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Slide deck for Public Meeting on July 12, 2023

U.S. Environmental Protection Agency · from the EPA · 22 pages · 1.8 MB
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Public Meeting
National Pollutant Discharge Elimination System
(NPDES) 
Draft Permit
for the
Massachusetts Water Resources Authority (MWRA)
Deer Island Treatment Plant & Combined Sewer Overflows 
Michele Barden, EPA Region 1 
July 12, 2023

Agenda 
• Purpose of the Meeting 
• NPDES Permitting in Massachusetts 
• Overview of MWRA Deer Island Treatment Plant Permitting History 
• Overview of Draft Permit 
• Outfall T01 – the Massachusetts Bay outfall 
• CSO Treatment Facilities 
• CSOs 
• Other significant changes 
• MassDEP Permit 
• Questions 
NOTE: This meeting will end promptly at 7:45, so we can promptly start the Public Hearing starting at 8:00. 
July 2023

Purpose of this Meeting 
• Explain the NPDES permitting process 
• Explain the elements of the draft permit 
• Following this meeting, we will be holding a public hearing. You will be able to
comment orally during the public hearing. 
• Comments may also be submitted in writing during the extended public comment
period which now closes on August 30, 2023. 
• Oral and written comments have equal value, and both will be addressed in EPA’s
Response to Comments which will be issued along with the Final Permit. 
July 2023

NPDES Permitting Program in MA 
• EPA Region 1 issues NPDES permits in MA and NH. 
• EPA and MassDEP issue two separate permits: a federal NPDES Permit and
a state surface water discharge permit. 
• MassDEP, generally, incorporates the EPA permit into the state permit and,
if necessary, adds any state-only requirements. 
• The comment period for both permits runs simultaneously. Those wishing
to comment on either or both permits should submit comments to the
appropriate agency. 
July 2023

EPA’s NPDES Permit Process 
July 2023 
EPA prepares
Draft Permit
and
accompanying
Fact Sheet 
Draft Permit
goes on Public
Notice for
minimum of 30
days 
Permittees, co-
permittees and
members of
the public
submit
comments by
the end of the
Public Notice
Period 
EPA reviews
the comments
received and
prepares a
Response to
Comments and
the Final
Permit 
Final Permit
and Response
to Comments
are issued 
Appeals 
Petition to the
Environmental
Appeals Board 
(Within 30
days from the
date the Final
Permit is
issued) 
If no appeals,
the Final
Permit goes
into effect on
the first
calendar day of
the month
following 60
days after the
issuance date
of the Final
Permit.

MWRA Deer Island
Treatment Plant
Permitting History 
1985 - MWRA formed by the
Massachusetts’ Legislature 
1991 – Sludge discharge to Boston
Harbor ends 
1995 - First stages of the improved
primary treatment units begin
operation 
1997 - First of three batteries of
secondary treatment started up 
2000 – 2000 NPDES Permit becomes
effective, and discharge is moved
from Boston Harbor to the
Massachusetts Bay 
July 2023

The 2000 MWRA DITP
Permit 
• The 2000 Permit was developed based on effluent data from the
old primary treatment plant and a pilot plant since the Deer Island
Treatment Plant was still being built. 
• Stringent effluent limitations 
• Extensive monitoring of the effluent for non-limited
parameters 
• It also focused on assuring the new discharge to Massachusetts Bay
did not negatively impact Massachusetts or Cape Cod Bays. 
• Ambient Monitoring Plan 
• Contingency Plan 
• Outfall Monitoring Science Advisory Panel (OMSAP) 
• The permit also included requirements for: 
• a Best Management Plan 
• a Pollution Prevention Plan 
• an Industrial Pretreatment Program 
• Operation and Maintenance requirements 
• Dye Studies to confirm dilution of the diffuser 
July 2023

