BOS-OO2- )ii EVALUATION OF SATELLITE
ADVANCED WASTEWATER TREATMENT FACILITIES
t4 . I t4rr r
REFERENCE Volume II
BOSTON HARBOR SUPPLEMENTAL
DRAFT
ENVIRONMENTAL IMPACT STATEMENT
U.S. ENViRONMENTAL PROTECTION AGENCY
REGION I
JOHN F. KENNEDY FEDERAL BUILDING
BOSTON, MASSACHUSETTS 02203
! EGI LIBRARY
rr FEDERAL BLDG
.cJON, MA 02203-2211
NOT FOR PUBLIC RELEASE
DRAFT REPORT
Prepared by:
CE MAGUIRE,
February 1984
0
Te. lW
INC.
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TABLE OF CONTENTS
Section Title
A HISTORICAL BACKGROUND
A.1 EMMA CONCEPTS
A.2 EMMA RECOMMENDED SATELLITE FACILITIES
A.3 1978 DRAFT EIS CONCLUSIONS
B DESCRIPTION OF SDEIS SATELLITE OPTIONS
8.1 EMMA RECOMMENDED SATELLITE FACILITIES UPDATE
B.2 WETLANDS DISPOSAL OPTION — PROPOSAL BY QUINCY SHORES ASSOCIATION
B.3 RELATIONSHIP OF SATELLITE OPTIONS OF ON-GOING MSD-SOUTH FACILITIES
PLAN
C EVALUATION OF SDEIS OPTIONS
C.1 EMMA RECOMMENDED FACILITIES
(i) Flow Augmentation
(ii) Water Quality
(iii) Water Supply
C.2 WETLANDS DISPOSAL OPTION
0 CONCLUSIONS
APPENDIX A WATER QUALITY MODELING CORRESPONDENCE
APPENDIX B WETLANDS DISPOSAL BIBLIOGRAPHY
APPENDIX C WETLANDS DISPOSAL-DEQE CORRESPONDENCE
APPENDIX 0 I/I PRELIMINARY REPORT TO PROF. CHARLES M. HOAR
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A. HISTORICAL BACKGROUND
1. EMMA Concepts
Five broad-scale wastewater management concepts were developed for
evaluation in the Eastern Massachusetts Metropolitan Area Wastewater
Management (EMMA) Study. Although the concepts themselves were not
necessarily formulated with the intention of any one being selected for
implementation in its entirety, it was intended that the evaluation of
these broad—scale concepts would establish the design criteria, system
limits, and other conditions and considerations required of an imple-
mentable, recommended plan.
Brief general descriptions and important features relative to
satellite facilities of the five original concepts are shown on Table 1.
An extensive rating system was employed to evaluate and rank the concepts
by the Technical Subcommittee. This evaluation led to the elimination of
concepts 3 and 5 from further consideration. As stated in the EMMA Study
Main Report (pg. 4-27):
“Upon evaluation of all the factors affecting the plan selection
process, and because of the closeness of the rankings for Concepts
1, 2 and 4, it was decided by the Technical Subcommittee that a
moderately decentralized system would be the best overall solution
considering river flows, increasing demand and decreasing oppor-
tunities for water-oriented activities, and the difficulties associ-
ated with extensive interceptor construction through urban areas and
the filling of Boston Harbor.”
Four satellite treatment alternatives were developed for further
evaluation. The satellite systems and communities to be served under
each alternative are summarized in Table 2. The wastewater flows from
remaining communities tributary to the Nut Island Treatment Plant would
continue to flow to Nut Island for treatment and discharge to Boston
Harbor. The following excerpt from EMMA Study Main Report summarizes the
evaluation of the four alternatives:
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TABLE 1
Satellite Facilities Design Communities Served
Concept Description ( River Basin) ( Plant Location) Flow By Satellite Plants
Upgrade existing facili- None
ties, minor system expan-
sion (addition of 7 com-
munities), no satellite
plants
2 Limited decentralization, Sudbury R. Framingham 19.0 IIGD Ashland, Framingham,
creation of five regional Hopkinton, Southborough
satellite systems
Charles R. Dedham 29.0 HGD Brookline (25%), Dedham,
Dover, Natick, Needham,
Newton (8%), Sherborn,
Wellesley, Boston (West
Roxbury)
Charles R. Watertown 45.0 MGD Lincoln, Newton (92%),
Waltham, Watertown,
Weston
Neponset R. Canton 25.0 MCD Canton (70%), Norwood (90%),
Sharon, Stoughton, Walpole
Neponset R. Canton 5.5 ?IGD Canton (30%), Dedham (10%),
Norwood (10%), Westwood
3 Maximum expansion of MSD None
treatment of all flows at
expanded harbor facili-
ties
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4 Maximum decentralization
of MSD, creation of six
regional satellite sys-
tem
Sudbury R.
Charles R.
Framingham
Dedham
19.0 HGD Same as Concept 2
22.0 MGD Dedham (40%), Dover,
Natick, Needham, Sherborn,
Welles ley
Charles R.
Neponset R.
Watertown
Canton
45.0 MGD Same as Concept 2
30 MGD
Canton, Norwood, Sharon,
Stoughton, Walpole,
Wes twood
5 Land application of five
of the six satellite
facilities as proposed
in Concept 4 - otherwise
identical to Concept 4
Mystic R.
Mystic R.
Woburn
Medford
Same as Concept 4 (Sudbury
River - Framiagham Facility
would not employ land appli-
cation)
31.0 MGD Burlington, Reading,
Stoneham (85%), Wakefield
(10%), Wilmington,
Winchester (45%), Woburn
30.0 MGD Arlington, Bedford, Belmont
(90%), Lexington, Medford
(20%), Winchester (55%)
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“Upon further analysis of the Neponet River, the Massachusetts
Division of Water Pollution Control recommended that if a satellite
treatment plant is located for discharge to the Neponset River, the
plant should be located as far upstream as possible to provide
maximum benefits to the river, particularly during the dry sunm er
months.
“A plant in the middle Charles area was considered vital to
provide effluent for low-flow augmentation. As mentioned earlier,
investigations (by the Corps of Engineers and the United States
Geological Survey) for other means of flow augmentation in the
Charles River were found not feasible and the need for conserving
river flows was shown to be critical (by the United States Geologi-
cal Survey). In terms of location, the lower middle Charles plant
would be undesirable due to the flat, slow flowing river in that
location. However, an upper middle Charles plant discharging at the
Cochrane Dam near Charles River Village would be in a location where
the discharge would benefit from the over one mile long rapids
section.
“In addition to these considerations, the plants will also
serve to reduce flows to the Nut Island Treatment Plant and will
reduce the need for relief lines along the Wellesley Extension
Sewer, the New Neponset Valley Sewer, and the High Level Sewer.
“Providing a 2 mgd wastewater treatment plant in the Aberjona
River area would cost on the order of $9.7 million to construct and
about $0.7 million per year to operate. These costs represent the
complete treatment process shown in Figure 3-4. On the basis of
operating costs alone, this would be in excess of three times the
cost of using MDC water for augmentation (which would be an unaccept-
able alternative). In addition to this, other alternatives of flow
augmentation should be considered such as groundwater pumping during
low flows and recharge during high flows.
“A wastewater treatment plant discharging to the Sudbury River
in the Framingham area was considered as not providing a significant
improvement in flows due to the large storage potential in the flat
swampy areas downstream.”
Based on the evaluation of these alternatives, a modified Alterna-
tive A was selected as the Recommended Plan.
2. EMMA Recommended Plan - Satellite Facilities
The Recommended Plan included satellite treatment facilities dis-
charging to the Middle Charles and Upper Neponset Rivers. The Middle
Charles Treatment Plant would serve Ashland, Framingham, Hopkinton,
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TABLE 2
Satellite Facilities Design
Alternative River Basin Plant Location Flow Communities Served by Satellite Plants
A Charles R. Middle Charles 31 MCD Ashland, Dover (60%), Framingham,
Area Hopkinton, Natick, Sherborn, South-
borough, Wellesley (80%)
Neponset R. Lower Neponset 31 MGD Canton, Norwood, Sharon, Stoughton,
Area Walpole, Westwood
B Charles R. Lower Middle 57 MGD Ashland, Brookline (15%), Dedham (40%),
Charles Area Dover, Framingham, Hopkinton, Natick,
Needham, Newton (54%), Sherborn, South-
borough, Wellesley
Neponset R. Lover Neponset 31 MCD (Same as Alternative A)
Area
C Charles R. Middle Charles 31 MGD (Same as Alternative A)
Area
Charles R. Lover Middle 27 MGD Brookline (15%), Dedham (40%), Dover
(60%), Needham, Newton (54%),
Wellesley (20%)
Neponset R. Lover Neponset 31 MCD (Same as Alternative A)
Area
D Sudbury R. Upper Sudbury 19 MGD Ashland, Framingham, Hopkinton, South-
Area borough
Charles R. Lower Middle 39 MCD Brookline (15%), Dedham (40%), Dover,
Charles Area Natick, Needham, Newton (54%),
Sherborn, Wellesley
Neponset R. Lower Neponset 31 MCD (Same as Alternative A)
Area
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Natick, Sherborn, Southborough and p 1 rtion of Dover and Wellesley and
would have a design flow capacity o&31 MGp. The Upper Neponset Treat-
ment Plant would serve Canton, Norwood., a’lpole, Sharon and Stoughton and
would have a design flow capacity of 25 MGD.
The anticipated benefits associated with these proposed facilities
were summarized as follows:
Neponset River: This facility would reduce the service area of
the Nut Island Treatment Plant and keep reclaimed wastewater as far
upstream in the Neponset River Basin as possible. The highly treated
effluent should help the Neponset River by increasing flows in dry summer
months. Restoration of clean water will also depend on the abatement of
nonpoint and other sources of pollution.
Charles River: This facility would treat 31 mgd in the year 2000,
reduce flows to the Nut Island plant, and help retain reclaimed waste-
water in its immediate basin. Adding these flows to the Charles River
will be helpful to water quality in dry seasons. However, there can be
no assurances of achieving intended water quality in the Charles River
unless nonpoint and other sources of pollution are eliminated. The
treatment facilities which are in various stages of implementation in the
Medfield, Medway, and Milford areas should also benefit the river.
It is worthwhile to note that, in recommending the implementation of
both treatment facilities, it was recognized by the Technical Subcom-
mittee and by those who participated in the public review process that
water quality in both the Charles and Neponset Rivers might not be
improved. There appears to have been, however, an implicit assumption
that water quality problems would not worsen as a result of the dis-
charges from these treatment facilities.
The Middle Charles and Upper Neponset facilities were scheduled as
sequence numbers 10 and 11 respectively in the Construction Staging
Program for MDC Wastewater Management Projects. The total cost of
both facilities was $90,700,000 based on January 1975 (ENR 2200) costs.
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The Construction Staging Program also listed interceptor relief in
lieu of sequence numbers 10 and 11 as sequence numbers 1OA and hA if the
satellite plants are not implemented. The total cost of additional
interceptor relief for the Wellesley Extension, New Neponset Valley and
High Level Sewers was listed as $64,700,000 (January 1975, ENR 2200).
Finally, four optional treatment scenarios were presented in the
EMMA Main Report which were intended to provide an economic perspective
of the impacts of major changes from the Recommended Plan such as timing
of implementation of major facilities (i.e. satellite plants); and policy
changes such as primary treatment with deep ocean discharge versus
secondary treatment. These “Other Treatment Options” and their assciated
capital and O&M costs are summarized in Table 3.
3. Conclusions Regarding Satellite Facilities - Draft EIS, 1978
The Draft EIS concluded that neither the Charles nor Neponset River
satellite plants should be constructed. This conclusion was based on
negative water quality impacts projected to occur or to be maintained at
the 7010 design flow condition.
o.
I Based on the application of a basic Streeter-Pheips dissolved oxygen
analysis in the Neponset River, the draft EIS concluded that:
“Any discharge to Neponset in the area proposed by the EMMA report
would result in a significant detrimental impact on the Neponset
River’s dissolved oxygen resources and overall water quality. In
addition, all the discharge points analyzed are upstream of a major
group of water supply wells (See Figure 2.5-18). It is very likely
that these wells draw from the Neponset during low flows, given
their proximity to the River and the nature of the aquifer. The
potential for significant adverse health effects is created by
utilizing any of these discharge point. In order to mitigate these
impacts it would be necessary to move the discharge point downstream
of point C. Such action reduces potential flow augmentation bene-
fits considerably.
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TABLE 3
SUMMARY OF OTHER TREATMENT OPTIONS - MDC - EMMA STUDY
Capital Cost( 1 ) Operation & Maintenanc?l)( 2 )
Option Description millions of $ cost, millions of $/yr
Recommended plan 855.3 25.6
Total ocean discharge No satellite treatment plants. 737.9 16.9
All flows discharged in deep
waters after receiving primary
treatment at the Harbor plants.
Ocean discharge in Satellite treatment plants con- 755.7 22.3
lieu of secondary structed. Primary treatment at
treatment the Harbor plants with deep
ocean discharge.
Deletion of satel- No satellite treatment plants. 872.4 20.9
lite plants All flows receiving secondary
treatment at the Harbor plants.
Postponing of satel- Delayed construction of satel- 884.8 20.3
lite plants lite plants. Upgrade primary
treatment at the Harbor plants.
Extend treatment capabilities at
the Harbor plants to secondary
along with construction of
satellite plants.
1. Costs shown are in millions of dollars based on January 1975 (ENR 2200) prices.
2. Costs on the basis of future flows (year 2000).
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“In light of the great potential negative impact upon water quality,
implementation of a Neponset River Satellite Plant is not recom-
mended.”
A fairly rigorous analysis of the Charlesiiver was undertaken by
Alan Ikalainen (at that time of EPA Region f’SYstems Analysis Branch
staff) employing a computer model developed for the Massachusetts
Division of Water Pollution Control (MDWPC) known as the STREAM model.
Based on this analysis, the draft EIS concluded that:
“A satellite plant represents a major new pollutant source for the
Charles River, which will increase point source mass input the River
of BOD 5 from 329 to 586 kg/d (725 to 1293 lbs/d) and nitrogenous
oxygen demand from 311 to 535 kg/d (685 to 1181 lbs/d) (See Table 7,
Appendix 3.2.2). In addition, the following table compares the
proposed discharge with River quality just upstream of the dis-
charge. Imposition of this additional load upon the already
stressed river system may effectively preclude the Charles from
recovering from its present stressed condition. If River conditions
improve such that standards are met, the satellite discharge is
indicated to cause violation of standards unless an extremely high
level of treatment is achieved on a consistent basis. As the result
of this analysis, a satellite plant discharge is seen as not improv-
ing water quality in the Charles River and contributing to the
maintenance of its present condition. The implementation of a
satellite plant discharging to the Charles River is not recom-
mended.”
The conclusions and recommendations of Mr. Ikalainen’s report are as
follows:
CONCLIJS IONS
1. The physical characteristics of the Charles River are such that it
has a very low assimilative capacity for oxygen demanding wastes at
the seven-day, ten-year low flow.
2. This analysis reveals a very major likelihood that the Charles
River, at the seven-day, ten-year low flow, when receiving year 2000
wasteloads (5 mg/i CBOD 5 and 1 mg/i N H 3 - N) from existing treatment
plants in Miiford, Medfield, and Miliis and the Charles
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COMPARISON OF AWT EFFLUENT AND CHARLES RIVER QUALITY /
Charles River’ Satellite Disch rge2
Flow, m 3 / 0.89 1.35 /
(ft Is) ( 31.4)t ’ (47.7 )
Dissolved Oxygen, mg/i 3.1 6.0
BOB 5 mg/i 0.6 5.0
(kg/d (lbs/d) 67 (148) 478 (1494)
Nitrogenous Oxygen Demand
mg/i 0.005 1.0
kg/d (lbs/d) 17.5 (38.5) 535.8 (1181.5)
Total Oxygen Demand
mg/i 1.1 11.9
kg/d (ibs/d) 84.6 (186.5) 1231.4 (2675.5)
‘River conditions as modelled at river kilometer 80.3 (river mile 50),
just upstream of Medfield State Hospital discharge point, during 7 day,
10 year low flow. All upstream point sources have effiuent quality of S
mg/i BOD 5 and 1 mg/i NH 3 -N.
recommended discharge and effluent quality.
p
M— ,LlL. J £0
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River Pollution Control District Plant, will not attain the D.O.
level of 5.0 mg/i for long stretches. This condition will prevail
with or without an MDC Satellite plant discharge at any of the
locations considered in this analysis.
3. If future discharges at Milford, Medfieid and Nulls and the Charles
River Pollution Control District can be reliably treated and the
river can be reliably treated such that D.0. levels in the river
upstream of an MDC satellite plant discharge are at 5.0 mg/i at the
seven—day, ten-year low flow, then an MDC satellite plant discharge
containing 5.0 mg/l of CBOD 5 would not lower D.O. levels below 5.0
mg/i if it is located upstream of the South Natick Dam. However,
this condition would be true only if no other oxygen demanding
phenomena such as algal die off and non-point source pollution occur
during the low flow periods.
4. It is understood that the “STREAM” model does not simulate all of
the physical and biochemical processes that occur in the Charles
River and which determine part of its water quality and biotic
condition. However, these processes, such as algal growth and death
dynamics, land-surface runoff dynamics, septic and solid waste
leaching——all of which are known to occur in the Charles River, can
further worsen D.O. conditions at critical periods beyond those
processes which are simulated by the “STEAM” model. Such critical
conditions would probably be during periods of high temperature, low
river flow and between periods of short duration, intense rainfall.
The occurrence of base flow (groundwater flow) into the river has
not been considered and its effect on water quality is not known.
5. An MDC satellite plant discharge under the anticipated year 2000
wasteloads (5.0 mg/l CBOD 5 andl.0 mg/i N B 3 - N at all upstream
discharges) will significantly improve D.0. levels in the Charles
River only if the discharge is located upstream of the South Natick
Dam or near the Medfield Hospital. The improvement will be I to 2
mg/i increase in D.O. along several miles of river. However, the
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improved condition will be significantly below the desired level of
5.0 mg/i.
6. This analysis indicates that benthal oxygen demand is a significant
oxygen loss to the Charles River. For example, at the seven-day,
ten-year flow, without any sediment oxygen demand and without any
treatment plant flow or wasteloads, the Charles would meet the D.O.
level of 5.0 mg/i except for a short stretch upstream of Milford
where background loads would cause 0.0. to fall to 2.5 mg/i.
Current wasteloads (1978) added to the river under these same
conditions cause D.0. levels to fail to zero below Milford and
within the South Natick Dam and Cochrane Dam impoundments. If these
wasteloads receive advanced treatment (5.0 mg/i CBOD 5 and 1.0 mg/i
NH 3 - N) and the Charles River Pollution Control District Plant
receives advanced wastewater treatment, at year 2000 wastewater
flows, the zero D.0. levels are raised to greater than 5.0 mg/l
below Milford and to about 2.5 mg/i in the South Natick Dam and
Cochrane Dam impoundments.
If an MDC Satellite plant discharge is added to the river at
?ledfield with year 2000 flows with advanced treatment, 0.0. levels
are raised by 1-2 mg/i within the South Natick Dam impoundment and
lowered by 1.0 mg/l to about 4.0 mg/i within the Silk Mill Dam
impoundment. If the Satellite plant discharge is located below the
. ‘Cochrane Dam, th will be no 0.0. increase within the South Natick
Dam impoundment and there will be an additional decrease in 0.0. of
QJ 1.0 mg/i to about 3.0 mg/l within the Silk Mill Dam impoundment.
In comparison, with sediment oxygen demand at the levels used in
this analysis, atthe volume of vastewater discharged, not including
the proposed satellite plant, increases from no plant wastewater
discharged to 1978 flows to 2000 flows, at the respective levels of
treatment, the 0.0. levels of the river increase successively. The
result is that the D.0. levels will be significantly better in the
Charles at the year 2000 flows at Milford, CRPCD and Medfield-
Millis, ret ivig advanced treatment, than at present flows and
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treatment levels. However, there will be long stretches with D.O.
very much less than 5.0 mg/l within the South Natick Dam and Silk
Mill dam impoundments. Adding the MDC Satellite plant flow at
Medfield will further raise D.O. by 1-2.5 mg/l within these impound-
ments, but it will remain 1-2.5 mg/i below the 5.0 mg/i level.
Adding the MDC Satellite plant flow below the Cochrane Dam will
raise D.O. about 1.5 mg/i at the discharge point and lover it about
1.0 mg/l within the Silk Mill Dam impoundment.
d fu rt
RECOMMENDATIONS
1. An MDC satellite plant should not be located on the Charles River
unless:
a. it can be shown through further data collection and analysis
that those river processes not considered in this analysis will
not increase D.O. deficits during low flow periods;
b. it can be shown that treatment plant facilities can be reliably
operated to provide the pollutant removals as are shown to be
required by this analysis to maintain 5.0 mg/i D.O. in the
Charles River at low flow;
c. the public is willing to bear the economic and environmental
impact costs of a satellite plant at the required location and
level of treatment.
I) P “% ‘
2. (Treatment applied to wa ewater discharges not reduce levels
of all pollutants below those occurring in runoff and other non-
) point pollution sources kf the Charles River unless it is proven
J
\ through detailed analysis that further treatment Iis,cost effective
in terms of significantly improving in stream water quality.
3. The water pollution control planning process for the Charles River
should include, as a possible control for future wastewater from
Milford, CRPCD and Medfield-Millis, the limiting of sewer service
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area and wastewater loadings, such that wastewater loadings to the
Charles River are minimized.
NOTE:
,) &Q These recommendations are based upon the premise that the water
quality standard for dissolved oxygen (5.0 mg/i) has to be met at the
seven-day, ten-year low flow. Therefore, new discharges to the Charles
must be such at D.O. levels of 5.0 mg/i will be met at low flow and they
will be discharging to a river which is meeting standards at low flow.
As a result of the conclusions stated regarding the negative water
quality impacts associated with both the Charles and Neponset satellite
facilities, the site selection process was abandoned for both facilities
prior to the selection of a recommended location for each plant.
Detailed evaluations of flow augmentation impacts of the satellite
facilities were conducted for each river and reported in the draft EIS.
The conclusions at these evaluations, which also reflect potential water
quality impacts previously described are summarized as follows:
Charles River
“The future low flow hydrology of the Charles River will be influ-
enced by a number of factors not previously considered. The most signi-
ficant of these is the presence of point source discharges upstream of
the MDC service area. Dischar e 3 from these sources is expecte o
increase approximately 4 . x10 m /d (12.7 mgd) - from 19.68x10 m /d (5.2
mgd) in 1973 to 67.76x10 m /d (17.9 mgd) in 2000. These upstream com-
munities draw groundwater from public wells scattered throughout the
Upper Watershed (see Figure 2.5-13b) and many private wells. Groundwater
withdrawals from wells distant from the river will adversely influence
the Charles only after a significant time lag. Conversely, the water
will rapidly reach the river via the sewer systems. The net effect can
be considered as augmentation of river flow by pumping groundwater
storage. These upstream sources roughly balance the export volume and
the flow situation in the Charles can be anticipated to remain relatively
constant. In addition, implementation of water conservation methods,
reduction in I/I and more effective management of the Mother Brook
diversion are techniques which can be utilized to ensure low flow prob-
lems in the lower Charles watershed do not develop.
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“In summary, it is felt that the benefits of flow augmentation to
the Charles River by an additional point source discharge, are not
sufficient to warrant the degradation in water quality that such a
discharge would cause. Given the option of Harbor discharge, the risks
involved with a Charles River satellite discharge are not offset by the
benefits to be derived.
“While recycling of water within a basin is a worthy objective of a
wastewater management plan, it should not be done at the expense of water
quality considerations. Indeed, recycling is occurring in the Charles
upstream of the study area. As a result of this, water is conserved
during times of drought 3 a d water quality is frequently degraded. Adding
an additional 120.24x10 m /d (31.77 mgd) point source to the river does
not appear to be environmentally sound. The expenditure of resources on
advanced waste treatment would be best applied to existing point sources
in the river to maximize the water quality and quantity benefits of their
operation. The water quantity/flow augmentation issue is extremely
difficult to project and is by no means closed. However, it is felt that
a system without satellite plants will best protect the overall environ-
mental concerns within the study area.”
Neponset River
“The Neponset River is actively regulated for industrial water
supply and this controls its low flow characteristics. In addition, the
only upstream discharges are industrial cooling waters. Sources of water
to make up for export to the Harbor are not readily available as in the
Charles watershed.
“Between 1970 and 2000, export of N p nset water to Boston Harbor
would increase by approximately 45.42x10 m /d (12 mgd). The loss of this
water is a negative impact associated with non—satellite alternatives.
However, as previously discussed, significant water quality impacts will
be caused by a Neponset discharge. Major water supply wells lie immedi-
ately downstream of the most likely discharge points, creating public
health concerns. The water quality related impacts are more severe than
the water quantity impacts and, therefore, an all harbor alternative is
preferable.
“The potential to mitigate those impacts through an alternative
augmentation system should be investigated. The active regulation of the
Neponset for industrial water supply could be coordinated with flow needs
such that both are satisfied during drought conditions. In addition,
major I/I reductions and water conservation should be emphasized as
methods to mitigate quantity related impacts. Such actions will have
greater long term benefits for the Neponset River Watershed than aug-
mentation with wastewater.”
A comparison of the Recommended Plan which evolved as the result of
the Draft EIS process and the EMMA Recommended Plan was presented in the
Draft EIS in Section 3.5.9 which summarized the major impacts and costs.
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This section is reported here in its entirety as it represents an impor-
tant link between the draft and supplemental EIS review process.
“3.5.9 Conclusion (Draft EIS, 1978)
“With respect to water quality considerations, the pn-satellite
y em Deer Island Plan) is the only system alternative which will
meet wate lTtyTti Tdi. This system will not affect water quality
in inland streams and will greatly improve the quality of the existing
effluent discharges. The EMMA Plan wi].1 similarly improve the quality of
the harbor discharges and will reduce their volume somewhat. The EMMA
Plan,_however, will cause degradation of water quality in the Charles and
Ne15 ithet Ri ST A Nep nàet RiviIdIicharge will cause its dissolved
oxygen standii d to be violated, while the Charles River discharge will
significantly increase the magnitude of projected water quality viola-
tions. The No Action alternative will result in the continued degrada-
tion of harbor waters. Modified No Action will cause an improvement in
ambient water quality conditions but degradation in the vicinity of the
existing primary discharge will persist. Overall, the Deer Island Plan
is the best of the four system alternatives with respect to water
quality.
“In terms of water quantity, the Deer Island Plan and both “No
Action” alternatives will have a similar effect. That is, they will
result in the export of water from the Charles and Neponset watersheds in
the form of sewage. For the Charles River watershed, this loss will be
approximately offset by additional point source dischar 9 to the river.
For the Neponset River, an estimated export of 45.42x10 m /d (12 mgd) per
day has been projected. The EMMA Plan, since it will result in the
discharge of treated effluent to the rivers, will have a lesser impact on
low river flows. In fact, the EMMA Plan will result in substantially
higher dry weather river flows than have occurred in the past, but at the
expense of water quality.
“The effects of the No Action alternative on the area’s biotic
communities will represent a continuation of present trends. That is,
organisms associated with polluted waters will remain. Increased
degradation of water quality as a result of increased pollutant loads
will continue to damage the harbor’s flora and fauna as well as the
public’s use of them. Modified No Action will improve the situation
except in the vicinity of the existing primary outfalls. Both the EMMA
Plan and the Deer Island Plan will further improve biotic conditions.
“The EMMA Plan and the Deer Island Plan will further improve biotic
conditions.
“The EMMA Plan will require the use of two additional sites for
facilities construction and specifies the filling of Quincy Bay to expand
the Nut Island plant and the filling of Boston Harbor to expand the Deer
Island plant. This is considered to be a major impact. The Deer Island
Plan avoids filling the harbor but requires the complete use of Deer
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Island plus a major bay crossing. Also, additional interceptor relief is
required for the Deer Island Plan.
“In terms of construction-related impacts, both the Deer Island Plan
and the EMMA Plan will cause more disturbance than either No Action
alternative. While each of these systems will produce its own set of
characteristic construction impacts, they cannot be easily separated on
this basis in terms of a value judgment.
“As far as air quality characteristics are concerned, the No Action
alternative would result in the least air emissions followed by the
Modified No Action alternative. The Modified No Action alternative
represents an increase in emissions to the ambient air due to the incin-
eration of the primary sludge, but it would not include the incineration
of the secondary sludge. Comparisons of the emissions from primary to
secondary sludge incineration at the Deer Island Plan and EMMA Plan
sites, indicates the Deer Island Plan would have less air quality impact.
This is based upon the lower quantities of emissions and the site loca-
tion of the Deer Island Plan. This differential is offset, however, by
the need to establish a landfill for disposal of digested sludge under
the Deer Island Plan.
“On the basis of the preceding comparison, the best of the four
system alternatives can be selected. The No Action alternative, while it
is economical and impacts upon air quality the least, is not considered
feasible. Existing primary sludge di charges to the Harbor, poor opera-
tion of existing facilities, gross and visible pollution from the Nut
Island facility, and persistent bacterial contamination of the Harbor
render this alternative untenable.
“The modified No Action alternative will improve water quality
conditions and benefit the harbor’s biota in a general sense, but the
gross pollution from the existing primary outfalls and bypasses will
persist. Pollution from sludge discharges will be abated, however. This
plan is significantly less expensive than either the Deer Island plan or
the EMMA plan and will be more favorable in terms of air quality impacts
and primary construction-related impacts. The alternative is rejected,
however, on the basis of permitting unacceptable water quality conditions
to persist.
“The EMMA plan and the Deer Island plan both further improve water
quality conditions in the Harbor. As described previously, these alter-
natives vary in terms of their specific impacts, but they can be sepa-
rated on the basis of several significant parameters. These include:
“1. The violation of water quality standards in the Neponset River
and a further deterioration of the Charles under the EMMA plan.
“2. The need for 42 acres of fill in the Harbor under the EMMA
plan.
“3. The need for a major harbor crossing, additional interceptor
relief and drumlin removal under the Deer Island plan.
17
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“Beside these factors, the other levels of impact are generally
similar with some trade-offs existing between the alternatives. Costs
are approximately equal. While Item #3 above represents significant
impacts, they can be justified in light of the magnitude of the problem
and its solution. Except for drumlin removal, these effects are short
term. Items #1 and #2, however, represent long term impacts which are
considered unacceptable. The solution to a wastewater management problem
should not be resolved by causing other water quality problems. The loss
of 40 acres of the Harbor likewise represents an irreversible impact
which should not be accepted if there exists any alternative. We
therefore, select the Deer Island Plan as the best of the four system
alternatives.”
In its role as Technical Consultant to EPA Region I in the prepara-
tion of the Supplemental Draft EIS, CE Maguire was asked to evaluate the
technical basis which led to the conclusions previously discussed regard-
ing satellite treatment facilities and to update the evaluations to
reflect additional data, analytical procedures or changes in technology.
In this regard, EIS documents and references from the Draft EIS were
reviewed; meetings were held with EPA, MDC, MDWPC, DEQE, Division of
Water Supply and other pertinent agencies; and data collected in inter-
vening years (e.g. water quality) was assembled and incorporated into the
review process.
With respect to the draft EIS itself, the water quality analysis of
the Charles River was found to be the major unresolved issue. This issue
is identified in a package of correspondence between MDC, Metcalf & Eddy,
EPA and MDWPC over the period of 5/18/77 to 7/25/79, culminating in a
letter from Martin Weiss, then Chief Engineer of the MDC to Thomas C.
Mcflahon, Director of the MDWPC dated 7/25/79. This letter established a
scope of work expected to be conducted by the MDWPC to respond to con-
cerns raised regarding the water quality modeling of the Charles River as
presented by Mr. Ikalainen. With the exception of the water quality
survey carried out by the MDWPC in 1978, no documentation was found to
indicate that the MDWPC responded to Mr. Weiss’ letter on that the MDWPC
has any plans to respond to these items at present. The complete text of
the referenced correspondence is continued in Appendix I.
The other issue left unresolved in the draft EIS is that of the
siting of the satellite faclities. Although it is pointed out that the
18
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issue of siting was apparently considered moot following the presentation
of findings regarding water quality impacts, it is unclear as to why a
siting decision was preempted at that point in the EIS process.
B. Description of SDEIS Satellite Options
As a result of the joint NEPA/MEPA scoping process for this supple-
mental draft EIS, EPA was required to reevaluate the original satellite
facilities proposed in the EMMA Recommended Plan and a satellite facili-
ties proposal submitted by the Quincy Shores Association incorporating
wastewater reclamation/reuse via wetlands effluent disposal in critical
water supply recharge areas in the metropolitan area. Both satellite
options are described in the following sections incorporating wastewater
flow projections reflecting revisions generated in the Nut Island Site
Option Study; updated facilities design criteria and costs; and identi-
fication of the benefits projected to be associated with each option.
EMMA Satellite Facilities
Wastewater flow projections for both the Middle Charles and Upper
Neponset satellite facilities were updated using flow projections revised
in the NI-SOS. The revised flow estimates are summarized in Table 4.
Based on these projections, the Middle Charles facility would be designed
to treat 15.27 MGD average flow and 37.13 MGD peak flow in the design
year 2010. The Upper Neponset would be designed based on average and
peak design flows of 9.00 MGD and 22.26 MGD, respectively, in the year
2010.
