perryville. Black (1983) determined
correlations in the Buffalo River between sediment polycyclic
hydrocarbons, neoplasms in feral fish and induction of neoplasms in
bullheads, from exposure to extracts of sediment polluted with 76. ug/g
wet weight PAH. Concentrations of PM -I’s in the French River impoundments
are within the range that correspond with fish neoplasms in Black’s 1983
study. (For more information concerning the sediments and benthic
communities, refer to page 3-73 which notes the predominance of
turbificid worms in Perryville.)
Sediment Oxygen Demand . Sediment deoxygenation rate surveys have
been conducted previously in the French River by the EPA during 1975,
1978 and 1985. An in situ technique developed by the U.S. EPA Region I,
3-145
-------
Surveillance & Analysis Division, was used exclusively in these
surveys. The results of these surveys are presented in Table 3-1k for
various locations along the French River in Massachusetts and
Connecticut.
The SOD rates have increased by factors ranging from 2 to 7 in
Perryville Pond during the period between 1975 and 1985. The rates
estimated using samples from the downstream (southern) part of Langer’s
Pond were more than three times higher in 1985 than in 1978. The rates
in North Grosvenordale Pond also have increased slightly, although rates
estimated for the southern end of this impoundment appear to have reached
a maximum during the 1978 survey.
Stressed SOD analyses (those taken under very low dissolved oxygen
concentrations) were also conducted during the 1985 survey. Research has
shown a direct dependence of SOD on the dissolved oxygen concentration in
the water column overlying the sediments. Lower water column dissolved
oxygen concentrations suppress both the biological and chemical SOD
pathways due to physical, as well as biochemical effects. For a
comprehensive review of key works in the SOD literature, the reader is
referred to Bowman and Delfino (1980), Belanger (1979) and Walker and
Snodgrass (1983).
Results for both the stressed and non-stressed SOD analysis
conducted on sediment cores taken from Perryville Pond in 1985 are
plotted in Figure 3—18. The suppression indicated in the literature for
SOD rates at lower water dissolved oxygen levels was verified. The
implication of this SOD suppression in the French River sediments is that
the extremely high SOD rates measured in 1985 under non-stressed
conditions would likely be suppressed to much lower rates under actual
summertime low flow conditions, when ambient overlying water dissolved
oxygen levels would be relatively low.
The water quality model used in this study for assessing the in-
stream dissolved oxygen impacts of the various alternatives was tested
for its sensitivity to the range of SOD rates measured during the 1975,
1978 and 1985 EPA surveys. The results of this sensitivity analysis are
discussed in the water quality modeling section of this chapter.
3-’ 6
-------
TAIII,E 3-1 I. 501) HArEs ’ I H0H VAIIIOUS EPA SIJIIVEYS (W III E FIfl .tdCII HIVER
Mi yJ9l3S tir ; uc1 I)OTrst ,
) ) ) ) ) i i tWr i l iiiii,ii IX) 1 ’ 1 less
t rj975 Septenil,er 1971)
lerattoti SOD (gm/rn 2 /ci) Std. error SO)) (gm/m 2 /d) Std. error SOI l (gm/m 2 / t) Std. error SO)) (gin/m /d) Std. crier SO)) (gm/oi 2 /d) Std
end’
‘lexis loud
Oxford 0.87 ±0.07
Upstream of
Ilarwood St.
llnidge, Oxford 0.76 ±0.09
Downstream of
USGS Gage,
Webster 1.28 ±0.21
leu’ryv ii I c (‘end
North End 2.15 ±0.66 8.92 ±1.86 1.3)) ±0.13
Middle 3.87 ±1.55 10.23 ±1.06 3.30 ±0.53 1.06
South End 0.92 ±0.01 1.149 ±0.30 10.78 ±2.26 - - 1.82
Lingers Pond
(Wilsonville)
East Arts 2.141 ±0.72
North End 2.83 ±0.7)4
South End 1.35 ±0.37 ±1.36
N. Grosvenordale Pond
Worth End 3.29 ±0.52 3.80 ±0.39
Middle 3.014 ±1.83 3.23 ±1.12
South End 1.91 ±0.28 3,14 14 ±0.07 1.9)4 ±0.11
Crosvenordale Pond
lOm upstream of
Blain Rd. 3.35 ±1.50
300m upstream of
131am Rd. 2.77 ±0.149
a. In-situ results at river temperature were corrected to values at 20°C, using the Arhaenius Eqn. with the thermal coefficient of 1.0147 proposed by Phelps
(19)4)4).
b, Dissolved oxygen level in overlying water at start of in-situ incubation for stressed DO tests.
-------
LOCATION WITHIN
PERRYVILLE POND
lOS SOUTH END
2O 11SMIDDLE
12S NORTH END
+1 STD. DEV.
MEAN
-1 STO. DEV.
:1
‘I
5
INITIAL DO IN OVERLYING WATER (mg/I)
FIG. 3-18 SENSITIVITY OF SOD TO DO iN OVERLYING WATER AT
START OF IN SITU ANALYSIS, SEDIMENT CORES FROM
PERRY VILLE POND, MAY 1985
>.
E
E
LU
I .-
0
U)
10
6
-------
Water Quality Model
Numerical modeling of water quality in the French River from
Sargent Pond to the confluence of the Quinebaug River was conducted as a
part of preparation of this IS using the steady-state, one-dimensional
stream water quality model, STREAM7B. The model was calibrated to
wastewater discharge and instreain water quality data obtained by the
Massachusetts DWPC and used to approximate existing and predict future
concentrations of dissolved oxygen under 7Q1O low flow conditions in the
French River.
Earlier modeling of water quality in the French River was
conducted by the Massachusetts DWPC using the STREAM7A model calibrated
to instream water quality and wastewater discharge data for June, 1976.
STREAM7A has since been modified to create the STREAM7B version used in
this study. Also, many wastewater discharges to the French River have
either been altered significantly or eliminated since 1976, as reflected
in the higher dissolved oxygen concentrations measured during more recent
summer surveys. The August 1982 water quality data, collected by the
Mass DWPC, were used to calibrate the model in this study.
In addition, previous model applications for the French River
relied on approximate methods for estimating time of travel and water
depths in the various river reaches. Since river hydraulics play an
important role in determining in stream DO levels, a more accurate
definition of depth and time of travel values input to the model was
derived for use in this study.
Hydrology and Hydraulics . The major in-stream processes which are
simulated using the STREAM7B model are BOD decay (nitrogenous and
carbonaceous); atmospheric reaeration; sediment oxygen demand; and net
photosynthetic oxygen production. The model treats the river as a one-
dimensional series of zero-dimensional, fully-stirred tank reactors
(FSTR’s), with a model reach consisting of one or more FSTR’s. The
dissolved oxygen concentration within an FSTR is thus dependent on the
time of travel and reaeration within that section of the river.
Reaeratjon is a function of the mean stream velocity and water depth
within each FSTR.
3_1 9
-------
Hydrologic input data for the model were updated using flow and
drainage area measurements for the Hodges Village and Webster gages, and
individual reach drainage areas digitized from USGS topographical maps.
With the exception of the calibration runs, 7Q10 low flow conditions were
used as input to the modeling of the French River.
The hydraulics of the French River were studied in detail during
recent Federal Emergency Management Administration (FEMA) Flood Insurance
Studies of Leicester, Oxford, and Webster, Massachusetts and Thompson,
Connecticut. Over 1400 stream cross-sections at natural valley areas
(between dams, culverts, etc.) and significant hydraulic control
structures along the French River were surveyed and input to the step-
backwater numerical model, HEC-Il (U.S. Army Corps of Engineers).
The same input data sets used for the FEMA studies to define river
and control structure geometries were used for the low flow HEC-Il runs
made in this water quality study. However, the river discharges were
modified to reflect a range of sununer low flow conditions in the French
River. As a result of the HEC-Il modeling of low flow conditions, more
accurate estimates of time of travel, current velocity and mean water
depths within each river reach were determined as a function of low flow
river discharge. This portion of the modeling resulted in 7Q10 profiles
as well as the stream bottom profiles for the French River between
Sargent’s Pond in Massachusetts and Mechanicsville, Connecticut. The
7Q10 profile was presented previously as Figure 3-2.
Results from the HEC-II modeling of low flow conditions were
subsequently input to a simple computer program to calculate river flow
power function coefficients and exponents for time of travel arid mean
depths of each reach, for input to the STREAM7B model.
Model Calibration . Using wastewater BOD and DO loads measured in
September 1982; time of travel and depth parameters generated by HEC—Il;
and stream discharge data obtained during the August 1982 survey;
STREAM7B was first used to simulate the minimum dissolved oxygen values
measured during the August 1982 survey, assuming no photosynthetic oxygen
production. This first simulation was achieved by adjusting the sediment
3-50
-------
oxygen demands within ranges of values which were measured in the French
River. The model was then calibrated to the average dissolved oxygen
values measured during the August 1982 survey. In this calibration, net
photosynthetic oxygen production was included and adjusted within
reasonable limits. A calibrated SOD rate of 3.5 g/in 2 /day was input to
the model for the reach between the Webster-Dudley WWTP and the
Perryville darn. Downstream of the Perryville dam to the North
Grosvenordale dam, SOD was input as 2.0 g/m 2 /day. Results of’ the August
1982 calibrations both with and without algal oxygen production are
presented in Figure 3-19, which demonstrates that photosynthetic activity
is an important contributor to dissolved oxygen levels in the river.
Conversely, DO levels may be somewhat depressed during periods of
nocturnal respiration, or when plant growth is otherwise suppressed.
Subsequent model runs predicting future water quality impacts of the
various alternatives exclude photosynthetic oxygen production as a
conservative assumption.
The sensitivity of the model to the SOD values measured in 1985
was subsequently evaluated, and compared to the calibration run (in the
lower portion of’ the river only). Photosynthetic oxygen production was
included in both runs. Results of the comparison are presented in
Figure 3-20. The 1985 SOD data collected in Perryville, MA and
Wilsonvilie, CT, were substantially higher than those collected in 1978
at these locations. Consequently, the model run using the more recent
data shows a severe depression of DO in the ponds. As discussed
previously, the actual “stressed” SODs are likely much lower, and would
have less impact on overlying DO than is shown. Subsequent model runs
projecting water quality with various alternatives utilized the
calibrated SOD values.
Simulation of Existing Low Flow Conditions . Once calibrated, the
model was used to simulate DO levels in the French River during a ?Q10
low flow event with a flow of 1LL8 cfs at the USGS Webster Gage. As
shown in Figure 3—21, extreme low flow conditions in the river, with
existing levels of wastewater treatment and no photosynthetic oxygen
production, would cause a severe depression of DO levels in the
downstream impoundments. DO concentrations in Perryville Pond and
3-51
-------
15
28 24 zu lb 8 4 0
RIVER MILE
— With 02 fkoduction
— — — —— Without 02 Production
o Maximum DO Value
o Average DO Value
+ Minimum DO Value
FIGURE 3-19 CALIBRATION TO 1982 DATA:
SENSITIVITY TO PHOTOSYNTHETIC OXYGEN PRODUCTION
14
13
12
11
10
8
7
5
w
a
z
K
0
a
w
-J
0
0)
a
6
4
3
2
1
0
-------
— Calibration
— — — 1985 SOD Values
RIVER MILE
FIGURE 3-20 CALIBRATION TO 1982 DATA:
SENSITIVITY TO MEASURED SEDIMENT OXYGEN DEMAND
C,
I
z
C,
x
0
0
>
-a
0
U)
U )
0
15
14
13
12
11
10
9
6
7
6
5
4
3
2
1
0
28 24 20 16 12 8 4 0
-------
15
g
6
5
2
10 8 6 4 2 0
RIVER MILE
Existing Treatment
Oriver 14.8 cfs
Owwtp = 6.0 rnqd
SOD 3.50 g/sq rn/day @ Perryville Pond
SOD a 2.00 g/sq rn/day Linger’s Pond
SOD a 2.00 g/sq rn/day @ N. Groivenordale Pond
14
J.
>.
w
-a
0
0
5
U i
-J
-J
>
>.
U i
U i
-J
-J
>
z
-J
Ui
-J
0
0
z
Ui
0
14
8
13
7
Mi
1
0
0
z
Mi
>
12
11
•10
4
9
‘S
WATER QUALITY CRITERION
7
1
T
.4
2
1
FIGURE 3.21 DISSOLVED OXYGEN CONCENTRATIONS UNDER LOW FLOW (7Q10) CONDITIONS
-------
Langer’s Pond are estimated to be between 1 and 2 mg/i, and reach a
minimum in North Grosvenordale. Levels in the Grosvenordaie impoundment
are also depressed, although not as severely. One major reason for these
extreme conditions is the increase in residence time during low flows,
which reduces reaeration and increases the influence of SOD and BOD
decay. Low flow residence times range from approximately 0.5 days in
Perryvilie Pond to 1.3 days in Langers Pond to almost 7 days in North
Grosvenordale.
Biological Conditions
The following summary of the biological conditions is based, to
the maximum extent possible, on site specific data. The review focuses
on the plants (phytoplankton and wetlands) as well as the benthic
invertebrates, fish and wildlife in the study area.
Phytoplankton . Phytoplankton communities are a good indicator of
the current health of a body of water in that they are affected fairly
rapidly by changes in water quality. They are, however, vulnerable to
transport by river flows and thus limited in site specificity.
Phytoplankton samples were taken at the Perryville impoundment by
MDWPC in August 1982 and July 1984. Summaries of the data may be found
in Tables 3-15 and 3-16. The total phytoplankton density in the 1982
survey was 9146,800 cells/i as compared to 210,000 cells/i in 19814. The
lower value in 198 4 may be due to the high flow (more than 14 times
greater than in 1982), which could have washed the community
downstream. In both studies, green algae (Chlorophyceae) dominated. In
1982 they made up 58 percent of the sample and in 198 4 they made up 46
percent. Blue-green algae (Cyanophyceae) accounted for 3 percent of the
sample in 1982 and 13 percent in 19814. No diatoms were recorded in 1984,
however, they comprised 39 percent of the community in 1982. In 19814,
golden-brown algae (Crysophyceae) made up 33 percent of the sample while
they were not present in 1982. Due to the high variation in density and
non-dominant species composition between the two sampling periods, it is
difficult to characterize the nature of the community in other than
qualitative terms.
3-55
-------
The domination of green algae, along with some blue-greens, is
typical of nutrient enriched temperate lakes during warmer periods of the
year. Lakes of this nature are typified by diatom blooms in spring,
smaller irregular suniner peaks of various flagellates, and large fall
blooms of diatoms, blue-green algae and dinoflagellates (Goldman and
Home, 1983). The difference in species composition between the two
sampling periods may be due to the natural variability of the community.
In August-September 198i , the CT DEP conducted phytoplankton
studies in the southern portion of the French River at Langer’s Pond,
North Grosvenordale, Grosvenordale and Mechanicsville (Table 3-17).
Diatoms, including Cyclotella sp. and Melosira sp., were the most
abundant organisms at all four sites. The blue-green alga Oscillatoria
was coninon in trawl samples at North Grosvenordale, however, blue-greens
were not observed at the other three areas. The green alga spirogyra was
TABLE 3—15 PHYTOPLANKTON DATA - AUGUST 18, 1982
PERRYVILLE IMPOUNDMENT, WEBSTER, MASS
TPLXA
Cell/i
Percent of total
Diatoms
39
Centric
105200
Pennate
263000
Blue-Green
3
Coccoid
26300
Filamentous
0
Green
58
Coccoid
526000
Desmids
26300
Filamentous
0
Flagellates
0
Green
0
Other
0
Total Live Algae
9 1 16800
100
SOURCE: MDWPC, 1952
3—56
-------
TABLE 3-16. PHYTOPLANKTON DATA - JULY 9, 1981$
PERRYVI LLE IMPOUNDMENT, WEBSTER, MASS
TAXA
Cell/i
Percent of
Total
Blue-Green
13
Aphanocapsa sp.
114000
Anabaena sp.
114000
Green
147
Pa.nadorina sp.
142000
Scenedesmus sp.
1 14000
Unidentified flagellate
42000
Golden-Brown
33
S jnura sp.
114000
Unidentified flagellate
56000
Euglenophyceae
7
Euglena sp.
1 40O0
TOTAL
210000
cells/i
100
Chlorophyll a value
0.6148 mg/rn 3
* Grab sample 0.5 in below surface
SOURCE: MDWPC, 19814
abundant in East Langer’s Pond and common in North Grosvenordale.
Pediastrum duplex was common in West Langer’s Pond, North Grosvenordale,
and Mechanicsville. Virtually all the species collected in this study at
all four locations (with the exception of volvox) are described as
pollution tolerant by Palmer (1969).
Plankton densities at the lower end of West Langer’s Pond, North
Grosvenordale, Grosvenordale and Mechanicsville ranged from essentially
zero at Mechanicsville to 3,650,000 cells per liter in Langer’s Pond.
These densities may be lower than usual due to high water flow during the
sampling period. The relatively higher plankton densities at upper west
Langer’s Pond and east Langer’s Pond are in backwater areas with less
flow. These areas are organically enriched, tepid waters, especially
conducive to algal growth. Appendix B contains the complete
phytoplankton species list for the downstream impoundments.
3-57
-------
TAII.E 3—17. FRENCH RIVER DOMINANT PLANETON DATA — AUGUST, 1984
CONNECTICUT INPOUNDNENTS
CT DEP, 1984
Taxa
F . Langera
Pond
14. Langera
Pond
N. Gro9Venordale
Gro9venordale
Mechanicaville
lower end
upper end
lower end
tipper end
01 a toes
-
Cyclotella ap.
93 2 ( 9)
100 2(a)
792(c)
872(s),q(t)
1002(e)
1002(a),
c(t)
Navicula ep.
Meloaira ap.
72(a)
MA(t)
MA(t)
142(c)
MA(t)
MA(t)
MA(t)
C—A
l”ragilaria tip.
Gompho,phaoria lacustrja
A(t)
CA(G)
C(t)
C—A(t)
C(t)
Fragilarla ap.
Blue—Green Algae
Oxclllatoria
C(t)
Green Algae
Spirogyra ap.
A(t)
C(t)
Scenede mua quadricauda
Vol v ax ap.
13 2( a),va(t)
MA(t)
IJaidenti fled filamentoua
Pediagtrum duplex
C—ACt)
82(a),c(t)
C(t)
2 on p Ia nk t on
Bogmina ap.
A(t)
MA(t)
Brachionux coidenta
MA(t)
Keratella tip.
MA
Total Oensity (celia/I)
1,053,000
211,000
3,650,000
562,000
211,000
211,000
—
(a) concentration in aurface grab aample
Ct) — relative concentration in trawl ample
MA — moat abundant
A — abundant
(‘—A common to abundant
C common
vs — Very sparse
a — sparse
-------
Along the French River the peripheral wetlands are mainly
palustrine deciduous forested wetlands and palustrine emergent
wetlands. This is the case from Rochdale south to Oxford. The
vegetation in Oxford was studied in depth by the U.S. Army Corps of
Engineers in 198)4 for their Draft Environmental Impact Statement for Low
Flow Augmentation at Hodges Village Dam. Four wetland cover types
present in the area are: palustrine deciduous forested wetlands;
palustrine needle leaved evergreen forested wetlands; palustrine scrub-
shrub wetlands; and palustrine emergent wetlands. Upland cover types
represented in the area include upland deciduous forest; upland needle-
leaved evergreen forest; upland scrub-shrub and upland forb/grassland.
Red maples predominate in the wetlands and are usually accompanied by
meadowsweet, black alder, speckled alder and other shrubs. Black willow,
red maple, gray birch and red osier dogwood are the common woody plants
along the river and stream banks. Major marsh species include the
rushes, spike rush, wool—grass, cattail and tussock sedge. Red osier
dominate the shrub swamps.
Vegetation . The French River basin was originally covered with
mixed forests of white pine, oak, chestnut, poplar, maple, and white and
gray birches, however, industrial and agricultural development of the
basin virtually eliminated all of the virgin forest. It has been
estimated that at one point in history, 80 to 85 percent of Worcester
County was cleared for agricultural use. Much of the land has since
returned to natural cover, and the vegetated portions of the basin are
now comprised of secondary-growth hardwood forests interspersed with
agricultural and oldfield vegetation.
The vegetation of a wetland influences the hydraulic regime,
contributes to nutrient cycling and provides ecologically valuable
wildlife habitats. The type of vegetation depends on several factors,
such as hydroperiod, soils and water chemistry. Aquatic plants produce
oxygen through photosynthesis, shade and cool sediments, diminish water
currents and provide habitat for benthic organisms, fish and wildlife.
Submerged macrophytes serve as food, nest sites and shelter from
predators for aquatic insects and fish.
3-59
-------
Submergent vegetation in the wetlands behind the Hodges Village
darn generally consist of water celery (vallisneria), coontail
(ceratophyllum sp.), watermilfoil (Kyriophyllum sp.) and pond weed
(Potamogetan sp.), which are generally covered with a periphyton
connuunity (U.S. Army Corps of Engineers, 19814).
The peripheral wetlands of’ the section of the French River which
flows from Hodges Village south to Oxford are classified as palustrine
deciduous forests with some palustrine shrub-scrub and emergents. The
peripheral wetlands from Oxford south to Dudley are classified mainly as
palustrine emergents with some palustrine deciduous forest into
Perryville.
According to the U.S. Fish and Wildlife Service’s wetlands
inventory mapping, the series of small impoundments in the lower half of
the French River basin are classified as lacustrine, open water, limnetic
habitat. The surrounding areas are palustrine deciduous forest and the
connecting stretches are open water riverine. Lacustrine habitats are
wetlands and deepwater habitats with all of the following
characteristics: situated in a topographic depression or a dammed river
channel; lacking trees, shrubs, persistent emergents, emergent mosses or
lichens with greater than 30 percent areal coverage; and total area
exceeds 8 hectares (20 acres). Similar wetland and deepwater habitats
totaling less than 9 hectares are also included in the lacustrine system
if an active wave-formed or bedrock shoreline feature makes up all or
part of the boundary, or if the water depth in the deepest part of the
basin exceeds 2m (6.6 feet) at low water. The lacustrine system is
bounded by upland or by wetland dominated by trees, shrubs, persistent
emergents, emergent mosses or lichens. Systems formed by damming a river
channel are bounded by a contour approximating the normal spiliway
elevation or normal pool elevation, except where palustrine wetlands
extend lakeward of that boundary (Cowardin et al., 1979). Limnetic
habitat refers to all deepwater habitats within the lacustrine system.
Aquatic macrophytes observed by MDWPC personnel in the Perryville
impoundment on 9 July 19814 are listed in Table 3-18 and mapped in
Figure 3-22. Connecticut DEP data for impoundments downstream of
3-60
-------
TABLE 3-18. TAXONOMIC LISTING OF AQUATIC AND
WETLAND VASCULAR PLANTS AND ASSOCIATED
HABITATS IN PERRYVILLE POND
July, 1981$
Relative
Plant Taxa Habitat Abundance
1. Typha latifolia littoral, abundant
(Common Cattail) shoreline
2. Sparganium sp. littoral common
(Burreed)
3. Potamogetan natans littoral uncommon
(Floating-leaf Pondweed)
14• sagittaria sp. littoral, abundant
(Arrowhead) shoreline
5. Elodea canadensis coves, littoral common
(Canadian Pondweed)
6. Grainineae littoral, common
(various grass genera shoreline
and species unidentified)
7. Dulichium arundinaceum littoral, uncommon
(Three—way Sedge) shoreline
8. Eleocharis sp. littoral uncommon
(Spikerush)
9. Carex stricta shoreline common
(Niggerhead)
10. Peltandra virginica littoral, common
(Arrow Arum) shoreline
11. Lemna minor open water, abundant
(Smaller Duckweed) coves, littoral
12. Woiffia sp. open water, abundant
(Water—meal) coves, littoral
13. Pontederia cordata littoral, abundant
(Pickerelweed) shoreline
114. Juncus etfusus littoral uncommon
(Soft Rush)
3-61
-------
TABLE 3-18 (Continued). TAXONOMIC LISTING OF AQUATIC AND
WETLAND VASCULAR PLANTS AND ASSOCIATED
HABITATS IN PERRYVILLE POND
July, 19814
Relative
Plant Taxa Habitat Abundance
15. Decodon verticillatus littoral, common
(Water-willow) shoreline
16. Lythrum salicaria shoreline uncommon
(Spiked or Purple
Loosestrife)
17. Myriophyllum sp. littoral common
(Water Milfoil)
18. Cornus stolonifera shoreline common
(Red osier Dogwood)
19. Myosotis scorpiodes littoral, uncommon
(Forget-me—nots) shoreline
20. Solanuni dulcamara shoreline uncommon
(Bittersweet Nightshade)
21. Gratiola sp. littoral uncommon
(Hedge Hyssop)
22. Cephalanthus occidentalis shoreline uncommon
(Buttonbush)
Source: MDWPC, 1984
3—62
-------
2. Lemnaceae (Duckweed)
4. Pontederia cordata (Pickereiweed)
7. Sagitarria sp. (Arrowhead)
latifolia (Common Cattail)
11. Wolffiasp. (Water-meal)
A = abundant
C = common
S = Sparse
2S
2C, itS
2C, 7C, 9S, ii S
2A, 4C, 1
2A, 7A, hA
SOURCE: MDWPC
0
SCALE IN FEET
2C, 4C,7C, 9C, hiS
2S
2C, his
4S
4C, 7S, 9C
4S, 7C, 9C
7C
9A, 4S, 7S
200
9A
7S
200
2C, 11C
FIG. 3-22 AQUATIC AND WETLAND VASCULAR PLANTS IN PERRY VILLE POND
-------
Perryville are listed in Table 3-19 and shown in Figures 3—23 through
3-25. Canadian pondweed, grasses, soft rush, smaller duck weed, water
milfoil, pickerelweed and burreed are all littoral herbaceous plants
requiring permanent standing or slow-flowing water. Common cattail and
water willow are herbaceous plants whose root system extends into the
water table or in a semi-saturated layer just above the water table.
Availability of “free” water is a requirement for growth. Buttonbush and
red osier dogwood are woody shrubs that tolerate saturated conditions for
limited periods of time during the growing season (US EPA, 1981).
Emergent macrophyte cattail marshes support insects, which are
essential food organisms for fish and avifauna, and serve as spawning
ground for sunfish and shelter for young fish (Fronne, 1938; Hubbs and
Eschmeyer, 1938). U.S. EPA (1981) described the value of’ some of the
other plants native to the impoundments. The pickerelweed, which is
abundant at Perryville, Langer’s Pond and Grosvenordale, provides
wildlife cover and food; its leaves are eaten by Canada geese and its
roots and seeds are food for muskrat and waterfowl. The smaller duckweed
(abundant at Perryville and east Langer’s Pond) often mats together and
forms a solid mantle of green on a ponded area; waterfowl and some fish
feed on it. Arrow aruin, which is common at Perryville, is an excellent
habitat cover type for waterfowl, marsh birds and muskrat. Buttonbush,
classified as uncommon in Perryville, is an important waterfowl food; its
stems are eaten by muskrats and it provides stabilization for mud at
pond edges. Spiked loosestrife, also uncommon in Perryville, is
considered to be low in value for wildlife.
Although Perryville is a relatively small wetland (< 10 acres), it
is made up of a diverse community of valuable plants that may provide
food and cover for many marsh inhabitants. It does not, however, have
the large open water habitat of the downstream impoundments. The open
water areas downstream provide a different type of habitat and would,
therefore, support a different type of community.
3_614
-------
TABLE 3—19. MACROPHYTE ANALYSIS IN CONNECTICUT INPOUNDN!NTS — AUCUST, 1984
Species
S. Langers Pond
W. Langera Pond
N. Groavenordale
Groavenordale
Mechanicsville
Myrioph iiiumap. (Water milroil)
MA(p)
A(p)
S
Anacharia canader,ic (Water Weed)
MA(p)
C(p)
Typha latifo.La (common cattail)
A
C—A(e)
S(e)
A(e)
A(e)
Pontederia cordata (Pickerel Weed)
A(e)
C—A(e)
S(e)
A(e)
A(e)
L mna minor (smaller duckweed)
A
C(p)
Sagittaria so. (arrowhead)
A(e)
C—Ate)
S(e)
Potamogeton ap. (Pond weed)
A(p)
S
Scirpus app. (bulruahes)
A(e)
NOTE: North Grosvenordale Pond had been dewatered, prior to survey.
MA — Moat abundant
A — Abundant
C—A — Common to abundant
S = Sparce
(p) — In pond
(e) — Around edges
Source: CT DSP, 1984
-------
1. Anacher,s canadensis (Waterweed)
2. Lemn.ce.e (Duckweed)
3. Myriophylum ap. (Water Milfoil)
4. Pontederia cordata (Pickereiweed)
5. Potamogeton epihydrus (Leafy Pondwised)
7. Sagitraria sp. (Arrowt ead)
8. Scirpus (Torreyi) ((Torreys) Three Square Bulrush)
9. Typha latifolia (Common Cattail)
12. filamentous algae
A abundant
C = common
SSparse
3C
9A
7A. 4A
7A
4A
9A
7A.
3C
7C
4C
SOURCE: CTDEP
FIG. 3-23 AQUATIC AND WETLAND VASCULAR PLANTS
IN LANCER’S POND (WILSON VILLE)
9A
8C
5S
Ii
9A
3S
9A
7A. 4A
200
9A
12A
0
200
SCALE IN FEET
-------
4. Pontederia corda ta (Pickereiweed)
9. Typha latifolia (Common Cattail)
A = abundant
C = common
S = Sparse
1,000 0 1.000
SCALE IN FEET
(approx.)
SOURCE: CTDEP
NOTE: Pond had been dewatered prior to survey
FIG. 3-24 AQUATIC AND WETLAND VASCULAR PLANTS
IN NORTH GROSVENORDALE POND
WEBSTE
ill iii Bk.
DUDLEY
MA ____ ___
CT
North
Grosvenordale
Dam—.. THOMPSON
4C
9c
4C
9C
-------
1. An haris canadensis (Water ed)
3. Myriophylum sp. (Water Milfoil)
4. Pontederia cordata (Pickereiweed)
6. Potamogeton (natans) (Floating-leaf Pondweed)
9. Typha Latifolia (Common Cattail)
10. (Vallisneria americana) (Taoe Grass)
A = abundant
C common
S = Sparse
3C
4C
1 C-A
6 C-A
10 C-A
3A
ic
los
4A
WEBSTE
MuI&.
DUDLEY
MA ____ ___
cY - - ___-
Grosvenordale THOMPSON
Dam—.
4A
1A
3S
4A
ic
9C
is
3S
6A
300
0 300
I I
4C
9A
SCALE IN FEET
(approx.)
RD.
SOURCE: CTDEP
FIG. 3-25 AQUATIC AND WETLAND VASCULAR PLANTS IN GROSVENORDALE POND
-------
Buffuinville Lake is located on the Little River, a tributary
flowing east into the Upper French River just south of Hodges Village.
The habitat types at Buffumville Lake are shown in Figure 3-26. The lake
was created as a flood control project by the U.S. Army Corps of
Engineers and completed in 1958. Due to the steep slope of the
surrounding lands, there is a minimal area of wetlands surrounding the
edges of Buffumville Lake. The Little River (the watershed on which this
lake has been based) is extremely narrow at the point of entry and
supports a very limited area of wetlands due to the steep elevational
gradient of the surrounding lands. The existing wetlands surrounding the
lake comprise approximately six acres. This includes all areas of
emergent macrophytes as well as areas of palustrine scrub shrub. Based
on the existing operational strategy of water level control within the
reservoir over the past five years (see Table 2 —1), these wetlands have
become established as zones that are spatially static in terms of
relative areal extent, when compared with the temporal dynamic changes in
water levels within the reservoir. There is approximately one acre of
emergent macrophyte wetlands near the headwaters and then the land rises
rapidly perhaps 3 to 14 feet in elevation into a beech—birch forest, and
then into higher ground with conifers and mixed deciduous hardwoods. The
water depth drops off rapidly from shore, and there is a very small band
of submerged macrophytes, Myriophyllum sp. (watermilfoil) in
clearwater. Fringe vegetation in the wetlands of Buffumville Lake
consist of pickerel weed (Pontederia) and arrowheads (sagittaria) as well
as black willows, etc. The area of open water is approximately 95
percent while the wetlands account for less than 5 percent of the area.
Benthic Invertebrates . The benthic community of any water body is
indicative of the long-term environmental conditions. The benthos is
primarily made up of slow moving organisms which must be capable of
adapting to changes in water quality as they cannot easily escape
stressful conditions. Thus they are generally a good indicator of the
typical conditions at that sampling point.
3—69
-------
MIXED DECIDUOUS AND
CONIFEROUS FOREST
PALUSTRINE SCRUB SHRUB
AND EMERGENT MACROPHYTES
LACUSTRINE LITTORAL
UNCONSOLIDATED SHORE
LACUSTRINE LITTORAL
UNCONSOLIDATED
BOTTOM AND SHORE
>10 LACUSTRINE LIMNETIC
UNCONSOLIDATED BOTTOM
A A’
FIG. 3-26. HABITATS AT BUFFIMVILLE LAKE
-------
BUFFUMVI LLE
POND
PALUSTRINE SCRUB SHRUB
t’ ”1 AND EMERGENT MACROPHYTES
LACUSTRINE LITTORAL
UNCONSOLIDATED SHORE
LACUSTRINE LITTORAL
UNCONSOLIDATED
BOTTOM AND SHORE
>10 - LACUSTRINE LIMNETIC
I. I UNCONSOLIDATED BOTTOM
A - - -___ — - A ’
8
* 1 MIXED DECIDUOUS AND
CONIFEROUS FOREST
B
B’
FIG. 3-26. (Cont.) HABITATS AT BUFFUMVILLE LAKE
-------
B
________ B’
MIXED DECIDUOUS AND
CONIFEROUS FOREST
PALUSTRINE SCRUB SHRUB
AND EMERGENT MACROPHYTES
LACUSTRINE LITTORAL
E &kk SS\NS1 UNCONSOLIDATED SHORE
LACUSTRINE LITTORAL
UNCONSOLI DATED
BOTTOM AND SHORE
L 1
>10’ - LACUSTRINE LIMNETIC
UNCONSOLI DATED BOTTOM
I.
I
C’
SAND AND GRAVEL
OPERATION
SAND AND GRAVEL
OPERATION
FIG. 3-26. (Cont.) HABITATS AT BUFFUMVILLE LAKE
-------
Excessive suspended sediment levels and silt deposition (as has
historically occurred in the French River impoundments) may influence
macroinvertebrates by causing avoidance of adverse conditions by
migration and drift; increased mortality due to physiological effects,
burial, and physical destruction; reduced reproduction rates because of
physiological effects, substrate changes and loss of early life stages;
and modified growth rates because of habitat modifications and changes in
food type and availability (Farnworth et al., 1979).
Table 3-20 is a summary of the benthic community sampled in the
Perryville impoundment on July 9, 1984 by MDWPC personnel. The community
is made up of oligochaetes and chironomids, both of’ which are considered
to be taxa capable of tolerating low DO conditions (U.S. EPA, 1984).
During the May 1985 SOD sampling survey conducted in the impoundments,
EPA biologists observed populations of organisms to be far more dense in
Perryville than in Wilsonville or North Grosvenordale and than ever
observed in previous surveys. Predominant organisms in Perryville Pond
included tubificid worms, chironomid larvae, leeches, physid snails and
midges. The midges were present in such abundance that the river bottom
near the dam was red as a result of the organisms’ hemoglobin.
Tables 3-21 through 3-23 summarize the benthic data collected by
CT DEP in October 1984 at the impoundments in the southern portions of
the French River. One of the most common benthic taxa at all five
sampling locations was the pollution tolerant midge (chironomids).
Midges typically increase in numbers with increasing degrees of
eutrophication (U.S. EPA, 1984). The oligochaete Limnodrilus
hoffmeisteri, known to predominate in areas receiving heavy sewage
pollution (Aston, 1973), was also present at all five locations. The
mayfly Caenis sp. was found in relatively large numbers at Mechanics-
yule. Unlike most mayflies, which are relatively pollution sensitive,
this genus has been found to exist at dissolved oxygen concentrations
less than 4 mg/l (Roback, 1974). The bivalve Sphaeriidae was found in
the western portion of Langer’s Pond, and the gastropod Amnicola limnosa
at Grosvenordale. Both are indicative of eutrophication (U.S. EPA,
3—73
-------
a.
TABLE 3-20. PERRYVILLE IMPPWJDMENT
INVERTEBRATE ANALySIS(a)
JULY 9, 19811
Taxon
Station
A
B
C
D
Oligochaeta (aquatic earthworm)
Insecta
Chironomidae (midges)
Procladius sp.
0
1
0
1
Chironomus sp.
14
17
6
13
Cryptochironomus sp.
0
1
0
0
Endochironomus nigricans
0
1
0
0
Glyptotendipes sp.
0
1
0
0
Phaenopsectra sp.
1
22
1 14
7
Polypedilwn or scalaenum
0
3
0
0
Rheotanytarsus sp.
0
0
1
0
Thnytarsus/!licrospectra sp.
1
1
0
0
Total number of organisms counted
6
47
21
21
each bank
Samples were obtained with a Petite Ponar grab sampler off
and at quarter points along one transect of the impoundment.
b. Station locations:
A — Right bank
B — Right quarter-point
C - Left quarter—point
D - Left bank
c. Abundant
SOURCE: MDWPC, 19814
3—714
-------
TABLE 3—2 1. PERCENT OCCURRENCE OF DOMINANT
MACROINVERTEBRATE TAXA AT LANGER’S POND
October, 19811
East West
Taxa Langers PondLangers Pond
O ligochaeta
Lininodrilus (hoffmeisteri) 85% 91%
Insecta (chironomids)
Procladius subletti 5%
Chironomus spp. 1% 6%
Chauhorus spp. 1%
Amph ipoda
Hyalella azetca 3%
Source: Ct CEP, 198 4
TABLE 3-22. PERCENT OCCURRENCE OF DOMINANT
MACROINVERTEBRATE TAXA AT NORTH
GROSVENORDALE POND - OCTOBER, 19811
Taxa North End South End
01 igochaeta
Lirnnodrilus (hoffmeisteri) 50% 33%
Tubifex tubifex 3%
Insecta (chironomids)
Chironomus spp. 14 )4% 140%
Bezzia group 3%
Chaobarus spp. 7%
Procladius subletti 13%
Odonata
Perithomis spp. 7%
Source: CT DEP, 198 4
3-75
-------
TABLE 3-23. PERCENT OCCURRENCE OF DOMINANT
MACROINVERTEBRATE TAXA AT
MECHANICSVILLE POND - OCTOBER, 1981
Taxa East Side West Side
01 igochaeta
Limnodrillus (hoftmeisteri) 19%
Insecta (chirono4nids)
Procladius su.bletti 19%
CryptochironoEus fuirs 19% 20%
Chironomus spp. 10% 20%
Chaoborus spp. 20%
Insecta (mayfly)
Caenis spp. 19%
Source: CT DEP, 198 4
3—76
-------
19814). Appendix B contains the complete benthic data set for the
downstream impoundments.
The benthic communities at all of the downstream impoundments were
dominated by organisms capable of existing in eutrophic conditions with
low DO concentrations.
In contrast to the downstream impoundments, MDWPC also conducted
benthic analyses in Town Meadow Brook (in Leicester), an upstream
tributary of the French River, during October 19814 (Table 3—214). This
area supports over twice as many taxa as the Perryville impoundment and
over four times as many individuals, assuming comparable sample sizes.
Species observed at Leicester include pollution sensitive organisms such
as the mayflies, as well as more tolerant organisms such as oligochaetes
and daniselflies. Pollution sensitive organisms were more abundant than
the more tolerant organisms. The benthic community in this area was
characteristic of a healthy water body. The benthic community structures
in the downstream impoundments appear to be the result of significant
anthropogenic influences, since the number of species and density of
individuals are low compared to an ecologically healthy benthic
community.
Fisheries . Although no site specific quantitative studies have
been made of the fish populations in the French River and its
impoundments (other than data site-specific to the flood control
reservoirs), fish collections for tissue analysis (MDWPC, 19814; CT DEP,
19814; US F&WS, 1985) document some of the species inhabiting the ponds.
Fish species known to occur at Perryville, Langer’s Pond and North
Grosvenordale are listed in Table 3-25. Bullheads, shiners, perch,
suckers, sunfish and black crappie are typical warmwater species.
Bullheads, yellow perch and largemouth bass prefer areas with sluggish
currents or slack water (less than 5 cm/second). Some species of
bullhead can withstand DO levels as low as 3 mg/i. Concentrations of 5
mg/i DO cause physiological stress in largemouth bass, and concentrations
less than 1.0 mg/l are lethal (U.S. EPA, 19814).
3—77
-------
TABLE 3_211
INVERTEBRATE ANALYSIS
TOWN MEADOW BROOK, LEICESTER MA
OCTOBER, 1981!
Repi icates
Taxon A B
Turbellaria (flat worms) 1 0
Oligochaeta (aquatic earthworms)
Tubificidae (immature without capilliform 0 1
chaetae)
Hydracarina (water mites) 1 1
Insecta
Ephemeroptera (mayflies)
Baetis sp. 2 0
Stenonema sp. 56 9
Habrophlebia vibrans 0 2
Paraleptophiebia sp. 114 7
Eurylophella sp. 10 9
serratella sp. 13 1
Odonata (dragonflies and dainseiflies)
Argia sp. 14 14
Calopteryx sp. 2 0
Hemiptera (true bugs)
Rhagovelia sp. 0 2
Megaloptera (dobsonfi ies)
Nigronia sp. 5
Trichoptera (cad isflies)
Chuematopsyche sp. 2 1
Chimarra sp. 3 0
!lystacides sp. 0 1
Polycentropus sp. 9 21
Coleoptera (beetles)
Psephenus herricki 7 8
Stenelmis sp. 2 3
Diptera (true flies)
Antocha sp. 0 1
Thienemannimyia group 3 1
Orthocladiinae sp. 1 0
Pelecypoda (clams)
Pisidiidae sp. 1 33
Total number of organisms 136 92
NOTE:
a. Two replicate samples were obtained using a Surber 1.0 ft. 2
sampler. Numbers refer to number of organisms per replicate.
SOURCE: MDWPC, 19811
3-78
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TABLE 3-25. FRENCH RIVER FISH DATA
AUGUST 19811
Scientific Name
Common Name
Perry—
yule
Langers
Pond
North
Gros-
venor-
dale
Catastomus commersoni
White sucker
X
X
Perca flavescens
Yellow perch
X
X
Lepomis sp.
Sunfish
X
X
Micropterus salmoides
Largemouth bass
X
X
Ictalurus sp.
Bullhead
X
X
X
Morone americana
White perch
X
Esox niger
Chain pickerel
X
X
Pomoxis nigromaculatus
Black crappie
X
Notemigonus crysoleucas
Golden shiner
X
X Observed
SOURCE: CT DEP & MDWPC, 198)4
Fisheries management is performed by the Massachusetts Division of
Fisheries and Wildlife (MDFW) at Buffumville Lake. The reservoir
supports a warm water fishery. The MDFW stocks trout in the South Fork,
Little River as well as in other tributary streams on private property on
a put and take basis. Fish are stocked in the spring in numbers which
vary each year according to availability from the hatchery. Trout are
stocked at one point on Corps property on the South Fork, Little River.
In recent years about 300 eastern book trout (salvelinus fontinalis) are
stocked in the 6 to 9 inch class depending on availability (U.S. Army
Corps of Engineers, 1981).
Tiger muskies (Esox lucius x E. masquinongy) were stocked in
Buffumville Lake by MDFW in September 1980 on an experimental basis in
hopes that the sterile fish would control the pan fish populations and
provide a trophy—size fish for the recreational sport angler (U.S. Army
Corps of Engineers, 1981). Eight hundred fifty tiger muskies were also
stocked in June 1982 and 700 Northern pike were stocked in December 1985.
The MDFW sampled the fish population of Buffumville Lake in June
1978 using gill nets and electroshocking. A total of ten species were
found including a single brown trout (Salmo trutta), chain pickerel (Esox
3—79
-------
niger), largemouth bass (Micropterus salmoides), yellow perch (Perca
flavescents) white perch (Marone americana), pumpkinseed (Lepomis
gibbosus), bluegills (L. macrochirus), yellow bullheads (Ictalarus
natalis), brown bull head (I. nebulosus), and white suckers (Catostomous
commersoni).
The fish community in the Hodges Village backwater was sampled
during the summer of 1983 with an electroshocker by the Massachusetts
Division of Fisheries and Wildlife and the U.S. Army Corps of
Engineers. The community in the upper reservoir was made up of warmwater
species, dominated by white sucker, followed by golden shiner,
puinpkinseed, largemouth bass and some chain pickerel, fallfish and brown
and yellow bullheads. The community in the river downstream of the dam
generally consisted of the same species and was dominated by puinpkinseed,
golden shiner, largemouth bass, sucker and pickerel.
In May 1985, the fish populations at North Village and Perryville
Ponds were sampled using gilinets by the U.S. Fish and Wildlife
Service. The fish community at North Village Pond, the control site, was
predominantly golden shiners and brown bullhead with some white suckers,
puinpkinseeds and yellow perch and few creek chubsuckers and largemouth
bass. The fish community at Perryville consisted of mostly golden
shiners, puinpkinseeds and brown bullheads with a few sunfish, bluegills
and chain pickerel also present.
Scientists noted that the fish sampled from North Village Pond
appeared to be healthy both externally and internally with the exception
of parasites (black—spot). Livers of the fish caught at North Village
Pond appeared to be normal. Fish collected in Perryville, however,
appeared to be stressed. Specimens caught in gillnets at Perryville were
less lively than those fish caught at North Village Pond. The gall
bladders of fish caught at Perryville were either empty or contained less
bile than the fish caught upstream. One brown bullhead had tumorous
growth on its skin and head and about 50 percent of the bullheads had
barbie erosion.
3-80
-------
Heavy metals were found in the tissues of fish caught in the
Perryville impoundment in 198L (Table 3-26). Specifically, copper, iron,
mercury, zinc and aluminum were detected in yellow bullhead, golden
shiner and large mouth bass. All of these metals were also present in
the water column and/or the sediment. Cadmium, chromium, copper, lead,
nickel, zinc, iron and mercury were found in varying concentrations in
fish sampled from Langer’s Pond and North Grosvenordale (Tables 3-27 and
3-28). In both of these ponds, the metals most highly concentrated in
fish tissue were copper, zinc and iron. Cadmium and nickel were present
in fish tissues from Langer’s Pond and North Grosvenordale but were not
found at Perryville. However, they were present in the sediment at all
three areas. Heavy metal concentrations in fish tissue may cause
impaired reproduction and in some cases can be lethal. Effects on the
fish population in Perryville are indicated by one U.S. Fish & Wildlife
Service biologist’s recent observations that the population was skewed
towards smaller, younger fish and that the condition of the fish
indicates environmental stress.
In May 1985, polycyclic aromatic hydrocarbons (PAH’s) were
detected in the bile of brown bullheads sampled in the French River by
EPA and F&WS. Fish caught in Perryville Pond had one order of magnitude
higher concentrations of PAH’s than did fish caught in North Village
Pond. PAH concentrations were also measured in the root masses and new
growth of cattails (Typha latitolia) at both Perryville and Langer’s
(Wilsonville) Ponds. Root masses were found to contain much higher
concentrations of PAH’s than did the new growth. New growth collected at
Langer’s Pond had the lowest overall concentrations of PAH’s while root
masses collected at the same location had much higher concentrations than
the sample collected in Perryville. The PAH data from the Spring 1985
survey presented previously.
Wildlife . While no site specific data have been collected on the
waterfowl and aquatic wildlife of impoundments in the downstream portion
of the study area, a list of non-game species typical of New England
inland wetlands and uplands is presented in Table 3-29. The river also
3-81
-------
TABLE 3—26. PEI*YVILLH FISH TISSUE METALS ANALYSIS (MG/LC VET WEIGHT)
AUGUST 1984
Scientific Name
Common Name
Type of Sample
Cd
Cr
Cu
Ni.
Pb
Hg
Icc 1arus natali,
Yellow bullhead
single left filet
0.00
0.00
1.1
0.00
0.00
4.8
0.02
5.7
<0.1
Notemigonuw crysoleucal
Golden shiner
composite of 5
left filets
0.00
0.00
0.75
0.00
0.00
3.3
0.01
5.0
<0.1
NicropterOs salmoides
Largeiiouth bass
single left filet
0.00
0.00
0.75
0.00
0.00
1.8
0.02
5.0
<0.1
SOURCE: NDWPC, 1984
-------
TABLE 3-27. LANGER’S POND FISH TISSUE METALS ANALYSIS (WET WEIGHT)
Edible portions analyzed only.
—Age not able to be determined.
SEPTEMBER, 1981$
Common
Length
Weight
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
Iron
Mercury
Name
Age in.
g.
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
White Sucker
14.0
17.00
970
0.05
0.00
1.50
0.01
0.25
14.0
6.8
0.27
White Sucker
14.0
18.00
1255
0.05
0.25
1.80
0.08
0.00
5.3
12.0
0.16
White Sucker
14.0
16.00
852
0.05
0.00
1.50
0.09
0.00
14.0
5.8
0.13
White Sucker
14.0
16.00
869
0.10
0.00
1.50
0.01
0.00
14.8
7.8
0.114
Yellow Perch
5.0
10.75
270
0.05
0.00
0.75
0.00
0.75
14•3
5.8
0.06
Yellow Perch
5.0
10.75
306
0.03
0.00
1.00
0.02
0.50
14.8
7.3
0.15
Yellow Perch
6.5
10.00
228
0.03
0.00
1.30
0.014
0.50
14.0
5.8
0.15
Yellow Perch
6.0
9.75
239
0.00
0.00
0.75
0.06
0.25
14.0
5.5
0.11
Yellow Perch
5.5
9.75
239
0.00
0.00
0.75
0.00
0.00
3.3
6.8
0.09
Yellow Perch
6.0
9.50
218
0.03
0.00
1.00
0.09
0.50
5.3
7.8
0.09
Sunfish
5.5
7.00
167
0.18
0.00
0.75
0.09
0.50
14.3
8.8
0.07
Sunfish
6.5
8.00
159
0.10
0.25
1.30
0.00
0.25
14.8
8.0
0.18
Sunfish
11.5
7.50
168
0.08
0.00
0.75
0.02
0.00
5.3
6.3
0.14
Sunfish
4.5
7.50
172
0.08
0.00
0.75
0.03
0.50
L$.3
5.5
0. 144
Sunfish
3.5
6.50
115
0.08
0.00
1.30
0.05
0.50
5.5
12.0
0.07
Largemouth Bass
3.0
9.00
1614
0.00
0.00
1.30
0.01
0.75
8.0
4.5
0.18
Largemouth Bass
Bullhead
3.0
-
10.00
12.00
254
337
0.13
0.03
0.00
0.00
2.00
1.00
0.09
0.00
1.30
0.50
14.5
2.8
22.0
14.8
0.18
0.06
Bullhead
-
12.75
561
0.05
0.00
1.30
0.00
0.75
4.0
6.0
0.05
Bullhead
-
12.00
3514
0.05
0.00
1.50
0.00
0.50
5.0
9.0
0.014
Bullhead
-
11.50
320
0.03
0.00
1.30
0.03
0.50
5.5
10.0
0.014
Bullhead
-
11.00
391
0.10
0.00
1.30
0.00
0.75
4.5
9.0
0.05
Bullhead
-
11.50
332
0.05
0.00
1.80
0.07
0.75
14.3
8.0
0.06
White Perch
2.5
9.00
222
0.05
0.00
1.50
0.02
0.00
14.5
16.0
0.07
White Perch
2.5
9.50
269
0.05
0.00
1.00
0.00
0.00
3.8
12.0
0.06
White Perch
2.5
9.50
264
0.05
0.00
1.30
0.01
0.50
3.3
214.0
0.03
White Perch
2.5
9.25
235
0.05
0.00
1.00
0.03
0.50
3.8
9.8
0.014
White Perch
2.5
9.50
2142
0.00
0.00
2.00
0.01
0.25
5.5
9.5
0.05
Chain Pickerel
3.0
18.00
576
0.08
0.00
1.30
0.00
0.50
5.3
4.3
0.28
Chain Pickerel
2.0
114.75
316
0.15
0.00
1.80
0.01
0.50
5.8
4.8
0.18
Chain Pickerel
3.0
17.00
536
0.10
0.00
1.80
0.00
0.75
6.5
8.3
0.26
-------
TABLE 3-28. NORTH GROSVENORDALE POND FISH
METALS ANALYSIS (WET WEIGHT)
Edible portions analyzed except as noted.
*Whole portion analyzed.
-Age not able to be determined.
SEPTEMBER,
TISSUE
1 98 4
Common
Name
Length
Age in.
Weight
g.
Cadmium
mg/kg
Chromium
mg/kg
Copper
mg/kg
Lead
mg/kg
Nickel
mg/kg
Zinc
mg/kg
Iron
mg/kg
Mercury
mg/kg
White Sucker*
Yellow Perch
Yellow Perch
Yellow Perch
Yellow Perch
4.5
4.5
5.5
4.5
14.5
18.25
8.75
9.25
9.75
8.75
1203
132
166
203
116
0.10
0.08
0.13
0.10
0.13
0.00
0.00
0.00
0.00
0.00
1.50
0.75
1.00
1.00
0.75
012
0.00
0.00
0.00
0.00
0.25
0.25
0.25
0.25
0.00
5.0
3.8
4.3
4.8
3.5
7.8
5.0
5.8
6.0
4.5
0.13
0.10
0.15
0.10
0.07
Yellow Perch
Yellow Perch
Sunfish
Sunfish
Sunfish
5.5
4.5
3.5
4.5
14.5
9.25
8.50
5.75
5.75
5.25
177
113
75
73
58
0.13
0.10
0.08
0.13
0.15
0.00
0.00
1.80
0.00
0.00
1.00
1.00
1.00
1.00
1.00
0.03
0.01
0.04
0.07
0.05
0.25
0.25
0.25
0.50
0.00
5.0
4.0
6.3
9.3
6.3
15.0
5.3
3.8
24.0
3.8
0.13
0.11
0.05
0.09
0.10
Sunfish
3.5
5.50
73
0.10
0.00
1.00
0.06
0.00
6.5
4.0
0.05
Sunfish*
3.5
6.75
105
0.08
0.00
1.50
0.01
0.50
7.5
9.3
0.11
Sunfish*
3.5
5.25
69
0.10
0.00
1.50
0.07
0.25
7.3
4.3
0.07
Sunfish*
3.5
7.00
134
0.13
0.00
1.00
0.21
0.25
4.8
16.0
0.12
Bullhead
-
12.80
422
0.20
0.00
1.50
10.00
0.25
6.3
140.0
0.05
Bullhead
-
11.80
329
0.08
0.00
1.80
0.114
0.00
5.5
11.0
0.04
Bullhead
-
11.80
382
0.08
0.00
1.00
0.24
0.25
2.8
5.5
0.05
Bullhead
-
11.50
276
0.10
0.00
1.00
0.02
0.25
3.0
5.0
0.06
Bullhead
-
11.75
367
0.18
0.00
1.00
0.07
0.50
14.0
7.0
0.08
Bullhead
-
12.50
1456
0.13
0.00
1.00
0.04
0.00
3.0
4.3
0.06
Bullhead
—
12.00
367
0.40
1.00
1.30
0.07
28.00
4.8
19.0
0.05
Chain Pickerel*
2.5
17.00
519
0.13
0.00
1.00
0.05
0.00
5.0
7.3
0.15
Black Crappie
3.5
8.00
1145
0.05
0.00
1.30
0.07
0.25
5.5
3.3
0.10
SOURCE: CT DEP, 19814
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TABLE 3-29. WILDLIFE LIKELY TO OCCUR IN FRENCH RIVER
IMPOUNDMENT AREAS
Avifauna
green heron least flycatcher black and white warbler
Canada goose eastern wood pewee yellow warbler
mallard tree swallow chestnut—gided warbler
black duck bank swallow prairie warbler
wood duck rough-winged swallow ovenbird
red—tailed hawk barn swallow common yellow throat
American kestrel blue jay American redstart
ruffed grouse common crow house sparrow
ring—necked pheasant black—capped chickadee redwinged black bird
spotted sandpiper tufted titmouse northern oriole
rock dover white—breasted nuthatch common grackle
mourning dove house wren brown—headed cowbird
yellow—billed cuckoo mockingbird scarlet tanager
black—billed cuckoo gray catbird cardinal
great horned owl brown thrasher rose—br. grosbeak
belted kingfisher American robin indigo bunting
common flicker wood thrush purple finch
hairy woodpecker veery American goldfinch
downy woodpecker cedar waxwing rufous sided tawhee
eastern kingbird starling field sparrow
eastern phoebe red—eyed vireo swamp sparrow
song sparrow
Amphibians
newt spring peeper
spotted salamander grey tree frog
dusky salamander pickerel frog
red—backed salamander leopard frog
two—lined salamander wood frog
American toad green frog
Towler’s toad bull frog
Reptiles
snapping turtle garter snake
wood turtle ribbon snake
spotted turtle hognose snake
musk turtle ringneck snake
painted turtle black racers
red—bellied snake green snake
Delay’s snake king snake
water snake
SOURCE: Adapted from letter to New England Corps of Engineers from Fish and
Wildlife Ser. Ecological Service, Concord, NH, April 10, 1978.
-------
supports populations of freshwater mussels, snails, and crayfish which
are often prey for mammals such as mink, muskrat and otter. Not all of
the species listed may actually occur in the study area due to habitat
limitations such as space, food and cover.
No threatened or endangered species have been observed in the
vicinity of the French River (U.S. Army Corps of Engineers, 1981).
Threatened or endangered species are generally associated with rare
habitat types or have exacting requirements with respect to a host of
environmental factors. The habitat types around the French River are not
uncommon and no rare or endangered species have been found.
Sunmiary of Environmental Quality
The downstream segments of the French River have historically
received a large volume of industrial and domestic wastewater
discharges. These discharges have resulted in deteriorated water quality
with regard to DO and nutrient levels, and the accumulation of polluted
sediments downstream. Biological conditions in the downstream stretches
of the river are consequently stressed. A variety of actions have been
taken in the last 10 years to reduce the impact of wastewater discharges
on water quality, particularly with regard to eliminating industrial
discharges and upgrading the treatment at the municipal treatment
plants. More point source cleanup is planned for the next few years.
The sediment deposits, however, still remain, continuing to significantly
degrade environmental quality.
Recent water quality surveys conducted in 1982, 1981 and 1985 by
MDWFC indicate that the water quality in the French River is generally in
compliance with Class B standards during average or above—average river
flows. Some water quality problems still persist, particularly during
very low flows. Downstream of the wastewater treatment plant discharges
in Leicester, Webster and Dudley, in-stream nutrient levels rise,
stimulating the growth of aquatic plants. DO and fecal coliform
standards are also violated. Significant diel variations of DO have been
observed in these reaches, indicating the impact of significant plant
photosynthesis and respiration. Violations of the dissolved oxygen 5.0
mg/i Class B standard also occur consistently behind the dam at
Perryville MA; and less frequently at Wilsonville, North Grosvenordale,
3-86
-------
and Grosvenordale, CT. Accumulated sediments and sluggish flow in these
locations result in a high sediment oxygen demand. These factors are a
primary contributor to the low DO levels. In addition, the sediments in
the impoundments are significantly polluted with heavy metals and PPIH
compounds. These conditions cause the impoundments to fail to meet the
states’ water quality criteria (objectionable deposits, nuisance species)
and also inhibit any water based recreational uses.