Changes between 2000 Permit and 2023 Draft Permit for Massachusetts
Bay outfall (T01) – Effluent Limits & Monitoring Requirements 
Effluent Parameter 2000 Final Permit 2023 Draft Permit Change Reason 
Effluent flow, MGD 436 MGD, avg monthly 361 MGD, annual rolling avg,
reported monthly ↑ 361 MGD is the annual average design flow for
secondary treatment that was built 
CBOD & TSS, % removal No limit 85% removal, during dry weather ↑ Consistent with other NPDES permit for POTWs with
CSOs 
pH, S.U. 6.0-9.0 6.0-8.5 ↑ Brings consistent with current state regulations 
Fecal Coliform Bacteria 14,000 avg. weekly, 
14,000 max. daily 
980 avg. weekly, 
1960 max. daily ↑ Brings consistent with current state regulations 
Enterococcus No limit 2450 colonies/100 mL avg. monthly,
9100 colonies/100 mL max. daily ↑ Brings consistent with current state regulations 
Oil & Grease Narrative language Non-detect limit ↑ Reasonable potential based on effluent data 
PCB, Aroclors 1016,
1221, 1232, 1242, 1248,
1254, 1260 ug/L 
0.000045 ug/L avg. monthly, 
Report max. daily No limit ↓ No limit required as PCB Aroclors never detected in
effluent since 2000 Permit became effective 
Total Nitrogen No requirement Report calculated value from data ↔ Provides added information 
40 PFAS Analytes No requirement Report ↔ Region 1 standard requirement implementing EPA
Strategic Roadmap for PFAS 
Adsorbable Organic
Fluorine No requirement Report ↔ Region 1 standard requirement implementing EPA
Strategic Roadmap for PFAS 
July 2023 
↑ ↓ ↔  
More 
Stringent 
Less 
Stringent Report Done;
completed 
This table is part of a presentation. For specifics on effluent limits, monitoring
requirements and other permit requirements, please review the Draft Permit.

Changes between 2000 Permit and 2023 Draft Permit for Massachusetts
Bay outfall (T01) – Whole Effluent Toxicity (WET) Testing 
Effluent Parameter 2000 Final Permit 2023 Draft Permit Change Reason 
Whole Effluent Toxicity 
LC50, % ≥50% ≥100% ↓ Frequency reduced from monthly to quarterly, limit revised to 
≥100% to be consistent with MA policy. No exceedances. 
Whole Effluent Toxicity 
C-NOEC ≥1.5% ≥1.5% ↔ 
Frequency from monthly to quarterly, no exceedances; most
permittees with dilution between 20.1-100:1 have no chronic
limit but retained due to the significance volume of the
discharge and its location. 
Salinity No requirement Report ↔ Current WET testing protocols now apply to MWRA 
Ammonia Nitrogen No requirement Report ↔ Current WET testing protocols now apply to MWRA 
Total Cadmium No requirement Report ↔ Current WET testing protocols now apply to MWRA 
Total Copper No requirement Report ↔ Current WET testing protocols now apply to MWRA 
Total Nickel No requirement Report ↔ Current WET testing protocols now apply to MWRA 
Total Lead No requirement Report ↔ Current WET testing protocols now apply to MWRA 
Total Zinc No requirement Report ↔ Current WET testing protocols now apply to MWRA 
Total Organic Carbon No requirement Report ↔ Current WET testing protocols now apply to MWRA 
July 2023 
↑ ↓ ↔  
More 
Stringent 
Less 
Stringent Report Done;
completed 
This table is part of a presentation. For specifics on effluent limits, monitoring
requirements and other permit requirements, please review the Draft Permit.

Changes between 2000 Permit and 2023 Draft Permit for
Massachusetts Bay outfall (T01) – Ambient Monitoring Plan 
Requirement 2000 Final Permit 2023 Draft Permit Change Reason 
Ambient Monitoring
Plan (AMP) 
Implement monitoring plan 
• Effluent Monitoring 
• Ambient Monitoring 
• Fish & Shellfish Monitoring 
• Benthic Monitoring 
Revise AMP to reflect the
changes in monitoring
requirements ↔ 
Ambient monitoring plan requirements have been revised to
continue water column monitoring during the same target
weeks and at the same stations, drop duplicative effluent
monitoring, drop fish & shellfish and benthic monitoring as
questions have been answered. 
Enhanced rapid response monitoring for HABs and nuisance
algae to address regional changes. 
• Bays Eutrophication
Model (BEM) 
Update, run and maintain BEM
(at least annually) No longer required ↓ BEM is a hindcast model. Continued ambient monitoring and
enhanced HABs monitoring will address the concern. 
• Plume tracking Implement plume track Completed  Permit requirement is complete. 
• Food Web Model MassDEP & EPA to review scope
and determined if necessary Requirement met  MassDEP & EPA deemed unnecessary 
• Outfall Monitoring
Science Advisory
Panel (OMSAP) 
Conduct peer reviews, evaluate
monitoring data and advise EPA
and MassDEP; evaluate
exceedances of Contingency Plan
thresholds 
No longer a requirement  
In 2018, OMSAP stated ; “after 25+ years of monitoring, the
data show that the MWRA outfall has not adversely affected
Massachusetts Bay.” OMSAP also found that the original
questions that were the basis for the AMP have been
answered. They have encouraged a more regional approach
with coordinated monitoring with other major dischargers. 
• Lobster studies Contaminant monitoring No longer required ↓ Contaminant concentrations considerably less than CP levels. 
• Red Tide Monitoring
Stations 
OMSAP to investigate the need
for additional Red Tide
Monitoring stations 
2023 Draft Permit includes
monitoring and rapid response
monitoring for selected HABs ↑ Enhanced rapid response monitoring for Alexandrium, Pseudo
nitzschia, Dinophysis, Phaeocyctis, Karenia and
Margalefidinium to address regional changes. 
July 2023 
↑ ↓ ↔  
More 
Stringent 
Less 
Stringent Report Done;
completed 
This table is part of a presentation. For specifics on effluent limits, monitoring
requirements and other permit requirements, please review the Draft Permit.