Capital and operation and maintenance costs for the Charles and
Neponset facilities were updated from 1978 (ENR 2654) to 1983 prices
based on an ENR of 4200. As the differences in design flows relative to
the overall size and complexity of each facility are small with respect
to the updated vs. the original flow estimates used as the basis of
design in the draft EIS, no adjustments in costs were made based on the
updated flow projections for each facility. Further, it is important to
note that the costs do not include sludge pumping, sludge processing
19
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(e.g. thickening, dewatering), incineration and ash disposal which are
presented as the sludge processing and disposal operations in the draft
EIS. (Draft EIS, pg. 3-232, “The sludge produced at the satellite plants
would undergo incineration at each plant.”) Updated costs are presented
Table 5. It was further determined that the level and type of treat-
ment projected to be provided at each facility should remain as proposed
in the EMMA Recommended Plan and as described in the draft EIS. Proposed
effluent limits of 5.0 mg/i CBOD 5 and 1.0 mg/i NH 3 - N at the design year
flows can be reliably expected to be achieved via the proposed treatment
facility process configuration.
As previously stated, from both the EMMA and draft EIS documents,
the major benefits anticipated to be derived as the result of the imple-
mentation of satellite facilities are summarized as follows:
1. Satellite facilities would maintain water in its basin of
origin and thus provide reliable sources of low-flow augmenta-
tion.
2. Satellite facilities would reduce treatment capacity and size
requirements at Nut Island.
3. Construction of satellite facilities would result in cost
savings for interceptor relief in the southern MSD.
4. Satellite facilities would provide additional opportunities for
feasibility on sludge treatment and management.
20
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TABLE 4
REVISED FLOW ESTIMATES - CHARLES & NEPONSET SATELLITE PLANTS
Charles River
Projected Flows
Community
Ave.
1980
1990
Peak Ave. Peak
2010
Ave. Peak
5.22 13.18 7.21 18.00 9.00 22.26
Source: MDC Nut Island Site Options Study, 1982, M&E.
Ashland
0.39
1.12
0.55
1.56
0.93
2.49
Framinghain
5.72
13.32
6.86
15.97
7.72
18.00
Natick
2.67
6.64
2.98
7.36
3.34
8.19
Southborough
0.00
0.00
0.00
0.00
1.06
2.75
Wellesley
1.73
4.24
1.75
4.28
1.85
4.49
Dover
0.00
0.00
0.00
0.00
0.09
0.32
Hopkinton
0.00
0.00
0.00
0.00
0.22
0.65
Sherborn
0.00
0.00
0.00
0.00
0.06
0.24
10.51 25.32 12.14 29.17
Projected Flows
Totals
Neponset River
Community
Canton (30%)
Norwood
Sharon
Stoughton
Walpole
Totals
1980 1990
Peak Ave. Peak
15.27 37.13
2010
Ave. Peak
Ave.
0.49
3.03
0.00
0.78
0.92
1.26
7.35
0.00
2.08
2.47
0.62
4.21
0.00
1.15
1.23
1.59
10.29
0.00
2.91
3.21
0.79
4.78
0.26
1.62
1.55
1.98
11.65
0.78
3.92
3.93
21
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N
TABLE 5 - COST UPDATE - EMMA SATELLITE FACILITIES
Satellite AmountW Capital Cost 2 Annual O M Cost 2 Total Annual Cost 3
106) s x 106) s x
Middle Charles 70.5 5.57 12.82
Upper Neponset 61.3 4.74 11.04
Cost of facilities based on wastewater treatment plant with diffused air aeration and post aeration.
2 Capital and O M costs updated from 1979 to present day based on ENR = $4,200.
3 Total annual costs computed based on 8 1/8% over 20 years (CRF = 0.1028).
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2. QUINCY SHORES ASSOCIATION STAELLITE FACILITIES PROPOSAL
A detailed proposal recommending the implementation of three satellite
facilities in three different river basins in the south MSD was prepared and
submitted to EPA for evaluation in this EIS during the NEPA/MEPA scoping
process.
The specific facilities recommended in this proposal are presented as
follows:
THE WEYMOUTH FORE RIVER BASIN
That a regional advanced wastewater treatment plant be constructed on
the 42” MDC Braintree-Randoiph Extension Sewer on Section 128A down-
stream of the Braintree Cranberry Brook trunk sewer. This plant
could have an 8-10 million gallon per day (mgd) capacity. It would
discharge into the Broad Meadow wetlands along the Cochato River
where it could replenish critical water supply resources for the
towns of Braintree, Randolph, and Holbrook.
A plant located at that point could remove the following flows from
the Nut Island plant:
1990 2010
Municipality Average Peak Average Peak*
Braintree (15%) 0.42 0.97 0.44 1.01
Holbrook 0.14 0.46 0.38 1.12
Randolph 1.83 4.43 1.92 4.62
2.39 mgd 5.86 mgd 2.74 mgd 6.75 mg.
Water Supply. Braintree, Holbrook, and Randolph all share a common
surface water supply, Great Pond Reservoir and Richardi Reservoir.
Surface waters of the Cochato and Farm Rivers are diverted during
peak flow periods to supplement the reservoirs. There have been
recent water shortages and the dry-year safe yield of this system
is marginal to meet the current demands. All three communities
are included in the current MDC water study as potential future
connections to the MDC water system.
*A11 flow values from June, 1982, Nut Island Wastewater Treatment
Plant Facilities Planning Project (NI-SOS).
THE NEPONSET RIVER BASIN
That a regional advanced wastewater treatment plant be constructed
on the 54” MDC New Neponset Valley Sewer on Section 113 downstream
of Westwood, Walpole, and Stoughton extension sewers. This plant
could have a 35 ingd capacity. It would discharge through a dis-
persion pipe laid along 1-95 to the extensive Fowl Meadows, which is
underlain by high and medium yield aquifers, which are critical to
the area’s water supplies.
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Such a plant could intercept the MDC New Neponset Valley Sewer at
Section No. 113. That sewer is a brick interceptor 54” x 60”.
Again, using Facilities Planning Report Data, it could recharge:
Municipality
1990
Average Peak
2010
Average Peak
Allowing for infiltration as was done in the Facilities Planning
Study, the plant would have an average flow design capacity of
approximately 35 mgd. If such a daily flow were to be recharged
in the Fowl Meadow, say along Route 95 upstream of the proposed
plant site, it would provide a dramatic increase in water resources
in the Towns of Canton, Norwood, Westwood, and Dedham. The
major well fields of the Dedhain Water Company are directly down-
stream of the suggested plant location. The Dedham Water Company
has had shortage in the past and has recently lost some capacity
due to contamination; they are actively attempting to join the
MDC water system.
THE CHARLES RIVER BASIN
That a regional advanced wastewater treatment plant be constructed
by intercepting the Wellesley Extension Sewer and the Wellesley
Relief Sewer at the Easterly Connection Chamber and pumping to
the plant located at the edge of nearby City of Boston landfill
on Gardner Street in West Roxbury. It would discharge to the
Cow Island Meadows along the railroad and Route 128, where they
are underlain by high and medium yield aquifers serving water
supplies in Dedhain, Needhain, Wellesley, and Weston.
Municipality
1990
Average
2010
Peak Average
Peak
1.56 mgd 0.93 mgd 2.49 mgd
0.00 0.09 0.32
15.97 7.72 18.00
0.00 0.22 0.65
7.36 3.34 8.19
5.30 2.24 5.41
0.00 0.06 0.24
0.00 1.06 2.75
4.28 1.85 4.49
14.31 mgd 34.47 ingd 17.51 mgd 42.54 mgd
Canton
2.08 mgd
5.30 mgd
2.62 mgd 6.60 mgd
Norwood
4.21
10.29
4.78
11.65
Sharon
0.00
0.00
0.26
0.78
Stoughton
1.15
2.91
1.62
3.92
Walpole
1.23
3.21
1.55
3.93
Westwood
0.54
1.49
0.82
2.16
9.21
23.20
11.65
29.04
Ashland
Dover
Framingham
Hopkinton
Natick
Needham
Sherborn
Southborough
Wellesley
0.55 mgd
0.00
6.86
0.00
2 • 98
2.17
0.00
0.00
1.75
24
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The plant size would have an average daily capacity of approx-
imately 50 mgd. Such a plant could recharge water to aquifers
containing wells of the Dedharn Water Company and the towns of
Needham, Wellesley, and Weston. Also, the recharge could take
place in part upstream of the MDC diversion structure on Mother
Brook. This would provide much greater dry-weather stream flows
for management of water quality in the lower reaches of the
Charles and Neponset Rivers.
The following excerpt from the QSA proposal highlights the benefits
perceived by the authors to be associated with the facilities described
above:
These facilities could:
Reduce the size of the presently planned wastewater and sludge
treatment facilities at Deer and Nut Islands;
Allow for future growth and expansion in the western suburbs
of the MDC district;
Provide economic reduction in the I/I and CSO problems in
the Harbor area by flow reduction in major conduits; and
Enhance recreation and water supply resources in the Weymouth
Fore River, Neponset River, and Charles River Basin.
The recommendation that the satellite facilities recommended in the QSA
proposal utilize natural wetlands for effluent renovation and groundwater
recharge to existing and potential public water supply aquifers required a
multi-level evaluation of effluent discharge criteria in order to develop a
basis for conceptual design and costing of the proposed facilities. A review
of available literature on wetlands discharge - wetlands treatment capabilities
was performed to define suitable hydraulic, organic, and nutrient loading
criteria for wetlands to serve as a basis for determining wetland acreage
requirements, for various levels of treatment to be provided at the proposed
satellite facilities. A complete bibliography of literature reviewed in this
regard is included in Appendix B. Based on this literature review, it was
decided to employ the organic and phosphorus loading criteria used to develop
wetland area requirements in a feasibility study of wetland disposal of waste-
water treatment plant effluent conducted by IEP, Inc., under a research grant
for the MDWPC ( ). This report employed a BOD loading rate of two gallons
per day per square foot (2 gpd/sf) which is based on a loading rate equivalent
zs
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TABLE 6 - WETLAND ACREAGE REQUIREMENTS - QSA SATELLITE FACILITIES PROPOSAL
Wetland Area Phosphorus Wetland Area Phosphorus Wetland Area
Flow Required Load-CAS(l) Required Load-ANT(2) Required
( MGD) ( Acres) ( #/Day) ( Acres) ( #/Day) ( Acres )
Charles River
Average Daily Design Flow 20.0 230 2002.0 1335 167.0 ill
Peak Design Flow 50.0 574 5004.0 3336 417.0 278
Neponset River
Average Daily Design Flow 12.0 138 1200.0 800 101.0 67
Peak Design Flow 35.0 402 3502.0 2335 292.0 195
Weymouth Fore River
Average Daily Flow 3.0 34 3000.0 200 25.0 17
Peak Design Flow 10.0 115 1000.0 667 83.0 55
N
- Phosphorus loadings based on assumed effluent phosphorus concentration of 12.0 mg/i for typical
conventional activated sludge treatment facilities in New England.
- Phosphorus loadings based on assumed effluent phosphorus concentration of 1.0 mg/i from advanced
waste treatment facility.
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to a dual media filter and a phosphorus loading rate of 1.5 pounds per acre
per day... “based both on preliminary review of the literature (108) and the
desire not to hydraulically overload the wetland, resulting in adverse
effects to the ecological and hydrogeological environment.” Applying these
criteria to the proposed facilities assuming effluent BOD and phosphorus
loadings for both secondary (conventional activated sludge) and advanced
wastewater treatment processes yield the wetland acreage requirements presented
in Table 6.
In recognition of the proposed discharge locations relative to goundwater
recharge areas in or near existing public water supply well fields, the
Massachusetts DEQE, Divisions of Water Supply and Water Pollution Control,
were contacted to ascertain effluent limits and discharge requirements in
light of revised regulations promulgated by DEQE in late 1983. The response
from the Division of Water Pollution Control, dated December 29, 1983, which
is included in its entirety in Appendix C, included the following remarks:
“On October 15, 1983, the Division of Water Pollution Control
promulgated a set of comprehensive water pollution control regu-
lations (Title 314 of the Code of Massachusetts Regulations)
which included detailed groundwater quality standards. These
standards define groundwater into these classes (1, 2, and 3);
Class 1 being defined as:
“fresh ground waters found in the saturated zone of
unconsolidated deposits or consolidated rock and bed
rock and are designated as a source of potable water
supply.”
Since all three proposed discharges will be tributary to groundwater
currently being utilized as public water supplies (Class 1), all
discharges to said groundwater will be required to meet very strict
discharge limits; see Attachment 1 (in Appendix C.l).
The discharge limits would basically require that the effluent
entering onto the wetland meet or exceed the Primary and Secondary
Drinking Water Parameters; see Attachment 2 (in Appendix C.l). In
addition, the Division is concerned with the periodic “pass through”
of materials such as oil, heavy metals, solvents, phenols, and
other highly toxic or contaminating materials which are not sub-
stantially removed with conventional wastewater treatment processes
and which could cause severe impacts upon these aquifers.
to
continuously meet Class 1 effluent limitations and to protect these
valuable public water supplies cannot be provided. jTh
Division strongly discourages the continued review of such subregio
facilities as proposed by the Quincy Shore
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Similar conclusions and recommendations were stated in a memorandum
from the DEQE Division of Water Supply to the DWPC dated December 16, 1983,
including the following:
“Aside from the problems associated with determining the assimilative
capacity of wetlands for pollutants, this proposal does not address
other potential water quality problems. For instance, the proposal
does not address the fact that very little control exists over the
nature and quality of sewage. Presently, the regulatory manpower
does not exist for monitoring illegal or haphazard industrial waste
disposal. Many industrial contaminants cannot be detected, let alone
treated, in standard wastewater treatment facilities. As a result,
it is very likely th t discharges from the proposed “satellite”
plants would ultimately result in the degradation of existing water
quality in the receiving wetlands/aquifer. All things considered,
water quality degradation is likely to occur either over the short
term through problems associated with seasonal flooding/freezing of
the wetland and/or the undetected discharge of a hazardous substance
or over the long term by the gradual saturation of the assimilative
capacity of the wetland.
Because of these uncertainties and the problems that may ensue, the
DWS must conclude that the Citizens Plan proposal for wastewater
discharge into wetlands is an unacceptable risk for potentially
degrading these vital existing drinking water supplies.”
The complete text of the DWS memorandum is included in Appendix C.
Although the statements of the DWPC and DWS strongly suggest that the
facilities proposal by QSA not be implemented, a preliminary conceptual
facilities design was outlined for the purpose of providing a basis for cost
comparisons between the two satellite options. The conceptual design shown
on Figure incorporates advanced wastewater treatment operations including
primary settling phosphorus removal via chemical additions, conventional
activated sludge secondary treatment, nitrification-denitrification and
final settling advanced waste treatment processing. Treatment beyond AWT
levels theoretically leading to wastewater reclamation includes mixed media
filtration, carbon absorption, chlorination-dechlorination and post-aeration
prior to discharge. Grit, sludge and scum processing and disposal operations
are also shown on the schematic.
Cost for each facility were developed using costs per gallon oj waste-
water as derived from the updated cost estimates prepared for the MMA
satellites. Capital costs were escalated by 25 percent and O M costs were
escalated by 40 percent to account for the increased level of treatment
provided. These increases are not considered to include sludge processing
and disposal. Generalized costs for each of these facilities are summarized
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in Table 7. While it is recognized that the accuracy of these cost estimates
is open to question, it is felt that the estimates reasonably reflect the
level of treatment provided under the conditions stated above.
.(
2 I
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AVAILABLE
DIGITALLY
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TABLE 7 - COST SUMMARY - QSA WETLANDS DISPOSAL SATELLITE FACILITIES
Capital Cost Annual 0 M Total Annualized Cost
Facility Flow x 10 ) Cs x 10 ) ( 5 x 10 )
Charles River 50 MGD 115.8 11.14 23.04
Wetlands Satellite
Neponset River 35 MGD 81.1 7.80 16.14
Wetlands Satellite
Weymouth Fore River 10 MGD 30.6 2.65 5.80
Wetlands Satellite
1 Total Annual Costs based on 8 1/8 percent over 20 years (CRF = 0.1028).
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3. RELATIONSHIP OFSD-EIS SATELLITE OPTIONS WITh ON-GOING FACILITIES PLANNING
IN THE SOUThERN MSD
As a result of the decision to delete the EMMA recommended satellite
facilities from further consideration based on the conclusions of the draft
EIS, facilities planning was initiated for relief of critically surcharged
interceptors in the southern MSD including the following:
Wellesley Extension Sewer (WES)
Framingham Extension Sewer (FES)
New Neponset Valley Sewer (NNVS)
Braintree-Weymouth Extension Sewer (BWES)
In addition to the interceptor relief plans, a major infiltration/inflow
(I/I) analysis of the south MSD was conducted by Fay, Spofford and Thorndyke.
I/I studies were also prepared for the MDC in the communities of Ashland,
Natick, and Frainingham, and for the area tributary to the proposed Weylnouth
Fore River Siphon. An evaluation of the hydraulic capacity of the High Level
Sewer was conducted in conjunction with the Nut Island Site Options Study
which incorporated the I/I reports mentioned above in addition to revised
wastewater flow projections previously discussed.
Additional studies and reports which must be taken into account include
the preliminary report on I/I removal submitted to Professor Charles M. Haar,
Court-Appointed Master in the suit brought by the City of Quincy vs. the MDC
by the Executive Office of Environmental Affairs in response to Procedural
Order, Item No. 5, entitled “Banking/Trading and Greater Than 2 for 1 Program.”
An overview of MSD I/I is currently being conducted by Camp, Dresser and
McKee for the MDWPC.
Consideration of these reports in the evaluation of satellite facilities
is of considerable importance relative to the following issues:
• Implementation time framCrelative to on-going impacts of presently
surcharged sewers.
• Impacts of uncertainties in present I/I studies on flow projections,
design capacity evaluations for interceptors and treatment facilities
and the projected or assumed reduction in the required capacity of the
harbor treatment facilities.
Based on the current state of completion of Step 1 and Step 2 facilities
planning for the major interceptor relief projects (e.g., WES, FES, NNVS, and
BWES), it would appear reasonable to project that construction of recommended
-------
relief components can be completed within the next three to five years, con-
tingent upon available levels of State and Federal funding. It is estimated
that the time frame from Step 1 facilities planning to start up c& operation
for any of the satellite advanced waste treatment facilities proposed will
range from ten to twelve years. If the elimination of overflows of untreated
wastewater due to surcharging conditions and the water quality degradation
presumed to result from such overflows is to be considered a primary objective
of the wastewater management programs of MDC, DWPC, and EPA being evaluated
in this SD-EIS, then it would appear prudent at this time to recommend that
the relief projects proceed to construction regardless of a decision to
reject or to proceed with the proposed satellite facilities.
The issue of the relationship between projected reductions in the required
capacity of harbor treatment facilities as a result of satellite facilities
implementation and the effects of estimated and measured quantities of I/I on
the capacity of the sewerage and treatment facilites has not yet been resolved.
Several factors have contributed to the lack of consensus or understanding
surrounding this issue.
Both revised wastewater flow projections and the evaluation of the
capacity of the High Level Sewer (HLS) presented in the Nut Island Site Options
Study (SOS) state that the results of the I/I studies in the south MSD system
prepared for the MDC and community-specific evaluations were taken into account
in their development and analysis. Flow estimates project a peak flow of
305 MGD in the 2010 design year. Hydraulic evaluations of the HLS under previous
conditions conclude that the HLS can adequately handle up to 310 MGD. Flow
measurements taken by FST and reported in their I/I study included values up
to 420 MGD. The conditions under which the extreme of 420 MGD were measured
are not clearly defined. It is important to note that although the capacity
of the HLS is 310 MGD, the available pumping capacity at Nut Island is only
280 MGD. This constriction, in combination with extreme high tide conditions
(e.g., spring high tires), or othez factors such as extreme precipitation
and/or seasonal high groundwater could produce a “stacking” effect in the HLS
which may have introduced large errors in flow measurement in the system.
Further, the manner and extent to which the I/I data were incorporated into
the revised flow estimates developed in the SOS is not clear. As a result
-------
of a meeting held at DWPC, Metcalf Eddy has agreed to provide more detailed
explanation of the incorporation of the I/I report into the flow projections.
The issues raised point to the need for additional information including
systematic flow monitoring at several locations throughout the south MSD.
Also, it would appear necessary to remove the constriction imposed by the
pumping capacity at Nut Is land by increasing the pumping capacity to equal
the design hydraulic capacity of the HLS. This in turn suggests that the
peak design capacity of the treatment facility serving the south MSD should
also be equal to the capacity of the HLS as recommended in the SOS. Although
the implementation of satellite facilities would theoretically reduce flows
to the harbor facilities equal to the design flows of these satellite plants,
it does not appear to constitute a safe, reliable basis for re$ducing the
design capacity of the harbor treatment facilities by an equivalent amount.
This in turn suggests that the implementation of satellite facilities should
be delayed until it can clearly and reliably be demonstrated that flows in
the south MSD exceed the capacity of the HLS and treatment system and that these
excess flows cannot otherwise be economically removed from the system.
34
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C. EVALUATION OF SATELLITE OPTIONS
Both of the satellite options were evaluated with respect to the major
environmental issues and perceived benefits which have been identified for
both options. These include flow augmentation, water quality and water
supply recharge. Issues and impacts relative to siting of any of the
satellite facilities have not been addressed at this stage of the EIS
process as the satellite issue has not progressed beyond the level of a
conceptual component of the wastewater management program of the MDC.
1. EMMA Satellite Evaluation
(1) Flow Augmentation : A detailed analysis of water quantity
impacts of the EMMA satellite facilities was presented in Section 3.5.1 of
the Draft-EIS. The analysis concluded that the satellite facilities would
provide significant streamfiow augmentation to the water resources of both
the Charles and Neponset Rivers. However, the analysis also evaluated the
future low flow conditions of the Charles River without the additional
future flows of the proposed middle Charles satellite facility. This
analysis incorporated consideration of two major factors which had not
previously been considered with respect to flow augmentation which are the
net water quantity exported from the Charles River Basin to Boston Harbor
relative to the projected flow of the satellite plant and the impacts of
projected increases in flow volumes from existing wastewater treatment
facilities on streamflów during low flow periods. As reported in the draft
EIS, only 13.0 MGD of the projected design flow of the middle Charles
satellite plant originates within the Charles River Basin. The remainder
originates in the Sudbury River Watershed or is supplied to the contribut-
ing communities from the MDC water supply system originating in the Quabbin
Reser oir. The draft EIS analysis further indicates that the projected
increases in discharge volumes from existing wastewater treatment plants in
the Charles River Basin totalling approximately 12.7 MGD nearly equals the
net projected exported flow of 13.0 MGD, thereby offsetting the effect of
exporting that flow to Boston Harbor. Although we concur with the analyses
with respect to projected streamfiow conditions without the implementation
-------
of the Middle Charles Facility, it must still be recognized that the
addition of this satellite plant will result in substantially improved
streamflow conditions. Questions raised in the draft EIS with regard to
water quality conditions and potential impacts on downstream water supply
resources are discussed in subsequent sections of this report.
The draft EIS acknowledges the potential streamflow benefit of the
upper Neponset satellite facility on the Neponset River, but concludes that
significant negative water quality impacts offset any potential benefits to
streamflow and water supply resources. Based on our review of the water
quality assessment of the Neponset River, we concur with the conclusions of
the Draft EIS.
(ii) Water Quality : The assessment of water quality impacts of
the EMMA recommended satellite facilities on the Charles and Neponset
Rivers consists of a review and analysis of previous modeling conducted for
the 1978 Draft EIS and a review of water quality data collected during
intervening years for both rivers.
As previously described, an extensive water quality modeling effort
was undertaken by EPA( ) to assess the impacts of the Middle Charles
satellite facility discharge on the dissolved oxygen (D.0.) resources of
the Charles River under the prescribed 1Q10 flow conditions. A low flow
version of the MDWPC stream model was developed and calibrated using data
generated by the MDWPC from surveys conducted in 1973 by Erdmann et al.
The low flow model was then used to evaluate the dissolved oxygen response
of the river to the projected waste flows and loads from the Middle Charles
satellite and other wastewater treatment facilities projected to be
discharging to the Charles River in the design year 2000. The effects of
the discharge from the satellite facility were also examined with the
discharge occurring at different locations in the Middle Charles. The
conclusions drawn from these modeling analyses were presented in Section
A.3 of this report. In general, although the modeling indicates that the
Class B water quality criteria for dissolved oxygen of 5.0 mg/l may be
violated over some river segments, overall dissolved oxygen conditions would
-------
be improved at specific critical locations under certain specified
conditions as a result of the discharge of a satellite facility as
compared to projected conditions without the satellite facility.
The facility would be required to provide advanced levels of waste
treatment bordering on the limits of reliable technology. While it
can be argued that the proposed satellite facility will not result
in attainment of Class B, D.O. levels at projected low flow con-
ditions, the analysis suggests that the proposed facility could
represent a potential benefit to the Charles River as D.O. levels
were observed to increase under certain conditions with the addi-
tion of the satellite facility as opposed to without it, and as
the modeling suggests that non-attainment conditions are beyond the
ability of point source treatment measures alone to achieve. The
analysis provides limited evaluation of the issue of other residual
pollutants from a satellite effluent discharge.
The concerns raised by Metcalf and Eddy and MDC in the correspondence
found in Appendix A and the responses of EPA staff to these concerns were
reviewed with respect to model formulation, coefficient selection-
computation, use of data within the model framework, and the limits within
which the available information was employed within the Stream model to
project impacts of conditions for which no data is/was available. Model
formulations were reviewed with respect to the model description contained
in the “STREAM 7A USER’S MANUAL”, prepared for the MDWPC in 1978 by
Resource Analysis, Inc. No major changes in model formulations were found
between the version of the Stream model employed by Erdmann and Ikalainen
and those described in the 1978 User’s Manual. Based on our review of the
work that was done by EPA and reported in the Draft EIS, we conclude that
the modeling reasonably and adequately reflects proper utilization of the
available data within the model framework and within the range of
sensitivity and variability tested.
Other issues were raised in the text of the Draft EIS which played a
substantial role in reaching the conclusion stated on page 3-155 that:
“The implementation of a satellite plant discharging to the Charles River
is not recommended.” These issues relate to the ability of the unit
treatment processes envisioned to provide the advanced levels of treatment
required to result in improved D.O. conditions reliably and consistently
given the variability of influent flow and pollutant loading conditions and
the limited degree of control obtainable over these conditions. These are
31
-------
still valid concerns, although there presently exists a significantly
increased amount of experience in the operation of advanced waste treatment
facilities than was available in 1978.
Another issue with respect to the water quality modeling raised by
both EPA and MDC/M&E concerned the parameters and in—stream processes not
accounted for in the Stream Model. Phosphorus is a particular parameter of
concerning this regard due to its potential impact on algae and aquatic
weed production, which in turn would be expected to impact on the magnitude
and severity of D.0. variablity. A satellite facility even providing
phosphorus removal to maintain effluent phosphorus concentrations on the
order of 1.0 mg/i represents a significant increase in phosphorus loading
from point sources in the Charles River. Incorporating these concerns with
the considerations offered by the water quality modeling (i.e., that under
certain conditions, some degree of benefit may be derived), leads us to
conclude that a satellite treatment facility discharging to the Middle
Charles River will be of limited, if any, benefit to water quality in the
Charles River. Based on available data, however, it is not expected that
such a discharge will, in or of itself, contribute noticeably to
degradation of water quality conditions beyond present conditions.
A sumary of water quality data from DWPC surveys in 1973 and 1978 is
presented in Table 7. Partial surveys of the Upper Charles (above the
South Natick Dam) were also conducted in 1980 and 1981. The more recent
surveys (1980 and 1981) reflect major upgrading of municipal treatment
facilities, including the construction of the Charles River Pollution
Control District AWl Facility serving the Franklin—Medway area and the
Millis—Medfield facilities. Average DO levels for all but one survey
period from all survey years are shown in Figure 2. Note the consistent
improvement in DO recovery downstream of River Mile (RM) 60 with successive
years of operation of recently—constructed facilities. Note also the
generally unchanged conditions upstream of RM 60 reflecting the continuing
problems observed in the Milford area with respect to the municipal sewer
and treatment systems in addition to int sources in the head water
areas of the river. Comparisons between the six survey periods (June’73;
-------
TAsAc7 7.
CHARLES RIVER WATER QUALITY SURVEY DATA SUMMARY - 1973/1978
Dissolved
Oxygen (mg/i)
SOD
(mg i)
NH -N
(m /l)
NO -Il
( g/l)
6/73 9/73 6/78 7/78 6/73 9/73 6/78
7/78 6/73 9/73
6/78 7/78 6/73 9/73 6/78 7/78 6/73
9/73 6/78 7/78
FLOW SUMMARIES DURING SURVEY PERIODS (FLOWS IN CPS)
Gauge Station
USGS Gauge. Dover
USGS Gauge, Wellesley
USGS Gauge. Waltham
6/73 9/73 6/78
Temperature
(°F)
CHO1
8.3
7.5
7.4
7.1
71.3
77.0
64
77
1.7
3.6
5.1
1.9
0.07
0.04
0.01
0.04
0.2
0.5
0.2
0.1
CHO2
3.9
4.7
8.0
7.9
74.2
78.0
67
77
3.1
1.6
4.9
3.1
0.29
0.09
0.02
0.04.
0.1
0.0
0.1
0.0
CHQ3
4.4
4.2
6.1
4.9
70.8
75.0
64
73
6.3
2.7
4.8
2.4
0.20
0.32
0.03
0.10
0.3
0.3
0.4
0.3
CHO4
3.9
1.1
4.6
1.2
70.7
75.0
63
73
21.6
12.3
7.9
5.4
3.85
4.45
3.6
4.9
2.1
2.4
1.6
2.1
CHO5
1.8
1.4
3.0
0.9
71.0
76.0
63
73
4.8
7.8
5.4
4.6
3.45
6.2
3.6
4.3
1.4
2.0
1.4
0.6
CHO6
11.5
4.5
8.7
5.3
74.7
80.0
68
78
9.5
4.9
6.4
29.5
2.85
1.01
1.6
5.6
1.0
1.4
0.8
0.6
CHO7
3.3
1.9
5.3
2.6
70.8
76.0
66
75
5.0
4.9
5.1
6.6
2.00
0.92
0.88
0.89
1.1
0.7
1.4
1.2
CHO7B
-——
———
7.5
5.2
-—-
---
66
78
---
——-
3.1
3.3
---
---
0.04
0.19
---
———
1.1
0.5
CHO7C
—--
——-
7.2
5.8
---
---
65
74
---
-——
1.9
2.5
---
---
0.02
0.10
---
——-
1.1
0.6
CHOB
6.7
5.5
7.4
6.3
71.1
77.0
64
75
2.6
1.8
2.7
1.6
0.13
0.13
0.04
0.08
0.4
0.7
0.8
0.5
CHO8A
7.3
5.5
6.7
6.0
71.9
77.0
64
79
4.4
2.4
2.5
2.4
0.13
0.36
0.10
0.38
0.6
0.4
0.7
0.8
CHO9
6.0
4.3
7.2
5.6
71.6
77.0
64
74
3.4
3.2
2.4
1.6
0.52
0.58
0.11
0.34
0.7
1.1
0.8
0.8
d uO
7.3
6.7
8.0
6.7
71.8
77.0
64
76
5.3
3.4
2.4
2.0
0.18
0.10
0.06
0.17
1.1
1.2
0.8
1.0
Cliii
7.0
7.4
7.2
10.7
73.7
79.0
65
70
4.0
3.6
5.0
3.6
0.07
0.25
0.03
0.01
0.8
0.5
0.6
0.0
CH I2
6.4
5.1
7.1
9.0
71.0
74.0
65
75
2.6
2.1
4.3
4.5
0.06
0.20
0.02
0.00
0.7
0.5
0.6
0.0
CH13
6.1
4.8
5.3
8.4
71.3
74.0
66
76
2.3
2.8
2.2
6.3
0.09
0.17
0.02
0.01
0.6
0.5
0.5
0.0
CH14
4.9
4.4
4.9
5.9
71.8
74.0
66
77
2.3
2.4
2.7
5.1
0.14
0.27
0.03
0.05
0.6
0.4
0.5
0.1
CH15
5.1
4.7
5.0
7.9
72.1
76.0
66
77
3.3
6.5
2.4
6.3
0.14
0.24
0.04
0.01
0.5
0.3
0.5
0.0
CH16
CH I7
6.2
7.0
5.7
5.9
5.4
6.5
8.1
7.6
72.4
72.7
76.0
76.0
67
68
77
74
4.1
5.4
6.0
4.6
2.5
2.4
5.5
4.0
0.07
0.06
0.16
0.14
0.04
0.02
0.01
0.05
0.5
0.5
0.3
0.1
0.6
0.4
0.0
0.0
CH17A
---
---
6.4
7.1
---
---
67
78
---
—--
2.1
4.0
---
---
0:03
0.08
---
---
0.4
0.0
CH18 ...
CH19
7.2
6.9
7.0
7.0
7.4
6.9
6.6
7.3
72.4
72.6
76.0
76.0
67
67
77
77
4.1
4.2
4.6
6.0
2.7
Q.7
4.5
3.9
0.09
0.07
0.12
0.06
0.02
0.02
0.12
0.12
0.4
0.4
0.1
0.0
0.4
0.4
0.1
0.0
CH2O
7.3
8.4
8.4
12.3
72.8
76.0
68
80
4.8
6.3
3.1
6.6
0.25
0.05
0.05
0.59
0.4
0.0
0.4
0.1
CH21
CH22
6.9
7.4
7.8
6.8
8.3
8.3
11.2
7.8
72.2
72.6
76.0
75.0
68
67
79
78
6.6
4.4
8.0
7.1
3.9
4.0
7.2 .