As a result of the degraded water quality and contaminated
sediments, the aquatic biota in the downstream impoundments are stressed
and dominated by pollution tolerant organisms. Several of the
impoundments have evolved into significant wetlands habitats.
Socioeconomic Conditions and Recreational Resources
Introduction . The settlements in the French River Basin are
primarily in or adjacent to the river valley and are concentrated in
Dudley, Oxford and Webster. The towns or portions thereof in the basin
are Auburn, Chariton, Douglas, Dudley, Leicester, Millbury, Oxford,
Spencer, Sutton, and Webster, Massachusetts; and the Town of Thompson,
Connecticut.
Socioeconomic data is presented here for the Towns of Leicester,
Charlton, Oxford, Dudley, and Thompson. Socioeconomic data for the
remaining communities in the basin are not relevant to this study and are
not included in the baseline data. The land area of Auburn, Douglas,
Milibury, Sutton and Spencer is all upland, undeveloped, and distant and
unrelated to the river or its major tributaries, the Little River and
Mill Brook. Moreover, the land area of Auburn, Millbury, Douglas and
Sutton included in the basin is minimal.
Eighty-five percent of the basin is in Worcester County,
Massachusetts, with the southern part being in Thompson, Connecticut.
The geography, circulation pattern, topography and economy of Thompson is
similar to the Massachusetts region of the basin. Therefore, for clarity
and ease of comparison, socioeconomic data for Thompson will be compared
herein to that of Worcester County, Massachusetts and thus to the rest
of the basin, rather than to Windham County, Connecticut.
3-87
-------
Population . As is seen in Table 3-30, the population of the river
basin has increased steadily over the post-war period and is projected to
continue to grow, although not dramatically. (Less than two percent in
two decades.) LiLcewise, with the exception of Webster, the individual
cozmnunities have grown and all are projected to continue to do so,
although not all at an even rate.
The persons residing in the basin are generally younger than the
Worcester Standard Metropolitan Statistical Area (SMSA) or the County and
generally are less well educated. The indications are that the basin as
a whole has a young, growing, increasingly exurban population. However
Webster, a notable exception, has been aging. Median 1980 family incomes
ranged from $17,7l 0 in Webster to $21,l 46 in Leicester.
The population is not distributed evenly throughout the basin.
The major concentrations are in Dudley, Oxford and Webster. Oxford is
essentially a residential community today with small manufacturing
establishments. Webster is highly industrialized with several very large
firms. Leicester is a bedroom and college community with major
concentrations outside of the basin. The other communities have a few
small concentrations in the basin around public facilities and small
existing or defunct mills. The overall population density is low because
of the large amount of undeveloped land in each community, Webster again
being the notable exception.
Economic Resources . Agriculture is still the economic base of
Charlton and some agriculture, primarily orchards, continues in Dudley
and Oxford. However, the economic base of most of the basin is
predominately manufacturing. This is especially so in Dudley and Webster
in the river valley itself. Supporting the industries are trucking
enterprises and small retail uses such as pubs and used car sales. There
are also a number of active and abandoned sand and gravel operations in
the area.
Although agriculture has been the historical base of all towns in
the basin at one time, and although Charlton and Leicester have had mills
in the past and continue to have some manufacturing, only Dudley and
Webster are now manufacturing communities. Charlton, Oxford and
Leicester are considered residential communities in the Worcester area.
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TABLE 3-30. POPULATION CHARACTERISTICS OF FRENCH RIVER STUDY AREA
Age Charlton Dudley Leicester Oxford Thompson Webster
% under 5
% under 18
65 and over
Education
% completed high
school only
% completed college
Income
Median family income
Per capita
Race/Ancestry
8.2
32.5
9.4
42.6
12.3
5.9
30.6
10.6
35.2
14.2
6.5
28.8
9.5
39.8
13.8
8.2
32.2
8.6
39.8
11.0
6.6
29 . 4
11.7
32.4
10.4
5.8
26.5
16.4
30.6
8.5
$19,864
$20,668
$21,446
$19,798
$19,170
$17,740
5,966
6,529
6,389
6,190
6,601
6,291
%
White
99.6
98.6
98.8
99.2
99.2
98.6
%
Polish
8.8
34.6
8.7
7.1
5.6
34.9
%
French
32.1
19.9
17.7
32.1
20.1
22.5
%
%
English
Irish
19.5
9.4
10.4
9.5
22.5
17.9
16.9
14.5
7.7
3.6
6.4
8.2
SOURCE: U.S. Census, 1980.
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Almost half of the labor force in Thompson is employed in
manufacturing while Dudley and Webster have forty percent of employment
in manufacturing; Oxford has thirty percent in government and thirty-four
percent in manufacturing. Chariton has thirty-seven percent in retail
trade and only five percent in manufacturing. The older manufacturing
employment is primarily on the French River, affected by historical
dependence on water power. Newer plants are nearer Route 52 and its
interchanges. The older establishments are textile or textile related.
Newer plants are in machinery, plastics, chemicals and materials.
Unemployment in the area is low.
In Massachusetts, towns are limited financially by the constraints
of Proposition 2 1/2 which imposes a limit on local taxes on real and
personal property equal to two and one half percent of the fair cash
value of the property being assessed. These local receipts are
supplemented by state aid and some grant programs. Debt incurred by the
Towns is primarily for schools and utilities, as seen in Table 3—31.
Land Use . The area along the French River in Dudley, Oxford and
Webster is urbanized, as is the center of Webster and the area along Lake
Webster. There are a few large public areas, such as the BufTumville Dam
recreation area. The area is characterized by a great deal of vacant
land, ranging from seventy—four percent (including the Lake) in Webster,
to ninety percent in Chariton. Housing in the basin outside of Dudley,
Oxford and Webster is predominantly single-family, although there are a
limited number of apartment complexes. Table 3-32, derived from figures
from the Central Massachusetts Regional Planning Agency and the
Northeastern Connecticut Planning Agency, presents existing and projected
land use.
Leicester is increasingly becoming a bedroom community to
Worcester and most of its new development is expected in areas outside of
the basin. However, within the basin there are few constraints to
residential development.
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TABLE 3—31. MUNICIPAL FINANCE
19811 FIGURES
Leicester
Tax rate $12.82 $13.20 $18.75 $22.29 $27. i40 $16.79
Per Capita tax levy $21414.00 $216.00 $259.00 $310.00 $328.00 $285.00
Net debt - per capita -— $28.00(1) $25.00 $145.00 $3145.00 $555.00
Debt purpose - percent
Schools -- —- -— 79.2 79.3 83.7
Sewer -- 1 43 -- -— 26.7 10.14
Water -- -- 100 - - -— --
Department Equipment -- 57 - — -— —- 2.14
Other -- —- -- 20.8 -- 3.5
(1) 1983 Figure
SOURCE: Massachusetts Department of Commerce, 19814, except Thompson, Annual Report , 19814.
Chariton Dudley
Oxford Thompson Webster
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TABLE 3-32. LAND USE IN FRENCH RIVER STUDY AREA
1980 FIGURES
Chariton Dudley Leicester Oxford Thompson Webster —
Area in Square Miles 42.8 21.07 22.70 26.71 1 46.5 12.53
Land 1.10 0.90 1.82 0.68 1.1 1.97
Total 143.96 21.57 211.52 27.39 147.6 114.50
Approximate % in Basin 30 60 60 100 — 100
Density Per Square Mile 157 41 4 LM6 437 128 1,156
1975 Land Use:
Residential 677 797 1,183 1,085 1,805 1,163
Industrial 3145 93 376 360 248 164
Commercial 43 46 1414 83 160 96
Industrial 144 90 75 91 796 614
Streets 1,043 518 543 709 1,099 639
Other 25,982 12,517 13,472 15,202 3,429 7,1514
TOTAL 28,134 14,061 15,693 17,530 29,760 9,280
1995 Projected Land Use:
Residential 880 1,076 1,1420 1,356 1,337
Industrial 1483 177 4114 630 199
Commercial 52 53 48 95 101
Industrial 44 90 75 91 64
Streets 1,130 611 593 1,000 693
Other 25,545 12,054 13,1143 14,358 6,886
TOTAL 28,1314 114,061 15,693 17,530 9,280
% urbanized 10 16 19 22 26
% vacant 90 84 81 78 74
1. Thompson figures are for 1969.
Massachusetts Department of Commerce, 1984
SOURCE: Brown & Donald, 1969
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Chariton remains an agricultural community, but is experiencing a
slow growth in low density residential land use. Such growth is
anticipated to increase. In the basin there is little opportunity for
any other type of urban development because of soil and topographic
constraints and the lack of sewer and water utilities.
Oxford has had a substantial increase in multi-family housing as
well as an increase in single family development, including subdivisions
near the Hodges Village Dam. It is anticipated that Route 52 will
stimulate industrial development. However, there are limitations to
development of much of the vacant land: wetlands, aquifer areas to be
protected or severe topography.
Dudley also is growing as a residential community. Industrial
growth is anticipated in the present industrial area along the French
River. This area is well served with utilities and, except for wetlands
along the river, has little constraint to development.
Webster, the most urbanized community in the basin, has little
potential for development because of severe limitations on vacant land
due to topography and soils. However, developed areas which are served
with utilities can be intensified as facilities are being planned which
will adequately handle such growth. Areas adjacent to the Lake require
careful monitoring because of traffic, intensification of sewage, erosion
and sedimentation.
Thompson’s urban development is concentrated along both the French
and Quinebaug Rivers. Future residential development is anticipated to
be in subdivisions. There is very little suitable land for urbanization
and for the most part it is outside the basin and outside the area served
by utilities.
Dudley, Oxford and Webster have municipal water systems dependent
on ground water sources. The Water Districts in Leicester and individual
wells in Charlton are similarly dependent.
Archaeological and Historic Resources . A walkover reconnaisance
survey of archeological resources was conducted in the study area in
July, 1985. (Environmental Archaeology Group, 1985.) The purpose of the
walkover was to observe the remains of prehistoric or historic sites that
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might be visible on the surface and to refine the topographic and
geological information that was initially obtained from maps. This
information is necessary in order to assess the likelihood that sites
exist on a parcel which are not recorded in the files of the Historical
Commissions, and to identify and assess the extent of cultural
disturbances of the land surface that obviate the need for future
archaeological subsurface testing, should a subsequent stage of
investigation be required.
All surface observations made during the walkover, including site
location, surface disturbance and modification of the landscape were
recorded in field notes and field maps. Also, soil types were identified
in the field with the aid of soil conservation maps of the region. The
field work also involved close examination of eroded shorelines,
footpaths and roadcuts for exposed subsurface artifacts; examination of
rodent burrows backdirt; examination of the bases of standing trees for
the presence of artifacts cast up to the surface by root growth; and
examination of’ the root-mat earth of fallen trees that might expose
subsurface artifacts. In addition, numerous suspect surfaces were
lightly scraped with trowels to expose artifacts that might be buried at
shallow depths. The following is a summary of archeological resources in
the study area.
The Buffumville Reservoir area contains a limited variety of
cultural resources. There are 16 stone walls that were constructed along
the shores of the north and south lakes during the nineteenth century.
Other historic resources consist of a possible Federal Period (A.D. 1775
to 1830) mill pond levee or breakwater, a possible Contact Period (A.D.
1500 to 1630) road, and an early twentieth century town boundary marker.
One prehistoric site is known and another is reported on the
shores of the north lake; their surface remains, however, are not evident
at present. Also, there are 33 potential locations of buried prehistoric
sites on the shores of both north and south lakes of Buffumville
Reservoir.
The Perryville Pond area contains a wider variety of historic
cultural resources. These consist of a nineteenth—century stone wall; an
Early Industrial Period (A.D. 1830 to 1870) railroad bed; the ruins of a
3...9!
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late industrial period (A.D. 1870 + 1915) mill and millpond, a late
nineteenth-century bridgehead or breakwater; and a twentieth—century
railroad storage crib. Also, there are nine potential locations of
buried prehistoric sites on the banks of this river impoundment.
The Langer’s Pond study area contains several historic cultural
resources. These consist of another segment of the Industrial Period
railroad bed; a Late Industrial Period railroad bridge; a mill and
millpond of the same era; a mill flow levee of similar age; and an early
nineteenth century house lot with standing privy. No potential locations
of buried prehistoric sites exist in this sector of the project area.
The North Grosvenordale Pond study area contains a number of
historic cultural resources. Preeminent among these is the early
Industrial Period Textile Mill No. 2 with its millpond dam. This mill
may be eligible for nomination to the National Register of Historic
Places. The foundation of a demolished railroad station from the same
period also exists there as does another segment of the railroad bed and
a levee by the railroad embankment. Ten stone walls of the same era are
located in the vicinity. More recent historic resources include a turn-
of-the-century domestic trash dump and the ruins of an early twentieth-
century Boy Scout Camp. Although no prehistoric sites are evident on the
banks of North Grosvenordale Pond, a 1.5 kilometer length of shoreline
contains several potential locations of buried aboriginal sites.
Based on the reconnaissance, the Massachusetts Historical
Commission has requested that prior to initiation of the proposed
remedial activities, “an intensive survey (950 CMR 70) be conducted in
order to locate and identify archaeological properties within the areas
of project impact.” Such an intensive survey would be conducted
concurrent with preparation of a Section )4Q)4 permit application.
Recreational Resources and Uses of the River . The French River
study area has several forest reserves and multi-use recreation areas in
addition to the parks and playgrounds maintained by the individual
communities and the private facilities on Lake Webster. Buffumville Lake
has facilities for boating, fishing, swimming, and picnicking. Hodges
Village Dam has a picnic area, athletic fields and snowmobile trails.
Table 3-33 presents the existing uses of the French River and its
3—95
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TABLE 3-33. EXISTING USES OF THE
FRENCH RIVER AND IMPOUNDI4ENTS
River Segment Use
Leicester wildlife habitat
Oxford/Charl ton industrial processing
boating
picnicking
hiking
hydro.-electric power
water skiing
wildlife habitat
Dudley/Webster industrial processing
boating
hydroelectric power
wildlife habitat
Thompson industrial cooling
boating
wildlife habitat
adjacent lands. Use of the river in Leicester is primarily limited to
wildlife habitat. In Oxford/Charlton, there are large areas of privately
held and public open space, especially around Hodges Village Darn and
Buffumville Lake. These impoundments, designed as flood control
structures, provide ample opportunity for recreational use of the river,
with picnicking, fishing, and hiking trails at both facilities as well as
boating, water skiing, swinuning and fishing at Buffuinville and hunting,
snowmobile trails and athletic fields at Hodges Village. The Buffumville
site attracts over 116,000 visitors a year. Trends show that the park is
becoming attractive more for its passive recreational opportunities than
its active recreation.
There is some recreational use of the river for canoeing in Oxford
arid Dudley/Webster, however, it is limited due to the river’s water
quality, sediment buildup, and the presence of the wastewater treatment
plants. The dams are of a general interest because of the materials used
to construct the dams as well as the locations of the dams. There is use
of the river for industrial processing and hydroelectric power in this
area •
3—96
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In Thompson, land adjacent to the river is primarily vacant. This
portion of the river is little used for recreation due to problems of
access and water quality. Rail lines encroach upon two of the
impoundments and adjacent land is primarily in private ownership. The
dams act as barriers to free use of the river for boating. Moreover,
wastewater treatment plants approximately one mile upstream in Dudley and
Webster act to deter intense recreational use of the river. There is
some use for industrial cooling and hydroelectric power. Table 3 3It
presents, in matrix form, the desired and designated uses for the French
River and factors restricting implementation of these uses. The desired
uses for the river as it flows through Thompson were derived from the
Thompson Plan of development, Northern Connecticut Regional Planning
Agency reports, the French River/Oxoboro River Impoundments Study,
Connecticut State Water Quality Standards, and discussions with local
officials. The desired uses for the remaining segments were derived from
Massachusetts State Water Quality Standards, reports of the Central
Massachusetts Regional Planning Commission, Town plans, and discussion
with local officials.
State water quality standards call for the River to meet Class B
water quality in both states. A Class B quality level would permit the
use of the river for fish, aquatic life and wildlife habitat; primary
contact recreation (e.g., swimming, water skiing); secondary contact
recreation (e.g., boating, fishing); agricultural uses; certain
industrial processes and cooling; and aesthetic enjoyment.
Local and regional plans stress use of the French River for
recreational purposes. The 1969 Charlton Master Plan called for setting
aside areas around the Buffumville reservoir and along the Little River
for open space and recreation. The Thompson plan of development, 1970,
called for expansion of open space along the River and upgrading of
swimming opportunities at North Grosvenordale.
The Central Massachusetts Regional Planning Commission (CMRPC)
report, Regional Qpen Space and Recreation Plan (1972), assessed regional
open space and recreation needs. The Plan recommended a series of
regional recreational areas serving more than one community and gave high
3-97
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hiking
swimming
boating
fishing
agricultural uses
industrial pro-
oessing/coo llng
habitat
aesthetic value
0
0
0
0
0
0
0
0
0
Availability of
Alternative Nearby
Facilities
hiking
swimming
boating
fishing
agricultural uses
industrial pro-
cessing/cooling
habitat
aesthetic value
hiking
swimming
boating
fishing
agricultural uses
industrial pro-
cesslng/cool lng
habitat
aesthetic value
hiking
Sw imining
boating
f’ I sh 1 ng
agricultural uses
Industrial pro-
cessing/cooling
habitat
aesthtlc value
0
0
0
0
0
0
• severely restricts attainment of desired/designated use
o may restrict attainment of desired/designated use
•
TABLE 3_3i4. FACTORS RESTRICTING ATFAIN NT OF DESIRED
AND DESIGNATED USES OF THE FRENCH RIVER
Factor Restricting Attainment
Uver Segment Use Access Water Quality Coat Parking
eicester
•
Utilities/ Physical
Facilities Factors
)xford/Charlton
udley/Webster
hompson
• 0
0
• 0
0
• • •
• • •
• • •
• I
I
I
I
I
I
I
I
.
I
•
• I •
• •
-------
priority to preservation of land along the river through Leicester and
Oxford and into Webster. The Plan also gave high priority to
preservation of open space along the Buffuinville Reservoir. A
recommendation for the acquisition of, or the purchase of, easements to
land along the river was included along with plans for establishment of
walking trails.
The Northern Connecticut Regional Planning Agency (NCRPA) report,
Open Space and Recreation , studied the regional open space and recreation
needs for northeastern Connecticut. The Plan recommended that each town
in the region provide balifields, tennis courts, municipal swimming
pools, public golf courses, and other recreational opportunities for
their residents. Further, it noted that the Town of Thompson required a
39.5 percent expansion in open space.
The NCRPA also studied the recreational potential of North
Grosvenordale Pond and Langer’s Pond. The 1980 study analyzed existing
recreation needs for the areas surrounding the ponds and assessed the
potential of the pond to meet these needs. The study determined that
public access to the ponds was almost non-existent: the land surrounding
Langer’s Pond was divided into several privately owned parcels and road
access was restricted to one entrance point (NCRPA, 1980). Land around
North Grosvenordale Pond was also in private ownership; however, most of
the land on the western side belonged to a single owner and road access
was not as restricted as that to Langer’s Pond. (EPA, 1982). The study
recommended a three phase plan to improve recreation at North
Grosvenordale Pond. Phase one would involve low cost actions
(installation of picnic tables, hiking trails) while phase two would
involve improving access and installing higher cost facilities: the
final phase would involve improving water quality (dredging sludges) and
installing additional facilities (NCRPA, 1980).
A Master Plan for Recreation Resources Development was produced by
the Army Corps of Engineers for Hodges Village Darn in 1980. The plan
notes that the Dam, originally conceived solely for flood control
purposes, has evolved from an undeveloped natural habitat surrounded by a
rural town into a multi-use recreation and flood control facility and
3-99
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suburban community park providing numerous recreation opportunities as
well as flood protection. The plan recommended the construction of two
multiuse courts, a softball field, a soccer field, a basketball court, 10
picnic sites, access road relocation, paved parking areas, a utility
building, playground and landscaping as well as the development of trails
between the Greenbriar Recreation area and Hodges Village Dam.
The Army Corps of Engineers developed a Master Plan for Recreation
Resources Development at Buffumville Reservoir in 1976. The plan
recommended construction of foot trails, upgrading and expansion of
picnicking facilities, regrading of the beach bottom, improvement of boat
ramps, and the restriction of access to certain environmentally sensitive
areas. The plan also noted a shift from use of the reservoirs for active
recreational opportunities (swimming, boating, and fishing) to its
passive recreation opportunities (picnicking and sightseeing).
At present, the significant factors limiting attainment of desired
or designated uses in the French River are access problems, existing
water quality, parking, and availability of nearby alternative
facilities. Also important are cost and physical factors.
Access to the river is limited because much of the land is in
private ownership or committed to use. This may not pose a serious
problem in Leicester, Chariton and Oxford where there is considerable
open space along the river, but much of the land along the river in
Dudley and Webster has been committed to urban uses. In Thompson, much
of the land along the river is held in small, privately owned parcels and
there are few points of entry; a rail line encroachs on frontage along
two impoundments and road access is poor.
Parking as a limiting factor is related to the issue of access.
To permit enjoyment of the river, parking must be provided. However,
with much of the land in private ownership or committed to use, it is
difficult to provide adequate parking facilities.
The existing water quality does not significantly impact use of
the river in Leicester, Oxford or Chariton. Water quality does, however,
limit use of the river for swimming, boating and fishing in Dudley,
3—100
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Webster, and Thompson. It also impacts the ability of that portion of
the river to support fish and aquatic wildlife, as well as the river’s
aesthetic appeal.
Cost as a limiting factor relates to acquisition and development
costs for enjoyment of the desired or designated use. Trails would have
to be cleared for hikers and launching ramps constructed for boaters.
Presently, there are limited facilities for boaters.
The availability of nearby alternative facilities also affects use
of the river for desired or designated uses. There are alternative
facilities available in both States. In Massachusetts, Lake Webster
provides swimming, picnicking and fishing opportunities. In Connecticut,
the Quinebaug River provides an alternative to the French River. In
addition, there are numerous lakes and ponds in the region.
Physical factors limiting the use of the river are water depth,
river width, and the dams. The depth and width of the river as it flows
through Leicester and north Oxford does not easily permit its use for
swimming and boating. The shallow depth and mucky bottom of the
impoundments in Dudley, Webster and Thompson limit the recreational use
of this portion of the river, and its ability to support fish and
wildlife. The nuisance species and contaminated sediments reduce
aesthetic appeal and impede entry into the river by sports enthusiasts.
The dams, to some extent, act as barriers to boating.
The Army Corps of Engineers has granted a license to the
Massachusetts Division of Fisheries and Game to manage the Hodges Village
Dam and Reservoir site for fish and wildlife purposes through October,
1987. The license does not exclude use of the site for the desired
recreation listed above, but it does stipulate that the water and land
use at the site must be approved by the Department of the Interior, the
Corps of Engineers and the state wetlands agency. The license permits
the State to construct necessary facilities, but does not permit it to
charge the public for use of’ the reservoir for swimming, bathing, fishing
and “other recreational purposes”.
3-10 1
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The Corps has also licensed management of Buffumville Reservoir to
the Department of Environmental Management for a public park, recreation,
fish and wildlife management, and forest management. The license runs
through June of 1989. As with the Hodges Village license, the license
does not exclude use of the site for the desired recreation listed above,
but it does stipulate that use of the site must be approved by the
Department of the Interior, the Corps of Engineers and the state wetlands
agency. All uses must be developed in accordance with the Master Plan
for the site (see above) and cannot adversely impact on resources in the
site.
Institutional and Regulatory Framework
Any alternative implemented for cleanup of the French River must
be in conformance with applicable local, regional, state and federal
plans, laws and regulations. A brief discussion of applicable regulatory
constraints is presented below.
Town Plans . Except for the Town of Oxford, local master plans are
either non-existent or outdated. The Leicester Master Plan was prepared
in 1971 and recommended maintenance of the town’s suburban residential
character. The future land use and development plan called for Leicester
to remain predominantly a rural and low density residential town with a
generous amount of recreation and open space, most of which is in the
northern part of the town. The Plan has not been revised.
The Charlton Comprehensive Plan, prepared in 1969, was never
officially adopted or presented to the town by the Planning Board. The
Plan called for, among other items, the adoption of strict development
standards and preservation of natural resources. The future land use
plan called for public open space and recreation along Pikes Pond, the
Little River and the Buffumville Reservoir. The Plan has not been
updated.
The Oxford Land Use and Development Plan, 1985, the only up-to-
date plan in effect, suggests that Oxford contains much environmentally
sensitive land which requires protection from poorly designed
development. The plan recommends adoption of land use controls to
3—102
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protect the aquifer beneath the French River along with Scarappa Pond for
sources of freshwater. The future land use plan recommends a
conservation district in flood control areas.
The Thompson Plan of Development, prepared in 1970, recommended
expansion of the open space along the French River and upgrading of the
swimming area in North Grosvenordale. Master plans for the remaining
towns were not available.
Town Zoning and Land Use Bylaws . Town land use bylaws will be
relevant to the extent that they regulate development along the river and
its impoundments and to the degree that they control the potential
dredging and deposition of materials from the impoundments. Each
community in the study has adopted zoning to varying extents, however,
local zoning will not affect implementation of alternatives under
consideration.
In addition to zoning bylaws, municipalities within the basin have
adopted other land use control bylaws. Thompson has adopted an Aquifer
Protection Program to protect present potential sources of municipal
water supply as well as primary and secondary recharge areas. The
Program prohibits the large scale use and/or storage of hazardous
materials and the disposal of industrial or commercial effluent into
surface or ground water without the necessary permits from the
Connecticut Department of Environmental Protection (DEP). Once the
necessary DEP permits are issued, the applicant must apply for a special
permit and submit a site plan and report to the Town Planning and Zoning
Commission detailing the amount and composition of industrial or
commercial wastes and proposed method of disposal and/or the amount and
composition of hazardous materials to be handled, transported, stored or
discharged to the air or to the ground at the site. The Commission has
sixty-five days in which to approve, modify or deny the site plan.
Thompson has also adopted the State law requiring a sediment and
erosion control plan for all projects disturbing more than one-half acre
of land, except for single family dwellings not within a subdivision.
3-103
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Town Wetlands and Floodplains Restrictions . Leicester has adopted
a wetlands bylaw similar to the Massachusetts Wetlands Protection Act.
It regulates by permit the removal, filling, dredging or alteration of
any area within one—hundred feet from any stream, pond or land under said
waters, or any land subject to flooding. The bylaw is administered by the
Conservation Commission, which is empowered, by a 2/3 vote, to deny any
permit.
Thompson has adopted regulations to administer the Connecticut
wetlands law. The regulations, administered by the Conservation
Coninission, permit among other uses grazing; farming; nurseries;
residences; boat anchorages/moorings; dams and impoundments operated by
water companies and municipal water supply systems; soil and wildlife
conservation; and recreation. Other uses which involve the removal
and/or deposition of material, construction within, or the alteration and
pollution of inland wetlands and water courses, require a permit from the
Commission. Persons proposing any use within a wetlands or water course
must submit information on the type and location of’ activity and its
purpose. The Commission then determines if it is permitted or regulated;
if the action is a permitted use, it may proceed. If the action is a
regulated use with no significant impact, a public hearing may be held
and the Commission may permit it to proceed with conditions. If the
regulated use will have a significant impact, the Commission must request
additional information including a site plan and biological evaluation; a
public hearing is held between thirty and sixty-five days of submittal of
the application and a permit is either approved with conditions or
denied. Appeals may be brought before the Court of Common Pleas for
Windham County. The State Commissioner of’ Environmental Protection
retains regulating jurisdiction over the construction and modification of
dams, the construction or placement of any obstruction within navigable
waters, and discharges into waters of the State, among other activities.
All municipalities along the river have adopted floodplain zoning
to varying degrees. Some communities have enacted separate ordinances,
other have merely included floodplain protection in their zoning by
reference to the Federal Flood Insurance Studies. The floodplain extends
3-1 O1
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to varying widths along both sides of the entire length of the river.
Local floodplain ordinances restrict development within the flood plain
primarily to uses that will not call for sustained human occupancy and
require permitted development to be constructed to flood proof standards.
Riparian Rights . Important at the local level is the doctrine of
riparian rights which relates to the water rights of land owners abutting
a body of water. Each owner (riparian) has a co —equal right to
reasonable use of an indefinite quantity of water, even if such use
results in alteration of quantity or quality (MacGregor, 1981); riparians
do not have ownership rights to the water (I3euscher, 1967). The concept
of “reasonable use” depends on many factors, (e.g., size of the river,
water velocity, importance of use) (MacGregor, 1981). Riparian issues
are important locally in regard to hydroelectric power plants along the
river and to the landowners abutting the proposed cleanup areas.
Water Quality Plans and Regulations . The Areawide Water Quality
Management Plan , prepared by the Central Massachusetts Regional Planning
Commission (CMRPC) in 1979, addressed water quality issues and provided
recommendations for improving water quality in those French River Basin
communities in Massachusetts. In general, the Plan recommended that
communities revise their subdivision bylaws to control stormwater runoff
and implement sewer maintenance programs. The Plan also recommended that
there be a study to determine if dredging and/or removal of sediments in
Perryville Pond is warranted.
The Federal Water Pollution Control Act Amendments of 1972 and
subsequent amendments of 1977, (also known as the Clean Water Act) set a
national goal of elimination of discharge of pollutants into navigable
waters by 1985. An interim goal of water quality which provides for the
protection and propagation of fish, shellfish, and wildlife and provides
for recreation in and on the water was to be achieved by July 1, 1983.
In order to achieve these goals, the act stipulated that “publicly owned
treatment works” were to achieve secondary treatment, as defined by the
Administrator of the United States Environmental Protection Agency (EPA),
by July 1, 1977.
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In addition to the above technology based limitations, the Clean
Water Act recognizes a need for more stringent effluent limitations on
discharges into some bodies of water in order to preserve or improve
their quality. These “water quality” limitations are based on standards
set by the states for individual stream segments, based on careful study
of the stream segment affected, and are subject to public review and
approval by the EPA.
The MDWPC, in conjunction with the EPA, has established that the
French River is water quality limited. That is, advanced wastewater
treatment must be provided to wastewaters discharged to the river.
Accordingly, the wastewaters which are discharged from Webster and
Dudley must conform to the effluent limitations set by U.S. EPA for the
French River. These limitations have been established in the form of
NPDES permits issued to the two towns. The effluent limitations in the
Webster permit and the Dudley permit, as discussed in the point source
discharges section of this report, are identical. Each permit assumes
that joint advanced treatment, in conjunction with low flow augmentation,
will be implemented, resulting in a discharge at only one of the existing
plant sites.
Massachusetts General Laws and Regulations . The Massachusetts
General laws relating to potential water quality improvement alternatives
under investigation are lengthy and involve complicated administrative
procedures.
The Massachusetts Environmental Policy Act (MEPA), Chapter 30,
Section 61, MGL, is administered by the MEPA Unit in the Executive Office
of Environmental Affairs (EOEA). The Act requires the examination of
environmental impacts of State actions, broadly defined to include
permits, approvals and funding, in the form of an Environmental Impact
Report (EIR). Proponents of projects requiring State action submit an
Environmental Notification Form (ENF) to the t4EPA Unit for publishing in
the Environmental Monitor which is circulated to a number of State
agencies and, upon request, to the public. A twenty day comment period
is observed. Within thirty days of publishing, the Commissioner of EOEA
reviews the proposal and site plans and determines if an EIR is
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required. If an EIR is required, the Commissioner will issue a scope,
identifying issues to be addressed in the EIR. A Draft EIR is prepared
and circulated for comments. These comments are addressed in a Final
EIR. Where a Federal Environmental Impact Statement (EIS) is required,
the EIS may be substituted for the EIR.
Not all State actions require the preparation of an EIR; some
actions are categorically excluded. Projects involving any of the
following aspects will require the preparation of an EIR: dredging or
disposal of more than 10,000 cubic yards of material; licenses for the
structural alteration of dams to effect; more than a 20 percent
increase/decrease in impoundment capacity; filling, dredging,
constructing, rip-rapping or direct alteration of more than 500 feet of
waterway bank; any landfill within a half—mile of a public ground water
supply or within the watershed of a public surface water supply; any new
nonresidential construction project entailing direct alteration of more
than fifty acres of land; any project requiring of alteration of ten or
more acres of land subject to Ch. 131, Sect. 140, (The Wetlands Protection
Act; see below); stream channelization or relocation of two—thousand feet
or more; new impoundments of one billion gallons or more; sites for
disposal of hazardous wastes.
The Massachusetts Wetlands Protection Act, Chapter 131,
Section 40, MGL, regulates any activity, including draining, dredging,
dumping, damming, discharging, excavating, filling or grading in or
within one hundred feet (the buffer zone) of an inland or coastal
wetland. The Act is administered locally by the municipal conservation
commission, and at the State level by the Division of Wetlands Protection
in the Department of Environmental Quality Engineering (DEQE). Project
proponents must file for all local permits before submitting a Notice of
Intent (NOl) with the Conservation Commission. An abbreviated NOl is
available if the project is within the buffer zone or land subject to
flooding, will disturb less than one thousand square feet of surface
area, and will not require U.S. Army Corps of Engineers or DEQE Division
of Waterways permits. A public hearing is held within twenty-one days of
submittal, after which, the Conservation Commission has an additional
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twenty-one days in which to issue, issue with an Order of Conditions
(Order), or deny a permit. The Conservation Commission may issue an
order for a project resulting in a loss of up to five thousand square
feet of bordering vegetated wetlands if the wetlands are replaced.
Appeals from a Conservation Commission action are brought to DEQE.
For projects involving an overriding community need and for which
there are no reasonable conditions or alternatives that would allow the
project to proceed, and which include mitigating measures, the
Commissioner of DEQE may issue a variance after an adjudicatory
hearing. The request for variance must be sent by certified mail to the
Commissioner along with information describing the project and
alternatives, a description of mitigating measures, and evidence of
overriding public interest. The Commissioner must act within twenty-one
days of receipt of the request.
The Massachusetts Clean Water Act, Chapter 21, Sections 26—53 MGL,
is administered by the Division of Water Pollution Control in DEQE. The
Act regulates water quality through a multi-faceted regulatory process of
water quality standards, effluent limitations, and permits. The French
River has been classified as Class B and designated for use for
propogation of fish and wildlife and primary and secondary recreation.
To achieve! maintain this standard, the Act establishes effluent
limitations and requires a National Pollution Discharge Elimination
System (NPDES) permit for discharge of pollutants into waters of the
Commonwealth. Both “discharge” and “pollutants” are defined broadly
enough to cover almost all type of activity and material, however,
discharges of dredged or fill material otherwise regulated under Section
14014 of the Federal Clean Water Act are exempt. Project proponents must
file with the State and EPA. The approval process is lengthy and
complicated.
The Waterways License and Permit Program, Chapter 91,
Section 12—23 MGL, regulates construction, dredging and filling in rivers
and streams for which public funds have been expended. The Program is
administered by the Division of Waterways within DEQE. Project
proponents submit an application and a plan stamped and signed by a
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professional engineer or land surveyor registered in Massachusetts after
obtaining an Order of Conditions in relation to the Wetlands Protection
Act. Public notice must be given and a hearing may be held at the
discretion of DEQE. The license must be recorded in the Registry of
Deeds and a license from the U.S. Army Corps of Engineers is required
before construction may begin. After construction is complete, a
Certificate of Compliance is issued.
The collection, transportation, storage, treatment, use or
disposal of hazardous waste requires a license from the Division of
Hazardous Waste in DEQE (Chapter 2lc MGL). Project proponents seeking to
transport hazardous waste material must file for a temporary generator
permit and transportation of the materials must be handled by a State
licensed transporter. Disposal plans must be approved by the Division
engineers and site assignment must be approved by the local board of
health (Chapter 11, Section 150B). However, if the material is moved
around on the same site (broadly defined in the State Law to include the
same community), the State hazardous waste regulations concerning
transportation do not apply. If the material is found not to contain
designated hazardous material, but does contain potentially hazardous
material, the wastes must be dewatered and a plan of disposal submitted
for approval. Detailed records must be kept.
Chapter 111, Section 150A regulates the disposal of wastes in
sanitary landfills and gives local boards of health site designation
authority for privately owned/operated facilities; DEQE is given site
designation authority for facilities owned/operated by an agency of the
State. Landfill facilities cannot be located in wetlands, floodplains or
areas subject to flooding, unless the facility will not significantly
affect the flood storage capacity of the area, there is no other site
available, and the use of wetlands is insignificant. Owners of’ landfills
must pay a disposal fee to the municipality in which the facility is
located at a rate of fifty cents per ton of waste from outside the
municipality in which it is located. Facility plans and designs are
subject to approval by DEQE after a public hearing. Disposal areas must
be covered daily and debris and fire hazards controlled.
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Connecticut General Laws and Regulations . Connecticut laws
relating to the water quality improvement alternatives under
investigation are found primarily in Title 22A of the Connecticut General
Statutes.
Section 207 of Title 22A regulates the construction and operation
of solid waste disposal areas. Facility plans and designs must be filed
with and approved by the Commissioner of the Department of Environmental
Protection (DEP) before a permit to construct or a permit to operate can
be issued. Notice of an application for such a permit is published in a
local newspaper and a public comment period of thirty days is observed,
after which a public hearing may be held. A closure plan must be filed
and approved. There must be a 60 inch clearance between the base of the
disposal area and the maximum high groundwater level or bedrock. A
groundwater monitoring system must be installed and water quality cannot
be impaired. Hazardous wastes cannot be disposed of in a solid waste
disposal area.
Under the authority of Section 3 2 of Title 22A, the Commissioner
of DEP is empowered to establish stream encroachment lines along inland
waterways and flood prone areas considered for stream clearance, channel
improvement or any form of flood control/flood alleviation measure. No
encroachment or obstruction is permitted beyond these lines without a
permit from the Water Resources Division of DEP. Permits are issued only
after review of the project’s effect on the flood carrying and water
storage capacity of the waterway and flood plains, hazards to life and
property, and the protection and preservation of the natural resources
and ecosystems of the area. Stream encroachment lines have been set for
the French River in Thompson south of the North Grosvenordale impoundment
between Sunset Hill Brook and the Cluett Peabody Dam.
Section 361 of Title 22A regulates the erection of structures and
incidental work within navigable waters of the State. The law prohibits
the erection of structures, the placement of encroachments, and dredging
without a permit from DEP. The DEP may place conditions upon said
permit.
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The Connecticut Water Pollution Control Act, Section ‘4l6- 17l of’
Title 22A, is administered by the Water Compliance Unit in DEP and
regulates water quality in the waters of the state. It establishes water
quality standards and criteria. The French River, as in Massachusetts,
is classified as Class B and designated for bathing and other recreation,
agricultural uses, industrial processes, fish and wildlife habitat, and
is expected to provide good aesthetic value. The Act requires a permit
for discharges of water, substance or material into the waters of
Connecticut. Notice of applications for such a permit is published in a
local newspaper and a thirty day comment period is observed before the
Commissioner of DEP may act. A permit may be approved, disapproved with
conditions, or denied.
Chapter 1 0 (Section 36) of Title 22A regulates development in or
near wetlands. This section is administered at the state level by DEP
and locally by municipal conservation commissions.
In addition to the Federal hazardous waste laws as administered by
the U.S. EPA, the Connecticut State Hazardous Waste Management
Regulations, Title 25—5’4cc(c), establish a manifest system with detailed
record keeping requirements and require compliance with hazardous waste
facility standards and permit requirements by generators who treat,
dispose of, or store wastes on-site for 90 days or more. Hazardous
wastes must be treated at a facility with a valid permit. No permit is
required for onsite accumulation of wastes for 90 calendar days or less,
but packaging, storage and inspection requirements must be met.
Transportation of hazardous wastes must be by licensed transporters.
Owners or operators of new facilities must file a groundwater monitoring
plan with the permit application and a closure plan must be prepared for
approval by the Commissioner of DEP.
Section l4la of Title 26 of the Connecticut General Statutes
relate to minimum flow standards for certain rivers and streams and is
administered by DEP.
A bill has been filed in the Connecticut legislature to provide
for the dredging of the North Grosvenordale and Wilsonville impoundments
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in Thompson. The work is contingent upon completion of’ wastewater
treatment facilities in Dudley and Webster.
Federal Laws . At the Federal level, laws relevant to the
alternatives under investigation are administered primarily by the Army
Corps of Engineers (ACE) and the Fish and Wildlife Service (FWS). Under
the authority of Section 1 0I of the Clean Water Act, ACE issues permits
that control the discharge of dredged and fill material into waters of’
the United States arid their adjacent wetlands. Under Section the
impact of dredge and fill projects must be evaluated in terms of
compliance with EPA environmental regulations (I4OCFR Part 230) and in
terms of the public interest, including such factors as flood control,
navigation, recreation, water supply and environmental and socioeconomic
concerns.
The collection, transportation, storage, treatment, use or
disposal of hazardous wastes is regulated by the Resources Conservation
and Recovery Act (RCRA). In Massachusetts, EPA has authorized the State
to administer these Federal hazardous waste laws. In Connecticut, these
Federal laws are currently administered by EPA.
Executive Order 11988 and Executive Order 11990 signed by
President Carter in 1977 control development in floodplains and wetlands,
respectively, by requiring a written justification for all Federal
projects including a statement that the action conforms to applicable
state/local flood plain and wetland standards. All significant impacts
must be addressed through mitigation measures; only unavoidable and
insignificant impacts are permitted. Executive Orders are directives
issued by the President to Federal agencies.
The Fish and Wildlife Coordination Act gives the FWS review status
when the waters of any stream or other body of water are proposed or
authorized to be impounded, diverted, deepened or otherwise controlled or
modified. Under the Act, any person may request a public hearing.
The National Historic Preservation Act (NHPA) protects and
maintains buildings, sites, districts, structures and objects of local,
state or national significance in American history, architecture,
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archaeology and culture. In order to be protected by this act, the site
or structure must be registered in the National Register of historic
places. Under Section 106 of the NHPA, a federal agency is responsible
for identifying National Register properties and for assessing the impact
of any federal action on them.
The Archaeological Resources Protection Act protects archeological
resources and sites which are on public lands and Indian lands. Under
this act an individual must apply to the Federal land manager for a
permit to excavate or remove any archeological resource located on public
lands or Indian lands and to carry out activities associated with such
excavation or removal.
The Endangered Species Act provides a means of conserving species
of fish, wildlife and plants which are threatened with extinction and the
ecosystems upon which these species depend. The U.S. Fish and Wildlife
Service has jurisdiction and responsibility for terrestial and fresh
water species. Section 7(a) of the Act requires Federal agencies such as
EPA to ensure that actions they authorize, fund or carry out are not
likely to jeopardize the continued existence of endangered or threatened
species.
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thapter 4
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CHAPTER 14
IMPACTS OF ALTERNATIVES
Introduction
After an initial screening of proposed water quality improvement
alternatives for the French River, four of these options were selected
and studied in further detail (see Chapter 2). These alternatives, all
of which assume advanced wastewater treatment at the proposed Webster—
Dudley treatment facility, are: 1) no action; 2) low flow augmentation at
Buffumville Lake; 3) sediment control at Perryville, Wilsonville and
North Grosvenordale impoundments; and 14) instream aeration at Perryville,
Wilsonville, and North Grosvenordale impoundments.
Various impacts of these improvement alternatives were examined
during the conduct of this EIS. Each alternative is expected to have a
long-term positive impact on dissolved oxygen concentrations in the
French River. The water quality model presented in Chapter 3 (STREAM 7B)
was used to assess dissolved oxygen impacts due to each alternative
during extreme low flow conditions. STREAM TB was used as a tool to
examine the relative impacts of various alternatives, although it is
difficult to predict the exact impact which each alternative will have on
dissolved oxygen concentrations. It should be noted that some
alternatives may exert a short—term negative impact on water quality
during the introductory stages of implementation. While decreased toxics
and sediment oxygen demand would impact biological communities
positively, the implementation of these improvement alternatives may also
exert negative biological impacts such as loss of habitat due to
excavation or impaired water quality due to sediment resuspension during
dredging. Other areas of impact include socioeconomic, historic and
archaeological, and recreational resources.
Impacts of the No Action Alternative
General . At the time of preparation of this EIS, a facilities
plan for advanced wastewater treatment at a consolidated Webster-Dudley
i t—i
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treatment plant had been accepted by the Commonwealth of Massachusetts
and EPA, and EPA had approved funding eligibility for the proposed
treatment plant. The towns of Webster and Dudley will regionalize their
treatment facilities, as this was determined to be the most cost-
effective means to provide advanced wastewater treatment (AWT) to both
towns. Thus, the water quality improvement alternative of No Action
assumes implementation of advanced wastewater treatment at Webster-
Dudley. The NPDES permit for the Webster-Dudley assumes a monthly flow a
6 mgd and sets seasonal limits of 10 mg/i for average BOD 5 , 2 mg/i for
average NH 3 -N and 6 mg/I. for dissolved oxygen. While it is expected to
substantially improve water quality in the river, the No Action
improvement alternative of advanced wastewater treatment will not be
sufficient for dissolved oxygen levels in certain portions of the river
to comply with the Class B water quality criterion of 5.0 mg/i during
conditions of’ 7Q10 low flow and zero net photosynthetic oxygen
production. As part of the evaluation for the No Action alternative, the
impact of various AWT effluent flow rates was evaluated, including flows
of zero, 3.25, 14.5 and 6.0 mgd. Flows of 3.25 mgd and 24.5 mgd represent
existing flow estimates from 1985 monthly average flows and from the
average weekday flow estimated in the Webster-Dudley facilities plan,
respectively. A flow of 6.0 mgd represents the monthly average design
flow for the Webster-Dudley treatment plant. The zero mgd alternative
includes an assessment of the feasibility of temporarily storing effluent
during critical water quality periods.
Water Quality Impacts of No Action . Assumptions used in
establishing this base case include advanced wastewater treatment at
Webster-Dudley, and the conservative scenario of zero net photosynthetic
oxygen production occurring during 7Q10 low flow in the French River of
114.8 cfs. Although oxygen produced during photosynthesis is usually a
net positive result, the base case assumes that there will only be enough
sunlight available for oxygen production to offset oxygen depletion due
to respiration at night.
24 2
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For evaluation of the No Action alternative, the conditions of
advanced wastewater treatment flow of 6.0 mgd, zero photosynthetic oxygen
production and 7Q10 low flow were compared to the same situation but with
existing treatment rather than advanced wastewater treatment. The
existing treatment simulation is based on the model calibration to 1982
MDWPC monitoring survey dissolved oxygen measurements, and does not
include the sludge discharge (currently being eliminated at Webster). As
presented in Figure 11_i, during 7Q10 low flow and zero photosynthetic
oxygen production, existing treatment is not sufficient to maintain the
dissolved oxygen concentration above the water quality criterion of
5.0 mg/i. Dissolved oxygen concentrations decrease to approximately 3.5
mg/i in the Perryville impoundment. The river water is then reaerated as
it falls over the impoundment. Dissolved oxygen consequently increases
to approximately 5.3 tng/l and remains constant for about one mile.
Upstream of the Wilsonvilie dam at Langer’s Pond, dissolved oxygen
sharply decreases again to less than 1.0 mg/I. Once more, it is
reaerated as the water travels over the dam but then drops to zero mg/i
in North Grosvenordale Pond. No dissolved oxygen is present in the water
until it falls over the North Grosvenordale dam and again becomes
aerated.
Advanced wastewater treatment at the Webster-Dudley treatment
facility would increase the dissolved oxygen concentration downstream of
the plant by approximately 0.75 to 2.0 mg/i (Figure ‘4-1). Average
improvement would be an increase of’ about 1.0 mg/i in dissolved oxygen.
Despite these improvements, dissolved oxygen levels during low flow would
still violate state water quality standards (5.0 mg/i) in the downstream
portions of the river except just below the Perryville and Wilsonville
dams (due to dam reaeration) and for about one mile downstream of the
Perryvilie dam. Violations of the dissolved oxygen criteria would occur
at Perryviile (‘4.8 mg/i) and Langer’s Ponds (3.0 mg/i), up from 3.5 mg/i
and 0.8 mg/i, respectively, without advanced wastewater treatment, and at
North Grosvenordaie Pond which would have dissolved oxygen between zero
and 1.5 mg/i, (up from zero oxygen dissolved throughout the impoundment
without advanced wastewater treatment).
4-3
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2
AWT and Existing Treatment
Qriver — 14.8 cfs
Qwwtp - 60 rngd
SOD • 3.50 g/sq rn/day @ Perryvills Pond
SOD - 2.00 q/sq rn/day Langer’s Pond
SOD • 2.00 g/sq rn/day N. Grosv.nord&e Pond
RIVER MILE
— — — — Base Case (AWT)
Existing Treatment
FIGURE 4-1 SENSITIVITY OF DISSOLVED OXYGEN TO ADVANCED WASTEWATER TREATMENT
UNDER LOW FLOW (7Q10) CONDITIONS
WATER QUALITY CRITERION
10 8 6 4 2 0
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As part of the analysis of the No Action alternative, the
sensitivity of the French River to variations in Webster-Dudley flow was
evaluated. Flows of 3.25 mgd and L5 mgd at the Webster-Dudley treatment
plant were evaluated. In addition, the potential benefit of storing
Webster-Dudley WWTP flow during periods of low French River flow was
evaluated. The assumptions used in evaluating these conditions include
advanced wastewater treatment at Webster-Dudley, zero net photosynthetic
oxygen production and 7Q10 low flow in the French River. A comparison of
water quality conditions in the French River during Webster-Dudley
discharges of zero and 6 mgd is presented in Figure 4-2. Simulation with
Webster-Dudley discharges of 3.25 and L5 mgd were also similar to those
presented in Figure 14_2. As shown in Figure 4-2, DO in the French River
is not highly sensitive to Webster-Dudley flow rates under conditions of
AWT alone, and water quality standards are not achieved with AWT alone.
As a result, there would be no water quality improvement due to
eliminating the Webster-Dudley discharge during low flow periods. This
is due, in part, to the high SOD rates in the river as well as long
residence times through the impoundments during low flow. In addition,
significant effort would be required to store Webster—Dudley flows. To
store the discharge during the summer low-flow period (June through
October) approximately 120 million cubic feet of’ storage volume would be
required based on the projected plant flow of 6.0 mgd. To store this
volume of flow lagoons with an average depth of 6 ft. covering 460
acres would be required. Construction of a storage facility of this
nature is not warranted since it would not provide for any improvement in
in—stream dissolved oxygen levels. Thus, the base case, No Action
alternative is based on a 6 mgd discharge from Webster-Dudley, with
implementation of AWT, and no seasonal storage of effluent.
An overall improvement in water quality would be expected with the
introduction of advanced wastewater treatment at the Webster-Dudley
treatment facility. Nutrient and BOD concentrations would be lower as a
result of decreased wastewater impacts on the French River. Solids loads
to the river will be substantially reduced with the elimination of sludge
discharges in the immediate future, and overall aesthetics of the river
will be enhanced.
4-5
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E
8
AWT
(1
>-
uJ
-I
0
0
Qriver — 14.8
cfs
Qwwtp - 0
mgd and 6.0 mgd
SOD 3.50
9/sq rn/day @
Perryville Pond
SOD = 2.00
9/sq rn/day 8)
Linger’s Pond
SOD 2.00
9/sq rn/day 8)
N. Grosvenordale Pond
4
0
-j
-J
>
z
-J
4
0
uJ
-J
4
0
0
z
w
>
(I )
0
1 .
z
4
0
w
-a
4
0
0
z
w
>
8
— — — — Base Case (6.0 rngd Discharge from W- D WWTP)
No Discharge from W. D WWTP
FIGURE 4-2 SENSITIVITY OF DISSOLVED OXYGEN TO FLOW FROM WEBSTER- DUDLEY
WASTE WATER TREATMENT PLANT UNDER LOW FLOW (7Q10) CONDITIONS
15
14
13
12
11
10
8
7
6
5
9
WATER QUALITY CRITERION
10
8
1
6
RIVER MILE
4
2
0
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Biological Impacts of No Action . Following the assumptions stated
above in the water quality impacts section, the evaluation of biological
impacts of the No Action alternative focuses on the existing conditions
as more fully described in Chapter 3.
Phytoplankton populations in the French River are not expected to
be significantly altered by the No Action Alternative. Although the
nutrient input from the treatment plants will be substantially reduced,
the impounded sediments probably would act as a continuing source of
excess nutrients.
Wetlands, especially the emergent macrophyte wetlands, would also
remain generally unchanged as a result of the No Action alternative. The
growth in areal extent of wetlands, due to increased sedimentation, is
part of the natural ecological successional process. The rate at which
the process occurs is controlled by a variety of factors. While
historical data document problems associated with increased siltation and
sediment transport, the existing conditions are relatively stable.
Consequently, the areal extent of wetlands in the river would not be
expected to change drastically.
Under the No Action alternative, the opportunity exists for
continued bioconeentration of contaminants from the impounded sediments
into the wetland plants. The predominant growth of’ the root/rhyzome mat
of the emergent macrophytes, including Typha latifolia, provides an
opportunity for the uptake and bioconcentration of the contaminants in
the sediments (previously described in Chapter 3). Through seasonal
production and ultimate transport of the resultant detritus, the
opportunity exists for continued trophic magnification of the
contaminants through the wetlands food webs.
The benthic macroinvertebrate population downstream of the
Webster.-Dudley discharges would benefit, to a minor extent, by the No
Action alternative. Water quality improvements associated with AWT and
elimination of sludge discharges could enhance the diversity of the
benthic community, as organisms less tolerant of extremely low DO
concentrations would be better able to survive and reproduce. However,
1 _7
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the sediments which they inhabit would continue to exert a high oxygen
demand. Density of the organisms could actually decrease, as a result of
reduced organic “food” input to the riverine system. Also, the potential
for bioaccumulation from contaminated sediments would remain.
Since most of the fish of the area are dependent not only on the
quality of the habitat cover type but also on other food (invertebrates,
vertebrates, and detritus) available, similar impacts would be expected
in the impoverished fisheries stocks that exist along the lower part of
the river. Improved water quality would enhance the diversity of the
fish, but the continued presence of contaminated sediments would impair
the health of the organisms.
Wildlife and waterfowl use of the downstream impoundments would
probably remain unchanged with the No Action alternative, as their
wetland habitat would not be altered. The existing limitations in the
quality of the water and sediment would limit the ecological health and
diversity of the resident fauna in the waters of the river, and would
also continue to potentially impair the diverse migratory waterfowl use
of the areas.
Socioeconomic Impacts of No Action . Economic impacts on both the
residents and the industries in the service area which would occur as a
result of the No Action alternative would only be those associated with
the construction and operation of the advanced treatment facility at
Webster—Dudley. These costs are summarized in Table i-1. As discussed
in the Facilities Plan, the financing of the upgraded plant would come
from the local residents and industries, and State and Federal
Construction Grants. Other socioeconomic impacts associated with AWT
were also addressed in the Facilities Plan.
Impacts of No Action on Recreational Resources and Use
Attainability . The No Action alternative would have no impact on
existing recreational activities or other uses of the river upstream of
the Webster/Dudley Treatment Plant. Further, there would be no
significant impacts on existing uses downstream of the plant. Over the
long term, water quality downstream would improve as a result of upgraded
-------
a.
TABLE 14. i. WEBSTER/DUDLEY ADVANCED WASTEWATER TREATMENT
ESTIMATED AVERAGE A1jN1 JAL COST
(DOLLARS/YR)
Industrial
Webster
Residential
Dudley
Residential
Industrial
Added Debt Service
for the reconinended
Plan
50,900
61,1400
27,000
10,500
Current Debt Service
20,700
25,000
11,000
14,300
Total Debt Service
71,600
86,1400
38,000
114,800
0&M
3142,500
6142,000
138,500
122,000
Total Cost
14114,100
728,1400
176,500
136,800
Estimated Cost
Per Household
Sewered
tlnsewered
91
21
92
17
All costs are in 19814 dollars. All costs are average costs over the
20 year planning period.
b. Based on 20 year bond at 9 1/2 interest.
c. Based on the average nuither of households served during the 20 year
planning period - 14,8714 households in Webster and 1,8145 households in
Dudley
Source: Metcalf & Eddy, 19814.
treatment. Sedimentation from discharges previously made directly to the
river would be discontinued in the preliminary stages of upgrading,
although sediments already deposited would remain and continue to degrade
water quality.
Consequently, the ability of the river to provide habitat for fish
and wildlife and to permit boating use would continue to be limited.
Swimming and fishing opportunities would not improve because of the
deposited sediments, the poor image for recreation at Perryville and
Langer’s Pond, and the limited fishing stock. Hiking along the river
would continue to be restricted by lack of access.
14—9
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Impacts of No Action on Archaeological and Historic Resources .
The No Action alternative consists of implementation of Advanced
Wastewater Treatment at the existing Webster treatment plant site, where
no significant historical or archaeological resources have been
identified. Thus, there would be no impacts on the resources in the area
associated with the alternative.
Regulatory and Institutional Constraints of No Action . With the
No Action alternative, water quality standards would still not be met in
downstream impoundments during extreme low flow events unless other
measures are implemented as well (an assumption in the Facilities
Plan). The State of Connecticut would not be prevented from dredging at
Wilsonville and North Grosvenordale, as proposed in the bill currently
before the State legislature (see Legal/Institutional Framework), however
the impetus to do so might be limited as long as uncontrolled sediment
deposits remain upstream in Perryville.
Impacts of Low Flow Augmentation From Buffumville Lake
General . Results of previous EPA and MDWPC water quality studies
of’ the French River, which were conducted using the STREAM7A river
dissolved oxygen (DO) model, suggest that maintenance of a minimum flow
of 22 cfs at the USGS gaging station in Webster would be required, in
addition to advanced wastewater treatment (AWT) at Webster-Dudley, to
meet State instreain dissolved oxygen standards of 5.0 mg/l during periods
of critical low flow. This augmented minimum flow was assumed in the
facilities planning for AWT at Webster-Dudley.
Results of the STREAM7B water quality modeling conducted during
preparation of this EIS suggest that low flow augmentation (LFA) to 22
cfs and AWT would improve water quality but would not be sufficient to
meet the dissolved oxygen standard. However, DO levels in portions of
the French River within Thompson, Connecticut would likely still drop
below 5.0 mg/i during periods of critical low flow. As a result, LFA to
22 cfs would not insure compliance with DO standards in Massachusetts and
Connecticut unless it was implemented in conjunction with one or more of
the other alternatives discussed in this EIS. Its implementation could
14 10
-------
constitute one phase in a multi-phase approach to improvement of water
quality within the French River.
Engineering Issues Associated with Low Flow Augmentation . As
stated previously, the most appropriate source of storage for low flow
augmentation in the basin is the existing lake behind the .Corps of
Engineers’ flood control dam at Buffumville.
