November 28, 2023 - Center for Coastal Studies

U.S. Environmental Protection Agency · from the EPA · 2 pages · 428 KB
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Center for Coastal Studies Provincetown 
HIEBERT MARINE LABORATORY • 5 Holway Avenue • Provincetown, MA 02657 
tel (508) 487-3622/(508) 487-3623 fax (508) 487-4695 
November 28, 2023 
Michele Barden 
U.S. Environmental Protection Agency - Region 1
5 Post Office Square, Suite 100 (06-1}
Boston, MA 02109-3912 
Submitted via email to: barden.michele@epa.gov 
Claire Golden
MassDEP, Surface Water Discharge Program
150 Presidential Way
Woburn, MA 01801 
Submitted via email: MassDEP.npdes@mass.gov 
Dear Ms. Barden and Ms. Golden, 
The Center for Coastal Studies (CCS} appreciates the opportunity to provide comments to th e
US EPA Region 1 and to MassDEP on the draft National Pollutant Discharge Elimination System
(NPDES} permit issued to the Massachusetts Water Resources Authority (MWRA) Deer Island
Treatment Plant and Combined Sewer Overflow (CSO} (MA0103284}. CCS has been contracted
by MWRA since 2010 to monitor three of the farfield stations: two in Cape Cod Bay {CCB} and
one near Stellwagen Bank National Marine Sanctuary (SBNMS). Based on our experience
monitoring these stations, we would recommend the following revisions to the Draft Permit: 
Section (e), Table 3: Water Column Parameters in Cape Cod Bay and Stellwagen NMS 
In the description for the Hydro profile under the "Depth" column, only downcast data are 
collected. Because we do not deploy our CTD with a rosette system, w e do not collect water 
samples on the upcast so only downcast data are useful in the characterization of the water 
column. Also, under the "Parameter" column, Transmissometry data are not a part of the 
CCB/SBNMS monitoring plan and should be removed from this table. 
We also recommend removing Alexandrium cantenella (row 3} from Table 3. In the current 
monitoring plan for CCB/SBNMS, Alexandrium is enumerated in the surface phytoplankton 
samples that are taken routinely during each survey. Testing via gene probe methods is not 
included but has been done on occasion when conditions warranted additional monitoring 
twice in the 13 years we've been monitoring. Because Alexandrium has been observed so

infrequently, additional testing beyond the routine sample collection does not appear to be
necessary. 
CCS values the monitoring work we've been involved with under the guidance of MWRA. We
also encourage and support modifications to the current permit that address the impacts of
larger scale environmental concerns including climate change and contaminants of emerging
concern. We appreciate your consideration of our proposed revisions. Should you wish to
discuss anything further, please do not hesitate to contact me. 
Sincerely, 
~i Richard Delaney
President and C.E.O.