6.1
0.25
0.28
0.05
0.07
0.02
0.04
0.30
0.38
0.4
0.4
0.0
0.1
0.4
0.4
0.1
0.2
CH22A
---
---
8.2
8.0
---
---
67
77
---
—--
3.9
6.3
---
---
0.02
0.34
---
---
0.4
0.2
CH23
7.1
7.8
8.3
10.2
73.5
76.0
67
79
5.9
7.2
4.0
7.0
0.24
0.06
0.01
0.09
0.4
0.0
0.3
0.2
CH24
7.4
6.6
7.8
8.0
72.1
74.0
67
73
4.1
5.1
3.7
5.8
0.27
0.08
0.01
0.08
0.4
0.1
0.3
0.3
7/78
149.2
105.2
199.8
73.3
134.0
111.2
198.2
79.4
170.8
141.6
257.4
98.6
-------
CHARLES RIVER WATER QUALITY SURVEY DATA SUMMARY — 1973/1978
Suspended Solids
(mg/I)
6/73 9/73 6/78 7/78
Total Solids
(mg/i)
6/73 9/73 6/78
Turbidity
(NTU)
7/78 6/73 9/73 6/78 7/79
Total Kjeldahl Nitrogen
(mg/l)
Total Phosphorus
(mg/i)
6/73 9/73 6/78 7/78 6/73 9/73 6/78 7/78
CR01
---
---
0.29
0.97
0.03
0.02
0.04
0.73
1.0
18
5.5
1.0
---
--f.
125
68
---
--- 1.3
1.3
CR02
---
---
0.34
1.2
0.06
0.04
0.05
1.0
1.0
19
1.8
1.0
---
---
116
137
---
--- 2.0
1.9
CR03
---
---
0.72
1.4
0.17
0.21
0.09
1.6
5
34
5.0
6.0
-——
---
179
183
-—-
—-- 2.3
3.9
CR04
-—-
---
4.3
5.8
3.55
4.60
2.1
4.3
4
22
16
1.5
—-—
---
241
256
-—-
——- 3.0
3.9
CR05
---
--—
4.3
4.4
3.10
4.00
1.3
4.2
1.0
37
5.8
5.2
-——
---
271
220
---
—-- 2.9
3.6
CR06
---
---
2.7
6.6
2.90
3.15
0.92
4.2
5
25
12
51
--—
---
216
305
---
——- 2.5
5.7
CR07
---
---
1.8
2.9
1.75
1.85
0.84
2.2
3
27
6.0
17
--—
---
190
202
---
--- 2.6
4.3
CR078
---
---
1.4
1.2
--—
—--
0.60
1.5
---
---
7.0
6.2
—-—
---
169
186
---
——- 2.4
3.5
CHO7C
---
---
0.72
1.4
--—
—--
0.57
1.2
- --
-—-
6.0
4.2
-——
---
169
262
---
—-- 1.7
3.6
CR08
---
---
0.84
1.5
0.75
0.90
0.47
1.0
1.0
19
5.2
0.5
---
---
170
157
---
—-- 2.0
3.1
CH O8A
---
---
0.45
1.6
0.48
0.35
0.59
1.0
6
32
6.0
2.2
---
---
165
172
---
—-- 2.4
3.1
CR09
---
---
0.89
1.4
0.93
0.93
0.68
1.0
1.0
17
4.5
2.5
---
---
170
170
---
--- 2.4
2.7
CR10
---
---
0.84
1.1
0.85
0.95
0.54
0.94
4
31
8.2
3.2
-——
---
174
179
---
——- 2.3
2.4
CHit
—--
---
0.72
1.6
0.88
0.63
0.40
0.44
5
22
10
28
———
--—
149
129
---
——- 2.1
5.0
CR12
---
---
0.35
1.2
0.58
0.38
0.37
0.38
1.0
20
10
6.0
--—
---
274
113
---
—-- 2.0
5.1
CH 13
——-
--—
0.38
1.2
0.44
0.33
0.39
0.40
8
26
12
11
—-—
---
145
129
-—-
——-
1.4
4.7
CR14
—--
---
098
1.5
0.45
0.35
0.34
0.44
6
33
10
18
—-—
---
177
130
---
——-
1.9
4.9
CH15
-—-
---
0.88
1.4
0.45
0.35
0.34
0.41
3
25
8.2
7.5
--—
---
162
133
---
—-—
1.5
5.3
CR16
——-
---
0.88
1.3
0.50
0.32
0.30
0.35
4
29
8.5
12
--—
---
160
171
-——
——- 1.4
3.5
CHJ7
-—-
---
0.85
1.2
0.37
0.24
0.16
0.27
3
30
8.5
21
--—
---
141
150
—-—
——— 1.3
2.7
CH17A
---
-—-
0.88
1.2
---
---
0.18
0.26
---
-—-
6.2
8.7
--—
-—-
140
146
---
——— 1.4
2.7
CR18
——-
---
0.83
1.3
0.36
0.23
0.21
0.29
4
27
6.7
8.2
--—
---
189
152
—--
——— 1.5
2.2
CH19
——-
---
0.91
1.4
0.36
0.20
0.17
0.28
5
36
8.5
16
--—
---
137
152
---
——- 1.2
3.1
CH2O
——-
---
1.1
2.0
0.39
0.16
0.17
0.25
5
40
18
14
--—
---
153
156
---
——— 1.4
6.1
CR21
—--
---
1.0
2.0
0.33
0.18
0.17
0.22
4
42
11
17
--—
--—
142
157
—--
——- 1.6
6.7
CR22
—--
---
0.95
1.9
0.28
0.17
0.16
1.2
3
31
20
22
—-—
---
171
184
---
——— 1.5
5.3
CR22A
——-
---
0.90
2.3
---
--—
0.16
0.24
—--
---
18
26
---
---
156
180
-—-
——— 1.5
5.5
CR23
---
---
0.88
2.4
0.26
0.16
0.20
0.20
7
28
16
14
---
---
160
169
---
--- 1.6
12
CR24
——-
—--
0.89
2.0
0.27
0.16
0.24
0.18
6
25
14
14
--—
---
176
168
—--
——- 1.8
9.3
-------
CHARLES RIVER WATER QUALITY SURVEY DATA SWQ1ARY - 1973/1978 (Cont’d)
pH
(mg/i)
Total Alkalinity
(Std. Units)
Total Coliform
(#/lOOmi)(Geo. Mean)
• Fecal Coliform
(#100/ml )(Geo.Mean)
CHO1
6/73
5.8
9/73
7.0
6/78
6.9
7/78
6.3
6/73
9/73
29
6/78
‘11
7/78
9
6/73
740
9/73
19800
6/78
550
7/78
i50
6/73
---
9/73
---
6/78
17
7/78
5
CHO2
6.9
6.9
7.4
7.4
19
31
20
29
630
29900
220
80
---
- - -
7
7
CHO3
6.9
6.5
7.3
7.2
23
37
31
38
23000
52300
12000
12000
—-—
--—
650
390
CHO4
CHO5
6.9
6.8
6.6
7.0
7.3
7.3
7.1
7.2
37
37
53
71
57
30
68
67
32000
16000
134000
56100
34000
9000
54000
1200
--—
---
---
---
3900
1100
6200
54
CHO6
7.4
7.0
7.5
7.1
37
45
38
58
630
13400
370
280
---
---
16
5
CHO7
7.1
6.8
7.3
7.4
31
35
30
40
350
30000
2000
3300
—--
-- -
150
240
CH078
CHO7C
---
—--
---
---
7.3
7.3
7.3
7.6
---
---
---
---
23
22
36
37
---
---
---
---
610
1100
1600
320
---
---
---
---
110
160
14
24
CHO8
7.1
7.0
7.2
7.4
19
30
19
32
2000
34600
1200
3400
---
---
300
550
CHO8B
7.2
7.5
7.2
7.3
16
28
20
33
490
8500
730
1200
---
---
130
150
CHO9
7.1
6.9
7.2
7.4
21
30
20
29
3000
40000
1600
1300
---
---
270
53
CH IO
7.2
7.2
7.2
7.5
21
26
19
27
22000
29200
1400
1800
-—-
-—-
380
240
CH11
7.2
7.3
7.1
8.4
18
27
19
25
1600
2400
1200
280
---
---
100
24
CH I2
7.2
7.3
7.2
7.9
17
24
18
26
1700
25900
2400
420
---
---
290
100
CH13
7.1
7.1
7.0
7.1
17
23
21
33
22000
16700
650
320
---
--—
89
23
CH I4
7.1
7.0
7.6
7.4
18
26
21
• 28
39000
52500
6920
84000
—--
---
140
89
CH15
7.1
7.3
7.6
7.7
18
28
22
28
35000
77500
4700
7600
---
---
56
28
CH I6
6.9
7.1
7.5
7.4
18
25
21
28
26000
13300
1900
740
---
- --
75
14
CH17
7.1
7.0
7.6
7.5
18
27
24
28
3300
34500
650 •
170
---
-—-
51
20
CH17A
—--
---
7.7
7.3
---
--—
22
27
—-—
---
200
710
---
---
20
20
CH18
7.1
7.3
7.6
7.4
19
27
23
28
2000
23100
720
710
---
---
63
34
CH19
7.2
7.1
7.6
7.4
18
27
20
27
850
28800
690
600
---
---
55
56
CH2O
7.1
7.4
7.5
—-—
21
29
23
35
1800
22000
940
240
---
-—-
130
60
CH21
7.2
7.6
7.7
8.7
22
29
24
33
5800
140000
1900
260
---
--—
180
74
CH22
7.3
7.6
7.5
7.7
21
31
25
31
1700
40600
8800
3700
---
-——
220
1000
CH22A
—--
---
7.5
7.7
---
---
24
31
---
---
2200
4600
---
--—
400
460
CH23
7.4
7.3
7.4
7.7
24
32
22
31
5200
34600
1400
4800
---
-——
80
400
CH24
7.3
7.0
7.5
7.6
25
32
23
32
20000
48600
9500
990
---
-——
240
320
-------
CHARLES RIVER
AVERAGE DISSOLVED OXYGEN
MINE BK—
HOPPING BK..— 1
fMILFORD SIP
MILL BK
NOT
HER BK
. DIVERSION
rUWMILL BK.
SUGAR BK —
r— )GASTOW
BK.
r MEADOW BK.
1 —bIICKEN BK
r—MEDFIELD
STATE
HOSP
rST0NY
BK.
MILL STOP
RIVER—I, RiVER— 1
rWA BAN BR.
reEAVER
1 D é M
aWPC. SURVEYS- 1973,1978,1980, & 1981
z
w
0
0
(I)
U)
0
RIVER MILES
BK.
-------
Sept. ‘73; June ‘78; July ‘78; July ‘80 and June ‘81) on a parametric basis
are of limited value based on reported differences in stream flow
conditions, water and air temperatures, rainfall and other climatic factors
prior to and during each survey period. Generally, although average and
minimum DO values have increased over the period covered by the data
record, violations of the Class B criteria still occur. Violations of the
Class B bacterial criteria of 200 colonies/100 ml continue to occur.
Although the fecal coliform data for the June, 1981 survey period show a
significant improvement over the portion of the river surveyed, the limited
scope of the survey precludes assessment of improvement in downstream
reaches. Nutrient loadings, particularly phosphorus, are of potential
concern based on a review of chlorophyll—a data at stations comon to all
surveys as presented below:
./J
y CHLOROPHYLL-a (mg/rn 3 )
,) iver 1973 1980 1981
() Mile Sta. Concentration Sta. Concentration Sta. Concentration
___ — ___________ — ___________ — ___________
J
76.5 CHO1 2.5 CHO1 0.81
72.0 CHO5 7.9 CHO5 3.32 CHO3 3.74
6O.1 CH1O 5.0 CH14 1.66 CHO9 1.08
44...6 CHI5_—__. 1L.8_. CH19 27.07 CH14 50.76
33.0 CH18 29.2
22.1 CH2O 92.2
18.3 CH22 90.0
9.8 CH24 60.8
Note: Chlor.—a data was not reported for the 1978 survey periods.
Substantial increases are observed over the sampling periods covered at the
sampling stations identified at RM 44.6. As chlorophi1l—a is indicative of
the productivity occurring in a water body in response to available
nutrient supplies, additional sampling over a wider area of stream coverage
appears waryanted. As indicated in earlier discussions, the potential
impacts of •increased nutrient loads from a satellite facility can be
expected tobe reflected in increased productivity and chlorophyll-a
levels. An area which has not been addressed with respect to a satellite
facility is that of possible instream mitigation measures to reduce or
-------
offset the potential impacts of the discharge, such as instream aeration,
use of artificial wetlands for nutrient removal (and subsequent
harvesting), or other alternative measures.
/> ¶ The impacts of a satellite facility discharge to the Neponset River
evaluated using a Streeter—Phelps analysis. The conclusions of this
analysis were presented in Section A.3 of this report. Based on our review
of the modeling discussion contained in the Draft EIS and Appendix 3.2.3—2,
we concur with the conclusion that a satellite discharge would negatively
impact the dissolved oxygen resources of the river. Again, although
in—stream mitigation measures were not considered in the evaluation, the
projected impacts are sufficiently severe on the Neponset River that any
such measures may not be capable of providing a reliable degree of
improvement.
Water quality data for surveys conducted in 1973 and 1978 by the MDWPC
are summarized in Table 8. Summaries of flow data during each survey
period are also shown on Table 8, together with the 1Q10 low flows for each
gauging station. As shown, the August, 1978 survey period flows are very
close to the 7Q10 flows. Although DO levels generally appear to increase
(both average and minimum values reported), periodic violations of the
Class B criteria still occur. Much of the river is also in violation of
the fecal coliform criteria, based on data reported in the 1978 survey.
(Fecal coliform were not enumerated in the 1973 survey.) The imposition of
a satellite facility to the upper Neponset River may be expected to reverse
any trends toward the gradual improvement of water quality conditions in
the river as are suggested to be occurring based on the available data.
(iii) Water Supply : Potential impacts of the satellite
facilities on water supply wells hydraulically connected to the main stem
rivers downstream of the proposed discharges were identified as major
concerns in the Draft ELS. The principal concerns relate to pollutants not
removed by the treatment processes, and the inability to control influent
quality to the treatment facilities. Under low stream flow conditions,
when discharge volumes would comprise a significant proportion of total
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‘3 o’ 6 NEPONSET RIVER WATER QUALITY SURVEY DATA SUI’V4ARY - 1973/1978
Dissolved Temperature DOD 1*1 -N NO —N Total Phosphorus
Oxygen (mg/i) (°F) (mg/i) (m /l) (in /l) (mg/i)
7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78
NEO1 8.9 5.4 7.5 79.5 76.2 2 6.15 4.20 4.0 0.00 0.270 0.02 0.00 0.00 0.0 0.085 0.125 0.10
NEO2 7.7 3.5 6.8 79.0 72.7 71 4.50 2.95 6.3 0.015 0.400 0.08 0.35 0.20 0.1 0.280 0.335 0.14
NEO3 7.4 6.1 7.0 76.8 71.9 71 3.70 4.05 5.0 0.020 0.265 0.09 0.40 0.40 0.2 0.170 0.205 0.12
NEO4 4.9 3.0 5.1 75.2 71.0 69 2.40 2.10 3.0 0.040 0.190 0.05 0.25 0.15 0.2 0.185 0.160 0.09
NEO5 6.7 6.5 7.8 74.8 71.8 69 3.20 2.60 5.0 0.030 0.150 0.01 0.30 0.30 0.2 0.165 0.135 0.08
NEO6 3.8 3.9 7.8 75.5 71.7 69 2.80 6.20 3.2 0.065 0.080 0.01 0.20 0.20 0.2 0.130 0.170 0.10
NEO7 4.8 4.5 6.7 82.5 78.0 77 3.50 1.80 3.3 0.085 0.190 0.02 0.25 0.30 0.1 0.100 0.105 0.06
NE08 6.7 6.8 8.1 79.8 76.6 74 3.20 2.50 3.8 0.040 0.200 0.03 0.25 0.25 0.1 0.105 0.100 0.05
NEO9 7.8 7.8 8.0 76.0 72.8 71 1.70 1.70 2.8 0.065 0.110 0.01 0.45 0.35 0.1 0.090 0.040 0.10
NEW 6.7 6.9 7.4 77.7 74.7 71 2.50 1.30 4.5 0.025 0.115 0.01 0.35 0.35 0.2 0.100 0.095 0.05
NEIl 5.6 5.7 6.5 76.2 73.1 70 2.00 2.20 2.7 0.090 0.175 0.07 0.35 0.65 0.4 0.105 0.085 0.06
NEI2 6.9 6.8 6.5 76.3 73.4 72 1.90 1.80 3.9 0.030 0.145 0.06 0.35 1.15 0.6 0.055 0.055 0.06
NE I3 5.0 5.2 5.8 75.6 72.6 70 3.00 1.80 2.8 0.080 0.110 0.06 0.35 0.45 0.2 0.095 0.090 0.05
NE14 5.6 5.6 6.7 77.0 73.2 70 3.15 2.50 2.4 0.135 0.175 0.08 0.45 0.35 0.2 0.170 0.135 0.06
NE15 6.5 6.6 6.9 76.5 73.3 70 3.45 2.00 3.2 0.120 0.120 0.19 0.45 0.45 0.4 0.180 0.085 0.12
NE I6 5.7 5.6 7.8 76.3 72.2 70 2.10 1.70 2.8 0.100 0.140 0.10 0.45 0.45 0.2 0.170 0.085 0.09
NEll 5.3 6.0 5.2 68.3 68.4 69 1.45 1.40 3.2 0.370 0.340 0.28 0.05 0.05 0.0 0.130 0.080 0.22
FLOW SUMMARIES DURING SURVEY PERIODS
Average Flow (CPS) Average Flow
7/73 8/73 8/78 Gage Record 7Q10
fleponset River USGS Gauge at Non ood 36.0 46.8 11.08 51.8 4.9
East Branch USGS Gauge at Canton 45.8 47.8 12.08 50.6 3.4
-------
rIEPONSET RIVER WATER QUALITY SURVEY DATA SUI 1ARY - 1973/1978 (Cont’d)
Total Alkalinity p H Total Coliform
(mg/i) (Std. Units) (#/lOOmi)(Geo. Mean)
7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78 7/73 8/73 8/78
riLul 19.0 4.0 24 7.4 7.0 7.0 300 300 500
NE02 22.0 25.0 24 7.5 6.6 7.0 3000 2500 5000
NEO3 24.5 24.5 26 7.4 6.6 7.1 21000 26000 16000
NEO4 24.5 23.5 26 7.4 6.3 7.1 6500 5300 2400
PIEO5 23.0 23.5 26 7.4 6.6 7.1 24000 5000 6000
NEO6 21.0 25.5 28 7.5 6.8 7.2 34000 5000 15000
NEO7 21.0 28.0 29 7.3 6.9 7.3 11000 3500 3000
NEO8 21.0 27.0 30 7.4 6.6 7.2 9000 1900 1400
NEO9 20.5 22.5 23 7.4 6.8 7.3 35000 13000 4800
NElO 22.0 27.5 27 7.3 6.9 7.2 23000 11000 27000
NEll 23.5 29.0 30 7.4 6.7 7.3 12000 1000 9700
NE12 22.0 23.0 30 7.4 6.8 7.2 3700 15000 6000
NE13 22.5 24.5 30 7.6 6.6 7.2 7700 81000 1700
NE I4 24.5 26.0 30 7.6 6.6 7.2 29000 79000 21000
NE15 22.5 24.5 33 7.6 6.5 7.3 33000 62000 84000
NE16 23.5 25.0 33 7.5 6.8 7.3 12000 25000 50000
NE17 70.0 85.0 92 8.0 7.3 7.4 34000 12000 38000
-------
stream flow, it is possible that wells located near the mainstem of both
rivers could result in drawing surface water in the river channels into the
groundwater regime of the wells, resulting in potential health impacts to
the populations served by those wells. While the concern for potential
public health impacts is certainly a valid one, the assessment of risk
associated with the proposed satellite facilities is difficult, given the
long history of discharges of both treated and untreated wastewaters to
both the Charles and Neponset Rivers. Given that there are no existing
wastewater treatment facilities discharging to the Neponset River, it can
reasonably be argued that the satellite facility proposed represents an
unacceptable risk with respect to the protection of water supply resources.
Given both the existing and projected wastewater flows from existing
treatment facilities discharging to the Charles River, it cannot be clearly
established that the discharge from the proposed satellite facility would
represent an increase in the degree of risk of public health impacts, in
addition to the risk that must be associated with existing facilities.
Detailed hydrogeological investigations would be required to develop a
reliable basis for defining the incremental risk associated with a
satellite facility on the Charles River.
2. Wetlands Disposal Option
An initial step in the evaluation of the QSA-Wetlands Disposal
Satellite Option involved the determination of available wetlands within
reasonable close proximity to the proposed sites for the three satellite
facilities included in the proposal. Wetland maps for the Weymouth,
Charles and Neponset River Basins prepared in 1976 by the Metropolitan Area
Planning Council (MAPC) 208 water quality project were used to determine
the acreage of inland wetlands located within 1000 feet radius and within a
1 mile radius of the proposed location of each facility. Table 9
sumarizes the estimated wetland acreage available within these two zones
and compares the “available” wetland acreage with the previous estimate of
wetland acreage required for each discharge as presented in Table 6. The
estimated wetland acreage required is based on the phosphorus and BOD
loading criteria as previously described. As can be seen, the extent of
-------
TABLE 9
PRELIMINARY ESTIMATE OF WETLAND AVAILABILITY
FOR WETLANDS DISPOSAL FACILITIES
Treatment Wetland Acreage 1 Inland Wetland Area Inland Wetland Area
Facility Required Within 1000’ (Acres) Within 1 mile (Acres )
P BOD
Charles River 278 574 232.5 593.9
Neponset River 195 402 116.9 269.3
Weymou th
Fore River 55 115 69.2 189.5
1 Based on phosphorus and BOD loading criteria as per Table 6.
-------
“available” wetlands is dependent upon the selection of loading criteria
used in the cases of the Charles and Weymouth Fore Rivers. The Neponset
River does not appear to have a sufficient amount of available wetlands
within 1000—foot radius to satisfy either criteria. The available wetlands
within 6 miles of the Nepo js_etiacility would satisfy only. the phosphorus - -
li Ing criteria . It is important to recognize that this estimate of
“available” wetlands is based on available mapped information only and has
not been confirmed by any level of field investigation of the wetlands
identified. The estimate has not considered the ownership or other aspect
of allowable or restricted uses which may affect the actual availability of
a particular area. Finally, the costs which might reasonably be associated
with an effluent pumping and distribution system which might be required
under any of the treatment plant—wetland disposal area combinations possible.
I L
Based on the responses of the DEQE-DWPC and DWS to the subject
proposal, which are presented in Appendix C and which reflect preliminary
assessments of the proposal conducted by Maguire staff, additional
evaluations were not conducted. The major areas of concern with regard to
impacts are sumarized below.
The development of the proposed satellite facilities present an
unacceptable risk to public health and important water supply sources in
the metropolitan region. As in the discussion of risk associated with the
EMMA satellite facilities, the risks associated with placing a wastewater
treatment plant discharge in intimate contact with existing clean sources
of public water supply are unacceptable.
Actual versus estimated wetland areas available and limits posed by
the selection of loading criteria suggest that the scale of the wastewater
facilities proposed is excessive for the safe application of wetlands
disposal technology. Also, the use of wetlands for effluent disposal on a
year—round basis could preclude the flow regulating function of natural
wetlands which is an important aspect of flood storage hydrology in an
urban area. This aspect may negate any potential benefits with respect to
groundwater recharge.
11
-------
As pointed out by the DWPC and DWS, the renovation aspect of wetlands
disposal is one of uptake and release. Experience with small—scale
wetlands disposal projects relative to this aspect of facility operation
and maintenance has led to the more prevalent practice of artificial
wetland systems which can periodically be renovated by harvesting or
dredging accumulated vegetation and decaying organic matter.
D. CONCLUSIONS
Based on the preceding evaluations, the following conclusions can be
stated regarding satellite facilities in the South MSD:
EMMA Recommended Satellite Facilities
1. Based on structural and hydrological analysis of the High Level
Sewer (HIS) and revisions to wastewater flow projections (as reported in
the Nut Island Site Options Study) , the HLS was found to be of adequate
capacity and condition to accommodate flows up to 310 MGD without any
relief requirement. Based on available I/I data, the HLS could see
occasional peak flows higher than 310 MGD which have been estimated to
reach up to 420 MGD. The development of the two proposed satellite AWT
facilities to remove approximately 59 MGD from the south MSD system would
not in and of themselves reduce these flows sufficiently to a level whereby
harbor treatment facilities would be reduced in size.
2. Following the completion of necessary upstream interceptor relief
projects, removal of limiting hydraulic factors in terms of pumping
capacity at Nut Island, implementation of a flow monitoring program in the
southern MSD, and a more realistic assessment of I/I reduction
( alternatives, the development of satellite treatment facilities in the
south system versus other flow reduction/management options should be
reevaluated as a priority in determing a cost effective and equitable
solution to future system expansion needs.
-------
3. Based current updated facility plans of the MDC and their
implementation time frame, it is our view that major interceptor relief
projects currently proposed downstream of the sites investigated for AWT
facilities would still be required to alleviate overflows and other
surcharging conditions created by constrictions and other structural or
hydraulic problems presently in the system, irrespective of a decision
regarding satellite facilities.
4. The discharge of the AWl facility effluent to the Neponset River
will have an adverse impact on water quality, particularly upon the dis-
solved oxygen resources of the river. Additionally, during periods of low
stream flow, potential public health/water supply impacts pose significant
problems to public water supplies based on stream flow-groundwater relation-
ships under low flow conditions and groundwater pumping close to the river.
Potential public health/water supply impacts outweigh any potential benefit
in terms of low—flow augmentation of the Neponset River. A satellite
facility on the Neponset River is not recommended for further consideration.
5. The discharge of an AWl facility effluent to the Charles River
may have a beneficial impact on the dissolved oxygen resources of the river
even though water quality standards might be violated during certain
periods. Increased phosphorus loads may exacerbate nuisance algae
conditions in downstream reaches of the river. During periods of low
stream flow)potential public health/water supply impacts may pose
significant problems to public water supplies based on stream flow—
groundwater relationships under low flow conditions and groundwater pumping
close to the river. Potential public health/water supply impacts may
outweigh any potential benefits in terms of low flow augmentation of either
the Charles River or, via the Mother Brook diversion, the Neponset River.
In accordance with Conclusion 2 above, at such time as satellite facilities
are determined to be required to limit flows to the Harbor treatment system
to the design limit of the HIS and treatment system, a satellite facility
on the Charles River should be reconsidered incorporating consideration of
possible in-stream and other impact mitigation measures as may be
determined necessary.
s I
-------
Satellite AWT treatment facilities facilities proposed by Quincy
Shores Associates, to be locate d on the Charles, Neponset and Weymouth
Fore Rivers with discharge to adjacent wetlands, are not recomended for
further consideration as part of the current facility siting analysis for
the following reasons:
1. Development of these AWl facilities which would treat approxi-
mately 97 MGD of wastewater would not provide sufficient flow relief or
otherwise reduce the volume of flows in the MSD southern system in order to
reduce the size of a harbor sited treatment facility. This is largely due
to the existing adequate capacity of the High Level Sewer to handle all
flows reaching it and sufficient excess volume wastewater flows to deliver
a projected 310 MGD to a southern MSD harbor treatment plant.
2. All currently planned MDC interceptor relief projects are
downstream of the proposed sites for these three AWl facilities and would,
therefore, still be required offering no offsetting capital outlay savings.
3. The potential water supply/public health dangers associated with
the impacts of discharge to a wetlands/watershed area are significant. The
state has reviewed this proposal and has found sufficient elements of
uncertainty and/or detrimental effect that they do not support this
proposal’s feasibility. In particular, the issues raised about potential
dangers from such a siting location include the expected pass—through of
untreated organics and other potentially harmful materials, the more
stringent groundwater/surface water standards that would be applied to such
a facility’s effluent essentially resulting in drinking water standards,
and concerns about such a facility’s operational limitations. These
concerns outweigh any potential low flow augmentation benefits.
4. The limited availability of wetlands in close proximity to the
proposed systems of sufficient size to accept effluent volumes of 10, 35,
and 52 MGD as proposed, as well as limitations of the hydraulic and
renovation capacities of the existing wetlands, suggests that facilities of
such magnitude as proposed would be difficult to site. Required
-------
hydrologic and wetland ecology evaluations are also expected to require a
substantially longer implementation time frame.
5. The major capital costs of developing three AWT facilities,
estimated to be considerably in excess of $238 million, coupled with major
O&M costs annually, do not appear to be justified by the lack of potential
benefits of such facilities relative to the need to site harbor treatment
facilities.
-------
APPENDIX A
WATER QUALITY MODELING CORRESPONDENCE
-------
.- /? (U
/,.; (, ?-(
.‘(..J ifl,,J,, I /ui,,’!. (J’Y{
O ’CE or -lE
C - T .
July 25, 1579
Mr. Thomas C. McMahon, Director
Division of Water Pollution Control
110 Tren3nt Street
Boston, MA 02108
Dear Mr. McMahon:
Pursuant to our discussions of July 3, relative to the DWPC
co,rnitr ent to do a Phase II Basin Plan for the Charles River, and
in light of recent discussions between Mr. Al Ccoperman of your
office and Mr. Jekabs Vittands of Metcalf & Eddy, we find that the
following tasks remain to be carried out under the DWPC basin planning
proc rm.
1. Cor.duct a detailed review of the Charles River model input
values and develop their ranae of confidence . For example,
theW jS modelling effort assumed_certain_values for_flofl flt
source impacts and sediment deposit_impacts which e
res 1ted in using up abàiiT 40 percent of the River’s oxyaen
resources. Therefore, assumed values played the most
significant role.
2. Conduct a detailed revie oL r od 1 parameters and develop _their
rangeofcon:fidence. For example, the reaeration coefficients
used by the EIS modelling effort in certain reaches .ere about
ten percent of those used by the WPC E.asin Plan. Yet, both
efforts reflect similar model calibration results.
3. Conduct sensitivity analyses on parameters and input data
relative€ ir irnpact n satellite plant discharges.
4. Conduct field measurements to narrow the confidence ranges of
those parameters and input data that impact water quality
modelling based decisions on satellite plants.
-------
.:r. Tr.cr3 5 C. Mc h o n , Director - 2 - July 25, 197
5. Make model runs and conduct analyses to provide the water quality
modelling bases for determining the desirability of satellite
plants addressing questions, such as:
- Do dissolved oxygen violations occur with and without satellite
plants?
- If so, how often do they occur and how severe are they?
- What water quality goals can be achieved with ar.d without
satellite plants?
Mr. Cooperman further indicated two additional relevant points.
First, the modelling formulations for the Charles River have been carried
out by the DWPC and have been verified. Secondly, OWPC plans to conduct
the remaining tasks when new members of his staff have been sufficiently
trained, but that results would not be available in the near future.
Our interest is to insure that the necessary work will be reasonably
scheduled so that future wastewater treatment decisions can properly be made.
At such time that Mr. Cooperrian’s staff resume activities in tiis matter
I suggest they contact and visit with Metcalf & Eddy personnel who have been
involved with Charles River modelling review. I enclose for your staffs use
a copy of some of this work as it relatI €ö EPA’s EIS n odelling on the Charles
River. - - -
If we have your concurrence the above tasks will be included in the
Phase II Basin Planning, there will be no need for DC to do this work in
the ut Island Facilities Planning.
Please advise this office as soon as possible as to your concurrence
so that we can finalize the scope of work for the Nut Island Facilities
Planning contract.
Yours truly,
Martin Weiss
Chief Engineer
RG 3 :
Enclosures (1 — 8, inclusive)
cc: Al Cooperman w/o enclosures
J b 2 1979
J .)iV 3 i r’r
: ..T._-, Zi . - ,r..
-------
?. Nl.m4R i€jic 3 / ..,
2O eYJe1 S ree4 02’68 /
i__ /
/1
, J /I.; .
7/;7 -/2):;;
April 26, 1979
Mr. Kenneth Johnson
Special Assistant
Environmental Protection Agency
JFK Federal Building
Boston, Mass.
Re: Charles River Water Quality Analysis
Dear Ken:
I am writing because I believe some clarification of EPA and
conducting the Charles River Water Analysis is needed.
Attached is the Charles River Analysis section from
scope of services, which outlines MDC’s work items.
which we asked Metcalf Eddy to prepare, outlining
EPA.
We would appreciate your reviewing the rneinorandi.mi and scope to assure that we
are in accord on our mutual responsibilities.
Yours truly,
Libby Blank
Director of Environmental Planning
LB/co
cc: D.O’Brien, EPA
J.Vittands, M E 1
MDC responsibilities in
the Site Options Investigation
Also enclosed is a rnemoran&rn,
the tasks to be performed by
Environmental
Planning Office
METCAI F & EDDY, I !C
FILE......
:f;U
1 FD TO______ A
PNS BY_ _____
Enc: 2
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— the b J r ’r .iLc sclcclicn nc]i. rj:
— ‘CC ’1C! IC 3
— (‘IIV roimicntal irnp lct5,
— ;ocia1. im ’acts,
— t •‘c 1 Cal I , and
— in Utution3l ii:ip cts.