Buffumville Dam, which was completed in 1958 by the U.S. Army
Corps of Engineers, New England Division, is located on the Little River,
1.3 miles upstream of its confluence with the French River. The dam
consists of a rolled earthf ill embankment, concrete ogee spillway, outlet
works and storage capacity for recreation and flood control.
At the presently maintained permanent recreational pool elevation
of 1492.5 feet above NGVD MSL, the surface area and capacity of
Buffuinville Lake are 200 acres and 114140 acre-ft, respectively. The lake
extends up the Little River approximately 1.7 miles and up the South Fork
Little River for 1.9 miles. The lake drainage area of 26.5 square miles
is predominantly rural with a few small hamlets nearby.
The outlet works (see Figures 14-3 and 4-14), which are located in
the center of the emergency spiliway, consist of three 3’-O” wide by
4’ 6” high gated rectangular conduits, with inverts at 1481.5 feet above
MSL. Flow through each of these conduits is controlled by electrically
operated slide gates, which can open or close partially or completely
within 4.5 minutes. The piers between gate passages are elongated in the
upstream direction and the channel thus formed is spanned by a weir,
which is used to maintain the lake at the permanent recreational pool
elevation. The control weir does not regulate flow through the conduits
on either side of the center conduit. Since October 1980, the normal
opening of the center gate has been lowered from 14 5 ft. to 2.0 ft., and
since 19714 during the summer months, one of the side gates has been
raised to an opening of 0.1 ft. The reduced center gate opening ensures
that significant reservoir releases will not occur during unexpected
storms. The raising of the outside gate by 0.1 ft. helps to create a
better mixing of impoundment waters during the warm weather months.
14.11
-------
STI
OUTLET STRUCTURE
SRI LLWAY CREST EL. 324.0
—
—
20
0
20
I
*
I
SCALE IN FEET
FIG. 4-3 SPILLWAY AND OUTLET WORKS OF BUFFUMVILLE DAM
(PLAN A ND LONGITUDINAL SECTION)
STA. 5 + 59
PLAN
4 ;.
;:.l :w:-.
__ I 1.--
c. 3-0” x 4-6” CONDUITS
LONGITUDINAL SECTION
THRU GALLERY CENTERLINE
3ØBLACKSTEEL
PIPE TO FOOT WELL
AT EL. 483.0
-------
+
‘ ° SPILLWAY CREST LINE
I — -
I I
9 1+00 4+00 5+00 7+00 8+00
60
SCALE IN FEET
60
FIG. 4-4 SPILLWAY AND OUTLET WORKS OF BUFFUMVILLE DAM
(SECTION VIEW)
6+00
PERMANENT POOL EL.
TOP OF DAM
Q0F DAM
CONTROL HOUSE
TOP OF WELL EL. 522.5
APPROX IMATE
ROCK LINE
L
OUTLET STRUCTURE
-------
Details of the control weir and the outlet conduit and weir rating
curves are shown in Figure 14-5. The three weir stoplogs can be removed
separately, providing stepped variation in vertical control from a
maximum elevation of 1492.5 feet to a minimum of 1489.0 feet. In addition,
discharge at lake elevations below the normal weir setting of 1492.5 feet
can be continuously varied by opening or closing either one or both of
the side conduit slide gate controls. Discharge at lake elevations above
the normal weir setting can be continuously varied by opening or closing
one or more of the three conduit slide gate controls.
The Hodges Village EIS (ACE, 19814), using the Hodges Village Flood
Control Reservoir as a source for flow augmentation, indicated that
approximately 500 acre-feet of seasonal storage would be required to
augment French River flows to a minimum of 22 cfs, during the June 1
through October 31 low flow period. This storage volume was based on
records from the U.S.G.S. Webster gage. Daily average flows were
examined for the period from 1959 (Buffuxnville Lake was constructed in
1958) to 1981, in order to determine maximum storage requirements for LFA
to 22 cfs. It was found that during most years very little, if any, LFA
storage would have been required. However, during 1965, 1970, 1977 and
1981 significant LFA would have been required. The periods of critical
low flow and resultant storage requirements for LFA during each of these
four years are given in Table 14-2.
TABLE p4-2. LFA STORAGE REQUIREMENTS
Year
LFA Period
Required Storage
For 22 cfs Minimum Flow
(acre-ft)
1965
August — September
513
1970
July - August
1014
1977
August — September
256
1981
September - October
82
14_ 114
-------
40
35
30
25
I —
LU
LU
z
LU
C l)
0
>
LU
C / )
LU
20
15
ERMANENT PC )L WEIR
(U/S Center Gate Only)
Permanent Pool Weir consists
of three stoplog openings, each
6’ wide.
Top of Stoplogs:
EIev. 492.5
5
0
0 1 2 3 4 5 6
DISCHARGE (100 CFS)
THREE 3’ WIDE x 4’-6” HIGH GATES
FIG. 4-5 OUTLET RATING CURVES FOR BUFFUMVILLE LAKE
-------
The U.S. Army Corps of Engineers estimate of the maximum LFA
storage requirement was based on the 1965 critical low flow period. This
period also corresponds to the most critical 7-day duration low flow
event contained in the gage records. However, these records also suggest
that substantial flow diversion and/or storage occurred in the French
River, between its confluence with the Little River and the Webster gage,
during a portion of the 1965 critical low flow period. Upstream
diversion and/or storage, such as that suggested by the 1965 gage data,
appears to have occurred continuously, over one to seven day periods,
during the years between 1959 and 1967. However, gage data from later
years suggest that significant upstream diversion and/or storage did not
occur subsequent to 1967. The lack of significant upstream diversion
and/or storage during more recent years is likely the result of stricter
government regulations for operation of run-of-the-river hydropower
facilities and use of river water by factories and municipal
watertreatment plants. These regulations are meant to keep the above
users from diverting and/or storing water required to maintain adequate
downstream river flows during periods of low flow.
As a result of the above considerations, the U.S. Army Corps of
Engineers’ storage volume estimate of 500 acre-feet (based on the flood
of record) appears to be conservative and actually less would be required
during future low flow periods. In this report, however, the 500 acre-ft
estimate was retained as an extreme condition for use in initial
screening of LFA sources and in assessing the engineering feasibility and
worst possible impacts of the recommended LFA alternative.
The impact of the withdrawal of 500 acre-ft volume of water on the
level of Buffumville Lake is determined using the Stage-Storage data
given in Table 14—3. This information is presented graphically in Figure
4-6.
From these data, it is seen that a discharge of 500 acre-feet of
LFA storage would drop the water surface elevation in Buffuinville Lake by
2.14 feet.
14... 16
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TABLE 1I_3. STAGE-vs-STORAGE FOR BUFFUMVILLE LAKE
Stage
Area
Volume
(ft. above MSL)
(acres)
(acre—feet)
Permanent Storage
1481.5 51 0
482.5 60
1483.5 68 120
4814.5 76 190
4855 85 210
1486.5 150 390
1487.5 158 5 4O
1488.5 167 700
1489.5 176 880
490.5 1814 1060
1491.5 192 1240
1492.5 200 11440
Storage above Normal Pool El 492.5
1492.5 200 0
493.5 209 300
14914.5 218 1420
1495.5 228 6 140
1496.5 237 870
497.5 2146 1110
1498.5 256 1360
1499.5 266 1620
500.5 276 1900
502.5 296 21170
5014.5 316 3080
506.5 336 3730
508.5 356 141420
510.5 377 5160
512.5 399 5930
513.5 1410 63 4O
14-17
-------
I-
U-
w
0
I-
U)
(THOUSANDS)
STORAGE (ACRE - FT)
6 7 8
FIG. 4-6 BUFFUMVILLE LAKE STAGE - STORAGE CURVE
-------
Drawdown impacts could be decreased significantly if lake levels
were initially increased above the normal pool elevation of 492.5 during
April and May of each year. This water would subsequently be released
during periods of required LFA discharge. There are a variety of options
available for controlling the storage in Buffumville Lake to accomplish
the objectives of low flow augmentation in the French River. Two of
these include increasing the elevation 1.5 ft. above normal pool in the
spring, and releasing water as needed to a maximum of one foot below the
normal elevation; another option is to raise the level 2.5 ft. above
normal pool elevation, and draw the reservoir back down to normal pool
again. There is some concern regarding impacts associated with drawing
the pool level below the existing operating level. Due to the shallow
nature of the lake and the presence of submerged stumps, there may be
negative impacts during drawdown related to recreational uses, aesthetic
uses, wildlife and wetlands. Due to these potential negative impacts,
the alternative of drawing the lake level down significantly below
elevation L 92.5 has been precluded from further consideration. Thus, an
increase in the normal operating pool elevation of 2.5 ft. will provide
for the 500 acre—ft. of storage needed for LFA to 22 cfs during worst
case conditions. If that low flow augmentation is implemented, the U.S.
Army Corps of Engineers, which owns and operates the Buffumville
facilities, would develop the operating procedures of the low flow
augmentation plan. Design and construction associated with the project
would be conducted by the Corps (or by another agency in accordance with
Corps criteria and review). The low flow augmentation plan would need to
be coordinated with the Massachusetts Division of Water Pollution Control
and EPA.
Water Quality Impacts of Low Flow Augmentation . By augmenting low
flow in the French River to 22 cfs with water stored in Buffuinville Lake,
dissolved oxygen concentrations would increase approximately 1.0 mg/l
over base case conditions (see Figure 1 _7). As previously mentioned, the
base case assumes advanced wastewater treatment at Webster-Dudley, no
photosynthetic oxygen production and 7Q10 low flow conditions. With low
flow augmentation to 22 cfs, dissolved oxygen ranges from 4. I to 7.0 mg/l
!4 19
-------
= 14.8 cfs , 22 cfs , 50 cfs
— 6.0 mgd
- 3.50 g/sq rn/day Perryville Pond
2.00 g/sq rn/day @ Linger’s Pond
- 2.00 9/sq rn/day N. Grosvenordale Pond
0
‘U
-J
0
0
z
‘U
>
— — — — Base Case (14.8 cfs)
22 cfs
— — 50cfs
FIG. 4-7 SENSITIVITY OF DISSOLVED OXYGEN TO LOW FLOW AUGMENTATION
FROM BUFFUMVILLE LAKE UNDER LOW FLOW (7Q10) CONDITIONS
15
14
11
‘U
-I
0
D
0
5
‘U
-J
-J
>
>-
‘U
0 .
0
‘U
-J
(
0
0
z
‘U
-J
-j
>
z
-J
14
13
12
11
•10
.9
r
I
WATER QUALITY CRITERION
2
AWT
Oriver
Qwwtp
SOD
SOD
SOD
I
10 8 6 4 2 0
RIVER MILE
1
-------
in the segment from upstream of Perryville dam to Wilsonville Jam.
However, once the water reaches North Grosvenordale Pond, the dissolved
oxygen concentrations yield to the high sediment oxygen demand and drop
to 1.0 mg/i.
To achieve a dissolved oxygen level above 5.0 mg/i in North
Grosvenordaie, low flow augmentation well in excess of 22 cfs would be
required. Several STREAM7B runs were made with low flow augmentation to
flows higher than 22 cfs. To show sensitivity to low flow augmentation
with flows greater than 22 cfs, a DO simulation assuming low flow
augmentation to 50 cfs is also presented in Figure i _7. As is shown,
even with LFA at this level, the dissolved oxygen level in North
Grosvenordale is below 5.0 mg/i. The additional storage required at
Buffumville Lake to maintain 50 cfs in the French River under worst case
conditions would be approximately 6300 acre ft., requiring an increase in
lake level to 513.5 (see Table 14_3). Approximately 220 acres of land
would be flooded, including 70 acres of wetlands, to provide this
increased storage. The option of meeting water quality standards through
only AWT and LFA is therefore not recommended due to the significant
detrimental efforts which would be experienced by the loss of extensive
wetland habitat. A river flow of 22 cfs will be used in further
evaluations of the LFA alternative since higher flows would be harmful to
the wetlands surrounding Buffumville Lake.
While low flow augmentation to 22 cfs from Buffumville Lake would
not achieve Class B water quality in all portions of the French River
during extreme low flow, it would have a positive impact on water quality
downstream of the Little River’s confluence with French River.
Significant increases in DO would be achieved due to LFA at this level.
Hydraulics during low flow would be enhanced, minimizing residence times
in the downstream impoundments. In addition, flow from Buffumville Lake
would reduce the downstream concentrations of BOD, nutrients, metals and
other pollutants which are input to the river from sources such as
stormwater runoff and the river bottom sediments.
4-2 1
-------
Biological Impacts of Low Flow Augmentation . The available
information on the biota indigenous to Buffuinville Lake and the
downstream impoundments were summarized in Chapter 3. Using the above
described scenario relative to the implementation of the low flow
augmentation to 22 cTh (LFA) using Buffumville Lake, the biological
impacts are evaluated. Since the increased water level elevation
necessary for adequate low flow augmentation is completely within the
operational level fluctuation (as based on the past five year operational
records), there will be no effect on the biota of Buffumville Lake.
While this alternative would not alter the phytoplankton in
Buffumville Lake, LFA would improve water quality in limited reaches of
the French River during certain critical periods of the year. As defined
above, the release of this water would be during the low flow periods
(generally from June 1 through October 31). While the slight increase in
dissolved oxygen concentration would not affect phytoplankton growth in
the river, the elimination of periodic nearly stagnant conditions in some
downstream segments could deter the occurrence of occasional algal blooms
in these areas.
Similarly, the LFA alternative would have little or no impact on
wetlands since the proposed action would not alter water levels beyond
what normally occurs in the lake. Only those emergent macrophytes
located along the central western edge of the reservoir, might be subject
to habitat/cover type change should water levels be operated as suggested
for LFA. If seasonal levels of water were significantly greater than two
feet higher in elevation than water levels as recorded over the past five
years, during the active growing season (April to September), then less
than two acres of palustrine scrub shrub habitat might undergo ecological
succession and be transformed by seasonally high water levels into
emergent macrophyte habitat cover type (such as cattails, sedges,
etc.). All the areas surrounding the reservoir where there exist large
expanses of deciduous and coniferous trees, are of reasonably steep
grades with slopes of 2:1 to 5:1. These areas are presently, to a large
extent, devoid of standing trees within 20 horizontal feet of existing
water levels (based on site evaluations when the water level was 1.6 feet
4-22
-------
above the normal pool elevation of 92.5 feet MSL). Thus, water levels
would have to be increased by over 5 to 6 feet above normal pooi
elevation before operational problems would exist as a result of trees
being inundated, killed and falling into the reservoir. The increased
water level necessary for adequate low flow augmentation is completely
within the existing operational level fluctuation (Table 2-2) and thus
there also would not be any significant leaching of nutrients from soils
that may be periodically inundated. This conclusion is reached since
these same soils have been subject to such inundation and leaching
activities during the past five or more years of reservoir operation.
The LFA alternative at Buffuinville Lake would also not be expected
to change the benthic rnacroinvertebrate populations within the lake. The
resultant increase in dissolved oxygen downstream of the release would
result in some increase in opportunity for survival and reproduction of
benthic invertebrates in downstream sections of the French River.
Benthic communities in the downstream impoundments would have the
opportunity for slightly increased density and diversity, and thus a
limited improvement in the ecological health as a result of low flow
augmentation. These changes are viewed as beneficial but minor, and
limited in scope due to the fact that the sediments would continue to
limit the availability of oxygen in the benthos and provide a potentially
toxic environment.
LFA from Buffumville Lake would also not be expected to have any
adverse impact on the fisheries of the lake nor the French River. The
temporary 2.5 foot change in depth of the lake would not make a
significant change in either the quality or the quantity of the
habitat. The fisheries downstream in the French River would be
positively impacted by improved DO and enhancement of benthic
communities, which provide food for fish. The fisheries would, however,
continue to be limited by the shallow depth of the river and its
impoundments, and by water quality impacts of the sediments.
The existing waterfowl and wildlife use of the French River
environment would also not be expected to change as a result of
implementation of this alternative. Since the areal extent of the water
surface at Buffumville Lake would not significantly change (over existing
1-23
-------
operational patterns associated with the lake’s use as a flood control
structure), nor will new areas downstream be inundated, no significant
areas of submerged or floating mat vegetation, nor emergent macrophytes
are anticipated. Thus, there is no reason to expect significant positive
nor negative impacts on waterfowl or wildlife associated with the LFA
alternative.
Socioeconomic Impacts of Low Flow Augmentation . Implementation of
the low flow augmentation alternative would have little or no impact on
the socioeconomic resources of the communities in the French River Basin,
beyond those associated with implementing Advanced Treatment at Webster-
Dudley, as described under the No Action alternative.
Estimated costs associated with low flow augmentation are
presented in Table l 1• Since the proposed increase in pool elevation is
within the range of elevations currently experienced at the lake, no new
impacts will be experienced and no significant mitigating measures are
required. The LFA project will require more control over outflow during
low flow periods, which could be accomplished by manual or automated
control. It is assumed that automated controls would be used. Costs for
a microprocessor and controls for this purpose would be approximately
$25,000 with annual operating costs of $30,000 during periods of
operation. Also, there is a possibility that the beach would benefit
from widening, and the cost for this is included in Table l _4 The
annual costs for LFA are for the manpower required to operate the
discharge from the reservoir during periods of low flows. During many
years, no flow augmentation will be required, and thus these operating
costs will not be required. Flow augmentation would be initiated only
when the river flow drops below 22 cfs. Stream flow records indicate
that in many years, no flow augmentation would be required to maintain
this minimum flow. It should be noted that outflow from Buffumville Lake
is currently controlled by U.S. Army Corps of Engineers personnel, and
LFA releases may be able to be handled by existing Corps staff. Thus,
the annual cost of $30,000 is actually a conservative (high) estimate.
There is an existing culvert connecting Colicum Reservoir to
Buffun vifle Lake which is 13 ft. in diameter with 8 ft. of clearance
during the existing operating pool level (Buffumville Lake Master Plan,
4-2k
-------
TABLE k-a. LOW FLOW EUGMENTATION COSTS
A) Microprocessor & Controls $ 25,000
Operating Costs 8 Months ________
55,000
B) Widen Beach 3,000
3,000
C) Replace 100’ of 13’O’ Pipe Culvert
with 15’O’
Remove 13’O” Culvert 50,000 50,000
New $800/LF 80,000
Jacking 25,000
Mob/Demob 25,000
Elevate 15,000
Caisons (2) 50,000
60x20x$20 $195,000
10% Engineering X 1.10
25% Contingency X 1.25
TOTAL ESTIMATED COSTS 17 , 000 (b)
a. Operating costs required only during low flow periods; operation
may be assumed by Corps of Engineers existing staff, thus
reducing cost.
b. Total includes one full year (8 months) operating costs.
1976). Under existing operating conditions the clearance at this culvert
is significantly reduced and the culvert is sometimes completely
submerged during periods of high water. Thus, problems related to
clearance at this culvert already occur due to existing variation in
water level. But, since the proposed LFA plan will reduce clearance at
this culvert during the peak boating season, costs for replacing this
culvert are included. Costs are summarized in Table
Impacts of Low Flow Augmentation on Recreational Resources and Use
Attainability . The low flow augmentation alternative would have no
impact on existing uses of the French River upstream of its confluence
with the Little River. Downstream of the confluence, flow augmentation
4—25
-------
could improve the generation of hydroelectric power by supplying slightly
improved flow during what would normally be low flow situations and would
improve flow for use in industrial processing and cooling. However, all
hydropower facilities operate as “run of the river” and storage of water
is not permitted. Low flow augmentation will not be implemented to
benefit hydropower generation at the expense of water quality. The
ability of the river to support fish and wildlife would also be somewhat
improved, as discussed in the preceding section. Since there is little
use of the river at present for boating, and the dams and sediments would
remain as barriers, low flow augmentation would not significantly impact
this use. General aesthetics would, however, be improved due to the
reduction in periods of stagnant water.
At Buffumville Lake, recreational use has declined such that flow
augmentation would have only a minor impact on visitation. Since low
flow augmentation would be required during the summer months, the peak
boating season, headroom at the culvert under the road at the north end
of the reservoir, already tight, would be decreased. The enlargement of
the culvert has already been taken into account in the costing of the
alternative. Boating in the reservoir for water skiing has decreased
because the lake is shallow, making it hazardous for fast boats and
skiers. Raising the pool elevation may have a positive effect on boating
depending on the degree of fluctuation.
Impacts on recreational use of the lake for swimming and fishing
should not be significant since trends show such use of the reservoir has
declined from a high of 60,000 swimmers in 1965 and 9,000 anglers in 1970
in favor of sightseeing (23,000 in 1975). Fluctuation of the water level
would be minimal during the summer season due to LFA, occurring approx-
imately once in 10 years. There will, however, be an annual fluctuation
for LFA storage purposes. All fluctuations in water level would be
within the normally occurring range. The beach, which extends 6 feet
into the water, would be minimally flooded when the reservoir is
filled. It may be necessary to widen the beach to minimize impacts,
depending on the storage scheme implemented.
1 .. .26
-------
Impacts of Low Flow Augmentation on Archaeological and Historic
Resources . Since the fluctuation in water level due to LFA is less than
the level due to the normally occurring operating range, no impacts will
occur to the archaeological resources of the area beyond impacts that may
already be occurring due to water level fluctuations. Potentially
significant historical resources that may be affected by increased pool
elevations include the Mill Pond breakwater and a segment of the Old
Oxford Road. The relatively recent ages and limited research value of
all other historic resources in this area render them ineligible for
nomination at either the Federal or the State Register. Although no
surface remains of either the known or the reported prehistoric sites at
the reservoir are evident, both locations may be affected by increased
pool elevations.
Regulatory and Institutional Constraints of Low Flow Augmentation .
A number of State and Federal permits would be required for implement-
ation of the flow augmentation alternative. A Wetlands Protection Act
permit from the Chariton Conservation Commission may be required,
however, since the project is entirely within Federal land this permit
may not be necessary. If the devegetation (if required) is beyond the
parameters set by the Act, a variance would be required from the
Commissioner of DEQE. U.S. Army Corps of Engineers has indicated that
they would clear and grub the periphery of Buffumville Lake to an
elevation of J49 7 feet. In accordance with the management license for
fish and wildlife for the reservoir, the project would require the
concurrence of the Department of the Interior and the Massachusetts
Division of Wetlands and Waterways. Also, a Section 4Ol4 permit for
dredge and fill activities would be required. Sediment removal will not
be implemented at Buffumville since repeated floodings leach out
nutrients in the soil. Further, compliance with Executive Orders 11988
and 11990 would be required. For a detailed description of permit
requirements, see the Legal/Institutional Framework section, Chapter 3.
14...27
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I acts of Sediment Control in Perryville, Langer’ s Pond and North
Grosvenordale I oundments
General . As discussed in the preliminary screening described in
Chapter 2, several alternative methods that could be used to provide
sediment control have been identified. The selection of alternative
methods was based on consultation with experts in the field of
impoundment sediment control, and recent findings of science and
technology with respect to sediment control within impoundments. The
alternative methods selected for further evaluation are listed. in
Table L4_5.
TABLE 14_5. ALTERNATIVE SEDIMENT CONTROL METHODS
ALTERNATIVE
TYPE
METHOD
Excavation
Dredging
Hydraulic
Excavation
Dredging
Mechanical
Excavation
Dry
Mechanical
Capping
Concrete
In Place Application
Capping
Sand
In Place Application
Capping
Sand and Flexible
Impermeable Liner
In Place Application
Capping
Sand and Flexible
Permeable Liner
In Place Application
Wetlands Isolation
Sheet Piling
In Place Application
Engineering Issues Associated with Sediment Control . The
advantages and disadvantages of each method, based on engineering and
water quality criteria, are summarized in Table
Based on this evaluation, the mechanical dredging alternative, one
of the excavation methods, was eliminated from further consideration.
This was because mechanical dredging could cause high re-suspension and
re-settlement of sediments during the dredging operation, causing
possible adverse impacts on water quality and characteristics of
sediments in the impoundments.
14.28
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TABLE 11_6 EVALUATION OF SEDIMENT CONTROL METHODS
Action Type Method Advantages Disadvantages
Excavation Removes sediment which Resuspension of sediments may increase the
may be contributing oxygen demand and nutrient levels in the
oxygen demand, toxics water column, and release toxics.
and nutrients to the
water column. May reduce velocities in the pond channel
system increasing rate of deposition of
Can be selectively incoming sediments.
undertaken to preserve
wetlands, to develop Depending on method of excavation, a large
swimming areas or to percentage of excavated material may be
improve pond hydraulics, redeposited in the pond.
Due to redeposition or increased rate of’
deposition of incoming sediments may have
short effective life.
Nature of sediments and availability of river
and/or land access critical in selecting
appropriate methodology.
May create “Cat Clays”.
Dredging Hydraulic Low resuspension of Effluent quality from dewatering and
sediment during dredging flocculation systems may adversely impact
oxygen operations, receiving water body.
limiting demand and
nutrient transfer to Productivity rate extremely variable, depending
the water column. on operator performance, nature of sediments
-------
and under water obstacles.
Extensive gravity settling and flocculation
facilities required.
Chemicals required to flocculate and settle
fines in sediment.
Sediment must be pumped from pond to dewatering
facilities, resulting in high maintenance cost.
Limited availability of portable dredging
equipment from construction industry.
May release toxics and nutrients.
May result in toxic sediments that require
special handling and disposal sites.
High resuspension of sediments during dredging
operation.
High resuspension of sediments may increase the
oxygen demand and nutrient levels in the water
column.
Action Type Method
TABLE J -6 (Continued). EVALUATION OF SEDIMENT CONTROL ME HODS
Advantages Disadvantages
Excavation Dredging Hydraulic
(Continued)
Dredging Mechanical
Compact portable
equipment available,
access not critical.
Clamshell and dragline
excavation equipment
readily available from
construction industry.
Excavated material may
be hauled away by truck
to disposal site.
-------
TABLE Is_6 (Continued). EVALUATION OF SEDIMENT CONTROL METHODS
Action Type Method Advantages Disadvantages
Excavation Dredging Mechanical Normal size cranes will not support booms much
(Continued) greater than 100 feet in length, which limits
the working area, from any particular shore
location to 100 foot radius.
May cause slumping of adjacent wetlands.
Dry Mechanical Mechanical excavation Requires pond dewatering either by channelizing
equipment readily avail- or by passing low flows.
able from construction
industry. Dewatering by channelizing low flows requires
low level outlet at dam structure or pumping.
Excavated material may
be hauled away by truck Rate and depth of dessication of sediments
to disposal site. uncertain. Sediments may not have sufficient
strength to support mechanical excavation
equipment.
Pond dewatering may adversely impact quality
of water downstream from pond.
Dewatering may adversely effect regrowth of
plants in areas not excavated.
-------
TABLE k-6 (Continued). EVALUATION OF SEDIMENT CONTROL METHODS
Action Type Method Advantages Disadvantages
May reduce the rate of
oxygen demand and nutrient
transfer at sediment water
column interface.
May completely or
partially isolate the
sediment Interface from
the water column.
Complete isolation of the sediment interface
from the water columnmay destroy biological
life in the upper layer of the sediment.
Decomposition of capped sediments may
generate gases.
Control of thickness of capping material may
be difficult.
In stream velocities may be sufficient to
scour out capping materials.
Concrete In Place
May completely isolate
the oxygen demand in the
sediments from the water
column.
In place appucation
techniques used in con-
struction industry.
Complete isolation of the sediment interface
from the water colulmnmay destroy aerobic
biological life in the upper layers of the
sediment.
Control of thickness of capping material may
be difficult.
Concrete capping material
not easily scoured from
the bottom.
Capping material readily
available.
Capping material may crack due to differential
settlement.
Capping material may settle into sediments or
crack due to differences in densities.
Capping
-------
TABLE 11_6 (Continued). EVALUATION OF SEDIMENT CONTROL METHODS
Action Type Method Advantages Disadvantages
Capping Gases may be generated under capping material.
(Continued)
Capping material may have a short-term life.
Sand In Place Permeability of’ sand may Capping material may be scoured by stream flows.
Application permit sustaining
biological life in the Capping material may settle into sediments due
upper layers of’ the to differences in density.
sediment.
May reduce the impact of Capping material may become contaminated with
oxygen demand in the sed- underlying sediments increasing the oxygen
iments on the water column.demand on and nutrient transfer to the water
column.
May reduce the transfer
of nutrients from the Capping material may become contaminated by
sediments to the water transport of toxicants from lower layers by
column. wetlands plants.
In place application
that techniques widely Would raise water elevation so that area would
used In construction no longer support wetland plants.
industry.
-------
Method
In Place
Application
Any gases generated under
the capping material
should be dispersed In
the water column.
May completely isolate
the oxygen demand and
nutrient transfer from
the sediments to the
water column.
Provides a sediment which
should have a low oxygen
demand and low nutrient
transfer to the water
column.
Interface
aerobic
of the
Action
Capping
(Continued)
Type
Sand
Sand and
Flexible
Impermeable
Liner
TABLE 1 6 (Continued). EVALUATION OF SEDIMENT CONTROL METHODS
Advantages Disadvantages
In Place
Appl icat ion
floating.
Complete isolation of the sediment
from the water columin may destroy
bilogical life in the upper layers
sediment.
Requires cover material to prevent
Gases may be generated under liner.
Underground materials may puncture
May require gravel base and piping
disperse accumulated gases.
Construction may require innovation procedures.
Sand may be scoured out at high stream flows.
Unless sufficient depth, new wetland plants
would grow
liner.
to
-------
TABLE I-5 (Continued). EVALUATION OF SEDIMENT CONTROL METHODS
Action Type Method Advantages Disadvantages
Capping Sand and May completely or Complete isolation of the sediment interface
(Continued) Flexible partially isolate the from the water column may destroy bacterial
Permeable oxygen demand and nu- life in the upper layers of the sediment.
Liner trient transfer from the
water column. Gases may be genreated under liner.
Provided a sediment which Underground mateirals may puncture liner.
should have a low oxygen
demand and low nutrient Construction may require innovative
transfer to the water procedures.
column.
Sand may be scoured by stream flows.
Gases that are generated
under the liner should Unless sufficient depth, new wetland plants
be dispersed in water would grow in sand.
column.
Permeability of sand and During construciton period turbidity in pond
liner may permit sustain- area may increase.
ing aerobic biological
life in the upper layers
of the sediment.
Wetlands Sheet In Place Maintains wetlands.
Isolation Piling Application Minimizes sediment move—
ment from wetlands to
pond area.
Minimizes sediment oxygen
demand, toxic and nutrient
transfer from wetlands to
pond area.
-------
TABLE 11_6 (Continued). EVALUATION OF SEDIMENT CONTROL M HODS
Action Type Method Advantages Disadvantages
Wetlands Sheet In Place Minimizes both short-
Isolation Piling Application term and long-term
(Continued) impact to existing
adjacent wetlands.
Facilitates continued
biological succession
of wetlands.
Minimizes adverse
impacts of existing
toxics In sediments
in wetlands.
Provides continued
balance of open water
and wetland habitat.
-------
Four alternative technologies for capping the sediments were
considered: capping with concrete; capping with sand; capping with sand
and an impermeable liner; and capping with sand and a permeable liner.
However, the disadvantages of each are such that all the capping alterna-
tives were eliminated from further consideration. Concrete was excluded
because of the potential of the concrete to develop cracks due to
differential settlement, and its adverse impacts on the existing sediment
layer within the impoundments. Capping with sand and capping with both
sand and an impermeable liner were also not considered acceptable. With
the former, the sand could settle into the existing sediment due to
differences in sediment density. With the latter method, although the
impermeable liner would tend to support the sand, the adverse impact
of’ the liner on the bottom sediment layer (i.e., the development of’
anaerobic sediment layer with possible gas generation) was considered
sufficient to eliminate this alternative.
Capping with sand and a permeable liner was eliminated from
further consideration because there is no evidence that this arrangement
will eliminate the transfer of oxygen demand, toxins, or nutrients from
the sediment layer to the water column.
Sediment removal is a viable improvement alternative that would
significantly reduce sediment oxygen demand rates and sediment
concentrations of toxics. Disposal of the dredged material from
Perryville, Langer’s and North Grosvenordale Ponds is an important issue
related to sediment removal. As was presented in Table 3-13, the results
of the EP toxicity tests conducted on the sediments at Langer’s and North
Grosvenordale Ponds comply with RCRA standards and are not considered to
be hazardous. An EP toxicity test was not conducted on the sediments at
Perryville. Since pollutant concentrations at Perryville are close to
the concentrations found at Langer’s and North Grosvenordale Ponds, it is
expected that EP toxicity test results on the sediments from Perryville
will also be close to those results for Langer’s and North Grosvenordale
Ponds. Thus, the excavated sediments from Perryville Pond will likely be
classified as nonhazardous by EP toxicity standards. This assumption
must be confirmed by an EP toxicity test, prior to disposal of the
dredged material. Polycyclic aromatic hydrocarbons (PAHs) are not
‘4-37
-------
specifically regulated and therefore PAH concentrations can not be used
to classify the sediments to be excavated at Perryville, Langer’s and
North Grosvenordale Ponds. Preliminary discussion with Mass DEQE
indicates that mitigating measures such as hydraulic dredging, siltation
control and control of effluent from sediment dewatering basins would be
advisable during dredging and disposal. Further investigation is
advisable to assure that sediments containing PAH compounds will be
dredged and disposed of properly.
It is probable that the dredged material is nonhazardous and can
be brought to a landfill or applied to the land for disposal. According
to Mass DEQE guidelines, the sediments in Perryville Pond are classified
as Type II sludge and the sediments in Langer’s and North Grosvenordale
Ponds are classified as Type III (P310 CMR 32, Hearing Draft Regulations
for Land Application of Sludge and Septage). State classification of
sludge depends on the sediment’s metals and pesticides concentrations,
with Type III containing the highest concentrations.
Massachusetts permits the land application of Types II and III
sludge, subject to several restrictions. Types II and III sludge cannot
be applied to crops which are to be consumed by animals or humans within
30 days. There must be a minimum of 3 feet from the bottom of
application to the top of’ the groundwater table. Application of Types II
and III sludges is limited to soil types ranging from sandy loazns to
silty clays which have pHs greater than 6.5. The slope of the
application site must not be greater than 8 percent. In addition,
institutional guidelines help to regulate the selling, sampling and
transportation of Type II and III sludges.
The landfill in Thompson, CT may have the capacity to hold the
sediments to be removed from Langer’s and North Grosvenordale Ponds.
Both the Webster and Dudley, MA landfills are full and are not available
to accept the dredged sediments from Perryville Pond. Provided the state
of Connecticut agrees, the Thompson landfill would be large enough to
accept the dredged material from Perryville. Otherwise, it may be
necessary to identify a new site in Massachusetts for the Perryville
sediments.
14 38
-------
The feasibility of using any of the remaining alternative methods
at each of the three impoundments, Perryville, Langer t s Pond and North
Grosvenordale, was evaluated by considering the technical applicability
of the alternative and the impact of the alternative on the primary
intended use of each impoundment. Due to the physical and chemical
characteristics of the sediments, analysis is predicated on two major
assumptions: that normal landfill disposal of the excavated sediments
would be possible, and that resuspended sediments would not have long-
term adverse impacts on the quality of water in the water column or on
TABLE 1j_7 SITE-SPECIFIC FEASIBILITY OF
SEDIMENT CONTROL ALTERNATIVES
Impoundment
Alternative Sediment Control Method
Wetlands
Isolation
and
Channel Impoundment
Primary Use Excavation Excavation
Perryville
Wetland Habitat
*
Langer’s Pond
Wetland Habitat
*
North
Grosvenordale
Recreation
*
*Feasible alter
native for this site
plant life in wetlands. The findings of this analysis are shown in Table
As is shown in Table 14_7, two approaches to sediment removal were
considered in this EIS; complete excavation of the impoundment and
excavation of the river channel only. Complete excavation of sediments
in Perryville and Langer’s Ponds was considered but eliminated from
further consideration due to the numerous acres of wetland habitat which
would be lost to excavation. The State and Federal regulatory agencies
involved in this SEIS effort recognize the importance of wetlands as
habitat for fish and wildlife, and have expressed an interest in
maintaining the wetlands that exist in the Perryville and Langer’s Pond
impoundments and, to the extent they exist there, in North
Grosvenordale. If these wetlands are to be protected, then sediment
4-39
-------
control through the excavation of the entire sediment bed, either
mechanically or by dredging, is not possible since it would destroy the
ecosystem which supports the wetlands in these impoundments. The
destruction and subsequent replacement of the wetlands has also been
deemed unacceptable. Therefore, in order to both preserve the wetlands
and prevent migration of sediment, nutrients and contaminants from the
wetlands to the pond area, the wetlands at Perryville and Langer’s Pond
would be isolated by placing a physical barrier (steel sheeting) between
them and the open water area. The top elevation of the steel sheeting
would be just above the sediment bed to restrict sediment movement across
the barrier, but permit the exchange of some water between the pond area
and the wetlands. At North Grosvenordale, such a method is not
necessary, as the wetlands are minimal and can simply be avoided.
To provide a reduction in SOD exertion within Perryville and
Langer’s Ponds or impoundments downstream, the sediments within the
channel sections of these impoundments would be removed. Since these
impoundments are not presently equipped with low level outlets, there is
no feasible way to drain them for excavation during the low flow summer
months. (Such an approach would also not be desirable from a wetland
protection standpoint either.) For this reason, channel sediment
excavation would be undertaken by hydraulic dredging in Perryville and/or
Langer’s Ponds as required. The isolated wetlands would still have high
SODs and probably low DOs, as is natural in a productive wetland, but
their impacts on the riverine water should be minimal as there would be
minimal mixing between the channel and the wetland areas.
As was indicated in Table the alternative method of sediment
control that has been identified as most feasible for North Grosvenordale
is impoundment excavation. Since this impoundment can be dewatered
through a sluice way at the dam, and there are not extensive wetlands
that would be impacted during dewatering, excavation could be undertaken
during the dry season with low flow channelization as well as by
hydraulic dredging.
Water Quality Impacts of Sediment Control . In order to evaluate
the long—term impacts of sediment control measures on water quality,
several different combinations of’ sediment control in the three
I -j 4 O
-------
downstream impoundments were modelled with STREAM7B with a 7Q10 of 1!L8
cfs. This initial evaluation was undertaken to determine the effects
that sediment control in each of the impoundments would have on the
system as a whole and, consequently, where sediment control should be
implemented.
To assess water quality impacts, the reduction in SOD due to
sediment control measures was estimated. Future SOD rates were estimated
based on historical SOD measurements from the French River. Past
measurements of SOD in the French River were presented in Table 3 .1l4.
The 1975 measurements indicated SOD rates of 0.92 g/m 2 /day in Perryville
and 1.91 g/m 2 /day in North Grosvenordale, with higher SOD rates measured
in 1978 and 1985. Upstream of the Webster and Dudley treatment plants
the 1975 SOD measurements were slightly lower, ranging from 0.76 g/m 2 /day
to 1.28 g/m 2 /day. With implementation of AWT and sediment removal in
Perryville, Langers and North Grosvenordale Ponds, it is expected that
SOD rates in these impoundments can be reduced to a level on the order of
that measured in 1975 upstream of Webster and Dudley. Thus, an SOD rate
of 1.0 g/m 2 /day was used to estimate water quality with implementation of
AWT and sediment control.
Approximate average SOD rates for river bottom sediments reported
in “Rates, Constant and Kinetics Formulations in Surface Water Quality
Modeling” (EPA-600/3—78--105, 1978) range from 0.07 g/m 2 /day for mineral
soils to 7.0 g/m 2 /day for cellulosic fiber sludge. Sewage sludge SOD in
the immediate vicinity of an outfall is reported to range from 2 to 10
g/m 2 /day, with an average of g/m 2 /day. “Aged” sewage sludge downstream
of an outfall is reported to have an average SOD rate of 1.5 g.m 2 /day.
Estuarine mud is also reported to have an average SOD rate of
approximately 1.5 g/m 2 /day. This information indicates that SOD rates
are highly dependent on the specific nature of the sediments of
concern. Thus, historical SOD measurements in the French River provide a
reasonable estimate of projected SOD rates with implementation of
sediment control and SWT. The estimated SOD rate of 1.0 g/m 2 /day
following sediment control is within the range of values reported in the
literature, and represents the best estimate of future SOD rates.
L _L 1
-------
The first alternative evaluated was to conduct sediment control at
Perryville only. This would significantly improve water quality in
Perryville Pond, increasing the dissolved oxygen levels from a range of
1 1.8 to 6.2 mg/i with No Action to a range of 6.2 to 6.5 mg/i
(Figure 1I_8). However, the improvement in water quality would be a local
effect as dissolved oxygen would sharply decreases again in Langer’s
Pond. The dissolved oxygen concentrations at Langer’s Pond and
downstream closely follow the dissolved oxygen concentrations of the base
case No Action alternative.
The next alternative evaluated was sediment removal at both
Perryville and Langer’s Ponds. Both Perryvilie and Langer’s Ponds were
included in this scenario, since it is known that sediment control at
Langer’s Pond alone will not improve conditions upstream in Perryville
Pond. Minimum dissolved oxygen increased from 11.8 mg/i to 6.2 mg/I in
Perryville Pond and from 3.0 mg/i to 11.7 mg/i in Langer’s Pond (Figure 14 .
9). Although there is a slight increase in dissolved oxygen in North
Grosvenordale Pond, dissolved oxygen is still in violation, at 0 mg/i.
Another alternative evaluated was the implementation of sediment
removal at Perryville, Langer’s and North Grosvenordaie Ponds. Minimum
dissolved oxygen in the three ponds would range from 1.0 mg/i to 7.0 mg/i
(Figure 4-10). The lowest dissolved oxygen concentrations would be 1.0
mg/i at the North Grosvenordaie darn. Advanced wastewater treatment and
sediment removal would provide dissolved oxygen concentrations which are
much higher than those under existing conditions. However, water quality
criteria for dissolved oxygen would still be violated, so additional
improvements would be needed under these conditions.
During periods of low flow, travel through an impoundment
increases. The longer residence time in North Grosvenordale Pond during
7Q10 low flows is a critical determinant of dissolved oxygen. At times
other than periods of low flow, when the residence time is shorter, the
dissolved oxygen, as presented in Figure 3-8 and 3—9, was measured to be
a minimum of 3.8 mg/i and an average of 8.0 mg/i.
The above DO simulations include the effect that dredging would
have on the hydraulics in the North Grosvenordale impoundment. The
increased depth of the impoundment will cause changes in the residence
-------
E
AWT
Oriver 14.8 cfs
Owwtp 6.0 mgd
SOD 1.00 9/sq rn/day @ Perryvitle Pond
SOD 2.00 9/sq rn/day @ Langer’s Pond
SOD 2.00 g/sq rn/day @ N. Grosvenordale Pond
FIGURE 4-8 SENSITIVITY OF DISSOLVED OXYGEN TO SEDIMENT CONTROL
AT PERRY VILLE IMPOUNDMENT UNDER LOW FLOW (7Q10) CONDITIONS
— — — Base Case
Sedirnent Control at Perryville Pond
RIVER MILE
-------
— 14.8 cfs
- 6.0 rngd
— 1.00 9/sq rn/days Perryville Pond
- 1.00 g/sq rn/day @ Lingers Pond
* 2.00 g/sq rn/day @ N. Grosvenordale Pond
4
0
LU
-J
-J
>
— — — Base Case
Sediment Control at Perryville and Langer’s Ponds
FIGURE 4-9 SENSITIVITY OF DISSOLVED OXYGEN TO SEDIMENT CONTROL AT PERRY VILLE AND LANGER’S IMPOUNDMENTS
UNDER LOW FLOW (7Q10) CONDITIONS
14
11
LU
-J
0
0
LU
-J
-J
>
>.
LU
a.
a
LU
-J
4
0
0
z
8
4
0
LU
-J
4
0
0
z
LU
>
7
6
5
4
WATER QUALITY CRITERION
AWT
Oriver
Owwtp
SOD
SOD
SOD
10 8 6 4 2 0
RIVER MILE
2
1
-------
E
AWT
Oriver = 14.8
cfs
Owwtp = 6.0
mgd
SOD = 1.00
g/sq rn/day @
Perryville Pond
SOD = 1.00
g/sq rn/day @
Langers Pond
SOD = 1.00
g/sq rn/day @
N. Grosvenordale Pond
— — — Base Case
Sediment Control at Perryvitle, Langer’s
and N. Grosvenordale Ponds
FIGURE 4-10 SENSITIVITY OF DISSOLVED OXYGEN TO SEDIMENT CONTROL
AT PERRYVILLE, LANGER’S AND NORTH GROSVENORDALE IMPOUNDMENTS
UNDER LOW FLOW (7Q10) CONDITIONS
10 8 6 4 2 0
RIVER MILE
-------
time, flow velocity, BOD decay and reaeration, and these effects are
included in the model. It is assumed that the hydraulics of the
impoundments would not be altered significantly by sediment control in
Perryville and Langer’s Ponds, where wetlands isolation (with limited,
shallow channel excavation) is the most feasible method of sediment
control. Even though the wetland sediments would be sheeted, hydraulic
equilibrium would still be maintained.
Sediment control by either wetlands isolation or wet excavation
would have some short—term negative impacts on water quality, by Figure
disturbing the river bottom and thus resuspending the solids materials.
Suspended solids concentrations and turbidity would likely increase. It
is also possible that some of the contaminants in the sediments could be
mobilized, although this could be minimized by mitigation techniques.
After the initial implementation of sediment control, however, overall
water quality can be expected to be significantly improved.
Biological Impacts of Sediment Control . The sediment control
alternatives discussed in preceding sections afford the opportunity for
several significant changes in the biological community inhabiting the
French River.
The improvements in water quality associated with sediment control
would have little, if any, effect on the phytoplankton beyond that
associated with AWT.
In those areas excavated, i.e. in North Grosvenordale and the
channel areas of Perryville and Langer’s Pond, the existing benthic
conmnrnity would be destroyed and a new type of community would
subsequently colonize the new bottom substrate. A few opportunistic
species may dominate at first, but within a relatively short time frame a
more diverse, stable community would become established. The character
of the new benthic community would be primarily dependent on the type of
substrate which remains, but it would probably closely resemble the
communities sampled in cleaner upstream areas of the French River. Due
to the longer-term positive impacts on overlying DO and the removal of
potentially toxic material, the benthic organisms which recolonize the
excavated area would be less stressed than those which presently inhabit
the ponds. As discussed with respect to the No Action alternative, they
-------
would also be receiving less organic “food” input than has historically
been the case, as a result of upgraded solids handling at Webster-
Dudley. The benthic invertebrate community in the wetlands areas would
not be significantly impacted by sediment control, as the substrate,
detrital production, and overlying water quality would remain
undisturbed.
Sediment control in the three impoundments would incur both
positive and negative impacts on the warmwater fishery of the river.
Actual implementation of the sediment control measures would have
adverse, but temporary effects on the fish. These effects would occur as
a result of increased suspended solids concentrations (causing DO
depletion and turbidity), mobilization of contaminants arid, where
sediments are removed, the elimination of benthic organisms which provide
food for many fish. The dry excavation alternative for North
Grosvenordale, whereby the impoundment would be drained for at least one
summer while sediment removal took place, would obviously preclude the
survival of fish populations in the pond until it is refilled and
restocked. At the present, North Grosvenordale Pond supports a fish
population which includes perch.
Longer-term impacts of sediment control on the warmwater fishery
would be significantly more positive. The maintenance of higher DO
concentrations would eliminate the occasional fish kills and stressed
areas which presently occur and which would continue to occur, with less
frequency, after AWT is implemented. It should also enhance the
diversity of the fish community, as those species which can not tolerate
low DO would be able to survive and reproduce. In excavated areas,
greater depths would increase the fish habitat and would enhance survival
during winter freezes. The removal of contaminants from these areas
would also benefit the health of the fish population and would reduce the
potential for trophic magnification of the contaminants.
The wetland areas, which would be physically isolated with
sheeting, would retain their sediments and associated SOD and
contaminants. The fish habitat in these areas would therefore continue
to be stressed. However, the cover and food which the wetlands provide
for fish and other aquatic organisms would be preserved. The top
L _)47
-------
elevation of the sheeting will be equal to that of the existing
wetland. Consequently, with seasonal high flows of water, the sheeting
between the vegetated wetlands and the channel areas will permit the
normal passage of fish and other fauna, (as currently exists) between
habitat-types. In addition, some of the sheeting will be perforated,
creating the opportunity for limited horizontal groundwater movement
similar to that which currently exists.
Due to the fact that the feasibility of the various methods of
sediment control was evaluated with wetlands protection as one of the
criteria, the implementation of the measures selected should not have a
significant adverse impact on wetlands in the impoundments. The
extensive areas of rooted vegetation in Perryville and Langer’s Pond
would be retained, but isolated from the channel areas to prevent
sediment transport. As mentioned previously, hydraulic exchange would be
maintained such that natural water level fluctuations and seasonal
overflows could continue to sustain these ecologically important areas.
This alternative would also continue to facilitate the release of
detritus from the wetlands to the surrounding waters, and would maintain
a valuable and productive habitat for wildlife and waterfowl. The
opportunity would, however, continue to exist for the biomagnificatiori of
contaminants from the underlying sediments, and for the transport (and
potential trophic magnification) of these contaminants into other parts
of the ecosystem.
Socioeconomic Impacts of Sediment Control . The costs of the
applicable alternative sediment control methods are shown in Table 11-8.
These costs provide for all labor, materials, contractors’ overhead, and
profit and include a 10 percent allowance for engineering and 25 percent
for contingencies. Although state aid may be available through
legislative appropriations and lake restoration or related programs, it
is expected that some of the costs of sediment control in the
impoundments would be the responsibility of the towns involved.
Costs for wet excavation (dredging) provide for: purchase of
dredging and auxiliary equipment; development of gravity settling
facilities consisting of settling and flocculation basins; and the
present worth of operating costs covering labor, fuel and chemicals. The
1448
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TABLE I -8 COSTS OF SEDIMENT CONTROL
IMPOUNDMENT
EXCAVATION
ISOLATION
WETLAND ISOLATION
AND
CHANNEL EXCAVATION
Wet
Wet
With Wet
With Wet
Settling With Direct
Settling With Direct
& Hauling Pumping to
Dry
& Hauling Pumping to
to Disposal Disposal
to Disposal Disposal Site
Site Site
Site
Perryville
$3311,0 00
$1,760,000 $689,000
Langer’s Pond
$33k,0 00
$1,361,000 $600,000
North
Grosvenordale
$5,887 ,000 $2,011,000
$3, 699,000
-------
costs for the excavation alternatives assume a twenty mile round trip
haul distance to dispose of excavated sediments.
Since a larger proportion of the costs of the wet excavation
alternatives are incurred by providing gravity settling facilities and by
hauling the excavated sediments to a final disposal site, a second
approach was also assessed. Under this approach, the excavated materials
would be pumped directly to a final disposal site located approximately
3 miles from the excavation area (assuming a suitable site could be
located). With this arrangement, the costs for development of gravity
settling facilities as well as the cost of a twenty mile round trip haul
di3tanCe could be eliminated. As indicated in Table -8, the estimated
costs for this arrangement are considerably less than for settling and
hauling.
Dredging of the sediments and isolation of the wetlands at the
impoundments would result in short term impacts while work is in
progress. The duration of the wetlands isolation work would be short-
lived and the impacts during this phase would be minimal. Sediment
excavation would be a longer process. There would be an increase in
traffic on local roads by heavy equipment, but local roads are such that
the traffic would easily be absorbed. There are a few residences near
the impoundments that could be impacted by noise, dust and odors from the
dredging and diking, but for the most part, the area is buffered by
natural vegetation. Some new road accesses to the ponds may be required,
and there would have to be clearing of vegetated areas to provide access
for heavy equipment as well as temporary storage of machinery.
With the settling and hauling approach to sediment removal, there
would be a need to transport the dredged sediments to a local disposal
site; a new landfill site would have to be designated if existing
landfills are not able to receive the dredge material. The designation
of a new landfill would require state permits.
acts of Sediment Control on Recreational Resources and Use
Attainability . There would be little impact on recreational use of the
impoundments at Perryville and Wilsonville (Langer’s Pond) as a result of
sediment control, as there is presently little use of these sites for
4-5O
-------
swimming, fishing or boating. Removal of the sediments at North
Grosvenordale would improve water quality, provide deeper water and
improve access, permitting enjoyment of the site for swimming, fishing
and boating. Some facilities may need to be provided (e.g. bath houses,
beach) to fully realize this recreational potential. Improving access
would permit use of the pond areas for hiking and other passive
recreational activities. The warmwater fishery and aquatic habitat would
also be enhanced. Thus, this alternative would result in the attainment
of desired uses in the river.
Impacts of Sediment Control on Archaeological and Historic
Resources . As described in Chapter 3, there has been a potentially
important historical and archaeological resource identified in the
vicinity of’ the village of North Grosvenordale. This consists primarily
of an old mill site. The sediment control alternatives would have no
impacts on this resource, particularly since it is visible and easily
avoided. For those alternatives requiring improvement of access roads
and the storage of heavy equipment or other material near the site(s), an
intensive survey will be required to satisfy the requirements of 950 CMR
70 prior to implementation of the alternative to avoid impacting any as
yet undiscovered historical or archaeological resources.
Regulatory and Institutional Constraints of Sediment Control . At
Perryville, sediment removal work must comply with the Webster floodplain
regulations which require compensation for any loss in the flood carrying
capacity of the French River. A Massachusetts Wetlands Protection permit
would be required for both the dredge work and the wetlands isolation. A
Section 140U permit from the U.S. Army Corps of Engineers would be re-
quired if’ dredged sediment is deposited below the ordinary highwater mark
or bulldozed within the riverbed. The issue of a specific sediment
disposal site location would be addressed in the 40 4 permit
application. A Massachusetts Waterways License and Permit (Ch.91) from
the Division of Waterways in DEQE would also be required. A landfill
permit from DEQE and site designation for disposal from the local board
of health may be necessary for disposal of the material excavated from
the ponds. As discussed previously, the Webster, MA landfill probably
does not have enough capacity. Further, if the material in the sediments
L ..5 1
-------
is determined to contain hazardous wastes (which is unlikely), a
temporary generator permit would be required and the spoils would have to
be trucked to a licensed disposal site by a licensed transporter.
At the two impoundments in Connecticut, work would have to be done
in compliance with the Thompson floodplain regulations, which requires
compensation for the loss in flood carrying capacity of the river.
Sediment removal and wetlands isolation would require a wetlands permit
from the Thompson Conservation Commission and a Section 140 14 permit from
the Army Corps of Engineers. A permit from the Connecticut Department of
Environmental Protection (DEP) would be required under the authority of
Section 361 of the Connecticut General Statutes.
The wet excavation alternative for North Grosvenordale would
require the designation of a nearby site for dewatering, and this site
would require approximately 8 acres of land. The wet excavation
alternative, which entails hauling of sediment to a landfill, would
generate 100,000 cubic yards of spoil, 3 times per year over a 3 year
period. (The pumped volume would be similar). The dry excavation
alternative would generate 2140,000 cubic yards of material over an 8
month period. All of these alternatives would require the designation of
a disposal site in the study area. Some of the material could be
distributed as landfill cover. During dry excavation, the impoundment
would be drained, thus there could be adverse impacts from odors and
aesthetic impacts from the exposed sediments. Improved road access would
be required for the wet excavation alternative only.
I acts of Instream Aeration in Perryville, Langer’s Pond and North
Grosvenordale I oundments
General . Artificial stream aeration has been considered as a
partial solution to river DO problems for over 50 years (Usage et al.,
1966). With the more recent emphasis on higher river DO standards,
instream aeration has received increased consideration, particularly when
DO improvements are required for short periods of adverse river me
assimilative capacity.
14-52
-------
Artificial aeration could be used, in conjunction with advanced
wastewater treatment, during low flow periods within specific problem
areas along the French River.
Engineering Feasibility Associated with Instrearn Aeration . In
this section, the engineering feasibility of instream aeration is
assessed, based on the state ambient DO standard of 5.0 mg/i for the
French River; STREAM7B model predicted river DO levels under 7Q10 low
flow conditions with AWT and no algal photosynthetic oxygen production;
and an analysis of the performance of previous laboratory and river
installations for both mechanical surface aerators and submerged air
diffusers.
As indicated in the water quality modeling presented in Chapter 3,
the minimum DO standard of 5.0 mg/i would likely be violated under the
above critical low flow conditions within the Perryville, Wilsonville
(Langer’s Pond), North Grosvenordale and Grosvenordale impoundments.
Accordingly, the objective of’ instream aeration would be to increase DO
levels within these impoundments above 5.0 mg/i, during periods of
summertime low flow.
Instreani and/or laboratory studies have been conducted previously
by Kaplovsky et al., (19624), Kalinske (1965), Usage et al. (1966), Conway
and Kunike (1966), Whipple et al. (1969) and Whipple and Coughlan (1970),
using mechanical surface aerators and/or submerged air diffusers. In
addition, oxygen transfer rates of commercially available treatment plant
aeration systems are published by their manufacturers. However, aeration
system transfer rates are typically specified for standard conditions,
i.e., 200 C ambient water temperature, 760 mm Hg atmospheric pressure,
zero mg/l ambient DO concentration at aeration unit, and clean ambient
water quality. Therefore, for use in this analysis, the published
transfer rates (efficiencies) were converted to ambient low flow
conditions for the French River before the assessment of engineering
feasibility was made.
Usage et al. (1966) and Yu (1970) developed methods for converting
aeration unit oxygen transfer rates determined under field test
conditions to corresponding values under standard conditions. These
conversions were made by Yu (1970) using the following expression:
L -53
-------
R Rt (C ) 20 / [ (C b—CJ (TF) (a) (1)
where; R 5 oxygen transfer rate under standard conditions
(C 5 ) 20 saturation DO concentration under standard
conditions (9.02 mg/i)
(C 3 )t saturation DO concentration under field test
conditions
TF temperature correction factor 1.025 (t20)
b specific DO solubility (1.0)
a = specific oxygen transfer rate (0.85)
= oxygen transfer rate under field test conditions
Cm = DO concentration at the aeration unit
Substituting the above values for (C 5 ) 20’ TF, b and a into
equation (1) yields the following expression:
R 5 Rt F Rt ( 9 •O 2 )/(Cs_Cm) (1.025) t—20 (0.85)
The conversion factor, F, is plotted in Figure 14_li as a function
of the test water temperature and DO deficit at the aeration unit. It is
seen that oxygen transfer rates (lb 02 per hp-hr) determined at low
ambient water temperatures and small ambient DO deficits at the aeration
unit convert to much higher rates under standard conditions. This is due
to the fact that the rate of oxygen transfer across air-water interfaces
is greater at higher water temperatures and larger water DO deficits.
Conversely, when published standard condition transfer rates are
converted using equation (1) in order to project the transfer rates of an
in—stream installation on the French River, the higher water temperatures
(23°C) and smaller DO deficits estimated for the aeration unit locations
on the river (compared to standard conditions of 20°C and a maximum DO
deficit) would result in much lower transfer rates than those reported,
for the same aeration unit, under standard conditions.
14-54
-------
18
17
16
15
14-
13
12
11
10
9
8
7
6
/CSAT - CUNIT = 1.6 MGIL
(FRENCH RIVER)
CSAT - CUNIT = 1 MG/L
-
3
2 mg/I
1
5
10
15
WATER TEMP.
