Water Use & Pollution
Local, state, and federal enforcement of water quality standards is often lacking. Without it, pollution discharge and sewage treatment systems go unchecked; water is wasted, standards wither. Community water must be protected—from misuse, pollution, waste, or the dangers of neglect and poor enforcement. That’s why CRWC is constantly reviewing water-withdrawal and pollution discharge permits for industries, cities, and governments, large and small. Everyone from citizens to business, from mammals to farms, and from fish to town governments, is dependent on clean, available, water daily.
Five new energy production plants proposed in Massachusetts
While Governor Patrick and Executive Office of Environmental Affairs Secretary Ian Bowles have both stated their support for the known benefits of energy conservation and the jobs it will create, there now seems a rush to create new energy generation in our region. Five new proposals for regional energy production have cropped up in Massachusetts recently. All these new plant proposals will require significant amounts of water to cool their operations—a consideration the public often is unaware of. In most cases that water will be drawn directly from rivers, reservoirs or wells that can impact groundwater tables.
These plants are not proposed to replace old plants coming off-line--they are presented as answers to projected increases in energy use in the coming decade. CRWC wants to be sure the energy is necessary, and that individual plants use best available technology to protect critical resources.
We are also concerned with the plant-by-plant approach being taken by the DEP and other state agencies to assess current and projected energy needs. CRWC believes the Commonwealth should be looking at the aggregate impacts of so many new plants, and assess them with the “big picture” in mind. It would be irresponsible to do otherwise.
Pioneer Renewable Energy Project, Greenfield MA. This proposed 47-MW biomass energy plant will use wet cooling. The project will use between 550,000 and 880,000 gallons per day (gpd), mostly treated effluent from the Greenfield Water Pollution Control Plant (WPCP), returning only 161,260 gpd to the WPCP. Read CRWC’s comment letter.
Russell Biomass, Russell, MA is a proposed 50-MW biomass plant, to be located on the banks of the Westfield River at a former paper mill site. The plant is aiming to use “wet cooling” technology, and will withdraw up to 885,000 gallons of Westfield River water daily to cool its steam turbines. Only 15 percent of the withdrawn water will be returned to the river.
In 2008, CRWC joined several partnering groups to petition the Massachusetts Department of Environmental Protection (DEP) to make changes to a water withdrawal permit issued to Russell Biomass LLC. At issue is that DEP didn’t conduct a “safe yield analysis” as required under the Commonwealth’s Water Management Act (WMA.) If left as issued, the Watershed Council believes the permit won’t adequately protect the biological integrity of the nationally designated “wild and scenic” Westfield River under the plant’s proposed water withdrawal regime--particularly in summer and times of drought.
The larger concern has been that this ruling could establish a dangerous precedent in new plant permitting at DEP, at a time when new projects spring up monthly. Rather than employ more benign air cooling technology, Russell Biomass has chosen a cheaper solution: using up to 885,000 gallons of Westfield River water per day to cool their plant, while returning just 15% of that water to the river. In fact, the owners would be allowed to continue drawing water until reaching the lowest historic level ever recorded on the Westfield before shutting down plant operations.
Though DEP excluded testimony and expert witness appearances by Trout Unlimited and the Concerned Citizens of Russell, River Steward Andrea Donlon was able to present CRWC’s evidence at legal proceedings that took place in Springfield, MA on January 27, 2009.
DEP’s ruling on the permit challenge was expected that spring. Circumstances conspired such that is wasn’t until late-January 2010 that the Watershed Council received word that MA DEP’s Commissioner Laurie Burt had remanded the water withdrawal permit issued to Russell Biomass, LLC. Her decision required DEP’s Western Regional Office in Springfield to review the permit under an interim safe yield policy developed in November 2009.
Commissioner Burt’s remand came in light of recent policy changes implemented by the Patrick Administration in issuing permits under the Water Management Act. A groundswell of opposition ensued in the fall of 2009 when DEP changed its longstanding position on safe yield—including allowing rivers to be drawn down to conditions of severe drought. Scores of groups protested, and several resigned from the state’s Water Management Advisory Committee. In light of this, Governor Patrick reconsidered and DEP clarified and redefined its position on safe yield to include environmental protection factors such as water quality, a subject the presiding officer excluded from the appeal testimony last year.
CRWC and its partners had largely lost their 2008 appeal of the permit issued to Russell Biomass on water quality grounds, when arguing that DEP had not adequately considered safe yield in the Russell permit. The permit were upheld in August 2009, in a recommended decision by a DEP presiding officer. Parties had since been awaiting a final decision by Commissioner Burt.
Though, the Council is pleased that DEP re-affirmed that permitting decisions should be based on the best available science, it’s still deeply troubling that interim “safe yield” policies will guide the upcoming decision on the permit remand. Our position remains that the Westfield River deserves better protection than a permit allowing a corporation to draw on the river’s water down to the point of the lowest flow ever recorded—and then dump that heated water back in.