13. . r ’ lvt c 1 inv’ i ption of Charles River l! Lcr C’ lity
The pur ose of this invostiCation is to deterrn ne •;hether
there is any opportunity for the discharge from an f• DC
satellite treatment plant into the Charles River in
conformance with The Clean l ater Act such that the pctential
for reclar ation of wastewater, as well as the deployment
of innovative technologies, can be considered. The
investigation is intended as a continuation of the effort
made byE?A during preparation of the EIS on the E!i •A
study.
Plthough the continuation Is to be a joint EPA—NDC effort,
the major work is expected to be conducted by EPA wIth MDC
participating in a program guidance, review and decision—
making role. To this end, it is expected that EPA will
carry out the following:
— Update the EIS data base on the Charles River studies,
especially with new information on wastewater discharges
and recent field measurements. Prepare a file on that
data base and provide a copy to MDC.
— Review modeling formulations especially considering the
results of such an effort carried out on behalf of the
—12—
-------
;chi :-rt P vi i on or :, tcr Fo] ]ut :t’Cr:Y : i (“
‘CI I tR !1l. i. ii ( %IC1 C!1 r{;c:; L
— •icd i l’y Lhc i’oarnmu. ’dby EPI as nccc:;:.niy and ;r.. d
1 Lh f•DC, mci ud ii; c1 3ri cs nccd d to r rcptirc o it.rut
In ncrc ii ab le Iormnt
— u ce for and conduct a phy3ical i.n J)ccL ion (by boat,
%:i crc a! Porz’ifltC) of the Charles River, a]so includir.
pc r:;onncl selected by r 1DC.
— Conduct a detailed evaluation of all para eters ein
the modeling effort and jointly with MDC develop the
range of confidence for each.
- Arrange for free access for the project_participants to
special experts where such are necessary for decision—
making.
— Conduct sensitivity analyses of parameters as necessary
by supplementing computer runs made during the EIS and
provide copies to MDC.
— At locations where it is jointly agreed that further
field Information is required for decision—making,
conduct fIeld measurements. Such may include measurement
of stream reaeration capacity.
— Following development of ..a final agreed upon model of the
Charles River, conduct model runs of jointly agreed upon
conditions needed for decision—making and provide copies
to MDC.
— Prepare and print a jointly agreed upon report on study
findings.
Metcalf & Eddy’s function In this effort will be to assist
-------
r:)C in this 1: r tiC .t ion s foJlo :s:
— the Charle3 ivcr data baac fi]c t c:cic: ‘.
.n(i ‘ dV1SC ‘.DC of pos tble ips needed to be fi] .d.
— I rLicip tC in the phvsica]. jrirpection of the Charles
lUvi ’r for nur;’oses of aiding in model prLrarflotcr selection.
— A si ;L 1’iDC in evaluating the review of riodclthg
• fot’ :nilat ions and of modeling done to date.
— ;dvi c DC on model changes that are neccs ary or that
will facilitate the review of results.
— Assist MDC in the selection of a range of parameters
for sehsltivity analysis.
— Review results of sensitivity analyses and advise on
final model adoption, including the conduct of discussions
with special consultants and participation in the
development of special field measurements.
— Assist MDC in the development and evaluation of’
alternatives and in the development of’ recommendations .
— Conduct reviews of reports and attend meetings as
requested by MDC.
1 14. Assessment of Existing Nut Island Treatment Plant Conditions
— Compile and review existing data and studies on the plant
conditions and operations.
— Make field investigations of physical features of the
existing facilities including hydraulic and treatment
capability, and equipment and structural work, as
applicable.
— Conduct detailed investigations and, If necessary, field
testing of the condition and adequacy of’ major eau pment
that is pertinent to the site selection process.
—l 4—
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os on
jz o565 L /5/7a
MEMORANDUM FOR THE RECORD
The following presents a more detailed explanation of the work
tasks expected to be conducted by the EPA as part of the
analytical investigation of the Charles River water quality.
— Update the EIS data base on the Charles River studies especially
w .th new information on wastewater discharges and recent field
measurements. Prepare a file on that data base and provide a
copy to MDC.
This task involves the collection and analysis of
previous data and reports related to the Charles River.
Included would be data from physical and water quality
surveys conducted by the MDWPC and others; data from
treatment plant discharges and industrial discharges;
data on river flows; data from previous water quality
modeling efforts; and any other pertinent information
related to .the river’s water quality. The data
should be analyzed to identify any treads, either
beneficial or adverse, in the rivers water quality
that may be evident upon review of the data. The
history of the level of treatment and discharge
location for all point sources should be investigated.
The extent and frequency of low flow conditions on
the river should be analyzed.
— Review modeling formulations especially considering the results
of such an effort carried out on behalf of the Massachusetts
Division of Water Pollution Control (MDWPC) and identify model
changes that may be necessary.
This task involves a thorough analysis of modeling
formulations used In the computer sImulation. An
understanding of’ how the model uses the various input
data should be developed. Recommendations would be
made identifying model changes that may be necessary
to properly represent the various processes occurring
in the river.
— Modify the program used by EPA as necessary and agreed upon with
MDC, Including changes needed to prepare output In a more usable
format.
This task Involves the implementation of the needed changes
identified in the previous task along with any format changes
desired to enchance the readability of the computer output.
-------
— Arrange for and conduct a physical nspecticn (by boat, where
appropriate) of the Charles River, also including personnel
selected by MDC.
This task involves a physical inspection of sections of
the river to develop a better understanding of the river’s
characteristics. Possible limited spot checks might include
cross— Ct1on measurements ,. velocity. measurements, depth
measurements, extent. of sediment deposits, and the -
collection of grab samples. A detailed field log would
be maintaIned and any necessary changes to the various
modeled river segments would be identified.
— Conduct a detailed evaluation of all parameters used in the modeling
effort and jointly with MDC develop the range of confidence for
each.
This task involves a review of the state—of—the—art
r.ated to the various parameters used in water quality
_ iodelIng. Included would be parameters related to
such processes as BOD removal, nitriuication, reaeration,
sediment demand, and photosynthesis. A range of
confidence would be Identified for each parameter.
— Arrange for free access for the project participants to special
experts where such are necessary for decision-making.
This task Involves making arrangements for the MDC
to have free access to technical experts in areas
where this Is needed, such as the areas of deoxygenation
and reaeratlon in river systems.
— Conduct sensitivIty analyses of parameters as necessary by
supplementing computer runs made during the EIS and provide
copies to MDC.
This task Involves conducting computer sImulations to
determine the sensitivity of the results to the range
of values identified previously for critical parameters.
In this manner tj e parameters most a.ffectlng the
simulation results will be Identified.
— At locations where it is joIntly agreed that further field
informatioji Is required for decision-making, conduct field
measurements. Such may include measurement of stream reaeration
capacity.
This task would involve making arrangements for the_conduct
of special field measurements, where such have been
identified as critical to the decision-making process due
to the output from the previous tasks.
METCALr & EDOY
-------
— Following development of’ a final agreed upon model of the Charles
River, conduct model runs of jointly agreed upon cond tions
needed for decision—making and provide copies to MDC.
This task would involve the conduct and analysis of computer
simulations representative of conditions selected by the
MDC.
— Prepare and print a Jointly agreed upon report on study findings.
This task would involve the preparation and printing of
a report presenting the results of this investigation as
agreed upon with the MDC.
Throughout the conduct of the tasks described above, the MDC and
Metcalf & Eddy would be involved In the investigation both
directly in the technical analysis and functioning in a program
guidance, review and decision—making role.
Daniel W. Donahue
DWD:dd
METCALF & E OY
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CS: :S: :- s_:
E7 :, 93 Tt.
• ‘p . a I
• — . — - —
— .. .. 4 .._ -— ._ — . .a . —.
Consulting Engineers
March 29, 1978
J— 5250
Ms. Libby Blank
Director of Environmental Planning
Metropolitan District Coriniss on
20 Somerset Street
Boston, Massachusetts 02108
Dear Ms. Blank:
Following our brief review of the mater a1s submitted to you by
Mr. Wallace Stickney, EPA, dated March 1, 1978, on Dissolved
0xy en Modeling, Charles River, Massachusetts , and our attendance
with you at a meeting with EPA on i•iarch 21, 1978, on the same
subject, we felt it necessary to summarize our comments herewith.
In general, the above—mentioned materials and meeting do not
change the coniments made in our Memorandum on the Review of
Dissolved Oxygen Mode1in , Charles River, Massachusetts , sub-
mItted to you on January 10, 1975.
In order to be brief, we will only touch on the more important
points to provide further clarification.
Model Formulation Accuracy
As mentioned before, we have not checked the correctness of the
program. However, we do suggest checking, for example, the
temperature correction formu1at on for the upstream reach iflflOW.
AWT Performance Reliability and Deoxygenation Rates
We suggest checking the performance capability of the Marlboro
Easterly plant to achieve the 5 rng/L BOD 5 and 1 mg/L NH 3 —N.
NEWYORK PALQAL O C’ ICAGO
-------
Y . L ..bby Ela.nk
March 29, 1978
S .n±1ar1y, we suggest checking th±s plant’s effluent cha’acte’—
Istics to determine the appropriate deoxygenatlon rates for AW?
effluents. For further references on the change in deoxygenation
rates with increasing levels of treatment for plant effluents and
receiving streams, we suggest reading Professor Schroepfer’s
pIoneering work on the Mississippi River*, as well as recent wcrk
by the Geological Survey on the Willainette River in Oregonhl*.
DocumentatIon of Assumptions and Hand1in of Dan Reaeration, T e
of Flow, etc . -
Againj we suggest that the sources of information be documented.
For example, the sources of the data in Table 5 of’ the EPA Report
need to be shown, to identify where such are from the BasIn Plan
and where such are from other references.
In our earlier memorandum we commented on some of the formulatIon
used. Our concern was with the correct use of these and not with
the answers they may produce.
PhotosynthesIs and RespiratIon
In developing the photosynthesis and respiration terms for water
quality modeling, a set of selected K rates was used for the
purpose of oxygen budgeting in the DICURV2 Program. Then a dIf-
ferent set of K 2 values was used in the actual water quality
modeling. This cannot be considered as a process leadIng to model
calibration.
Further, the photosynthesis/respiration information derived from
the above calibration process was not used in the low flow
sImulations. The input reflecting photosynthetic oxygen
production was greatly reduced while the oxygen consumption due to
respiration was held constant.
FIgure 6 of the EPA Report shows a curve labeled ALGPO = ALGRA.
This represents a conditIon where photosynthesis and repiratlon
are modeled to In effect zero each other. Such a condition is
more favorable to the oxygen resources of a stream than can be
expected at night, when the respiration load is not canceled.
However, the curve as shown falls below the range of measured DO
values over most of the Charles River. Since these measurements
G. J. Schroepfer, M. L. Robins and R. H. Susag, “Reaopralsal of
Deoxygenation Rates of Raw Sewage, Effluents and Receiving
Waters”, Journal WPCF, Vol. 32, No. 11, November 1960.
**R. A. Rickert, W. G. HInes and S. W. McKenzie, “Methodology for
River — Quality Assessment with ApplicatIon to the Willamette
River Basin”, Oregon, Geological Survey Circular 7l5—M, 1976.
-------
Libby Slank
:arch 29, 1973
include nIghttime readings WhiCh are representatIve of river con-
ditIons where there is a respiratlon load but no photosynthesls
addition, calIbration should be adjusted to allow the curve to
fall wIthin the range of field measurements;
Reaeration Coefficients
Undoubtedly the whole reaeration approach is a most important
factor in thIs modeling effort.
Again, one cannot use a different basis of reaeration in the
development of photosynthesis and respiratIon budgeting the.n one
would use in modeling the same data In the River. One cannot Use
the wrong formulation to represent dam reaeration irrespectIve of
the results.
Wtth respect to selecting a formulation for stream reaeratlon, as
stated In EPA’s latest submittal, there is no one formula capable
of adequately predicting reaeration capacity in any stream. Thls
includes the Tsivouglu—Neal formulation as well as the O’Connor—
Dobbins formulation. The Tsivouglu—Neal formulation is am attempt
at this. Covar’s paper (see EPA Memorandum, March 1, 1978 for
reference) recommends a set of three equations, including the
O’Connor—Dobblns formulation, for three conditions but does not
recommend the use of the Tsivouglu—Nea]. formulatIon due to a
considerable scatter in the data.” As an objection to the use of
the O’Connor—Dobbins formulation (used by DWPC in the Charles
River BasIn Plan), the EPA Memorandum, apparently using Covar’s
paper as a basis, cites that the data used for its development
were under conditions where velocities were greater than 0.1 feet
per second —— a condition not occurring in the Charles River
during low flows. Perusal of the Tsivouglu— 1eal data base, as It
is published, did not show any data points with velocities less
than 0.1 feet per second either.
It should be pointed out that we do not necessarily subscribe to
any of these formulas as being the most appropriate for the
Charles River. Our feeling is that the impact of this parameter
is sufficiently significant to warrant a sound basis for its
determination.
Impacts on Oxygen Resources
Again, as modeled, the most significant impacts result from as-
sumed data. On the basis of a limited review of the available
data and without the ability to obtaIn computer runs we would have
liked to see as input to our review, the following numbers can be
only consIdered as crude approximations of impacts.
-------
::s. Li b:.’ Blank
?:arch 29, 1978
Cause
Impact on DO
in m /L Basis
Sedinent oxygen demand
3
Rept. FIg. 15.
El ]. and Gil.
Cases
Phctosynthes ls/
respiration
6
Rept. Fig. 16.
D2 and E2.
Cases
Upstream plants
Unknown
i• DC satellite plant
1.5
Rept. Fig. 12.
B]. and 311.
Cases
Nonpolnt sources
Unknown
Following the March 21st meeting, at which the last paragraph on
Page 11 of EPA ’s March 1st memorandum was discussed, we reviewed
the EPA computer run No. 368 which had been submitted as the basIs
for the conclusions in that paragraph. As stated 2 the purpose o ’
the run was to test the significance of the oxygen demand from all
of the treatment plants by reducing CBOD 5 to 1 mg/L and NBOD to 0.
The run showed DO values significantly lower than those quoted in
the paragraph. A spot check of the input data showed that the
NEOD values had not been set to zero. A further check showed that
the Input data had been further changed by raIsing upstream
background water quality, by increasing K 2 in five segments, by
decreasing K 2 In three segments, and by elImInatIng a small point
source.
Very truly yours,
ekabs P. Vittands
VIce PresIdent
JPV:jfj
-------
Metcalf & Eddyjnc .
SC S:ai’torC S e : Sos:0 Massa: e S C 1
617 523. 9OOT VX 71C 321 635 Ca ,eAOOreSS M TEOD Boston
Apr11 28, 1976
-
‘.‘ —1
Ir. Jonn Elwood
E v1rozi- enta1 P1ann1r Dlvislon
etropo11tan District Cor IssIon
20 Somerset Street
3t ston, assachusetts 02108
Dear ] r. Ciwood:
As you requested, we have reviewed r. Folese’s ne-iorandu on
the Charles River 1978 Survey. The memorandum implIes that this
year’s survey will resolve some of the problems encountered in
the co puter modeling of the river. AssumIng this to be one cf
thc- goals of the sampJ.ing program, the following cor ents are
made.
1. The sampling program should be conducted under
conditions similar to those used In the modeling
effort. That is, since the river modeling Is for
\ /7 low flow conditions, the measurement program
\ / should be conducted during dry weather under low
flow conditions. Also, the timing should be
flexible so that the program can be rescheduled
If signIficant rainfall occurs prior to p1anned
program.
2. In order to obtain dependable results from the
modeling effort, it is essential to have all com-
ponents sampled at the same time. Therefore, when
the main stem is sampled, the point sources and at
least the major tributaries, such as fine Brook,
Stop River 2 and Sugar Brook, should also be a&’ipled.
Net’ Yo,A Palo Alto Chicago
rc— —0
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-. John lwood 2
,_._ 1
. dI
3. i1th regard to additional sampling stations, it
would be desirable to establish a station somewhere
between river mile 70.3 and 66.1, where rnodelin o ’
the 1973 data indicates no dissolved oxygen.
Stations should also be established above and below
ajor point source discharges to aid in assessing
their impact on the river’s water quality. (Eince
no advanced plants are operating on the river,
Perhaps monitoring an existing advanced plant,
such as Marlborough, would provide valuable data in
deter in1ng tile effects these plants will have on
river water quality.)
. Time of travel studies should be conducted in con-
junction with the samplir.g program.
5. upplenenta1 flow gages should be installed and oper-
ated before and during the sampling program.
6. Dam reaeratjon should be measured by measuring dis-
solved oxygen concentrations immediately above and
below the dams.
7. Sediment samples should be taken and analyzed to
determine benthic demands. It is not necess y,
however, that these samples be taken during the
sampling program. For convenience, they could be
taken either before or after the program.
6. Measurements should be taken from which determinations
can be made of instream carbonaceous decay rates,
nitrogenous decay rates, and reaeration rates.
9. The sampling program should include both daytime and
nighttime measurements to aid in assessing the
diurnal variation in dissolved oxygen concentrations
and to ascertain the level of algal photosynthesis
and respiration.
10. Groundwater samples should be analyzed to aid in
determining the water quality characteristics of
base flow under extreme low flow conditions.
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‘• jo F.wood
Apr11 23, 1978
In sur unary 1 we believe that a considerable effort is requIred
to re olie all the probleris that have been encountered in
the ! ?A ater quality modeling effort. U recom end that tha
sampling proGra! be caref 1ly designed and carrIed out so that
the data collected will be useful in further studie3 of the
Charles iver water quality.
It you should have any queztions regardIng these co en:s, please
do not hesitate to contact us.
Vc ry truly yours,
/1, )• ,
.1 ‘ .• —
ona. ue
Projec: : ineer
WD: ob
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N:EnORANDU 1 FOR THE RECORD
BY: A. Lawrence Polese
DATE: April 14, 1978
SUBJECT: Charles River 1978 Survey
The Charles River 1978 Water Quality Survey has been scheduled by the
Division for the week of July 17 — 21. The last intensive survey was
conducted in 1973 in which both main stem and major tributaries to
the Charles were included in the sampling runs.
During March and April of this year personnel from the Division cdnducted
two preliminary spring surveys, one on the main stem and one on the
tributaries. The purpose of these was to collect background data and
to investigate possible pollutant loads carried in runoff from snovmelc,
and leechate resulting from high water tables. Results from chemical
and bacteriological analysis are not yet available.
This year’s survey will differ somewhat from the 1973 study. For
modeling p . poses the entire main stem (minus tributaries) will be
sampled in one run, whereas in 1973 the run was divided into Upper
and Lower Charles runs. This was done in order to keep the runs from
being too time consuming i.e., seven hours. By postponing the tributary
stations a few days one complete run on the Charles can be accomplished.
This was not possible in 1973 with the Upper and Lower Charles arrange-
ment. Again complete runs should make modeling both easier and more
representative of actual river conditions.
The sampling stations for the current year are identical to those used
in 1973 (see The Charles River Part A, MDWPC 1973). Since tributaries
are being sampled separately, a more comprehensive survey is allowed.
A list of tributaries to be sampled is attached along with a list of
main stem stations.
The selection of sampling stations and time of survey is not yet final.
Addition/deletion of stations will be considered to make modeling as
accurate as possible. This memorandum is to provide interested parties
with an idea of how the Division is handling this year’s survey.
Coiwnents and questions should be directed to Larry Polese at the Division’s
Water Quality and Research Section, Westborough, MA (617—727—6983 Boston)
or (366—9181, 9182 Jestborough).
ALP / ro
Attachment
cc: A. Akalainen
L. Blank
Ii. Shaughnessy
.1. Vittands
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CHARLES RIVER ?t .IN STEM STATIONF
CHO1 Dilla St., Milford
CHO2 Cedar Swamp Pond Darn, Milford
CR03 Howard St., Milford
CR04 Mellen St., Hopedale
CR05 Hartford Ave., Bellingham
cR06 Box Pond Darn, Bellingham
CR07 Rte. 126, Bellingham
CR08 Pond St., Franklin—Hedway
CR09 Elm St., (Shaw St.), Franklin—Medway
CR10 Bent St. (Walker St.), Medway
CR11 River Rd., Norfolk
CR12 Forest Rd. — Orchard St., Millis—Medfield
CR13 Dover Rd. — West St., Millis—Medfield
CH14 Rte. 27, Sherborn—Medfield
CR15 Bridge St., Sherborn—Dover
CR16 South Natick Dam, Natick
CR17 Central Ave. — Centre St., Needham—Dover
CRIB Chestnut St., Needham—Dover
CR19 Ames St., Dedham
CR20 Kendrick St., Needham—Newton
CR21 Elliot St., Needham—Newton
CR22 Walnut St. (Wales St.), Wellesley—Newton
CR23 Moody St., Waltham
CR24 Watertown Dam, Watertown
CHARLES RIVER TRIBUTARY STATIONS
1 Godfrey Brook — Depot Rd., Milford
2 Beaver Brook — Taunton St., Bellingham
3 Hopping Brook — Rte. 109, Bellingharn
4 Chicken Brook — Rte. 109, Nedway
5 Sheppards Brook — Elm St., Franklin
6 Mine Brook
a) Rte. 140, Franklin
b) Near Rte. 495, Franklin
c) Pond St., Franklin
7 Miii River — River Rd., Norfolk (CR11)
8 Stop River
a) Pond St., Norfolk
b) Winter St., Norfolk—Walpole
c) Campbell St., Norfolk
c) South St., Medfield
9 Sugar Brook — Of f Dover Rd., Millis
10 Vine Brook — Rt. 109, Medfield
11 Bogastow Brook — Rte. 115, Nulls
12 Fuller Brook — Dover Rd., Wellesley
13 Waban Brook — Rte. 16, Wellesley
14 South Meadow Brook — At Charles River, Newton
15 Beaver Brook — River St., Waltham
TOTAL STATIONS 19
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-- UN iTED STATES ENViPONMENTAL ? OTECTION A3E.; CY
pEGIO .:
j F KE DY FEDERAL BUILDING, aosro . chUS T S c:: 3
flarch 1, 1973
Ms. Libby Blank
Director of Environmental Planning
::e r politan District Coc’.mission
20 Somerset Street
Boston, MA 02108
Dear Ms. Blank:
Upon receipt of your January 11, 1978 letter containing your corm ants
prepared by Metcalf and Eddy on the Draft Report —— “Dissolved Oxygen
Modeling — Charles River, Massachusetts”, Mr. Allen Ikalainen reviewed
the comments closely. He has prepared remarks concerning each point
addressed by Metcalf and Eddy.
I have enclosed a copy of Hr. Ikalainen’s remarks. It is evident that
there are some misunderstandings of what the report says. In particular,
your comments concerning temperature correction for reaction rate con—
stants which are temperature corrected, photosynthetic oxygen production
3nd respiration rates used in the model calibration, rtitrification rate
constants in simulations at low flow and the discussion of dam reaeration
reflect these misunderstandings. The attached remarks explain these points
in detail.
In addition to the specific misunderstandings mentioned above there are
several items in your comments which deserve further attention. For
instance, your comments on variations in river flow during the time of
travel survey in 1973 and differences in river flow between the September
1973 calibration and projected flows in the year 2000 are discussed in
the attached remarks. Also, your comments on sediment oxygen demand and
the magnitude of their effect are considered in some detail.
Your comment on in—stream reaeration raises Tsivoglou and Neal’s caution,
concerning use of their method in impoundments. However, they raise the
note of caution because the procedure may predict reaeration rates in
excess of what they may actually be impoundments. The opposite is iridi—
c..ited by the language of your comment. Again, the attached remarks
explain these points in detail.
-------
Your reco .- endationS raise an important consideration in understanding and
interpreting modeling results. Sensitivity analyses should be done to
determine which modeling parameters most greatly affect the results, in this
case, predicted river dissolved oxygen levels. As mentioned in the attached
remarks concerning your conclusions and recommendations, sensitivity tests
on sediment oxygen demand, photosynthetic oxygen production and in—scream
nitrificaciori rates are included within the report. We also point out
subsequent to the modeling report and receipt of your con encs, sensi—
ti ’içy tests have been done on deoxygenacion rates of plant discharges,
bioche ical oxygen demand loads in runoff, treatment plant loadings and
in—stream reacration. These sensitivity tests are not rigorous and have
not been done to determine the effect on results from varying percent
changes in model input, but have been done over wide ranges to determine
the most sensitive input parameters in terms of their effect on results.
It is evident that in order in—stream reaeration, treatment plant loadin ,
and sediment oxygen demand
Although not yet tested, time of flow is undoubtedly an important para ecer
also.
In your recommendations, you have suggested confidence testing of each
“factor”. In this case this cannot be done because the field data collected
by the Division of Water Pollution Control in 1973, 1972, and other data
developed by EPA does not contain any duplicate samples or replicate
analyses or is not available in its original form. We agree that further
investigation of assumed values or field sampling could provide more
information to us. However, we question if the time and expense involved
in time of travel measurement, sediment oxygen de:. nd measurement and
tracer measurement of reaeration will provide information which will change
our understanding of the river’s dissolved oxygen resources. We still
believe there is a major doubt that the Charles River can assimilate the
projected waste loads for the year 2000, after advanced treatment, and main-
tain D.0. levels of 5.0. mg/i consistently during the surer_ g ;j
Therefore, we question the advisability of discharging any more waste—
loads_to the river than is absolutely necessar .
r. Alan Cooperman of the Division of Water Pollution Control informed us
that he is planning a water quality survey of the Charles River next summer
and that he would like all parties involved in this modeling to decide upon
any specific field measurements which we need to further calibrate and
verify the model. I suggest that once you review the attached remarks
we meet with Mr. Cooperman to discuss the need for additional field
measurements.
-------
Lastly, at several points in r. Ikalainen’s remarks h . . ha n i :ed t’r. t
he tould review and consider any information that you or N tcali and Eddy
might have to further elaborate on the points of discussion concerning
deo ygenation rates of wastewatcr after advanced treatment, in—stream
reaeration predictive methods and in—stream deoxygenation rates for strear s
receiving effluents after advanced treatment. In this regard please contact
Mr. Ikalainen directly.
Sincerely,
.
Wallace E. Stickney, PE.
Director
Environmental and Economic Impact Office
Enclosures
cc: Mr. Alan Cooperman (MDWPC)
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Ca=e n:
on
“ cmorandum on the Revicw of Dissolved ( ‘ cer.
? :adelin • Charles Rivet, fl3 sachus c ts ”
(Co-z ents refer to paragraphs in sequence—first to last
of the above 1emorandu:n)
Paragraph 1.
On February 9 and 11, 1977 I met with Mr. Alan Coopernan, ? t.TC at
Wes:boro, MA. We discussed modeling of the Charles River for purposes
of analyzing the effects of a proposed MDC Satellite treatment plant
discharge on dissolved oxygen. The EPA — Environmental Iipact Office
and their consultants were interested in the effects of the proposed
discharge if the discharge points were located at points other than
just downstream of the Cochrane Dam. This interest developed because
of difficulty in finding a site for the satellite plant near the E> LA
recommended location.
Mr. Cooperman explained that Mr. John Erdmann had modeled the June
and September, 1973 water quality conditions with the STREAM and DICURV2
models, but h d not developed a low flow simulation with the STREAM model
prior to his leaving the MDWPC. Mr. Cooperman and I agreed that low flow
conditions should be simulated with the STR.EAN model to analyze the effect
of alternative satellite plant discharge locations. The Division did not
have the resources at that time to develop the low flow model. However,
r. Cooperman provided to me card decks of Mr. Erdmann’s September 1973
simulation, the DICURV2 program and its input data for June and September
1973, a memorandum on the use and development of DICURV2 and computer
printout of the September 1973 simulation of the Charles River with the
STREAM model. He provided this information so that I might develop a low
flow simulation. Mr. Erdmann and Mr. Cooperman were planning on using
the STREAM model and DICURV2 to determine wasteload allocations under
drought flow conditions for inclusion in the Charles River 1976 Water
Quality Management Plan. (Ref: Part C, Water Quality Analysis, the Charles
River and Charles River Basin 1973, 1976 Page 65.) However, Mr. Erdmann’s
leaving precluded this.
In my report I have referenced this prior work by Mr. Erdrann in the
ACKO LEDGE NT and on page 17 — last paragraph. Also in the model
calibration procedures discussed on pages 18—32 of my report, Mr. Erdmann’s
and thus the Division’s work is referenced repeatedly although each
parameter is not specifically indicated as being developed by Mr. Erdmann.
I have modified Mr. Erdmann’s model calibration input data for the September
1973 simulation in two major areas, in—scream reaeration and sediment oxv en
demand. Reasons for and the details of these modifications will be discussed
under com ents on paragraphs relating to those subjects, specifically.
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2.
Th ‘.TC has reviewed the report in dctoil. rr .flLr ro rh s: -
Office ( azcr Quality Section) has scheduled a water quality sur ey for t:
Ch::les River Basin for the sunmer of 1978. The purpose of the survey is to
u 3ta the past water quality information and to provide current infor o: or
for development of a Phase 2—Water Quality Mar.a enent Plan. The Phace 2
Plan is intended to review and update wasteload allocations for point so :c
ar.d to develop wasceload allocations for new point sources and non—point
sources. The Plan is scheduled for completion in early C.Y. 1979 and .s
being developed in coordination with NAPC and EPA.
Paragraph 2.
The impetus for this modeling did come from the EIS preparation.
However, under the requirements of the Federal Water Pollution Control
Act facilities planning cannot be funded by EPA unless there is an EPA
a,proved basin plan among other require ants. Basin plans which apply
to streams and rivers which are designated as water qu_ .zy ii .:
cannot be approved by EPA unless vasteload allocations for point source
discharges will meet water quality standards as set by the states and
approved by EPA. Therefore, this modeling of the Charles which is
considering the current approved wasteload allocations is part of the
continuing water quality management process including facilities planning
and wasteload allocation. It is also part of the EIS preparation which
reviews the water quality impact of facilities planned to meet wasteload
allocations.
Paragraph 3.
Recommendation 1 c. is based uoon the pure logic that treatment
plants which would provide effluanc quality as seems necessary accorfing
to this analysis would be very costly to construct, operate and maintain.
Also, it is my understanding that there are very few large municipal
treatment plants operating at levels producing effluents of 5 ng/i CBOD 5
and zero NH 3 —N and therefore one can only question the reliability of a
plant to do so. One of the reasons that an EIS is in preparation is
because a satellite plant will have a significant environmental imo.a t.
Recommendation 3 does not recotr.mend that sewer service areas be
limiced. It recommends in fact that “the water pollution planning process
for the Charles River should include, as a possible control for future
wascewater from MILFORD,..., the limiting of sewer service area and
wastewacer loadings,...”
Conclusion 4 says leaching from solid waste is known to occur in
the Charles River. This statement is based upon Part D, Water Quality
Management Plan — WPC 1976 — Charles River Basin, pages 17, 24.
Paragraph 4.
If the DC and Metcalf and Eddy will recall the meeting at which
they were present in Westboro, MA at the Division Offices on May 27, 1977.
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At t i : reetin; Mr. Coope an explained to all present that their cons ..i:. ’:,
?csour:c Analysis, Inc., wa reviewin; the nodel f u1 tion. As oi :h:s
writing I has not cc ’lc:cd their a alvsis, but recent conversntion i:
them indicates that the model is correct in the steady—stare form. Ai
l, constants input to the model in this analysis are tenperature corrected
by the model as explained on page 16. Reaeracion rates have been adjusre
Thpward outside of the model by the temperature correction factor specified
by Tsivo 1ou and Neal and have also been temperature corrected (an upward
adjustment) within the model. This is explained in footnote (1) on page
30 of the report.
In the year 2000 low flow simulations the Mother Brook diversion was
inadvertently located at the downstream end of Reach 26 when it should be
located at the head end of the reach. A low flow simulation has been run
with the diversion located at the head end of Reach 26. The difference in
downstream D.0. conditions as a result of this error is less than 0.1 mg/i
for the case tested.
Paragraph 5.
The assumptions icade in the model calibration and the low flow .ode1
development are stated in the report. Also, many of the assumptions are
the sa ne as those in the modeling portion of the approved Water Quality
Management Plan for the Charles — Part D — WPC 1976.
Paragraph 6.
If one looks closely at the time of travel study data from April —
May 1973 it is seen that river reaches between river mile 76.5—75.5 and
72.0-70.3 were surveyed on May 8. All of the remaining main stem reaches
were surveyed between April 30 and May 4, inclusive. Flow variations at
the Charles River Village, Wellesley and Waltham USGS gaging stations were
22 , ll and l3 of the minimum daily flow, respectively for the period
April 30 to Nay 4, inclusive.
Again, if one looks closely, the 2000 projected low flow with an ! WC
satellite plant is seen to be about 7 times less than the average flows
during the time of travel study. This is based upon the projected and
measured flows at the three USGS gaging stations.
The tine of travel—flow relationships used in the September 1973 and
low—flow simulations are the same as those used in tha modeling of Part D—
Water Quality Management Plan, Charles River, 1976 C Table VI—3 and are
essentially the same as those in Appendix E of Charles River Water Ou 1jtv
Study EPA—Region I, September 1971, except as noted in Table Vt—3. As
explained in the Report on page 18 the work of Leopold and Maddock is the
basis for determining the time of travel—flow relationships. This is a
widely accepted procedure for predicting river velocity at varying flows.
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4.
A rD:ed in the co:-ients Leopold and laddock d ve]oped the procedure
fran data collected on “freely—flowin; streams witheut dams”. If this
s in fact the case, then it is very possible that the relationship may
predict velocities that are too high in the impounded reacnes. The
relationshap somewhat underpredicts time of travel as measured in April—
y 1973. (See Attached Table 1) Additional testing of the relationship
at flows approaching those of the projected low flow with a satellite plant
would be useful. However it will require a great deal of luck to schedule
a tiie of travel survey to coincide with low flows being stead:: throughau
the river and approaching the projected lowflows.