FRENCH RIVER
LOW FLOW
20
25
TEMP °C
FIG. 4.11 OXYGEN TRANSFER RATE CONVERSION FACTOR
-------
Figure iI_12 shows the locations and extent of DO problem areas
within the downstream impoundments of the French River and the locations
and probable impacts of in-stream aeration units required to maintain
ambient DO levels above the 5.0 mg/i standard when instream aeration is
implemented with AWT only. Instream aeration was simulated by inputting
an additional reach to STREAM7B for each aerator required. The model
routine for dam reaeration was used in each new reach so as to model
reaeration due to instream aerators. One aeration unit each would be
required in Perryville and Langer’s Pond, and four units would be
required In the North Grosvenordale impoundment.
A 2.0 mg/l increase in ambient DO levels is specified across the
aeration units, based on the consideration that any additional increase
above 7.0 mg/I (ambient saturation level is approximately 8.0 mg/i) would
be extremely inefficient. As was seen in Figure 1 10, the efficiency
(oxygen transfer rate) of an in-stream aeration unit is much lower than
under standard conditions, when the ambient DO deficit at the unit is
small. For example, a decrease in the ambient DO deficit (at the
aeration unit) from 2.0 mg/i to 1.0 mg/i would result in a 50 percent
decrease in the corresponding unit efficiency. This large decrease in
efficiency is due to the rapid percent decrease in DO deficit at ambient
DO levels near saturation and the fact that a DO deficit, and hence a DO
gradient, is the force which drives DO transfer across air/water
interfaces.
Instream aeration units can be sized using the following
relationship proposed by Whipple et al. (1969):
O.22 6 Q (C -C )
dn (2)
where; Rt = same as defined previously
Q river volumetric discharge rate (7Q )0 = 20 cfs)
Cd = DO level downstream of aeration unit (mg/i)
C , DO level upstream of aeration unit (mg/i)
P power developed by aeration unit (shaft-hp)
O.22l 6 units conversion factor
4—56
-------
b
E
AWT
Qriver — 14.8
Qwwtp — 6.0
SOD - 3.50
SOD - 2.00
SOD - 2.00
Instream Aeration
cfs
rngd
g/sq rn/day @ Perryville Pond
g/sq rn/day @ Langer’s Pond
g/sq rn/day @ N. Grosvenordale Pond
at 6 Locations
BaseCase
Instrearn Aeration
* Location of Aerator
FIGURE 4-12 SENSITIVITY OF DISSOLVED OXYGEN TO INSTREAM AERATION
UNDER LOW FLOW (7Q10) CONDITIONS
1
‘14
13
12
•10
10 8 6 4 2 0
RIVER MILE
-------
In the present study, values of Rt were determined using equation
(1) to convert oxygen transfer rates reported by Yu (1970) for standard
conditions (R 5 ) to field rates corresponding to low—flow conditions in
the French River. Rates reported by lu (1970) were determined from a
field study of mechanical surface aerators and submerged air diffusers in
a highly polluted reach of the Passaic River in New Jersey. This reach
of the Passaic was also similar, in width and depth, to the downstream
impoundments on the French River.
Yu (1970) reported average standard condition oxygen transfer
rates of 2.1 lb 02 per hp-hr for a mechanical aerator and 1.2 lb 02 per
hp-hr for a submerged coarse bubble diffuser. Whipple and Coughian
(1970) have shown that fine bubble diffusers can perform much better than
coarse bubble diffusers. Accordingly, use of Yu’s rates for a submerged
diffuser is conservative. Installation of fine bubble diffusers would
likely result in transfer rates similar to those determined by Yu for a
mechanical surface aerator.
Values of’ Rt were determined for the French River downstream
impoundment aeration units using Figure 4—10 and oxygen transfer rates
reported by Yu (1970). The value of the DO deficit at the aeration unit,
(CsAT—Cuflit) was calculated as 1.6 mg/i, assuming a logarithmic increase
in the DO level from 5.0 mg/i approximately 50 feet upstream of the
aeration unit to 7.0 mg/i approximately 50 downstream of the unit. In
laboratory tests, Usage et al. (1966) found that use of the above
logarithmic increase, which is based on the aeration equation, yielded
values very close to the DO deficit measured at their test aeration unit.
The values of Rt found using Yu’s data and Figure 4-11 are 0.30 lb
02 per hp-hr for a mechanical surface aerator and 0.17 lb 02 per hp-hr
for a submerged coarse bubble diffuser.
Substituting the above values of Rt into equation (2) and solving
for the shaft horsepower required by the aeration unit, P, yields values
of 30 shp and 53 shp, for a mechanical surface aerator and submerged
coarse b ibble diffuser, respectively.
-------
As a worst case scenario, if submerged coarse bubble diffusers
were used at the 6 locations shown in Figure 4-12, then assuming an
85 percent system efficiency, a total of 312 blower shp (2141 kw) would be
required. Thus, each unit would require a minimum power source of 62-hp
(46 kw) during operation.
A schematic of a typical instreani aerator installation to be used
in this alternative is shown in Figure 14-13. Each of the six required
aerators would consist of a fine-bubble diffuser mounted approximately 3
feet off the bottom, in the middle of a 10 foot deep, 50 foot top-width
dredged and lined trench. The trench would extend across each
impoundment, except in the vegetated wetland areas.
Each diffuser would be supplied compressed air by a 50 shaft-
horsepower centrifugal blower driven by diesel engine. The air supply
system would be enclosed in a small brick and block building located near
the pond shoreline at the diffuser site.
Water Quality Impacts of Instream Aeration . Instreani aeration in
the ponds of the French River would increase base case (No Action)
dissolved oxygen concentrations anywhere from 1.0 to 5.5 mg/i. As
previously described, the base case assumes advanced wastewater
treatment, no photosynthetic oxygen production and 7Q10 low flow
conditions. Dissolved oxygen concentrations in the impoundments would
improve from concentrations of’ 1.5 to 5.5 mg/i under base case conditions
to a range of 5.0 to 7.0 mg/i with instrearn aeration.
Localized dissolved oxygen concentrations would increase with the
introduction of instrearn aeration, bringing water quality in the
impoundments up to the dissolved oxygen criteria. It would riot, however,
address any other water quality parameters, the sources of degradation,
or the contaminants in the sediments. During installation of the
aerators, sediment would be disturbed, thus increasing the impoundments’
turbidity and suspended solids concentrations. These negative impacts
during installation would, however, be temporary.
14...59
-------
B-B
/PONDSURIACE
VAR IES —CtJRJtFr4T
LINE
50
POND FLOI1
a — a
F
__I__ D FUSERL7
D l
A-A
•EXHAUST STACI
IF DIESEL
---
LINE
FIG. 4-13 SCHEMATIC OF IN-STREAM AERATION DIFFUSER SYSTEM
-------
Biological Impacts of Instream Aeration . The biological impacts
of instreain aeration are both short and long term, and are similar to
those associated with sediment control. Construction related activity
would have an adverse impact on the phytoplankton, benthic
macroinvertebrates and fish in the impoundments, due to sediment
excavation, resuspension, and general disturbance. The resultant long
term impacts, however, would be beneficial in that the improved water
quality would result in increased diversity of organisms in the sediment
and water column. Occasional low DO conditions would be eliminated,
preventing fish kills. Instream aeration would not have any impact on
the adjacent wetlands, nor on wildlife and waterfowl.
Socioeconomic Impacts of Instream Aeration . The estimated total
capital and operation and maintenance costs associated with the
alternative requiring six instreani aerators are given in Table LI..9.
These costs are for all six aeration units as described in this
section. In all likelihood, the high costs of instreani aeration would be
borne by local residents, as no state or Federal funding would be
available for such a measure.
Most of’ the other socioeconomic impacts associated with this
alternative would be short term ones, during construction. These impacts
would be similar at. all three impoundments. There would be some noise
and traffic generated, but as discussed previously, these impacts are
minor. Access would have to be improved at each site and some clearing
of vegetated areas would be required. Some sediment removal would be
necessary, but nothing approaching the quantity required by the sediment
removal alternative. The dredged materials would have to be trucked to
an off-site landfill. The volume may be low enough that it could be used
as cover in an existing landfill.
During operation, there would be noise from the pumps, however,
the pumps would run infrequently, and running time would depend on the
duration of depressed DO conditions. With instreani aeration as the only
remedial action aside from AWT, aeration would be required frequently to
maintain DO levels above 5.0 mg/l. The noise should be muffled by the
enclosure and buffered by the natural vegetation and distance to adjacent
14_6 1
-------
TABLE 4-9. INSTREAM AERATION COSTS*
Diffusers
Pipe 1200 X $50 60,000
Anchors 120’ X 200 214,000
Excavate 12,000 cy X 148,000
Backfill 148,000
Equ i prnent
Blower 36,000
Diesel 30,000
Bldg. 30,000
Roadway, Chain Link 12,000
Fence
Property (allow) 120,000
0&M 6 mos.** 36,000
Subtotal 141414,000
Engineering 10% 1414,000
Contingency € 25% 122,000
$610,000**
* Based on installation of six instreani aerators.
** First year 0&M costs only included.
land uses. If necessary, the pumps could be enclosed below ground to
provide further muffling. Access to the facilities would have to be
maintained for inspection and operation of the pumps. This would improve
access for recreational use of the ponds.
Impacts of Instream Aeration on Recreational Resources and Use
Attainability . Instreasn aeration in the impoundments would not
significantly affect the existing recreational value of these areas.
Although water quality (with respect to DO) and biological habitat would
be improved during low flow conditions, the use of the ponds for swimming
and boating would still be constrained by the limited depth and presence
of mucky sediments on the pond bottom. Although access roads provided
for construction and maintenance of the aeration facilities would improve
access for passive recreation, the aesthetic appeal of the sites may
suffer due to the addition of pump house structures and odors. Selective
planting or locating the structures below ground could mitigate this
impact.
14-62
-------
Impacts of Instream Aeration on Archaeological and Historic
Resources . The instream aeration alternatives would have no impact on
historical and archaeological resources that have been identified in the
area, as these resources are structures which are located in Wilsonville,
Perryville, and North Grosvenordale, and not in the impoundments
themselves.
Regulatory and Institutional Constraints of Instream Aeration . At
Perryville, a Massachusetts Wetlands Protection Act permit from the
Webster Conservation Commission would be required along with Section 14014
and Section 10 permits from the Army Corps of Engineers for instream
aeration. A Waterways License and Permit would also be required from the
State. At Wilsonville and North Grosvenordale, wetlands permits would
have to be sought from the Thompson Conservation Commission and
Section 14014 and Section 10 permits from the U.S. Army Corps of
Engineers. A Section 361 permit would be required from the Connecticut
Department of Environmental Protection. Operation and maintenance of the
aeration units would most likely be the responsibility of the towns.
This may make implementation of this alternative difficult, since the
towns may not have available and qualified personnel and financial
resources to assume this responsibility. Frequent checks of the aerators
would be necessary during low flow periods.
‘4—63
-------
Chapter 5
-------
CHAPTER 5
COMPARISON OF ALTERNATIVES AND SELECTION OF RECOMMENDED PLAN
General
This report specifically addresses the identified water quality
problems in that portion of the river between Webster-Dudley,
Massachusetts and North Grosvenordale, Connecticut. Three impoundments,
Perryville, Wilsonville (Langer’s Pond) and North Grosvenordale are
located within this stretch of the river.
State and Federal environmental regulatory agencies have expressed
a desire to maintain the wetlands that exist in the Perryville and
Langer’s Pond impoundments. Present planning indicates that the North
Grosvenordale impoundment will be used for recreational purposes, once
suitable water quality is attained.
The French River in Massachusetts and Connecticut is designated
for Class B inland water uses, and as a warmwater fishery. In both
states, waters designated as Class B must have good aesthetic value, be
suitable as a fish and wildlife habitat and be suitable for primary and
secondary contact recreation. Class B waters are also required to
achieve specific dissolved oxygen, temperature, pH, fecal coliform,
sludge deposits, nutrients, color and turbidity, and taste and odor
standards. The recommended plan is designed so that the French River
will meet all of its Class B water quality criteria. The inability of
the river at present to meet the Class B dissolved oxygen standard of 5
mg/l during low flows can be greatly attributed to the characteristics of
the treated wastewater and solids discharged to the river by the Webster
and Dudley wastewater treatment plants and to the high oxygen demand of
the sediments that have accumulated in the Perryvi1le, Langer’s Pond and
North Grosvenordale impoundments located in this stretch of the river.
Present planning is that the Webster and Dudley wastewater
treatment plants will be combined and upgraded to advanced treatment
levels. Elimination of the sludge discharge at Webster has already been
initiated. Both of these measures will appreciably improve the dissolved
5-1
-------
oxygen characteristics of the French River during the critical low flow
suntner months. However, this analysis and that of the EPA advanced
treatment review process indicate that, even with the upgrading of the
Webster-Dudley wastewater treatment facilities, a minimum dissolved
oxygen concentration of 5.0 mg/i cannot be maintained at critical low
flow conditions within the three downstream impoundments. This
deficiency is attributed to the existing wastewater discharges at Webster
and Dudley, the oxygen demand that is exerted by the sediments which have
accumulated wtthth these impoundments and the long residence times in the
impoundments under low flow conditions.
o arison of Alternatives
A detailed description of each of the alternatives that have been
identified to improve water quality conditions in the French River basin
has been presented in Chapter U. Along with the principal engineering
features and technical feasibility, the anticipated impacts, both
positive and negative, in terms of water quality, biology, socioeconomic
and recreational resources and historical/archaeological features have
been identified. This chapter describes how the various alternatives
were analyzed and compared to develop a plan that will meet the principal
objective of this project, which is compliance with water quality
standards in the French River and its impoundments downstream of the
Webster-Dudley wastewater treatment plant, while minimizing impacts on
valuable resources. The principal engineering features of each of the
alternatives are sni rized in Table 5-1. Table 5-2 presents the changes
in dissolved oxygen concentrations, as predicted by the water quality
modeling, that would occur throughout the French River as a result of
each of the final alternatives. Figure U-i shows the water quality
conditions as a result of the No Action alternative, which assumes
implementation of Advanced Wastewater Treatment (AWT) at Webster-
Dudley. While the water quality standard of 5.0 mg/i of dissolved oxygen
would be met iniuediateiy downstream of the future plant, dissolved oxygen
between Perryville and North Grosvenordale Ponds would range from zero
5-2
-------
otar p-i
1*01* 18 1*0 FEWTIRFS
caq’WnuoceI c i Atotmat lA bs
QI IANTI It
J 1JANT I rn AOtAOW CIJNSIAUCT 1(111 00ElJL
u’CONr OF PRil1FCT WAIE 0IAL P4AIEAIAL ACCESS N eAL MAltitleL TOM!.
OEAEOtiTAtii)l SHOAL! tIE 50. IF FttI CTTNSIlAa— EXCAPA IEII AEVOINUl Ft UAAAEL MATEHIAL CONSIAQLI1Y41SPACIS OiSIiAtAArCE ILWAIEA15c PAQJLCT
ALIFANAIIAF IWPOOW34ENT AFQ!JIitlil FAPISEIT OdAwoQeef 1113ff tIde lO0 I fl) 3 ) AOAQI 1t0 3 1 NOISE 013CR 0)51 or SEOIWFM1S SItE COSTS OTAFA
LiSt FLOW Auttueuiiie minimal tAt new lb 2— 4 aloe, MA WA NA NA Minor construction NA NA 1411 ,000
AOG4ENtATIOW LaAe around shoreline drawdoan impact associated with
To 72 CFS periphery entOsure proposed culvert modification —
of Lake construction duration
will be brief.
SFO It4EtI I same NA NA small aee,unt - 1104,000
CONT AOL during during
Wetlands Perryville WA MA MA I t A n, NA caastrc— driniog at
isolation Pond ctiac sheet plI Ing
Wetlands minimal MA WA 4-8 ton. 22,000 00,000 2,000 24,000 same MA Sane same to be 8,0 acres bt,3613,000
Isolation for access cc yds during ainieiaad
0 Chattel road at end cytst— by hydrau—
Eacacatian at 8 aos. ractian lit dredging
le/settlina 0
seal mgI
Wetlands tI N NA MA 4—a toe, 22,000 12 .000 none; poet same MA Same ease to be 4.0 acres Otu4A,i)Q0
Isolation S ci to during mInimized
& Chattel denateriag cohen- by hpdrau—
tacecetian site raction lit dredgIng
Iw/p&anpiagt
Wetlands Langers Pond NA MA NA I ‘a. NA same MA NA small ae,aunt — 1034,000
Isalatian during during drivIng
canst— at sheet piiing
ruth lam
Wetland mInimal NA NA I-S eon, 10,000 40,000 2,000 11.000 same MA Same same; ta te 3 acres 11,361,000
isolatIon for attest cc yds SF during minimIzed by
0 Chattel raad end 0 t coast— htdreaiic
Outstation 2 toe. ractian dredging
la/settling 0
haul lag!
-------
T E .l 4 nhuuiN.d)
ENOIP RN I P(ATI S
C I ’ ALT ATIAPS
Quest) T V
QUAsI It
B004
STRI T I o.
00E O I 1 E
Qf
PROJACT
MATERIAl.
MATERIAl.
ACCESS
esot.
NATERIAI.
TOTAL
DEVEITETATION
ALTERNATIVE 1I0)iti0)AIPIT REQuIRED
SIOIELIME
E0)00ED
NO. 0) FEE t C 4STRI .C—
CI 1ANOWN lION Ti
EXCAVATE))
iY0 I
REQUIRED ITT QtfAV .
ItO 3 ) ROAD)
MATERIAL
ITO 3 )
CONSTI41JCTIQN
NOISE 000f
INAACTS
OUST
DISTiaV*MPCE
Of SEDIMENTS
OfUATEffIeG
SITE
PROJECT
COSTS OTHER
Wet florAl. n ,InI iI
Eucaustlon Orostenordel. for
(m/nsttiieg 6 acc..e road
haul log)
Dry
Eucavetlon
PcrrtoilIe, olnicel for NA
anqer’ s construction
end North of pus.
Oro.nno.-dal. hou;inq on-
ponds sham
/yr over
0—6 ysers
nOne) SUeR)
5 muSh to
d e net.r I ng/
dl sposRI
sit’
240,000 .04 . 1 st . OSs Sinilel
o ver Chart short
I I so p.riod P. . . t ,*
1; to Is 4.2 ecrss
.in l.i Zcd
b using
hydreul It
dredg l nq
Nose; to be 5.7 ocr.,
.ini .) t d
b using
PlydraVi IC
dr e dgIng
minima) when Non.
50 1 ’V Is
r.tii),d;
such less
Allen set
I on
NA NA No NA Sf 1 10,000 ssn .I—p.ro .annot
piec ,n .er,t of
of diffuser
pipes In pond.
O aerators
resu I r.d,
4.0 lend,
isolation
I DnannaI
Eucenet lo.,
i s/puen leg)
sos .; to be 2 acres
.ini.) 0.4 by
hydra..) IC
dr.daing
Wet NA NA NA 3-6 yr.,
Encenetion
in/pumpIng)
.50 ) 115 NA MA NA I-S eon, 10.000 20,000 - none) sos. NA N V
Pond pump 3 .1. during
to dnat.r- tosser-
leg sit. ruction
NA NA 3-h yrs 240,000 2)6,000 3000 100,1700 ,Inhinb) NA ,iniNAi
yd 3 , 3 times
24 ) 1,000 23,000 - .Inim.I NA mInim.)
NA NA EstIrs 8 sot, 240.000 NA
pond
dra I mud
NA NA
Sf100,000
55,847,0)10
S2,0)I.000
40.699,00)1
I P4-ST VEAM
AE.IAT ills
VItA Awl
10) IV
-------
TA&E 5 —I ( .tInuud)
E f IJtEI t l ID FEATIJ 1ES
I’ARI5GI W NL1El IATIVES
QUART I T V
OXANTITY
BORRI)4
CONSTNI tIOf4
IX tEO SE
AMOUNT OF
eqOJECT
MATERIAL
MATERIAL
ACCESS
HAUL
MATERIAL
TOTAL
JEVEGETATIOA
SHORELINE
NO. OF F
EEF CONSTI 1LIC—
EXCAVATED
ItEQUIItEX
1FF ONAVEL
MAtERiAL
CONSTRUCTION
If#’ACTS
DISTLItBAtICE
DEWATERIHO
PHO ECT
ALTERNATIVE I’B’OIJNONENT REQUIItVU
EXMOSEO
ORAWD V
TION TIME
IYX )
IVO I
ROAD)
ITO 3 )
NOISE OOON
DUST
OF SEDIMENTS SITE
COSTS OTHER
n,inIn, i for NA
construction
of ouep
hous I nq
onshore
North ninintal
Grosvenordalo for
Pond construcn ion
of ounp
nouN I nq
onshore.
Ilotos: VA Rot Anpllcable
Costs for eli 5 unIts to be used in the 3 Iopoutdnnents
NA NA No NA %300,OUO sennl—peroanent
placenent of
diffuser pipes
In pond. 3 aerators
required.
NA NA No NA P200,000 s.nnf-p.raan.nt
pIaC..nent of
diffuser PiPes
In pond. 2 aecator,
required.
With M IT at) Lenqers
Sod intent and North
Control GrOsvernor—
dale Ponds
NA
‘IA NA
With AlT,
Sad inent
Control end
LFA To
D2CFS
NA NA
NA NA
-------
TABLE 5-2
WAlER QUALITY IIFACTS
CONPARISCU (W ALIERBATI YES
DO range 11.8
to 6.0 mg/I
DO range 3.0 to
6.0 mg/i
DO range 0 tO
1 mg/i
Low Flow
Augmentation
to 22 C I ’S
Wetlands
Isolation and
Sediment Removal
In channels of
I ’erryvilie,
Langer’s Ponds
and Sediment
Removal in entire
N. (Iroavenordala
Pond
Wetlands
Isoiiit ion and
Sediment Removal
in , hannels of
Perryviile,
Langer’s Ponds
and Sediment
Removal In entire
N. Crosvenorda ie
Ponds with Low •
Flow Angumentatlon
to 22 CFS
DO range 5.5
to 6.5, no other
significant change
in water quality
DO range 6.1
to 6.9, initial
increase (short—
term) In suspended
solids and turbidity
followed by long-term
decrease
DO range 6.5 to
7 14, initial increase
(short-term) in sus-
pended solids and
turbidity followed by
long—term decrease
DO range 11.3 to
6,3 mg/if no other
significant change
in water quality
DO range i 11.8 to
6.2, inItial Increase
(short-term) in suspended
solids and turbidity
followed by long-term
decrease
DO range 5.7 to
7.0 mg/I, initial in-
crease (short-term) in
suspended solids and
turbidity followed by
long-term decrease
DO range • 0.3 to
2.5,.no other
significant change in
water quality
DO range 1.0 to
3.0 mg/i, initial Increase
(short-term) in suspended
solids and turbidity
followed by long-term
decrease.
DO range 2.5 to
11.0, InItial Increase
(short-term) in suspended
solids and turbidity
fat towed by long-term
decrease
No Action
LOCATION
ALTERNATIVE
(EACH
INCLUDES
NORTH
ANT AT
WEBSTER
P RRYVIU.E
LANCER’S
GROSVENO I IDALE
DUDLEY
WWTP)
POND
POND
POND
-------
Instream Aeration
in Perryville,
Langer’s Pond
and North
Grosvenordaie
TABLE 5-2 (Continued)
WATER QUALITY fl(’ACTS
CG1PARISON OF ALTERNATIVES
DO range 5 to 7 mg/i,
no other change In
water quality
DO range 5 to 7 mg/i,
no other change in
water quality
DO range 5 to 7 mg/i,
no other change in
water quality
Wetlands
Isolation and
sediment removal
Perryvilie,
Langer’s Ponds
and sediment
removal in entire
N. Grosvenordale
Pond with instream
aeration
Wetlands
Isolation and
Sediment Removal
in Channels of
Perryville,
Langer’s Ponds
and Sediment
removal in entire
N. Grosvenordale
Pond with Low
Flow Augmentation
to 22 CES and
Instream Aeration
DO range 6.1 to 7.1 mg/I,
initial increase (short—
term) in suspended solids
solids and turbidity
followed by long—term
decrease
DO range 6.6 to 7.3 mg/i,
initial (short—term)
in suspended solids
and turbidity followed
by long-term
DO range = 5.1 to 7.3 mg/i,
initial increase
(short—term) in
suspended solids and
turbidity followed by
long-term decrease
DO range 5.7 to 7.0 mg/i,
initial increase
(short—term) in
suspended solids and
turbidity followed
by long-term decrease
DO range 5.0 to 7.0 mg/l,
initial increase
(short-term) in
suspended solids and
turbidity followed by
long-term decrease
DO range .0 to 7.0 mg/i,
initial increase
(short-term) in suspended
solids and turbidity
followed by long-term
decrease
LOCATION
ALTERNATIVE
(EACH
INCLUDES
NORTH
AWT AT
WEBSTER/
PERRYVILLE
LANCER’S
GROSVENORDALE
DUDLEY
WWTP)
POND
POND
POND
NA Not Applicable
-------
in North Grosvenordale Pond to 6.3 mg/i in the stretch of river between
Perryville and Langer’s Ponds. Poor water and sediment quality would
continue to adversely affect organisms in or near the French River, thus
posing the threat of fish kills or bioaccumulation.
Figure 4—10 illustrates dissolved oxygen concentrations in the
river as a result of sediment control in the Perryville, Wilsonville
(Langer’s Pond), and North Grosvenordale impoundments, in addition to the
AWT “base case”. Sediment control alone is not adequate to achieve the
state water quality standards at all times. DO concentrations in
Langer’s Pond, North Grosvenordale Pond and Grosvenordale Ponds (the next
impoundment downstream) would still violate the 5.0 mg/i criterion during
the critical low flow period. In addition to DO improvements, sediment
control would result in a healthier and more diverse benthic community,
and would improve the aesthetics of the impoundments. The potential of
neoplasms or bioaccuniulation in fish would be significantly reduced,
especially in bottom feeders.
Figure 4—7 shows the improvement in water quality due to low flow
augmentation from Buffumville Lake, in addition to AWT. These data
indicate that the water quality standards would still be violated at
Langer’s Pond, and then again in North Grosvenordale and Grosvenordale
Ponds with LFA to 22 cfs. Thus, LFA by itself would not increase the
dissolved oxygen concentration levels sufficiently downstream to meet
standards. Even with LFA to 50 cfs, DO standards would still be violated
in North Grosvenordale Pond.
It has been demonstrated that neither sediment control nor low
flow augmentation alone provides sufficient water quality improvement to
meet the dissolved oxygen standards of 5.0 mg/i during 7Q10 low flow.
Although instream aeration alone has the potential to meet the dissolved
oxygen criteria, it does not address the source of the problem and it
would not provide additional water quality improvements which the other
alternatives provide, and which are important in improving conditions in
the French River. Therefore, the recommended plan for improving water
quality in the French River must include a combination of two or more
improvement alternatives.
5-8
-------
Several combinations of alternatives were considered. In all
cases sediment control was assumed since it addresses the cause of
multiple problems in the river, including high SOD, sediment nutrient
release, contamination of the river water and associated biological
impacts due to metals and other contaminants in the sediment, and
impaired recreational use due to sediment deposits.
Figure 5-1 illustrates the dissolved oxygen concentrations that
would occur in the river (at low flow) with sediment control to reduce
SOD to 1 g/M 2 /day (see chapter 14) in the three impoundments and low flow
augmentation to 22 cfs from Buffumville Lake, in addition to the
implementation of AWT. This plot indicates that the water quality will
be substantially improved over the base case throughout the French River
downstream of the combined Webster-Dudley treatment plant. However, the
DO standard of 5.0 mg/l would not be met in the North Grosvenordale
impoundment during critical low flow periods. To achieve DO standards in
North Grosvenordale it would be necessary to increase LFA to
approximately 70 cfs, as is also presented in Figure 5-1. As was
discussed in Chapter 24, the storage required at Buffumville Lake to
maintain even 50 cfs in the French River is excessive, and would
necessitate the flooding of over 200 acres of land, including 70 acres of
wetlands. Loss of these wetlands would be environmentally unacceptable,
and thus LFA to 50 cfs is not feasible. On the other hand, LFA to 22 cfs
results in only a minimal increase in stage at Buffumville Lake and
effectively no loss of wetlands, since the increase in stage would be
within the normal operating range of the reservoir (see Chapter 2).
Figure 5—2 presents dissolved oxygen concentrations, as predicted
by STREAM7B, as a result of implementing AWT, sediment control in all
three impoundments and instream aeration at Langer’s and North
Grosvenordale Ponds. Three aerators would be required for this
alternative, two in North Grosvenordale and one in Langer’s. With this
combination of improvement alternatives, dissolved oxygen concentrations
would meet the minimum water quality criterion of 5.0 mg/l in all
portions of the French River downstream of the Webster-Dudley WWTP.
5—9
-------
15
14
13
12
11
10•
B.
7
0
w
-J
-J
>
U i
4
0
Ui
-J
-J
0
U ’
-J
4
0
4
0
U’
4
a
8
AWl
Oriver 22 cfs and 70 c i ,
Q tp - 6.0 , — — — — Base Case
SOD • 1.00 g/sq rn/day Perryville pond Sediment Control. LFA to 70 c i i
SOD • 1.00 g/sq rn/day Langers Pond — — — Sediment Control. LFA to 22 c li
SOD • 1.00 g/sq rn/day N. Grosvenordale Pond
FIGURE 5-1 SENSITIVITY OF DISSOLVED OXYGEN TO LOW FLOW AUGMENTATION
FROM JMJFFUMVILLE LAKE AND SEDIMENT CONTROL AT PERRYVILLE, LANGER’S
AND NORTH GROSVENORDALE PONDS UNDER LOW FLOW (7Q10) CONDITIONS
U’
-J
0
0
WATER QUALITY CRITERION
10 B 6 4 2 0
RIVER MILE
-------
E
g
AWT
Oriver = 14.8 cfs
Qwwtp 6.0 rngd
SOD 1.0 g/sq rn/day Perryville Pond
SOD 1.0 g/sq rn/day @ L.ngers Pond
SOD = 1.0 g/sq rn/day @ N. Grosvenordale Pond
Instream Aeration at 3 Locations
RIVER MILE
— — — Base Case
Instream Aeration. Sediment Control
* Location of Aerator
FIGURE 5-2 SENSITIVITY OF DISSOLVED OXYGEN TO SEDIMENT CONTROL
AT PERRY VILLE, LANGER’S AND NORTH GROSVENORDALE PONDS
AND INSTREAM AERATION UNDER LOW FLOW (7Q10) CONDITIONS
WATER QUALITY CRITERION
10 8 6 4 2 0
-------
Another potential improvement plan is one which includes AWT,
sediment control in all these impoundments, low flow augmentation and
instream aeration at North Grosvenordale Pond only. Two aerators would
be required in North Grosvenordale. As seen in Figure 5—3, dissolved
oxygen concentrations will meet the water quality standard of 5.0 mg/l in
all portions of the French River downstream of Webster-Dudley WWTP.
Tables 5-3 and 5_14 summarize the impact of each of the
alternatives on biological and socioeconomic/recreational resources
respectively.
Alternatives Selection
The purpose of the French River improvement program is to
implement improvement alternatives which will address the source of the
problems, will improve water quality conditions to achieve standards,
will have minimal adverse environmental impacts, and can be reasonably
implemented. Using these criteria, the following paragraphs summarize
the relative merits of each alternative and the rationale for selecting
the recommended plan.
No Action . As has been discussed previously, AWT at
Webster/Dudley is considered to be the “no action” alternative, and will
be implemented as the base case. AWT addresses the main point source
pollutant load upstream of the problem areas in the French River, and is
a necessary step in implementing a long range improvement plan for the
river.
Sediment Control . The sediment control alternative also addresses
one of the sources of the water quality problems in the French River.
Although there are some institutional problems associated with sediment
control, Connecticut and Massachusetts have the potential to implement
this improvement alternative. By implementing sediment control measures,
a major DO demand (SOD) can be reduced, as well as reducing a source of
other pollutants (e.g. sediment metals, nutrients). Another added
benefit to sediment control is that it enhances the recreational value of
the impoundments through deepening and removal of aesthetically
5-12
-------
— — Base Case
Instream Aeration, Sediment Control,
* Location of Aerator
AWT
Oriver = 22 cfs
Owwtp = 6.00 mgd ___________
SOD = 1.00 g/sq rn/day PerryviUe Pond
SOD = 1.00 g/sq rn/day @ Langer’s Pond
SOD = 1.00 g/sq rn/day @ N. Grosvenordale Pond
Instream Aeration at 2 Locations
FIGURE 5-3 SENSITIVITY OF DISSOLVED OXYGEN TO LOW FLOW AUGMENTATION
FROM BUFFUMVILLE LAKE, SEDIMENT CONTROL AT PERRYVILLE, LANGER’S AND NORTH
GROSVENORDALE PONDS AND INSTREAM AERATION UNDER LOW FLOW (7Q10) CONDITIONS
‘2
Low Flow Augmentation
1:
0
‘U
-J
-J
>
>.
‘U
‘U
-J
-J
>
z
0
U,
-J
9 ,
a
‘U
-J
0
0
z
‘U
>
U)
0
z
‘4
8’
E
0
0
0
‘U
-J
0
0
z
‘U
>
U,
0
0
13
7
12
6
11
*
‘10
4
8
2
7
1
.,
/
8
.3
RIVER MILE
6
4
1
2
0
-------
TABLE 5-3
BIOt 1 OGTCAL IMPACTS
OIPAR1S I4 ALTS JIATIV
LOCATION
ALTERNATIVE
(EACH
INCLUDES
FRENCH
RIVER
NORTH
AN? A?
WEP S?ER/
RUFPUMVILLE
BETWEEN
BUFFUNVILLE
PERRYVILLE
LANGER’S
GROSVENORDALE
DUDLET
It ?P)
LAKE
PERRYVILLE
POND
P 1D
POND
organisms in and
along river will
continue to be
neoativelv impacted
limited improvement
in survival and
reoroduction of
benthic invertebrates
organ urns in and
along river will.
continue to be
negatively
imoacted
limited improvement
in survival and
reproduction of
aquatic organisms
orqanisma in and
along river will
continue to be
negatively
impacted
limited imorovement
in survival and
reProduction of
aquatic organisms
organisms in and
alonq river will
continue to be
negatively
impacted
limited imnrovement
in survival and
reproduction of
aquatic orqanisms
Wetlands Isolation NA
and Sediment in
channel of Perry—
yule and Lanqer’.
Ponds and Sediment
Removal in entire
N. Groevenordale
Pond
no significant impact
on wetlands, significant
imorovements in health
anti diversity of aquatic
organisms
no significant impact
on wetlands, significant
improvements in
health and diversity
of aquatic organisms
significant improvements
in health and diversity of
aquatic orqanisms, eliminate
of possibility of troohic
magnification of contaminant.
Wetlands Isolation NA
and Sediment
Removal in
channels of Perry—
villa, Lenger’s
Ponds and Sediment
Removal in entire
N. Grosvenordale
Pond with Low Flow
Augmentation
limited improvement
in survival and
reproduction
aquatic Organisms
no significant impact
on wetlands, significant
improvements in health
and diversity of aquatic
organisms
no significant impact
on wetlands, significant
improvements in
health and diversity
of aquatic orqanisma
significant improvements
in health and diversity of
aquatic organisms, eliminate
of possibility of trophic
maqnification of contaminant.
Wetlands Isolation
anti Sediment
Removal in
channels of Perry—
villa and Lanqer’s
Pond, sediment
removel in entire
N. (Zrosvenordale
Pond, Low Plow
Auamentat ton to 22 CFS
and Instream Aeration
limited improvement
in survival and
reproduction of aquatic
organisms
no significant impact
on wetlands, atqntficant
imorovements in health
and diversity of aquatic
aqua tic orqantsms
no significant impact
on w’tlanls, siqnificant
improvements in health
and diversity of
aquatic oroanisms
significant improvements
in health and diversity of
organisms, elimination of
of possibility of trophic
maqnification of contaminant.
No Piction tIA
low Flow
Augmentation
no significant
impact
NA
NA Not Apolicahie
-------
T ( b—a
SOCIOEQNIC WIC GtEATI4JIAL ieacts
W WtUHaSAPIVES
erasant. may
iiia-roca
hove . , ,0 advert.
leq,rotaan.tt iatnct
no significant localized
adoarsa lea-acts;
sane recreational
use Iaproo.d
Watlnnds Isolation
& Ci.annal Excavation
a/haul nq
Wetlands isolation
A thatoal Excavation
a/ouao I nq
Wetlands Isolation
& Channel Eecaontlo..
n/hauling
So.na
inflect on
Iboetson.
Stat. ney
food.
ltcratse access ntsslble clear— Note
for hibino etc. crobie.t be-
neath culu.rt; to
be alt lqatad
to usa at present, sosa le—
nay I,prooa prooenann
2000 tt of no use at prasan , soam I c—
road raxuirad access I ial-tad orooesett
beach nay to significant stort ten.
require adoarss ias.acts; and localized
aonanslon so.m rscr.atinnal
use itatruxad
short tare, none
aal I absorbed
no adoarse Ia— si lyhtly mama, minor labact tin inal and short— nova
pact, little tinning, sale— duo ty short tern.
mscraationai amy construction tie.
usa
to adoarsa ie— si iqhtly ma-moe elto n ietact so —., hot ael I
cnct; little tlshieq, salon.— due to short absorbed
recreational itq , boatity corstructiot nima
use
00 Oduarse In-
pact, little
recreational
puns, 3 dIes to de—
aat.r I nq/d isposa I
site Itead sital
CU hCtlPs IWaTI no
ElSOhClti
(1EWEUE 151100
WhtEW
lOlStitG
UtS1OEU OtWU
C.unSl.tSiCtlUN
ltdCohOSEiu
(bfcmesEU —___________
i.a000r 00
ttaT
apotiec
QEidElIt/
dtmcdyiostc
ttysistatnp
it&iist, ocee
cidutrlc 00
tfdt (RiWi 5
dLTcUtdbtIVE itW’yiJtOfEtfTS CitfMJNiItitl
piS0050i. CESS USE
OESIWEPICS
USES
USES
itJSt, E 1C 1
Lifthl tOa dS
UlSOUSti.
L00 1100 tU&tEbtttlUtl auttuavil I. Lai.a None
SEP lidEnit CUtdTNOL Parryol lie Pxnd inaact
on aebs tar
Wetiatds isolation
well absorbed
nave requirad;
done tron a
baron
on usa at present, some Ia—
amy inprnoa prtclenant
None
to
to
to
2000 tt. ot no use at trasant, so.ea in-
road required eat iniirooe prouenent
Watiatds isolation lanqers Pond
I n a -oct
on Webster
I ta-ann
on Webstar
Utom
ietacn ot
Thonoson.
Stats may
tund ,
no aduarsa Ia— sightly ina-rooe eitor intact son., hut aai I
pact; littiS tistmny, snia— dun to short absorbed
recreational city, boating cotsnruction tie.
note required;
done trot a
barge
00 us,’ at prasant, son,. le-
anness I ieitad prooen.nt
haul 0 nuts,
eoisnito or
tea lanUtili
to adoarse in— no incraasad
pact; I Itti a us. aupectad
recreational
use
nitor impact
do. to Short
construction niaa
ainor intact
due to short
construction tita
no incraasad
use eopected
amnieal atd short nona
tarn
so..., but bell haul 10 alias to
absorbed anisting or
tea landlIll
-------
W.tiand l.ni.fion
& Chenn.i f,canstlOn
5/ 5 ,_s log
Imeict on
tho,v,on.
Stone n.y
fond.
1 .E 5-4 )Q,.Floandt
I f JI IC APIS REO Atp (e& PPI ’ACTd
dLlE )A1PVtS
no us. Of presont, so.. is-
ant.., 1)010,,) PrOoSnant
no odu.rs• lie— no lncree ,ed
sect, lift). 055 sooecfs .d
recreltionsi
us.
Ory Eoceoef)on North inn ’,
Gro,u.norial. i M Pact On
Thon,p,on,
Itst. soy
fund.
)N$TREODP NER4T1I) ) P.rryc)il. Pond loans could .Ini , . ,) at s,ch
Lantern Pond pat c.sital sit.
North 4roar.oordel. end PAM coot.
lOAM 0 00)
non, non. .oisting Short term
I Insect s
during
nonth cr0—
I.ct ‘ni,.;
loot f.m. li ,-
prOor,.nt
sh.it.r* man
dntr,cf
slightly
fran e,sth.—
tic 0 00 ,8)
myron. fishing, nonentiel odor .ini ..) Ohort—t.rn; han) IS mile, for
boating, S .),. . 5mb ). dos to sell absorbed disposal, need
InS .ooonid h.di ,e,ht, nso l,ndtfli
i.nyrovsd octet Short tees; so, minim.)
nay procid. On) ,. from 0 55,
hi) Ing octet, but intregu.nt
bubbles nay b.
sef.ty issu, for
soltoning, b,atlng.
Srlncipeily ot
North Orosusodor—
NOTES,
A, Possiol. funding source foe the,. alternatic., or. not h0000 at Ohs pr,s.nt tb., ‘boever, tn ,.mn is pon,otinl
funding nourt.s o li b. ld.ntlf led.
no
Financial
o.n.enfstion
— W,fsr
Eol ,f)nt
De.ir.d
Constructi .n
I mp Ocy on
end
R oefltq
On.ilft/
ibsor.otlonel
Oss)gnsf,4
Ito) ,., odor
Sr.) fit
)5ed,ed
Material
AlternatioN innpntnd,.nts O,o ,ns ;nityiA)
Dinnohal — Aces,. Us,
hssth,flcs
Us..
Us..
dust, aft)
Local ifoads
Ois 5 on ,i
Mat Encanation North Scone
./hauiint Sro.oenord.Ie isoict on
monsoon.
Stat. sey
fend,
5s0 Eoc.uot ion
Some
no
e/p plog
in I n p a ct On
Tho M Pson,
State ‘n.y
fund.
non.
Minor Impact
to. to short
coosfruction tie.
50 5m. hot ani) pens cues to A.—
.hsorb.d satier inq/d isoosal
slt in.,d sit.)
nines for road ant... 3000 ft. road
non. •ol,tioq
long t sr,
no Adverse I ’—
strov, fishing,
noise
reguir.d
i,fron,n.on
Deco; lint),
r.ur,.tional
Use
bn.tlng, sol,—
lt
construction I i—
pacts nv,r 3—6
yrs,; sit, well
Potter,,)
flOO
non. SCistlot
ion 4 t.rt,
inprone,,nt
no adverse is—
Deco; lifti,
r,cr.ation,i
us,
improv, fishing,
boetino, sole,,—
ing
oct., e,4 oyt,r
Construction is.—
Dent. over 3—6
fri.; sit, sell
Sr... lODger tar.
th,n 0th., eit,r—
‘cstin,o, Sot sell
absurD.,)
SO ,,; 1000 f.r,
then other sitar—
net muss but sell
sbsorb,d
d,Oatsr tsar site;
pint) Ii) ni lit for
disposal, nls.d nan
landfill
d,w.f.r end dlspoa,
055rco. 3 cii.. try,,
site, ftse , ) n.e
landfill
Son., lnpron..snt no inmact or
at ,ecb site in.provs,e,ot
no advert. un-
sect; litti,
recreational
us.
mini,.,) •olnt—
tinq 035 in
eny of Oh,
ponds
emma) secant;
dIsposed It bItting
)bndf) i
4,10
cost snoring b.to.,n Faders), State end loon 0000rnmeflts, ho Oh. tim, Of ) ,,e,),n.ctetion of any ,it.rn,t)v.,
-------
undesirable sediments. This recreational improvement is especially
important at North Grosvenordale. The sediment control plan as proposed
herein will minimize any adverse impact on the wetlands in Perryville and
Langer’s Ponds.
Low Flow Augmentation . Although LFA. does not directly address a
pollutant source, it does directly address a contributing cause of
violations of the dissolved oxygen standard (i.e. low flow on the French
River). In addition to improving dissolved oxygen conditions during low
flow periods, LFA would also improve other water quality conditions by
enhancing flow during critical low flow periods. Concentrations of
pollutants from such sources as stormwater runoff and river bottom
sediments would be reduced. Also, periods of aesthetically unpleasing
stagnant water would be reduced. As has been discussed, LFA to 22 cfs
can be implemented through release from Buffumville Lake (operated by the
U.S. Army Corps of Engineers) without causing any significant adverse
impacts.
In-Stream Aeration . In-stream aeration does not address a
pollutant source, but rather directly addresses low dissolved oxygen
concentrations through mechanical addition of oxygen at specific problem
areas. Although this technique is effective in achieving DO standards,
it addresses only one symptom of the water quality problem in the
river. Other water quality issues, such as pollutants present in the
water column or sediment and overall aesthetic value of the river are not
addressed by in—stream aeration. In addition, there are certain
institutional constraints associated with in—stream aeration. There is
no Federal funding source for this alternative, and much of the cost may
need to be borne by local residents. In addition to the capital costs,
the annual operating and maintenance costs associated with in-stream
aeration are significant. It is not clear who would assume
responsibility for operating and maintaining the required aeration
units. In the event that the aeration units are not properly operated
and maintained, or should the annual expenses not be met, dissolved
oxygen improvements would immediately cease.
5—17
-------
Summary . Based on the above discussion, the order of preference
in selecting improvement alternatives is AWT, sediment control, LFA and
in-stream aeration.
Because the recommended plan is based on the predictions of a
conservative computer model, it is possible that not all measures will
need to be implemented. AWT is a necessary first step, and beyond this
action it is recommended that improvements be implemented in a phased
approach. Phase 1 includes sediment control and LFA. Phase 2 would be
implementation of in-stream aeration. If Phase 1 is implemented, and
dissolved oxygen standards are met during 7Q10 low flow conditions, it is
recommended that Phase 2 not be implemented. If, however, Phase 1 has
been introduced and dissolved oxygen concentrations are still not 5.0
mg/i or higher, then instream aerators should be installed.
Description of the Recomended Plan
The recommended plan, in conjunction with an upgraded Webster-
Dudley wastewater treatment plant, has been selected to provide adequate
dissolved oxygen levels in the French River downstream of the Webster-
Dudley facility and to preserve/achieve the desired uses of the three
impoundments. In developing the recommended plan, various alternatives
were first considered with respect to their ability to provide required
levels of dissolved oxygen concentrations within the reach of the French
River under consideration. Since analysis indicated that no one
alternative would achieve the desired objective, the recommended plan
suggests that several applicable alternatives should be combined and
implemented in a sequence which will maximize the efficacy of the
alternatives while minimizing the time elapsed before improvements are
realized. The recommended sequence of alternatives has been developed in
consultation with the regulatory agencies and other interested parties.
In addition to the implementation of AWT at the Webster-Dudley
Wastewater Treatment Plant, the recommended plan consists of two phases
as outlined below. Phase 2 will be implemented only if improvements due
to Phase 1 do not increase dissolved oxygen to a minimum of 5.0 mg/l.
5-18
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Phase 1
• Implement low flow augmentation from Buffumville Lake.
• Isolate wetlands at Perryville and Langer’s (Wilsonville)
Ponds.
• Excavate (dredge) sediment in channels at Perryville and
Langer’s Ponds.
• Excavate dried sediment in North Grosvenordale Pond.
Phase 2
• Install two aerators in North Grosvenordale Pond
Implement Advanced Wastewater Treatment . Advanced wastewater
treatment at the upgraded Webster-Dudley wastewater treatment plant will
provide a nitrified effluent which will result in the reduction of the
effluent’s oxygen demand. Sludge processing with belt filter presses and
landfill disposal is presently being implemented. Both of these actions
should lower the oxygen demand on the French River and correspondingly
improve the dissolved oxygen concentrations in the river under low flow
conditions. The upgraded plant, anticipated to go on line by 1990, is an
integral part of the “no action” alternative since it is already required
by the Clean Water Act.
Implement Low Flow Augmentation . Low flow augmentation would be
implemented as the initial activity in the recommended plan, by providing
up to 500 acre-feet of storage at Buffumville Lake. This quantity of
storage would permit the release of supplemental flow to maintain a
minimum flow of 22 cfs (measured at the Webster Gage) in the river at all
times. To achieve the 500 acre-feet of storage would require raising the
pool elevation approximately 2.5 feet in the spring, with a subsequent
maximum drawdown to normal pool elevation during a severe low flow
event. LFA will have a minor impact on approximately two acres of
wetlands along the central western portion of the lake. In this region
with low elevational relief, where emergent macrophytes are now bordered
by palustrine scrub shrub, the slightly increased duration of seasonally
elevated water levels may result in some of the scrub shrub areas
transformation to emergent macrophyte wetlands.
5-19
-------
In conformance with Section 102 (b) of the Clean Water Act and
with EPA policies, flow augmentation may be considered to achieve water
quality standards only if adequate treatment is installed to minimize
pollutants from point sources. EPA has determined that advanced
treatment as Webster-Dudley WWTP will be “adequate treatment”. Since low
flow augmentation can be implemented relatively quickly, some water
quality benefits would be realized in stressed sections of the French
River within the first year of implementation. The augmentation of low
flows to 22 cfs would improve DO concentrations in the downstream
impoundments and lessen the impact of point source discharges to the
river during low flows. If following implementation of AWT, LFA and the
proposed sediment control measures, it is found via the monitoring
program some years later that low flow augmentation is not needed to
achieve water quality standards, then LFA would be phased out of the
program or if it is determined that low flow of 22 cfs can be reduced, a
lower flow will be implemented.
Isolate Wetlands at Perryville and Langer’s Ponds . The wetlands
in both Perryville and Langer’s Ponds would be isolated by placing a
barrier between them and the pond area. While permitting water transfer,
the barrier would minimize sediment movement from the wetlands to the
pond areas, decreasing sediment oxygen demand and thereby improving
dissolved oxygen concentrations in these impoundments. The type of
material(s) to be used as barriers would be determined at the time of
implementation.
Excavate Sediment in Channels at Perryville and Langer’s Ponds .
The excavation of the sediments in the channels in both Perryville and
Langer’s (Wilsonville) Ponds would be conducted using a hydraulic
dredge. Once this action, as well as that of isolating the wetlands in
these impoundments and implementation of AWT and LFA is complete, the
impact of the existing sediment oxygen demand should be substantially
reduced, and the dissolved oxygen levels in these impoundments should
meet Class B standards under low flow conditions. The dimensions of the
channels to be excavated in the Perryville and Wilsonville impoundments
are presented in Table 5—5.
5-20
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TABLE 5-5. CHANNEL DIMENSIONS
Pond
Average
Width
Ft.
Average
Depth
Ft.
Length
Ft.
Langer’s Pond
Perryville
95
85
9.5
7.0
1800
1700
Excavate Dry Sediment in North Grosvenordale Pond . Dry excavation
of the entire sediment deposition in the North Grosvenordale impoundment
(except the small fringe of emergent macrophytes) is recommended in lieu
of dredging, as it would be substantially quicker and less costly.
Analysis indicates that Once this action is implemented, the dissolved
oxygen level in all of the downstream impoundments would meet Class B
standards under low flow conditions will increase and the recreational
value of the pond will be enhanced. Since the flow of the French River
will be diverted from the excavation areas during removal, this action
could be conducted concurrently with sediment control activities
upstream, with no adverse impacts.
Install Two Aerators in North Grosvenordale Pond . If, after
implementation of Phase 1 the post implementation monitoring program
indicates that DO standards are not met in North Grosvenordale Pond, then
installation of two aerators in the North Grosvenordale impoundment is
recommended. Instreain aerators would be installed at approximate river
miles 5.0 and 5.6 of the French River. One blower building per aerator
site, as well as access to each building, will be required to implement
instream aeration.
Impacts of the Reconinended Plan
The impacts of each of the alternatives comprising the recommended
plan have been presented in Chapter , and summarized in Tables 5-1
through 5_14. In summary, a number of benefits would be realized by
implementation of the recommended plan. The elimination of stressed DO
conditions and the dilution of point source discharges during low flow
5-21
-------
occurrences in the river would enhance the health and diversity of
benthic macroinvertebrates, fish, and other aquatic organisms. The
potential for bioaccuinulation and trophic magnification of contaminants
contained in the sediments would be reduced in those areas excavated,
while valuable wetlands habitat would be preserved. EPA intends to
monitor river water quality following implementation of the recommended
plan to document improvements from the proposed action.
In addition, access to the impoundments for recreational use would
be somewhat improved, as would the aesthetic appeal. Excavation of the
sediments in North Grosvenordale in particular would greatly improve the
impoundment’s recreational potential by deepening the pond, improving
bottom conditions, limiting macrophyte growth, enhancing the fishery, and
eliminating the potential for nutrient and contaminant transfer from the
sediments to the water column.
Some short-term, adverse impacts would necessarily be incurred
during implementation of’ the project activities. These impacts,
and reconunended measures to mitigate them, are described in the following
section. In addition, implementation of instreain aeration would include
negative socioeconomic impacts due to the economic burden of constructing
and operating the system since Federal funding and operation is not
available for this alternative. Due to these impacts the Recommended
Plan includes instream aeration only if other options are not successful
in meeting the DO standard.
The total costs of providing the recommended improvements
(supplemental to AWT) are listed in Table 5-6. Although precise funding
sources have not yet been identified, it is anticipated that the low flow
augmentation alternative would be federally funded, while possible
sources of funding for the remaining activities include the State and
Federal Clean Lakes Programs, MA Department of Environmental Management’s
Clean Rivers and Harbors Program and direct legislative grants.
5-22
-------
TABLE 5-6. COST OF flISTREAM IMPROVEMENTS
Item Cost - Dollars
Low flow augmentation from
Buffuinville Lake $ 1 417,000
Isolate wetlands at Perryville
impoundment $3314 ,000
Isolate wetlands at Langer’s
impoundment $3314 , 000
Excavate sediment in channel
at Perryville impoundment $1, 1 426,000
Excavate sediment in channel
at Langer’s impoundment $1,027,000
Excavate sediment in North
Grosvenordale impoundment $3, 699,000
Install and operate two instreain
aerators in North Grosvenordale
impoundment $200,000
Total $7,1437,000
1. Wetlands isolation and channel excavation costs assume Perryville and
Langer’s Pond work conducted together.
2. Costs for LFA and instream aeration include estimate of one years
operating cost only; annual costs may be required for additional
years of operation.
3. In stream aeration costs scaled from aeration costs presented in
Table 14-9.
14. Sediment excavation costs at Perryville and Langer’s Pond assume
excavation with settling and hauling to a final disposal site. If
the sediments can be pumped directly to a final disposal site, costs
will be reduced.
Mitigation Measures
Although the recommended improvement alternatives were selected
based upon their impacts on water quality, specifically dissolved oxygen
concentrations, another important criterion in choosing alternatives was
to avoid negative impacts, either short-term or long-term, to the maximum
5—23
-------
extent possible. This is evident in the selection of wetlands isolation,
which would have no negative impact and perhaps even have a positive
impact on wetlands, as opposed to dredging the entire impoundments at
Perryville and Wilsonville, thus eliminating wetlands from these ponds.
Channel excavation at Perryville and Langer’s Ponds is expected to
take between 14 and 8 months to complete. Sediment excavation at North
Grosvenordale is expected to last approximately 8 months. To mitigate
the disturbance effects of excavation, these processes could be regulated
by controlling hours of operation and minimizing adverse impacts of
traffic and noise. Other measures which may help to alleviate the
impacts felt at North Grosvenordale during excavation include odor
control, perhaps by covering the sediments with a sheet—like material or
with a material which could absorb the offensive odor, and dust
control, which would involve lightly sprinkling the exposed sediments
with water. Mitigation of sediment disturbance during hydraulic dredging
could include the use of silt curtains.
Negative impacts at Buffuinville Lake would include noise and dust
during the installation of the larger culvert. Since the park at
Buffuinville Lake has many visitors during summer days, by conducting any
work at Buffumville during off-season periods or off-peak hours, most of
the adverse effects would be mitigated. Mitigation of impacts on
recreational activities have been incorporated in the project outlines
and cost estimates.
-------
APPENDIX A
A-i
-------
APPENDIX A
REFE CES
Belanger, T.V. 1979. Benthic Oxygen Demand in Selected Florida Aquatic
Systems, Ph. D. Dissertation, U. of Florida, Gainsville, Fl, 210 pp.
Beuscher, J.H., 1967. Water Rights . College Printing & Typing Co., Inc.
Black, J., 1983. Field and Laboratory Studies of Environmental
Carcinogenesis in Niagara River Fish. J. Great Lakes Res. 9 (2) : 326—33k
Bowman, G.T., and J.J. Delfino. 1980. Sediment Oxygen Demand Techniques: A
Review of Laboratory and In-Situ Systems, Water Research, Vol. 1k,
149 1 1499.
Brown, Donald and Donald, Town of Thompson, Plan of Development , 1969.
Bruce Campbell and Associates, 1971, Master Plan, Town of Leicester .
Chariton, Town of, no date, Zoning bylaws
Dudley, Town of, no date, Zoning bylaws
Connecticut Department of Environmental Protectior. (CT DEP), 198k. Letter
from Guy Hoffman (CT DEP) to Sue Cobler (M&E), re: CT DEP 1984 summer
sampling data.
Central Massachusetts Regional Planning Commission, 1979, Areawide Water
Quality Management Plan .
Central Massachusetts Regional Planning Commission, 1985, Land Use
Development Plan 1985-90, Oxford’ Massachusetts .
Central Massachusetts Regional Planning Commission, 1972, Recreation and
Open Space Plan .
Farnworth, E.G. et al., 1979. Impact of Sediment and Nutrients on Biota
in Surface Water of the United States EPA-600/3-79-105, U.S.
Environmental Protection Agency, Athens, GA.
Frohne, W., 1938. Limnological of Higher Aquatic Plants. Trans. Amer.
Micros. Soc . 57 (3) 256—262.
Goldman, C. and A. Home, 1983. Limnology McGraw-Hill Book Company,
New York. 14614 p.
Governor’s Development Office, 1980, State Construction Permits Handbood ,
Commonwealth of Massachusetts.
A-2
-------
APPENDIX A
REFERENCES (Continued)
Hubbard, Edwin L., 1979. The Effects of Numerous Old Mill Dams on Lower Basin
Stream Development: 250 Years of Industrial Use of the French River and
its Tributaries, Southern Worcester County, Massachusetts. Clark
University Ph D. dissertation.
Hubbs, C. and R. Eschmeyer, 1938. Improvement of Lakes for Fishing. Mishigan
Dept. Conserve., Institute for Fisheries Research, Bulletin 2.
Leicester, Town of, no date, Zoning Bylaws
Massachusetts Association of Conservation Commission, 1982, Environmental
Handbood for Conservation Commissioners .
Massachusetts Department of Commerce, 19814, Monographs , Town of Charlton,
Dudley, Leicester, Oxford, Webster.
Massachusetts Department of Environmental Quality Engineering, 19814,
Massachusetts Wetlands and Waterways: A General Guide to the
Massachusetts Regulartory Programs , Commonwealth of Massachusetts.
Massachusetts Division of Water Pollution Control (MDWPC), November 1973.
French and Quinebaug Rivers; Part A, Water Quality Data, 1972.
