CRC comments on draft Chicopee WWTP NPDES permit

August 26, 2021

Subject:   Chicopee Water Pollution Control Facility and 15 Combined Sewer Overflow (CSO) Discharge Outfalls

Permit Number: MA0101508, Public Notice MA-20-21

Dear Ms. Deshais and Ms. Golden,

I am submitting comments on the revised draft National Pollutant Discharge Elimination System (NPDES) permits for the Chicopee Water Pollution Control Facility (WPCF) and 15 CSOs, on behalf of the Connecticut River Conservancy (CRC), formerly the Connecticut River Watershed Council.  The WPCF and CSOs discharge into the Connecticut River, Chicopee River, and Willimansett Brook.  The Connecticut River, an American Heritage River and America’s only National Blueway, is a regional resource that merits the highest level of protection.  The Connecticut River downstream of the Holyoke Dam to the Connecticut state border is listed as an impaired water body due to priority organics and Escherichia coli.  CRC is particularly interested in improving water quality in the Connecticut River so that it can support existing primary and secondary contact uses, even during wet weather.  CRC has also been following the work of the Long Island Sound TMDL workgroup to reduce nutrient discharges into Long Island Sound.

Nitrogen Requirements.  CRC supports EPA’s approach to setting nitrogen loading limits.  CRC recognizes that something will have to change, because the facility has been discharging an average of 1,890 lb/day and the draft limit is 647 lb/day.  We don’t know the cost of facility upgrades that will reduce nitrogen, or how that may affect the existing timeline for other wastewater-related expenses.  We would appreciate to be kept in the loop on any changes to timelines of CSO separation projects or major treatment plant upgrades.

Ambient Phosphorus Monitoring.  CRC supports the draft permit requirement for monthly total phosphorus (TP) effluent testing as well as ambient TP testing.  Section I.G(2) of the draft permit requires monthly samples from April through October collected at a location upstream of the facility, during even numbered years only, and tested for total phosphorus.  CRC supports the requirement of an approved Quality Assurance Project Plan, or QAPP.  CRC recommends that EPA and DEP require that the data be uploaded into the Water Quality Exchange (WQX) system so that the public and DEP have easy access to this data for use in the Integrated List and for scientific inquiry (retrieval through ECHO is cumbersome and difficult for non-discharge data like this).

PFAS requirements.  CRC supports the efforts of EPA and DEP to characterize PFAS inputs to river systems.  We support the quarterly influent, effluent, and sludge testing requirement shown in Part I(A)1, as well as the annual industrial discharge testing outlined in Section E(7).  Some early river testing results recently presented by MassDEP and the U.S. Geological Survey didn’t include any testing in the Connecticut River mainstem, but in eastern Massachusetts rivers with wastewater treatment plant discharges, levels were on the higher end of the ranges – see https://www.mass.gov/doc/pfas-in-massachusetts-rivers-presentation/download.  Understanding the inputs is very important to tackle this emerging contaminant.  We understand that these facilities are not designed to treat persistent chemicals such as PFAS.

Toxicity Testing

The Fact Sheet in section 5.1.10 explains why the toxicity testing is not going to continue the requirement for using brook trout as a target species.  But the DMR summary in Appendix A of the Fact Sheet indicates “no data” for the brook trout (only 2 years were required), so we are not able to determine that the fathead minnow turned out to be more sensitive than the brook trout.  As the Fact Sheet states, the facility violated the quarterly WET limit five times between 2014 and 2019.  What is the cause of the failures, and is anything being done to improve the situation?

CSO discharges

CRC volunteers conduct weekly bacteria sampling in the vicinity of the facility; Chicopee4Rivers Watershed Council tests every other week.  Please see results on our “Is it Clean?” web page at https://connecticutriver.us/site/content/sites-list.  Generally, sites downstream of the CSOs for Chicopee and Springfield exhibit high bacteria levels during and right after wet weather.

The Public Notification Plan described in I.H(3)g needs to be made accessible to the public.  This plan has been required in past permits and it’s not clear what the plan entailed.  Additionally, the City’s 5-year CSO plan on its website describes planned activities for the years 2004-2008  (see https://www.chicopeema.gov/DocumentCenter/View/1495/CSO-Five-Year-Plan).  This needs to be updated.

The Fact Sheet contained no information on the number and volume of CSO discharges.  This is a key part of CRC’s typical review of NPDES permits in CSO communities.  I obtained monthly CSO discharge volumes from EPA for the years 2017, 2018, and 2019 and had to hand-compile them to make sense out of them.

Below (next page) is a table of the compilation of the 2017-2019 results.

It is encouraging that 2019 had more rainfall than 2017, but a lower annual CSO discharge volume.  Nevertheless, Chicopee is contributing at least 90-200 million gallons/year of CSO discharges to the CT River system per year, after several decades of CSO elimination.  It is evident that CSOs 003 (Power Line ROW of James St) and 024 (Exhange Street) are the big contributors to the CSO volumes each year, accounting for more than half of the city’s CSO discharge volume.  CRC is curious where these facilities are in the current agreed-upon Integrated Plan schedule.  We do not have a copy of the new schedule.

CRC’s analysis brought up several questions that we didn’t get answered in the review period, as follows:

• When Chicopee reports CSO volumes for 7.1 and 7.2, is this the amount of untreated discharge from the Jones Ferry CSO Treatment Facility? Ideally, we’d like to assess whether the CSO Treatment Facility is performing the way it was originally designed, and that the number of untreated events is in line with what was modeled during the design and build phase.
• Appendix A of the Fact Sheet didn’t contain summaries on effluent results for the bypass flow. How often and what are the volumes of water discharging that have only received primary treatment and not secondary treatment?
• Outfall 40 is only listed in the 2017 table, not 2018 & 2019. Has it been eliminated?  If so, why list it as one of the CSOs covered in the new permit (Attachment B)?  If it still exists, what were the CSO discharge volumes for 2018 and 2019?
• Outfall 42 (Willimansett Brook) is not listed on the CSO tables provided by Chicopee. Has it been eliminated?  If so, why list it as one of the CSOs covered in the new permit (Attachment B)?  If it still exists, what were the CSO discharge volumes for 2017-2019?

Table:  Chicopee’s reported CSO discharge volumes as provided by EPA

General comments

CRC requests that EPA develop a way for the public to access annual reports submitted by NPDES permit holders without having to file a FOIA request, similar to the system available for reviewing annual NPDES MS4 compliance reports for each community.  If these reports are already available via the ECHO system or some other system, please let me know.

CRC appreciates the opportunity to provide comments on the draft permit.  I can be reached at adonlon@ctriver.org or (413) 772-2020 x.205.

Sincerely,

Andrea F. Donlon

River Steward

Cc:         Quinn Lonczak, Chicopee Water Pollution Control Department

Keith Davies, Chicopee4Rivers Watershed Council

Patty Gambarini, Pioneer Valley Planning Commission

Brian Harrington, MassDEP WERO

Roger Reynolds, Save the Sound

Jennifer Perry, CT DEEP