I presume Netcaif and Eddy’s reference to “hydraulic efficiency” of
impoundments is an attempt to explain that large, recent man—made impound-
ments may retain the original river cross section along the bottom surface
profile and that at extremely low flows the river will flow within its
original channel causing lower times of flow. I don’t believe this is the
case in the Charles River because I observed the river on August 16, 1977
when the daily average flow at the Charles River Village Gaging station was
58cfs or 28% less than the projected seven—day 10 year low flow as shown in
Table 8 of my report. On that day the impoundments behind the So. Natick
Dam and Cochrane Dam were fully impounded and velocity of flow was extremely
slow. Floating algae were barely distinguishable as moving downstream.
Further, I don’t believe the concept of “hydraulic efficiency” is applicable
to rivers flowing through wetlands and lowlands, as does the Charles, with
impoundments formed by run of the river darns.
Paragraph 7.
The September 1973 calibration includes pollutant loadings from Sugar
Brook as measured on 9/4/73. The ?Iillis wastewater treatment plant
discharges to Sugar Brook. In this particular case the model includes the
loading from Sugar Brook which carries the loads frou’ Millis and Coct Corp.
via the Millis treatment plant.
I have not reviewed and compared the operating procedures in 1973 and
1974. Perhaps Mr. Erdmann did in preparing the model for calibration.
1r. Erdmann’s conclusion number 2 from Part C ‘ater Quality Analysis,
1973—1976, Charles River and Charles River Basin points out that non—point
sources “undoubtedly degrade the quality of many more miles of stream than
do the waste discharges and the sewer overflows, but in more moderate degree”.
Paragraph 8.
The second sentence in this paragraph partially reiterates a point
discussed at length in the report on page 36 and 38. Non—point sources
contribute much more CBOD 5 to the river than do point sources. The
calibration simulation under predicts CBOD 5 loads in the river. For
example, the total river CBOD 5 mass loading in pounds per day for the
surface runoff, as assumed, is 83 percent of the total CBOD 5 mass loading
from tributaries and point sources. Yet the CBOD 5 profile as simulated
and shown in Figure 8 is consistently lower than the measured CBOD 5 in
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5.
the r:ver for the river reaches below river mile 70. Figure 9 further
en h .as :es the iagnitude of non—point source loadings to the river as
ccnpared to point source loadings.
The last sentence of paragraph S is not very meaningful and grOSSlY
misrepresents the benthal oxygen demand used in the calibration. If one
looks cio ely at Table 5 and computes the sediment denand values in te s
of m;/l—dav it is seen that the naximum denand rate is 3.28 mg/i—day only
in Reach 2. Furthernore, of the remaining reaches, three have sedir.enc
d ands of 1.66 to 1.0 and the last 18 have sediment demands of 0.80 to
0.13. g/l—day. The discussion of sediment oxygen demand on page 29 of
the report explains and justifies the sediment demand inclusion in the
calibration modeling.
The D.O. simulation of September 4, 1973 conditions as shown in
Figure IV—5, Part C, Water Quality Analysis, Charles River and Charles
River Basin apparently includes a sediment oxygen demand of 2.5 gm/m 2 /dav.
This rate seems much too high, but nay result in a predicted profile close
to the mean of measured values if reacration rates are also too high.
Paragraph 9.
The photosynthesis discussion in this paragraph is totally wrong .
The calibration simulations as shown in Figures 6 and 7 represent average
photosynthetic oxygen production and respiration and average photosynthetic
oxygen production set equal to average photosynthetic respiration. This is
e: :plainad in detail on page 32 of the report and is indicated on Figure 6.
Thus photosynthesis is represented only as having a net D.0. production
over a day or having no net D.O. production. No simulations are presented
in the report with “zero respiration”.
The discussion presented in Paragraph 9 of weather conditions is
no: a complete representation of river flow conditions on September 4, 5
and 6, 1973. The river system cannot be viewed as simplisticly as in
the cc=ents. For example, the streanflow data presented in Table 1 of
the ceants indicates that daily average river flows at Charles River
Village were higher by 31 percent on September 4, 1973 than on September
6, 1973. However, if we look at USGS recorded river flows on those days
at e1lesley and Waltham we find that river flows were 15 percent higher
and l7 lower, respectively on September 4 and September 6. The conrents
fail to present this further information which indicates that higher river
flows resulting from rainfall in the upper Charles Basin cannot necessarily
be associated with higher 0.0. conditions during daylight hours.
In addition, the comment fails to point Out or recognire that the
higher DO’s referred to on page 36 of the report occurred predominantly
during daylight hours. Looking at the data further in Appendix B the
higher DO’s on September 4 occurred as peaks in diurnal D.O. variations
-------
6.
cn that day, while diurnal variations were significantly lower on
September 6. This bears out the conclusion in paragraph 5 of page 36
in the report that photosyn:hecic D.C. producticn on September A
exceeded chat on September 6. This conclusion is also supported by
the observation that at al’l but one location peak photosynthetic oxygen
production rates, as determined by the DICURV2 analysis of John Erdmann,
occurred on September 4, 1973.
Lastly, as shown in Figure 8 and as discussed in the second and third
paragraphs on page 38 runoff in the lower reaches of the Charles may contain
si nificant CBOD 5 which would offset its dilution potential, even though
the m joricy of D.C. demand effect of the runoff SOD would not be exerted
until some days later.
Table 1 of the comments contains two errors. First, there is no
rainfall recorded on September 7, 1973 at the Boston WSO location. The
Table indicates .44 inches as being recorded on that day. Second, the
Data Sourae 1 as listed should be dated September 1973, not January 1973.
Paragraph 10 — “Biochemical Deoxygenacion Rates”
The background loadings as input to the September 1973 calibration
simulation and the 2000 low flow simulation are about 5 pounds per day
of CBOD . The concentrations of ultimate and 5—day carbonaceous biochemical
oxygen emand, respectively are 10.6 and 4.2 mg/i. This total mass loading
is input to the river only at r.m.76.5 and is based upon the CBOD 5 loadings
measured at r.m.76.5 in September, 1973. This is a natural background
loading and there is no infor iation or implementation plan to indicate
this loading will change by 2000.
As stated on page 43 of the report the deoxygenacion rate for the
treatment plant loadings is a normal rate for biochemical oxidation. If
Metcalf and Eddy and/or the C has data available on deoxygenacion rates
for advanced treatment plants I would like to review the data for further
consideration of the rate constants.
It should be noted, however, that the rate constant within the range
of .1 to .4 will not affect the results of the modeling analysis to a
significant degree. Copies of simulations pointing this out are attached.
I see no justification for decreasing K., rates in the river between
1973 and 2000. In 1973 the river’s water’ uality was predominantly
affected by non—point sources, in particular below r.m.40. As stated in
Mr. Erdmann’s conclusions as referenced on pages 11—12 and as discussed on
page 38 of the report non—point sources affect the D.0. balance in the
Charles River over many more miles of river than do point sources but to
a more moderate degree and BOD loads in the river are attributable to
algal mass and or SOD in runoff with D.O. incre3sing as BOD increases.
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I.
Also, as they are indicated on page 43 in Tahi 7 the t ca K 1 rates
(hiocher ical reaction rates) range between .09—. 23. These are not high
races jar streams of low to moderate pollution asl have seen and
C::?erienced. Furthermore, if one does some simple calculazions, it can b
seen from the data in Table 8 that the Charles River at low flow in 2000
w uid consist of between 50 and 80 percent treatment plant effluent with
the effluent containing 5.0 mg/i CBOD 5 . This level of CBOD 5 is not analgous
with high quality water or clear rivers, in my mind. Therefore, lower
deox:’genation races in the river are not justifiable.
Par graph 11 — Nitrogenous Oxidation Rate
The discussion in this paragraph is not meaningful to the analysis of
the report because the discussion in item 4 on page 56 under Cases A, B,
E, C and H simulations and the D.0. profiles of figure 15 indicate that the
simulation results are not very sensitive to nitrificacion rate constants
of 0.6—0.2.
With regard to the comment concerning “certain fot-ms of algae” caking
“great inroads upon the ammonia supply”. Such a phenomenon has not bRen
studied in the Charles River and is beyond the scope of this analysis.
AJ.so, as will be considered under the discussion of Paragraph 12 it is
probably not sound thinking from a water quality protection standpoint to
count on highly variable algal populations, which are one of the Charles’
water quality problems, to mitigate the effects of oxidation of ammonia.
Lastly, I don’t believe water quality simulation has advanced far
enough in the understanding of algal and plant growth and death dynamics so
that anyone could definitively quantify algal consumption of ammonia.
Paragraph 12
The discussion in this paragraph has not mentioned at all the material.
presented in the report on page 28 which considers both the Quirk and Eder
and !astropietro dam reaeration prediction procedures. To reiterate that
material, a comparative analysis of D.0. values downstream of each dam
on the Charles as predicted by the two procedures and compared to measured
values indicated little difference.
At low floy, with an ! DC Satellite plant located downstream of the
Cochrane Datii the Mastropietro procedure gave significantly higher
1.0 mg/i), DO’s due to dam reaeratiori at three dams, slightly higher
DO’s (.2—.6 mg.l) at six dams, equal DO’s at one dam, and lower DO’s
(up to 0.6 mg/l) at four dams. Here again there appears to be less than
significant difference between the two procedures as applied in this
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S.
analysiS. Hawever, the rodel will he ‘od fi d to pred cr P.O. by th
: astropietro procedure and the impact of the change evaluated b ca se the
: !as:ropietro procedure is more logical and was developed frc’rn enpir cal
analysis of measured darn reaeracion.
Paragraph 13 — Stream Reaeration 1(7
The first paragraph of this comment has taken the work of Tsivoglou
and Neal out of context giving the authors’ recommendations an incorrect
in:erprecacion. Conclusion number 15 in the article referenced in the
resort says in full:
“15. Certain limitations of the foregoing predictive tro als should be
emphasized, notably those that relate to scream segments in which tnixin is
poor. Thus, although the pools that occur as the result of natural
topography are incorporated in the results suc _- arized here, the predictive
models have not. been derived for, and do not apply to, major man—made
impoundments. In general, very small slopes and small rates of energy
dissipation imply less turbulence and poor mixing and, consequently,
relatively low values for the escape coefficient C.”
As can be seen by observing the relationship as given on page 28 of
the report, a low escape coefficient results in a low 1(7 value. Thus the
relationship may be predicting 2 values which are too high for the long
ir pounded reaches of the Charles.
With regard to the second comment on stream reaeration it is useful to
look at the facts of how and when “K 2 ’s” were predicted by the MDWPC in
Part D — Water Quality Management Plan — 1976 and Part C — Water Quality
Analysis — the Charles River and Charles River Basin.
Page 71, Part D, indicates that the equation of O’Connor and Dobbins
developed for channels having isotropic turbulence was used with the
relationship (referenced to EPA) for a minimum These were applied
such that the higher 2 yielded by either method was used in the modeling
in this Basin Plan. Tables VI—5 and VI—6 indicate which 1(7 values were
adjusted upward to a minimum value of 2.0/depth.
If we first look at the O’Connor Dobbins relationship as described
by Covar (1976) and Rinard (1976) we see that it was developed and
tested on streams in which velocities ranged from 0.2 to 4.0 feet/sec
and depths from 2 to over 30 feet. Table VI—6 showsthat velocities in
25 of the 33 reaches are between .17 and .001 ft/sec and 18 of those 25
have velocities less than 0.1 ft/sec. Also, if we look at the depths in
Table VI—6 we see that most are near the lower limit of the range of
depths over which the O’Connor—Dobbins relationship was developed and
tested.
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a
:e:.:t, looking at the EPA relationship (developed by Hydroscicrice
under con: act to Mitre Corp. arid EPA) in Appendix A of Sin lified ath
> :ode1ir. , 1971, we see that the reference says that the reaeration rate
X2 is equal to a transfer coefficient K, divided by the average deoth.
“In the lover range, a minimum value in the order of 2 feet per day is
an apprr’ximate limit” for the transfer coefficient. Thus Ka 2.0 ft/day
is the minimum reaeration.coefficient predictable by this method. h
There are two major deficiencies in this relationship. First, it
is not logical that all streams of the same depth have the same reaeration
ch racteristics. Second, the more recent work of Tsivoglou indicates
that reaeration is not directly related to depth, but is only influenced
by depth as it is related to crcss—sectional area and time of flow for a
particular stream geometry.
Now, if we look at reaeration rate coefficients as developed.in
Part C — Water Quality Analysis Charles River 1973, 1976, we see on page
25 that the estimated values of K 2 on 9/4 and 9/6 are considerably lower
than those of Table VI—6, Part D in sixteen of the 33 model reaches. As
computed in Part D the 2 values in sixteen river reaches are higher when
river flows are lower, when velocities are lower and when depths are lower
than in September 1973. This emphasizes inconsistencies of the O’Connor—
Dobbins relationship and the EPA relationship in reaeration prediction.
The last part of the Stream Reaaration comment suggests that “alternative
methods of computing K 2 which have been developed for conditions more
similar to the Charles River should be investigated as part of a sensitivity
analysis.”
I agree that methods of computing K 2 which have been developed for
depths, velocities and flows similar to those of the Charles River should
be used in modeling the Charles. This is precisely why the Tsivoglou—Neal
relationship was used. Covar (1976) and Rinard (1976) have examined the
conditions under which relationships by O’Connor—Dobbins, Chufchhill, Owens
Thackston and Krenkel, and Tsivoglou and a1lace were developed. Their
work reveals that none of these more prominent relationships were developed
for velocities less than about .2 feet/sec.
Tsivoglou and Neal have tested, in their Energy Dissipation Model
paper, the accuracy of the predictive models of O’Connor—Dobbins,
Churchhill, Langbein—Durum, Thackston—Krenkel and Owens by comparing
predicted K 2 ’s with K 2 1 s measured by tracer studies. “None of the
models tested proved capable of predicting reaeration capacity within
acceptable limits of error.”
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10.
I would bc happy to review any predictive procedures fcr which
: aif an E. dy and the C have inforitation describir.g their develop-
e c under veloci:y conditions sicilar to those of the Charles River
and based U O actual tracer measur_:.c- : f :eaeration.
Para r2Dh l1 — Photosynthetic O :ygen Production and Respiration
As described in the report on pages 31 and 3 photosynthetic oxygen
p-oduc:ion and respiration rates used in the Septe:nber 1973 calibration
siculat on are those developed by John Erdnann utilizing his DICURV2
model. Thus, the K 2 ’s used in determining the gross rate of photosynthetic
ox gen production via DICIJRV2 are those estimated by Mr. Erdcann and
repozted by the Division in Part C.
, — Kfs as predicted by the Tsivoglou—Neal relationship were not used
‘with DICLR ’2 to give new photosynthetic oxygen production rates for
incorporation in the calibration simulations of the report because there
‘was no purpose to do so. It would have the effect of giving higher oxygen
production rates which would raise the entire solid line profile in
Figures 6 and 7 of the report. This would indicate that the STRL 1 codel
with these higher photosynthetic oxygen production rates more closely
pred cts naxicum D.0. as measured on September 4—6, 1973 than it does
mean or rninimum D.O. as measured.
With regard to the comment concerning “future projected conditions”
there again is evident an incomplete review of :- e report. Page 57. . . ..
las: paragraph describes a low flow simulation in which the peak
photosynthetic oxygen production rates are incorporated. This sinulation
as shown in Figure 16 indicates that photosynthesis can cause near saturation
D.O. conditions throughout the river. However, the discussion points out
that this source of oxygen “occurs only during periods of sunlight, is not
reliable and requires abundant algal populations to sustain it”. In this
case, as in the case of algae utilizing ammonia thereby lessening oxygen
consump:ion in oxidation of ammonia in the river, a water quality problem
(high algal populations) should not be considered as a reliable oxygen
resource to the river.
Paragraph 15 — Conclusions and Recommendations
As explair.ed in the previous comments the major differences between
John Erd-ann’s September 1973 simulations and those of this report are
in reaeraciori rates and sediment oxygen demand races. D.0. simulation
results in the report show a somewhat higher D.0. profile for the September
conditions than do Mr. Erdmann’s (See Attached Figure IV—5 from Part C—
MD PC, as modified) I believe that the work in the report. properly represents
the oxygen resources of the Charles River whether or not it is “unfavorable”
to planning for utilization of the river for wastewater assimilation after
advanced treatment such that some eighty percent of the river will be
wastewaccr during low flow conditions.
-------
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11.
? :es 55—57 of the rc?3rt e: 1ain why alternative tsc at r lo ::-
an a1te ative river c nd::ions were simulated. If ?:eccalf a Ed nd
the :•ijC will recall a : ng with the PC and EP.A at es:bort’,
. u; s: 10, 1977, it was c;reed at that time that year 2000 icw fio :
si ulacions would include alternative waszewdter loading and river co di: c-
simulations.
The scoring system waS developed to evaluate the relative differenccs
betveen alternative simulations and was applied uniformly to all low flow
simulations.
The following comments relate specifically to the four recoriendatio s
or: the last page of the Memorandum.
The low flow simulations have been tested for their sensitivity both
within the work which is described in the draft modeling report and in
continuing modeling subsequent to completion of the draft report. -
First , within the report simulation Cases A, B, and E demonstrate the
effects of varying the nitrification rate constant from 0.6 to 0.2 day —1.
Figure 15 on page 61 and Table 12 indicate that the simulated D.0. profile
is not vety sensitive to varying the nicrification rate constant from 0.6
to 0.2 day . (Cases All and Ell). Simulation Cases G and H demonstrate
the effects of the sediment oxygen demand. Figure 15 and Table 12 point
out that even with zero sediment oxygen demand a D.C. level of 5.0 mg/i
cannot be maintained throughout the river. Simulation Case D demonstrates
the effect of having a net D.C. production due to photosynthesis at the
rates of September 4, 1973. This is discussed on page 57, last paragr: h.
Second , since completion of the draft report additional sensitivity
test simulations have been run. Deoxygenation rates of treatment plant
discharges (K 1 p) were set at 0.4 in the report; rates of 0.2 and 0.1 have
been tested with conditions of Case E simulations as deEmed in the re,ort.
These lower deo ygenacion rates yield a higher ultimate or initial CBOD
thus producing significantly lower D.C. profiles than with a rate of 0.4.
This is shown in the attached printouts of the low flow simulations.
The sensitivity of the simulated D.0. profile to C30D 5 loads in the
uniform distributed flow was tested under Case E conditions by reducing
the CBOD 5 loads to 1.0 mgfl in all reaches. This resulted in no appreciable
change in the D.0. profile as indicated in the attached printout.
In order to test the significance of the oxygen demand of the treatment
plant loadings a simulation was run with CBOD 5 loadings at 1.0 mg/l and with
30D loadings at ze This resulted in a D.C. profile which reached minimum
values for D.C. of 3.5 mg/l behind the So. Natick Dam, 3.7 mg/i behind the
Cochrane Dam and 4.9 mg/i behind the Silk Mill Dam. (See enclosed printout).
This points out that the plant loads are a significant oxygen derranding sourcc.
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12.
F.:rJt 3n rates were d%.mbl d as input to Ca E si ulat or s to
test their se .sitivity. D.O. profiles resulting from this reveal : a:
reaeraci is a najor determinant of D.O. levels in the Charles River.
H :ever. even with doub1in of the rates predicted by the Tsivoglou— eai
thod, there re ains long stretches of river with D.O. levels very mu r
below 5.0 r;/l. (See enclosed printout).
Comment Pre?ared By
Allen J. Ikalainen
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TA5LE I
Ti a of Travel C2libration
Char1 s River April 30 to ay 4, 1973
FLOW !E SLR 1EI T RIVER FLOWJ MEASU? ED2J SIMULATED J
LOCATION cfs TI 1E OF TD!E OF
(USGS GAGE) TP WEL, hours TP VEL, hours
C RLES RIVER
VILLAGE—r.t . 34.3 545 129 113
aT: N—r.m. 18.3 463 164 145
LESLEY—r. . 12.0 483 184 163
i Average of mean daily flows for 4/30 through 5/4, 1973.
jJ Tine of travel between r.m. 76.5 and gaging stations.
-------
R fererices
Covar, A.P.; “Se1ecci ig th Proper Reaeratior Coefficient for Use in
ter Quality Models”; Proceedir. s of the Conference on Envircnnen:al
Mode1i g and Simulation — April 19—20, 1976, Cincinnati, Ohio; EP. .
600/9—76—016.
i ard, I.E.; HCT DOSAC. River Oualitv Sirrulation Model, User’s Manual ;
Halcon Computer Technologies, Inc., ew York; January, 1976.
-------
7L IC C SZ. SITIVI t ’f ZST SDIL’.TIo:;S
The sic si :. 1 tIon upcn hIc the tcsts are ade is iden.ticel
to th t of Case E con.ditions as described in. the Report (page 51-Ta5le 10)
In.this case all plants era diEch rging at 5.0 /i CBOD 5 and 1.0 r /1
L 3 -N. Sedizent oxygen densnd is included as in the Sept. 1973 ca libratlcn
sir.ulatlcn and In-stream nltrification rates are 0.20 day (base e).
JC ;o. s :sITIvIrf TEST
C QD 1OEd].n ifl unifcr r ncff Is 1.0 ! /1.
356 K 1 of plant wastes is 0.20 day (base e).
3 2 K 1 of plant wastes is 0.10 day (base e),
J ll plant loadmn.&s to the river ar 1.0 z;/l only.
3 3 mn.-strea reaeraticn r tes are doubled in all reeches.
-------
rr-i*redcp Er4rh , m r
R ;CLLCSLI ¼r.. I& I. ..
;-mr - : .1 ‘, i:73
‘ ‘ec mr n t’ - ?1 :m-ilz.—
c. ‘c- t..ltt flctr- ct Cc—r.lss!on
—- —‘
; ., : —r’ --’ , - C .V CC .2/:1CtL :-
-- : r :r:st :-
- - - - — - - - -•_ —
— — - ‘ S 1 - -. I ‘b L
- _: : : - - . : --: : ‘o:. - ‘ rt__ 1
t:-v ::-vi- -:;.t-. ::_.t-i :-::t.
:--; ,. c-r tl. :.
- - •‘
• s--:;.: F. :ttz-n -i
.L- ....? •w
L i
I ” -
- - I - — - -
Affit 5 -h. :
-------
• ‘.—‘.... f_,. —.— —
..L
DI 3LVED O:•YGEN NODELING
C EARLES RIVER. ! 4ESACHUSETTS
A signIfIcant part of the materIal presented in the report
was developed by the Commonwealth of Massachusetts DivIsion cf Water
?cilution Control (DWPC) as part of Its Charles River BasIn Water
ual!ty. Management Plan. Some of it was acknowledged ex lIcI:ly an
some was not. It would serve the Commonwealth and the readers If
the material that was taken from the DWPC work were referenced cx-
plic±tly. On the other hand, the departures from the 3asln Plan and
the basis for them should also be identified because the 3asln Plan
Is resently the approved document for pollutIon control and waste
load allocations in the Charles River BasIn. Therefore, any changes
must be explicitly shown so that the Plan can be amended accordingly
where such changes are adopted.
The report Preface IdentifIes the purpose of the report as
being “part of the wasteload allocatIon, facilIties planning and en-
vironmental im act assessment procedures underway” In the as:ern
: :assachusetts Metro olItan Area (Er !A). However 1 wasteload alloca—
tICfl Is the responsibIlity of the DWPC through its basin planning
process for which a resulting approved basin plan exists for the
Charles River Basin. FacilItIes plannIng with itS envIronmental
i ;act assessment, on the other hand, is the responsIbIlIty of the
!DC a.id the municipalities. In the case of ?WC, thIs process
is not being carried out at this tIme due to the prerecuislte EIS
being prepared by the EPA. The document under review here Is a part
of the EIS and not any of the above.
The report Conclusions and Recommendation do not follow the
data base reported upon in discussing treatment relIabIlity and
economic and environmental impact costs. These are not addressed
in the report itself. As an example, a recorr endaticn is made to
lImit future service areas without an analysIs of alternatives or
ccr.secuences, yet a conclusion is also made that septIc leaching cc—
curs into the Charles RIver.
The following review has not included a check of the model-
ling formulation and the input data base whIch should be made. As
examples, some of the rate constants used In the mcdel are tempera-
ture corrected while others are not, and the Mother Brook Diversion
is Incorrectly located in the runs representIng projected conditIons
whereas it Is correctly located for calIbratIon runs.
In evaluatIng the calibratIon effcr:s and fIndIngs, it must be
understood that hydrologic condItIons were quite varlabl C durIng the
calibration erIod, that data fcr d!schar es used In calibratl:n are
for conditions one year later than the stream water qualIty survey
-------
an : -.at a siznificar.: com:cnent cf the Inout da:a a e usa
f r caii ra:±cn Is assumed.
DurIng the water qualIty survey period used for calIbration,
stream flows were ten times those of the low flow period. During this
time, the average daily flows varIed by more than thIrty percent as
a result of signIficant upstream raInfall that occurred just pricr
to the survey period. The time of flow n various parts of the river
Is a signIfIcant modeling parameter and, In thIs case, it was devel-
oped from relatIonships formulated for freely flowIng streams wi:hcut
dams. The constants for this relationship were developed under flow
conditions that were about three to four times those during calibra—
tion; but about thirty times those later used for modeling of prc—
jected future condItions. DurIng the extremely low flow regIme In
an area with im oundments the time of flow must also lncorporate the
hydraulIc efficiency of the impounded areas. WIthout such an analy-
SiS, a larger time of flow may result.
With respect to the waste discharges used, the dlfferences In
operating procedures between 1973 and 19714 must be revIewed. For
example, in 1973 Cott Corporation discharged its wastes to the 1111—
115 wastewater treatment plant. In 19714, however, It dIscharged
directly to Sugar Brook.
A number of values Incorporated in the calIbratIon process
were assumed. Assumed values for nonpoint sources total to 140 percent
cf the total wastewater point source discharges. Simliarly assumed
are sludge deposIts which are formulated to take up as much as 3 ng/1
of dIssolved oxygen, or nearly 140 percent of the river’s oxygen re-
sources.
Another sIgnificant factor in the calibratIon Is the photo-
synthetic oxygen production and algal respIratIon phenomena. As
modeled, ifl some locations of the Charles River, this, combined with
sludge deposits mentioned above, can take up as much as the entire
river’s oxygen resources. The basic formulation assumptions of this
and other parameters are dIscussed later. Here the dIscussion cen-
ters around their use in the calIbration process as presented on
pages 32 through 35 of the report. Figure 6 (page 3 ) presents the
sImulation of zero photosynthesis and zero respiratIon (dashed line)
su eri pcsed on the range of four measurements (two night time and
twc day time). With zero respIratIon, the simulation should show a
favorable DO condltion as compared to DO measurements at night zinc
which Include respIration. As shown on Figure 6, the simulatIon
generally falls below the measurement range indIcating the need for
a revIew of the modeling oarameters used. A further need Is to re-
view weather condItIons surroundIng the 1973 survey period to insure
that all factors are consIdered in the evaluation of the photosyn-
thesis and algal respiration phenomena. For example, the weather
condItIons discussed on page 36 of the report do not fully cover the
survey condItIons as shown in Table 1. For example, the favcrable
water ouail:y in the Charles RIver on September 14 can also be ac—
:ri5 ted to ItS increased flcw resulting from the September 1 rai .—
f 1l as well as favcrabie sunlIght condltions on that day.
-------
TABLE 1
AVI I1A0E DAILY RAINFALL AND RIVER FLOWS iN TIlE ChARLES RIVER BASIN AREA,
SEPTEMBER 1 TO SEPTEMBER 10, 1973
Location
Boston WSO
Blue hills
Frami ngham
Wa] po le
West Medway
Fran Ic 11 n
Milford
Char)es River
at; Charles
River Village
1.3 11
1.01
.36
98
115 120
116 103
88 99 125
(1) no rainfall
(2) ti’acc
:ia1Irce
1. UniLed 3taLes Department of Commerce, U.S. Weather Bureau Climatological D La: hew
I•:n 1an(1 , Vol. 85, No. 1, Asheville, N.C. , January, 1973.
2. tIn I t.ed SI;aLc Department of the Tnter br’ , (leol optca) Si rvey , WUer__He ;oi I ni
fin r.achiu;cL L3 , New Ilnmpsh Ire, Rhode inland 1 Vermont , Ilonton , finns . , ] 973
1
2
_(1) .01
3
02
.07
It eiri
Rainfall
(inches)
Iliver Flow
(cfs)
Time, days in September , 1973
T(2) ‘F .1111 .1 11. 1
1.30 — —
U 9 T1
.27
.18
.39
.60
.08
.78
—
80
1.80
.68
1 311
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: : €r— ca1 xv enat n Rates
In the computer modelIng effcrt, deoxy nation rate :cn—
sta:-its, K,, are input In associatIon with the wastelcad charac:eris—
tics of tfle fol1ow ng fIve areas:
1. background K,
2. stream K 1
3. treatment plant dIscharge K,
14 tributary K 1
5. unIformly distrIbuted flow
WithIn the model, all of these K 1 rates, except the stre -n K, , are
usec only to compute the ultimate BOD. All decay occurs at The
stre K, rate. ThIs results In the followIng ultimate 30D concen—
;rati.ons entering the Charles River in the year 2000:
Source Ult. 30D m /l
background 10.7
treatment plant 5.8
trIbutary flow 5.1
unIform flow
above r.m. 141.1 6.0
below r.m. 141.1 9.0
The background conditions reflected above were used in bc:h the
1973 calIbratIon run and the 2000 low flow runs. These loadings seem
ex eeding1y high, particularly for year 2000 condItIons.
In regard to treatment plants, in the year 2000 simulatIons
the report used a decay coefficient of 0.140/day. SInce these plants
would be advanced, the organic material remaInIng will be resistant
to decompositIon and therefore a lower K, rate can be justIfIed.
As mentioned previously, all deoxygenation Is carried out at
the stream K rate. In the computer simulatIons, the same K 1 rates
were used in the year 2000 runs as In the 1973 calIbration run. I;
has been shown that as water cual ty conaIt ons im rcve, tne ceoxy—
genation rates decrease. Therefore, with the anticIpated u zradThg
of the Charles River water quality, K 1 rates should decrease under
2000 condItIons.
-------
: : :‘o:encus Oxida:ior. a:e
In the modelir.g effort, the report a umed the : : s
decay rate to be .6 day 1 (or 2 day ‘ n sore casec) 0 6
value is extremely high. All treatment plants considered in the
investigation d scherge dis nfected effluents to the rIver. Chlo—
rination effectively kIlls all n1tr fy1ng bacteria in the discharge.
ffluents not carrying theIr own seed of nltrlfylng organIsms are
subject solely to the natural seed occurrIng In the river water Cr
in attached growths on the bottom and on submerged cbjects. In
addition, ammonia is a prime nutrient for certain for s of algae.
With’chlorination of effluents, these algae will pcssibly make
zreat inroads upon the ammonla supply and thereby reduce the amour.:
of ammonia avaIlable for oxidation by nitrlfylng bacteria. Also,
the range of oxIdation rates found in the reference cited by the
report is actually .i to .6 day —1.
Da Reaeration
The report chose to represent this phenomenon by a reia:i:r.—
Ship developed by Quirk and Eder. This relationship was developed
to represent reaekation through a vented turbine and not for free
fall over a dam. Due to the lack of data, the authors used a linear
relation between Fd(Q) and Q which passes through the origin. This
assumption results in low reaeration rates under low flow con :icms,
which is not correct for a free fall over a darn when more cf the
overflcwlng water mass is exposed to the air and subject to reaera—
ticn. A representation of darn reaeration which relates reaerat cn
to the height of fall over the dam, such as that developed by
Mastropietro or Foree, would give a better representation of actual
darn reaeration under low flow conditions. Such a formulation was
also used by the DWPC in their Basin Plan.
Stream eaeratIon • 2
In—stream reaeration was computed usIng a relationship deve—
oped by Tsivoglou and Neal. The relatIonship states that the
reacratlon rate in a reach is a functIon of the change in water sur-
face elevation along the reach and of the time of travel :hrc gh the
reach. The authors caution users of their formulation in applying
it to rivers whose physlcal characteristics are predcmir.anzly con-
trolled by dams.
As an example, for the projected future conditions, the ‘s
computed under thIs method are on the order of ten :ercent of those
used by the DWPC in a number of reaches. Therefore, alternative
methods of computing K 2 which have been developed for conditions
more similar to the Charles River should be ±nvest!gated as part of
a sensitivity analysis.
-------
Fs:: e:io C’xy en ?rdu::ion and
The e:hod of acccunt ng for pflOoEynhe5 E and reEra: .:
Lsed in the report modeling was based on work perfcr ed by the :.?:
using the systematic diurnal curve analysis. The baslc fc aticn
Is: = K 2 (C 5 —C) + — R,
in whIch:
DC
= the tIme rate of change of DO concentratIon,
= the rate of atmospheric reaeraticn,
K 2 = the atmospheric reaeration constant,
Cs • = the DO .saturatlon concentration,
C = the DO concentration,
P = the gross rate of photosynthesis by the cc unIty
of algae and plants in the rIver locale,
= the gross rate of deoxygenatlon, including res-
piration and nitrification, by the entIre cc r.munI:y
of organisms In the river locale.
In 1973, the !VDWPC conducted DO measurements on the Charles
iver. These measurements, together With the determination of
resulted in a relationship from which P and could be determined.