Changes between 2000 Permit and 2023 Draft Permit for
Massachusetts Bay outfall (T01) – Plans and Conditions 
Plans/Conditions 2000 Final Permit 2023 Draft Permit Change Reason 
Contingency Plan Implement plan No longer required ↔ Outfall has been found to cause no adverse affects in MA Bay 
Operation and
Maintenance 
Focus on SSOs, develop
guidance for member
communities, eliminate
excessive I/I, develop
Regional I/I Reduction Plan 
Updated requirements including major
storm and flood evaluation &
mitigation requirement ↔ Consistent with other MA POTW permits 
Sludge Conditions 2000 Std. Conditions Updated Std. Conditions ↔ Consistent with existing federal and state laws 
Development of
Limitations for Industrial
Users 
2000 Std. Conditions Updated Std. Conditions ↔ Consistent with existing federal and state laws 
Industrial Pretreatment
Programs 2000 Std. Conditions Updated Std. Conditions ↔ Consistent with existing federal and state laws 
July 2023 
↑ ↓ ↔  
More 
Stringent 
Less 
Stringent Report Done;
completed 
This table is part of a presentation. For specifics on effluent limits, monitoring
requirements and other permit requirements, please review the Draft Permit.

Changes between 2000 Permit and 2023 Draft Permit for Massachusetts
Bay outfall (T01) – Plans and Conditions, continued 
Plans/Conditions 2000 Final Permit 2023 Draft Permit Change Reason 
Best Management
Practices Plan Develop & implement Continue to implement ↔ 
Assurance of
compliance with 436
MGD Flow Limit 
Reports on WWTP flows
and water conservation Effluent Limit ↔ Consistent with other MA POTW permits 
Pollution Prevention
Plan 
Develop, submit &
implement 
Update Household Hazardous Waste
booklet and school curriculum to
include CECs ↔ Focuses on household hazardous waste education, industrial
pretreatment program covers the industrial sources 
Groundwater
Remediation Site Waters Review of prohibition No requirement ↔ Required under MA law 
July 2023 
↑ ↓ ↔  
More 
Stringent 
Less 
Stringent Report Done;
completed 
This table is part of a presentation. For specifics on effluent limits, monitoring
requirements and other permit requirements, please review the Draft Permit.

Combined Sewer
Overflows (CSOs) &
CSO Treatment
Facilities 
• MWRA 
• 4 CSO Treatment Facilities 
• 6 CSOs 
• Boston 
• 27 CSOs 
• Cambridge 
• 9 CSOs 
• Chelsea 
• 3 CSOs 
• Somerville 
• 2 CSOs 
July 2023

Progress on CSOs 
Where it started - 1987 
• 86 active, uncontrolled
CSOs 
• 3.3 billion gallons of CSO
estimated annually 
• 0% of discharge flows were
treated 
Where are we now - 2023 
• 51 CSOs remain 
• 414 million gallons of CSO
annually (87% reduction) 
• 93% of remaining discharge
flows are treated. 
July 2023 
Note: Columns represent the annual
volume of CSO discharge flows.

Combined Sewer Overflow (CSO) Treatment Facilities:
Changes between 2000 Permit and 2023 Draft Permit 
Effluent Parameter 2000 Final Permit 2023 Draft Permit Change Reason 
Effluent Flow, MGD Report Report ↔ No change 
Rainfall/Precipitation Report Report ↔ No change 
BOD Report Report ↔ No change 
TSS Report Report ↔ No change 
Total Residual Chlorine
(TRC) 
0.1 mg/L avg. weekly, 
0.25 max. hourly Specific to each outfall ↑ Consistent with WQS 
E. Coli (Outfalls
MWR201 and
MWR205A) 
No limit 126 cfu/100 mL avg. monthly, 
410 cfu/100 mL max. daily ↔ Bring consistent with current MA WQS 
Enterococcus (Outfalls
MWR203, MWR205, &
MWR215) 
No limit 35 cfu/100 mL, 
130 cfu/100 mL ↔ Bring consistent with current MA WQS 
Fecal Coliform Bacteria Shall meet water quality
standards No requirement ↔ MA WQS have changed, and indictor bacteria are now 
E. coli and Enterococcus 
Whole Effluent Toxicity Report Report ↔ Includes effluent and ambient monitoring in current
WET protocols 
Dye Studies for the CSO
Treatment Facility No requirement New requirement ↑ Provide accurate dilution information for future permitting
decisions 
July 2023 
↑ ↓ ↔  
More 
Stringent 
Less 
Stringent Report Done;
completed 
This table is part of a presentation. For specifics on effluent limits, monitoring
requirements and other permit requirements, please review the Draft Permit.