Massachusetts Division of Water Pollution Control (MDWPC), November 1973.
French and Quinebaug rivers; Part B, Wastewater Discharges, 1972.
Massachusetts Division of Water Pollution Control (MDWPC), March 1975. French
and Quinebaug Rivers, 19714 Water Quality Analysis.
Massachusetts Division of Water Pollution Control (WDWPC), September 1975.
French and Quinebaug River Basin Water Quality Management Plan.
Massachusetts Division of Water Pollution Control (MDWPC), December 1976. The
French and Quinebaug Rivers; Part A, Water Quality Data, 1976.
Massachusetts Division of Water Pollution Control (MDWPC), December 1976. The
French and Quinebaug Rivers; Part B, Wastewater Discharge Data, 1976.
Massachusetts Division of Water Pollution Control (MDWPC), March 1978. The
French and Quinebaug Rivers; Part B, Wastewater Discharge Data, 1977.
Massachusetts Division of Water Pollution Control (MDWPC), September 1978.
The French and Quinebaug Rivers; Part C, Water Quality Analysis, 19714 and
1976.
Massachusetts Division of Water Pollution Control (MDWPC), January 1981. The
French and Quinebaug Rivers; Part B, Wastewater Discharge Data, 1978-80.
A—3
-------
APPENDIX A
REFERENCES (Continued)
Massachusetts Division of Water Pollution Control (MDWPC), March 1982. The
French and Q inebaug River Basin Water Quality Management Plan, 1981.
Massachusetts Division of Water Pollution Control (MDWPC), November 1983.
French and Quinebaug River Basin; French River Basin Survey 1982,
Part A-B, Water Quality and Wastewater Discharge Data.
Massachusetts Division of Water Pollution Control (MDWPC), 198k. Letter from
Mary Wheeler (MDWPC) to Richard Moore (M&E) re: MDWPC Summer 1984 French
River Sampling Data.
Massachusetts Division of Water Pollution Control (MDWPC), 1985. Letter from
Margo Webber (MDWPC) to Lisa Eggleston (M&E) re: MDWPC April 1985 French
River Sampling Data.
McGregor, Gregor I., Esq., 1981, Environmental Law . Massachusetts Continuing
Legal Education - New England Law Institute.
Metcalf & Eddy, Inc., 1969, Comprehensive Plan, Chariton, Massachusetts .
Metcalf & Eddy, inc., 198k, Facilities Plan for Wastewater Treatment,
Towns of Webster and Dudley, Massachusetts .
Metcalf & Eddy, Inc. (M&E), 1984. French River EIS; Field Report of
Impoundment Studies.
Northeastern Connecticut Regional Planning Agency, 1972, Open Space and
Recreation
Northeastern Connecticut Regional Planning Agency, 1980, Potential for
Recreational Development, North Grosvenordale Pond/Langer’s Pond,
Thompson, Connecticut .
Oxford, Town of, no date, Zoning Bylaws
Palmer C. 1969. A Composite Rating of Algae tolerating Organic Pollution. J.
of Phycology 5 : 78-82.
Roback, S. 1974. Insects (Arthropoda: Insecta). In; Pollution Ecology of
Freshwater Invertebrates , C.W. Hart and S.C. Fuller, eds. Academic Press,
New York, pp. 313-376.
Thompsqn, Town of, no date, Zoning Bylaws
U.S. Army Corps of Engineers (ACE), June 1967 (revised July 1980). Thames
River Basin; Massachusetts, Connecticut, and Rhode Island Master Water
Control Manual; Mansfield Hollow Lake, Buffuinville Lake, Hodges Village
Dam, East Brimfield Lake, Westviiie Lake, West Thomson Lake.
A—k
-------
APPENDIX A
REFERENCES (Continued)
U.S. Army Corps of Engineers (ACE), 1972 and 1977. Section 22 Studies
U.S. Army Corps of Engineers (ACE), 1972 and 1977. Section 22 Studies:
French River, CT Report.
U.S. Army Corps of Engineers, New England Division, March, 1976, Master Plan
for Recreation Resources Development, Buffumville Lake, Charlton, Mass .
U.S. Army Corps of Engineers (ACE), March 1981. Buffumville Lake, Charlton,
Mass. Forest Management Plan Master Plan Appendix B and Fish and Wildlife
Management Plan Appendix D.
U.S. Army Corps of Engineers (ACE), February 198’4. Draft Environmental Impact
Statement for Low flow Augmentation at Hodges Village Dam, Oxford,
Massachusetts. With Technical Appendices A, B & C, plus addendum to
Appendix A.
U.S. Army Corps of Engineers (ACE), July 19814. Buffumville Lake Water Quality
Evaluation Update.
U.S. Department of Agriculture, 1927. Soil Survey of Worcester County,
Massachusetts.
U.S. Environmental Protection Agency, (EPA) 1975. Memorandum from Peter Nolan
and allen J. lkalainen (EPA) to Dr. T.M. Spittler (EPA), re: sediment
oxygen demand (SOD) data for the French River.
U.S. Environmental Protection Agency, (EPA) 1976. “Red Book”, Quality
Criteria for Water. Office of Water and Hazardous Materials, 256 p.
U.S. Environmental Protection Agency, (EPA) 1918 (P.M. Nolan, A.F. Johnson,
and H.S. Davis, authors). Sediment Oxygen Demand - French River,
Massachusetts and Connecticut, September 1978.
U.S. Environmental Protection Agency, (EPA) 1981. New England Wetlands Plant
Identification and Protective Laws. Dredge and Fill (1404) Program.
U.S. Environmental Protection Agency, (EPA) 1983. Water Quality Criteria for
the Protection of Aquatic Life and its Uses - Ammonia (Final Draft).
U.S. Environmental Protection Agency, (EPA) 1983. Ambient Water Quality
Criteria for Dissolved Oxygen (Draft).
U.S. Environmental Protection Agency, (EPA) 19814. Technical Support Manual:
Water Body Surveys and Assessments for Conducting Use Attainability
Analyses. Volume III: Lake Systems. Office of Water Regulations and
Standards Criteria.
A—S
-------
APPENDIX A
REFER lCES (Continued)
U.S. Environmental Protection Agency (EPA), January 1985. Draft, Summary of
Findings, Advanced Wastewater Treatment Facilities Proposed for Webster
and Dudley, Massachusetts.
U.S. Environmental Protection Agency (EPA), June 1985. Report by Michael D.
Bilger and Peter M. Nolan on: Sediment Oxygen Demand, French River,
Massachusetts and Connecticut, May 1985.
U.S. Environmental Protection Agency (EPA), May 1986, “Gold Book” Quality
Criteria for Water, Office of Water Regulations and Standards.
U.S. Fish & Wildlife Service, Ecological Services Branch, 1978. Letter from
Vernon Lang (F&WS) to New England Army Corps of Engineers, 10 April 1978.
U.S. Geological Survey (USGS), 1982. Water Resources Data; Connecticut, Water
Year 1982.
U.S. Geological Survey (USGS), 1983. Water Resources Data; Massachusetts and
Rhode Island, Water Year 1983.
Walker, R.W., and W.J. Snodgrass. Modeling Sediment Oxygen Demand in Hamilton
Harbour, presented at WPCF 56th Annual Conf., October 2-7, 1983.
Wetzel, R.G., 1975. Linmology . W.B. Saunders Co. Philadelphia, PA.
A—6
-------
APPENDIX B
-------
UNITCO srAT c GOVE M. .
YE: J ’ 23, 9b riernora.riciun’:
1
“ ‘ Lc.x acc12>ifl — ‘Mi L4
Jc’ in aic ey - (t tlan 1 eli
Fr nth R v .r Suir 1t s
O : Ken Carl, Wern Lang — Con:ord FielJ Office
Arnie .Julin, HR, Newton Cornet, MA
This is to r rovide an upthte on the status of the sanples taken from
the Frendt River durinq May 1985. We are currently waiting for the first slides.
to be rett rned from the histol c y lab at RPMI. L that the cocperative
agree ent bet’ en Rc s el 1 and F cS is in plac they should he ready soon. Bile
sarç les are currently being run on the HPLC and the enclosed data are (ran
a aiysis of bile fran il1 tn br ri bullheads collected during the sanpling
trip. x ho to finish the other bile sazrples fran shiners and s ite suckers
durir the next r:onth.
The results from the bile analysis suggest that the bro bullheads in the
Perryville Reservoir are being exposed to a wide spectrum of polynuclear
aromatic hydrocartons (PM) arid that’ they are metabolizing these carpounds. The
levels of three PAH, nphthalcne, phenanthrene, nd benzo [ ajpyrene, found in the
bile of bullheads in the Perrjville Reser ir were, on the average, an order of
n gnitude higher than the levels found in bullheads fran the brth Valley Pond
(Table 1). have not at the present att ipted to identify individual ccznpounds
aria the significanos of this fir ding in ter r.s of tuz r incidenos in the fish is
as yet undetermined..
ThUe 1. The sum areaa o.E nap thalene, phenanthrene, and benzo [ a]pyrene
in bile taken from brc n bullheads.
Site
Naphthaiene
Ph nanthrene
Benzol a ]pyrene
Perryville Reservoir
?brth Vi1la e Pond
3.4±2.0
2.2 1.i
x10 8
x10 7
3.0±2.0
1.5±1.1
x10 8
x10 7
4.2±3.0
2.1±1.4
x10 7
x10 6
a- s r area is the total area of all peaks with retention times of 7 m.irLutes or
ntre. Values are neans plus/minus standard deviation.
u.:. cI3c ’ L irv o •- P..;r j.I P1.n
- G ..’ (PM
I . -...‘ I-
B—i
-------
W skr f
rssv Dale
C l ’ ‘Dt
t ’i P TA
M Sa ’cv 7
Zøca 1’..tc
l’fASS
82
4 QAj rS
P,,1
I!ø(ft
85
#1 t
b rn dr &i’(
G,,ci,,isr D.k
‘I
I
131
MecA.m,a
B—2
-------
FRENCH RIVER BIOLOGICAL SURVEY
PLANKTON DATA
Fall 1984
STATION NUMBER ---‘ B2 B3(a) B3(b) B4 B5 B7 BlO
Phytop]. ankton
CYANOPHYCEAE (Blue-Green Algae)
Non- fi 1 amentou a
Anacystis cyanae X . . .
Gomphosphaeria lacustris X X X X X X X
Fi lainentous
Oscillatoria spp. . X X X
HLOROPHYCEAE (Green Algae)
Non-f i lamentous
Ankistrodeaxnus app. . . . . X
Closterium app. X X X X X X
Cosinariwn app. . . . X
Pediastruin duplex. X 4 X X X X X
Scenedesmus app. - . . X
Scenedesrnus dimorphus-like . . . X
Scenedesmus guaciricauda-like . X X . 1 X
Staurastrum paradoxum X . . .
Volvoxapp. X . . X . X X
Fi lamentous
(chaetophora app.) . . X
Spirogyra app. X X X X X
unidentified . . . X
BACILLARIOPHYCEAE (Diatoms)
Centric diatoms
Cyclotella app. 14 41 3 3 7 3 X
Melosiraspp. X 7 X X X X X
Melosira varians X . . X X X X
Pennate diatoms
Cymbella app. . . . . X
Cyinbella (ventricosa) X
Diatomaanceps . . . . . X
Fragilaria app. X X X X X X X
Fragilaria crotonensia . . . . X X
Gc mphonema app. X . . .
Navicula app. 1 X X X
Neidiwn dubiwn . . • . X
Nitzchiaspp. X X X X X X
Pinnularia app. . . . X X
Stauroneis phoenicentron X X X X X
B—3
-------
Surirella ovalis . X
Surirella ovata X
Synedra acus . . . x
Synedra acus var. radians . . x X
Tabellaria flocculosa X X X
CHRYSOPHYCEAE
Flagellated algae
Dinobryon sertularia X X X
Dinobryon stipitatum . X
DINOPHYCEAE (Dinoflagellates)
Ceratiurn hirundinella X X X X X
Zooplankton
Rotifera
Brachionus (bidentata) . . . X x . x
Keratellaspp. X X X X X X
Polyarthra (vulgaris) . X
Trichocerca app. x
Cladocera
Bosminaspp. X X X X X
Copepoda
Cyc].opsspp. X X X . X
Nauplius larvae . X X X X x
Protozoa
Difflugia app. X x
8—4
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FRENCR RIVER BIOLOGICAL SURVEY
MACTROINVERTEBRATE TAXA LIST
OCTOBER 1984
STATION NUMBER---> B2 B3 B4 B5 B7 B9 BlO Bi B6 B8
PLATYHELMINTHES
TURBELLARIA
TRICLADIDA (Planarians) . .
PLANAR I IDAE • • •
UNIDENTIFIED . . . . . . . x x
ANNELIDA
OLIGOCHAETA (Aquatic Earthworms)
UNIDENTIFIED . .
HAPLOTAX IDA . .
TUBIFICIDAE
Limnodrilus (Hoffmeisteri) 177 158 16
(Tubifex tubifex) . .
unidentified
HIRUDINEA (Leeches)
RHYNCHOBDELLIDA
GLOSSIPHONIIDAE
Glossiphonia complanata
PHARYNGOBDELLIDA
ERPOBDELLIDAE
Erpobdella p. punctata
ARTHROPODA
CRUSTACEA
CLADOCERA (Water Fleas)
ISOPODA (Sow Bugs)
ASELLIDAE
Asellus coniinunis
AMPHIPODA (Scuds)
HYALELL IDAE
Hyalel].a Azteca
GANMARIDAE
Ganunarus lacustris
HYDRACARINA (Water Mites)
SPERCHON IDAE
Sperchonopsis verrucosa
INSECTA . .
EPHEMEROPTER.A (Mayflies) . • •
SIPRLONURIDAE •
Isonychia app. . . . . . . . . . x
- . . 2 . 1
5 32 4
2 x
2
x
• 6 1
• . x
• 7 10
x • • 471002
: : .2.. i.
• I
• .
• S
• S
x2
. S • • • . •
B-.5
-------
BAETIDAE
Baetia intercalarie
Pseudocloeon app.
HEPTAGENI IDAE
Stenonema inodestum
LEPTOPHLEBI IDAE
Leptophiebia app.
EPHEMERELLIDAE
Ephemerella dorothea
Ephemerel la rotunda
CAENIDAE
Caenis app.
• S S • S • • . .
• S • • • . . S
• . . . . . . 1 x
• S S • S S S
• . . . x . . 48 24
• S • S • • . x
ODONATA (Dragonflies,Damselflies).
ANISOPTERA (Dragonflies)
MACROM II DAE
Macromia illinoienais
LIBELLUDIDAE
Perithemis app.
ZYGOPTEP.A(Damselfliea)
COENAGRIONIDAE
(Argia app.)
Iachnura app.
• S S •
• S • •
• S S S
1 . 1 1
• S 5 7
• . S S •
• . . .
• . S • X
• . . 1
• . x x
3
PLECOPTERA (Stoneflies)
TAENIOPTERYGIDAE
Taeniopteryx burksi group
LEUCTRIDAE / CAPNIIDAE
unidentified
PERLIDAE
Paragnetina media
HEMIPTERA (True Bugs)
CORIXIDAE
Trichocorixa app.
1 4 19
• . . . . S • S • 1
• S S • • • . S • 5
• S • • • . . S • S
• . . • . . . S
• . S • • . . . x •
COLEOPTERA (Beetles)
HYDROPHILIDAE (Scav. Beetles)
Berosua app.
PSEPHENIDAE (Water Pennies)
Psephenus herricki
ELMIDAE (Riffle Beetles)
Dubiraphia app.
Macronychus app.
• . . 1
• . . •
• S S
• . . 1
. •
1
24
x
MEGALOPTERA (Dobsonf lies)
CORYDALIDAE (Dobsonflies)
Corydalus cornutus
TRICHOPTERA (Caddiaf lies)
PHILOPOTAMIDAE
Chimarta obscura
HYDROPSYCHIDAE
Cheuinatopsyche app.
Hydropsyche betteni
Macronenta app.
Symphitopsyche bifida gr.
Symphitopsyche aparna
HYDROPTILIDAE
S S S S S • S
. . . . . . . 2
x 5
• . . . • 3
• . . 1001 362 720
• . . 243123140
• . . • • 153
• . . . . 95
• . . 2 • 27
S S S S S S • .
S
x
x
203
1
1
3
• 17 4 •
S S S
S S S
. S S
B—6
-------
S • • . . 1
Oxyethira app.
PHRYGANE I DAE
Phryganea app.
BR.ACHYCENTR IDAE
Micrasema app.
LEPTOCER I DAE
Oecetis app.
• . . . • . . . S S
• . S • X . . S
• S S • • S • S S
• . . . . . • S • 3 .
• . S S S • •
• . S • S • • . 3. 1
DIPTERA (True Flies)
TIPULIDAE (Crane Flies)
Antocha app.
Tipu].a app.
CHAOBORIDAE (PHANTOM MIDGES)
Chaoborus app.
CERATOPOGONIDAE (Biting Midges)
Bezzia group
SIMULIIDAE (Blackflies)
Simuliwn app.
Simulium vittatuin
HIRON0MIDAE (Midges)
(TANYPODINAE)
ClinotanypUs app.
Procladius sublettei 10
Thienemanniznyia group
(CHIRONOMINAE)
Chironoinus app. 6
CryptochironornUS fulvus gr. 1
Dicrotendipes nervosus (I)
Dicrotendipes nervosus (II)
Endochironomus nigricans
Glyptotendipes . lobiferus
Microtendipes caelwn
ParatanytarsUs app.
Polypedilwn illinoense
Polypedilum nr. scalaenum
RheotanytarsUS exiguus gr.
(ORTHOCLADI INAE)
Brillia flavifrons?
Cricotopus bicinctus
Eukiefferiella discoloripes
Nanocladius spiniplenus
Orthocladius obuinbratus
RheocricotopUS (robacki)
Synorthocladius semivirens
EMPIDIDAE
Hemerodromia app.
• . . • .
• . . . S
1
x x 1
x
33
2 . x
38 2
33
3
• • 2
• • 24
.
• . x
3 . . 3.
• . 62
6 1
18
• . . 3
• 5 2 3.
• . x
• • • 3.
: : : : : : ;
1 .
1
4
1
1
22
• 1
37
S
• 1
• 1
2 1
4 1
• S S
2 .
• 1
1
• S
10 14
• S
35
1 9
1
10 24
3.
MOLLUSCA
GASTROPODA (Snails & Limpets)
PROSOBRANCH IA
HYDROBI IDA
Amnicola limosa
PULMONATA
PHYS IDAE
Physella heterostropha
PLANORB I DAE
Gyraulus circuxnstriatu s.
ANCYLIDAE (Limpets)
15
xix
• • S S S X
• S • • S •
B-7
-------
Ferrissia (walkeri) . . . . . . . 2 . 2
PELECYPODA (Bivalves) . . . . . .
HETERODONTA
PISIDIIDAE (Fingernail Clams) . . . . . .
unidentified 3 1 . . . . . 18 5
ID tentative in reference used
( ) Species determination tentative
Bezzia group Symphitopsyche bifida group
Bezzia spp. S. bifida
Palpomyia app. S. bronta
Probezzia app. S. morosa
S. walkeri
Thienemannimyia group Taeniopteryx burksi group
Arctopelopia app. T. burksi
Conchapelopia app. T. maura
Telopelopia okoboji
Thienemannimyi a app.
Xenopelopia tincta
B—8
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APPENDIX C
RESPONSIVENESS SUMMARY
c —i
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PART C-i.
DRAFT EIS COMMENTS
AND RESPONSES
C-2
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STATE OF CONNECTICUT _____
DEPARTMENT OF ENVIRONMENTAL PROTECTION
YEARS
August 19, 1985 1985 & 1986
Mr. Ronald Manfredonia
Water Quality Branch
U. S. EPA Region I
JFK Federal Building
Boston, Massachusetts 02203
Dear Mr. Manfredonia:
I s vuld like to offer the following administrative comments following our
review and discussion of the Preliminary Draft Supplemental EIS on the French
River restoration program.
1. The conclusions of the study are consistent with those of earlier
studies conducted under the auspices of the State/EPA Working Group on the
Interstate Transport of Pollutants. The report lends further support to
implementation of low flow augmentation, advanced treatment at Webster and
Dudley, and sediment control in the impoundments. Water quality studies of the
French River have spanned 15 years, and initial recon ndat ions have not been
fundamentally altered by recent studies. It is time to conclude the study
phase and seriously pursue implementation.
2. In regard to the sequencing of program elements, reccirurend that low
flow augmentation be undertaken iirEnediately. The supplemental EIS indicates
that low flow augmentation can be accomplished at Buffuxnvile relatively
quickly at a reasonable cost. Augmentation of sunarer flows will provide for
interim water quality inprovenents before completion of advanced treatment and
sediment control. After complete implementation of the restoration program,
low flow augmentation will provide benefits in addition to dissolved oxygen
improvements. These include dilution of potentially toxic metals, ixre rapid
flushing of impoundments reducing algal bloom potential, and providing sane
margin of safety in the event of treatment plant operational problems.
Sediment controls in the impoundments should be ixiplenented as one project,
with dredging being iirplenented at Perryvifle followed by Wilsonville, then
! rth Grosvenordale. Sediment controls should be undertaken after solids
handling problems at Webster are corrected, but could be accomplished before
completion of advanced treatment.
3. The need for water quality surveys following inpleirentation of each
stage of the project has not been justified. The water quality surveys and
nodel exercises which have been done provide adequate justification for program
iir lementation. We are concerned that recommendations for additional studies
will only serve to delay inpleuentation further.
Thank you for your consideration of these comments.
Sincerely yours,
67 d 2V%J
Robert L. Smith
Phone: Assistant Director
RLS: job 165 Capitol Avenue • Hartford, Connecticut 06106
An Equal Opportunity Employer
C—3
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FRENCH RIVER PRELIMINARY DRAFT EIS
RESPONSE TO COMMENTS FROM CONNECTICUT
DEPARTMENT OF ENVIRONMENTAL PROTECTION
AUGUST 19, 1985
The Connecticut Department of Environmental Protection has expressed
its support of the recommended plan and strongly urges that
implementation of the recommended improvement alternatives begin as soon
as possible.
C- i l
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DEPARTMENT OF THE ARMY
NEW ENGLAND DIVISION. CORPS OF ENGINEERS
424 TRAPELO ROAD
WALTHAM. MASSACH USETTS 02254-9149
EPLV TO
Jlovember 19, 1985
Planning Division
Impact Analysis Branch
Mr. Larry MacMillan
Environmental Protection Agency
Environmental Evaluation Section
J.F.K. Building
Boston, Massachusetts 02203
Dear Mr. MacMillan:
He have reviewed your Draft Supplemental Environmental Impact
Statement (EIS) for the French River Cleanup Program in Massachusetts
and Connecticut. Enclosed are general and specific comments on your
document.
A number of project activities will require a Department of the
Army permit under Section 404 of the Clean Rater Act. Should these
be implemented or any temporary or permanent fill be placed in any
waters or wetlands, a Department of Army permit will be required. Re
urge you to contact Mr. Gene Crouch at (617) 647—8491 as soon as
possible to determine our permit requirements. PLease understand
that processing a permit presently takes an average of two to three
months.
He thank you for the opportunity to review and comment on your
supplemental Els. Should you have any questions please contact
Mr. David Tomey, of my staff, at 647—8139.
Sincerely,
Joseph L. Ignazio
Chief, Planning Division
Enclosure
c—s
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Copies furnished to the following people:
Mr. Vern Lang
U.S. Fish 8 Wildlife Service
P.O. Box 1518
Concord, WE 03301—1518
Ms. Valerie A. Talmadge
Mass. Historical Comm.
80 Boylston Street
Boston, HA 02115
Mr. John H. Shannahan
State Historic Preservation Officer
59 S. Prospect Street
Hartford, Connecticut 06106
Commonwealth of’ Massachusetts
DEQE
Department of Hater Pollution Control
One Hinter Street
Boston, Massachusetts 02108
Mr. Chris Thurlow
Massachusetts Division of Fisheries and Wildlife
Rt. 140
West Boylston, Massachusetts 01583
Mr. Charles ‘Fredett
CT Department of Environmental Protection
Hater Compliance Unit
122 Washington Street
Hartford, Connecticut 06115
C—6
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General comments on the document.
1. The first thing that should be addressed in this document
(probably in a preface) is why this document is a “Supplemental
EIS. ” The findings of the Draft EIS on Hodges Village should be
summarized, the issues analyzed and the need for a Supplement EIS
should be clear to the reader up front. Secondly, the document
reads more like a plan evaluation (feasibility) study, than an
EIS; It presents a large array of alternatives none of which
are adequate alone to meet the objectives of the project. The
final selected plan does meet these objectives but the reader is
not aware of that until Chapter 5. The preliminary (Chapters 2,
4) and final (Chapter 5) alternative screening analyses could be
an appendix to the Supplemental EIS. The HIS could evaluate at
least the following list of final alternatives: (1) the no
action.. plan;. (2) the selected plan as proposed in Chapter 5;
(3). portions of the selected plan (Advanced Treatment and
Sediment Control) with instream aeration (a feasible alternative
even though it is dismissed as a “band—aid” measure); and (4)
the selected plan with Hodges Village as a low flow augmentatior
(LFA) source since this plan was concluded to be feasible in the
referenced HIS for Hodges Village. Other alternatives should not
be presented as final alternatives (page 2-8) since they do not
meet the primary objective of the project, i. e. to insure Class
“B” standards for the lower French River Basin.
2. Rith regard to the selected plan, the feasibility of using LFA at
Buffumville Lake should be addressed in comparable detail as that
used in the Hodges Village Draft HIS so that the reader can make
direct comparisons of the alternatives based on the issues.
3. The archaeological walk—over survey was both scoped and
implemented following only minimal coordination with this
office. Re have not been provided the resultant report for
review, but have several major concerns regarding study legality,
adequacy, and its impact upon seleätion of project alternatives
and their costs.
Firstly, we provided tacit verbal approval for the Buffumville
Lake walk over directly to the archaeological contractor, in
conjunction with a request for information. This was provided
under the assumption that no excavation would occur and no
-artifacts-would be collected. Any material which may have been
collected in ignorance of these constraints was obtained in
violation of Federal Law (P1. 96 Sec. 6 (a)), and is the property
of’ the U.S. Government, vested in NED. Proper disposition of any
such material should be negotiated with this office and the
Massachusetts Historical -Commission. As provided in PL 96—95
Sec. 4, a permit from NED will be required for all further
archaeological studies at Buffumville Lake.
C— 7
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In Spring 1985, we provided information on recorded prehistoric
and historic archaeological sites at Buffumville Lake to Metcalf’
I Eddy, Inc. for use in scoping and implementing archaeological
studies. Unfortunately, this information was not transmitted to
their archaeological consultants, but was again provided
following a separate request from them after completion of the
walk over. This oversight may have affected study adequacy.
Closer coordination of further studies is encouraged. In the
interim, four copies of the walk—over survey report should be
provided to this office for our review and comment, as
Cooperating Agency and the Federal Land Manager which would be
affected by the low flow augmentation alternative.
Kalk over survey, while a proper initial study f or large project
areas, is universally recognized as insufficient for locating
prehistoric resources in the Northeast, and an insufficient level
of study for an EIS where such resources are anticipated. It
should be noted that our archaeological survey for low flow
augmentation at Hodges Village Dam incorporated extensive
subsurface testing. The present study is in no way commensurate
with that effort. An intensive subsurface testing survey is
essential prior to issuance of the FEIS (not merely prior to
inundation as stated on p. 4—22, para. 2).
In the absence of the walk over survey report, we cannot
adequately assess the adequacy of archaeological studies thus
far, impacts upon archaeological resources (including those on
NED property) or the cost of mitigating such impacts. The
synopsis on pp. 3—87 to 3—89 indicates that a considerable number
of significant historic and archaeological resources may be
impacted by the selected plan. This could be a major significant
environmental impact which has been completely overlooked. A
firmer knowledge of such impacts could affect selection of
alternatives and their costs. This is particularly notable for
the low flow augmentation and in—stream aeration alternatives,
where the cost of archaeological data recovery at a single site
would undoubtedly exceed 1% of project cost (tables 4—4 & 4—9)
and require specific Congressional authorization.
Also, there is no indication in the report of the extent, result
or necessity for consultation with the Massachusetts Historical
Commission, Connecticut State Historic Preservation Office or
Advisory Council on Historic Preservation (as required by P.L.
89—665). Assuming that some such coordination was undertaken,
pertinent correspondence should be included in the EIS, and its
results synopsized in the appropriate sections.
4. Also, there is no Coordination/Public Involvement Section which
idehtifies the Agencies, organizations and persons to whom copies
of’ the HIS are sent as recommended by 40 CFR Section 1502.10.
The final document should include a list of all interested public
enti ties.
C—8
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Specific comments on the document:
Page 1—3, 1st paragraph:
1. Reference is made to a 1983 request from the EPA and
MDRPC to the Corps requesting a feasibility study of Hodges
Village. No record of any such request in 1983 exists.
There are initial requests from the HDHPC in 1970 and from
EPA in 1975. Other requests and indorsements followed
throughout the course of’ our study.
2. The term “destruction” of 130 acres of wetlands is
unfortunate and misleading. Nithout going into mitigation,
and what is meant by destruction, it is recommended to
eliminate the statement altogether.
3. The impacts and issues of the Hodges Village EIS should
be summarized in this paragraph.
4. The term “failure” of’ the report ——— is untrue. On this
same page is the statement that the EPA and )1DWPC requested
a study of’ Hodges Village. There was never a request Of the
Corps to study basin—wide water quality. All Corps of
Engineers reports have been specifically titled as Hodges
Village. The EPA and MDRPC maintained primary
responsibility for basin—wide water quality and alternative
solutions to problems.
Page 2—2, last para. , last sentence:
Insert “the effects of” after “It is expected that.
Page 2—3, 1st paragraph, 3rd sentence:
The significant impacts should be identified. Significant
impacts alone would not eliminate Hodges Village as a
feasible alternative.
Page 2—4, 1st paragraph:
It is indicated that LFA alternatives were narrowed down to
8 options. The Hodges Village Plan should be mentioned
since it is still a feasible option.
Page 2—8: Selection of Final Alternatives:
See general comment above.
Page 3—6:
Under the heading “Impoundment” in Table 3-1 the value for
Hodges Villages is deceiving since it indicates zero.
Either the heading should say “Permanent Impoundment” or
storage for the flood control pool should be shown.
Page 3-7, 2 nd paragraph, 2 nd sentence:
Re suggest this sentence be deleted and rewritten as
follows: “Both reservoir projects are regulated to attempt
to limit French River flows to 1,000 cm, which is
considered to be nondamaging channel capacity.
C— 9
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Page 3—11, 1st paragraph:
The concept of Biochemical Oxygen Demand (SOD) and BOD 5
should be explained to the reader.
Page 3—39, Tables 3—11, 3—13:
Considering the high values of metals (especially As, Hg,
Cr, Pb) it is hard to believe that the concentrations in the
leachate (Table 3-13) are from the same sediments (Table
3-11). Sediments should be rechecked to verify the
potential for impacts of’ land disposal. We realize that
this testing methodology is required for any land disposal
under CRA and State regulations, however, we feel that the
testing methodology developed by our Waterways Experiment
Station may be a more accurate way of determining the
potential for long term impacts. He suggest that you
contact Dr. James Brannon at (601) 634—3725 in
Vicksburg, MS.
Page 3—67, 2nd paragraph:
1. The water quality and biological conditions at
Buffumville Lake are not adequately described here.
Information in this section should be comparable to that
presented in the Hodges Village EIS.
2. In the Hodges Village £13 there was mention of water
quality problems in Buffumville. Since the subject report
is a supplement to this ElS, either that Water quality
problem should be highlighted, pointing out how it might
affect the LFA proposal or it sould be stated why it is no
longer a problem.
3. He have provided some fisheries data from Buffumville
Lake to the EPA contractor which does not appear to be
included in the text.
Page 3—87, paragraph 4:
The assertion that the recorded prehistoric site may be
below present pool appears unsupported by any data. It
should be noted that full extent, and even location, at New
England prehistoric sites is rarely determined by walk
over. Considerable portions of this site could be well
above the present pool and subject to impact by the proposed
project.
Page 3—88, paragraph 4:
The absence of dwellings on the 1795 map is most likely an
artifact of map quality, rather than actual absence of
structures. The 1795 map series rarely shows an dwellings,
even in town centers.
c—i 0
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Page 3—93
The Hodges Village Master Plan should also be mentioned.
Page 3—105, 3rd paragraph, 2nd sentence:
Our Regulatory jurisdiction includes all “waters of the U.S.
and adjacent wetlands” without exception. The statement
should be changed to reflect this and the explanation of our
404 jurisdiction should be expanded.
Page 3—105, 4th paragraph:
£ Department of’ Army permit under Section 10 of’ the Rivers
and Harbors Act of 1899 does not apply to the French River
because it is not a “navigable water”.
Federal Laws:
1. Compliance with both the National Historic Preservation
Act (PL 89—665) and Archaeological Resources Protection Act
(PL—96—95) is a requirement of this project, and should be
noted and discussed here.
2. The requirements under the Endangered Species Act should
be addressed here. The EIS should discuss whether or not
endangered or threatened species occur in the basin. You
should show evidence that you coordinated with the U.S. Fish
and Rildlife Service which is a requirement under this Act.
Page 4—8:
Under the heading “Engineering Issues Associated with Low
Flow Augmentation” there is the statement that Buffumville
is the most appropriate source for low flow augmentation.
Since a direct comparison with Hodges Village is not made,
an appropriate source is not evident in the study.
Page 4—9, 2nd paragraph, last sentence:
This sentence is inaccurate on two counts: Since October
1980 the normal opening of the center gate has been lowered
from 4—1/2 to 2 feet, and since 1974 during the summer
months one of the side gates has been raised to an opening
of 0.1 foot, resulting in the following normal gate
settings:
Summer Months — 0’ —2. 0’ —0. 1’
Remainder — 0’ —2. 0’ —0’
The reduced center gate opening ensures that significant
reservoir releases will not occur during unexpected storms.
The raising of the outside gate by 0.1 foot helps to create
a better mixing of impoundment waters during the warm
weather months.
c—il
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Page 4—14, last paragraph. 1st sentence:
The environmental impacts of drawdown could be identified
here.
Page 4—15, 1st paragraph, last sentence:
As mentioned, a 500 acre—feet storage requirement for LFA
means about a 2—1/2 foot pool level fluctuation. However,
due to the realities of the precision with phich discharge
and pool levels can be controlled at Buffumville Lake, a
3—foot pool level fluctuation would be required. This
sentence should be changed to reflect this requirement if
the LFL requirements could be met with a smaller volume that
would theoretically require only a 1—foot rise above normal
pool stage, the realities of’ operating would require a
2-foot increase.
Page 4—15, 2nd paragraph:
The area—capacity could be included to graphically give the
reader a picture of storage changes above the recreational
pool elevation.
Page 4—15, 3rd paragraph, last sentence:
It indicates here that if LFA is implemented, the Corps will
develop the details of the plan. It is possible that
another agency can design and construct the project in
accordance with Corps criteria and close review. In any
event, this plan would have to be coordinated with the
Massachusetts Division of Rater Pollution Control and EPA.
Page 4—15, “Rater Quality Impacts of Low Flow Augmentation”:
1. No description is given of’ water quality at Buffumville
Lake for either existing conditions or conditions with LFA.
Rater quality conditions at the confluence of the Little and
French Rivers are depicted, and the implication is that,
since water quality conditions there are good, they must not
be too bad at Buffumville Lake. This is not adequate. It
is not enough that there be a certain volume of water at
Ruffumville Lake available for LFA, this water must also
meet minimum DO and maximum HOD limits. This should be
addressed in the report.
2. Buffumville Lake has had problems with excessive aquatic
weed growth which has led to herbicide applications in 1972,
1976, 1977. and 1978. There is concern that if LFA is
implemented at Buffumville the increased pool depth would
make it unsuitable for aquatic macrophytes. Under that
condition, the present high nutrient levels (which had
previously allowed heavy weed growth) combined with the
C—12
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nutrients from the newly inundated areas would allow algae
blooms in the lake. Algae blooms, if they occurred, would
interfere with the lake recreational. uses of the project.
Even more important, they would cause DO fluctuations and
increased BOD levels which could negate the very purpose of
.LFL. This should be addressed in the Els.
3. The EIS should address the impacts of alternative
drawdown scenarios (e’.g. (a) 2 foot rise in pool to 1 foot
below; or (b) 3 foot rise in pool to normal elevation) in
the spring. Included in these impacts should be the effect
on nutrient levels in the pool and the consequent effects on
algae and BOD.
Page 4—17, 1st paragraph, last sentence:
The benefit of metal dilution by LFA should be analyzed in
text and shown graphically.
Page 4—17, 3rd paragraph, 1st sentence:
The impacts of LFA on phytoplankton in Buffumville Lake have
not been analyzed; thus, this statement seems premature.
Refer to comments on Rater Quality Impacts.
Page 4—18, 1st paragraph:
The impact of LFA on wetlands and upland vegetation of the
alternative drawdown scenarios cited above should be
addressed. The acreage of wetlands and uplands that wo uld
be affected under each scenario should be indicated. Low
lying upland areas 2 to 3 feet above the existing pool might
create wetland areas. The resultant vegetation distribution
should also be projected for each scenario.
Page 4—18, 2nd paragraph:
It also seems premature to conclude that no significant
impact would occur to benthic organisms at Buffumville
Lake. The degree of’ impact to benthic organisms is
dependent upon the population and species composition in the
lakes littoral area and bow extensively (in terms of time
and area) the shoreline areas are exposed. The resource nd
extent of drawdown have not been identified or analyzed in
the text.
Page 4—19, 3rd paragraph:
The above comments apply to fisheries as well. The species
which inhabit Buffumville Lake have not been identified.
The impacts of the suggested LF& alternative scenarios could
have detrimental impacts on the reproductive success of
shore spawners and fry who require cover in littoral areas
during the summer. The timing and extent of drawdown may
have an effect on the survival of a given year class. The
range of potential conditions as they relate to the species
present needs to be analyzed.
C—13
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Page 4—19
The loss and distributional changes of vegetation in the
area 2 to 3 ft. above the existing pool elevation will have
impacts to wildlife using the Buffumville Lake shoreline.
These changes in area and quality of upland and wetland
vegetation for each drawdown scenario should be discussed as
they relate to wildlife use of the area. A habitat—based
evaluation can be used to compare the 2 and 3 foot
options. The impacts of the “bath tub ring” and the
seasonality of the fluctuating pool to wildlife should also
be addressed. Mitigation of the wildlife habitat losses
would be required. The losses and changes should be
compared to the impacts discussed in the Hodges Village
alternative. Then a clear case of a preferable alternative
(from a wildlife impacts perspective) can be made.
Page 4—19, 3rd paragraph:
To the reader unfamiliar with the facilities at Buffumvi].le
Lake, a description of the bridge, its location and why it
needs to be enlarged would be helpful.
Page 4—19, 4th paragraph, 1st sentence:
Devegetation will be required.
Page 4—19, 4th paragraph, 5th sentence:
Delete “if it is necessary at all.
It will be necessary.
Page 4—20. Table 4-4:
1. Cost should include engineering and design, supervision
and administration, and contingencies consistent with those
values used in the Hodges Village ElS.
2. There is no discussion on what purpose the
microprocessor serves.
3. The $30,000 for operating costs for S months — is this
annual cost?
4. Costs for reservoir clearing should be included,
extending 2 to 3 feet above the present permanent pool
level.
Page 4—20, 1st paragraph, 2nd sentence:
The sentence is hydrologically correct. However, what is
necessary to ensure that none of these augmentation releases
are temporarily stored at a downstream waterbody, thereby
resulting in riverfiows less than 22 cfs at Hebster?
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Page 4—21, 1st paragraph, 2nd sentence:
Boating in the reservoir for Rater skiing has decreased
because the lake is shallow, making it hazardous for fast
boats and skiers. Raising the pool 3 ft. may have a
positive effect on boating depending on the degree of
fluctuation.
Page 4—21, 2nd paragraph, 1st sentence:
This says that sightseeing is becoming a more important
recreational use of Buffumville Lake and seems to imply it
is becoming the most important recreational use. If that is
the case, the appearance of the bath tub ring caused by a 2
to 3 foot seasonal pool level fluctuation and associated
devegetation should be discussed in the report.
Page 4—21, 2nd paragraph, 2nd sentence:
Fluctuations of’ the pool level would not be infrequent but
rather would be an annual event, because the reservoir would
be operated on a rule curve.
Page 4—21, 2nd paragraph, 3rd sentence:
Re feel a 3 ft. fluctuation in the pool would significantly
impact the beach area.
Page 4—21, 2nd paragraph, 5th sentence:
It should be mentioned that devegetation would have a
negative impact on fish and wildlife values at the lake and
may decrease related active and passive recreation
opportuni ties.
Page 4—21, 2nd paragraph, 6 sentence:
The clearing of the ring around the pool could have a
greater impact on aesthetic appeal of the reservoir. The
EIS assumed a 1 foot pool raising whereras, a 3 foot pool is
needed; thus, the size of the ring may increase
significantly.
Page 4—22, “Regulatory & Institutional Constraints...”
1. A permit may not be required from the local
conservation commission since the project is entirely within
Federal lands and, therefore, may not have to comply with
local or State regulations.
2. To clarify the management license, it should be stated
that this is for fish and wildlife purposes.
3. Depending upon the extent of’ work, a Section 404 permit
may be required.
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Page 4—22, Paragraphs I and 2:
I. In accordance with the National Historic Preservation
Act, archaeological resources which would be impacted by the
proposed project should be identified prior to issuance of a
FEIS, and Determination of Eligibility for inclusion in the
National Register of Historic Places obtained for each.
Such sites must be mitigated (not just surveyed) prior to
project implementation.
2. It is our understanding that removal of some sediment
may be necessary under this alternative. Upland disposal at
sites other than disturbed areas, for such material may
require archaeological investigations prior to final
disposal site selection.
Page 4-23, 1st paragraph, 2nd sentence:
The mechanical dredging alternative may not be such a bad
option if a water—tight clamshell bucket is used.
Table 4—6:
“Disadvantages” should include potential impacts on the
disposal sites chosen for any of the excavated pond
sediments.
Page 4—22 — 4—26, “Impacts of Sediment Control...”:
Discussions should include potential physical, chemical,
biological, and socioeconomic impacts of the disposal of any
excavated sediments at a given disposal site. Despite the
fact that the sediments passed the EP Toxicity tests, the
level of contaminants in the Perryville and North
Grosvenordale deserve more attention. As stated above we
suggest you contact our Raterways Experiment Station for
further information on more sensitive testing methodologies.
Page 4—23, 1st paragraph, 2nd sentence:
A water—tight clamshell bucket might cause less resuspension
and therefore may make mechanical dredging more acceptable.
Page 4—41, 1st paragraph, last sentence:
A discussion should be developed to assess the need for
“restocking” the North Grosvenordale Pond with fish. If
restocking is necessary the costs should be reflected in
Table 4—8. There is no evidence that this was coordinated
with the Connecticut DEP. Also, discuss how the addition of
the sheeting will alter the value of’ the riverine/wetland
habitat for fish and other aquatic organisms.
Page 4—4 , 2nd paragraph, 3rd sentence:
A Section 10 Permit from the Corps would not be required
(see comment Page 3-105).
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Page 4—45, last paragraph, 2nd sentence:
The Corps 3urisdiction should be clarified in this
sentence. Removal of sediment does not in and of itself
require a Section 404 permit. £ permit will be required if’
the sediment is deposited below the ordinary high water mark
or is bulldozed within the river bed.
Page 4—45, paragraph 1:
See second comment referring to Page 4-22, para. 1 & 2.
Page 4—56, paragraph 3:
See second comment referring to Page 4-22, para. I & 2.
Page 5—2:
Compariso1 s of alternatives are made; but, none is made on
an economic basis, which must include both the complete cost
and benefits of’ LFA
Table 5—1:
Under devegetation, the word “minimal” is used. Bow many
acres are involved.
Shoreline Exposed — I fdot maximum assumes just one of’ the
options described. Perhaps a range of exposed shoreline
should be given.
— what shows here for LFA has
nothing to do with construction time. What about automatic
gate control 1 culvert and devegetation?
— there is construction required for
LFL. In fact, Table 4-4 shows $471,000 worth of’
construction.
— have annual costs Ce. g. , operation and
maintenance) been included where appropriate?
Table 5—4:
— what does “indensing” mean?
c c Qfl — what does “minimal” mean?
Although this table is supposed to include socio-economic
impacts, neither the costs nor the benefits are mentioned.
Hill the benefits be equal to the Hodges Village proposal?
What is the benefit—cost ratio?
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Page 5—9, Fig. 5—2:
It appears from this figure that the 5 mg/i DO objective is
met without LFA (i.e., ART plus sediment removal) at all
points below the Rebster/Dudley treatment plant except at
Grosvenordale Pond, where the DO fails margihaily below 5
mg/i. Perhaps a site—specific measure (e.g., aeration at
Crosvenordale) or one implemented only during the limited
amount of’ time this violation would occur (the 7Q10 flow)
should be considered as the actual alternative to LFA. If
such alternatives are considered, the benefits of LFA would
be substantially smaller than those provided by EPA for the
Hodges Village report, and need to be revised.
Page 5—10:
Since the goal is to meet the 5 mg/i DO objective downstream
of the R/D treatment plants, why are LFA releases used to
bring DO levels up to 5. 5 mg/i as shown in this figure?
Perhaps a lower level of’ LFA should be investigated.
Page 5—11 “Description of the Recommended Plan”:
1. The sequencing of the proposed plan is a reversal of the
preliminary Draft in that LFA is now being recommended as
the initial step rather than the last step.
2. Since the Hodges Village plan is never described in this
supplemental HIS, it is obvious that Buffumville is
considered by EPA to be the best LFA source. But Bo]ges
cannot be eliminated as an alternative until a thorough
comparison based on equal level of detailed study is
accomplished. Not only should the complete cost and
benefits for Buffumvilie be compared with Hodges Village,
but also a more complete environmental study such as REP
should be done on Buffumville. Until this comparison is
accomplished a valid recommendation cannot be made.
3. The recommended plan gives no timeframe to the
implementation of the Buffumvi].le augmentation proposal nor
does it indicate who will pay for the work.
Page 5—16, paragraph 3, and Page 5—17, para. 3:
Potential loss of National Register eligible archaeological
and historic resources is a significant impact which would
require mitigation and possibly affect project costs and
selection of’ alternatives. This has not been addressed
here.
t — 18
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Page 5 —18, 2nd paragraph:
1. The wildlife impacts of’ devegetation should also be
evaluated and mitigated, if necessary. Throughout this
report there are terms such as “minor”related to impacts,
and “only a few trees” in discussion of devegetation. These
values should be in terms of what impacts, how many acres,
how many trees, etc. On this page we see only a few trees
will be lost in devegetation, however, it is highlighted on
the same page that to avoid impacts this work should be done
during off hours. If’ impacts are minor, why is there
emphasis on doing the work during off hours, particularly
since “only a few trees” are involved?
2. Re suggest that any work be accomplished at Buffumville
Lake in October and November, after the recreation season is
over to minimize impacts to recreation and wildlife.
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FRENCH RIVER DRAFT EIS
RESPONSES TO U.S. ARMY CORPS OF ENGINEERS
REVIEW COMMENTS OF NOVEMBER 19, 1985
General Comments
General comment 1 silninary : “The findings of the Draft EIS on Hodges
Village should be summarized, the issues analyzed and the need for a
Supplement BIS should be clear to the reader up front.” Also, the
document presents a large array of alternatives, none of which are
adequate alone to meet the objectives of the project. The final selected
plan does meet the objectives, but the reader is not aware of that until
Chapter 5. As a result, Comment 1 contains suggestions for
reorganization of the chapters.
EPA response: A summary of Hodges Village EIS issues and the need
for the supplemental EIS has been developed and incorporated in Chapter 1
of the FSEIS. The purpose of the supplemental document is to evaluate
additional alternatives for solving the problems in the river to meet the
objectives of Clean Water Act. EPA believes that the organization of the
document serves this intended purpose. The heading on page 2-8 of the
DSEIS has been modified to read “Selection of Alternatives for Further
Evaluation.”
General comment 2 : “With regard to the selected plan, the
feasibility of using LFA at Buffumville Lake should be addressed in
comparable detail to that used in the Hodges Village draft EIS so that
the reader can make direct comparisons of the alternatives based on the
issues.”
EPA response: It is not necessary to provide such a level of detail
for Buffumville as was provided in Hodges Village since Buffumville does
not include construction activity and widespread destruction of habitat
that Hodges Village LFA does. However, additional information is
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suitable. Information related to wetland expanse, cover type, land use,
etc. has been included in the existing description of the Buffuniville
site. Table 2-1 has been prepared for inclusion in the FEIS providing a
comparison of impacts from the Hodges Village and Buffuniville proposals
for low flow augmentation.
General comment 3, paragraph 1 : “The archaeological walk over survey
was both scoped and implemented following only minimal coordination with
this office. We have not been provided the resultant report for review.
EPA response: A copy of the report entitled “Archaeological
Reconnaissance of the French River Quality Improvement District
Buffumville, Massachusetts to North Grosvenor Dale, Connecticut” was
provided to U.S. Army Corps of Engineers in early December, 1985. II’
additional copies of this report are needed, they will be provided.
General comment 3, paragraph 2 summary : “Any material which may
have been collected during the archaeological survey was obtained in
violation of Federal Law (Fl 96 Sec. 6(a), and is the property of the
U.S. Government, vested in NED.”
EPA response: No excavation was conducted; therefore no material
was collected.
General comment 3, paragraph 3 summary : Information on
archaeological sites was provided by the Corps to Metcalf & Eddy and was
not provided to the archaeological consultants until after their walk
over survey. “This oversight may have affected study adequacy. Four
copies of the walkover survey report should be provided to this office
for our review and comments . ..“
EPA response: Upon review of the copy provided, the Corps should be
convinced that the oversight did not interfere with the adequacy of the
study.
General comment 3, paragraph : “Walk over survey ... is
universally recognized as insufficient for locating prehistoric resources
in the northeast, and an insufficient level of study for an EIS where
such resources are anticipated ... Survey for low flow augmentation at
Hodges Village Dam incorporated extensive subsurface testing. An
intensive subsurface testing survey is essential prior to issuance of the
FEIS (not merely prior to inundation as stated on p. 4-22 part 2).”
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EPA response: Documentation of water levels at Buffumville
Reservoir show that the area to be inundated by low flow augmentation is
already inundated at various times of year to elevations of up to 13 feet
above the normal pool elevation of 1492.5 ft. NGVD. A maximum pool
elevation increase of approximately 2.5 ft. above normal pool elevation
would be required to provide 500 acre-ft. of added storage for LFA
(assuming no drawdown below the existing pool elevation during periods of
low flow). This would result in a reservoir operating level of 495.0.
The table below (Table 2-2 in the FSEIS) snmm rizes the variation in
water level in the reservoir from water year 1980 to 1984. These
increases in pool elevation occur mainly in the spring and summer
concurrent with increased precipitation and flood control measures.
BUFFUMV
1980-19814
ILLE RESERVOIR WATER
(NORMAL POOL ELEVATION
LEVELS
1492.5 NGVD)
Number of Days
Number of Days
Maximum
Pool Exceeded
Pool Exceeded
Pool
Elevation 495.0
Elevation 1492.5
Water
Year
Elevation
(LFA Elevation)
(Normal Elevation)
1980
501.0
15
205
1981
1499.6
10
185
1982
506.3
31
280
1983
5014.0
142
232
19814
506.6
30
227
This information documents that the proposed seasonal increase in
operating pool elevation is within the range of pool elevations currently
expeHenced at the reservoir. Therefore there will be no new impact to
archaeological sites since elevations produced by LFA are considerably
less than the maximum range of existing conditions. Since no impact is
anticipated, no further archaeological study is necessary.
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Implementation of sediment control alternatives in Perryville,
Langer’s Pond and North Grosvenordale Impoundments should avoid
potentially sensitive archaeological locations. If it is necessary to
impact any of the potentially sensitive locations identified in the
survey, then an intensive (locational) archaeological survey should be
conducted first to determine if the expected buried site actually
exists. Such surveys would become a part of section 4O1 permit
application.
General comment 3, paragraph 5 : “In the absence of the walk over
survey report, we cannot adequately assess the adequacy of archaeological
studies thus far, impacts upon archaeological resources (including those
on NED property) or the cost of mitigating such impacts. The synopsis on
pp. 3-87 to 3—89 indicates that a considerable number of significant
historic and archaeological resources may be impacted by the selected
plan. This could be a major significant environmental impact which has
been completely overlooked. A firmer knowledge of such impacts could
affect selection of alternatives and their costs. This is particularly
notable for the low flow augmentation and in—stream aeration
alternatives, where the cost of archaeological data recovery at a single
site would undoubtedly exceed l? of project cost (Tables 4—4 and 4—9) and
require specific Congressional authorization.”
EPA response: The walkover survey documented potential historic
resource issues at North Grosvenordale, however, the resources were
outside the area proposed for sediment control at North Grosvenordale
Pond. In addition, the archaeological impacts resulting from the
proposed LFA using Buffuinville Lake are insignificant when the present
operation of water level is considered. Even with the higher water
levels (well above those associated with LFA) which normally already
inundate the areas, scouring action is not sufficient to disrupt buried
historic resources.
General comment 3, paragraph 6 : “There is no indication in the
report of the extent, result or necessity for consultation with the
Massachusetts Historical commission, Connecticut State Historic
Preservation Office or Advisory Council on Historic Preservation (as
required by p.L. 89-665). Assuming some such coordination was
undertaken, pertinent correspondence should be included in the EIS, and
its results synopsized in the appropriate section.”
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EPA response: The Massachusetts Historical Commission and
Connecticut State Historic Preservation Office were consulted prior to
initiation of this archaeological study. Both of these agencies received
a copies of the archaeological report. They were also consulted
following their review of the report. The results of these consultation
are included in the FSEIS.
General coimnent 14 sunin ry : There is no Coordination/Public
Involvement Section which identifies the agencies, organizations and
persons to whom copies of the EIS are sent as recommended by 140 CRF
Section 1502.10. The final document should include a list of all
interested public entities.
EPA response: A list of all public coordination, meetings, etc.,
has been included as an appendix to the FSEIS.
Specific comments
Page 1-3, 1st paragraph, item 1 : “Reference is made to a 1983
request from the EPA and I4DWPC to the Corps requesting a feasibility
study of Hodges Village. No record of any such request in 1983 exists.”
EPA response: On page vi of the Hodges Village EIS reference is
made to an MDWPC letter of May 18, 1983. It was assumed (apparently
incorrectly) that this letter included the recommendation to investigate
low flow augmentation at Hodges Village. Reference to this letter will
be eliminated in the FSEIS.
Page 1—3, 1st paragraph, item 2 : “The term ‘destruction’ of 130
acres of wetlands is unfortunate and misleading. Without going into
mitigation and what is meant by destruction, it is recommended to
eliminate the statement altogether.
EPA response: We agree to delete this statement.
, Page 1—3, 1st paragraph, item 3 : The impacts and issues of the
Hodges Village ELS should be summarized in this paragraph.
EPA response: A brief sunmi ry of the Hodges Village EIS impacts and
issues has been provided in this section and the reader is referred to
the earlier Hodges Village Dam EIS.
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Page 1-3, 1st paragraph, item 14 summary : “The term ‘failure’ of the
report is untrue. This same page states that the EPA and MDWPC requested
a study of Hodges Village... There was never a request of the Corps to
study basin-wide water quality . All Corps of Engineers’ reports have
been specifically titled as Hodges Village. The EPA and MDWPC maintained
primary responsibility for basin—wide water quality and alternative
solutions to problems.”
EPA response: The text will be corrected to clarify this point.
Page 2—2, last paragraph : “Insert ‘the effects of’ after ‘it is
expected that ...
EPA response: This change will be made in the text.
Page 2-3, 1st paragraph, 3rd sentence : “The significant impacts
should be identified. Significant impacts alone would not eliminate
Hodges Village as a feasible alternative.”
EPA response: The impacts and effects of’ the Hodges Village
proposal will be summarized in Chapter 1, as stated previously. Also,
Table 1 presented previously will be incorporated in the text.
Page 2-14, 1st paragraph : “It is indicated that LFA alternatives
were narrowed down to 8 options. The Hodges Village Plan should be
mentioned since it is still a feasible alternative.”
EPA response: Due to the impacts and effects attributed to the
Hodges Village proposal, as discussed previously, it is less valid than
other options for low flow augmentation. Thus, the Hodges Village
proposal can be ruled out early. The text in this paragraph will be
modified to indicate this.
Page 2-8 : “Selection of Final Alternatives: see general comment
above.”
EPA response: See response to general comment 1.
Page 3-6 : “Under the heading ‘Impoundment’ Ifl Table 3-1 the value
for Hodges Villages is deceiving, since it indicates zero. Either the
heading should say ‘Permanent Impoundment’ or storage for the flood
control pool should be shown.”
EPA response: A footnote has been added to the table indicating
that Hodges Village is currently used for flood control storage only.
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Page 3-7, 2nd paragraph, 2nd sentence : “We suggest this sentence be
deleted and rewritten as follows: ‘Both reservoir projects are regulated
to attempt to limit French River flows to 1000 cfs, which is considered
to be nondamaging channel capacity. ‘“
EPA response: The text has been modified as suggested. The 1000
cfs figure is consistent with that stated in the Buffuinville Lake Master
Plan (1976).
Page 3-11, 1st paragraph : “The concept of Biochemical Oxygen Demand
(DOD) and BOD 5 should be explained to the reader.”
EPA response: A brief definition of BOD and BOD 5 has been added to
the text.
Page 3-39, Tables 3-11, 3-13 : “Q nsidering the high values of
metals ... it is hard to believe that the concentrations in the leachate
(Table 3—13) are from the same sediments (Table 3—11).” Sediments should
be checked to verify the potential for impacts of land disposal.
EPA response: While the sediment samples presented in Table 3—13
and Table 3-11 are from different sources, it is not uncommon for bulk
sediment metals concentrations to be several orders of magnitude higher
than EP toxicity metals concentrations. Measurements of both bulk
sediment metals content and EP toxicity metals content from the Assabet
River sediments in Acton, Massachusetts confirm this (these data have
been added to Chapter 3 of the Final EIS).
Page 3-67, 2nd paragraph item 1 : “The water quality and biological
conditions at Buffumville Lake are not adequately described here.
Information in this section should be comparable to that presented in
Hodges Village EIS.”
EPA response: The report “Buffuinville Lake Water Quality Evaluation
Update”, prepared by the U.S. Army Corps of Engineers and dated July,
1984, describes water quality conditions in the lake. A brief summary of
water quality conditions in Buffuinville Lake has been added to the FSEIS
on page 3-35, prior to the Sediment Quality section. Additional wetland
and fisheries information has been added to page 3-67 and 3—73
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respectively. The reader has also been referred to the 198L Corps report
as well as the results of a yet to be published general limnological
survey conducted by the Corps for further information.