As can be seen, the value of H — P is dependent on the value of K 2
used in the analysis. The value of R, so determined, is a total
deoxygenation rate which includes CEOD, NBOD, and sediment dei and.
Therefore, in goiflg from the total deoxygenatlon rate to that rep—
resentati th of algal respiratIon, all other oxygen demands must be
subtracted. This process is in turn a function of the C3CD and N3cD
decay rates and the sediment demand.
In the model calibration pràcess used ifl the report, the values
of phctosynthetic oxygen production and oxygen consumption due tc
algal resciration aDoear to be those as determined by the D •ZFC usI z
theIr estImatIon of K 2 tS. However, when the photosynthesis values
were Incorporated into the river basin model for callbrat!cn and for
simulatIng future projected conditions, the report used the lower K 2
values as dIscussed earlIer. In addItion, under the future rcjec:ed
conditions, the input values of algal respIratIon are the saie as
the 1973 calIbratIon runs, but the values representIng photosyn:he:Ic
oxygen production have been greatly reduced. If anything, i.t would
seem that the photosynthetic oxygen production would increase under
the culescent low flow conditions. The basIs for the manipulatIon of
D ?C’s data In the 1973 calibratIon run, and the basis for the dras-
:ic reduction in ho:csynthetIc oxygen productior. w!:ile cxy en c:n—
sur ::icn by algal respiration is not reduced in the pro ec:ed
cbndl:ion simulations, need to be determIned.
-------
— r — —. • c — — — — — —— — — — _ —
The EIS ?.epcr; has çresented res it cf cdel c :: c i
forts for the Charles River DO resources which are si .lar :c re :
of a lIke effort by the DWPC 3asln Plan; however it uses si .car:—
ly dIffering factors. In the EIS eport, these factors are selected
on the side of an unfavorable oxygen resources representatIon In the
river.
The calibration effort also includes a number of assumed val-
ues which have a significant impact on results.
Several alternative projected future condItIons, as well as
scne crianges in factors, have been simulated. The basis for their
selectIon is not ex laIned. A scoring system was used to measure
the alternatives which appears to be rather arbitrary.
We recommend that:
•a thorough evaluation be made of each factor and each
assumed value,
• the range of confidence for each factor be developed
on the basis of present data,
•a sensItIvIty analysis be conducted to Identify those
values havIng a sIgnifIcant impact on decIsions and
requiring a narrowIng of their confidence range, and
•Investlgatlons, includIng, if necessary, field mea-
surements, be conducted to achieve the necessary
narrowing of that confldence range.
-------
f UN TE STATES ENVIRONMENTAL F OTECT;O:
REGI3N I
.tc
F FE EP L PUILD:NG. B0 TON. 3
July 22, 1977
:s. Libb” Blank
Director of Environmental Planning
4etro olitan District Commission
20 Scmsrset Street
Boston, !• 02108
Dear Ms. Blank:
Thank you for your letter and comments of July 18, 1977
with regard to the Charles River water quality ode!in .
We will respond in detail to each question raised by
I etcalf and Eddy by August 10, 1977.
Please understand, ho :ever, that the computer odeling
of the Charles River which we are performing is based
u on our understanding of the Charles River and oui
deteri inations of proper mathematical representations of
river processes affecting water cuality. Thus, our
final model simulations zi11 incorporate any necessary
corrections to the model input revealed by ietcalf and
Eddy after considering each of their comments.
I have attached for your information a copy of the letter
which we sent to Dover, Framincham, fledfield, N tick, eed-
ham, Sherborn and Te1les1ey reciuestinc their artic ation
in an expanded site selection committee. We would welcome
your participation with us and the communities in the site
selection process. e will notify you as soon as we re-
ceive responses from the communities and set the first
meetinc7 date.
Sincerely yours,
£ Y OLLL
! ary E. Shaughnessy
Environmental Impact Analyst
-------
f “ ‘ UNITD STATES ENVIRCNMENTAL PROTECTION AGENCY
REGION I
J F. KENNEDY FEDERAL BUILDING, BOSTON YASSA iUSET1S 02203
,\utjunl 5, 1977
. Libby Blank
!)Ir’ ctOr of Environi enta1 Planning
c 1 O1It )n 1 )jstrlCt Cc ission
..‘ I ,oia.rsCt 5tre t
I);t’)rt, u21 3
I) ’ t M . clank:
This is in response to your letter of July 18, 1977 to t1S.
; . i .y Shaugnnessy of t)’! vLruILIIental and conornic I act
OLLic’ concerniny tne dater ‘quality modelinc of the Charles
uver and effects of tne ?ro D;:fl — i ries aste ater
treatment plant. I itin; te you directly because I am
the person doing the odc1ing. 44’ C. ’Lt arc- used by the
Cnvironn ntal ani Ecorao ic Irn?act Office and their
consultants in er for i j : .. •‘1.:: .: t: i ssessn ent of
the pro7osed tr . atrt nt lt rri tives for the system.
First, I will revie4 ou: in tne C. arle ver
iaodelin’j and Ln n res c. to the juetions by etcalf and
Eddy, Inc.
In June an Se te ber, 1973, the assac u etts Division of
beater ?o1l tion C itrol, ( D C), conducted water u li j
surveys of the Charles River etween ilfori ai
isssachus’ tt ;. ata fro.i these surveys was used to set u
the streai ode1 of the ;.: •; c Lor simulation of water
qual it ; ., i..; )urin, the .June a’ J c ,te: ber sur’ evs.
The stream model is t iat : escrihe in Syst .i5 \ n 1ysis for
iater Po11 ticn Control 5 . uirk, Lawler ani T3tus y, June
19 _Il.
iir. John Erdr ann, formerly of the D. PC perfor.nei the model
set u i;1 i! ’Jl tion of the June and Septe r.5er survey
conditions, a process tcr. ed rnodel cal br . tion. At tne
request of our n iironr.ental an) Economic I. pact Office an
with the cooLeration of ; ir. Alan Cooperrar. of the ND. 1 ?C, I
obtained tne Charles Riv r c,]’ l . s calibrated by 4r.
Erdmann a nd developed a simulation of the Char1e Riv2r
unoer 7—day, lu—year recurring low f 104 c’)nditionS for
COI 9aLiS ).1 with dater quality standards. Tnis si 1 ulation
was done usinj the ?A v. rs•ion of the stream model progra’n
which is analacous to the i D.cPC stream model program.
At the pres- nt time, the rr.o elirkj is being done with the
steady—state option of the model and we are si,ru1atir
-------
I tcrr t Ve trectT flt plant locatior.z ar.. ± r
criL C ) r i1ty COr d1tlC .Z. T: : —s •: o :::-
is bein J u30d bccE.use tno port cn Of tne r oue1 ?o-:r: .u;-
L• - o urn l Ls )lV ’J ox en v riat:on due to
noio ynt iCSiS was found to be incorrect. Tl is_•no _i ;
snoulc3 be co.n ’lcted by the end of tne month and the fine!
results will be reporteJ in aetaii—k sU concerne3 -)art1e .
NOW, in responding to th questions by •1etcalf and Eddy,
Inc., I will comment on each as presented by them.
QuestiOn 1: Projected Upstream water Qualit Conditions
Water quality conditions upstrea: of the .outh Natick
Dam, .; ;i ulated, are those resulting from stream
conditions as we preJict thei to be and ei ted
wtC4Jt L loadings horn th various treatment plants
discharging to the river in the year 2033. irie
waatewater loadings for •lilford, the proposed Charles
River Pollution District, • rentham State School,
Norfolk—. elpole £• CI and !•:edfield—’4illis are.thg
estimated to be disc ar’jed with the respective
treat!! e’ t • l nt configurations producing their hignest
quality effluent achievable. Loa incjs ani flo. were
determine.5 by t ie Environment3l . ; essment Council,
Inc. and Greeley and Hansen, Inc. after revie : ng
information on tne facilities currently being planned
for the various communities. Results of modeling under
tnese cond!ticns indicat- that it will be v rv ikeav
that certain stream reaches u3stream of the South
Natick Dam will not meet water uality standards for
dissolved oxygen under year 2CO 3 conditions. :nere—
fore, it is erroneous to assu: e th water quality
standards for dissolve 1 o y; n will be met under
critical low flow conditions in ll upper river
— reaches.
Question 2: Prcjected astew ter Flows
The anticipated edfield— illis facility was initially
simulated witn a wasteJat2r flow rate of 1.5 million
gallons per ciy (ngd) her e.ise that is the desi;n flo’
capacity of t e exjstin.3 Me’5fi i treat;nent plant. T e
projecte t’ t r flow for b tn co,ni .mities cotbir: d
in the year 20C3 is estimated to be 3.0 ngd. T.- e modal
has beei c. nrjed to reflect effects of the entire
3.0 mgd.
Question 3: Stream Rer tion
In reviewing the calibrated model by Mr. Erdmann and
-------
tne sl d : i’: re:c.:t.2: i t 1976 C .::1
River .ater ; t zn wa
seen that the rc cr tion coc i:i r. as co ted
theC Connor—Dcb is isotro i T -h - -’.c’ rel t:or.z :.
Tnis relotionship is !nost valid for use with streams
having ocptns of 7. 3 to 12. feet ‘ icit1es of
0.5 to 2.5 feet r second. Under conditoiis of 7—n. .,
1( —year recurring low flow the water depths aior J t e
entire river are co : 1 puted by the model to be between
1.0 and 10.5 feet 4ith velocities of C.C5 to 0.55 feet
per secoi d. Thcrcfore, the Tsivoglou—:9a1 ner.;J
Diasipation relot on hip was used to compute the
reaerat.ion coefficient. The reIationsn p is valid for
str .i f.low and asso iated deDtns and velocities in t e
range of 1.0 to cqbic f€at per s2cond, which
icludes th’ range of flows along the entire Charles
River durin j lo flow conditions.
The Tsivoglou—Neal relationship includes the change in
water surface elevation along the longit dina1 strea.
profile, the ti e of flow within the stream and a
coefficient terrn related to flow rate. Receration
rates within each river reacn ere co— it 3 using the
proper coefficient for stream flow, the ciange in water
surface elevaticn as taken fro Corps n i,eers
profiles of the river at low fic;; and tne time of f1o
as co:nputed by the ode1. These and o: r ter s for
river reaches 17 tnrough 22 are sndwn n tne attached
table.
Regardin’j ietca1f and Eddy’s co :ent on the “choice” of
reaeration coefficient values and ass tions of
sedirr ent oxygen de .and rates; the reac-ration rates are
co itout J L âCh by reach as oravio sly exDlair.ed h1J
sedi 1 nent oxygen de and rates were assu ei cOi rLn
available data. 3 j. ent de ar.d is ass ed to e
present in the river within reacnes upstres o the
da s and where stream bo to ateria1 analysis
indicates or;ani: sediment is rese it. As sho n in ti C
attaciieo table, seoi 1 nent oxygen ce ano is ioc t
behind the Soutfl tick and Cocnrane Dams and in loAer
velocity reaches.
In the table, note that the receration coefficients for
reaches 20, 21 and 22 as input in the sinulations
reviewed by £•ietcalf and Eddy were in error as computed
and ha ie since been corrected.
Question 4: Dam Reaeration
The value of the model input variable for dam
-------
rcaer3t Q .1) .t the Sc jt iat Ck D w
origlfl3llj iflto tne model as Tn’ val’ e
shauld n :e n U.{J088. :odel in ut h s been
correct t :iic value. The discrepancy CC’)’J C f
th larL3 difference in dam rearation between tne Souti
Natick and Ca hran : )..ns.
Question 5: Deoxy enatiofl Coefficient or Nitrogenous
1 qcn Denand
The modeling described in the Charles Rivet t r
Qu.ulity 1anage ent Plan is sii lifi. I rocedurc which
considers car onaceou hiocnc ical oxygen den
njtro nous oxven cemand a . one proc’ -; uccurrin; r.
one rate and tnercf.ore both rate constants must be tne
sami . T: u3 stream nodcl colisilers thc’;’ •)tOCC CS
separatc y as they actually occur in nature. The
deoxyjenation coefficient for nitrification of at
2G°C is a hign value which results in the a inonia
concentration simulation comparing sell with the
Septe’ bet 1973 a rnonia concentrations as measur. d in
the river. Also, th higi v hie is a logical
ascui ption consid?rinj t at when the four major
treatment plants on t ie river are operating as advanced
biological syst .ns the river should continue to have a
well est.ablisned population of nitrifyin j or is S.
Because tha jdel is well calibrated for an on a a d
high po;ul3tic .s of nitrifyir. j organi3. S can be
expected in t’.e rivur in the future, the assi ed rate
of O.G is valid.
In summary, the modeling is contiuing as explained he eir..
When final results are available, tney will be sent to all
involved parties for review.
I hope this explains my position with regard to the r 1 odeli g
and should you have ny further • uestions please do not
hesitate to contact me.
Sincerely,
Allen J. Ikalainen
Acting Chief
Systems Analysis Branch
cc: i. Shaughnessy , EPA
A. Coopern n , l ?c
,L. Gitto, EPA
“j. Vittan )s, Metcalf and Eddy, Inc.
I. Polese, MD ;PC
R. Chapin, EAC
-------
c ; s:.:S RIVF.R ‘.:zo r.
vsTE;S \::,\I.v I i,v;c i
— nzcio:; I
RIVER RflJ CIIITS
17 TIIRU 22
Sediment
Oxygen Demand
( ranis /irt /dav
Ve1ocity /
Ft/Sec —
.07
.08
• 19
.12
.45
.32
Low
F low
Depth
Ft.
4.8
5.1
2.5
7.5
2.8
7.0
Time of ’
Flow
Hours
10.6
53.6
12.5
56.2
5.2
14.9
Change in Elan
of Water Surface
Ft.
0.5
2.0
0.25
1.45
1.0
2.0
Reacra tionE’
Rate
Day
0.06
0.05
0.03
0.04
0 .27
0 . 19
a/ Reach
— Reach
Reach
Reach
Re a c h
Re a cit
17,— flogastow Brook to Medfielcl hospital — 0.5 miles
18 Medfie1d Hospital to South Natick Dam — 6.7 miles
19 — South Natick Darn to Waban Brook — 1.7 miles
20 — Waban Brook to Cochrane Dam - 4.8 miles
21 — Cochranc Dam to Che5tnut Street, Nccdham — 1.6 miles
22 - Chestnut Lreet, Needham to Long Ditch Inlet — 3.2 miles
b/ Proposed MDC plant located at head of Reach 18
H each
17
3.46
18
3.46
19
0
20
1.38
21
0
22
1.38
C, Coefficient for Tsivoglou relationship 0.060 @ 25.5°C
-------
:i :: a:-k
irec:or of vironne.r tal ? .anning
: :e:rcpcli:an istrict Ccr.zission
So erse: Street
.— ——
— . ., ...t J . . .VLi
arNs. Plank:
:— re cnse to the recuest by NDC we have ccnduc:e a brief
‘ E:s Consuitantts Charles iver odeli g effcr :s
assccia;ed with the location of the 1iddIe Charles azellite
:as:e ater Trea: ent Plan:. S ec1fically, we have reviewed the
f:Li :in dccuren:s:
a. . eri:rar.dw :or. r.?. :hap of the virori-
en:al essnent c incil, Inc. (IS Ccns l:ant)
:c :ary Sha gnnessy cf EPA, descri : six eJn
cases and reccn e in that the scharge of the
subject plan: be Thcated as far u :rean of the
cuth azic : Daz as ;cssib.e.
Cc :uter ou::u; from the odelir.g of Case 3A described
in the P15 Consultant : er crandum.
r ana.ysis has focused on the assumptions and pa’a eters used
in :ne c:n:u:er mcdelir. effort. : :h s review, we have assuned
:he :ara e;ers used i . Case 3 are the same as those used in
the cther fi :e :ases described in the E S Ccnsultant :• eno’ana
that f.r- : e :as:s fcr tneir reccr. endation. ! cwever, in
:-e 0 :.c:s : e E3 Cc s :a t e cra o ’ —a’ es ::s as—
s n:::cn : stionabie s:ecifically because of he peculiar :ic:s
for Cases and 3 between river r.iles 35.7 and Conp :er
runs for other than Case 3A were not supplied for review.
o initial review, we raise aues:icns in the fcllowin areas:
I. Prciected a:er a.i:: cnditicns . In a1.
six of tne cases considered :y tne 1 Ctnsuitant, sent_s
viclat ons of Class P :ater cuali:y standards are nc ec:ei
f:r severa cf the sez en:s u:szrean cf the Scu:h ::a:i:
the rea:hes i . dia;ely upszrean cf ; e
da :here a C of :eno is :rc ec:ed as a result of
:reat effluent beds, i.e., excluding the i iddbe Chan.es
is ioocr:ant to :now the extent to which
E5 Ccnsu:tan: t s reccr endaticns relative to the i de
— __ . __ . .. __ . —
- .._..
-...:—.—: :—.-
-------
; a:er c ua.i:y. In ncdeling the River under the :.ear
2000 conditions, shoud it not be expected that ut—
stream discharges w ll be treated to the point wnere
wate:’ ua1ity standards wIll be met?
2. ? z’o ected Wastewater F].cws . In the EIS Consultant’s
modeling, ;ne Charles River i assumed to receive
1.5 mlll!on gallons Der day (:n d) of wastewater from
a cc b ec ecf:el — 1lisfac:1.:y in tne year 2C00
: cwever, the DW?C ifl its basin planning has repcr:ed
flow projections of 1.0 mgd for each commun Ity in 19E .
ProjectIons in the study also show larger values
for the year 2000. In the EIS Consultant’s mcdeling
work, were changes made n the sewerage servIce con-
cepts In that location to warrant the reduced effluent
d s charges?
3. Stream Reacration . The values of the coefficient cf
reaeration ( ‘. 2 ) used ifl the model are consideraoly less
than re crted in the 1976 Water uality ?lanagemen; P:.an
c.f the Massachusetts Division of Water Po.lluticn Control
(DW?C). The attached table comoares these values for
the eleven reaches on the Charles RIver of interest :0
the ±ddle Charles plant analysis. ifl the nine reaches
not considered to be “rapids”, the values cf used
in the model are L1 to 96 percent less than those re-
ported by DWPC. Reach 21, immediately below tne
Cochrane Da . •:alue of • 2 as increased to reflect
the higher reaeration rate expected in this so—called
“rapids” section. The value, however, is only acout
one—half that used by the DW?C. Eowever, In the other
“rapids” section (Reach 19, just below the Scuth a:ick
Dam), a K 2 value was used that is amcng the lowest as-
sumed by the EIS Ccnsulzant anywhere. This choice of K
is inconsistent with the assumptions on benthic oxygen
demand made in the EIS Consu.tant’s :emcrandum. On the
other hand, ifl the lcng flat reach between the Sou:n
Natick and Cochrane dams (Reach 20), a : value was
used almost ecual to that used at the Cc hrane Dam
“rapids”. What is the basis fcr significantly cnanging
the DW?C parameters?
Da- eae at o . The DW?C used f 4 eld sam 1ing data to
conclude that :ne South Natlck and Cochrane d s have
equal values of the reaeraticn deficit ratio. he ::
Consultant used a similar parameter, the reaera:icn
f nc:ion. Thus, one would expect the two dams to be
-------
cnarac:eri:ed by ecual values of P’d ( ). Ecwever,
the EIS Consultant modeling work is based cn in u:
parameters that give the South atick Dam a reaera i:n
ca ability nearly nine times that cf the Cochrane :am.
What is the basis for this significant change?
• Deox:: enaticn Coefficjent for encus Ox1zer’.
Demand . The model ou: uts :roducedby tne ES
Ccnsuj.tant are based on a value cf 0.67 for the
nitrogenous deoxyger.ation coefficient n all reaches.
This is markedly hIgher than the 0.2 value used by
DW?C. Again, the basis for this change needs to be
det errnlned.
A: this time, we have identifIed five areas •.:here the sé:.ec:icr.
o: parameters are expected to impact s:gnl ant .y :ne con:_u—
sicns cf the EIS Consultant’s Memorar.duzn.
It is apparent that an item by item review of the mcdeiing da:a,
and cssibly the Program formulatIon is needed as tne next step.
cr the significant model parameters, the range cf confidence
cu be identified and their sensitivity should be de:ermine .
acme :arame:ers can be fiei.d checked easily. An exam;.e cf s cn
is the reaeraticn capabIlity at the critical dams.
Due to the recent attention given to possIble discharge lcca:icns,
1: is recormended that MDC review with DWPC the following prc::se
ne:•:: ste:s.
1. Detailed review of all input parameters.
2. s:a:lishment of a cssIble range fcr each siznifi—
cant parameter.
3. eview of the Program formulation.
i. Senslti7ity analysIs of parameter ranges wIth
res:ec: to a decisIon for the desired locaticn and
required effluent cuality for a Middle Charles lant.
A; a minimwn, modeling runs should be made wIth the above—noted
changes, to determine the Impact on tne S Consultant’s ccnc -.
sion relative to the discharge location.
7 j t” veu s,
‘I —i’ .’s
b.:. : zs
-------
C0MI AI I :;oi i 0i•’ Ui .:AI•:UA’i’i oil (Ic 2 ) VAI. IE IJ:;l•:I)
;ii r,a i. Urook 119 . 9
‘10 . 3
‘I [ . I
39 . 1
3” . 6
33.0
29.1 1
2I 1 . 2
21.2
20. 2
16 0.056 0311
Ilecel ve 1 I :r.harge Iiouii
Medf Ie]d—MllJ I:i
I1ui ,u:; Low Urook
Mud 1 I e id Ito Lp1 La 1
HaL. tc k Daiii
t’Jn L tii Ui’oolc
( ucIirane Darn
Clic : Liiii L SILeC I;
l.nii ç Ditch f i ii eL
1•lu 1.1 iu i fli’ook
:;; w I I .1. I r()c)k
Ii •;iilow fli’nc.’Ic
I I Ic 11 i :i i i)ani
Il:;ci l by 111 Cons i I LniiI. roi’ iro.Iec Led Yeat 2000 cond It; Ionn
J:;uI by I1Wl in CIi ir Ieu l I vc %dat.ur Quit] I ty Man igemerit. Plan For p ojec Lcd Yeai 1 9t1
i: 01 v i i I I cii i :;
H lver
:‘ .LZL I I on nil 1 e
No
Ileach
.
Vjlue:; oF
--
Fl 9(1)
1(2 (h H;e
e)
—
2) lb ie ;
nwpc (
17 0.1115 0.35
0.056 0.33
19 0.033 0.82
20 0.5117 0.25
21 0.569 1.1
22 0.089 0.29
23 0.033 0.22
2 I 0.011 0.30
2’i 0.022 0.27
26 0.13 11 0.2 11
“Rapids” (hole low E [ 1 K 2 )
( hole high ETS K 2 )
“flapid:i
Diversion to Neponsel I(Ivt i
-------
• _•__ :.
‘. •__
ENVIRO’ M NTAL
PLA .NING OFFICE
rt 10.
Ms. Mary Shaughnessy
Environmental Section
Enviroriniental Protection Agency
J.F.K. Federal Building
Boston, Mass.
July 18, 1977
.L c i 11? 1?
Re: E NA EIS - Charles River Water
Quality
TEL.. 7z7-eae
.Dear Ms. Shaughnessy:
At
quality
plant.
our request, Metcalf Eddy, Inc. has reviewed the Charles River water
modeling data relative to the proposed Mid-Charles wastewater treati ent
The following are comments provided to us by Metcalf and Eddy.
“Specifically, we have reviewed the following documents:
a. A memorandiun from Mr. R.W. Chapin of the Enviroriniental Assess”ent
Council, Inc. (EIS Consultant) to Mary Shaughnessy of EPA, describing
six modeling cases and recommending that the discharge of the subject
plant be located as far upstream of the South Natick Dan as possible.
b. Computer output from the modeling of Case 3A described in the EIS
Consultant Memorandum.
Our analysis has focused on the assumption and parameters used in the
computer modeling effort. In this review, we have assumed that the parameters
used in Case 3A are the same as those used in the other five cases described in
the EIS Consultant Memorandum that form the basis for their reco endation.
However, inspection of the DO plots in the EIS Consultant Memorandum makes
this assumption questionable specifically because of the peculiar plot for
Cases 1 and 3 between river miles 39.7 and 40.5. Computer runs for other than
Case 5 were not supplied for review. Based on our initial review, vC raise
questions in the following areas:
1. Projected stream Water Qua1i r Conditions . In all six of the cases
considered by the EIS Consultant, serious violations of Class B water
quality standards are projected for several of the segments upstream
of the South Xat±ck Ds. in:1uding the rea:hes ir .edia e1v trea - ‘f t-.e
/_•
....,/he C,’ I , a . .. aC/’!’ ‘
2i2 i ’me,. .°/ S4 ee t zd .n O&1O8
-------
dim here a DJ of :ero is projected as a result of pstr a.
cffluont loads, i.e., excluding the idJle Charles plant. It
is i iportant to ow the extent to which the E1S Consultant’s
reconr endations relative to the Middle Charles plant are influenced
by this modeled uvstre3zn water quality. In modeling the Rive
under the year 2000 conditions, should it not be expected that
upstream discharges will be treated to the point where water
quality standards will be met?
2. Projected Wastewater Flows . In the EIS Consultant’s modeling, the
Charles River is assumed to receive 1.5 million gallons per day
(mgd) of wastewater from a combined Medfield-Millis facility in
the year 2000. However, the DIcPC in its basin planning has reported
flow projections of 1.0 mgd for each community in 1985. Projections
in the E’Mk study also show larger values for the year 2000. In
the EIS Consultant’s modeling work, were changes made in the
sewerage service concepts in that location to warrant the reduced
effluent discharges?
3. Stream Reaeration . The values of the coefficient of reaeration (K 2 )
used in the model are considerably less than reported in the 1976
Water Quality Management Plan of the Massachusetts Division of Water
Pollution Control (DWPC). The attached table compares these values for
the eleven reache.s on the Charles River of interest to the Middle
Charles plant analysis. In the nine reaches not considered to be
“rapids”, the values of K, used in the model are 44 to 96 percent
less than those reported y DWPC. In Reach 21, iii nediate1y below the
Cochrane Dam, the value of K, was increased to reflect the higher
reaeration rate ex-pected in this so-called “rapids” section. Tne
value, however, is only about one-half that used by the DWPC. Ho ever,
in the other “rapids” section (Reach 19, just below the South Natick
Dam), a K, value was used that is among the lowest assumed by the EIS
Consultant anywhere. This choice of K 2 is inconsistent with the
assumptions on benthic oxygen demand made in the EIS Consultant’s
Memorandum. On the other hand, in the long flat reach bet een the
South Natick and Cochrane danis (Reach 20), a K, value was used almost
equal to that used at the Cochrane Dam “rapids . What is the basis
for significantly changing the DWPC parameters?
4. Dam Reaeration . The DWPC used field sampling data to conclude that the
South Natick and Cochrane dams have equal values of the reaeration
deficit ratio. The EIS Consultant used a similar parameter, the
reaeration function. Thus, one would expect the two dams .to be
characterized by equal values of Fd (Q). However, the EIS Consultant
modeling work is based on input parameters that give the South
Natici: Dam a reaeration capability nearly nine times that of the C zhra.ie
Dam. What is the basis for this significant change?
-------
5. De xv enation Coefficient for Nitrogenous Oxvcen Demand . Th
model outputs produced by the EIS Consultant are based on a
value of 0.67 for the nitrogenous deoxygenation coefficient
in all reaches. This is markedly higher than the 0.2 value used
by DWPC. Again, the basis for this change needs to be determined.”
We have discussed the modeling data with Messrs. Cooprnari and Polese
of the Division of Water Pollution Control and they concur with Metcalf and
Eddy’s comments. At this time the MDC and the DWPC request that you rerun
the model with the changes indicated by Metcalf Eddy. If you have any
questions regarding these changes, please contact Jekabs Vittands of Metcalf
Eddy at 523-1900 ext. 456.
When these model reruns have been made, the MDC and DWPC staff would
appreciate the opportunity to discuss the outputs with you and determine
whether additional analyses are required.
Yours truly,
Libby Blank
Director of Environnental Plann.ng
LB/co
r:: A.Coopman, Dl PC
J . Vittands, M E V
A. Ekalainen, EPA
-------
‘ -S.
- • — - - - .
1 ) - - .. -
/
TO: Mary Shnchness’: - —
E.P.A., Project Officer j..i (P A (
CC: I. Klein; C. Koch; 0. Suler; 0. Bartlett
FR0 : R. ! ’. Chapin - .
DATE: May 18, 1977
RET: Location oE Mid—Charles River satellite ;lant dischar2e
The ECA study recorends dischartinc the effluent frcn the nid—Charles
River satellite olant a: the Cochrane dan. Our use of the Char les
River water çLall:v model has beer. aiTed at dete inin: if this is the
“best” location for the discharse. ?re’-ious renoranda. 15 .t.:ril and 25
April, srrarize n:delflnz activities. This nenorand e clua:es the
effects of the t-aricus cases uton the ox-.-cen balar.ce in the Ch:rles
RIver. (Results are evaluated relative to Class 3 dissolved o:c en
standards. See nerorancun cf 10 May 1977.)
The E 2:s. re crt recorzended a dischar e of 31 rad containir.: 5 t-z’l SOD:
and 1 r.zfl a: the Ccchrar.e d an. Early nodellint runs indicated :: :
to violate - azer :tali:v st:ndards for dissolved oxvzan and. :nerefcre,
the discharge effects of an “advanced” evel of treatTent, to a 502; of
5 ngtl and .n 0 : 0 were Lnvest:tatec. :r. adn:Ion, two a tcrattve
discharge locations were rodelled: at the S. :;atick dan: anc 6.7 nies to—
strean of : e S. ::a:ick dan a: the he=± of —.:dellirs roach IS ( areafter
called Reach 13). Figures 1 and 2 :resent. res:ec:iva:v, :lc:s s -ari:izz
these treatrent levels and dischar e Thcazicns and their affects u:or dis-
solved oxygen levels ir. the Charles.
The E’2 A reconnended discharge resulted in a larte 0.0. sag below the
Cochrane fan, which violates the Class 5 standard of never less than
5 ngIl a: an:.-ti e. Discharge at the S. Nat:ck dar resulted in two sa;s
below the 5 rz1 level, howr:er, thace ware no: as severe as the Cocnrane
dan discharge sag. Conversely, d:schar e at each IS caused no ‘iclaticn
of the 5 e /l standard below the S. at:ck fan. Dissolved o::v en levCs
above the far are well below this class 3 lint, althou:h dischar2e at
Reach :s ger.erallv in;rcves ccnditions over those predicted to exist v:th-
out a C discharge.
When dischsr;ing the ad-.anced efflucr.t at the Cochrane darn a sag below the
Class 3 5 n/l lint occurs. This level of treatnent does not violate
standard wher. dischar;ef at the S. Sotick dan, hcwe”er. the 16 hour class S
standard is violated by a S. ‘azick dr disoharce. Reach IS dischzrce as:
does not violate the 5 z:!l standzr below the S. Satick fan, while d:sscved
oxygen levels above the dan fall below that level. However, a discharge
here i—.prcves conditions in this reach ever the discharge conoition. ;Cdi—
tionally the 16 hour stancord toes ntt aopear to be v:clatef b-- the aaoh
.S dis:harcc.
-------
Paze —2-
.ay iS, 1977
ThIs ar.aiysis indicates the greatest benefit to the oxygen ba1 n e cf
the river occurs when the .Id—Cha:ies satellIte plant d±sh rçes a.- a-
vanced effluent placed above the S. Natick da at river iie 7.8. The
political reality of placing such a discharge at that location is beyond
the scope of this discussion. Nevertheless, it is the position of EAC
that any discharge from a id—Charies satellite iant be placed as far
upstrean of the S. Natick da as possible. Such a discharge appears to
provide the osc benefit to the cxygen balance of the Charles River.
-------
cha :es F. vc: :e-::e—z .—...s
Modellir.g waste ¶aste C arac:eri!: :s
P1a t Reach - F1c ( ) 30D ( /1) ( j )
M.ilford CHO3 6 5 1.1
CRPCD CH].3 8.4 5 1.0
reithe State spol 3.1 5 1
• Schocl
Norfolk 31po1e SPO5 0.4 5 1
MCI
Medfie1d— iiiis CHiC 1.5 9 2
ENVISO .E’..TA. r. .Er 7 C L: L
-------
- -
Case escr:i .
ec: - -.er e ar. 1ca i :s at the C r3 c dan.
oxvcen sacs t3 1. :/l heh: :-.e s :< ].i -. (::.-e: - .le 0.)
violating Cass 2 s:ardads (see at:athed Pic re 1)
3 accn er.de disc arce and lcadjn s s: the S. atick ear. : : :a1
sac to .a rc,’l a elc:s enin ::- C:cn:ar.e den (at ::ver -.ie E.4
while a seccnd sac : 4.1 nc /i evelo:s e .ind the £.i•: ‘:ll a-.
This icla :es Ca53 2 D.O. cr.teria (see F:ci.re 1)
4 Advanced disth2r:e and icadi at the Ccch:ane den. .. sag at 4.1
g/l be:-.ind s.i:.: :::1J. an which v::lates Cass 3 standards.
4E Acvanced scharce e.c 1cad.n s at che 3. at.ck dan. 5 a. . d .scnar:e
ca .ises sa: t 5.L :- .‘ “:11 a-. i:h d:es nc:
Class 3 1c er :.:e :a. A : 1e cf ns icr 3 — c r er :
:s s:ndar :s v:cla:ed (see ale 1 an
F1c re 2).