Combined Sewer Overflows (CSOs) 
EPA’s CSO Control Policy requires communities: 
• Implement the nine minimum controls 
• Implement their long-term control plan 
• Conduct monitoring to verify that water quality standards are being
met 
July 2023

Additional CSO requirements 
• CSOs hydraulically connected to the Deer Island Treatment Plant are also
overseen by the Federal Court as part of the Boston Harbor case. 
• The Draft Permit authorizes discharges from these CSOs in accordance with
the typical year discharge frequencies and volumes that are in Attachment I
of the Draft Permit. 
• The discharges must meet federal and state WQS subject to and consistent
with any water quality standards variances issued by MassDEP and
approved by EPA. 
• MWRA and each of the CSO-responsible co-permittees must submit annual
reports including information on activation frequency and volumes. 
July 2023

Co-permittees 
Co-permittees are municipalities that own
or operate sanitary sewer systems that
contribute to the Deer Island Treatment
Plant. 
• There are 43 co-permittees that discharge to
Deer Island including the CSO-responsible Co-
permittees of Boston, Cambridge, Chelsea and
Somerville. 
• Only four sections of the draft permit are
applicable to all co-permittees: 
• Unauthorized Discharges (Section C) 
• Operation and Maintenance of the Sewer
System (Section E) including a major
storm and flood events plan. 
• Alternative Power Source (Section F) 
• Reporting Requirements (related to the
requirements above in Section J) 
July 2023

Region 1 Co-permittee
Background 
• Region 1 began routinely including co-permittees in
Publicly Owned Treatment Works (POTW) permits in 2005
in MA and NH. (The first was MWRA Clinton in 2000 at
MWRA’s request.) 
• Definition of POTW (40 CFR 122.2) includes the collection
system 
• Purpose is to require that all portions of the POTW,
including the collection systems that feed the treatment
plant are properly operated and maintained. 
• Provides accountability and enforceability of federal and
state collection system operation and maintenance
requirements. 
• Addresses ongoing problems of: 
• Sewer System Overflows (SSOs) 
• Infiltration (groundwater) 
• Inflow (stormwater) 
• Obstructions (roots, collapses) 
July 2023

Massachusetts Permit Process 
• EPA is NPDES permitting authority in Massachusetts. 
• Until June 2020, EPA and MassDEP jointly issued NPDES permits, and
State surface water discharge permits as one document. 
• Agencies now issue two separate permits. 
• MassDEP generally incorporates the EPA permit (by reference) into the
state permit and, if necessary, adds any state-only requirements. 
• State draft permit and draft Water Quality Certification can be reviewed at 
https://www.mass.gov/info-details/massdep-permits-approvals-for-
comment . 
• Comments on the State permit or the Water Quality Certification should be
submitted to massdep.npdes@mass.gov . 
July 2023 presented by David Boyer, MassDEP

MassDEP Surface Water Discharge (SWD)
Permit Requirements 
• Incorporates by reference all terms and conditions of the NPDES permit 
• PFAS testing: 
• Influent 
• Effluent 
• Sludge 
• All Significant Industrial Users (SIUs) [different from NPDES limited listing]: 
• Subject to categorical pretreatment standards; OR 
• Discharges and average of 25,000 gpd or more process wastewater to the POTW; OR 
• Contributes a wastestream that makes up 5 % or more of average dry-weather hydraulic or organic
capacity of the POTW; OR 
• Designated by the POTW as having a reasonable potential to adversely affect the POTW operation of
for violating a pretreatment standard/requirement 
• All PFAS results (NPDES and SWD) are uploaded to MassDEP database by testing
laboratory 
• Submittal of names and locations of all tested industries (NPDES and SWD) with updating
once a year as needed 
July 2023 presented by David Boyer, MassDEP

Contacts: 
EPA Contact: 
Michele Barden barden.michele@epa.gov or 
617-918-1539 
MassDEP Contact: 
Claire Golden Claire.Golden@mass.gov or 
617-997-8874 
submit comments to: massdep.npdes@mass.gov 
July 2023