Page 3-67, 2nd paragraph item 2 : “In the Hodges Village EIS there
was mention of water quality problems in Buffumville. Since the subject
report is a supplement to this EIS, either that water quality problem
should be highlighted, pointing out how it might affect the LFA proposal,
or it should be stated why it is no longer a problem.”
EPA response: The basis of the statement in the Hodges Village EIS
referring to water quality problems in Buffumville Lake is not clear.
Based on analyses of available operational data on Buffumville Lake and
consultation with the Corps’ Thames River Basin Manager (Bob Hanacek,
1986 pers. corn.) no significant water quality problems have existed.
Existing water quality in Buffumville Lake has been summarized in the
FSEIS. Consequently, no significant impacts are expected to be caused by
the proposed low flow augmentation project at Buffumville.
Page 3—67, 2nd paragraph, item 3 : “We have provided some fisheries
data from Buffumville Lake to EPA contractor which does not appear to be
included in the text.”
EPA response. Additional fisheries data from the Massachusetts
Division of Fish and Wildlife have been incorporated into the text.
Page 3-87, paragraph : “The assertion that the recorded
prehistoric site may be below present pool appears unsupported by any
data. It should be noted that full extent, and even location, at New
England prehistoric sites is rarely determined by walk over.
Considerable portions of this site could be well above the present pool
and subject to impact by the proposed project.”
EPA response: Since the proposed pool elevation will only increase
a maximum of 2.5 feet above the average operating level of Buffumville
(492.5 ft. NG\JD) and the present operational history of the reservoir
documents water level fluctuations in excess of four times this projected
variation, no impact associated with LFA will occur for archeological
resources. The Buffumville Lake Master Plan, prepared by the U.S. Army
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Corps of Engineers (1976) states the following: “There are no known
archaeological or historical features located within the project area or
in close enough proximity to the site to affect its popularity or use.”
Page 3-88, paragraph 14 : “The absence of dwellings on the 1795 map
is most likely an artifact of map quality, rather than actual absence of
structures. The 1795 map series rarely shows dwellings, even in town
centers.”
EPA response: As stated earlier, any impacts on historic dwellings
due to LFA have already occurred due to the existing operational strategy
of Buffumville Lake. Consequently, if such impacts have not been of a
critical nature with respect to flood control operational aspects of
Buffumville Lake, the impacts will be considerably less than those
associated with LFA.
Page 3—93 : “The Hodges Village Master Plan should also be
mentioned.”
EPA response: A reference to Hodges Village Master Plan has been
added to this section.
Page 3—105, 3rd paragraph, 2nd sentence : “Our regulatory
jurisdiction includes all ‘waters of the U.S. and adjacent wetlands’
without exception. The statement should be changed to reflect this and
the explanation of our 404 jurisdiction should be expanded.”
EPA response: The text has been modified accordingly.
Page 3-105, 14th paragraph : “A Department of Army permit under
Section 10 of the Rivers and Harbors Act of 1899 does not apply to the
French River because it is not a ‘navigable water.
EPA response: The text has been clarified to reflect this.
Federal Laws, item 1 : “Compliance with both the National Historic
Preservation Act (PL 89-665) and Archaeological Resources Protection Act
(PL-96—95) is a requirement of this project, and should be noted and
discussed here.”
EPA response: This has been added to the “Federal Laws” section.
Federal Laws, item 2 : “The requirements under the Endangered
Species Act should be addressed here. The BIS should discuss whether or
not endangered or threatened species occur in the basin. You should show
evidence that you coordinated with the U.S. Fish and Wildlife Service
which is a requirement under this act.”
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EPA response: The Corp’s Fish and Wildlife Management Plan (1981)
states that no threatened or endangered species are present in
Buffumville. This statement is based on coordination with U.S. Fish and
Wildlife Service which has confirmed this statement through oral
coninunication. This document has been cited in the revised text.
Page 4-8 : “Under the heading ‘Engineering Issues Associated with
Low Flow Augmentation’ there is the statement that Buffumville is the
most appropriate source for low flow augmentation. Since a direct
comparison with Hodges Village is not made, an appropriate source is not
evident in the study.”
EPA response: A summary of the impacts and issues associated with
the Hodges Village proposal has been added to Chapter 1. The FSEIS text
clearly states that this is no longer considered a viable alternative. A
matrix comparing Hodges Village with Buffumville has been prepared (Table
2-1 of the FSEIS). Rationale for the selection of Buffumville as the
most appropriate source for low flow augmentation is presented in Chapter
2.
Page 14 _ 9, 2nd paragraph, last sentence : “This sentence is
inaccurate on two counts: Since October, 1980 the normal opening of the
center gate has been lowered from 4—i to 2 feet, and since 1974 during
the summer months one of the side gates has been raised to an opening of
0.1 foot, resulting in the following normal gate settings:
Summer Months - 0’ -2.0’ —0.1’
Remainder - 0’ -2.0’ —0’
The reduced center gate opening ensures that significant reservoir
releases will not occur during unexpected storms. The raising of the
outside gate by 0.1 foot helps to create a better mixing of impoundment
waters during the warm weather months.”
EPA response: The text has been revised as requested.
Page 14 _ iLl, last paragraph, 1st sentence. : “The environmental
impacts of drawdown could be identified here.”
EPA response: Drawdown has been eliminated as an option in the
FSEIS based on the impacts of drawdown related to recreational uses,
aesthetic uses, wildlife and wetlands. Due to these negative impacts,
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the alternative of drawing lake level down by as much as 2. t feet was
precluded from further consideration.
Page -15, 1st paragraph, last sentence : “As mentioned, a 500 acre—
feet storage requirement for LFA means about a 2.5 toot pool level
fluctuation. However, due to the realities of the precision with which
discharge and pool levels can be controlled at Buffumville Lake, a 3-foot
pooi level fluctuation would be required. This sentence should be
changed to reflect this requirement. If the LFA requirements could be
met with a smaller volume that would theoretically require only a 1-foot
rise above normal pool stage, the realities of operating would require a
2—foot increase.”
EPA response: As is presented on pg. 1 _13 of the DSEIS, the
required low flow augmentation volume of 500 acre-ft. is based on a very
conservative estimate (the drought of record during the period 1950 to
present.) Thus, raising the operating lake level a maximum of 2.5 ft.
above the existing operating level of L 92.5 would provide for all the
storage needed for low flow augmentation.
Page 1 15, 2nd paragraph : “The area—capacity could be included to
graphically give the reader a picture of storage changes above the
recreational pool elevation.”
EPA response: A figure has been added to the FSEIS showing the
elevation-volume relationship of the reservoir. This same information is
presented in Table Z 3 of the DSEIS.
Page 4-15, 3rd paragraph, last sentence : “It indicates here that if
LFA is implemented, the Corps will develop the details of the plan. It
is possible that another agency can design and construct the project in
accordance with Corps’ criteria and close review. In any event, this
plan would have to be coordinated with the Massachusetts Division of
Water Pollution Control and EPA.”
EPA response: The text has been modified to read as follows: “...
the U.S. Army Corps of Engineers, which owns and operates the Buffumville
facilities, would develop the operating procedures of the low flow
augmentation plan. Design and construction associated with the project
would be conducted by the Corps or by another agency in accordance with
Corps criteria and review. The low flow augmentation plan would need to
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be coordinated with the Massachusetts Division of Water Pollution Control
and EPA.”
Page - .15, ‘Water Quality Impacts of Low Flow Augmentation’ item
1: “No description is given of water quality at Buffumville Lake for
either existing conditions or conditions with LFA. Water quality
conditions at the confluence of the Little and French Rivers are
depicted, and the implication is that, since water quality conditions
there are good, they must not be too bad at Buffumville Lake. This is
not adequate. It is not enough that there be a certain volume of water
at Buffumville Lake available for LFA, this water must also meet minimum
DO and maximum BOD limits. This should be addressed in the report. U
EPA response: As described in response to a previous comment (pg.
3-67, 2nd par., item 1), the existing water quality in Buffumville Lake
has been summarized based on a recent Corps data. These data indicate
that the average DO level in the reservoir is approximately 90 percent of
saturation, and is satisfactory for low flow augmentation purposes. The
BOD and DO concentrations from Buffumville that were used in the
calibration of the water quality model were based on actual field data
from Buffumville. Thus, the effects of DO and BOD from Buffumville
outflow are included in the analysis presented in the DSEIS.
Page I _ 15, ‘Water Quality Impacts of Low Flow Augmentation’ item
2: “Buffumville Lake has had problems with excessive aquatic weed
growth, which has led to herbicide applications in 1972, 1976, 1977, and
1978. There is concern that if LFA is implemented at Buff urnville the
increased pool depth would make it unsuitable for aquatic macrophytes.
Under that condition, the present high nutrient levels (which had
previously allowed heavy weed growth), combined with the nutrients from
the newly inundated areas would allow algae blooms in the lake. Algae
blooms, if they occurred, would interfere with the lake recreational uses
of the project. Even more important, they would cause DO fluctuations
and increased BOD levels which could negate the very purpose of LFA.
This should be addressed in the EIS.”
EPA response: The existing COE data do not substantiate the claim
that the nutrient concentrations are excessively high. The basin manager
stated on 31 December 1985 that there have been no documented reports of
excessive algae growth, no blooms nor no known nuisance species other
than weed control measures have been implemented. Due to the existing
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operational water level (where often over 50 percent of the time each
year the water level exceeds the normal pool elevation), any such impacts
associated with increased nutrient leaching would have already occurred
over the past years.
Page 1 _ 15 ‘Water Quality Impact of Low Flow Augmentation’, item 3 :
“The BIS should address the impacts of alternative drawdown scenarios
(e.g., (a) 2 foot rise in p001 to 1 foot below; or (b) 3 foot rise in
pool to normal elevation) in the spring. Included in these impacts
should be the effect on nutrient levels in the pooi and the consequent
effects on algae and ROD.”
EPA response: Based on earlier discussions, we will not include the
scenario of drawdown below the normal pool elevation of 1 92.5 ft NGVD due
to adverse recreational and aesthetic impacts.
Page k-17, 1st paragraph, last sentence : “The benefit of metal
dilution by LFA should be analyzed in the text and shown graphically.
EPA response: Dilution of metals concentrations in the Webster-
Dudley effluent is an incidental effect of LFA, and is not part of’ the
rationale for implementing LFA.
Page 1I _ 17, 3rd paragraph, 1st sentence : “The impacts of LF’A on
phytoplankton in Buffumville Lake have not been analyzed; thus, this
statement seems premature. Refer to comments on Water Quality Impacts.”
EPA response: This has been addressed as discussed earlier.
Page -18, 1st paragraph : “The impact of LFA on wetlands and upland
vegetation of the alternative drawdown scenarios cited above should be
addressed. The acreage of wetlands and uplands that would be affected
under each scenario should be indicated. Low lying upland area 2 to 3
feet above Lhe existing pool might create wetland areas. The resultant
vegetation distribution should also be projected for each scenario.”
EPA response: Additional information on wetlands and upland
vegetation has been incorporated in the FSEIS in Chapter 3 in the
“Bioldgical Conditions” section and in Chapter )4 under “Biological
Impacts of Low Flow Augmentation”. This information is summarized in the
following paragraphs.
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The existing wetlands surrounding Buffumville Reservoir comprise
approximately six acres. This includes all areas of emergent macrophytes
as well as areas of palustrine scrub shrub and palustrine forest. Based
on the existing operational strategy of water level control within the
reservoir over the past five (or more) years, these wetlands have become
established as zones that are spacially static in terms of relative areal
extent, when contrasted with the temporal dynamic changes in water levels
within the reservoir. Only those emergent macrophytes located along the
central western edge of the reservoir might be subject to habitat/cover
type change should water levels be operated as recommended to accommodate
low flow augmentation. The central western area is the largest expanse
of flat low area which, with additional inundation, might result in the
change from palustrine scrub shrub to emergent macrophyte wetland
habitat/cover type. If seasonal levels of water were more than two feet
higher in elevation than water levels as recorded over the past five
years, during the active plant growing season (April to September), then
less than two acres of emergent macrophytes might undergo ecological
succession and be transformed by the seasonally higher water levels. All
the areas surrounding the reservoir where there exist large expanses of
deciduous and coniferous trees are reasonably steep grades with slopes of
2:1 to 5:1. Field survey indicated that these areas are currently, to a
large extent, devoid of standing trees within 20 horizontal feet of
existing water levels (when water level was 1.6 feet above the normal
pool elevation of )492.Sft MSL). Thus, water levels would have to be
increased by over 5 to 6 feet above normal pool elevation before
operational problems would exist as a result of trees being inundated,
killed, and falling into the reservoir. The increased water level
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necessary for adequate low flow augmentation is completely within the
operational level fluctuation (as based on the past five years
operational records) and thus there also would not be any significant
leaching of nutrients from soils that may be periodically inundated.
This conclusion is reached since these same soils have been subject to
such inundation and leaching activities during the past five or more
years of reservoir operation.
Page 14-18, 2nd paragraph : “It also seems premature to conclude that
no significant impact would occur to benthic organisms at Buffumville
Lake. The degree of impact to benthic organisms is dependent upon the
population and species composition in the lake’s littoral area and how
extensively (in terms of time and area) the shoreline areas are
exposed. The resource and extent of drawdown have not been identified or
analyzed in the text.”
EPA response: In the absence of any available information (to date)
on the benthos and the wide range of lake levels currently experienced at
Buffumville (discussed earlier; see response to General Comment 3,
paragraph 14) it is impossible to predict the impact on the benthos.
However, it is reasonable to assume that there will be no significant
impact on the benthos since the increased elevation is considerably less
than the normal operating elevation range of the lake.
Page 14-19, 3rd paragraph : “The above comments apply to fisheries as
well. The species which inhabit Buffumville Lake have not been
identified. The impacts of the suggested LFA alternative scenarios could
have detrimental impacts on the reproductive success of shore spawners
and fry who require cover in littoral areas during the surrzrner. The
timing and extent of drawdown may have an effect on the survival of a
given year class. The range of potential conditions as they relate to
the species present needs to be analyzed.”
EPA response: The impacts of the proposed project on fish are the
same as the no action alternative impacts (i.e., the Corps’ existing
operational situation, based on the last five years of record). These
conclusions are based on baseline information on the presence of fish (as
determined by the Mass Div. of Fisheries and Forestry) has been added to
the FSEIS.
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Page 4—19 : “The loss and distributional changes of vegetation in
the area 2 to 3 ft. above the existing pool elevation will have impacts
to wildlife using the Buffumville Lake shoreline. These changes in area
and quality of upland and wetland vegetation for each drawdown scenario
should be discussed as they relate to wildlife use of the area. A
habitat—based evaluation can be used to compare the 2 and 3 foot
options. The impacts of the “bath tub ring” and the seasonality of the
fluctuating pool to wildlife should also be addressed. Mitigation of the
wildlife habitat losses would be required. The losses and changes should
be compared to the impacts discussed in the Hodges Village alternative.
Then a clear case of a preferable alternative (from a wildlife impacts
perspective) can be made.”
EPA response: EPA believes a Habitat Evaluation Procedure is not
required. As stated previously, discussion has been added to the text
regarding wetlands and upland vegetation under both existing conditions
and with low flow augmentation. As is also discussed previously, the
proposed LFA alternative does not result in the lake level at Buffuinville
changing outside the existing range of elevations experienced at the
lake.
Page 4-19, 3rd paragraph : “To the reader unfamiliar with the
facilities at Buffumville Lake, a description of the bridge, its location
and why it needs to be enlarged would be helpful.”
EPA response: Information in the Buffumville Lake Master Plan
(1976) indicates that this culvert is 13 ft. in diameter and has an 8 ft.
clearance. If the operating water level in the lake is raised a maximum
of 2.5 ft. this clearance will be reduced to 5.5 ft. Under existing
water level conditions the clearance in this culvert is completely
submerged during periods of high water. Thus, any problems related to
clearance at this culvert are already occurring due to existing variation
in water level. Therefore, the LFA project would not cause problems that
do not already exist.
Page 14 19, 4th paragraph, 1st sentence : “Devegetatiofl will be
required.”
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EPA response: It is not clear how the Corps made this conclusion.
Vegetation is very limited, thus the clearing will have limited
benefits. Due to present operating strategy of the dam, it is not clear
how it could be determined that 2.5 foot maximum increase above 1492.5
feet will result in more significant impacts than the range of
elevational variation documented over the past 5 years (13 ft. above
normal pool elevation).
Page 14—19. 14th paragraph, 5th sentence : “Replace ‘if necessary at
all’ with ‘it will be necessary.
EPA response: We do not agree - see earlier discussion.
Page li _ 20, Table 14-4, item 1 : “Cost should include engineering and
design, supervision and administration, and contingencies consistent with
those values used in the Hodges Village EIS.”
EPA response: Reasonable cost estimates for engineering design and
contingencies are provided in the Table 14-14, of the DSEIS. This type of
cost information is not found in the Hodges Village EIS. There is no
necessity to compare costs of the Hodges Village project with the
Buffuznville project since the Hodge Village alternative has been ruled
out due to environmental impact considerations (see earlier discussion).
Page 14—20, Table 14 1I, item 2 : “There is no discussion on what
purpose the microprocessor serves,”
EPA response: The LFA project proposed at Buffumville would require
a change in the operating pool elevation in the reservoir, and would also
require more control over outflow during low flow periods. Outflow
during low flow periods could be regulated manually or by automated
control. The cost included for the microprocessor provides for automated
control of outflows during low flow periods.
Page 14-20, Table 14-14, item 3 : “The $30,000 for operating costs for
8 months — is this annual cost?”
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EPA response: See previous response. This cost is an annual cost
associated with regulating outflow during years when low flow
augmentation is required.
Page 4-20, Table 14 4, item 4 : “Costs for reservoir clearing should
be included extending 2 to 3 feet above the present permanent pooi
level.”
EPA response: Based on field observations and the fact that the
proposed increase in lake level is considerably less than the range of
lake level variation now experienced at Buffumville, significant
reservoir clearing does not appear necessary.
Page 4-20, 1st paragraph, 2nd sentence : “The sentence is
hydrologically correct. However, what is necessary to ensure that none
of these augmentation releases are temporarily stored at a downstream
waterbody, thereby resulting in rivertlows less than 22 cfs at Webster?”
EPA response: All hydropower projects on the French River are
licensed by FERC. All FERC licenses are written to require “run of the
river” operation, and thus holding water at a downstream water body is
not permitted. This run of the river mode of operation is currently
monitored by a variety of Federal and State agencies, and they will be
encouraged to continue to do this in the future.
Page 4-21, 1st paragraph, 2nd sentence : “Boating in the reservoir
for water skiing has decreased because the lake is shallow, making it
hazardous for fast boats and skiers. Raising the pool 3 ft. may have a
positive effect on boating depending on the degree of fluctuation.”
EPA response: This point has been added to this section of the
FSEIS.
Page 4-21, 2nd paragraph, 1st sentence : “This says that sightseeing
is becoming a more important recreational use of Buffumville Lake and
seems to imply it is becoming the most important recreational use. If
that is the case, the appearance of the bath tub ring caused by a 2 to 3
foot seasonal pool level fluctuation and associated devegetation should
be discussed in the report.”
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EPA response: Since water level already fluctuates more than the
level associated with LFA there will be no change in appearance of the
lake.
Page -21, 2nd paragraph, 2nd sentence : “Fluctuations of the pooi
level would not be infrequent but rather would be an annual event,
because the reservoir would be operated on a rule curve.”
EPA response: The point of this sentence is that the lake level
will not be continuously fluctuating during the summer season due to the
LFA proposal. It is agreed that there will be an annual fluctuation for
LFA storage purposes. The text will be clarified in this regard.
Page 4—21, 2nd paragraph, 3rd sentence : “We feel a 3 foot
fluctuation in the pool would significantly impact the beach area.”
EPA response: Based on the present seasonal elevational changes in
water level associated with existing conditions (discussed previously),
fluctuations currently experienced at the beach area are approximately
four times those proposed for LFA. Thus, there would be no anticipated
beach or recreational impacts outside those already present.
Page k-21, 2nd paragraph, 5th sentence : “It should be mentioned
that deve get ation would have a negative impact on fish and wildlife
values at the lake and may decrease related active and passive recreation
opportunities.”
EPA response: Although EPA does not find devegetation to be
critical, if it were done, it would actually have a beneficial impact on
fisheries by providing more gravel and sand areas for pan fish and other
warm water shallow species to spawn, thus increasing an important habitat
cover type. This has been included in revised text.
Page -21, 2nd paragraph, 6th sentence : “The clearing of the ring
around the pool could have a greater impact on aesthetic appeal of the
reservoir. The BIS assumed a 1 foot pool raising, whereas a 3-foot pooi
is needed; thus, the size of the ring may increase significantly.”
EPA response: Extensive clearing is not required and thus there
will be no aesthetic impacts due to clearing.
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Page 4-22, Regulatory & Institutional Constraints ..., item 1 : “A
permit may not be required from the local conservation corm -niss ion since
the project is entirely within Federal lands and, therefore, may not have
to comply with local or State regulations.”
EPA response: The text has been modified to include this
information.
Page 4-22, Regulatory & Institutional Constraints ..., item 2 : “To
clarify the management license, it should be stated that this is for fish
and wildlife purposes.”
EPA response: The text has been modified to include information.
Page 4-22, Regulatory & Institutional Constraints .., item 3 :
“Depending upon the extent of work, a Section 404 permit may be
required.”
EPA response: A statement has been added to the text in this
regard.
Page 4-22, paragraphs 1 and 2, item 1 : “In accordance with the
National Historic Preservation Act, archaeological resources which would
be impacted by the proposed project should be identified prior to
issuance of a FEIS, and Determination of Eligibility for inclusion in the
National Register of Historic Places obtained for each. Such sites must
be mitigated (not just surveyed) prior to project implementation.”
EPA response: Agree. This information is provided in the
archaeological reconnaissance report and is summarized in the DSEIS. It
also has been noted in the text that the proposed LFA alternative will
not result in a lake elevation increase outside of the range of
elevations now experienced at Buffumville.
Page 4-22, paragraphs 1 and 2, item 2 : “it is our understanding
that removal of some sediment may be necessary under this alternative.
Upland disposal at sites other than disturbed areas, for such material
may require archaeological investigations prior to final disposal site
selection.”
EPA response: No sediment removal is anticipated at Buffumville.
Page 4-23, 1st paragraph, 2nd sentence : “The mechanical dredging
alternative may not be such a bad option if a watertight clamshell bucket
is used.
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EPA response: Some leakage is expected even from “watertight”
clamshell buckets. Also, high sediment resuspension would occur during
dredging of this type. In addition, the mobilization/demobilization of
land based equipment could have severe impact on shoreline areas.
Table k _ 6 : “‘Disadvantages’ should include potential impacts on the
disposal sites chosen for any of the excavated pond sediments.”
EPA response: Disposal sites are presumed to be available and
equal. Additional considerations for these would be identified in the
preparation of a Section 404 permit application before the work is
actually implemented.
Page 1I _ 22 to 14 _ 26, ‘Impacts of Sediment Control ...‘ : “Discussions
should include potential physical, chemical, biological, and
socioeconomic impacts of the disposal of any excavated sediments at a
given disposal site. Despite the fact that the sediments passed the EP
Toxicity tests, the level of contaminants in the Perryville and North
Grosvenordale impoundments deserve more attention. As stated above we
suggest you contact our Waterways Experiment Station for further
information on more sensitive testing methodologies.
EPA response: The Army Corps of Engineers, Waterways Experiment
Station, will be a valuable information resource in the sediment
characterization. The type and extent of sediment removal will determine
whether a 401 1 permit is needed. The ultimate location of disposal sites
would be addressed in the state permitting process.
Page 4-23, 1st paragraph, 2nd sentence : “A watertight clamshell
bucket might cause less resuspension and therefore may make mechanical
dredging more acceptable.”
EPA response: See earlier response to this same sentence.
Page 14 _ ill, 1st paragraph, last sentence : “A discussion should be
developed to assess the need for “restocking” the North Grosvenordale
Pond with fish. If restocking is necessary the costs should be reflected
in Table 4-8. There is no evidence that this was coordinated with the
Connecticut DEP. Also, discuss how the addition of the sheeting will
alter the value of the riverine/wetland habitat for fish and other
aquatic organisms.”
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EPA response: Discussions have been initiated with CT DEP relative
to a management plan for the pond. Determination of need for restoring
as well as the fisheries management plan for North Grosvenordale Pond
remains the responsibility of CT DEP. Additional discussion has been
added to the FSEIS regarding the impacts of sheeting and the wetlands
functional values.
Page 14 .145, 2nd paragraph, 3rd sentence : “A section 10 Permit from
the Corps would not be required. (See comment Page 3—105).”
EPA response: Agree with comment, text has been amended.
Page 4—45, last paragraph 2nd sentence : “The Corps jurisdiction
should be clarified in this sentence. Removal of sediment does not in
and of itself require a Section 404 permit. A permit will be required if
the sediment is deposited below the ordinary high water mark or is
bulldozed within the river bed.”
EPA response: Agree with comment, text has been amended.
Page 4 J45, paragraph 1 : “See second comment referring to page 4-22,
para. 1 & 2.”
EPA response: Agree with comment. Potential impacts on
archaeological resources are already discussed in this paragraph.
Page 4-56 paragraph 3 : “See second comment referring to Page 4-22,
paragraph I & 2.”
EPA response: See response to comment “page 14 22, paragraph 1 & 2.”
Page 5-2 : “Comparisons of alternatives are made; but none is made
on an economic basis, which must include both the complete cost and
benefits of LFA.”
EPA response: The cost of the Buffumville Reservoir project was
$3,000,000 in 1958. Using ENR indices, this is equivalent to $16,000,000
in 1985 dollars. EPA feels that the cost of the LFA proposal added to
the present worth (or cost) of the reservoir will not significantly
change the cost/benefit ratio of the project, especially since benefits
are being added.
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Table 5-1 : “Under devegetation, the word ‘minimal’ is used. How
many acres are involved?
Shoreline Exposed — 1 foot maximum assumes just one of the options
described. Perhaps a range of exposed shoreline should be given.
Project Construction Time - what shows here for LFA has nothing to do
with construction time. What about automatic gate control, culvert and
devegetation?
Construction Impacts - there is construction required for LF’A. In fact,
Table 4—4 shows $471,000 worth of construction.
Total Project costs — have annual costs (e.g., operation and maintenance)
been included where appropriate?”
EPA response: Following a comprehensive reevaluation of
devegetation contrasted with existing temporal variations in water level
associated with flood control, no devegetation is expected to be
required. In addition, the shoreline area to be exposed for the LFA will
be less than that associated with the present operational strategy and no
shoreline will be exposed due to drawdown since this is not a viable
alternative.
Modifications in the Construction Time, Construction Impacts and
Project Costs sections of Table 5—1 have been made.
Table 5 _ 14: “ Existing Recreation — what does indensing mean?
Construction - what does minimal mean? Although this table is supposed
to include socioeconomic impacts, neither the costs nor the benefits are
mentioned. Will the benefits be equal to the Hodges Village proposal?
What is the benefit-cost ratio?”
EPA response: These points and the typographical error have been
clarified in the FSEIS. Also, see response to previous comment (pg. 5-2)
regarding LFA cost projections.
Page 5-9, Fig. 5-2 : “It appears from this figure that the 5 mg/i DO
objectfl’e is met without LFA (i.e., Awl’ plus sediment removal) at all
points below the Webster/Dudley treatment plant except at Grosvenordale
Pond, where the DO falls marginally below 5 mg/i. Perhaps a site—
specific measure (e.g., aeration at Grosvenordale) or one implemented
only during the limited amount of time this violation would occur (the
7Q10 flow) should be considered as the actual alternative to LFA. If
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such alternatives are considered, the benefits of LFA would be substan-
tially smaller than those provided by EPA for the Hodges Village report,
and need to be revised.”
EPA response: Revised water quality modeling was conducted as part
of the Final EIS. Figure 14_lU of the FEIS shows that with both AWT and
sediment control, dissolved oxygen standards are not met during low flow
conditions. As is presented in the FEIS, LFA is preferred over instreain
aeration as a means of improving water quality.
Pane 5-10 : “Since the goal is to meet the 5 mg/i DO objective
downstream of the W/D treatment plants, why are LFA releases used to
bring DO levels up to 5.5 mg/l as shown in this figure? Perhaps a lower
level of LFA should be investigated.”
EPA response: Various levels of LFA were considered in the FEIS.
Based on the revised water quality modeling conducted for the FEIS, it
was determined that LFA at 22 cfs will provide significant water quality
improvements without causing significant negative environmental impacts.
Page 5—11 ‘Description of Recommended Plan’ item 1 : “The
sequencing of the proposed plan is a reversal of the preliminary Draft in
that LFA is now being recommended as the initial step rather than the
last step.
EPA response: The final EIS notes that AWT is a (given) initial
step in the cleaning up of the French River. Due to the limited amount
of construction required to implement LFA, it will be the next phase of
the proposed plan to be implemented.
Page 5-11 ‘Description of Recommended Plan’ item 2 : “Since the
Hodges Village plan is never described in this supplemental ElS, it is
obvious that Buffumville is considered by EPA to be the best LFA
source. But Hodges cannot be eliminated as an alternative until a
thorough comparison based on equal level of detailed study is
accomplished. Not only should the complete cost and benefits for
Buffumville be compared with Hodges Village, but also a more complete
environmental study such as HEP should be done on Butfumville. Until
this comparison is accomplished a valid recommendation cannot be made.”
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EPA response: The comparison developed as a response to an earlier
COE comment answers this concern. The matrix (Table 2-1 in the FEIS)
comparing Buffumville with Hodges Village, coupled with several
references in the revised text to Hodges Village EIS address this
concern.
Page 5-11 ‘Description of Recommended Plan’ item 3 : “The
recomaeaded plan gives no timeframe to the implementation of the
Buffumville augmentation proposal nor does it indicate who will pay for
the work.”
EPA response: It is EPA’s hope that the Corps will favorably
receive the Low Flow Augmentation alternative, and that the Corps would
make an appropriation request to be acted on by the U.S. Congress in a
future budget year based on an engineering/justification report on the
Buffumville Lake as a LFA pool.
Page 5—16, paragraph 3 and Page 5-17, paragraph 3 : “Potential loss
of National Register eligible archaeological and historic resources is a
significant impact which would require mitigation and possibly affect
project costs and selection of alternatives. This has not been addressed
here.
EPA response: As discussed previously, mitigation measures
necessary to protect archaeological and historic resources are not
expected to be extensive, and thus costs will not be large since dredged
material disposal areas (to be identified at the time of preparation of a
Section ItOh permit application) will be selected so as to avoid such
archaeological and instreain resources.
Page 5—18, 2nd paragraph, item 1 : “The wildlife impacts of
devegetation should also be evaluated and mitigated, if necessary.
Throughout this report there are terms such as “minor” related to
impacts, and “only a few trees” in discussion of devegetation. These
values should be in terms of what impacts, how many acres, how maiy
trees, etc. On this page we see only a few trees will be lost in
deve get ation, however, it is highlighted on the same page that to avoid
impacts this work should be done during off hours. If impacts are minor,
why is there emphasis on doing the work during off hours, particularly
since “only a few trees” are involved?”
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EPA response: Since no devegetation is required in association with
the LFA, no impacts will require mitigation.
Page 5-18 paragraph, item 2 : “We suggest that any work be
accomplished at Buffumville Lake in October and November, after the
recreation season is over to minimize impacts to recreation and
wildlife.”
EPA response: Agree with comment.
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STATEMENT OF CRANSTON PRINT WORKS ON SUPPLEMENTAL
ENVIRONMENT IMPACT STATEMENT FOR FRENCH RIVER CLEANUP
OCTOBER 30, 1985
Cranston Print Works is pleased to have an opportunity to comment on
the Supplemental Environment Impact Statement for the French River Clean—up
Program. We also appreciate the efforts made by EPA to resolve the various
factors contributing to water quality problems on the French River. In par-
ticular, we feel that the water quality model h as been an effective tool in
evaluating the relative magnitudes of vastewater discharges, sediments and low
flows on dissolved oxygen. However, we do have several concerns.
Cranston Print Works has strongly supported the Town of Webster and
the Commonwealth in their efforts to improve solids handling at the Webster
plant. Although these improvements will be completed in December of this
year, no consideration has been given to the extent of water quality improve-
ment that will result. Improvements may be very significant because the
Webster plant currently discharges as much as 30 tons of solids at approxi-
mately monthly invervals.
Cranston Print Works has come out in favor of a regional trea nent
plant meeting secondary effluent limitations. The supplemental EIS study does
not address the secondary treatment option but assnmes a priori that advanced
watewater treatment is necessary.
We feel that the model can illustrate the relative impacts of
various factors on dissolved oxygen. Thus the model results can be used to
establish priorities among clean—up options. However, the use of the model to
predict actual dissolved oxygen levels is questionable. Factors which limit
the model’s ability to predict dissolved oxygen levels include its sensitivity
to sediment oxygen demand and photosynthetic activity and its requirement of
steady state conditions.
The recommended plan includes low flow augmentation, advanced waste—
water treatment (“Awl’) and isolation and renewal of sediments. The costs for
flow augmentation and sediment control are compared in Table 5—6. When com-
parisons are made of these costs with AWT and the DO improvement expected,
several factors become apparent. First, Awl is the most expensive option be-
cause it has a high capital cost and requires a large annual 0 & N expense.
AWT also results in a small DO improvement. Thus AWl is the leaat cost effec-
tive option. Second, sediment control results in the most significant DO im-
provement and although capital costs are also high, there are no annual 0 & N
costs.. Third, low flow augmentation is the lowest cost option and provides
for improved DO both above and below the Webster and Dudley treatment plants.
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The water quality model projects that all three options (in addition
to the solids handling system coming on stream in Webster during December,
1985) will be needed to achieve desired water quality levels. This conclusion
is a misuse of the model, which is only valid for relative option comparisons
and not absolute water quality predictions. The EPA has itself recognized
that in practice all three options may not be required. On June 11, 1985, it
concluded:
the State of Connecticut must provide written assurance
prior to grant award that reaffirms the State’s intention
to participate in the removal of sediments in the reservoirs,
if necessary , and the Regional Achninistrator should determine
based on post—construction monitoring data provided by the
State whether such action is required to fully attain the
warm water fishery use for the French River.” (emphasis added)
Cranston Print Works and the EPA thus both agree that a step—by—step approach
is best in order to avoid unnecessary costs. As suggested below, the only
difference is in the best order of implementation. As the EPA concluded,
following each step, there should be monitoring of the River to determine the
actual improvement and whether further steps are necessary.
In view of the cost effectiveness of available option, CPW proposes
that the following sequence of steps is the most logical order:
1. Regionalize the Webster/Dudley treatment plants into a secondary
system during 1986. This could be accomplished at minimal costs because the
Webster facility will have the capacity to handle flows and solids loads of
both plants. A combined system would eliminate solids discharges to the
river. These solids discharges are a major concern to connecticut.
2. Monitor the actual improvements resulting from combined flow and
solids handling, especially in July—August (low flow months) 1986.
3. Prepare Buffumville Lake for flow augmentation with completion
in 1987.
4. If needed, remove and isolate sediments during the stmimer of
1987 made possible by the control of solids discharged at the regional secon-
dary plant in Webster/Dudley.
5. Conduct a water quality survey during the st mer of 1988 to
evaluate improvements.
6. In late 1988, early 1989, proceed with plans for AWT if river
improvements do not meet expectation.
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CPW feels that the steps outlined above are in compliance with E?As
goals and charter to obtain “fishable—swimmable” water quality and represent
the most cost effective approach to these goals.
In order to carry out this logical sequence, we urge all parties to
cooperate as soon as possible, especially in the first step of secondary plant
regionalization. It would be detrimental to water quality goals if the full
benefits of the solids handling system to be placed in service in December,
1985, were not maximized by such regionalization.
C. W. Shuster, Group Vice President
A. Sylvia, Plant Manager
H. Donaldson, Environmental Chemist
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FRENCH RIVER DRAFT EIS
RESPONSE TO CRANSTON PRINT WORKS STATEMENT
OF OCTOBER 30, 1985
In their statement, Cranston Print Works questions the value of AWT
at Webster Dudley and argues that EPA should consider a secondary
treatment plant, placing more emphasis on improvement alternatives such
as low flow augmentation. However, the intent of the French River EIS is
to evaluate improvement alternatives beyond AWT. AWT has been determined
by EPA to be required in accordance with the Clean Water Act, and is
assumed as the base case for this EIS. According to the Clean Water Act
(1977), publicly owned treatment works (POTWs) were required to achieve
secondary treatment by July 1, 1977. The Clean Water Act further
requires more stringent effluent limitations on some discharges in order
to comply with state water quality standards. The Massachusetts DWPC and
EPA have established that the French River is “water quality limited,”
requiring effluent limits more stringent than secondary.
The AT Review for the Webster-Dudley wastewater treatment plant was
conducted by U.S. EPA in January 1985, in accordance with the
Appropriations Conference Committee’s Report (September 1978, as amended)
and EPA’s AT review policy (May 21, 198 4). The AT Review concluded that
AWT is necessary for the French River to meet water quality standards.
It is expected that AWT, along with the pretreatment program, will
significantly reduce metals which are detrimental to fish and benthic
communities. The EIS demonstrates that alternatives beyond AWT are also
necessary to assure that a dissolved oxygen criterion of 5 mg/l will be
achieved in the French River during 7Q10 low flow conditions.
C- 1 49
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Cranston Print Works also questions EPA basing its recommendations
to improve water quality in the French River on a computer model. While
EPA acknowledges that no computer model will predict exact values, EPA
feels that STREAM7B is a useful tool for predicting changes in dissolved
oxygen concentration with the addition of each improvement alternative to
the French River.
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STATEMENT OF ANGLO FABRICS CO., INC. ON SUPPLEI ENTAL
ENVIRONMENT It ACT STATEMENT FOR FRENCH RIVER CLEAN-UP
OCTOBER 30, 1985
Anglo Fabrics Co., .Inc. welcomes the opportunity to comment on the
Supplemental Environment Impact Statement for the French River
Clean-up.
From the very beginning, Anglo Fabrics Company, Inc. has supported
cost effective options to improve the water quality of the French
River.
Anglo Fabrics Company, Inc. has repeatedly urged the Towns of
Webster and Dudley to form a Regional treatment plant capable
of meeting secondary effluent limitations.
We acknowledge the diligence of the EPA ’s efforts to resolve a very
complex situation. However, we feel the water quality model was and
is not able to take into consideration the extent of water quality
improvements that can be achieved by the new solids handling at
the Webster plant when it goes on line at the beginning of 1986.
We also think that with low flow augmentation, improved solids
handling by a regional secondary treatment plant and selective
sediment control, any further improvements achieved by an advanced
waste water treatment plant would be minimal and would not warrant
the high 0 & M costs.
Therefore, we concur with Cranston Print Works’ proposed sequence
of steps for the most effective options, as outlined in their
statement of October 30, 1985.
J hn President
K [ fred Natkin, Vice President
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FRENCH RIVER DRAFT SUPPLEMENTAL EIS
RESPONSE TO ANGLO FABRICS STATEMENT OF OCTOBER 30, 1985
As was explained in response to the October 30, 1985 statement
subiiitted by Cranston Print Works, AWT was riot evaluated as an
improvement option in the EIS. AWT was considered to be the base case
against which improvements alternatives were compared. AWT is required
by the Clean Water Act, which requires treatment plants to achieve
secondary treatment and any more stringent effluent limits needed to meet
state water quality standards. (See response to October 30 Cranston
Print Works statement.)
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STAT. )F CONNECTICUT _____
DEPARTMENT OF ENVIRONMENTAL PROTECTION
YEARS
1985 & 1986
Mr. Michael R. Deland
Regional Aäninistrator
Region I EPA
JFK Federal Building
Boston, Mass.
Dear Mr. Deland:
The Connecticut D arbnent of Enviromental Protection welcomes this
o ortunity to ca ent on the EPA r ort entitled “Draft Sippl iental
Envirorinental Inpact StateTent for the French River Cleanup Program in
Massachnsetts and Connecticut” deted S ’t nber 1985. As you knc , the
Connecticut DEP has assigned a high priority to u gra ing the water quality of
the French River in Thoupson, Connecticut to its adopted Class B
“fish le/swin ab1e” goal. Over the past several yeaxs, this agency has
actively participated in the developtent of a French River restoration plan
under the ispices of the State/EPA Working Group on the Inte tate Transport
of Pollutants. The supplenental EIS provides a ccinpehensive review and
critique of the water quality plans and studies utilized by the Working Group
In the forirulation of its clean—up program. The r ort’s recanrrended c)ean-up
program is conceptually consistent with the Working Group plan, with sound
technical justification for supplying fl augmentation fran Buffunville Lake
rather than the aedges Village inpourdrrent. The Connecticut Departh ent of
Erwironnental Protection therefore endorses inpienentation of the supplenental
EIS reccii nended program of low fk,w augmentation fran Buffiimvi]e, ath7anc2d
westewater treatment at Wetster and rx dley, and management of contaminated
sediirents in river inpouit1irents.
We trust that the publication of the su lemental EIS marks the end of
project planning and the beginning of corrective action. The Connecticut 1 P
pledges to commit the resources neces ry to fulfill Connecticut’s
responsibility to manage contaminated sediments in the Wi]sonville and North
Grosvenordale inpourdnents such that water quality goals are met. We se&
reciprocal caitnitxrents fran other rking group partici nts to unc rtake
projects within their jurisdiction. In particular, we sed a canmitment fran
the to s of wetster and aidley to inpierrent advanced waste ater treathent; we
se c a commitment f ran the u. S. ArrrW Corps of EngineeiB to inpiement low f]rw
augmentation; we seek a canmitiTent from Massachisetts DEQE to a3&ess
contaminated sedirrents in the pertyvile inpourriment and we sed a canrnitnlent
from EPA to provide the a ninistrative and legal oversight necessary to
expedite the clean-up program.
Phone:
165 Capitol Avenue • Hartford, Connecticut 06106
An Equal Opportunity Employer
-------
Thait you for your attention to this matter and, ]xdc forward to rkthg
with the EPA a id its Working Group to bring this program to a successful
conclusion.
Very truly yours,
awhyjf
5’1 PNL 3. AC
M SIOl€R
SIP: job
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FRENCH RIVER DRAFT SUPPLEMENTAL EIS
RESPONSE TO LETTER FROM CONNECTICUT DEPARTMENT OF
ENVIRONMENTAL PROTECTION (UNDATED)
Connecticut Department of Environmental Protection has expressed
strong support of the EIS.
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CRANSTON PRINT WORKS COMPANY
CORPORATE OFFICES
1381 CRANSTON STREET. CRANSTON. R. I. 02920
TEL. 401 -9434800
November 18, 1985
Mr. Larry Macl4illan
Environmenta l Protection Agency
Environmental Evaluation Section
J.F. Kennedy Federal Building
Boston, MA
Dear Larry:
Enclosed, please find our comments on the Draft SEIS for the
French River Cleanup Program in Massachusetts and Connecticut.
If we can be of any service to you in answering questions
concerning the cleanup program, please feel free to call.
Sincerely,
41
Henr /Donaldson, Ph.D.
Environmental Chemist
MD/np
Enclosure
cc: file
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COMMENTS
ON
DRAFT SUPPLEMENTAL ENVIRONMENTAL Th ACT
STATEMENT FOR TIlE FRENCH RIVER CLEANUP
PROGRAM IN MASSACHUSETTS AND CONNECTICUT
Submitted by
Cranston Print Works Company
November, 1985
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TABLE OF CON IrNIS
Item Page
1.0 SUMMARY 1
2.0 INTRODUCTION 3
3.0 EPA ADMINISTRATOR’ S ADVANCED WASTEWATER TREATMENT REVIEW 4
3.1 Basis for AWT Review Recommendations
3.2 Implications of the Supplemental EIS on AWT
Recommenda tions
4.0 WATER QUALITY MODEL PREDICTIONS 7
5.0 COSTS BENEFITS OF THE SEIS RECOMMENDATIONS 9
5.1 Costs of the Alternatives and Projected DO
Improvements
5.2 Proposed Cleanup Plan
6.0 CONCLUSIONS 14
REFERENCES
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SECTION 1
SUMMARY
Cranston Print Works Company has reviewed the EPA Advanced Wastewater
Treatment Review (AWTR, June,1985) and the Supplemental Environmental Impact
Statement (SEIS, SEPT. 1985) on the French River Cleanup Program. In the
AWTR, the EPA Administrator approved the plan for Advanced Wastewater Treat-
ment. His approval was based on the prediction that AWT would improve dis-
solved oxygen (DO) 2—4 mg/L and prevent DO from falling below 3.0 mg/L. He
assumed there would be no flow augmentation and noted that additional review
would be required if flow augmentation was considered.
Subsequently, the SEIS presented additional water quality predictions and
recommendations that should change the AWT Review. First, the updated water
quality model predicted that AWT would only improve DO an average of 1 ing/L.
Secondly, the model predicted that DO would fall below 3.0 mg/L even with AWT.
Thirdly, flow augmentation was recommended as an initial step in the cleanup.
Therefore, additional AWT review is required by the EPA Administrators.
The SEIS analyzed the water quality model, with respect to its ability to
predict water quality. Important factors influencing the model’s predictive
ability are its sensitivity to photosynthetic activity and sediment oxygen de-
mand, and the assumption of steady state. Analysis of the SEIS makes evident
that the model is effective in predicting relative DO improvements among the
various options, but that the model cannot accurately predict actual DO
levels.
Costs of, and relative, DO improvements expected from AWT, low flow aug—
itentation and sediment control can be compared. AWT is the least cost effec-
tive option, while flow augmentation is the most cost effective. Sediment
control provides the greatest DO improvement but at the highest capital cost.
Following consideration of all factors involved, we present a brief plan
and schedule for cleanup of the French River. This plan recommends, as a
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first step, regionalization of the Webster and Dudley treatment plants into a
secondary system. Subsequent steps include, in order, flow augmentation,
sediment control, and AWT. The need to implement these steps should be as-
sessed after each stage by actual water quality measurements. Our proposed
plan would result in immediate water quality improvements and ensure that any
subsequent steps were necessary and cost effective.
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SECTION 2
INTRODUCTION
The need for an upgrade of the Webster and Dudley wastewater treatment
plants has long been recognized by State and Federal regulators, the Towns,
and Cranston Print Works Company (CPw). However, the best way to minimize
costs and still achieve water quality goals has been at issue for several
years. CPW has always favored a stepwise approach. Our approach includes
compliance with secondary treatment standards at the treatment plants in order
to determine the need to proceed with more advanced vastewater treatment tech-
nologies. In contrast, State and Federal regulatory agencies have recommended
AWT to the extent that the Towns have been issued an Administrative Order to
construct and operate an AWT facility.
Regulatory agencies have recognized the complex factors affecting water
quality on the French River. The Supplemental Environmental Impact Statement
is an effort to identify the factors causing water quality problems and to
identify solutions. Cranston Print Works Company is pleased to have this op-
portunity to comment on the SEIS and review its implications for the AWT pro-
cess at Webster and Dudley. At the conclusion of our review, we propose a
schedule for cleanup of the French River which is cost effective and will meet
the regulatory agencies’ objectives. This implementation schedule is based on
a review of the following items:
1. U.S. Environmental Protection Agency’s Advanced Wastewater Treatment
Review,
2. The capability of the SEIS model to predict water quality in the
French River, and
3. Cost benefits of the SEIS recommendations.
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SECTION 3
EPA ADMINISTRATOR’S ADVANCED WASTEWATER TREATMENT REVIEW
All advanced wastewater treatment projects with a capital cost in excess
of $3 million must undergo a special EPA review. The EPA Administrator must
personally determine that AWT is required and will definitely result in sigili—
ficant water quality and public health improvements. This section examines
the AWT review for Webster/Dudley and evaluates it in light of the French
River SEIS.
3.1 Basis of AWT Review Recommendations
The EPA Administrator concurred with the AWT Task Force’s recommendations
that funding should proceed for AWT at Webster and Dudley. The apparent basis
for this recommendation was as follows (AWT Review, 1985 pg. 8):
1. “AT provides a 2—4 mg/L DO improvement throughout the 8 miles of
river.”
2. “The proposed project viii likely prevent the occurrence of DO con-
centrations of less than 3.0 tng/L and the associated mortality.”
Draft DO criteria documents recommend an “acute mortality limit” of
3.0 mg/L for a warmwater fishery. Thus the EPA Advanced Treatment
Task Force concludes that “the predicted DO improvement will likely
result in a significant warmwater fishery.”
The above conclusions were reached by the AWT review staff with the
recognition of the uncertainties in the water quality model.
The AWT review was also conducted and recommendations were made with the
understanding that flow augmentation was not going to be implemented:
“Flow augmentation has been considered for the French River in the
past. Based on discussion with the region, this review assumes
that flow augmentation will not be implemented. If flow augmentation
is proposed again and results in higher stream flows, additional AT
review viii be required.” (AWT Review, Introduction).
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Thus, the EPA administrator will need to re—examine the need for AWT if
flow augmentation is a possibility.
3.2 Implications of the Supplemental EIS on the AWT Recommendations:
The AWT review recognizes problems with the water quality model that
were previously used to predict the DO improvements resulting from AWT.
The EPA Administrator’s recommendation to proceed with the funding for
AWT is based on this inadequate model and its predictions that AWT will
improve DO by 2—4 ppm and ensure that DO will not drop below 3 ppm. He
assumes that flow augmentation will not be implemented.
The water quality model of the French River was recalibrated and im-
proved significantly for use in evaluating cleanup options in the SEIS.
The improved water quality model predicted that AWT at the Webster—Dudley
treatment facility would increase downstream DO, during low flow, by ap-
proximately 0.75 to 2.5 mg/L with an average increase of about 1.0 mgIL
(EIS, 1985, pg. 4—4). Actual dissolved oxygen values were predicted to
be approximately 3.5 mg/L in Perryville and Langer’s Ponds and 1.0 mg/L
in North Grosvenordale.
These updated DO predictions in the SEIS contradict previous pre-
dictions that formed the basis for the AWT Task Force’s recommendation
to proceed with AWT at Webster and Dudley. Specifically AWT may not pro-
vide a 2—4 mg/L DO improvement throughout 8 miles of river. Neither does
AWT ensure.that DO will remain above the 3 mg/L considered necessary for
a warmwater fishery.
Low flow augmentation is discussed in the SEIS. In fact, the recom-
mended plan calls for implementation of flow augmentation as the initial
activity to clean ‘up the river. CPW agrees that flow augmentation should
precede AWT.
In conclusion, information contained in the supplemental SEIS re-
quires that the need for AWT at Webster/Dudley be re—evaluated, because:
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1. The increases in dissolved oxygen currently predicted for AWT are
lover than those originally predicted. The EPA Administrator should
examine these new predictions to determine if AWT will definitely re-
sult in significant water quality and public health improvements as
required by Amendment No. 23 of the Appropriations Conference Commit—
tee 1 s report (September, 1978) to fund AWT projects.
2. The EPA Advanced Treatment Task Force assumed that flow augmentation
would not be implemented. The SEtS recommends flow augmentation be-
fore AWT. The Task Force states that additional AWT review will be
required if flow augmentation is proposed.
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SECTION 4
WATER QUALITY MODEL PREDICTIONS
The proposed steps for the cleanup of the French River have been based on
water quality models. Because significant amounts of money are required to
implement recommended improvements, care should be taken in interpreting re—
suits of the water quality model predictions. Water quality models are useful
in predicting the relative changes in DO that would result from various op-
tions. However, water quality modeling, as applied to the French River, can-
not be used to predict actual in—stream dissolved oxygen values. Support for
this statement follows:
The water quality model used in the Supplemental EIS was calibrated to
data collected during August, 1982. Calibration runs, with and without photo-
synthetic oxygen production, demonstrated that photosynthetic activity was an
important contributor to DO levels in the river. However, photosynthetic oxy-
gen production was excluded from model runs predicting water quality condi-
tions under various cleanup alternatives. This exclusion represents a con-
servative assumption, which could result in under—predicting DO during day-
light conditions of high productivity.
The model was also sensitive to sediment oxygen demand (SOD) levels. The
use of SOD values, from either 1978 or 1985 studies, resulted in a change in
DO of 2—3 tng/L. SOD is also sensitive to the DO value of the overlying water
column. The lover the overlying DO, the lower the SOD. Although this effect
was taken into account in the model by selecting the lower of the two sets of
SOD values, the model’s built—in sensitivity to SOD will affect its ability to
predict actual in—stream DO values.
The model assumes steady state conditions. Thus, fluctuating pollutant
loads and river flows further restrict the ability of the model to predict
actual water quality. The water quality data used to calibrate the model were
collected August 16—19, 1982. (MDWPC, 1983). Because the U.S.G.S. gauge was
not operating, individual flow measurements were made on August 18 and 19 be—
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low the Perryville Dam. On August 18, the river flow was determined to be 50
cfs. On August 19, the flow was determined to be 36.36 cfs. No measurements
were taken on the 16th or 17th.
Both the Webster and Dudley treatment plants have solids handling prob-
lems. The Webster plant retains solids in its mixed liquor until the level
reaches its acceptable limits. Solids are then allowed to overflow to the
river. Webster currently discharges excess solids at approximately monthly
intervals. When solids are discharged, as much as 30 tons can be discharged
in a 24—hour period. This quantity compares with an average discharge of 2—3
tons in a 24—hour period. Because of fluctuating river flows and solids loads
to the river, steady state conditions have not been present for accurate model
calibration.
In addition to these specific shortcomings, the model, by its very nature
as a model, has built—in ranges of error. The history of water pollution
cleanup efforts affords many examples of actual water quality improvements for
exceeding the levels that had been predicted by models alone.
In conclusion, the model can be used to evaluate relative DO improvements
provided by each of the proposed cleanup options. Rovever, the model cannot
accurately predict actual DO levels in the river to determine which option or
combination of options will produce DO values of S mg/L as required by the
State Standards. In summary, the predictive ability of the model is limited
because:
1. the model is sensitive to photosynthetic activity,
2. the model is sensitive to SOD values,
3. steady state conditions did not occur at the time of model
calibration, and
4. . inherent in any model are predictive errors based on the inability
of models to reflect the full range of variables in each real world
application.
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SECTION 5
COST BENEFITS OF THE SEIS RECOMMENDATIONS
The analyses presented in the SEIS indicated that no one alternative
would provide adequate dissolved oxygen levels in the French River downstream
of the Webster and Dudley treatment plants. This condition requires determi-
nation of which alternatives should be implemented, and in what sequence, to
“maximize the efficacy of the alternatives, while minimizing the time elapsed
before improvements are realized.” (Quote from SEIS, pg. 5—11). Alternatives
are reviewed below by comparing costs, anticipated DO improvements, and time
for implementation to develop a logical, cost—effective plan for cleanup of
the French River Basin.
5.1 Costs of the Alternatives and Projected DO Improvements
The SEIS considers four cleanup alternatives and their costs. These in-
clude low flow augmentation from Buffumville Lake and three sediment control
steps. No consideration is given to the costs of AWT. Excluding AWT costs
when considering cleanup alternatives is a major deficiency in the SEIS.
Therefore, we have compared costs of AWT (Facility Plan, 1984 pg. 8—38) with
those of the other alternatives described in the SEIS (Tables 4—4 and 5—6).
These costs and the associated increases in DO are as follows:
INCREMENTAL
10—YEAR COST
PER 1 irag/L DO
ITEM COST - DOLlARS DO IMPROVEMENT IMPROVEMENT
AWT Webster/Dudley
Capital Cost $5.014 million 0.75—2.5 mg/L
Annual Operation* $1 .212 million (Ave. 1 mgIL) $11 .014 million
Low Flow Augmentation
Capital Costs $441,000 1 mg/L $.741 million
Annual Operation $30,000
* Total O&M Costs. Incremental increase over current O&M is expected to be
approximately $600,000.
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Sediment Control Total $6 .820 million 1—4 mg/L $2.273 million
(Ave. 3 mg/L)
Isolate wetlands
at Perryville and
Langer’s Impound-
ments $668,000
ITEM COST — DOL1AR
Remove channel sediments at
Perryville and Langer’s
Impoundments $2.453 million
Excavate sediments in North
Grosvenordale Impoundment $3 .699 million
AWT is the least cost effective alternative. DO will only improve
about 1 mg/L with a capital investment of $5 million. Low flow augmenta-
tion provides a similar benefit for one tenth the capital cost. AWT also
requires a significant operation and maintenance cost (0&}I). O&M for
flow augmentation is minimal. Thus, the overall ten—year incremental
cost of AWT is fifteen times that of low flow augmentation for the same
DO improvement.
The most significant DO improvement would come from implementation
of sediment control options. Although capital costs of sediment control
would approach $7 million dollars, these are one—time costs with no an-
nual O&M. The SEIS also notes (pg. 3—80) that the “sediments in the im-
poundments are significantly polluted with heavy metals and PAH com-
pounds.” Thus, sediment control should not only result in significant
DO improvements but would also remove potential sources of chronic, ad-
verse biological impacts. This latter benefit would not be achieved by
AWT.
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Based on objective consideration of costs and water quality improvements,
the results of the SETS call for implementation of flow augmentation and
sediment control before AWT. As noted in the EIS regarding the inipound—
ments, “Accumulated sediments and sluggish flow in these locations result
in a high sediment oxygen demand. These factors are a primary contribu—
tor to the low DO levels.” (pg. 3—80)
5.2 Proposed Cleanup Plan
CPW has repeatedly criticized the Federal and State cleanup plan for
requiring AWT as the first step. Although AWT is not a necessary, or
even logical, first step, there is a real need to reduce the current pol-
lutant levels from the Webster and Dudley treatment plants. It be
that AWT will be a necessary subsequent step to achieve water quality
goals. However, the least cost—effective alternative should not be im-
plemented first, particularly when the argument for implementation is
based on theoretical water quality model, and such alternative may ac-
tually prove unnecessary in the real world after other options are im-
plemented.
The EPA Administrator should concur with CPW’s position. First, EPA
has recognized potential problems in the first model. Secondly, the EPA
Administrator notes that additional AWT review will be required if flow
augmentation is proposed. Thirdly, the updated model alters the DO pre-
dictions which formed the basis for EPA’s original approval of AWT.
EPA’s recognition of the weakness of water quality models is further
demonstrated in their memorandum (Thomas, 1985) stating that monitoring
data should be submitted following AWT and before proceeding with sedi-
ment removal. This memorandum thus implicitly recognizes the principle
of proceeding step by step with monitoring after each step and then pro-
ceeding with additional steps only as needed. We differ only in calling
for selection of the most cost—effective steps first, not the least cost—
effective (AWT) first.
In view of the above comments, CPW proposes the following plan and
schedule for cleanup of the French River:
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1. Regionalize the Webster/Dudley treatment plants into a
secondary wastewater treatment plant in early 1986, in-
cluding combined solids handling.
2. Monitor water quality in the river in July—August, 1986,
to document possible improvements resulting from regionali—
zation to secondary treatment.
3. Prepare Buff u mville Lake for flow augmentation with com-
pletion in 1987.
4. Ijj needed , remove and isolate sediments from the impound-
ments during the summer of 1987.
5. Conduct a water quality survey during the summer of 1988
to evaluate improvements.
6. Proceed with plans for AWT in late 1988 — early 1989 j .
river improvements do not meet expectations.