Advan:ed a:a: a - lcadinzs : a.- ci S. a ::: s ..— a: r:er
cile 47.5 (che f : e S. ::: z — :eac.-). T: is :;rcves d s—
solved c:.: :ez _- :ns a:- :v : these c:: :: -; : -:.: :ne
dis:ha::e : : . . eveis d nc: ::se e.cve : e 5 :-: l .er 1_—::
for Class 3 wa:e: . A sac : 5.7 nc/ eveLc :s he. -. nd :::1
A cycle cf r a i:r a 24 hc z• :::± :n !ca:es tne :mss 2 1 h::r
standard is ;:::ez.y nc: :ic1 :e see a ie 1 ani F: re 2)
d::-arce and 1: i nrs .cs:rean cf S. a::c den
at river n .1e his al_c::-— ves .O. levels :na S.
Na:ic d in. -:: as ch as ase 4 . A sag :o 5.4 c/1 deveic;s
behir.i d , hcwever a : r cycle has r.c: heen n icr
this case.
‘Unless s:.±.e:, all : ns at S a.n.
ENVON?. 5’ TAL AS! S5.’E T C3U .IL 1C
-------
Charles River enthic
Demand
Reach ______ Z Bottom Coverage Co=e :s
19 — S. Natick Darn to
Waban Brook 0 0 rapids
20 — Waban Brook to
Cochrane Dam 1.38 25
21 — Cochrane Dam to
Chestnut St. Needharn 0 0 rapids
22 — Chestnut St. to Long
Ditch Inlet 1.38 75
23 — Long Ditch Inlet to
Mother Brook 1.38 75
24 — Mother Brook to Long
Ditch Outlet 1.38 75
25 — Long Ditch Outlet to
S. Meadow Brook 1.38 75
26 — S. Meadow Brook to
Sick Mill Dam 1.38 90
ENvIqop4M r rAL A SE S E T L CIL C
-------
S. 2 :: —c. . e -
Time Low D.O., /i _ .
3am 5.7
5ai 5.1
9am 5.5
12 pm 7.7
6pm 9.9
12 am 6.7
Reach 13 Di!: zr;es
Case
3am 6.2
5 5.6
9 a 6.0
12 8.2
12 7.2
Note: A 1 1o .C. es are dcs:: : cf
Cochrar.e a: ri:er .iie
the Silk : i1.
ENVIRO. .T . .L .SSES5. ENT CCU C L ‘.C
-------
:!1 [ TI.:1:::
DISC 1hRGE L—.---
P GD.I.
f.•x. JLL E OI
/4GtLL.t’JH
.J____
i .
I .:.
.1...!..
:::5
L .:J
LLInIT
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-------
APPENDIX B
BIBLIOGRAPHY - WETLANDS TREAThIENT
-------
BIBLIOGRAPHY
1. Gersberg, R.M., Elkins, B.V., and Goldman, C.R., The Use of Artificial
Wetlands to Remove Nitrogen from Wastewater , Ecological Research Associates,
Davis, California.
2. Kadlec, Robert H., Wetlands for Tertiary Treatment , University of
Michigan, 1978.
3. Mudroch, A. and Capobianco, J.A., Effects of Treated Effluent on a
Natural Marsh , Canada Centre for Inland Waters, Burlington, Ontario,
J.W.P.C.F., September, 1979.
4. Oduin, H.T.., Ewel, K.C., Mitsch, W.J. and Ordway, J.W., Recycling Treated
Sewage Through Cypress Wetlands in Florida , Center for Wetlands, Univer-
sity of Florida, 1975.
5. Reed, Sherwood C and Bastian, Robert K., Aguaculture Systems for Waste-
water Treatment: An Engineering Assessment , U.S. E.P.A., Washington,
DC, June, 1980.
6. Spangler, Fred I., Fetter, C.W. and Sloey, William E., Phosphorus
Accuiiiulation - Discharge Cycles in Marshes , American Water Resources
Association, 1977.
7. Tuschall, John R., Brezonik, Patrick L., and Ewel, Katherine C.,
Tertiary Treatment of Wastewater Using Flow-Through Wetlands Systems ,
Department of Environmental Engineering Sciences and Center for Wetlands,
University of Florida, Gainsville.
8. Valielu, Ivan; Vince, Susan and Teal, John M., Assimilation of Sewage
by Wetlands , Woods Hole Oceanographic Institution, Woods Hole, MA.
9. Valk, A.G. van der, Baker, James L., Davis, Craig B., Beer, Craig E.,
Natural Freshwater Wetlands as Nitrogen and Phosphorus Traps , Iowa
Agriculture and Home Economics Experiment Station, Ames, Iowa.
10. Weber, A. Scott, Tchobanaglous, George, Colt, John E., Aquatic Systems
for Secondary and Advanced Treatment of Wastewater , Department of Civil
Engineers, University of California, Davis.
11. Whighain, Dennis F and Bayley, Suzanne E., Nutrient Dynamics in Freshwater
Wetlands , Chesapeake Bay Center for Environmental Studies and Maryland
Coastal Zone Management, Department of Natural Resources.
12. Yonika, Donald and Lowry, Dennis, Feasibility Study of Wetland Disposal
of Wastewater Treatment Plant Effluent , Massachusetts Division of Water
Pollution Control, 1979.
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APPENDIX C
CORRESPONDENCE RE: QSA WETLANDS DISCHARGE SATELLITE
PROPOSAL - MASSACHUSETTS DEQE - DIVISION OF WATER
POLLUTION CONTROL AND DIVISION OF WATER SUPPLY
-------
•1
ez? 1 e w zwea # a t 1
xecu4 e Cjfl e naI4f
a nent of o e zI Qiia4 £ee# uj
of 7i e 6 ‘ e i d
ANThONY D. CORTESE. Sc. D e 7f nte e Aeee . && 02108
December 29, 1983
Walter Newman, Acting Chief Re: MDC
Environmental Evaluation Section SDEIS, Siting of
Environmental Protection Agency Wastewater Treatment
J.F.K. Kennedy Building Facilities
Boston, MA 02203
Dear Mr. Newman:
In response to a request from your agency, the Division of Water
Pollution Control, Permits Section has reviewed the proposal by the Quincy
Shore Association for subregional wetland application satellite wastewater
treatment plants. The proposal calls for the construction of three facili-
ties, one each to be located in the Weymouth Fore River Basin, Neponset
River Basin and the Charles River Basin. All three plants would include
advanced wastewater treatment processes with discharge of their effluent to
major wetland areas which are hydraulicly connected to groundwater aquifers
currently being utilized by various municipalities as major sources of
drinking water. Information presented to the Division indicates that
during recharge periods up to 80% of the effluent discharged to the marshes
would enter the groundwater regime and recharçe the subject aquifers.
On October 15, 1983 the Division of Water Pollution Control pro-
mulgated a set of comprehensive water pollution control regulations
(Title 314 of the Code of Massachusetts Regulations) which included
detailed groundwater quality standards. These standards define groundwater
into these classes (1,2,and 3); Class 1 being defined as
“fresh ground waters found in the saturated zone of uncon-
solidated deposits or consolidated rock and bed rock and are
designated as a source of potable water supply”.
Since all three proposed discharges will be tributary to groundwater
currently being utilized as public water supplies (Class 1), all discharges
to said groundwater will be required to meet very strict discharge limits,
see attachment #1.
The discharge limits would basicly require that the effluent entering
onto the wetland meet or exceed the Primary &nd Secondary Drinking Water
-------
Walter Newman
December 29, 1983
Page 2
Parameters, see attachment #2. In addition, the Division is concerned with
the periodic “pass through” of materials such as oil, heavy metals,
solvents, phenols and other highly toxic or contaminating materials which
are not substantially removed with conventional wastewater treatment pro-
cesses and which could cause severe impacts upon these aquifers.
The Division is of the opinion that proper safeguards necessary to
continuously meet Class I effluent limitations and to protect these va1uable
public water suppites can not be provided. Therefore, the Division
strongly discourages the continued review of such subregional facilities as
proposed by the Quincy Shore Associates.
Ver, truly yours,
Thomas C. McMahon
Director
TCM/MP/pmm
cc: Sam Mygatt, MEPA
David Fierra, EPA
Steven Lipman, DEQE
William Gaughah, DWPC
Marjorie O’Malley, EOEA
Noel Baratta, MDC
Robert Daylor,Quincy Shores Associates
-------
ATTACHflENT 1
!82
314 CMR: DIVISION OF WATER POLLUTIO 1 COr TRDL
6.07: Application of Standards
(1) Ground Water Discharge Permits . r o person shall
make or permit an outlet for the discharge of sewage
or industrial waste or other wastes or the effluent
therefrom, into any ground water of the CciTunonwealth
without first obtaining a permit from the Director
of the Division of Water Pollution Control pursuant
to 314 CMR 5.00. Said permit shall be issued subject
to such conditions as the Director may deem
necessary to insure compliance with the standards
established in 314 CMR 6.06. Applications for ground-
water discharge permits shall be submitted within
times and on forms prescribed by the Director and
shall contain such information as he may require.
(2) Establishment of Discharge Limits . In regu—.
lating discharges of pollutants to ground waters of
the Commonwealth, the Division shall limit or prohi-
bit such discharges to insure that the quality stan-
dards of the receiving waters will be maintained or
attained. The determination by the Division of the
applicable level of treatment for an individual
discharger will be made in the establishment of
discharge limits in the individual ground water
discharge permit. In establishing effluent limita-
tions in the individual permits, the Division must
consider natural background conditions, must protect
existing adjacent and downgradient uses and must not
interfere with the maintenance and attainznent of
beneficial uses in adjacent and downgradient waters.
Toward this end, the Division may provide a reaso-
nable margin of safety to account for any lack of
knowledge concerning the relationship between the
pollutants being discharged and their impact on the
quality of the ground waters.
(3) For purposes of determining compliance with 314
CMR 6.06(1)aa for toxic pollutants in Class I and
Class II ground waters, the Division shall use
Health Advisories which have been adopted by the
Department or EPA. Generally, the level of a
toxic pollutant which may result in one additional
incident of cancer in 100,000 given a lifetime expo-
sure (iO Excess Lifetit e Cancer Risk) will be used
in determining compliance with that section of the
regulatiori .
— 17 —
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Attachment # 2
.11 (;
314 CMR: DIVISION OF WATER POLLUTION CONTROL
Parameter Limit
1. Coliforni Shall not be
Bacteria discharged in
amounts sufficient
to render ground
waters detrimental
to public health,
safety or welfare)
or impair the
ground water for
use as a source of
potable water.
2. Arsenic Shall not exceed
0.05 mg/i
3. Barium Shall not exceed
1.0 mg/i
4. Cadmium Shall not exceed
0.01 mg/i
5. Chromium Shall not exceed
0.05 mg/I
6. Fluoride Shall not exceed
2.4 mg/i
7. Lead Shall not exceed
0.05 mg/i
— 17 —
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— - f
314 CMR: DIVISION OF WATER POLLUTION CO 1TROL
8. Mercury Shall not exceed
0.002 mg/i
9. Total Trihalomethanes Shall not exceed
0.1 mg/i
10. Selenium Shall not exceed
0.01. mg/i
11. Silver Shall not exceed
0.05 mg/i
12. Endrin (1,2,3,4,10, Shall not exceed
10-hexachloro—1,7-epoxy-1, 0.0002 mg/i
4,4a,5,6,7,8,9a—octahydro—
1 ,4—endo,endo—5,8—dimethano
naphthalene)
13. Lindane (1,2,3,4,5, Shall not exceed
6-hexachlorocyclohexane, 0.004 mg/i
gamma isomer)
14. Methoxychlor (1,1,1— Shall not exceed
Trichloro—2, 2-bis 0.1 mg/i
(p—methoxyphenyl) ethane)
15. Toxaphene (C 1 OH1OC18, Shall not exceed
Technical Chlorinated 0.005 mg/i
Camphene, 67—69 percent
chlorine)
16. Chiarophenoxys:
2,4-D,(2,4—Oichloro— Shall not exceed
phenoxyacetic acid) 0.1 mg/i
2,4,5-TP Silvex (2,4, Shall not exceed
5-Trichlorophenoxy- 0.01 mg/i
propionic acid)
17. Radioactivity Shall not exceed
the maximum
radionuclide con—
taminant levels as
stated in the
uationai Interim
Pr r ary Drinking
Water Standards.
- -
-------
314 CMR: DIVISION OF WATER POLLUTION COt TROL
18. Toxic pollutants Shall not exceed
(other than those “Health Advisories”
listed above) which have been
adopted by the
Department and/or
EPA. A toxic pol-
lutant for which
there is no avail-
able 11 Heaith
Advisory” and for
which there is not
sufficient data
available to the
Department for the
establishment of a
Health Advisory”
will be prohibited
from discharge.
(b) Secondary effluent limitations for Class I
and Class II ground waters . In addition to the
effluent limitations in 314 CMR S.lO(3)(a), the
following limitations shall also apply to any
discharge from a point source or outlet which
enters the saturated zone of, or the ünsa—
turated zone above, Class I and Class II ground
waters.
Parameter Limit
1. Copper Shall not exceed
1.0 mgIl
2. Foaming Agents Shall not exceed
1.0 mg/i
3. Iron Shall not exceed
0.3 mg/i
4. Manganese Shall not exceed
0.05 mg/i
5. Oil and Grease Shall not exceed
15 mg/i
6. pH Shall be in the
range of 6.5 to
8.5 standard units
7. Sulfute Shall not exceed
250 r g,’i
- 19 -
-------
.1 . 9
314 CMR: DIVISION OF WATER POLLUTION CONTROL
8. Zinc Shall not exceed
5.0 mg/i
9. All other None in such
poll utants concentrations
which in the opfn—
ion of the Director
would. impair the
ground water for
use as a source of
potable water or
cause or -contribute
to a condition in
contravention of
standards for other
classified waters
of the
Com.monwealth.
Cc) Additional effluent limitations for Class I
and Class II ground waters . In addition to the
effluent limitations listed in 314 CMR
5.10(3)(a) and (b), the following limitations
shall apply to treatment works designed to
treat wastewater at flows in excess of 150)000
gallons per day:
Parameter Limit
1. Nitrate Nitrogen Shall not exceed
(as Nitrogen) 10.0 mg/I
2. Total Nitrogen Shall not exceed
(as Nitrogen) 10.0 mg/I
Cd) Additional effluent limitations for Class I
ground waters . In addition to the effluent
limitations in 314 CNR 5.1O(3)(a)(b) and (c)
the following limitations shall apply to treat-
ment works discharging to Class I ground
waters:
Parameter Limit
1. Chlorides Shall not exceed
250 mg/i
2. Total Dissolved Shall not exceed
Solids 1000 cig/l
- 20 -
-------
_____ Yom’mm zrn €zf (€y
ecid ve O//e o/ é ?2:à cfl,flCflg / Q ( g ,c.s
/ta trnent 0/ iv wonment, / ea6i ( i,e ’zee bi,
ANTHONY 0. CORTESE SC. 0. . VL Wfl €j/ # te,
COMMIUION R
O#&e ) K U $ ee .Ji i 02/08
MEMORANDUM
TO: Steve Lipman, Boston Harbor Coordinator
FROM: Ilyas Bhatti, Director, Division of Water Supply
DATE: December 16, 1983
SUBJECT: Metropolitan District Commission, Southern Sewerage
District Wastewater Treatment Facilities Planning Project:
The Citizens Plan.
The Division of Water Supply COWS) has reviewed the proposed plan for
subregional “satellite” wastewater treatment facilities as part of the
general plan for rehabilitating the MDC wastewater treatment system. As
the agency responsible for ensuring safe drinking water supplies, we are
particularly concerned with the impact these treatment plants could poten-
tially have on the water quality of nearby aquifers and wetlands which
serve as public water supplies for many communities. Specifically, these
areas are:
1. Weymouth Fore River Basin — proposed 8—10 mgd discharge into
Broad Meadow, a wetlands of the Cochato River; Cochato and
Farm Rivers are diverted to reservoirs for use by Braintree,
Randolph, and Holbrook. -
2. Neponset River Basin — proposed discharge of 35 mgd to Fowl
Meadows which supplies Canton, Westwood and Dedham.
3. Charles River Basin - proposed 50 mgd discharge into Cow
Island Meadows, a wetland in an aquifer area which supplies
Dedham, Needham, Wellesley, and Weston.
With regard to these sites, the sponsors of the Citizens Plan claim
that there are several advantages to these projects as compared to the
current MDC proposal. The following comments reflect the Division’s con-
cern with claims in the proposal that the development of the satellite
-------
Mernor an dum
December 16, 1983
Page 2
plants will increase the water quantity and improve the water quality of
the water supplies in the 10 affected cornunities (Braintree, Randoplh,
Holbrook, Canton, Norwood, Westwood, Dedham, Wellesley, Needham, and
Weston).
Although the Citizens Plan is an innovative proposal for solving the
extremely complex problem of dealing with wastewater treatment in the
Metropolitan Area and the associated water quality problems in Boston
Harbor, its claim with regard to increasing the water quality/quantity in
the aformentioned wetlands and aquifers is based on questionable
assumptions.
As noted in the proposal, wetlands have been studied by many agencies,
including DEQE, and are known to have significant capacities to attenuate
various types of pollution such as nitrates, phosphates, and heavy metals.
Although this feature of wetlands is well documented, the present proposal
assumes that wetlands have a limitless capacity to act as “sinks’ for con-
taminants and that all discharges from the proposed wastewater treatment
plants will be “polished” by the assimilative capacity of wetlands. In
fact, wetlands have limited capacities to assimilate wastes; unlike treat-
ment plants which accelerate the process of waste removal , wetlands
recycle and absorb pollutants over a long period.
It is difficult to generalize about the capability of wetlands to
function as water purification systems. Ultimately, the diversity of the
many wetland charateristics will determine their net efficiency to assimi-
late sewage contaminants. The vegetative type, rate of flooding, and the
area of a wetland will determine: the rate at which pollutants are recycled,
the BOO loading tolerance, the sedimentation rate, and the level of bioche-
mical degradation. The geographical location of a particular wetland will
also markedly affect the seasonal capacity of wetlands to. assimilate
wastes. For instance, It is quite possible that the wetlands proposed for
discharge in the Citizen’s Plan would freeze during certain periods of the
year which would inhibit even the mechanical, primary treatment function of
plant screening and particulate sedimentation.
Aside from the problems associated with determining the assimilative
capacity of wetlands for pollutants, this proposal does not address other
potential water quality problems. For instance, the proposal does not
address the fact that very little control exists over the nature and
quality of sewage. Presently, the regulatory manpower does not exist for
monitoring illegal or haphazard industrial waste disposal. Many industrial
contaminants cannot be detected, let alone treated, in standard wastewater
treatment facilities. As a result it is very likely that discharges from
the proposed “satellite” plants would ultimately result in the degradation
of existing water quality in the receiving wetlands/aquifer. All things
considered, water quality degraiation is likely to occur either over the
-------
Memorandum
December 16, 1983
Page 3
short term through problems associated with seasonal flooding/freezing of
the wetland and/or the undetected discharge of a harzardous substance, or
over the long-term by the gradual saturation of the assimilative capacity
of the wetland.
Because of these uncertainties, and the problems that may ensue, the
OWS must conclude that the Citizens Plan proposal for wastewater discharge
into wetlands is an unacceptable risk for potentially degrading these vital
existing drinking water supplies.
-------
APPENDIX D
INFLOW! INF I LTRATION TRADING/BANKING PROPOSAL
-------
Y e inicnccea&% c/cacAaaee
1? f q
c3.ceac( c £ 1 ) 1 2az eye’ &n z:e”. nmcn(a/
100 dZ’.cct
Jfaiack dt i 02202
C3-.!TAL ZONE
Frc essor Charles M. Haar
3C0 Gris ald } all
arvard La School
C br1dge, L4 02138
Re: Q i cv v >!DC , Schedule lte :
Dec ber 2, 1983
e r ?rofess r Haa::
! c1osed is he p e1i inary report on I/I r oval.
Sincerely,
L: b
enc 1:
cc: ?ecer L. Koif
Raiph A. Child
E. lichael Slo an
Sce ie C. Horo tcz
Jeffery Fo iey
1s. Laura Sceirberg
Wjlli3 C. -o1dcn
Scephen C. Karn s
S:erhen P. turgay
Stev ’. Li:
r— ‘ ‘— - 0
fC
, I-
-‘ ,._.._ ._ . . 2EL
. ._. V = ..
—3 I. —
1:E: 7
‘.1 £
rr i
Jç’..I’ .‘..
Counsel
-------
December 2. 1983
Procedural Order — Item #5.
BANKING/TRADING AND GREATER THAN 2 FOR 1 PROGRAM
Item #5 of the Procedural Order requires that DEQE assess the feasibi-
lity of a Banking and Trading System and a greater than 2 for 1 sewer
extension permit program. This document not only provides the Court with
those feasibility assessments but attempts to develop a basis for an
expanded discussion of the need for an integrated approach to all I/i
related items contained in the Procedural Order. It is our intention to
use this expanded discussion document to hopefully stimulate fresh
approaches to these technicafly and politically complex issues. This
document should not be viewed as a DEQE position paper but as a discussion
document and comments are not only welcomed but strongly requested.
In order to assess either of these programs adequately one must con-
duct such an assessment in the context of DEQE and MDC’s overall efforts to
deal with the entire sewerage system and its myraidof problems.
Within the MDC regional sewer system there currently exists 5,400
miles of municipal sewers, 228 miles of MDC sewers, approximately 3,000
miles of privately owned house laterals, over 70,000 manholes, 10 MDC
pumping stations and numerous municipal and privately owned pumping sta-
tions. Large sections of the North System have combined sewer/drain faci-
lities and literally thbusands of cross connections or interconnecticns
exist within the sewers and drains tributary to both the North and South
Systems. Also various exfiltrating sewers are underdrained with small
diameter perforated pipe which discharge to adjacent watercourses.
Extensive gauging or flow monitoring facilities currently do not exist
within eithe the MDC or municipal sewerage systems and therefore there is
very little historical data concerning the distribution of wastewater
within this maze of pipes, pumping stations, diversion structures, treat-
ment plants and overflow facilities.
Due to the nature of the segmented ownership of these facilities,
management of flows into the system is extremely difficult to control and
monitor. Infiltration and inflow (I/I) within this system is a very signi-
ficant flow component (estimated to be over 50% of the average monthly
flow). It must be emphasized that I/I is not peculiar to the MDC system
but also exists in large amounts in all sewer systems particularly older
systems. Others have statea that if I/I could be significantly reduced,
many of the system problems could be solved without the construction of new
relief sewers, pumping stations or expanded treatment plants. There is no
question that I/I reduction could aid in these efforts, particularly with
reaard to localized surcharging and overflows, but it is ot a panacea to
the problems of the MDC system or pollution of Boston Harbor.
-------
I/I within the MDC system has been extensively investigated with
millions of dollars expended to date in •this effort. Due to the length of
time needed to complete the study and design phases of the I/I program,
very few communities within the MDC have actually begun the physical
reconstruction phase of the I/I program. Therefore, relatively little I/I
removal has been achieved to date even though a great deal of effort and
money has been expanded by local and federal agencies on this program.
Rehabilitation projects have been completed, are under construction or soon
to be initiated within seven (7) MDC municipalities and are expected to
remove 30 MGD of 1/I from the sewerage systems (3.6 MGD within the South
System and 26.5 MGD within the North System).
Unfortunately I/I studies and rehabilitation programs are more of an
art than a science and this program is receiving extensive national reex—
mination by the EPA, consulting engineering firms, I/I gauging and rehabi —
litation firms,, major municipal sewer authorities, and state agencies.
This review is in large measure due to the demonstrated inability of coin—
munities to reduce I/I rates to those originally assumed to be realistic
(and often mandated). During 1979 and 1980 EPA funded a major study to
examine the level of success of it Construction Grants I/I Rehabilitation
Program. The results showed that of the nineteen (19) communities studied,
none had attained the assumed levels of I/I reduction and many had not
reduced I/I at all despite extensive reconstruction efforts. The study
concluded that current I/I determination and rehabilitation techniques
generally will not result in substantial system I/I flow reductions. This
study further recommended nine (9) major revisions to the EPA I/I program
(See attachment #1). —
During the past seven years numerous I/I studies have been performed
within the overall MDC system by various consulting firms. It is very dif-
ficult to compare the results of the varoius studies to each other and
often impossible to even correlate the results of Phase I and Phase II I/I
studies within a single community conducted during consecutive years by the
same consultant. The MDC has performed 2 system—wide I/I studies,
(North System performed during 1978 by Camp, Dresser & McKee and the South
System performed during 1979 by Fay, Spofford, and Thorndike), plus 7
system component I/I studies by 6 different firms for individual projects
such as the Framingham Interceptor, Fore River Siphon, etc. Of the 43
member municipalities, 25 have already performed additional I/I studies
utilizing 11 different consulting firms. All these studies were required
to comply with the EPA cost-effectiveness guidelines which resulted in
significant amounts of I/i not being cost-effective for removal due to
ccmparatively low transporation and treatment costs for the MDC system.
Therefore, projects which have progressed into the Phase II — Sewer System
Evaluation Survey Phase, Design Phase or construction Phase are skewed
towards removal of I/I to the point where the EPA regulations deem the I/I
component of total flow to a treatment facility anon—excessive”. This
approach does not emphasize significant elimination or reduction of I/I
through continued and routine maintenance of a sewer system, but rather one-
time repairs or replacement of sewers which may or may not have a lasting
effect in reducing I/I system—wide.
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Problems in the MDC Sewer System can be classified as:
1) ACUTE — Conditions which can lead to direct public health
impacts such as sewage overflows into recreational areas, shellfish areas,
and public water supplies and back—ups into homes; and
2) CHRONIC — Conditions such as sewer surcharging leading to
flow restrictions, reduced pollutant removal efficiencies at treatment
facilities, •and overflows to watercourses in non—critical areas.
DEQE believes that there is room for improvement in the treatment of
both acute and chronic problems, but the appropriate remedies are not
necessarily the same.
Past practice : A) DEQE has utilized enforcement action (sewer bans,
monitoring, two for one, holding tanks, etc.) to address ACUTE problems.
It is our opinion that a degree of success has been reached but still more
can be done to identify problem areas and initiate enforcement action which
would utilize the existing array of possible remedies and tailor specific
remedies to particular situations.
B) DEQE has utilized a format of developing a
Memorandum of Understanding (orginally signed on April 13, 1982) between
its Division of Water Pollution Control and the MDC to prioritize major
water pollution abatement projects, develop compliance schedules and allo-
cate federal/state grdnts as a primary remedy for the CHRONIC problems of
the MDC system.
We now recognize that an effective remedy to the CHRO?UC problems must
also include other elements beyond the construction grants project list.
The remedy fDr the CHRONIC problems must include an organized, structured,
long term approach to reducing extraneous flow of “clean wat2ru into the
entire MDC system.
During August and September the Division of Water Pollution Control
(DWPC) developed interim maximum I/I removal rates for each MDC member corn—
munityas required by the Court. Since these rates had to be developed
during a very short period of time, DWPC had to assume across—the—board—
removal rates (30% and 50% reduction in infiltration and inflow respec-
tively were chosen) for each community based upon the flow studies
available at the time. This analysis indicated that 110 £- GD and 80 MGD
could possibly be removed from the South and North System respectively if
30% and 50% reduction could be obtained in each community along with a
source of monies to fund this extensive work (estimated at $100 million).
It was never the Department’s intent to indicate that this level of
I/I reduction was easily obtainable, cost effective, or could be instituted
within a short period of time. The following are some of the major
problems and uncertainties which we believe stand in the way of instituting
any program to deal with the Chronic problems within the South System
(similar problems exist within the FJorth System):
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1) It has been estimated that total flows in excess of 450 MGD
enter various sections of the South System at any one time;
2) The theoretical maximum flow reduction within the system has
been estimated at 110 MGD assuming across—the—board reduc-
tions of Infiltration by 30% and Inflow by 50%;
3) The major constriction within the conveyance and treatment
facilities are the High Level Sewer with a peak caPacity of
310 MGD and the Nut Island Treatment Plant with a peak capa-
city of 250 MGO. Flows cannot be reduced to these levels
even if the theoretical maximum I/I reduction rates were
attained;
4) The estimated cost for removal of 110 MGD is $60 million, if
30% & 50% reductions could be obtained in all cornunities;
5) Current state—of—the—art hi reduction practices indicate a
significantly lower I/I removal capability (15% total I/I
reduction);
6) It is uncertain whether current I/I reduction techniques
withstand the passage of time. Rehabilitated sewer lines may
quickly revert to prior conditions and other currently non—
leaking sewer segments may begin to leak as the lines
detert rate with age;
7) Current information indicates that as much as 50% ofall
infiltration within a sewer system originates from privately
owned 3 or 4 inch house connections (pipe connecting the
building to the street sewer);
8) Various I/I experts now belive that “allowable” non—cost—
effective I/I rates for a community may be as high as 10,000
gallons per day/inch/mile of pipe (gpd—in—mi) instead of
6,000 gpd-in—mi currently being used by EPA and 1,500 gpd—in—
mi which was originally used by EPA. if the 10,000 gpd—in—mi
figure is used as a cut-off point for further I/I work, a
review of the existing I/I rates for Southern System
Cornunities (attachment 2) indicates that only Boston,
Dedham, and Hingham would require I/I reduction.
9) Since all prior I/I studies were performed utilizing the EPA
cost—effectiveness program, many if not all the prior studies
will need to be revised. This may also require additional
flow monitoring to supplement prior monitoring data. This
monitoring work can only be performed during high groundwater
(“hunting”) periods and such revision to any of the existing
studies could add approximately two years to their completion
times; and
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10) We currently have• no methods of monitoring total system
flows, flows from each municipality, loss of flow due to
localized overflows, etc. Any attempt to develop maximum I/I
rates for each municipality in order to ‘solve” all of the
many problems experienced in the MDC and local sewer systems
(i.e. surcharging and overflows, downstream constrictions in
MDC trunk sewers, overloading of pumping stations, hydraulic
overloading of the treatment plant and pollution abatement
within Boston Harbor) with the existing information is likeS
trying to fine—tune a piano when half the keys are missing.
In order to resolve some of these uncertainties and to begin the deve-
lopment of an effective system-wide approach to the chronic problems of the
MDC, the Department is undertaking the following:
1) The DEQE sent two staff engineers to New Jersey during August
to attend a nationl EPA—sponsored seminar titled “New
Concepts in I/I Evaluation and Sewer System Rehabilitation”;
2) DEQE has formed an internal task force to devise a consistent
statewide policy on I/I, specifically to address the recent
development of and revision to state—of—the—art rehabilita-
tion techniques as enumerated at the above discussed EPA
seminar;
3) DEQE is in the process of developing a Technical Advisory
Group to work with us to develop an acceptable and implemen—
table I/i program for the MDC system. Our preliminary idea
for membership of this group is to have one representative
from the following: DEQE, MDC, BWSC, EPA, Quincy , a North
System Community, a South System Community, engineering con-
sultant, sewer rehabilitation company and developer/home
builder. This would provide for a workable 10 member tech-
nical committee. We would also be requestina that each
member representing a larger grouping develop an extended
committee to whom they could report in order to ensure a wide
dissemination of data.
4) DEQE recently held an interagency seminar on I/I at which
Gerald Conklin, a well known expert on state—of—the—art I/I
rehabilitation techniques, explained the results of a study
the firm Dufresne — Henry performed for the EPA;
5) DEQE has sent letters to Region 1 and Washington EPA strongly
requesting that EPA hold the New Jersey seminar in Boston so
that a thorough discussion could be held with all parties to
the court suit. EPA recently indicated to DEQE that they
could probably fund this seminar;
6) DEQE has contacted Michael Bank from the Washington South
Suburban Sanitary District requesting permission for members
of cur I/I Task Force to visit their facility and discuss
their extensive experience in I/-I rehabilitation programs.
This macting has been tentatively sheduled for December 6 and 7.
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7) DEQE filed legislation seeking $100 infl lion in state funding
for I/I rehabilitation programs which includes a section
which would allow DEQE to fund a system—wide flow gauging and
monitoring system for the MDC;
8) DEQE is in the process of entering into a $39,000 contract
with a well known consulting firm to review all I/I data
within the MDC’s South System and to recommend an action
plan with regard to I/I reduction for the MOC.
9) DEQE plans to send correspondence to many of the MDC’s member
communities (letters already sent to Hingharri, Stoughton,
Westwood, Needham, Randolph, Quincy, Framingham, Natick,
Ashland, and Brookline) requesting their attendance at indi-
vidual meetings to discuss the additional I/-i work that they
will be required to perform.
DEQE believes that there must be a system-wide commitment for the
development and implementation of an integrated MDC sewer management
program. This program must include the provision for adequately sized
transmission and treatment facilities; a realistic I/I program; on—going
municipal sewer maintenance, effective sewer permit program and system—wide
flow monitoring. These five items will be discussed in greater detail in a
later section of this document.
These actions the Department has taken and plans to undertake are
based on our conclusions that the first priority in developing a new and
effective approach to solving the system-wide problems of the MDC is an
educational process for all concerned parties. The need for this educa—
tional process is a result of our review of our efforts, and those of EPA
and other major metropolitan sewer systems in dealing with I/I. By
recognizing past successes and failures, becoming familiar with new state—
of-the-art methods for dealing with I/I, and reviewing this information and
obtaining the advice of the Technical Advisory Group, we will have the
opportunity for the first time to devise an effective and workable system—
wide solution to the MDC’s problems.