The Stony Brook Energy Center II, Ludlow, MA is an expansion of an existing plant. The new plant will generate 280-megawatt (MW) of electricity by burning natural gas and #2 distillate oil. Originally, Massachusetts Municipal Wholesale Electric Company proposed to use 1.13 million gallons per day (MGD) of municipal water from the Springfield Water and Sewer Commission (SWSC), returning 103,200 gallons per day (gpd) to Springfield’s sewer system. MMWEC changed its plans from wet cooling to dry cooling, however, and now propose to use an average of 122,000 gpd, returning only 22,000 gpd to the sewer system. The SWSC’s drinking water source comes chiefly from a tributary of the Westfield River, while its wastewater discharges into the Connecticut River.
The Pioneer Valley Energy Center, Westfield MA is a proposed 400-MW natural gas energy facility that will burn diesel in the winter. Initially, the developers were proposing to use dry cooling technology, which would have required 200,000 gallons per day from the Westfield public water supply, discharging 150,000 gpd to the Westfield Wastewater Treatment Plant. The developers now propose to use wet cooling and will buy up to 2 MGD from the City of Holyoke’s Tighe-Carmody Reservoir, a dammed portion of the Manhan River. They will also be using between 120,000 to 500,000 gpd from the City of Westfield’s water supply system. A small portion of the water used will be sent to the Westfield River via the City of Westfield’s wastewater treatment plant, while the rest will be lost to evaporation.
Palmer Renewable Energy Project, Springfield MA. This proposed 38-MW biomass energy plant will burn a combination of wood fuel from construction and demolition (C&D) processors and green wood chips. According to the MEPA Environmental Notification Form, the project will use an air cooled condenser instead of a wet-mechanical cooling tower, which minimizes water use. The project will use 115,500 gallons per day of municipal water from SWSC, returning just 23% of the water or 26,500 gpd to Springfield’s sewer system.
The tragedy at Kleen Energy. On Sunday, February 7, 2010, a tragic explosion occurred at the Kleen Energy Plant in Middletown, CT. Six people were killed and 26 were injured at the nearly-completed natural gas and low-sulfur oil burning facility. Large parts of the plants infrastructure were destroyed, and six major buildings on site sustained damage that rendered them unsafe. These will either have to be overhauled, or leveled and completely rebuilt from scratch. This has been a terrible tragedy for the families of those killed and injured. It has had a ripple effect throughout surrounding communities.
Two years ago, CRWC had been involved in solving a discharge and sedimentation problem affecting the Connecticut River on the border of the plant construction site. In May, 2008, CT DEP issued a Notice of Violation to Kleen Energy of Middletown, CT. Two months prior, a concerned citizen notified CRWC of serious sedimentation flowing down an embankment on the Connecticut. Kleen Energy was out of compliance with their general construction permit and tailings from a former feldspar mine were washing directly into the river. CRWC alerted Kleen Energy, Middletown officials, and the CT DEP. Later, along with the CT Rivers Alliance, CRWC brought a complaint to the Council on Environmental Quality.
Ultimately, new erosion controls were put in place by the company, and DEP was expected to revise Kleen Energy’s general construction permit by the end of 2009. The tragedy of February 7, 2010, will certainly reverberate through the process if Kleen Energy moves forward with rebuilding this project.
We submit comments on a dozen or more NPDES (National Pollutant Discharge Elimination System) permits in Massachusetts each year. In the past year, we have commented on municipal NPDES permits for Northampton, Northfield, Montague, Westfield, Erving, and Gardner; and several industrial NPDES permits in the Chicopee, Westfield, and Millers River watersheds. CRWC has also been involved with revisions to Water Management Act permits and registrations.
In 2007 MA Steward Andrea Donlon commented on the draft NPDES permit for the City of Holyoke’s wastewater treatment plant and its combined sewers (CSOs). CRWC also succeeded in convening a public hearing with regional EPA officials where citizens and staff argued for more oversight and enforcement on these critical issues.
In December 2007, CRWC filed a motion to intervene on an EPA enforcement action in a related issue against the town of South Hadley for violating their NPDES permit. As a result, CRWC was able to guide the penalties for these violations to a solution that included water quality monitoring of two tributaries in South Hadley where CSOs had recently been eliminated. Also--included as satisfaction for the town’s violation in lieu of fines, was the installation of a neighborhood water treatment device in a neighborhood with persistent storm water problems.
CRWC submitted comments on the draft 2008 Massachusetts Integrated List of Waters. The list identifies all “impaired” waters in the state. MassDEP proposed de-listing of the section of the Connecticut River from the confluence of the Deerfield to the Holyoke Dam as no longer being impaired because of bacteria. CRWC opposed the de-listing, as Holyoke still has five CSOs upstream of the Holyoke dam, spilling an average of 130 million gallons of untreated wastewater into the Connecticut River annually.
Photo credits (above): anonymous whistle blower
Image Credits at Right - Illustrations: Bill Singleton; Photos: ©Al Braden www.albradenphoto.com, CRWC Staff.