Regionalization of the Webster and Dudley treatment plants could be
accomplished at minimal cost. Webster has the hydraulic capacity to
handle flows of 6 mgd, and by January Webster will have capacity to waste
solids produced by treating flows of 6 mgd. The major cost would be for
a pipe to bring Dudley’s flow across the river to Webster, a distance of
no more than 100 yards. Webster and Dudley both violate their permits on
occasion due to solids buildup. Regionalization would eliminate the ex-
cessive solids discharges that currently enter the river. These solids
discharges are a major concern of Connecticut and a primary reason they
have not proceeded with sediment removal in several impoundments.
During the warm summer months, the Webster treatment plant has
reached BOD— and suspended solids limits 50% or more below those required
under general secondary standards. Thus, a regional secondary system
should be implemented and optimized. Such a plant may be able to meet
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effluent limits which approach those proposed for AWT, without the extra
capital and O&M costs projected for AWT.
Water quality surveys, which could include SOD measurements 3 could
provide quantitative data for evaluating effects of improved sewage dis-
charge. The data could also be used to recalibrate the water quality
model.
Once positive steps have been taken at Webster and Dudley, flow
augmentation could be implemented. As noted, this alternative is cost
effective.
Although capital intensive, sediment control would result in the
most significant DO improvement. Agencies in Connecticut are hesitant
to initiate sediment control for fear of downstream transport of sedi-
ments or sludge from upstream areas. Regionalization of Webster/Dudley
to eliminate existing solids discharges and reduce effluent oxygen de-
mand loads represents a positive step which should alleviate their con-
cern regarding discharges from the treatment plant. Regionalization will
also make it possible for the Commonwealth of Massachusetts to address
the sediment problem in the Perryville impoundment.
Water quality improvements should be documented following sediment
control, by conducting field surveys during the low flow months. If
water quality standards are not met following regionalization, flow aug-
mentation, and sediment control, CPW would then recommend proceeding with
design and construction of AWT.
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SECTION 6
CONCLUSIONS
Cranston Print Works Company is interested in seeing the French River
Cleanup Program proceed so that the recreational and aesthetic potential of
the river can be reached. The only issue is how best to proceed. Regulatory
agencies at the State and Federal levels have demonstrated that sediment con—
trol, improved sewage treatment, and flow augmentation are necessary. CPW
concurs with this position but concludes that the costs associated with im-
proved sewage treatment warrant a stepwise approach. Federal EPA has sug-
gested that secondary treatment has been in existence at Webster and Dudley
and has not been effective in meeting water quality objectives. Because
solids handling has never been adequate at either Webster or Dudley, effec-
tive secondary treatment has never existed and has, therefore, never been
evaluated.
Installation of solids handling facilities will be completed in Webster
in December, 1985. Maximizing these facilities by tying Dudley into the Web—
ster Plant will finally provide the opportunity to evaluate the capability of
the Webster Plant to meet secondary or better—than—secondary effluent limita—
tions. Regionalization will also provide a positive step toward cleaning up
the river and one which can be implemented in the near future.
Connecticut, with respect to sediment control, and the Army Corps., with
respect to low flow augmentation, are looking for a positive step at Webster
and Dudley before proceeding with their plans. Regionalization at Webster
and Dudley followed by plant optimization provides this positive step. We
urge local, State and Federal officials to support our proposed plan as a
cost—effective and timely approach toward moving forward on the French River
cleanu p.
Cranston Print Works Company
By: / /M
George WjShuster, Group Vice President
—14—
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Andrew F. Sylvia, Plant Ianager
Henry “ Donaldson, Environmental Chemist
—15—
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REFERXRCES
AWT Review, 1985. Summary of Findings Advanced Wastewater Treatment
Facilities’Proposed for Webster and Dudley, Massachusetts. Prepared by
Environmental Protection Agency Advanced Treatment Task Force
EIS, 1985. Draft Supplemental Environmental Impact Statement for the French
River Cleanup Program in Massachusetts and Connecticut. For: U.S.
Environmental Protection Agency Region I, By: Metcalf and Eddy, Inc.,
Woburn, MA
MDWPC, 1983. Massachusetts Division of Water Pollution Control (MThJPC),
November, 1983. French and Quinebaug River Basin; French River Basin
Survey 1982, Part A—B, Water Quality and Wastewater JYischarge Data
Facilities Plan, 1984. Draft Facilities Plan for Wastewater Treatment.
Towns of Webster and Dudley, Massachusetts. February, 1984. Proposed
by Metcalf and Eddy Inc., Woburn, MA
Thomas, L.M., 1985. Review of Advanced Treatment Facilities Proposed for
Webster and Dudley, MA. Memorandum to N. R. Deland, Regional Adminis-
trator, EPA Region I
—16—
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FRENCH RIVER DRAFT SUPPLEMENTAL EIS
RESPONSE TO LETTER OF CRANSTON PRINT WORKS COMPANY,
REVIEW COMMENTS OF NOVEMBER 18, 1985
The Clean Water Act requires that publicly owned treatment works
provide secondary treatment and any more stringent treatment needed to
meet water quality standards. AWT is a necessary action in the cleanup
of the French River. The intent of the EIS was not to decide whether or
not to implement AWT but to investigate improvement alternatives beyond
AWT. For a more detailed response see EPA ’s response to October 30, 1985
statement from Cranston Print Works Company. See also EPA’s response to
comments which accompanied reissuance of NPDES permits for Webster and
Dudley, dated September 30, 1986.
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OFFICE OF EAST-Y1ILABE SEWER CONSTRUCTION
COMMITTEE
MUNICIPAL BUILDING
WEBSTER, MASSACHUSETTS 01570
November 19, 1985
Larry MacMillan
Environmental Protection Agency
Environmental Evaluation Section
J. F. Kennedy Federal Building
Boston, MA 02203
Dear Sir,
The Town of Webster is in favor of the program recommended by
Cranston Print Works at the hearing held in Dudley on October
30, 1985.
To implement this, we recommend that Dudley be allowed to enter
the Webster system so that both towns can take advantage of the
s1ud ge handling facilities being constructed now.
We would appreciate a commitment from the State of Connecticut
on cleaning the impoundments, and to the steps necessary for
implementation.
Sincerely for the Town of Webster,
A. R. ebart, Chairman East Village
Sewer Construction Committee
* P RK;lt
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FRENCH RIVER DRAFT SUPPLEMENTAL EIS
RESPONSE TO EAST VILLAGE SEWER CONSTRUCTION COMMITTEE,
LETTER OF NOVEMBER ‘19, 1985
As pointed out in response to the Anglo Fabrics and Cranston Print
Works statements of October 30, 1985, AWT has been evaluated by EPA and
has been determined to be necessary in accordance with the Clean Water
Act. The purpose of the EIS was not to decide whether or not AWT should
be implemented. The EIS was produced to investigate improvement
alternatives beyond AWT which would help to improve water quality in the
French River. (See response to statements submitted by Anglo Fabrics and
Cranston Print Works for further details). Connecticut has provided a
commitment to conduct sediment control following completion of AWT
facilities. See the letter suniitted by CT DEL’ in response to the Draft
EIS.
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A. RODNEY KLEBART
CIVIL ENGINEER AND SURVEYOR
Box 84
WEBSTER, MASSACHUSETTS
NOv. 1., 1985
Mr. Larry MacMillan
Enviro !iental Protection Agency
Enviro enta1 Evaluation Agency
J. F. Keflnedy Federal B.iilding
3oston, “assachusetts, 02203
Dear Sir,
As stated at t e October 30, 1985 hearing, y Dersonal
feeling was that t e French River Cleen-up Pro ra did not
cover all the issues, both oresent a -id future, which could
have been address d by a less biased scope of’ work.
The Metcalf and Eddy staff apoeared to nave the exper
tise to present an unbiased sti dy of t ’e history and proble is
of’ the whole basin. For exa’nole, the fact tnat all indus-
tries in Webster and Dudley are being treated i the Treat-
ment Plaf ts and have a- ded no untreated waste to the im-
pound’ents in the last ten yeats is not noted.
Sincerely,
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FRENCH RIVER DRAFT SUPPLEMENTAL EIS
RESPONSE TO A. RODNEY KLEBART, LETTER OF
NOVEMBER 19, 1985
EPA feels that the French River ElS has been thorough and that the
scope of work was not biased. The EIS does state that industries in
Webster and Dudley have tied their wastes into the towns’ POTWs and no
longer discharge directly to the French River.
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Conservation Law Foundation of New England, Inc.
‘J J
Board of Directors
-ton Francis W. Hatch. Jr.
Cria”man h ,e Board
Dr. John M Teat
ce Chairman of the Board
Dav d F Cavers. Jr. Esq.
Secrera,y and T easurer
Nancy Clayton Anderson. Esq
coert Bac us, Esg.
Mr. John Bell
Professor William Bossed
Alexandra 1, Breed. Esg.
Russell L. 9rennemar ,. Esq.
Jonathan Brownell. Esq.
Charles C. Cabot. Jr., Esq.
Dr Donald G. ( mb
Donald L. Connors. Eso.
Mrs. Lee Dane
Mr Wilham L Duntey
Mr. Fredenc A. Eustis. II
Professor James A. Fay
Dr. Richard A. Flaveli
Dr. Robert L. French
Sarah U. B Henry. Esq.
Horace A. Hildreth. Jr Esq
Samuel Moat. Esq.
Mr Albert E. Mulhn. Jr.
Peter tiessen. C.P.A.
Pr&essor Russet! K. Osgood
Mrs. Sarah W. Richards
Hon. Francis W. Sargent
Mrs. Henry 0. Sharpe. Jr.
George 1. Shaw. Eso.
Or Ralpn Z. Sorenson
James W Slorey. Esq
Harot R. Ward. Esg.
Alan Wilson. Esq.
Douglas I. Foy, Esg.
Exec jtive Director
3 Joy Street
Boston. Massachusetts
02108-1497
(617) 742-2540
November 20, 1985
Larry MacMillan
Environmental Protection Agency
Environmental Evaluation Section
J.F.K. Federal Building
Boston, Massachusetts 02203
Dear Mr. MacMillan:
Thank you for the opportunity to submit comments
on the Draft Supplemental Environmer..tal Impact
Statement for the French River Cleanup Program in
Massachusetts and Connecticut. As reflected in our
comments, CLF appreciates the tremendous effort
EPA has expended in developing an effective
river cleanup program, and most notably in develop-
ing a more environmentally sound low flow augmenta-
tion proposal.
If you have any questions on our comments,
please do not hesitate to call.
Sincerely,
n’
Emily . Bateson
Programs Director
enclosure
EMB/ko
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$ Conservation Law Foundation of New England, Inc.
3 Street
3oston. Massachusetts
ZO8 -1497
6171742-2540
COMMENTS OF THE CONSERVATION LAW FOUNDATION
ON THE DRAFT SUPPLEMENTAL ENVIRONMENTAL
IMPACT STATEMENT
FOR THE FRENCH RIVER CLEANUP PROGRAM
IN MASSACHUSETTS AND CONNECTICUT
I. INTRODUCTION
The Conservation Law Foundation of New England, Inc. (“CLF”)
appreciates this opportunity to comment on the Draft Supplemental
Environmental Impact Statement (“SDEIS”) for the French River
Cleanup Program in Massachusetts and Connecticut. CLF fully
supports the Environmental Protection Agency’s (“EPA’s”) goal of
fishable/swimmable class B status for the French River, and
commends the agency’s decision to prepare this more comprehensive
EIS after reviewing the effects of the Hodges Village Damn low
flow augmentation proposal. We are extremely pleased to see that
further analysis has revealed an environmentally preferable
alternative site for low flow augmentation —— Buffunville Lake —
— and that 130 acres of wetlands will not be inundated in the
pursuit of higher water quality for the French River. Following
are more specific comments on the SDEIS.
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Conservation Law Foundation of New England, Inc.
II. Dam Removal
There is no question that the dams along the French River
have contributed greatly to the water quality problem: “The
cumulative effect of the large number of dams has been to cause
sluggish flow in many portions of the river, contributing to high
sediment deposition and poor water quality.” SDEIS at 3—4.
Although dam removal is briefly considered as a cleanup
alternative, it is unclear whether it was fully analyzed before
being rejected. It is extremely difficult to piece together from
the SDEIS the necessary information about the dams —— which are
private and which are being, or could be, used for hydropower,
for instance —— and equally difficult to determine their
costs/benefits to water quality. The improved flow and velocity
which would result from breaching the dams are never fully
weighed against the potential loss in reaeration that presently
occurs over the dam (although this tradeoff is generally
mentioned, SDEIS at 2—7). The SDEIS dismisses dam removal partly
because it would eliminate the potential recreational, wildlife
habitat, and hydropower uses of these structures. SDEIS at 2—7.
However, it remains uncertain whether recreation and wildlife do
or could profit from the dams, e.g.: “ [ recreational use] is
limited due to the river’s water quality, the barriers presented
by the dams...,” SDEIS at 3—89; “The dams act as barriers to free
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—3—
Conservation Law Foundation of New England, Inc.
use of the river for boating,” SDEIS at 3—89; “There is presently
little use of these sites (Perryville and Wilsonville) for
swimming, fishing, and boating,” SDEIS at 4—44; and “The
fisheries would, however, continue to be limited by the shallow
depth of the river and its impoundments...” SDEIS at 4—18.
Although CLF does not necessarily advocate breaching any of the
dams, it appears to be an alternative worthy of further analysis,
particularly in the case of dams that are not privately owned and
are already being proposed for sediment removal, such as
Perryville.
III. SEDIMENT REMOVAL
A. GrosvenOrdale : Sediment removal is an integral
component of ultimate French River cleanup. Therefore, CLF
wonders if there are reasons, other than cost, for not cleaning
out the sediments above the Grosvenordale dam. Although metal
concentrations are not quite as high as other areas being
cleaned, they “are still contaminated, particularly with arsenic,
chromium, lead, and mercury.” SDEIS at 3—39, see also Table 3—
12. Furthermore, sediment excavation upstream at the North
Grosvenordale impoundment will increase residence time there,
resulting in “a possibility that dissolved oxygen concentrations
in Grosvenordale would still violate the 5.0 nig/l on occasion.”
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—4—
Conservation Law Foundation of New England, Inc.
SDEIS at 5—10. It is the only area in significant violation of
priority pollutant standards and dissolved oxygen that has not
been recommended for sediment excavation. CLF recommends that
this possibility be considered and that the analysis underlying
the ultimate decision be more extensively set out in the Final
EIS.
B. Future sediment accumulation : Given the high
environmental and aesthetic costs of sediment accumulation in the
river to—date, and the high economic cost of removal, it is
essential to couple the present excavation efforts with
preventative steps for the future. The SDEIS is surprisingly
scanty on information concerning the source of the metals and
other pollutants, and on what steps are being taken to reduce
ongoing point sources. (Although upstream NPDES permits are
discussed, they are dismissed as having “relatively no impact on
the stressed areas.” SDEIS at 2—3.) It is our understanding that
a Webster/Dudley Pretreatment Program is being reviewed for
approval, which should ultimately reduce the source of many of
the priority pollutants now being found downstream. Personal
Communication, EPA. The Final EIS should discuss the issue of
pollution sources and future prevention in more detail. For
instance, will there be aggressive enforcement of industrial
violators of pretreatment regulations and NPDES permits? This
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—5—
Conservation Law Foundation of New England, Inc.
will be a critical factor for the future health of this
ecosystem.
Will there be frequent and accurate monitoring of water
quality, particularly of priority pollutants? As the EPA is
aware, prior testing has been hampered by the fact that “the
detection limits were in some cases higher than the levels of
chronic toxicity for these metals.” SDEIS at 3—34; see also
table 3—7. Prevention of future heavy metal accumulation will
avoid a twenty or thirty year recurring cycle of envirdnmental
degradation and ultimate sediment excavation.
IV. LOW FLOW AUGMENTATION
CLF is extremely pleased that another site -has been chosen
for the proposed low flow augmentation (“LFA”) of the French
River. However, we are concerned whether this option should be
implemented as the “initial activity” as planned, or whether it
would be more reasonable to implement LFA as a last resort, if
advanced treatment, pretreatment, and sediment removal are not
fully effective. We appreciate the fact that EPA is erring on
the side of caution and the environment by providing LFA even
though class B standards may be met without it (using a
conservative dissolved oxygen model which does not reflect
photosynthesis). However, it is clear that LFA should never
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—b—
Conservation Law Foundation of New England, Inc.
substitute for adequate cleanup of present or future pollution
sources, and its early implementation may inadvertantly slow down
advanced treatment plant completion, or discourage truly
stringent pretreatment standards. For instance, the SDEIS
asserts that LFA would:
dilute the concentration of BOD and other
pollutants...the benefit is particularly significant with
respect to the Webster/Dudley AWT facility, where metals
effluent limitations might otherwise require far more
costly polishing procedures .
SDEIS at 4—17 (emphasis added).
CLF sincerely hopes that this does not suggest a slackening
of all steps possible to reduce the pollution sources entering
the river. Although we are sympathetic to the fact that LFA is
federally funded, engineered river dilution must not replace
effective treatment and point source pollution reduction. See
also CLF’s comments on Hodges Village Dam LFA, May 29, 1984,
attached. LFA is similar in nature to instream aeration, which
was ultimately discarded in the SDEIS as a “band—aid’ measure
only.” SDEIS at 5—10. Although LFA may be a very effective
band—aid indeed, treating the symptoms of river pollution must
never detract from progress on the cure. CLF respectfully urges
EPA to’ ensure that the use of LFA, if ultimately necessary, is
for insurance management of BOD, DO, nitrogen, and other
transient pollutants only; and to preclude its use for diluticn
of persistent pollutants such as heavy metals. Dilution is not a
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—7—
Conservation Law Foundation of New England, Inc.
feasible method for cleanup of priority pollutants, and its
deceptive use may easily replace effective reduction of point
source pollution.
Finally, the Hodges Village Dam DEIS dismisses Buffumville
Lake as an LFA alternative partly because of high nutrieht
levels, particularly phosphorus: “Even with proper reservoir
preparation such as stripping of organic soil at the reservoir
bottom, high inflow nutrient levels in a larger pool could cause
algae blooms which would make releases unsuitable for low flow
augmentation.” Hodges Village DEIS at 2. This issue is not
reflected in the current SDEIS. If more recent testing has
dispelled the concern, itshculd be more fully explained in the
Final EIS so that the discrepancy in the two documents may be
reconciled.
Thank you again for this opportunity to comment on the
important issue of French River cleanup.
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FRENCH RIVER DRAFT SUPPLEMENTAL EIS
RESPONSE TO CONSERVATION LAW FOUNDATION OF NEW ENGLAND
COMMENTS OF NOVEMBER 20, 1985
Page 2, paragraph 1 and page 3, paragraph 1 : “Although dam removal
is briefly considered as a cleanup alternative, it is unclear whether it
was fully analyzed before being rejected. It is extremely difficult to
piece together from the SDEIS the necessary information about the dams --
which are private and which are being, or could be, used for hydropower,
for instance —— and equally difficult to determine their costs/benefits
to water quality. The improved flow and velocity which would result from
breaching the dams are never fully weighed against the potential loss in
reaeration that presently occurs over the dam (although this tradeoff is
generally mentioned, SDEIS at 2-7)... Although CliP does not necessarily
advocate breaching any of the dams, it appears to be an alternative
worthy of further analysis, particularly in the case of dams that are not
privately owned and are already being proposed for sediment removal, such
as Perryville.
EPA Response: Darn removal was considered in detail before it was
eliminated as an improvement alternative for the French River. The
removal of a darn would involve extensive sediment excavation in the
impoundment so as to prevent contaminated sediments from traveling
further downstream. Acquisition of the dams would be required as they
are privately owned. The combination of extensive sediment removal and
acquisition of the dams would be quite costly. Currently the
leaseholders and owners of the Wilsonville and North Grosvenordale danis
are investigating the potential for hydropower generation at their
dams. Darn removal would eliminate valuable resources such as wetlands in
Perryville and Langer’s Ponds and recreation in North Grosvenordale Pond
(its intended use). While the removal of dams would increase travel time
and therefore increase dissolved oxygen concentrations in the river, it
would also eliminate the increased dissolved oxygen concentrations due to
darn reaeration.
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Page 3, Paragraph 2 and Page 4, Paragraph 1 : “Sediment removal is
an integral component of ultimate French River cleanup. Therefore, CLF
wonders if there are reasons, other than cost, for not cleaning out the
sediments above the Grosvenordale dam. Although metal concentrations are
not quite as high as other areas being cleaned, they “are still
contaminated, particularly with arsenic, chromium, lead, and mercury.”
SDEIS at 3—39, see also Table 3—12. Furthermore, sediment excavation
upstream at the North Grosvenordale impoundment will increase residence
time there, resulting in “a possibility that dissolved oxygen
concentrations in Grosvenordale would still violate the 5.0 mq/l on
occasion.” SDEIS at 5-10. It is the only area in significant violation
of priority pollutant standards and dissolved oxygen that has not been
recommended for sediment excavation. CLF recommends that this
possibility be considered and that the analysis underlying the ultimate
decision be more extensively set out in the Final EIS.”
EPA Response: As presented in the modeling results of the Final
EIS, dissolved oxygen concentrations at Grosvenordale Pond will meet the
water quality criterion of 5 mg/l during 7Q10 low flow conditions with
the implementation of AWT at Webster-Dudley WWTP, low flow augmentation
from Buffumville Lake, sediment control at Perryville, Langers and North
Grosvenordale Ponds and instream aeration at North Grosvenordale Pond.
Because dissolved oxygen at Grosvenordale Pond will not violate the
standard of 5 mg/i, EPA doe not feel that additional improvement
alternatives are warranted. Although sediment samples from Grosvenordale
Pond indicate the presence of metals in the sediment, there is no
evidence that these sediments violate any applicable priority pollutant
standards.
Page 4, Paragraph 2 and Page 5, Paragraph 1 and 2 : “The SDEIS is
surprisingly scanty on information concerning the source of the metals
and other pollutants, and on what steps are being taken to reduce ongoing
point sources. (Although upstream NPDES permits are discussed, they are
dismissed as having “relatively no impact on the stressed areas.” SDEIS
at 2-3. It is our understanding that a Webster/Dudley Pretreatment
Program is being reviewed for approval, which should ultimately reduce
the source of many of the priority pollutants now being found
downstream. Personal Communication, EPA. The Final EIS should discuss
the issue of pollution sources and future prevention in more detail. For
instance, will there be aggressive enforcement of industrial violators of
pretreatment regulations and NPDES permits?
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Will there be frequent and accurate monitoring of water quality,
particularly of priority pollutants? As the EPA is aware, prior testing
has been hampered by the fact that “the detection limits were in some
cases higher than the levels of chronic toxicity for these metals.”
SDEIS at 3—34; see also Table 3—7. Prevention of future heavy metal
accumulation will avoid a twenty or thirty year recurring cycle of
environmental degradation and ultimate sediment excavation.”
EPA Response: The NPDES permits for Webster and Dudley set
stringent limits on the treatment plant’s effluent and require
development of a program to control local industrial waste. Sludge
handling at Webster-Dudley will prevent discharge and accumulation of
sludges in the French River. Compliance monitoring, including
biomonitoring to measure effluent toxicity, is included in the permits.
Pretreatment regulations will be aggressively enforced.
Page 5, Paragraph 2 and Page 6, Paragraphs 1 and 2 : CM ’ is
extremely pleased that another site has been chosen for the proposed low
flow augmentation (“LFA”) of the French River. However, we are concerned
whether this option should be implemented as the “initial activity” as
planned, or whether it would be more reasonable to implement LFA as a
last resort, if advanced treatment, pretreatment, and sediment removal
are not fully effective. We appreciate the fact that EPA is erring on
the side of caution and the environment by providing LFA even though
class B standards may be met without it (using a conservative dissolved
oxygen model which does not reflect photosynthesis). However, it is
clear that LFA should never substitute for adequate cleanup of present or
future pollution sources, and its early implementation may inadvertently
slow down advanced treatment plant completion, or discourage truly
stringent pretreatment standards. For instance, the SDEIS asserts the
LFA would:
dilute the concentration of BOD and other pollutants ... the benefit
is particularly significant with respect to the Webster/Dudley AWT
facility, where metals effluent limitations might otherwise require
far more costly polishing procedures .
SDEIS at 4-17 (emphasis added).
cLF respectfully urges EPA to ensure that the use of LFA, if
ultimately necessary, is for insurance management of BOD, DO, nitrogen,
and other transient pollutants only; and to preclude its use for dilution
of persistent pollutants such as heavy metals.”
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EPA Response: STREAM7B water quality modeling indicates that
advanced wastewater treatment, low flow augmentation, sediment removal
and instream aeration must all be implemented for the French River to
comply with the DO water quality standard of 5 mg/i. As is noted in the
EIS (Chapter 5) since LFA can be implemented relatively quickly, some
water quality benefits could be realized quickly. If following
implementation of other measures of the recommended plan it is found via
the monitoring program that LFA is no longer needed, it would be phased
out. The intent of LFA is not to provide a means to dilute point source
pollutants such as metals. A stringent pretreatment program must be
established to control industrial discharges to the Webster/Dudley
wastewater treatment plant and compliance with these requirements will be
expected.
Page 7, Paragraph 2 : “Finally, the Hodges Village Dam DEIS
dismisses Buffumville Lake as an LFA alternative partly because of high
nutrient levels, particularly phosphorus: “Even with proper reservoir
preparation such as stripping of organic soil at the reservoir bottom,
high inflow nutrient levels in a larger pool could cause algae blooms
which would make releases unsuitable for low flow augmentation.” Hodges
Village DEIS at 2. This issue is not reflected in the current SDEIS. If
more recent testing has dispelled the concern, it should be more fully
explained in the Final EIS so that the discrepancy in the two documents
may be reconciled.”
EPA Response: Additional information is included in the FSEIS
regarding impacts at Buffumville Lake due to the LFA alternative. Recent
water quality surveys have reported improvements in the nutrient levels
at Buffumviile. According to the U.S. Army Corps of Engineers
(Buffurnville Lake Water Quality Evaluation Update, July, 198 4), the
threshold levels for potential algae blooms are 0.3 mg/i for total
nitrogen and 0.015 mg/i for phosphorus. In 1983 samples collected at the
outlet of Buffumvilie Lake contained 0.07 mg/i of nitrogen and O.O1U mg/i
of phosphorus. These values are much lower than those measured in the
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French River. According to the U.S. Army Corps of Engineers,
(Buffumville Lake Water Quality Evaluation Update, July 1981 ,) “...
Buffumville Lake was found to be slightly eutrophic for the period 1978
to 1982, but has improved to a borderline mesotrophic/oligotrophic
condition in 1982 and 1983.” In addition, the increased water level
necessary for adequate low flow augmentation is within the operational
level fluctuation (as based on the past five years operational records)
and thus there would not be any significant leaching of nutrients from
soils that may be periodically inundated.
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United States Department of the Interior
OFFICE OF THE SECRETARY
Office of Environmental Project Review
1500 Custom House
l PLY ER TO 165 State Street
Boston Massachusetts 02109
4_ ‘
November 26, 1985
Mr. Michael R. Deland
Regional Administrator
Environmental Protection Agency
Government Center, JFK Federal Building
Boston, Massachusetts 02203
Dear Mr. Deland:
This is in response to your request for Department of the
Interior review of the Draft Supplemental Environmental Impact
Statement (DSEIS) for the French River Cleanup Program,
Connecticut and Massachusetts (ER 85/1504).
The DSEIS is a substantial improvement over the previous Hodges
Village EIS. This document includes more background data per-
taining to the existing environmental setting in the French River
Basin than was in the DEIS and discusses several alternative
solutions to the existing water quality problems. However, in
our opinion, the document still has a number of significant
deficiencies. “The background data does not provide a clear
discussion of the basic causes and sources of the existing water
quality problem. This is extremely important if reviewers are to
be in a position to understand the root causes of the problem and
therefore, be in an informed position to determine what reaso-
nable alternatives to the proposed action might consist of. A
number of reasonable/practicable alternatives were dismissed
summarily in Chapter 2, while others were simply not considered.
Among these are higher levels of advanced waste treatment beyond
nitrification at Webster-Dudley and the various flow reduction or
waste load allocation measures at Webster—Dudley, including the
very significant industrial flow components and possible combina-
tions of these and other alternatives. The alternatives that
were discussed in the document did not have a similar level of
detail comparable to the previous Hodges Village proposal.
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Specific Comments:
The sections in the DSEIS pertaining to problem identification
and affected environment do not provide sufficient data on the
sources of pollution loading and therefore, the basic reasons for
the water quality problems in the lower French River Basin. The
basic sources of the water quality problems should be fully and
completely discussed in the PSEIS. Data in the EPA Advanced
Treatment-Task Force Review Report and facilities plans which
detail the specific sources and causes of the water quality
problem under existing conditions and with sludge handling and
nitrification in place should be summarized and incorporated in
the Final Supplemental Environmental Imapact Statement (FSEIS).
The significance of the industrial loading to the Webster
facility should be fully discussed.
One very important factor, the time element, was omitted from the
discussion of the no action and other alternatives. The no
action evaluation must be conducted using target years after the
completion of the sludge handling and nitrification facilities at
Webster-Dudley,. An evaluation of this alternative at a single
instantaneous point in time is of limited value, because of the
natural physical, chemical and biological cleansing processes
that will take place in the river downstream of Webster-Dudley.
Once the solids problem is corrected, large masses of sludge will
lift off the river bottom and float downstream to unknown desti-
nations. This action is currently taking place in the river but
the inputs from Webster-Dudley exceed outputs and hence, the
sludge masses and consequently, sediment oxygen demand (SOD)
loadings are increasing. Since the SOD accounts for a signifi-
cant dissolved oxygen requirement, this natural decay process
should result in a gradual improvement in dissolved oxygen
conditions as time passes. Therefore, the FSEIS should discuss
the most probable scenario for each section of river downstream
of Webster-Dudley at selected time intervals during the life of
the project. This discussion should show the physical, chemical
and biological changes expected in the Perryville, Langers and
North Grosvenordale impoundments. In addition, these projected
conditions should be related to existing and future conditions in
North Village Pond above Webster-Dudley as it is important to
relate downstream conditions to background conditions upstream.
The FSEIS should state that wide diurnal fluctuations in dis-
solved oxygen do exist in areas upstream from Webster-Dudley due
to extensive wetlands and backwater areas adjacent to the river.
Additionally, the document should state that significant differ-
ences between dissolved oxygen and temperature exist between the
main river channel and backwater areas and that relatively little
or no mixing of these water masses occurs at low river flows. In
the FSEIS, EPA should indicate that it will conduct water quality
surveys on the river to document improvements resulting from the
correction of the solids problem, the addition of seasonal nitri
fication and natural cleansing actions in the river.
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The DSEIS provides a general or theoretical discussion of the
sediment control alternative and potential implementation
methods. The level of detail when compared to the Hodges Village
alternative in the Corps DEIS is such that more questions are
raised than answered. A feasibility study comparable in detail
to that conducted for Hodges Village would be necessary to
reasonably investigate and demonstrate the practicability and
environmental consequences of this alternative as was recommended
by the FWS in previous correspondence (March 30, 1984). For
example, what impact does the high phosphorous loading have on
dissolved oxygen and SOD levels in these impoundments with or
without sediment controls? Could algae blooms subsequently cause
an SOD problem after these impoundments were dredged? What State
or Federal agency has the authority to conduct. a full feasibility
study of the sediment control alternative and subsequently,
implement the action? How do SOD rates in the downstream
impoundments relate to upstream impoundments? What and where are
the alternative disposal sites for the dredge material? Would
dredging cause the existing dams to become unstable thereby
jeopardizing the wetland systems?
On page 4—38 of the DSEIS, a statement is made that the sediment
control alternative, in conjunction with advanced treatment,
would provide for Class B water quality standards at the 7Q10
flow of 11.5 cfs. Using the most recent 7Q10 flow of 14 cfs, the
resultant dissolved oxygen would be somewhat higher. However,
the recommended plan includes advanced treatment, sediment
control and flow augmentation. No reason is given for including
flow augmentation when sediment control and advanced treatment
alone would meet project objectives. The EPA Advanced Treatment
Task Force Report, dated January 1985, also concluded that water
quality standards would be met without flow augmentation. While
sediment control is not preferred by us as a first choice option,
it nonetheless is an action directed at some of the basic causes
of the water quality problem unlike instream aeration and flow
augmentation. Further in-depth studies would be required to
demonstrate the feasibility and environmental acceptability of
this alternative.
Instream aeration was dismissed as a viable alternative (pg. 5-
10) because it was considered to be a “bandaid” approach in that
it treated the symptoms and not the basic causes of the water
quality problem. We concur.
With regard to the flow augmentation alternative in general, we
believe the long—term socio —economic—eflVirOflmefltal consequences
were inadequately discussed. The FWS previously (March 30, 1984)
expressed concerns about the long-term direct and indirect conse-
quences of this pollution dilution concept. We believe flow
augmentation is another “bandaid” approach to the water quality
C—95
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problems in the basin in that it only treats symptoms of the
problem, not the basic problem itself. It should be discarded as
a ‘bandai& concept in the same fashion that instream aeration
was discarded. Additionally, flow augmentation coupled with
advanced treatment does not solve the water quality problem
downstream from Webster-Dudley. Water quality standards will
still be violated if this alternative is implemented. The 22 cfs
flow augmentation plan only provides for a 1.0 mg/i increase in
dissolved oxygen above ambient levels. Since this would not
solve the water quality problem, it is quite conceivable that the
augmentation flows would be increased after implementation as an
expedient solution to abate downstream pollution.
With regards to the Buffuinville analysis, we believe a signifi-
cant difference exists in the level of detail for it and the
previous Hodges Village Proposal. Insufficient data is presented
to allow for an adequate evaluation of the consequences of imple-
menting this alternative. Details concerning site preparation
and project operation are vague or missing. How many acres of
land and water would be impacted? What are the habitat types and
how many acres of each would be impacted? Would the reservoir
need to be cleared, grubbed and stripped as was proposed for
Hodges Village? Does the proposal comply with the 404(b)(l)
Guidelines if wetlands are involved? If all of these and many
other questions and analyses are being left for a future feasi-
bility study to be conducted by a yet-undetermined party or
agency, it does not constitute proper integration of NEPA into
the planning process.
Two generic alternatives previously suggested by FWS that were
not given a rigorous and objective evaluation include AWT beyond
nitrification and various flow reduction or load allocation
options. Inasmuch as the problem at Webster-Dudley occurs during
the workweek (Monday - Friday) and is due to heavy biological
oxygen demand loading with flows from industrial sources, the
PSEIS should evaluate measures to control the problem at its
source(s). This action could be accomplished administratively by
EPA and would essentially entail an industrial BOD load alloca-
tion based on river flow and assimilative capacity. This type of
waste load allocation is required by the Clean Water Act when
technology based treatment measures alone are not sufficient to
enable a water body to meet national goal uses. The mere fact
that industrial discharges are dumping into the Webster-Dudley
municipal sewer system should not preclude EPA from vigorously
evaluating this solution. In evaluating this alternative, EPA
should demonstrate beyond any reasonable doubt that everything
that can be done, is in fact, being done to control the pollution
problem at its source.
C —96
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The alternative of utilizing more advanced waste treatment
systems beyond nitrification should be fully evaluated in the
FSEIS. In our opinion, merely referring to previously completed
Facilities Plans is not sufficient for NEPA compliance. Proven
advanced waste treatment systems that are practicable in this
climate should be an integral part of the analysis. Combinations
of advanced waste treatment systems and flow reduction or BOD
load allocations should also be evaluated.
Summary
In summary, we remain concerned with various aspects of the
French River Water Quality Program. While we support the overall
objectives of the program to restore swimmable-fishable waters to
the French River, we remain opposed to some of the alternative
solutions being considered to solve or ameliorate the water
quality problems. We remain opposed to low flow augmentation.
The flow augmentation alternative is inconsistent with the goals
and objectives of the Clean Water Act. Additionally, once the
precedent has been established by EPA of accepting flow augmenta-
tion (dilution) ,as an alternative solution to adequate waste
treatment, future resource conflicts would be unavoidable in this
and perhaps other basins as well. We also note that the previous
Hodges Village proposal has not been formally dropped from con-
sideration by EPA. We request that EPA clearly do so in the
PSEIS.
We urge EPA to carefully reevaluate the alternative plan of
controlling the pollution problem at its source(s). Once this
has been accomplished, the sediment control options should be
investigated to determine feasible and environmentally acceptable
methods of solving the remaining water quality problems.
In our May 24, 1984 comment letter on the Corps DEIS, we indi-
cated that unless issues addressed in that letter were resolved
prior to release of the FEIS, it would be a candidate for ref er-
ral to the Council on Environmental Quality. A number of our
earlier concurs have been addressed in the DSEIS. However, if
flow augmentation is part of the selected plan in the FSEIS, we
would again consider CEQ referral.
In summary, of the alternatives presented in the DSEIS for
detailed evaluation, the action which includes sludge management
and nitrification (“no action”) is our preferred alternative at
this time.
Sincerely yours,
/
;T z.
William Patterson
Regional Environmental Officer
C —97
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FRENCH RIVER DRAFT EIS
RESPONSE TO U.S. DEPT. OF INTERIOR LETTER
OF NOVEMBER 26, 1985
Page 1, par. 2, line 7-12 . Review comment: “The background data
does not provide a clear discussion of the basic causes and sources of
the existing water quality problem” in the French River.
EPA response: Extensive discussion of water quality conditions and
problems in the French River is provided in Chapter 3 of the DSEIS and in
the DEIS for the Hodges Village Project. The causes of the existing
water quality problems in the river are related to the history of
industrial and domestic discharges to the river, the construction of
numerous mill dams along the river, sediment deposits in the river and
impoundments and naturally occurring periods of low flow. Modeling
presented in the DSEIS quantifies the impact of each of the major problem
sources (Webster—Dudley discharge, SOD, low river flows) on water quality
(dissolved oxygen) in the river and impoundments
Page 1, par. 2, line 12—21 . Review comment: “A number of
reasonable/practicable alternatives were dismissed summarily in Chapter
2, while others were simply not considered. Among these are higher
levels of advanced waste treatment beyond nitrification at Webster-Dudley
and the various flow reduction or waste load allocation measures at
Webster-Dudley, including the very significant industrial flow components
and possible combination of these and other alternatives. The
alternatives that were discussed in the document did not have a similar
level of detail comparable to the previous Hodges Village proposal.”
EPA response: The level of treatment to be provided at the
Webster-Dudley regional treatment plant has been thoroughly evaluated in
facilities plans and in the EPA Advanced Treatment Task Force Review
Report. Advanced wastewater treatment (AWT) with nitrification and
phosphorus removal is the proposed level of treatment. The summer
monthly average permit limitations for BOD 5 and NH 3 for the proposed
facility are 10 mg/i and 2 mg/i, respectively. As stated in the Final
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EIS and supported in the facilities plan, additional treatment at the
Webster-Dudley facility would result in insignificant improvement in
effluent quality at a considerable cost. Results from dissolved oxygen
modeling comparing AWT with complete removal of the Webster-Dudley
discharge (both industrial and domestic) are presented in Chapter 11 of
the FEIS. These results indicate that with the Webster-Dudley discharge
completely eliminated, the improvement in river DO is minimal when
compared to river DO concentrations with AWT at the facility. It should
be noted even with the Webster-Dudley discharge or loading completely
removed, the water quality criterion for DO is violated due to SOD
demands using the revised 7Q10 flow of 114.8 cfs. (See discussion of new
7Q10 in EPA response to comment Page, 3, Par. 2, lines 1-11 — later in
this response.) The alternatives in the Draft EIS were evaluated with a
sufficient level of detail so as to determine the most feasible plan for
meeting water quality standards in the river. This evaluation included
an assessment of the environmental impacts associated with each
alternative.
Page 2, par. 1 . Review comment: “The sections of the DSEIS
pertaining to problem identification and affected environment do not
provide sufficient data on the sources of pollution loading and
therefore, the basic reasons for the water quality problems in the lower
French River Basin. The basic sources of the water quality problems
should be fully and completely discussed in the FSEIS. Data in the EPA
Advanced Treatment—Task Force Review Report and facilities plans which
detail the specific sources and causes of the water quality problem under
existing conditions and with sludge handling and nitrification in place
should be summarized and incorporated in the Final Supplemental
Environmental Impact Statement (FSEIS). The significance of the
industrial loading to the Webster facility should be fully discussed.”
EPA response: See response to comment on page 1, par. 2, lines 7-.
12. The conclusions reached from the Webster-Dudley facility plan
(advanced treatment) and EPA approval of this plan are noted in the DSEIS
C-99
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(pg. 2-2). The EPA Advanced Treatment Task Force Report and the facility
plan for Webster-Dudley provide more specific information on flows and
loads front the treatment plant. Specific references to this EPA report
have been added to Chapter 2 of the Final EIS.
Page 2, par. 2, lines 1-25 . Review comment: “One very important
factor, the time element, was omitted from the discussion of the no
action and other alternatives. The no action evaluation must be
conducted using target years after the completion of the sludge handling
and nitrification facilities at Webster-Dudley. An evaluation of this
alternative at a single instantaneous point in time is of limited value,
because of the natural physical, chemical and biological cleansing
processes that will take place in the river downstream of Webster—
Dudley. Once the solids problem is corrected, large masses of sludge
will lift off the river bottom and float downstream to unknown desti-
nations. This action is currently taking place in the river but the
inputs from Webster—Dudley exceed outputs and hence, the sludge masses
and consequently, sediment oxygen demand (SOD) loadings are increasing.
Since the SOD accounts for a significant dissolved oxygen requirement,
this natural decay process should result in a gradual improvement in
dissolved oxygen conditions as time passes. Therefore, the FSEIS should
discuss the most probable scenario for each section of river downstream
of Webster-Dudley at selected time intervals during the life of the
project. This discussion should show the physical, chemical and
biological changes expected in the Perryville, Lan gers and North
Grosvenordale impoundments. In addition, these projected conditions
should be related to existing and future conditions in North Village Pond
above Webster—Dudley as it is important to relate downstream conditions
to background conditions upstream.”
EPA response: There is no way to precisely quantify the extent of
sediment resuspension that will occur nor the rate at which it will
occur. The areas where the most severe DO impacts are experienced are in
the downstream impoundments. In these areas flow velocities are low, and
sediment resuspension is expected to be minimal. Thus, by not reducing
the SOD demand in the no-action evaluation a reasonably accurate
assessment of water quality impacts in the critical areas is obtained.
Physical, chemical and biological changes in the various segments of the
river are fully discussed in Chapters LI and 5 of the EIS. Reducing SOD,
the AT upgrade at Webster-Dudley, LFA and instreain aeration should
C -100
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provide significant improvements in the water quality of the French River
(based on the modeling results). The proposed sediment control options
also are important in establishing a healthy arid diverse benthic
community and eliminating objectionable bottom deposits.
Page 2, par. 2, lines 26-32 . Review comment: “The PSEIS should
state that wide diurnal fluctuations in dissolved oxygen do exist in
areas upstream from Webster—Dudley due to extensive wetlands and
backwater areas adjacent to the river. Additionally, the document should
state that significant differences between dissolved oxygen and
temperature exist between the main river channel and backwater areas and
that relatively little or rio mixing of these water masses occurs at low
river flows.”
EPA response: Quantitative data linking diurnal DO fluctuation to
the wetlands and backwater areas adjacent to the French River are not
available. We understand D.O. and temperature variations do exist but
there is a paucity of data to document these differences. For instance,
U.S. Fish & Wildlife Service field personnel found pockets of higher D.O.
(and fish) 200 yards upstream of the Perryville impoundment in the summer
of 1985 (V. Lang, 985 personal communication).
Page 2, par. 2, lines 32-36 . Review comment: “In the FSEIS, EPA
should indicate that it will conduct water quality surveys on the river
to document improvements resulting from the correction of the solids
problem, the addition of seasonal nItrification and natural cleansing
actions in the river.”
EPA response: EPA intends to monitor river water quality following
implementation of the recommended plan to document improvements from the
proposed actions. A statement to this effect has been added to Chapter 5
of the EIS.
Page 3, par. 1 . Review comment: “A feasibility study comparable to
that conducted for Hodges village would be necessary to reasonably
investigate and demonstrate the practicability and environmental
c—lol
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consequences of this alternative (sediment control) as was recommended by
the FWS in previous correspondence (March 30, 1984). For example, what
impact does this high phosphorous loading have on dissolved oxygen and
SOD levels in these impoundments with or without sediment controls?
Could algae blooms subsequently cause an SOD problem after these
impoundments were dredged? What State or Federal agency has the
authority to conduct a full feasibility study of the sediment control
alternative and subsequently, implement the action? How do SOD rates in
the downstream impoundments relate to upstream impoundments? What and
where are the alternative disposal sites for the dredge material? Would
dredging cause the existing dams to become unstable thereby jeopardizing
the wetland systems?”
EPA response: The alternatives evaluated in the DSEIS were done so
with a sufficient level of detail so as to determine the most feasible
plan for meeting water quality standards in the river. General
information regarding dredged material disposal locations is presented in
the DSEIS. Additional information regarding dredged material disposal
will be developed at the time of the Section 14014 permit application.
Should a more detailed feasibility study be required when this
application is filed, that would be the time for the conduct of such
studies. The issue of dam stability during and following dredging will
be resolved during design of the dredging program. An investigation of
the existing dams may be required, and it may be found that measures will
be required to assure the stability of the structures. This may include
such measures as restricted dredging near the structures or installation
of sheeting at the structures.
Phosphorus removal at Webster-Dudley is part of the planned AWT
upgrade. This will have a significant impact on reducing nutrients
available for algal growth in the river. In addition, sludge discharges
to the river will be eliminated. Thus, following sediment removal and
implementation of AWT, the sources of existing and potential SOD will
have been substantially reduced. The dissolved oxygen modeling has not
C—102
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included algal activity since EPA routinely does not include algal
production in any model work related to NPDES permit decisions. This is
because in rivers which have a net positive algal production, there is no
guarantee that the same production will occur during periods of critical
low flow.
Page 3, par. 2, lines 1-11 . Review comment: “On page 4-38 of the
DSEIS, a statement is made that the sediment control alternative, in
conjunction with advanced treatment, would provide for Class B water
quality standards at the 7QlO flow of 11.5 cfs. Using the most recent
7Q10 flow of 14 cfs, the resultant dissolved oxygen would be somewhat
higher. However, the recommended plan includes advanced treatment,
sediment control and flow augmentation. No reason is given for including
flow augmentation when sediment control and advanced treatment alone
would meet project objectives. The EPA Advanced Treatment Task Force
Report, dated January 1985, also concluded that water quality standards
would be met without flow augmentation.”
EPA response: On page -38 of the Draft EIS, the statement that AWT
and sediment control would result in achievement of Class B water quality
standards has been taken out of context, and has been eliminated from the
EIS. The hypothetical assumption that SOD could be completely eliminated
is probably impossible to achieve, although substantial reduction is
expected. Also, the referenced sediment control option assumes no
alteration of the flow characteristics in the river. It is stated on pg.
14.. .38 of the Draft EIS that sediment removal at North Grosvenordale would
alter the hydraulics in the impoundment, and water quality modeling
indicates that DO in the impoundment would be reduced by approximately
0.3 mg/l due to these hydraulic modifications. Thus, a more realistic
look at the sediment control alternative indicates that water quality
standards would not be met during the 7Q10 flow of 11.5 cfs. The most
recent 7Q10 flow published by USGS is 1 4.8 cfs, for the period of record
from 1950 to 1980 at the French River gage at Webster. This new 7Q10
C-103
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flow was provided just as the Draft EIS was going to press. Dissolved
oxygen has been modeled with this new low flow value assuming sediment
removal is implemented. Using the higher 7Q10 flow, the modeling results
indicate a DO level below 5.0 mg/l in all of the downstream impoundments.
The EPA Advanced Treatment Report did not conclude “water quality
standards would be met without flow augmentation.” The report found that
AT would offer a significant improvement in water quality, although AT
alone would not enable water quality standards to be met (DO of 5 mg/i).
Page 3, par. 2, lines 11-17 . Review comment: While sediment control
is not preferred by us as a first choice option, it nonetheless is an
action directed at some of the basic causes of the water quality problem
unlike instream aeration and flow augmentation. Further in—depth studies
would be required to demonstrate the feasibility and environmental
acceptability of this alternative.
EPA response: It has been clearly demonstrated in the Final EIS that
sediment control is required to achieve water quality standards in the
French River. Sediment control addresses a basic cause of water quality
problems in the river and impoundments. The impacts of sediment control
in the Perryville, Langer’s and North Grosvenordale impoundments are
described in Chapter 14 of the EIS. Additional information on dredged
material disposal will be developed at the time of the Section 14O 4 permit
application.
Page 3, par. 3 . Review comment: Instream aeration was dismissed as
a viable alternative because it was considered to be a “bandaid” approach
in that it treated the symptoms and not the basic causes of the water
quality problem. We concur.
EPA response: Instream aeration is less preferable than other
alternatives for several reasons. These reasons are because it is
difficult to implement institutionally, it may inhibit the planned
C-i 014
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recreational uses of North Grosvenordale Pond, it requires continued
operation and maintenance subsidies, and also, it does nothing to
eliminate the sources of the water quality problems. Thus, there are
several reasons for instream aeration being less preferable than other
alternatives. Nevertheless, instream aeration may be needed to achieve a
DO of 5 mg/i in the North Grosvenordale impoundment as a supplement to
the other alternatives (AWT, LFA and sediment control.)
Page 3, par. 14• Review comment. “With regard to the flow
augmentation alternative in general, we believe the long-term
socio—economic—environmental consequences were inadequately discussed.
The FWS previously (March 30, 1984) expressed concerns about the long-
term direct and indirect consequences of this pollution dilution
concept. We believe flow augmentation is another “bandaid” approach to
the problems in the basin in that it treats only symptoms of the problem,
not the basic problem itself. It should be discarded as a “bandaid”
concept in the same fashion that instream aeration was discarded.”
EPA response: The impacts of low flow augmentation are thoroughly
discussed in Chapter L of the EIS. From one perspective low flow
augmentation may be considered as a “bandaid” approach to the problem,
although this point of view does not necessarily focus on the water
quality of the French River. In addition to increasing DO concentration,
low flow augmentation will reduce concentrations of nutrients, metals and
other pollutants from sources such as rainfall runoff and river bottom
sediments. Also, low flow augmentation can be achieved relatively
rapidly, thus providing some relief to water quality problems in the
immediate future. If following implementation of AWT, LFA, and the
proposed sediment control measures, it is found via the monitoring
program some years later that low flow augmentation is not needed to
achieve water quality standards, then low flow augmentation will be
phased out of the program. Text to this effect is included in Chapter 5
of the Final EIS.
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Page 4, par. 1, lines 4-12 . Review comment: “Additionally, flow
augmentation coupled with advanced treatment does not solve the water
quality problem downstream from Webster—Dudley. Water quality standards
will still be violated if this alternative is implemented. The 22 cfs
flow augmentation plan only provides for a 1.0 mg/I increase in dissolved
oxygen above ambient levels. Since this would not solve the water
quality problem, it is quite conceivable that the augmentation flows
would be increased after implementation as an expedient solution to abate
downstream pollution.”
EPA response: We concur that low flow augmentation combined with AWT
at Webster-Dudley is not sufficient by itself to solve the water quality
problems in the river. The recommended plan calls for AWT, low flow
augmentation and sediment control, with implementation of instream
aeration if the monitoring program shows its necessity. It is
demonstrated in the Draft EIS that this recommended plan will result in
water quality improvements sufficient to eliminate violation of the DO
criteria in the river. There is no intention to increase low flow
augmentation to a level above 22 cfs in lieu of other segments of the
recommended plan. Thus, the contention that augmentation flows will be
increased is unwarranted.
Page 4, par. 2 . Review comment: “With regards to the Buffumville
analysis, we believe a significant difference exists in the level of
detail for it and the previous Hodges Village Proposal. Insufficient
data is presented to allow for an adequate evaluation of the consequences
of implementing this alternative. Details concerning site preparation
and project operation are vague or missing. How many acres of land and
water would be impacted? What are the habitat types and how many acres
of each would be impacted? Would the reservoir need to be cleared,
grubbed and stripped as was proposed for Hodges Village? Does the
proposal comply with the 404(b) (1) Guidelines if wetlands are involved?
If ll of these and many other questions and analyses are being left for
a future feasibility study to be conducted by a yet-undetermined party or
agency, it does not constitute proper integration of NEPA into the
planning process”.
EPA response: Additional information has been added to the FEIS
regarding impacts at Buffumville Reservoir due to the low flow
augmentation alternative. This information is summarized in the
following paragraphs.
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The existing wetlands surrounding Buffumville Reservoir comprise
approximately six acres. This includes all areas of emergent macrophytes
as well as areas of palustrine scrub shrub and palustrine forest. Based
on the existing operational strategy of water level control within the
reservoir over the past five years, these wetlands have become
established as zones that are spacially static in terms of relative areal
extent, when contrasted with the temporal dynamic changes in water levels
within the reservoir. Only those emergent macrophytes located along the
central western edge of the reservoir might be subject to habitat/cover
type change should water levels be operated as recommended to accommodate
low flow augmentation. The central western edge is the largest expanse
of flat low area which, with additional inundation, might result in the
change from palustrine scrub shrub to emergent macrophyte wetland habitat
cover type. If seasonal levels of water were more than two feet higher
in elevation than water levels as recorded over the past five years,
during the active plant growing season (April to September), then less
than two acres of emergent macrophytes might undergo ecological
succession and be transformed by the seasonally higher water levels. All
the areas surrounding the reservoir where there exist large expanses of
deciduous and coniferous trees are reasonably steep grades with slopes of
2:1 to 5:1. Field survey indicated that these areas are currently, to a
large extent, devoid of standing trees within 20 horizontal feet of
existing water levels (when water level was 1.6 feet above the normal
pool elevation of Lt92.Sft MSL). Thus, water levels would have to be
increased by over 5 to 6 feet above normal pool elevation before
operational problems would exist as a result of trees being inundated,
killed, and falling into the reservoir. The increased water level
C-107
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necessary for adequate low flow augmentation is completely within the
operational level fluctuation (as based on the past five years
operational records) and thus there also would not be any significant
leaching of nutrients from soils that may be periodically inundated.
This conclusion is reached since these same soils have been subject to
such inundation and leaching activities during the past five or more
years of reservoir operation.
The LFA proposal requires a maximum increase in the normal operating
pool elevation of 2.5 ft. to elevation 1495.0 during the spring. This
will provide the necessary 500 acre—ft. of added storage for low flow
augmentation should it be necessary. The table below summarizes the
variation in water level in the reservoir from water year 1980 to 19814.
Maximum
Water Year Pool Number of Days Number of Days
Elevation Pool Exceeded Pool Exceeded
(NGVD) Elevation 1495.0 Elevation 1492.5
1980 501.0 15 205
1981 1499.6 10 185
1982 506.3 31 280
1983 5014.0 142 232
19814 506.6 30 227
This information documents that the proposed seasonal increase in
operating pool elevation is within the range of pool elevations currently
experienced at the reservoir. No clearing and grubbing is anticipated to
be necessary due to the proposed project at Buffumville.
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With respect to compliance with 40 1 4(b)(1) guidelines, even though a
4O4 permit would not be required at Buffumville since no dredge and fill
activities will occur, a table has been prepared comparing each 1 404(b)(1)
guidelines with activities proposed at Buffumville and in the previous
Hodges Village EIS. This table has been included in Chapter 2 of the
FSEIS.
Page )4, par. 3 . Review comment: “Two generic alternatives
previously suggested by FWS that were not given a rigorous and objective
evaluation include AWT beyond nitrification and various flow reduction or
load allocation options. Inasmuch as the problem at Webster-Dudley
occurs during the workweek (Monday — Friday) and is due to heavy
biological oxygen demand loading with flows from industrial sources, the
FSEIS should evaluate measures to control the problem at its source(s).
This action could be accomplished administratively by EPA and would
essentially entail an industrial BOD load allocation based on river flow
and assimilative capacity. This type of waste load allocation is
required by the Clean Water Act when technology based treatment measures
alone are not sufficient to enable a water body to meet national goal
uses. The mere fact that industrial discharges are dumping into the
Webster—Dudley municipal sewer system should not preclude EPA from
vigorously evaluating this solution. In evaluating this alternative, EPA
should demonstrate beyond any reasonable doubt that everything that can
be done, is in fact, being done to control the pollution problem at its
source.
EPA response: Information regarding AWT beyond nitrification and
waste load allocations was presented previously in response to the review
comment on page 1, par. 2, lines 12 to 21. As presented in Chapter 24 of
the Final EIS, even with both the industrial and domestic discharges at
Webster—Dudley eliminated, water quality standards would not be met
without additional remedial measures.
As its recommended plan to improve water quality in the French River, the
EIS proposes the following activities: low flow augmentation to 22 cfs
at the Webster gage from Buffumville Lake, channel excavation and
wetlands isolation at Perryville and Langer’s Ponds, sediment excavation
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at North Grosvenordale Pond, and instream aeration at North Grosvenordale
Pond. These improvement alternatives have been proposed for the French
River because current information, including several years’ worth of
detailed water quality modeling, indicates that no amount of’ treatment at
Webster and Dudley (including termination of’ the discharges) will alone
enable water quality standards for dissolved oxygen to be met. According
to Section 102(b) of the CWA and to EPA policies, flow augmentation may
be considered to achieve water quality Standards only as long as adequate
treatment is installed to minimize pollutants from point sources. EPA
has determined that advanced treatment with nitrification is “adequate
treatment” for Webster and Dudley.
Page 5, par. 1 . Review comment: The alternative of utilizing more
advanced waste treatment systems beyond nitrification should be fully
evaluated in the FSEIS. In our opinion, merely referring to previously
completed Facilities Plans is not sufficient for NEPA compliance. Proven
advanced waste treatment systems that are practicable in this climate
should be an integral part of the analysis. Combinations of advanced
waste treatment systems and flow reduction or ROD load allocations should
also be evaluated.
EPA response: See response to previous review comment.
Page 5, par. 2 . Review comments: In summary, we remain concerned
with various aspects of the French River Water Quality Program. While we
support the overall objectives of the program to restore swimmable—
fishable waters to the French River, we remain opposed to some of the
alternative solutions being considered to solve or ameliorate the water
quality problems. We remain opposed to low flow augmentation. The flow
augmentation alternative is inconsistent with the goals and objectives of
the Clean Water Act. Additionally, once the precedent has been
established by EPA of accepting flow augmentation (dilution) as an
alternative solution to adequate waste treatment, future resource
conflicts would be unavoidable in this and perhaps other basins as
well. We also note that the previous Hodges Village proposal has not
been formally dropped from consideration by EPA. We request that EPA
clearly do so in the PSEIS.
C—i 10
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EPA response: As was discussed previously, the low flow augmentation
proposal is consistent with the Clean Water Act as an ecologically and
economically feasible approach to attaining water quality standards at as
early a date as possible. It has been pointed out in the FEIS that
following implementation of AWT and sediment control measures, it may be
possible to phase out LFA if it is demonstrated that it is not necessary
to meet water quality standards. The post implementation monitoring
program proposed by EPA will be used to determine the necessity of LFA in
the future. As a result of a comparison of alternatives incorporated in
the Final EIS, Hodges Village was eliminated from further consideration
because of the tremendous negative impacts of destruction of 130 acres of
wetland as well as other environmental considerations.