Because we haven’t yet completed that educational process, or
formed of the Technical Advisory Group, which we feel is essential in deve-
loping a program which has the support and endorsement of all concerned in
the operation of the MDC system, we cannot now recommend a detailed
approach to solving the I/I problems, or what the mix of technical, funding
and administrative or enforcement mechanisms should be in such a program.
However, we have developed some basic concepts about what an effective
system must include and have reviewed the concepts of banking and trading
and expanded 2 for 1 program as they might be part of this overall solu-
tion. We offer our comments on banking/trading and 2 for 1 and our
thoughts on the minimal components of an integrated MDC system management
program for the consideration and use of the Technical Advisory Group, the
Court and all parties as a first step in devising an effective program.
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Banking and Trading
DEQE has closely reviewed the feasibility of various types of
banking/trading systems, the two major catorgories being “private capital
systems” and a “central bank”.
A %4orkable banking/trading system must meet the following minimum
criteria: 1) Access to the system must be readily available to all who want
or need to participate; 2) I/I reductions for which credits are granted
should be verifiable; 3) I/I reductions should be permanent and enforceable;
and 4) I/I reductions should be exchangeable in a way that is meaningful
in terms of system—wide conditions. An examination of the MDC I/I
situation indicates that a private capital banking/trading system is unli-
kely to be successful in meeting these criteria.
A “private capital” system is one in which private developers
wishing to obtain sewer connection permits would either directly produce
reductions in I/I or purchase reductions from other private or public enti-
ties who had performed work necessary to remove I/I. Credits could be
“stored” in a bank or privately held under such a system. A “central bank”
system is one in which reduction credits are created by the bank (an
existing or new public entity or quasi—public entity) only, then sold to
developers who need connection permits.
A. Access to system . Perhaps the most fundamental barrier to a
private capital system is that access to that system is constricted and
complex. The sewerage system is made up of several layers of ownership:
MDC sewers; municipal sewers; and private laterals. Obtaining necessary
permission to perform work within such a system requires several steps:
site selection, ownership determination, and securing necessary approvals
from several sources. Municipalities may be unable or unwilling to grant
access under the terms of their easements; individuals may deny access
necessary to disconnect unauthorized laterals or remove sump pumps.
Apportioning potential tort liability will complicate the system further.
Finally, all ol? these barriers may be compounded by interjurisdictional
problems. In some municipalities reductions may be difficult or impossible
to achieve, causing developers to seek credits through reductions in other
jurisdictions. Some municipalities may be reluctant to encourage develop-
ment outside of their boundaries by allowing such work. Lack of technical
expertise may be another significant barrier.
In brief, access to the reduction credit system would be con-
siderably constrained and many potential entrants may be excluded. The
same set of barriers makes it unlikely that their will be many
‘ 1 speculators ” who will produce credits for sale to developers.
By contrast, a central bank system does not necessarily pose such
barriers to access. To some extent, the same impediments to the creation
of I/I reduction credits exist; however, they are less severe because the
process could be centralized in a public or quasi-public entity which might
be able to secure necessar ’ access rights through specific enabling
legislation. More importantly, these barriers would not bar access into
the system by those wishing to purchase credits, as the purchase of credits
from the central bank requires only a cash exchange.
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B.•Verification : Verification issues, though chiefly technical,
have significant structural ramifications. The technical
problem posed by the preselit conditidn of the sewerage system
are multifold, but for purpose of this discussion can be sum-
marized as follows. Because there is no effective flow moni-
toring facilities within either the MDC or its tributary
member system, it is extremely difficult to measure accurately
either a baseline for I/I removal in specific locations or the
amount removed. In addition, a gallon of I/I removed from one
point does not necessarily represent a gallon removed from the
system as a whole.
The impact of this situation on a private capital banking/trading
system is that realistic verification of I/I removal is virtually unob-
tainable and reduction would be ephemeral. Realistic verification would
require Department monitoring before and after each reduction, at all sites
selected by those attempting removal. The Department does not currently
have the staff or equipment to perform such monitoring tasks and the
required resources would be excessive compared to the potential benefits.
Even rough calculations based on total flow would be of little use because
it would be necessary to apportion specific amounts of reduction credit to
individual projects which would be occuring continually throughout the
sewerage system if the banking/trading system were to function properly. A
workable system with unverifiable reduction credits would be difficult if
not impossible to establish and certainly impossible to administer
equitably.
The same technical problems confront a central bank system, but
the structure of a central system offers the possibility that they-might be
manageable. Because credits would only be created through projects coor-
dinated centrally, baseline and post—project monitoring are more feasible.
Rather than isolated projects chosen by developers scattered throughout the
system, target areas can be selected for I/I removal and some determination
made of the effects of the work on the system. Because all credits created
go into the central bank, it is not necessary to apportion system—wide (or
sub—system—wide) credits among different projects. Credit allowances,
though not completely quantifiable would at least be more consistent;
making the system more equitable and more likely to obtain the desired
results. -
C. Enforceability . The technical and structural issues con-
cerning the enforceability of I/I reduction are inextricably linked to
those of verification. Thus, the same problems outlined above affect this
criterion as well. Adding to these problems is the need for some sort of
permanence to the reductions obtained; i.e. removal of I/I must be effec-
tive for some specified period of time, or credits would be meaningless.
This concern requires the maintenance of that work, throughout the life of
the credit. A private capital system poses serious enforcement problems
from this standpoint. Quality assurance would require constant
Departmental presence at all projects. Requiring developers to return to
removal sites to perform maintenance work would be extremely difficult in
practical terms. The Department currently laciçs the resources to perform
either of these functions.
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Again, a central bank system might be able to minimize some of
these difficulties. Both quality control and maintenance could be assured
more effectively by centralizing removal work. There is less likelihood of
either fraud or inadequate performance and as a result, such a system would
be more equitable and reliable.
0. . Credit exchange . The premise of the banking/trading system
is that I/I removal credits are both fungible and adequate to allow for
added new flow; in other words removal credits should be interchangeable
both with other removals and with added new flows elsewhere in the sewerage
system, regardless of time. A private capital banking/trading system assu-
mes that these units are interchangeable and in terms of the
banking/trading system only , this assumption is not unreasonable. However,
in terms of the sewerage system the assumption is false, and a system based
on it would be ineffective for solving the underlying problems of the
sewerage system.
Equal volume removal credits are not fungible for several
reasons, including timing of flow concentration•, location within the system
or sub—system and likelihood that I/I removed from one point will enter (in
some propoi tion) at another or cause flooding.
If the effectiveness of removal measures deteriorates over time,
I/I reduction credits in the bank must also be devalued in the same ratio_
The wider the system and the more variation in conditions the greater the
likelihood of incompatibility of removal credits. Moreover, some of the
MDC component systems are fairly “tight”, while others offer good oppor-
tunities for I/I removal and still others may present flow problems that
should be solved in other ways . I/I removal actions also differ in cost—
effectiveness (in real terms, as opposed to EPA’s grant—related criteria
for cost—effectiveness).
The implications of the technical sewerage issues for the
banking/trading system strongly suggest that the only type of implementable
system is a central bank. A central bank system would focus I/I removal
efforts on target areas where I/I removal is most useful from a system—wide
viewpoint. The compatibility of removal credits with each other or with
proposed additional flows could be judged technically and adjustments in
the amount of credit allowed or needed for a particular project could be
made. It should be easier to establish sub—systems in which trading of
credits could occur. For example, credits neededfor North System connec-
tions should be based on North System removal. It may also be necessary to
further restrict the transfer area to sub—system levels.
Conclusions . Considering the four criteria of market access,
verification of removal credits, enforceability, and exchangeability of
rem3val credits from the standpoint of the sewerage system as a whole, a
central bank system seems to offer considerable advantages over a private
capital system of banking and trading I/I removal. The apparent advantage
of mobilizing private capital to address the I/I problem suggested by a
pri’:ate capital banking/trading system is minimal, particularly since the
same amount of capital could be generated through the sale of removal cre-
dits created by a central bank and the resources could be directed more
effectivly with a centralized structure.
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Nevertheless, adoption of a centralized banking and trading structure
would not solve the underlying technical problems.. In particular, the
absence of effective flow monitoring capability within the system, and the
practical difficulties inherent in effectively removing I/I (see discuss o
below), seriously weakens any banking and trading system.
The central bank alternative would obviously require enabling legisla-
tion. This legislation would both establish the bank and the basic trading
rules and provide an initial funding resource. One major policy issue that
should be addressed if establishment of such a system is proposed is the
extent to which both start-up and futtire costs should be borne by the
public at large and what portion should be borne by those seeking to
purchase credits. Should the entire burden be placed on “new development”
or should some portion of the burden be shared by existing system users.
Greater Than 2 For 1 Program
There appears to be some confusion by the Court as to the intent of
the DWPC’s existing 2 for 1 program and whether that program could be used
to Jjnificantly reduce I/I in the MDC system. The program was never
intended to replace the Commonwealth’s Construction Grants Program which
has been providing large amounts of money to communities for work such as
sewer rehabilitation and I/I projects. The sewer ban and resultant 2 for I
program was devised as an enforcement tool to get the particular --
community’s “attention”. Some people have used the following analogy to
describe the program: “it is like hitting the community in the face with a
two—by—four to get t•heir attention and then once their attention is
assured, develop a rasonably implementable method for reviewing, revising
and approving sewer extensions while not exacerbating flow problems within
the localized sewer system”.
To date there are 9 comunities on the 2 for 1 program and several
others are under review. Since the implementation of the program in 1980
approximately 5.5 million gallons of flow have been listed as possibly
being removed from the sewer system. In affidavits presented to the Court,
DWPC stated that even if all I/I specified as being removed from the system
was in fact removed, it would take over thirty (30) years to reduce the
South System flows by 60 MGD using the same 2 for 1 format and assuming
similar numbers of yearly permit applications. The 2 for 1 program is even
less likely to significantly reduce flows to the sewer system as the town—
wide I/I rehabilitation programs previously attempted by the EPA. In fact
the “hunt and seek method” used by developers to find and repair isolated
sources of I/I to justify connection of a new building is precisely the
type of 1/I rehabilitation procedure that all experts have denounced as
unworkable.
Professor Haar stated in his Masters Report the following with regard
to the current 2 for 1 program:
“The 2:1 reduction program is an interim remedy. Although it
will not result in the sane kind of significant flow reductions as will the
planned system-wide infiltration/inflow reduct.ion program it will provide
relief since, without it, new additions will exacerbate the current
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failures of the system. While hot bringing about large improvements, it
will prevent the situation from deteriorating further in the near future.
It can be initiated immediately and can maintain the status quo or even
slightly lesson the frequency and/or the level of treatment bypasses while
the longer—term remedy of a p1anned system—wide infiltration/inflow program
can be increased by changing the present ratio 2:1 to require a removal of
three or even four units of infiltration/inflow for every new unit of flow
added to the system.
It is thus possible to design the program in an equitable and effi-
cient manner. The DWPC has the authority to impose such a program on MDC
member communities. Experience with jndividual communities has shown that
development typically does not stop and that infiltration/inflow is
removed as a result of the imposition of such programs. Therefore, the 2:1
reduction program is an appropriate interlocutory remedy to be imposed by
the Court.”
DEQE believes that just increasing the percentage removals of ru
from the current 2 for 1 to 3 or 4 for 1 will have no measurable impact on
bypassing and overflows into Boston Harbor. We do believe that the sewer
ban and 2 for 1 program is effective in forcing a community to deal with
its sewage problems and provides a framework for closer coordination be-
tween DEQE, the municipality and the development cori nunity.
Therefore, DEQE proposes to continue with the current 2 for 1 reduc-
tion percentage as part of its enforcement actions in comnunities with
acute problems. However, the continued use and effectiveness of this
enforcement mechanism will be closely reviewed in conjunction with the
development of a system—wide approach for dealing with I/I in the MDC
system, which is discussed below. If the system-wide approach offers more
effective alternatives to permanent removal of hr. the use of the 2 for 1
program as an enforcement tool may be altered or discontinued.
Intearated Sewer Management Program
There must be a system-wide commitment for the develapment and imple-
mentation of an integrated MDC sewer management program. This program
must include at a minimum:
1) Provision of transmission, pumping and treatment facilities
with adequate capacity for the MDC system;
2) A realistic on-going I/I reduction program;
3) An effective sewer extension and permitting program;
4) An on-going municipal sewer maintenance/rehabilitation program
for all communities within the MDC system; and
5) A system-wide flow monitoring network.
We further believe that these five program elements can be implemented
and that much of it is currently on-going as specified below:
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1) Capacity : The MDC. and many of its member communities are
already implementing this program with such projects as the
Nut Island and Deer Island Primary Upgradings, East Boston
Pumping Station, Framingham Interceptor, Charlestown Pumping
Station, etc. The Procedural Order Item #23 tracks the
compliance for most of these ongoing projects.
2) I/I Reduction : The Departement plans to utilize the $100
million grants program (if enacted) to develop a state—of—the—
art I/I rehabilitation program which could remove DEQE from
the artificial cost effectiveness regulations required for the
expenditure of EPA grant monies. We would like to be able to
define major problem neighborhoods and rehabilitate all sewers
and associated facilities within the entire area wit1 pre— and
post— flow gauging. Based upon the effectiveness of those
projects we would develop a priority rating system for the
entire MDC system and begin funding neighborhood reduction
projects.
3) Permits : DEQE has developed an interim program to ensure ade-
quate reviews of all permits within the MDC service area.
DWPC has sent requests to all South System municipalities
requesting copies of all building permits issued by them from
January 1982 to the present. This data will be cross—checked
against Sewer Extension Permit Applications to determine the
extent of compliance with our regulations. An extensive educ—
tional program has also been initiated by OW?C to help ensure
compliance with our permitting program.
4) Ongoinq Municipal Rehabilitation : This is the most difficult
aspect to control and enforce since it is strictly a local
function with no state or federal regulations mandating the
nature and extent of such work and no outside funding sources
available to the municipality to offset the costs. A thorough
sewer maintenance program would require the expenditure of
significant amounts of local monies. Due to the current
financial constraints imposed upon the municipal governments
and the constraints upon new state regulations that increase
costs imposed by the Proposition 21 tax cap legislation, it
can almost be guaranteed that any type of elective expen-
ditures (preventive maintenance) will not take place. DEQE
believes that this type of work will become much more attrac-
tive to the municipalities if a method of assessment versus
flows is devised and implemented by MDC.
Also under existing regulations (MDC regulations and most local sewer
ordinances) it is presently illegal to discharge clean water (vooling
water, storm water, or groundwater) to the sanitary sewer systems. However
these regulations are not strictly or actively enforced in most cases. Any
preventive rnanintenance program should be “supported” by a strong enfor—
cenent program conducted at the local, district (MDC) and state (DEQE)
levels aimed at eliminating to the maxii in extent feasible illegal conner—
tions of clean water into the MDC and mem5er communities sewer systems.
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Enforcement activities would be cohducted by parties such as the MDC
Industrial Section; local public works departments, building and plumbing
inspection personnel; with general oversight by the DEQE — DWPC. The
system—wide monitoring capability would be used to target priority areas
for enforcement and investigations; to evaluate results and to monitor the
possibility or reconnection. Available penalties would be examined and
modifications proposed where appropriate.
5) Systemwide Flow Monitoring Network : The capability to monitor
and evaluate flow continuously throughout the MDC system and
at strategic locations within its member municipal systems is
essential to the proposed program of minimizing extraneous
flow in the system. The information gained through this capa-
bility could be utilized: a) in both the Federal and State
Grants Program for setting priorities for funding and eva-
luation of construction and rehabilitation work; b) in the
Enforcement Program to identify prime areas for investigation
of illegal connections; and c) on the Incentive Program in
establishing the flow upon which sewer charges will be based.,
Continuous system—wide flow monitoring capability is a prere-
quisite for implementation of the proposed flow based sewer
charge system and for a realistic banking and trading systerrr_
In summary we wish to again stress our belief that an intergrated
approach to the regional sewerage system difficulties is needed. The only
way to develop such an approach is to jointly educate all participants
(State Agencies, Municipal Officials, Area Legislators, etc.) in the
various facets of th process. We do not want to blindly grab onto one or
a combination of quick—fix alternatives. Our own experiences with the 2
for 1 program is a perfect example . Our agency saw the program as a
readily enforceable and implementable method of reducing flows in the local
and MDC sewerage system to mitigate sewer overflows and surcharging while
allowing for reasonable continued growth to occur. DEQE, like EPA, assumed
that I/I reduction techniques used in the late 70’s and early 80’s actually
removed a significant percentage of I/I. We have recently learned that
such an assumption was incorrect to a large extent. The development of
our proposed Technical Advisory Group, can be used as a spring board to
begin this eductional process.
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. ttacvnent .j. - • ““
:valu3tjc,r o1 Irfi1eratjo /In:iow .o _ ..., ... Rc ort
July 1980
U.S. Environ nta1 Protection ?.ge c’,
CHAPTER 4
The findingsof this.study indicate that Sewer Svste Evalua-
tion and Rehabilitation generally does not result in sub—-
s r.tial systen I/I flow reductions. The conse uence of
.thizis that returning I/I has used up all or substa ja1
port onsc the reserve capacity of new and u graded, treat—
zac .l .t es and thus, shortened the plants’ design lives.
I/I is not going to be removed by ignori git -—.Thus;—j 5 -—
eer aJ. that it be evaluated in order that sewerage works
ca b esigned and operatec effectively.
The follcwin recom mendations are offered as possible courses
of action that EPA can undertake in order to ensi e ti at
I,: is effectively addressed in design and operations of
s- : rage works. These recommendations offer a variety of
: - ic that could be im?leTnented. Some recodatic s
c 2.d be implemented together while others could not A
dizcu sicn is presented with each reco endation.
C> E DATIO ’1 l
REuSE THE I/I PROGR ’i f ETHODOLOGYI
Is — — ‘— ‘- — . _, -.
The existing i/I Progren methodology simply has not achie red
expacted results. It has become evident that successful
r& ebilitation is more of an e>:ce?tion than a gemexal case;
just the opposite of ‘ hat was assumed when the I/I Picgraza
w s initiated. If the I/I Program is to be continued., the
th ology be revised.
The following arc o a of the possible changes to Sewe:
S7stem Evaluations that would provide more realistic initial
data, thus, resulting in i ore successful projects :
- St r.!ardi:e cuantificaticn of system—wide I/I_
Cu:: n:1y, a wi c variety Of para ct :s are used in
design ar. cost e cctiv cz analyses for the
f1c : c c :: 1.2. w t ce o I/I, - at: da-.;
v : -’ ...-¼:1 I/I, I/I at 1OQ v..:: - This
c. . .,r,’:r t j :n :?1lv C5t t C d
tO D OV1( e 1t .
‘. cr.: . n cost er:: v: : . al.
7 .:r. . :cr I,’ r.
‘1—1
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i/i flow monitoring and televis.icn inspection 111.Lst
be rformed during wet weather and/or high ground-
water conditions (I/I Hunting Season) - This study
hz z found that in many instances television i .spec—
tion was not perfo ed during peak high groundwater
conditions. Any leaks observed from manholes, sewers
and house service connections were factored u to re-
flect. peak flows. This practice has resulted in er—
ronsous flow estimates from point sources. It is
L perative that flow monitorthg and television inspec—
tion be performed during a specific “hunting season” •
This can be defined by using a specific syster . total
flow parameter: for example, three (3) times base
flow, or a system I/I rate greater than 6,000 gallons
per day per in-mile.
Establish a realistic system I/I rate to be used as
a cut-off for projects to proceed to Sewer System
Zva1uatio Surveys, ie, 6,000 gallons per day er
inch mile.
EPA established an infiltration rate of 1,500 pd/irL
mile including service connections in its PR i7 —lO
Any rate balo ; this value was considered non—excessive..
This study has fo nd that most of the projects had
-rabilitat n high week I/I rates exceeding
6,000 gpd/in—mile. Post rehabilitation high week
I/I rates ware reduced from above to belo 7 6,000
ctd/in—mile in only one (1) project. It may be pos—
that cost-e:rective rehabll2.tatlon work can be
a:hi ved in sewer systems with pre-rehabilitation I/I
: zt below 6,0CC god/in-mile, but chances of success
would be minL al. Establishment of a cut-of f I/I
rate of, say, 6,000 gpd/in-mile could speed u any
rojects, and result in more successful rehabilita—
Include limited television inspection and rainfall
sL ulaticn work in the I/I Analysis ?hase.
In the I/I Analysis Phase, estimates of I/I to be
r no;ed are made, rehabilitation programs projected
and cost—effectivenezs estimated. All this is done
wjth ut firm documentation of There the I/I is coming
from. This study has found that ‘a major source of
i/I is house service connections, and the flow iroa
4—2
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this sourco is not detectable in the I/i Analy is
Phase. In most instances, the flow measured or
estimated during this Phase erroneously ass nas that
most of th. I/I is from manholes or sewer lines, and
the resulting reco r ended I/I. removals via sewer
line rehabilitation looks attracti ie. If limited
television inspection identi d s ecific sources, a
more realistice rehabilitation program could be out-
lined. Pa:foming limited television inspection of,
say, 2 to 5% of the system, and possibly limited
rainfall sii ulation where inflow is suspected, during
the I/I Analysis Phase would result in ore realistic
ccnclusions of this Phase of work.
Consider the impact of ±/1 from house set-vice connec—
tion and groundwater migration aftef sewer line
rehabUitation.
This study has found that estimates cf I/I to be re—
duced by rehabilitation generally have been in the
60 to 0% range, while actual reductions have generally
been n tne 0 to 30% range. In acc t on, curing
cost effectiveness analysis no consideration is given
fo: migration of groundwater to non-rehabilitated
sources. The oercent I/I reduction achievable by
main barrel sewer line renabilizat on, nclu 1flg
test and seal prog:ams, is dependent on one (1) par-
ameter more so than any other: the percentage of I/I
coming from main barrel defects versus the pecentage
co: ing from house service connections. eteievising
curing zh .s stucy found tnat I/I coes ig:ate to non—
rehabiljta ted sources, and that rehabilitated sewers
where less than 60% of the pre-rehabilitation I/I
was docum2nted coming from sewer joint leaks (versus
house service connections) achieved reducticns less
than 25%.
A rough estimate of this important parameter should
be ascertained as early as possible. Under the pre-
sent methodology, t:iis parameter is not defined until
at least the SEES televising phase. In certair. cases,
where SSES televising was foregone in lieu of pro— -
posed test and seal program, or when SSES televising
as done during low groundwat :, the se ;er line
jOint leak percentage was not asce:zained at eli.
In order to re listica1ly predict I/I percentage
ro;al , we have daveloped the cu: e3 presented in
Tig re 4—i. Zsti:r atir g I/I Reductions. These curvcs
. d ‘elo e fro -r actual rc :ul:z a’d :e:liztically
i: cDrpor e retu:ning I/i from h se s r ice connec—
2.Ofl5 ar f mig:at n.
1
.8
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0 25 50 75 tOO
% INFILTRATION REDUCTION
I/I REDUCTION
FIGURE 4—I ESTIMATING
CURVE A
• TEST a SEAL WITH LIMITED
SERVICE CONNECTION flEP !fl
CURVE B
REPLACEMENT
SLIP LINE
• TEST a SEAL WITH EXTENSIVE
WORK ON SERVICES
1/ )
I—
0
U i
ti—
(U
-J
‘Ii
c i:
C r )
0
LL
IL
0
U)
U i
L)
>
a:
Ui
U)
0
a:
Li
I I—
0
-------
Stanciardjz television inspection flow. estir at ng
techniqt e.
Visual flow estimation of leaks bserved •during tele-
vision inspection can vary by as much as +5O .. This
data is .a significant element of any cost effective—
nass analysis and resultant rehabilitation procr _
A standardized technique should be developed_ -
2
REQUIRE THAT REHABILITATION BE PERFORMD ON A “PATCW’ BASIS..
SUC 1 THAT NO PIPE IS LEFT UNREHABILITATED IN AN AREA CHOSEN
FOR REHABILITATION, THIS WILL MINIMIZE THE OPPORTUIilTY FOR
I/I TO MIGRATE FROM REHABILITATED SEWER SECTIO’NS TO f ON—
REHABrLITATED SECTIONS 1
T::.. notion of I/I migration from rehabilitated sewer sac—
t n to non-rehabilitated sections is widespread. Reha.bili—
t :ticn work can zc eeimas take on a “little bit here, little
bit there” appearance; thus maximizing the opportunity for
I/I tc igrata upstream or downstream of rehabilitated sotircas
acceptance of test and sea]. grouting over specified
j in g:o ting wa based on resolving the I/I migration ef—
:: e x ensive .test and seal, as well as other rehabilitation
t: u may be reçuired to minimize the I/I migration
p:oblam.
— ‘“ I -. re. m
1 . —. .. .i i. 1.
DECREL SE THE STANDARD DESIGN LIFE OF iR ATI iENL. PLANiS FRON
20 Ya RS TO 10—20 YEARS., DEPENDING ON THE ABILITY OF LONG
RA; GE RE} ABiLiTATiOU TO REDUCE I/I.
T. : : ; nt ituatior., in part d to the failure df the I/I
is eh t n w C: u? racec t:e tr nt plants are at or
r. r a: n c c .tv afzc: only cn (1) or t o• (2) years of
c: z .-n. ccr u-ities ar f c with planning now or
4—5
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in thc r.car future for either substantial sewer line.rehab—.
iiitation tnd/cr pia t ex ansion. These communi .es were, in
face, cxp Ctiflg to attain 20 years of useful life from
— ‘
A way around the present dilemna is to be realistic and not
OV i optimistic about the effectiveness of sewer-line re—
habilitation and trsatment plant design life. The following
• infor a ion hou!d be considered du ing the planning and/or
operation of new sewe age works.
Recognize that generally a sewer system rehabilita-
tion program will reduce 1/I from 10 to 30 . There,
of course, will be exceptions to this general rule..
“One shot” sewer system evaluation and r habLritaeion
will not identify and/or eliminate all th& sewer
system I/I problems. - on-going operation a d main—
tcnanc program must be L ip1emented to include in—
vestigatir.g new and old I/I sources and performing
on-going rehabilitation.
The actual effectiveness of rehabilitation in red ic—
ing I/I flows in the system should be determined,
after rehabilit €ion is complete.
Thus, the approach to sizing treatment plants would be to
i l c e a lercer i/ flow com onent (than would be esti ated
a±: : rehabilitation under the present methodology, which
to e::pect large reductions in I/I) and a smaller re—
z r e capac ty f r base flow expansion. This would tend to
; ? th average treat ent plant size and cost about the -
s a a under the present I/I methodOlogy. By designing r e
lants to handle not—so—drastically reduced I/I flows, and
p yin for this by limiting future reserve capacity the
actual changes in I/I nd base flow can be monitored, and
thus, facilitate decisions on additional rehabilitation andf
or plant c x nsion as the 10 yea: or more design. life-is
apprcached.
REC 1 -: YO.;TION 4
E FO CE SE’dER LINE OPERATION AND MAINTENANCE PROGRPJIS.
O tr2tion d maintenance (0 & i -i) progr s on sewer systcms
are r q f: d p:r PR i7!—lC- This study has fou d that this
I —6
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is nc t being ir 1e Gnted. .on—go ; 0 ! orogra will
disco er fl’2w I/I Sources and often these will be easily re—
t.tir d It is .in the best interest of the co unity, from
a co t effective pe soactive to cont r’a1 v ava 1 ua e ar d re—
/! that s less ex?enslve to elii nate than to treat
C0 Z DATI0N S
AJDRESS THE PROSLEM OF I/I FROM PRIVATE SOURCES SPECIFICALLY
THE DETECTION., DISCONNECTION A D REPAIR OF PRIVATE I/I
SOURCES SUCH AS SUN? PUMPS.. DRAINS, ROOF LEADERS A LEAK—
U G SERVICE L TEP 4LSI
DIScUSSION
I/I con thuted from orivate sources generally constitutes
o er 5Q of the system I/I. Thus, treatr ent plants will
ct to have high I/I flows during wet weathe and high
g:o’ ;ater conditions if private I/I sources are not re—
In order to reduce treatrnent plant sizes ai airi—
good treatment plant operation, cor. unities should ad—
c r ss these private l/T sources. Thcse co unities that
ig’c:e this major problem should be penalized.
? DATI0
c• . ‘CcTirAT t-IDTPI A IINr1T !r 7Dlv-TIfD: TL!, T J 1 t
Li r irL I l u ri unu hu iLiw U riL .- ..LLJ;I
F R ?: ASED RE;-L43ILITAT1ON WITH GO/NO-ED DECiSION POIf’ TS
• Ci,f U DL..”C -
1. IL.. LtLI1 riu- ...,
( \T
T; e 1/ 1 reduction aohieved by rehabilitating a collection
s t cannot be ascertained finally until after the work
iz cc plete and the system e>:periences design—level pre—
ci iticn/sn . elt conditions.
n atter ho ::e1l-docu anted the pre-rehabilitatioi . I/I
so rc s, it at:aars that counzin on an timated reductiort.
cosr. ef czive is analaoous to counting on a cood be
t core zhro gh. A phased program o: r ao2 .l .tat fl ouJ
the actual reduction achieved by rehabilitating part
C: a coll2ct:cn sysze to be used in dat2r ining the èost
cti’.n ss of f :zher rehabilitaticn.
4—7
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Ped rch i1itation could be integra ed with seivice.pop—
ulat d e: :PaI’s1on; i.e. phased reduction of the I/I design
cc: 2ona1t could kee up treat ene plant design capacity
base flow expansion.
There are p:obler s with .such an approach. The variability
of rainfall and snowme lt from year to year could lead to
fft’.se conclusions about achieved reductions. f ndi g
- ct re znat a1lcc s Go/No—Go dec .sions after each ohase
cc .d e an ad inis rative n ghtnare.. The problens i vo1ved
funding, in particular, would rec’ ire detailed evalua—
ti before adopting any forrn of phased rehabilitation.
7
W 1ITUTE A STUD? TO DETEP UNE THE ACTUAL EFFECTS OF 111
LO Ji G O TREATMENT PL4NT PERFORMANCE. USE THE RESULTS
TO ESTABLISH GUiDELINES FOR DESIGNING FOR I/I,
Thera is currently no standard design practice for ha d1ing
i/I ot: : than the use of standard design hydraulic loading
r t s dcveloped for rew savage. A rational basis for treat—
i:: diluted se :age is ç arly needed, based on the docunented
e t of I/I loading on plant performance. The capacity
t: - ent plants to weather both short-term “inflo
a:d long—term “i’ ltrat on ’ should b determined, as
i : :v :eo:esent a significant “source’ of I/I capacity in—
t in standard treat ent plant design practice.
Z D..TION 8
I T TUTE DISCHARGE PERMIT REQUIREMENT VARIANCES DUR1N5
P .:• oDS OF HIGH I/I FLOWSJ TAKING PIDVAUTAGE OF Th:E INCREASE
[ i!L TiVE CAPACITY OF RECEIVING WATERS THAT GENERALLY
II It
jLU 1 r i :S rilGn I/I
•% •• _•1c —,.s
I L .1 _.‘.. .
- . nil I/I loadings r y cause treat ent plant efficiencies
r c d well b lcw the recuired 85% re iovals for Bio—
c ic l Oxygen Demand (3CD) and Suspended Solids (55)
acc p ying dilut!on effect of the 1/! generally enab].es
::i c e±!].uent ch r ctc:is ic5 to rer ain elc ; 3D iliigrans
!itc . The to::;l of these effluent ;a: etcrs
b i: c: asec3, :,‘: the high : receiving te: flc rs may
- . s .ly ;e the az ;i; .iletivc capacity.
4—8
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cc: : ? T!O 9
i: STLTUTE A (1O ATOR1UM ON ALL I/I ANALYSES AND SE 1ER SYSTEM
EVALUATION SURVEY REPORIS THAT ARE UND: WAY OR RECEi iLY
COr PLETED 1 THESE PROJECTS SHOULD BE REVIEW AND 1• 3D [ FIED
ACCORDING TO THE FINDINGS OF THE STUDY,
DISCUSSION
I/I f_ alysas and Sewer System Evaluation Surveys are still
being based on unrealistically high expected reduCtions.
One (1) or two (2) years from now these projects will be con—
structed and the same findings of effectiveness will be
m. de as in this study. Thus, in the long run it woiild be
beneficial to delay these projects for a short period now,
and obtain more realistic results when sewer line reb bilita—
tion is completed.
4—9
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Estir ated
M D 2
0.63
125.0
16.2
8.8
5.1
10.3
7.1
.6.0
N/A
3.1
-
4.1
11.3
9.2
22.4
2.6
1.2
3.3
3.7
1.2
2.1
•) ‘ .,
• -,
PE.K 1/.1 ? .EDUCi’ICN
SOUT.- ! TROPOLI AN DIS ICr
Existing I/I’ Procsed
C-PDIM 3
3330 0.36
20830 66.0
10750 9.05
9150 5.30
7800 2.85
12500 5.9
3180 4.2
26500 1.0
N/A N/s.
3500 2.2
3250 2.0
3100 2.65
5530 6.5
8310 6.0
9150 12.9
3660 1.5
3860
6350 1.2
2370 2.5
2900 0.7
5550 5.1
139.11
I/I
G?DI 1
-a
11000
6000
5500
4350
7150
1900
4400
500
1850
2000
3200
5400
5250
2150
2550
3130
1600
1300
3500
cC : : NIFL
S ston*
Car.tort
De rn
: r 1 r. .ngh m
Hc1 :cok
N i:k
N
1 .’ — i—. .
& __.e_ —
O incy
s tc• . tcn
-
.: as d .rc: j r- c rr :-t - icn .
c :r c :,
- = G-.1! ’ r :... ‘ :
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