Page 5, par. 3 . Review comment: “We urge EPA to carefully
reevaluate the alternative plan of controlling the pollution problem at
its source(s). Once this has been accomplished, the sediment control
options should be investigated to determine feasible and environmentally
acceptable methods of solving the remaining water quality problems.
EPA response: EPA believes that all alternative plans for
controlling the pollution problems at their sources have been prudently
addressed, and that the alternatives presented in the DSEIS are indeed
the most environmentally feasible for solving the remaining water quality
problems. Therefore, reevaluation is not appropriate.
Page 5, par. 4 . Review comment: “In our May 24, 1984 comment letter
on the Corps’ DEIS, we indicated that unless issues addressed in that
letter were resolved prior to release of the FEIS, it would be a
candidate for referral to the Council on Environmental Quality. A number
of our earlier (concerns) have been addressed in the DSEIS. However, if
flow augmentation is part of the selected plan in the PSEIS, we would
again consider CEQ referral.”
C-i 11
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EPA response: EPA believes that prudent indepth attempts have been
made to address the FWS concerns expressed in the May 2l , 19814 comment
letter relative to a completely different project, Hodges Village. EPA
believes that the EWS should fully evaluate the quantitative information
on low flow augmentation, combined with findings on the most
environmentally feasible means of abating the pollution problems in the
French River, before making a premature conclusion that this project
should be referred via CEQ. Impacts at Buffumville Reservoir are very
minimal, and LFA is an integral part of the overall plan to improve water
quality in the French River.
C — i 12
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December 2, 1985
Thomas C. cMahon, Director
Division of Water Pollution Control
David k. Fierra, Director
Water i ana exnent Diiision
Dear Sirs:
At tie November 6, 19 3 5i eeting at Dept. of Environ nental
Quality En ineer1ng I expressed the following corcerns.
I have always questioned the 11 c.f.s. for the 7Q10
:4odel. This figure was set ur1n the 1960’s when the flow
was effected by t’ie replacement of the dam at Ecist Village,
the construction of route 395, and also flood control dam at
Euffumsville. It did riot actually represent the flow at the
Treatment Plants because tr e flow from the Steven’s Impound-
rnent was not included.
A study of the flows from 1970 to1991 corrected for t e
byoassing of approximately four million gallons a day, useing
1.55 c.f.s, for GD al1ons shows that the flow at the Plants
would average 20 c.f.s. or better and with flow au nentation
would further improve,
In addition, the Summery of Findings for Advanced Treat—
‘nent Facilities ignored the sii dge E andling Facilities under
construction since December 19BL , and which are to be com-
pleted by December 31,1985.
Enclosed is a coos of co merts on the E.I.S. on the
French giver, submitted by Cranston Print Works--Enclosed
with t-ieir permission. This covers my concerns also,and saves
duoLication. As a result we question whether further AWT
for a six montns a year period is cost effective.
Sincerely,
2.
A. Rodney lebart.
Enclosed;
Comments
Type of Flow 1970-- 1971
C— 113
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RESPONSE TO COMMENTS FROM A. RODNEY KLEBART,
TO THOMAS C. MCMAHON AND DAVID A. FIERRA,
DECEMBER 2, 1985
USGS has recently updated stream flow data in the French River to
produce a 7Q10 flow of 14.8 cfs. This value was used in the EElS to
characterize low flow conditions. As previously mentioned in response to
Cranston Print Works, Anglo Fabrics and the East Village Sewer
Construction Conmiittee’s comments to EPA, it was not the purpose of the
EIS to evaluate advanced wastewater treatment as a option for improving
water quality in the French River. AWT is required by the Clean Water
Act (1977) and is necessary for compliance with water quality
standards. (See responses to letters submitted to EPA by Cranston Print
Works, Anglo Fabrics and the East Village Sewer Construction Committee).
C—i 114
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PART C-2. FINAL EIS COMMENTS AND RESPONSES
c-i 15
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eca 4ve 4 e I uvà€mmen(aj J ftg,c
4 tz ti’me* of e onmenhd22wa&y £pree emj
Thomas C. McMahon / ‘W I // /eon n€ o/
Director —
V,s. $q, $ Jjajj. O / 7
July 9, 1986
Richard Kotelly, Deputy Director
Water Management Division, EPA
JFK Federal Building
Boston, MA 02203
Dear Mr. Kotelly:
The Massachusetts Division of Water Pollution Control, Technical Services Branch
(TSB) has reviewed the final copy of the French River Supplementary
Environmental Impact Statement (FSEIS). The report was very thorough and well
done. Several alternatives to improve water quality in the French River were
examined and three solutions were proposed. The final recoi endations were for
a regional advanced wastewater treatment (AWT) facility to serve both Webster
and Dudley, low flow augmentation (LFA) from Buffumville Reservoir and sediment
isolation and excavation from three downstream impoundments.
The sensitivity of the dissolved oxygen in the river was modeled with no action,
AWT only (p 4—3) AWT and LFA (p 4—15) AWT with sediment control at Perryville (p
4—37), AW? with sediment control at North Crosvenordale Pond and/or Langers
Pond (p 4—38, 4—39, 4—40) and various other combinations (p 5—6 to 5—9). Every
sensitivity model vas done assuming AWT was on line as the base case for
comparison.
Excavating the sediment from Perryville impoundment, Langers Pond and North
Grosvenordale Pond was modeled individually and in various combinations (p 4—37
to p 4—40). From these model predictions it appears that sediment control at
Perryville had very little effect in improving the water quality in the
downstream impoundments in Connecticut. Connecticut hopes to create a swimming
and boating recreation area in North Grosvenordale Pond, and thus, this pond is
the, area of greatest water quality concern. Figures 4—7, and 4—8 show water
quality improvements above water quality standards in North Grosvenordale by
controlling the sediment in North Grosvenordale Pond and Langers Pond.
Figure 4—9 models the D.0. sensitivity with sediment control at all three
downstream impoundments. Sediment control at the Perryville impoundments along
with Langers Pond and North Grosvenordale (Fig. 4—9) does not produce any higher
D.0.’s in Langers Pond or North Grosvenordale when compared to Figure 4—7 with
no sediment control at Perryville.
C—116
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Richard otelly —2— July 9, 1986
Figure 5-3 modeled the D.O. sensitivity with AWT and LFA. Perryville impound-
ment did not violate the water quality standards with AWT and LFA. In Figure
5—4 the model predicts the sensitivity with AWT, LFA and sediment control in all
3 impoundments. As shown earlier in Chapter 4, sediment control in Perryvilie
does not affect the downstream impoundments. Therefore, if AWT, LFA and sediment
control in Langers Pond and North Grosvenordale Pond were modeled, the D.O. would
probably be above the water quality standards limit of 5.0 mg/i throughout the
lower portion of the river.
Connecticut has set aside funding to study sediment removal and carry out sedi-
ment control in Langers Pond and North Grosvenordale Pond. Massachusetts has
not set aside any funding and may not need to, since modeling shows the water
quality in the Connecticut impoundments does not improve with sediment
removal from Perryville.
The department has reviewed the FSEIS and agrees with the three final recommen-
dations. The department, however, feels that the regional advanced treatment
facility and low flow augmentation alternatives should be implemented first.
After the advanced treatment is on line an intensive water quality survey should
be conducted. It is felt that sediment isolation and excavation in the
Perryville impoundment should only occur if the AWT and LFA do not improve the
water quality sufficiently. In order to isolate and excavate the sediment a
consulting engineering firm would have to be hired to determine the most
feasible and economical method of removal and to locate a disposal site for the
contaminated sediment. The study would be very involved and expensive. Also,
there is no readily available funding for such a project. This recommendation
should be the final alternative. Once the advanced treatment is in operation
the TSB feels the water quality will improve dramatically.
To summarize, the TSB has reviewed the final SEIS and is in agreement and sup-
port of the three recommendations. The sediment isolation and excavation from
Perryville should be initiated last if water quality surveys determine a need.
If you have any further questions, please feel free to contact Margo Webber in
Westborough at (617) 366—9181.
Sincerely,
x y
Thomas C. McNahon
Director
TCM: d jm
cc: A. Cooperman
M. Webber
P. Hogan
M. Wheeler
Larry Mcflillian, EPA
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RESPONSE TO MASSACHUSETTS DEQE
LETTER OF JULY 9, 1986
In addition to reducing SOD, sediment control at Perryville has the
added benefit of removing contaminated sediments from the French River,
as is presented in the EIS. Removal of these sediments from Perryville
would be of significant benefit to the French River. Currently these
sediments inhibit the aesthetic appeal and recreational value of the
pond.
In addition, the State of Connecticut is pursuing a course to remove
sediments from Langer’s Pond and North Grosvenordale Pond (see letter
from Connecticut Dep to U.S. EPA dated September 29, 1986). It is
necessary that sediment control measures be implemented at Perryville to
avoid potential washdown of sediments to these downstream impoundments,
thereby negating the sediment cleanup efforts in Connecticut. Potential
sources of funding for this effort include the State and Federal Clean
Lakes Programs, Massachusetts Department of Environmental Management’s
Clean Rivers and Harbors Program or direct legislative grants.
C-i 18
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DEPARTMENT OF THE ARMY
NEW ENGLAND DLAS ON. CORPS OF ENGINEERS
424 TRAPELO ROAD
WALTHAM, MASSACHUSETfS 02254-9149
July 11, 1936
?anninc Division
Ti-’oact na1vsis Branch
Mr. Ronald G. Ilanfredonia, Chief
Environmental Evaluation Section
United States Environmental
9rotection Aaency Recion 1
J.F.K. Federal Buildina
Boston. Massachusetts 02203
Dear Mr. Manfredonia:
This letter is in response to comments received from
EPA to the Corps on May 29, 1986, reaardincz the Final
Supplemental Environmental Impact Statement (FSEIS) for the
French River Cleanup Proaram located in Massachusetts and
Connecticut. Please find attached the U.S. Army Corps of
Enaineers response to those comments.
It is honed that the EPA will review the comments and
address the concerns of the Corps in the FEIS. It is
stated in reaulation 40 CFR 1503.4 that comment responses
to an aaencv’s EIS should be part of the final document and
distributed to other public agencies. If there are any
cuestions concernino the comments contained within, please
contact Dave Tomev at (617) 647—8139.
Sincerely,
se
Chief, Planni ia Division
V
C—il 9
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French River Final. Supplemental ElS
Responses to U.S. Environmental Protection Agency
Coninents on May 29, 1986
General Coimnents
General Conm ent 1 SuninAry :
NED response: It is not clear in the final EIS the need for a
supplemental EIS. The FEIS is presented in a plan evaluation
(feasibility) study manner in that it presents a large array of
alternatives, none of which are adequate alone to meet the primary
objective of the project. Instead, the alternatives that are capable of
meeting the objectives of the Clean Water Act should be discussed as a
cohesive plan.
General Coninent 2 :
NED response: Table 1 provides additional information comparing the
impacts of Hodges Village and Buffumville proposals for low flow
augmentation (LFA). However, the table shows low D.O. resulting from LFA
at Hodges Village when the construction work at Hodges Village intended to
keep D.O. at a high level. It is unclear whether or not low D.O. levels
are a short term effect of construction activity. D.O. would not be of a
low level to impact organisms after Construction was completed.
General Coment 3, Paragraph 3 Snnin*ry :
NED response: Information on archaeological sites was provided by
the Corps to Metcalf and Eddy but was not provided to the archaeological
consultants until after their walk over survey. It is still felt that this
oversight may have affected study adequacy.
General Coninent 3, Paragraph 4 :
NED response: A walk over survey is universally recognized as
insufficient for locating prehistoric resources in the northeast. Table
2—2 stininarizes the variation in water level in the reservoir from water
year 1980 to 1984. This information is used as evidence that the area to
be inundated by LFA is already inundated at various times of the year to
elevations of up to 13 feet above the normal pool elevation of 492.5
feet. The comparison of the number of days the pool exceeded elevation
495.0 (LFA elevation) and number of days the pool exceeded elevation 492.5
(normal fluctuation) does not inform the reader about the sustained length
of pool elevations expected to be experienced at the reservoir with LFA.
While the range of inundation may be within current operating pool.
elevation, the length of time the area is affected by LFA would increase
causing longer periods of inundation and changes in soil chemistry
affecting archaeological sites not currently impacted by the reservoir.
General Connnent 3, Paragraph 5 :
NED response: The walk over study did not include subsurface
testing. Therefore, potential archaeological sites and unknown sites may
exist. Because sites may or may not exist, impacts are unknown and the
cost of mitigating such impacts questionable.
1
c—i 20
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General C ivnent 4 Summary :
NED response: A list of all public coordination and involvement has
been included as an appendix to the FSEIS as recommended by 40 CFR Section
1502.10. It is also recommended by 40 CFR Section 1503.4 that comment
responses to an agency’s EIS be incorporated into the final document and
distributed to other public agencies.
Specific Comments:
Page 2—4, 2nd Paragraph :
NED response: The Hodges Village Plan is still considered a feasible
alternative to other LFA options. The FEIS should include this in the
text.
Page 3—31, Tables 3—11, 3—13 :
NED response: The procedures using different sample sites and
sampling years for the bulk sediment tests and EP toxicity tests do not
allow comparison of the data. This greatly reduces the value of the data
that was presented. If the project requires a Section 404 permit,
additional testing that allows comparison may be necessary.
Page 4—16, 2nd Paragraph, 3rd Sentence :
NED response: While LFA may only require a 2.5 ft. increase in pool
level for a 500 acre—feet storage area, the operating lake level can not
be controlled with such precision. As such, a 3—foot pool level fluc-
tuation would be required to control the discharge and pool. levels at
Buffumville Lake.
Page 4—19, 1st Paragraph :
NED response: The LFA proposal would affect vegetation in a
different manner than the periodic inundation the edge of the pool
currently experiences. The current periodic flooding associated with
flood control operations of Buffumville Dam results in vegetation tolerant
to short periods of inundation. The proposed project would affect
emergent vegetation and other vegetation not tolerant of sustained
inundation of a few weeks to several months. As a consequence, water
level a few feet above the normal pool elevation will result in the need
to remove vegetation to avoid trees being inundated, killed or falling
into the reservoir.
Page 4—20 :
NED response: As discussed previously, the proposed LFA alternative
will result in a significant increase in reservoir level at Buffumville.
Continued inundation will result in the loss and distributional changes of
vegetation in the area 2 to 3 feet above the existing pooi elevation.
This will have impacts to wildlife visiting the Buffumville Lake. The
impacts of the “bathtub ring” and the seasonality of the fluctuating pool
to wildlife should be addressed as well as the mitigation to wildlife
habitat losses which would be required.
2
C—121
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Page 4—22, 2nd Paragraph :
NED response: The raising of the pool by 2—1/2 feet and keeping it
up for several months could create safety problems to recreational boaters
that use the causeway culvert to travel between both bodies of water.
Possible mitigation measures should be included in the report.
Page 4—22, 3rd Paragraph, 1st Sentence :
NED response: Water level fluctuation associated with LFA will
result in the appearance of a bathtub ring. The adverse impacts on the
aesthetics around the pool should be recognized and discussed in the
report.
Page 4—22, 3rd Paragraph, 5th Sentence :
NED response: The 2—1/2 foot raising of the pool and keeping it up
for several months will definitely have an adverse impact on the recrea-
tional use of the existing beach area. Mitigation measures to widen the
beach to minimize impacts should be discussed in the FEIS.
Table 4—7 :
NED response: Potential impacts on disposal sites chosen for any
excavated pond sediment should be included in the final EIS.
Page 4—23 — 4—27: “Impacts of Sediment Control” :
NED response: Discussions on potential physical, chemical,
biological, and socioeconomic impacts of the disposal of any excavated
sediments at a given disposal site should be clear in the final EIS.
Page 5—2 :
NED response: The Corps coninent was misinterpreted. We requested
cost/benefit ratio for the LFA project, not the existing Buffumville
reservoir project. The total annual costs for modifying Ruffumville
reservoir should be compared with the total annual benefits of improved
water quality downstream. The benefits for Hodges Village were provided
by EPA for the 1984 Environmental Impact Statement.
Page 5—11 “Description of Reconsnended Plan” :
NED response: There are currently no Corps plans to study the
proposed project further. No authority exists for continued work.
However, the Corps will consider the further study effect if funding is
available from other sources.
3
c—i 22
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RESPONSE TO COMMENTS FROM U.S. ARMY CORPS OF ENGINEERS,
JULY 11, 1986
General Comment 1 Summary :
“It is not clear in the final EIS the need for a supplemental EIS.
The F’EIS is presented in a plan evaluation (feasibility) study manner in
that it presents a large array of alternatives, none of which are
adequate alone to meet the primary objective of the project. Instead,
the alternatives that are capable of meeting the objectives of the Clean
Water Act should be discussed as a cohesive plan.”
EPA Response: The French River (or “supplemental”) EIS was produced
to investigate improvement alternatives for water quality in the French
River other than low flow augmentation at Hodges Village. A summary of
Hodges Village EIS issues and the need for the French River EIS has been
incorporated in Chapters 1 and 2 of that EIS. EPA believes the
alternatives are presented in a logical manner. Since no single
alternative can improve water quality enough for standards to be met, a
combination of alternatives is required. Chapter 5 presents a cohesive
plan to achieve improved water quality and dissolved oxygen
concentrations of at least 5 mg/i in the French River.
General Comment 2 :
“Table 1 provides additional information comparing the impacts of
Hodges Village and Buffumville proposals for low flow augmentation
(LFA). However, the table shows low D.O. resulting from LFA at Hodges
Village when the construction work at Hodges Village intended to keep
D.O. at a high level. It is unclear whether or not low D.O. levels are a
short term effect of construction activity. D.O. would not be of a low
level to impact organisms after construction was completed.”
EPA Response: Table 1 (or Table 2-1 of the final EIS) presents a
comparison of impacts due to low flow augmentation at Hodges Village and
Buffumville. The dissolved oxygen impacts referred to are due to
construction activities. Riverine and wildlife habitat would be
adversely impacted due to construction activities, as would be water
C—i 23
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quality in the river. Such construction impacts are not expected at
Buffumville, where there is already an existing reservoir.
General Comment 3, Paragraph 3 Summary :
“Information on archaeological sites was provided by the Corps to
Metcalf & Eddy but was not provided to the archaeological consultants
until after their walk over survey. It is still felt that this oversight
may have affected study adequacy.”
EPA Response: EPA does not feel that this oversight adversely
impacted the adequacy of the archaeological study or any conclusions made
in the EIS which were based upon this study. The archaeological
consultants did receive the information provided by the Corps and were
able to use it in their archaeological evaluation.
General Comment 3, Paragraph t4 :
“A walk over study is universally recognized as insufficient for
locating prehistoric resources in the northeast. Table 2-2 summarizes
the variation in water level in the reservoir from water year 1980 to
1984. This information is used as evidence that the area to be inundated
by LFA is already inundated at various times of the year to elevations of
up to 13 feet above the normal pooi elevation of 492.5 feet. The
comparison of the number of days the pool exceeded elevation 495.0 (LFA
elevation) and number of days the pooi exceeded elevation 492.5 (normal
fluctuation) does not inform the reader about the sustained length of
pool elevations expected to be experienced at the reservoir with LFA.
While the range of inundation may be within current operating pool
elevation, the length of time the area is affected by LFA would increase
causing longer periods of inundation and changes in soil chemistry
affecting archaeological sites not currently impacted by the reservoir.”
EPA Response: Soil chemistry is not expected to be drastically
altered due to the LFA proposal since the area is periodically flooded to
water elevations which are higher than the proposed elevation (el. 95.O)
for low flow augmentation to 22 oft. The scouring action at Buffumville
Lake at a pool level of Z 95 feet would not be sufficient to adversely
impact archaeological sites. This area is regularly flooded without
consequence and there is no indication that future flooding will produce
adverse impacts.
C-12 )4
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General Comment 3, Paragraph 5 :
“The walk over stud!,’ did not include subsurface testing. Therefore,
potential archaeological sites and unknown sites may exist. Because
sites may or may not exist, impacts are unknown and the cost of
litigating such impacts questionable.”
EPA Response: Since the pool level at Buf’funwille Lake is usually
higher than 492.5 feet (normal elevation) and is frequently higher than
495.0 feet (elevation required for low flow augmentation to 22 cfs),
impacts and mitigation measures resulting from implementation of low flow
augmentation are not expected to be significant.
General Comment U Summary :
“A list of all public coordination and involvement has been included
as an appendix to the FSEIS as recommended by 40 CFR Section 1502.10. It
is also recommended by 40 CFR Section 1503.4 that comment responses to an
agency’s BIS be incorporated into the final document and distributed to
other public agencies.”
EPA Response: Comment responses to the French River EIS are
included in the Appendices of the Final EIS as recommended by 40 CFR
Section 1503. 4.
Specific Comments:
Page 2-4, 2nd Paragraph :
The Hodges Village Plan is still considered a feasible alternative
to other LFA options. The FEIS should include this in the text.
EPA Response: A comparison of Hodges Village and Buffumville as
alternative LFA options is presented in Chapter 2. It is concluded in
the EIS that due to the more significant adverse environmental impacts
that would occur with the Hodges Village Plan, the Buffumville proposal
is preferred.
C— 125
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Page 3—37, Tables 3—11, 3—13 :
“The procedures using different sample sites and sampling years for
the bulk sediment tests and EP toxicity tests do not allow comparison of
the data. This greatly reduces the value of the data that was
presented. If the project requires a Section 404 permit, additional
testing that allows comparison may be necessary.”
EPA Response: It is not unusual that bulk sediment metals
concentrations are several orders of magnitude higher than EP toxicity
results. The data presented in Tables 3-11 and 3-13 are considered
valuable in that they help to characterize the pollutants found in the
sediments. EPA realizes that additional data may be required should a
section 1104 permit be necessary.
Page 4—16, 2nd Paragraph, 3rd Sentence :
“While LFA may only require a 2.5 ft. increase in pool level for a
500 acre—feet storage area, the operating lake level can not be
controlled with such precision. As such, a 3-foot pooi level fluctuation
would be required to control the discharge and pool levels at Buffumville
Lake.”
EPA Response: EPA understands that the pool elevation of
Buf’fumvjlle cannot be controlled with such precision that it will be
exactly 2.5 feet higher than normal pool elevation.
Page 4—9, 1st Paragraph :
“The LFA proposal would affect vegetation in a different manner than
the periodic inundation the edge of the pool currently experiences. The
current periodic flooding associated with flood control operations of
Buffwnville Dam results in vegetation tolerant to short periods of
inundation. The proposed project would affect emergent vegetation and
other vegetation not tolerant of sustained inundation of a few weeks to
several months. As a consequence, water level a few feet above the
normal pooi elevation will result in the need to remove vegetation to
avoid trees being inundated, killed or falling into the reservoir.”
EPA Response: Discussion has been added to the text describing
wetlands and upland vegetation during existing and low flow augmentation
conditions. This discussion is also presented in pages 18 to 20 of EPA’s
c—i 26
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Response to Comments from U.S. Army Corps of Engineers, dated November
19, 1985. According to this discussion, the water levels would have to
be increased by over 5 to 6 feet over normal pool elevation before
operational problems would exist as a result of trees being inundated,
killed and falling into the reservoir. Any clearing and grubbing that
would be required by the Corps is expected to be minimal.
Page 1 20 :
“As discussed previously, the proposed LFA alternative will result
in a significant increase in reservoir level at Buffumville. Continued
inundation will result in the loss and distributional changes of
vegetation in the area 2 to 3 feet above the existing pool elevation.
This will have impacts to wildlife visiting the Buffumville Lake. The
impacts of the “bathtub ring” and the seasonality of the fluctuating pooi
to wildlife should be addressed as well as the mitigation to wildlife
habitat losses which would be required.”
EPA Response: The proposed increased water level at Buffumville
Lake is within the lake’s operational level fluctuation. Little wildlife
habitat is expected to be impacted by increasing the length of time which
the pool is flooded. This issue is addressed in pages 18-20 of EPA’s
Response to Comments from U.S. Army Corps of Engineers, dated November
19, 1985.
Page 14 _ 22, 2nd Paragraph :
“The raising of the pool by 2-1/2 feet and keeping it up for several
months could create safety problems to recreational boaters that use the
causeway culvert to travel between both bodies of water. Possible
mitigation measures should be included in the report.”
EPA Response: Boating safety was considered by the EIS. As a
mitigation measure, the culvert at Buffumville will be replaced by a
larger culvert. (This mitigation measure is presented in Chapter 4 of
the EIS.)
C- .127
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Page 14 _ 22, 3rd Paragraph, 1st Sentence :
UWater level fluctuation associated with LFA will result in the
appearance of a bathtub ring. The adverse impacts on the aesthetics
around the pooi should be recognized and discussed in the report.”
EPA Response: EPA does not believe that the appearance of
Buffuinville Lake will change significantly since the proposed elevation
of the lake is within the pool elevation fluctuation.
Page 1I _ 22 , 3rd Paragraph, 5th Sentence :
“The 2-1/2 foot raising of the pool and keeping it up for several
months will definitely have an adverse impacts on the recreational use of
the existing beach area. Mitigation measures to widen the beach to
minimize impacts should be discussed in the PEIS.’
EPA Response: The final EIS includes addition of sand to the beach
in the proposed mitigation measures at Buffumville Lake. This item is
included in Chapter 14 of the EIS.
Table 14-7 :
“Potential impacts on disposal sites chosen for any excavated pond
sediment should be included in the final EIS.”
EPA Response: Preliminary information presented in the EIS
indicates that sediment excavation and disposal is a feasible option. It
would be difficult to assess specific impacts of disposal sites since
these sites have not been identified and impacts would be site
specific. An engineering feasibility study beyond that of the EIS will
be required to select specific disposal sites.
Page 14—23 — 14—27: “Impacts of Sediment Control” :
“Discussions on potential physical, chemical, biological, and
socioeconomic impacts of the disposal of any excavated sediments at a
given disposal site should be clear in the final EIS.”
EPA Response: See previous response.
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Page 5-2 :
“The Corps comment was misinterpreted. We requested cost/benefit
ratio for the LFA project, not the existing Buffumville reservoir
project. The total annual costs for modifying Buffumville reservoir
should be compared with the total annual benefits of improved water
quality downstream. The benefits for Hodges Village were provided by EPA
for the 1984 Environmental Impact Statement.
EPA Response: In choosing between Buffumville and Hodges Village as
a possible source of low flow augmentation, EPA feels that there are more
critical parameters than a cost/benefit ratio which should be used as
selection criteria. These include the acres of wetlands which would be
inundated with elevated pool levels. To provide 500 acre-feet of
additional storage, 130 acres of wetlands would be lost at Hodges Village
while at Buffuinville approximately only 6 acres of wetlands would be
lost.
Page 5—11 “Description of Recommended Plan” :
“There are currently no Corps plans to study the proposed project
further. No authoritq exists for continued work. However, the Corps
will consider the further study effect if funding is available from other
sources.”
EPA Response: EPA is committed to facilitating the implemention of
low flow augmentation at Buffumville Lake. Should additional study be
required, funding sources will be sought out.
C.-129
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Mr. Michael R. Delam3
Regional P dnini strator
U.S. Environ iiental Protection Ayency
JFK Federal Bldg.
Government Center
Boston, Massachusetts 2233
Dear Mr. Deland:
This is in response to your request for our review of tne Final
Supplemental Environmental Impact Statement (FSEIS) on the French
River Cleanup Program in Massachusetts and Connecticut.
As you know, we have previously identified this project as a
candidate for referral to the Council on Environmental Quality
(CEQ) in accordance with 40 CFR 1504. My staff informs me that
a number of significant unresolved issues remain between our
respective agencies on this program. Therefore, in accordance
with 40 CFR 1504.3(b), I am hereby requesting that you grant a
time extension of 30 days on the comment period for this FSEIS.
This should allow our respective staffs sufficient time to meet,
address and hopefully narrow, if not resolve, these outstanding
issues. If you concur with this request, I will shortly provide
you with a letter outlining the issues that need further
coordination between our respective agencies.
Sincerely yours,
Regional Director
c -.i,---t
rE EIvEo
I ’
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fr
4 .
‘Ji, ,—
r. Mich 1 P. r) l n
Regional Administrator
U.S. Environm nt l Prot ct ion Ag ncy
JFK Federal B1- cj.
Government Center
Boston, assachusetts 2254
_J ..,‘
Dear r. Deland:
Tais is in reseonse to your r :juest for D - partment of Interior
review of the Final Supplemental Environmental Impact Statement
(PSEIS) for the French River CU anup Program in Massachusetts and
Connecticut (ER 85/1489).
As you know, this Department raised serious objections to your
proposal to implement 1o i flow augmentation (LFA) as one of the
components of the Frencn River cleanup project. Based upon our
review of this FSEIS, we find no basis to modify our objections to
low flow augmentation as part of th selected plan. In fact, your
FSEIS has reinforced our opinion that water quality standards can
be achieved in the lower French River wit the No Action alternative
which includes advanced waste treatment (AWT) at Webster-Dudley;
and sediment control.
As the FSEIS clearly indicates on pages 4—36 and 4—41 and figure
5—2, water qudlity standards (dissolved oxygen = 5.1 mg/i)
would be met on the French River by Advanced Waste Treatment (AWT)
at Webster—Dudley, and sediment control. However, the recommended
plan includes flow augmentation from I3uffumville Reservoir, A T
and sediment control. In our comments on the DSEIS, we stated
that flow augmentation like instream aeration was a “bandaid”
measure in that it only treated symptoms of the problem, not the
problem itsz lf and tnerefore, snoula be discar d in the same
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fashion as instream aeration. However, since it would be federally
funded and operated at Buffumville reservoir, low flow augmentation
could be i nplemented more easily by EPA because the local polluters
would not be reauire-1 to fund or operate the dilution Project as
would be the case for instream a ration and other alternatives.
As shown on figure 5—3 and discussed on page 5—10, LFA and AWT
would not meet water quality standards downstream of ebster—Dudloy.
Low flow augmentation would only increase the dissolved oxygen level
approximately one opm over that achieved by AWT alone and only 0.4 mg/l
over AWT and sediment control combined. On page 4—17, EPA has attempted
to justify LFA based on i need for dilution of heavy metal and other
wastes from the Webster—Dudley sewage treatment plant (STP). However,
Webster and Dudley have refused to develop a pretreatment program
as required by 40 CFR 403, toxics identification surveys have not
been conducted to determine pollution sources and industrial dischargers
have not furnished baseline monitoring data on their discharges
so that regulators can determine the level of pretreatment required.
Therefore, EPA has no basis for stating that LFA is needed to
avoid a metal toxicity problem below the cbster—Dudley discharge.
A properly operated pretreatment program would eliminate this
problem. In addition, the pretreatment regulations (40 CF 403)
including the preamble expressly prohibit dilution as a form of
waste treatment.
In response to several of our comments on the DSEIS concerning
alternatives and combinations of alternatives to achieve water
quality standards, EPA used the Stream 78 water quality model
to develop tesponscs to our questions. In fact, EPA has relied
2
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very heavily on rod l1ing r sults to oredict water quality
changes with various alLernativ s and to suooort their position
for LEA. ha ar:. aence rn d no ’IeveL- , th t th :POc i line work
Jont to r Jiet :Ussolved oxvcjen levels at 7Ql flows may be
flawed. Im aroec r resi ancc Limes may hav been dcveiooad dv the
macel in downstream 1mpounc ments because the cross sections used to
comput: river segm nt volumes may have included wetlands and/or
backwaters and did not consider possible stratification in the
larger impoundments. These oversiahts could substantially in—
crease residence times leading to dissolved oxygen predictions
lower than would be actually observed.
In our comments on the DSEIS and the FV S letter of March 3 , l9 4,
we ex ressod concerns about secondary and cumulative effects of
the flow augmentation alternative. However, the FSEIS essentially
remains silent about this issue despite the fact that EP issued an
Environmental Assessment (E ) and Finding of No Significant Impact
(FONSI) on -iay 3 , 198G to greatly expand interceptor sewers in
Webster—Dudley and increase the average STP flow from 3.25 mgd to 5.4
rngd, an increase of over 6 percent. This sewer expansion proposal
is remarkable considering tuat on page 5—2 of the FSEIS, EPA clearly
states that the water quality problem is due to the high proportion
of wastewater flow under low flow conditions an-I sediment oxygen
demand. The sewer expansion proposal would increase 3oD, susoended
solids, nutrient, metal -and other pollutant loadings to a river
segment that currently does not meet water quality standards
and according to the modelling work (figure 5—1), would not
meet standards with AhT alone wita the existino flows of 3.25
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MGD. The Town of Oxford i hich is immediately upstream from
Webster—Dudley has a pooulation of about ii,øCc and is experiencing
vt ry raoid com r.er ia1, inlustrial and residential growth. Oxford
has no sewer system but does own a site for its STP adjacent to the
Fr ach River. In dd1tiofl, a number ol rt sidentia1 df’velooments
upstream from Oxford have plans to discharge effluent to the
French River. EPP has not token a holistic view of the precedent
setting implications of its proposed low flow augmentation proposal.
We firmly believe that if EP1 established a precedent of using flow
augmentation (dilution) as a substitute for adequate treatment at
Webster-Dudley and downstream sludge deposits, then other dischargers
in the French River Basin and conceivably elsewhere in New England,
will demand and perhaps receive authorization to substitute
adequate treatment for dilution of wastes. New England is
considered a water rich region of tho country and except for thc
Webster—Dudley project, the flow augmentation (dilution) precedent
for waste treatment has never been implemented or authorized
before. The implications of flow augmentation proposals to fish
and wildlife resources certainly transcend the French River Basin.
In our comments on the OSEIS we stated that while sediment control
is not preferred by us as a first choice option, it nonetheless
is an action directed at some of the basic causes of the water
quality problem unlike flow augmentation and instream aeration.
We also expressed concerns regarding the lack of specific details
conccrning the sediment control alternative to include data On
the natural decay rate of the flocculent sediment and sediment
oxygen demand (SOD), what agency(s) would be responsible for
4
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cnn iuc -iaa 3tu ’ nfl s: iT. n- on - -o —.n-
1 1 TcaL na : c r : u tin j e n (s) , - , ures n ssary to
t ifl ‘fl T I OOU Ifl G , I O j
Si t s tor :oat iaite s Uflents and oth:r issuos ref roncad
iu rur ort : f 3 , . Those issues hav c•itn u
not been aniressea Or lnaaeauataly a r:ss c by LP n -n F$Fi 3
ear r auest for so cific eetei is nos been answorc-•d with ‘j floral izad
stam aats in most cases. The s i ont control option and other
itoin tiv’ s includinq flow auqmentation have not boon •ve1op -I
to la ’e1 of detail comparable to t e Hodges Village alternative
orz rod by the Corps of Engineers. We do not believe that a
corn rabin lovel of detail will be achieved for the Buffucnville
uiternativ ’ until a specific feasibility study is conducto:i by the
Corps or erhaos sorn other aqency. Tnis is irnoortant because
EPA is me-;in.3 i oisioas to implomont a course of action bastd on
incom lete investigations of avail hlc alternatives.
pre i ously recommended that EP give a rigorous and objective
evaluation to higher levels of Ac T beyond nitrification, various
flow reduction o’- load allocation options and various combinations
of these and other alternatives. EPA’s ras onso to theso concorns
was to conduct more mode linq runs to show that water quality
standards would not b met with the discuarge from iebster—DudieY
eliminated or by djscii.arg nn put: water. EPA did not axnlora
::oeoinat ions of these measures and otnar alterno t ives as we hao
suqqesta-d in an ttamot to Linde oro :cc ?t hi elan of action.
he r dueste} EPA to 2e onstrate that averythin that on be done,
n fnet, H iad done to control the ooliut on proalam t its
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source. This demonstration h is not been macic and cannot be made
by EPA because ;:ebster and Dudley continue to violate their
axistincr NPDES nermits ni they have not icvelooe .i a nd imolemented
a oretreatment orogram to control the nollution problems enz nating
from local industries that: contribute a major portion of the pollu-
tion load. EPA’S enforcement orogra r. in the lower French I iver
basin is an important contribut nq element to the present dey
pollution problems in webster—Dudley and downstream.
e recommended that additional study be given to the no action
alternative wnich includes WT at webster—Dudley. However, EPA
continues to view the sediment qxygen demand in the downstream
impoundments as a static entity. while a great deal of data
may not be available conccrnincj natural decay rates for SOD,
information from EPA Region I personnel familiar with the St.
Croix River, Maine and New Brunswick, indicates that SOD declined
very rapidly following the addition of secondary treatment to a
local paper mill discharge. We requested EPA to predict these SOD
decay rates for the lower French River at various target years
for the 2 J—year planning period. EPA has not done so and
instead, continues to rely on SOD rates that may be unreasonably
high at target year 5, l , 15, etc., after the elimination of the
sludge discharge. It is our opinion that A ’iT and the process of
natural SOD decay should be modeled at various target years to
determine when water quality standards would be met for the
existing STP flow of 3.25 IGD and 7Ql flow of 14.8 cfs. This
information should be available to decision makers before decisions
are made to increase STP flows, add new or expand existing sewer
6
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systems, excavate sediment depOsits or us flow augmentation to
dilute wastes.
In summary, while we support the overall obj etives of the Program
to restore swimmable—fishable waters to the French River, we remaain
opposed to low flow augmentation. In our ocinion, the flow aug-
mentation alternative is inconsistent with the goals and objectives of
the Clean water Act. Additionally, once the precedent has been
established by EPA of accepting flow augmentation (dilution) as
an alternative solution to adequate waste treatment, future
resource conflicts would be unavoidable in this and perhaps other
basins as well. As stated in the F S letter of March 30, 1984,
we believe that present and future pollution abatement projects
should be designed to co—exist with the natural assimilative
capabilities of the basin.
e again urge EPA to carefully reevaluate the alternative plan
of controlling the pollution problem at its source(s). The
sediment control alternative should be investigated to determine
if natural SOD decay rates alone or in combination with other
measures wo’uld be sufficient to meet water quality standards at
existing flows.
Expansion of the sewer system in Webster—Dudley, the development
of new sewer systems in other towns and the addition of new point
sources in the basin that would affect water quality in the lower
section of the river should be prohibited until such time as the
water quality problems at Webster-Dudley and downstream are
completely corrected in accordance with the spirit and intent
7
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of th’ Clean at r Act.
inc . rclv yours,
R
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EPA RESPONSE TO DRAFT LETTER
FROM DEPARTMENT OF INTERIOR U.S. FISH AND WILDLIFE
SERVICE, JUNE 1986
Page 1, paragraphs 2 and 3 . “... we find no basis to modify our
objections to low flow augmentation as part of the selected plan. . .F’SEIS
clearly indicates on pages 4—36 and 4-41 and figure 5-2, water quality
standards (dissolved oxygen = 5.1 mg/i) would be met on the French River
by Advanced Waste Treatment (AWT) at Webster-Dudley, and sediment
control.
EPA Response: In previous drafts of the French River EIS it was
assumed that sediment removal in Perryville, Langer’s and North
Grosvenordale Ponds would leave a the river bottom with a sediment oxygen
demand (SOD) of zero in each of the three impoundments. As a result,
STREAM7B modeling may have overpredicted actual dissolved oxygen
concentrations in the river after sediment excavation. EPA has decided
that 1 g/m 2 /day is a more realistic value of SOD after excavation. As
presented in Chapter 5 of the FEIS, AWT plus sediment removal in the
three impoundments does not increase dissolved oxygen to the water
quality standard of 5 mg/l. Therefore, one or more additional
improvement alternatives are required for the French River to comply with
water quality criteria.
Page 1, paragraph 2 and Page 2, paragraph . “... flow augmentation
like instream aeration was a “bandaid” measure. . . therefore, should be
discarded in the same fashion as instream aeration.”
EPA Response: Instream aeration is difficult to implement
institutionally, it may inhibit the intended recreational use of North
Grosvenordale Pond, and requires continued subsidies for operation and
maintenance. Thus, low flow augmentation is a preferable improvement
alternative as compared to instream aeration.
C .-139
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Page 2, paragraph 1 . “On page 4-17, EPA has attempted to justify
LFA based on a need for dilution of heavy metal and other wastes from the
Webster—Dudley sewage treatment plant (STP). However, Webster and Dudley
have refused to develop a pretreatment program as required by 40 CPR 403,
toxics identification surveys have not been conducted to determine
pollution sources and industrial discharges have not furnished baseline
monitoring data on their discharges so that regulators can determine the
level of pretreatment required. A properly operated pretreatment program
would eliminate this problem.. . the pretreatment regulations (40 CFR 403)
including the preamble expressly prohibit dilution as a form of waste
treatment. N
EPA Response: The Webster and Dudley NPDES permits require the
development and implementation of a pretreatment program to control
industrial discharges. Both the permit and the pretreatment program will
be aggressively enforced. It is not the intent of EPA to implement low
flow augmentation so that point source discharges are not required to
comply with permit limitations and pretreatment requirements. However,
while pretreatment will control future discharges of metals to the river,
it will not address the sediment contamination problems that exist in the
impoundments. LFA will have the incidental benefit of reducing metals
concentrations in the river due to sediments and nonpoint sources.
Page 2. paragraph 2 and Page 3, paragraph 1 . TM lmproper residence
times may have been developed by the model in downstream impoundments
because the cross sections used to compute river segment volumes may have
included wetlands and/or backwaters and did not consider possible
stratification in the larger impoundments. II
EPA Response: Residence times for the French River water quality
model (STREAJ47B) were based on the hydraulic model HEC-2. HEC-2 was run
for both existing conditions and estimated conditions with sediment
control. , The hydraulic information input to STREAM7B from HEC- .2 was run
for both existing conditions and estimated conditions with sediment
control. The hydraulic information input to STREAM7B from I-IEC-2 took
into consideration where the effective flow areas of the river are. EPA
C _11 O
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feels that travel times predicted by STREAM7B are reasonable and are not
“improper”. STREAM7B is a one-dimensional model, and does not include
effects of stratification on either hydraulics or water quality. The
review comment above claims that stratification would reduce residence
times in the impoundments, thereby increasing DO, but the reviewer does
not recognize that simulation of a stratified condition would also result
in much lower DO levels in the lower layer of the impoundments. The
impoundments of concern are relatively shallow, and stratification is
expected to be intermittent. It is felt that considering an impoundment
to be one layer is reasonable for the purpose at hand.
Page 3, paragraph 2 and page 4, paragraph 1 . “. . .EPA issued an
Environmental Assessment (EA) and Finding of No significant Impact
(FONSI) on May 30, 1986 to greatly expand interceptor sewers in Webster—
Dudley and increase the average STP flow from 3.25 mgd to 5.4 mgd, an
increase of over 60 percent. This sewer expansion proposal is remarkable
considering that on page 5-2 of the FSEIS, EPA clearly states that the
water quality problem is due to the high proportion of wastewater flow
under low flow conditions and sediment oxygen demand. The sewer
expansion proposal would increase BOD, suspended solids, nutrient, metal
and other pollutant loadings to a river segment that currently does not
meet water quality standards and according to the modelling work (figure
5-1), would not meet standards with AWT along with the existing flows of
3.25 MCD. The Town of Oxford.. .is experiencing very rapid commercial,
industrial and residential growth... [ 1t1 has no sewer system but does own
a site for its STP adjacent to the French River. . . a number of residential
developments upstream from Oxford have plans to discharge effluent to the
French River.
EPt& Response: The FEIS has demonstrated that with AWT only,
variations in the effluent flow from the Webster—Dudley WWTP do not
significantly alter dissolved oxygen concentrations. A comparison of
dissolved oxygen concentrations in the French River with Webster Dudley
effluent flows of zero and 6 mgd is presented in Chapter )4 of the FEIS.
C-1 1 41
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Some new construction is occuring in Oxford. A recent condominium
development has been required to tie its wastewater into the Upper
Blackstone Sanitary District. Any proposed new discharge to the French
River would be authorized only if permit limits could ensure that water
quality standards in the river would be met.
Page 4, paragraph 1 . “We firmly believe that if EPA established a
precedent of using flow augmentation (dilution) as a substitute for
adequate treatment at Webster—Dudley and downstream sludge deposits, then
other discharges in the French River Basin and conceivably elsewhere in
New England, will demand and perhaps receive authorization to substitute
adequate treatment for dilution of wastes.”
EPA Response: Low flow augmentation will not be implemented in the
French River as a substitute for adequate treatment. In addition to
advanced wastewater treatment at Webster-Dudley and sediment control at
Perryville, Langer’s and North Grosvenordale Ponds, low flow augmentation
is proposed for the French River to comply with water quality criteria.
EPA would never allow low flow augmentation to be a substitute for
adequate treatment. The combination of circumstances leading to the need
for LFA in the French River is very unusual and unlikely to be
encountered often in the future.
/
Page 4, paragraph 2 and page 5, paragraph 1 . “We also expressed
concerns regarding the lack of the specific details concerning the
sediment control alternative to include data on the natural decay rate of
the flocculent sediment and sediment oxygen demand (SOD), what agency(s)
would be responsible for conducting the feasibility study on sediment
control and implementing the resulting plan(s), measures necessary to
protect wetlands within the impoundments, location of disposal sites for
contaminated sediments.... Those issues have either not been addressed
or inadequately addressed by EPA in the FSEIS.”
EPA Response: A feasibility study would be required prior to the
implementation of sediment control. The states of Massachusetts and
Connecticut are expected to assume at least partial responsibility for
this study. Possible sources of funding for the sediment control
C—1 42
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feasibility study are the State and Federal Clean Lakes Programs. The
Connecticut Department of Environmental Protection has expressed its
commitment to implement sediment control at Langer’s and North
Grosvenordale Ponds in an effort to improve water quality in the French
River. Potential funding sources for sediment control include the State
and Federal Clean Lakes Programs, Massachusetts’ Department of’
Environmental Management’s Clean Rivers and Harbor program or direct
legislative grants.
Page 5, Paragraph 1 . “The sediment control option and other
alternatives including flow augmentation have not been developed to a
level of detail comparable to the Hodges Village alternative prepared by
the Corps of Engineers. We do not believe that a comparable level of
detail will be achieved for the Buffumville alternative until a specific
feasibility study is conducted by the Corps or perhaps some other
agency. This is important because EPA is making decisions to implement a
course of action based on incomplete investigations of available
alternatives.”
EPA Response: Regarding sediment control, see previous response.
The EIS clearly demonstrates the advantage of LFA from Buffumville as
opposed to Hodges Village, and further detail is not needed for this
purpose. EPA feels that the EIS demonstrates that LFA for Buffumville is
a feasible alternative, but acknowledges that further study may be
required with the Corps to develop specific details regarding
implementation of low flow augmentation at Buffumville Lake.
Page 5, paragraph 2 . “We previously recommended that EPA gives a
rigorous and objective evaluation to higher levels of AWT beyond
nitrification, various flow reduction or load allocation options and
various combinations of these and other alternatives. EPA’S response to
these concerns was to conduct more modelling runs to show that water
quality standards would not be met with the discharge from Webster-Dudley
eliminated or by discharging pure water. EPA did not explore
combinations of these measures and other alternatives as we had suggested
in an attempt to find a more acceptable plan of action.”
C—V43
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EPA Response: EPA examined the possibilities of treatment beyond
E&WT and flow reduction, including no discharge at Webster-Dudley. EPA
feels the modeling results as presented previously and in the Final EIS
are sufficient to eliminate these alternatives from further
consideration.
Page 5, Paragraph 2 and Page 6, Paragraph 1 . “We requested EPA to
demonstrate that everything that can be done, is in fact, being done to
control the pollution problem at its source. This demonstration has not
been made and cannot be made by EPA because Webster and Dudley continue
to violate their existing NPDES permits and they have not developed and
implemented a pretreatment program to control the pollution problems
emanating from local industries that contribute a major portion of the
pollution load.”
EPA Response: EPA has issued a new NPDES to Webster and Dudley,
which require development and implementation of a pretreatment program to
control industrial discharges. Both the NPDES permit and the
pretreatment program will be aggressively enforced.
Page 6, Paragraph 2 and Page 7, Paragraph 1 . “... EPA continues to
view the sediment oxygen demand in the downstream impoundments as a
static entity... We requested EPA to predict these SOD decay rates for
the lower French River at various target years for the 20-year planning
period. EPA has not done so and instead, continues to relay on SOD rates
that may be unreasonably high at target year 5, 10, 15, etc., after the
elimination of the sludge discharge. It is our opinion that AWT and the
process of natural SOD decay should be modeled at various target years to
determine when water quality standards would be met for the existing STP
flow of 3.25 MCD and 7Q10 flow of 14.8 cfs. This information should be
available to decision makers before decisions are made to increase STP
flows, add new or expand existing sewer systems, excavate sediment
deposits or use flow augmentation to dilute wastes.”
EPA Response: See response to comment in previous Dept. of Interior
letter of November 26, 1985, Pg. 2, par. 2, lines 1—25. In addition,
sediment removal has the added benefit beyond SOD reduction of removing a
source of metals and other potential toxics from the river.
c-i 1414
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STATE OF CONNECTICUT
DEPARTMENT OF ENVIRON__NTA p TEc N
RECE! ’ t )‘)
Mr. Michael R. Deland 2 P
I REGION 1 I
Regional Administrator
I OFFICE OF THE
Region I EPA
JFK Federal Building
Boston, Mass. 02203
Dear Mr. Deland:
The Connecticut Department of Environmental Protection recently met with
the US Environmental Protection Agency, US Fish and Wildlife Service, and
Massachusetts DEQE to discuss the findings and recommendations of the
Environmental Impact Statement for the French River Cleanup Program. As a
follow-up to this meeting, the Connecticut Department of Environmental
Protection would like to present the following statements of our positions on
the issues raised during the discussion:
1. The State of Connecticut’s adopted water quality goal for the French
River is to attain Class B fishable/swimmable conditions. The French River EIS
recommends a restoration plan which can be expected to achieve this goal at
reasonable costs. The State of Connecticut has no intention of considering a
lower use goal for the French River.
2. In accordance with Connecticut Water Quality Standards and Criteria,
Class B waters are to exhibit no less than 5 mg/i dissolved oxygen at any time
to maintain a high quality recreational fishery. Under present conditions,
surface waters in the French River impoundments are well below 5 mg/l during
the summer. The EIS predicts that dissolved oxygen is depleted to zero in the
North Crosvenordale pond at the standard design low flow of 7Q10.
3. The EIS demonstrates that substantial progress will be made toward the
attainment of Class B waters with the implementation of advanced wastewatet
treatment at Webster/Dudley, low flow augmentation to maintain 22 cfs at the
Webster gage, and management of existing sediment deposits in the
impoundments. Each of these three projects will result in a significant
improvement in dissolved oxygen levels in the river. All three are needed to
approach the adopted goal. The EIS also demonstrates that in-stream aeration
or additional flow augmentation is needed to fully achieve a minimum dissolved
oxygen concentration of 5 mg/i at all times.
4. The State of Connecticut supports the implementation of advanced
wastewater treatment at Webster/Dudley to meet the effluent limits in the NPDES
permit. These limits include a weekly average BOD concentration of 10 mg/i,
a weekly average NH3-N concentration of 2 mg/l, p osphorus removal, and post
aeration to provide 6 mg/i dissolved oxygen at all tin es. These effluent
limits represent the highest degree of advanced treatment currently practiced
in Connecticut. We do not support a higher degree of treatment than that
C— 145
Phone:
165 Capitol Avenue • Hartford, Connecticut 06106
.4n Eqzw! Opportunity Emo!o er
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required by the NPDES permit. Any higher level of treatment would be
technically difficult to achieve, would impose substantial additional costs to
the communities of Webster and Dudley, and would not significantly improve
dissolved oxygen levels in the French River.
5. The State of Connecticut supports the implementation of low flow
augmentation from The U.S. Army Corps of Engineers Buffuniville flood control
project to maintain low flows at 22 cfs at the Webster gage on the French
River. This will provide for a significant increase in dissolved oxygen levels
in the impoundments during naturally low flow periods associated with the most
severe dissolved oxygen depletion. The EIS demonstrates that augmentation can
be accomplished within the existing operating range of the flood control pool
with no substantial new impacts on the Buffuniville environment. The impacts on
existing recreation at Buffumville are minor and can be overcome by recommended
mitigative measures -
6. The State of Connecticut supports the removal and isolation of
existing contaminated sediments in the French River impoundments. The State of
Connecticut is pursuing a course of utilizing its own resources to remove
sediments from North Grosvenordale pond and the channel at Langers Pond, and to
isolate remaining sediments in Langers Pond. Connecticut is currently
completing a French River sediment management engineering plan which was funded
by the Connecticut General Assembly. Continued support by the Connecticut
legislature for this plan is seen to be contingent upon progress toward
implementation of advanced treatment and low flow augmentation.
7. The State of Connecticut does not support low flow augmentation to
provide 47 cfs at the Webster gage. This has not been considered as a serious
alternative by the State/EPA Working Group and was not evaluated in detail in
the EIS. However, it is apparent from our review of the EIS that the
associated impacts on the Buffumville environment and existing recreational
uses could be serious.
8. The State of Connecticut supports the implementation of in-stream
aeration in North Grosvenordale if it is necessary to fully achieve the adopted
Class B goal. We recognize that critical parameters for the design of the
aeration system include water quality conditions, channel configuration, and
hydraulics. These parameters will change significantly in North Grosvenordale
pond following implementation of sediment dredging, low flow augmentation, and
advanced treatment. We therefore strongly recommend that the final design
studies for the aeration system be considered as the second phase of the
restoration program following completion of the other three projects. We also
recommend that the institutional mechanisms for implementing in-stream aeration
be pursued through the State/EPA Working Group forum.
In summary, the State of Connecticut strongly recommends that EPA make
final revisions to the EIS, issue appropriate permits for Dudley and Webster,
and pursue implementation of low flow augmentation at the Corps of Engineers
Buffumville flood control facility. In our judgement, these actions will
improve conditions sufficiently to maintain a significant fishery in the North
Crosvenordale Pond, improve aesthetic conditions consistent with requirements
for bathing, and eliminate the noxious odors that currently plague the
C— 146
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residents along the French River. In simple terms, the water quality will
improve sufficiently to support the uses specified for Class B
fishable/swimmable waters. Any remaining problems associated with dissolved
oxygen levels not achieving the goal of 5.0 nig/l for Class B waters will be
dealt with following implementation of the three primary remedial actions
recommended in the EIS.
As we have spent more than a decade studying this problem, we now feel it
is time to take action to implement the recommendations of the EIS. We would
greatly appreciate a response from you or your staff indicating the next steps
EPA will take in this matter and the timing of these steps.
Thank you for your attention to this matter.
Sincerely,
‘STANLEY Al PAC
COMMISSIONER
SJP:job
cc: Richard Kotelly,US EPA Region I
Michael Bartlett, US Fish & Wildlife Service
US Representative Sam Cejdenson
Cern Langlois, Town of Thompson
George Koch, French River Committee
c—i 47
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RESPONSE TO LETTER FROM CONNECTICUT
DEPARTMENT OF ENVIRONMENTAL PROTECTION
RECEIVED ON SEPTEMBER 29, 1986
Connecticut Department of Environmental Protection has expressed its
support of the EIS. EPA agrees with ConnDEP that low flow augmentation
to 7 cfs at the Webster gage would severely impact the environment
surrounding Buffumville as well as the lake’s recreational uses.
C-i 48
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PART C—3. SUMMARY OF MEETINGS
c_1149
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SUMMARY OF MEETINGS
IN PREPARATION FOR THE ElS
DATE LOCATION TYPE OF MEETING
8/16/814 Town of Dudley Scoping
8/22/8 1 1 EPA Scoping
9/11/814 US Army Corps of Engineers Review
12/18/814 EPA TAG
2/2/85 US Fish & Wildlife Service Review
11/9/85 DEQE/Westboro TAG
6/27/85 Conn DEP Review
7/2/85 DEQE/Westboro TAG
7/25/85 US Army Corps of Engineers Review
8/16/85 DEQE/Westboro TAG
10/30/85 Webster Town Hall Public Meeting
12/18/85 EPA Review
12/18/85 US Army Corps of Engineers Review
8/12/86 DEQE/Westboro Review
C-i so
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çc D ST ,.
, t t)
_____ UNtTED STATES ENVLRONMENTAL PROTECTtON AGENCY
REGION
.3. F. KENNEDY FEDERAL BL:LOING. BOSTON, MASSACHUSETTS O22O
DATE: February 12, 1987
SUBJECT: Public Meeting
French River Final EIS
FROM: Richard Kotelly, Deputy ctor
Water Management Divisi
TO: Interested Agencies, Public Groups and Citizens
This week we mailed the Final Environmental Impact Statement for
the French River Cleanup Program. We want to present the recommen-
dations and receive your comments before writing the Record of
Decision. To receive comments, a public meeting will be held at the
Dudley Town Hall on Schofield Avenue (Rt 12), March 5, 1987 at 1:30 pm.
We would appreciate oral and written comments at this meeting. The
comment period will formally close on March 20, 1987.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203
FEB 11 1987
To: All Interested Agencies, Public Groups, and Citizens
EPA Region I is pleased to distribute the Final Environmental
Impact Statement for the French River Cleanup Program for your
consideration. This Final EIS (FEIS) presents a series of pro-
posed actions to improve the water quality of the French River in
Massachusetts and Connecticut. It reflects comments and sugges-
tions made during the EIS process by interested and involved local,
state, and federal officials and citizens. A responsiveness summary
with all written comments to date is included.
The availability of this FEIS will be noticed in the February 20, 1987
Federal Register. The comment period will be for one month.
Please send any further comments to:
Ronald G. Manfredonia, Chief
Water Quality Branch
EPA, Water Management Division
J.F. Kennedy Federal Building
Boston, MA 02203
A Record of Decision will be prepared in April, 1987 specifying
the final recommended actions and mitigation measures.
sincerely yours,
1 P .J
Michael R. Deland
Regional Administrator
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J. F. XENNEDV FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203
Date: February 19, 1987
Subject: French River EIS
Change of Title
I i jL(
From: -Th nald G. Manfredonia, thief’
Water Quality Branch
To: Interested Agencies, Public Groups and Citizens
At the suggestion of legal counsel, we are giving notice that the Final
Environn ntal Inçact Staten nt for the French River Cleanup Program in
Massachusetts and Connecticut , January 1987, shall henceforth be called
the Pevised Supplerrental Final Environmental Inpact Statement for the
French River Cleanup Program in Massachusetts and Connecticut , January 1987.
The doctinent includes water quality nodeling under various scenarios, and
recaiinendations for improving water quality. Cc minents from numerous
agencies and public groups are included with our response.
We are conducting a public hearing at the tudley Town Hall on Schofield
Avenue (Rte 12), March 5, 1987 at 1:30 p u.
We uld appreciate oral and written cannents at this meeting. The
comment period will fonnally close on March 30, 1987.
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SEDIMENT
DEPTH
LI 0-1.9’
2’- 3.9’
4’ 5.9’
6’ - 7.9’
8’ - 9.9’
200 0 200
SCALE IN FEET
1
çle$
FIG. 3-15 SEDIMENT DISTRIBUTION IN PERRYVILLE POND
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