A River Runs Through It

I was doing some research the other day on the Nemasket River and came across an interesting statement which said “In the Wampanoag language it is said Nemasket means place of fish”. This, of course got me once again considering the Wampanoag Tribe’s push to build a mega resort casino in Middleboro.

The Nemasket River flows north from Assawompset Pond in Lakeville, then winds through Middleboro before emptying into the Taunton River. It has been noted as one of the most productive warmwater fisheries in eastern Massachusetts and is also the state's largest and most important Alewife fish runs. In the early spring the Nemasket River is said to run black with fish heading for the spawning grounds and it is notably a popular place for the canoeing enthusiast. What got me interested in the Nemasket River to begin with was the Intergovernmental Agreement between the Wampanoag Indian Tribe and the Town of Middleboro. The agreement has raised concerns about how much water the “project” would be using in regards to water conservation. This has lead me to question how much water the “project” will be discharging, and where it will be discharged too.

Under the agreement, the Town is required to provide utilities which not only includes water usage, but also includes wastewater discharge through Middleboro’s Wastewater Treatment Plant. The same plant that discharges treated wastewater effluent into the Nemasket river. So why the concern?…..I mean, it’s not like I actually live in Middleboro, right?

Well….clean water has been a national concern since the early 1970's. Because of that concern, in 1972, Congress adopted the Clean Water Act to protect all U.S. waters. Through this act, the U.S. Environmental Protection Agency and corresponding state agencies have been given the responsibility to regulate activities which threaten the quality of the nation's water resources. It is through the Clean Water Act that Congress was able to establish a comprehensive water policy for the nation and set as a national goal the elimination of pollutant discharges to the navigable waters of the U.S. by 1985. An interim goal was also set to insure that all navigable waters would be clean enough for fishing and swimming by 1983.

The U.S. Congress established this critical regulatory framework to ensure that

• No one has the righ to pollute the navigable waters of the United States. Dischargers are required to obtain permits.
• Permits shall set limits on the concentration of the pollutants being discharged. A violation of established limits can carry a penalty of fines or imprisonment.
  
• The best technology available shall be used to control the discharge of pollutants.

Each state, through a designated regulatory agency, which in our case is the MADEP, issues discharge permits and enforces the discharge limits established in the permit.

Wastewater treatment is a complicated multi-stage process that treats wastewater before it reenters a body of water, is applied to the land, or is reused. The goal in treatment is to reduce or remove organic matter, solids, nutrients, disease-causing organisms and other pollutants from the water before discharge. Sewer pipes are the means to collect the wastewater from homes and businesses and transport it to the treatment facility. From there it goes through the following steps:

Preliminary Treatment – The Preparation Step
Preliminary treatment is designed to screen out, grind up, or separate debris such as sticks, rags, large food particles, sand, gravel, toys, and anything else you can think of. Debris is removed at this stage to protect the pumping and other equipment in the treatment plant. The collected debris is usually disposed of in a landfill.

Primary Treatment – The First Step
Primary treatment separates suspended solids and greases from wastewater using settling tanks where it is held for several hours allowing the particles to settle to the bottom and the greases to float to the top. The solids drawn off the bottom and skimmed off the top receive further treatment as sludge. The clarified wastewater then flows on to the next stage of wastewater treatment.

Secondary Treatment – The Second Step
Secondary treatment is a biological treatment process that removes dissolved organic matter from wastewater using concentrated micro-organisms. Sewage microorganisms are cultivated and added to the wastewater. The microorganisms absorb organic matter from sewage as their food supply. There are three ways to accomplish secondary treatment; fixed film, suspended film and lagoon systems.

Final Treatment – The Third Step
Final treatment is required for the removal of disease-causing organisms from wastewater through disinfection (adding chlorine) or by using ultra violet light. Since high levels of chlorine may be harmful to aquatic life in receiving streams, treatment plants often add a chlorine-neutralizing chemical to the treated wastewater before stream discharge.
And then there is the lesser utilized step of….

Advanced Treatment
Advanced treatment is a vital step in the removal of nutrients such as nitrogen and phosphorus from wastewater. Chemicals are added during the treatment process to help settle out or strip out these nutrients. This is actually an important step because high levels of nitrogen and phosphorus are known to contribute to algae blooms and can kill fish in aquatic ecosystems.

The interesting thing here is that Massachusetts currently has 126 treatment facilities (not including Deer Island Treatment Plant) that discharge up to 435,000,000 gallons of treated wastewater but only 18% of these facilities have the advanced treatment process – source newwa.org.

The fact that advanced treatment is so underutilized should cause concern. High nitrogen and phosphorus loadings, or nutrient pollution, result in harmful algal blooms, reduced spawning grounds and nursery habitats, fish kills, oxygen-starved hypoxic or "dead" zones, and public health concerns related to impaired drinking water sources and increased exposure to toxic microbes such as cyanobacteria. Nutrient problems can exhibit themselves locally or much further downstream leading to degraded estuaries, lakes and reservoirs, and to hypoxic zones where fish and aquatic life can no longer survive.

Nutrient pollution, especially from nitrogen and phosphorus, has consistently ranked as one of the top causes of degradation in some U.S. waters for more than a decade. Excess nitrogen and phosphorus lead to significant water quality problems including harmful algal blooms, hypoxia and declines in wildlife and wildlife habitat. Excesses have also been linked to higher amounts of chemicals that make people sick. – source EPA

The Middleboro Wastewater Treatment Plant is a conventional activated- sludge facility that does utilize advanced waste treatment methods, such as nitrification for ammonia-nitrogen reduction and total phosphorus reduction by multi-point chemical addition. The facility is equipped with effluent sand filtration and utilizes sodium hypochlorite for seasonal disinfection and sodium bisulfite for dechlorination and releases treated wastewater effluent into the Nemasket River under an NPDES (National Pollutant Discharge Elimination System) permit issued through the US EPA and the Massachusetts Department of Environmental Protection. The Middleborough Wastewater Treatment Plant is the only NPDES permitted facility that discharges to the Nemasket River. – source MADEP

Although the Middleboro WWTP does utilize advanced treatment, there has been concern about the nitrogen levels being discharged as noted in public comments conducted during the last permit renewal process, and not without reason.

Water quality assessments of watersheds and subwatersheds have been performed by the MADEP Department of Water Management (DWM) to determine water quality status for supporting aquatic life as well as for use by people . There were two segments of the Nemasket river that were evaluated during this assessment:

Nemasket River (Segment MA62-25)
Location: From the outlet of Assawompsett Pond, Lakeville/Middleborough to the Middleborough WWTP, Middleborough.
Segment Length: 6.1 miles

Nemasket River (Segment MA62-26)
Location: From the Middleborough WWTP, Middleborough to the confluence with the Taunton River, Middleborough.
Segment Length: 5.2 miles

Summary for Nemasket River (Segment MA62-25)
In August 2001 DWM evaluated the habitat at one station (NR01) on this segment of the Nemasket River, approximately 200 meters upstream from Route 44, Middleboro. An alert status was issued for the support of aquatic life due to findings in the lack of stream sinuosity, homogenous flow regimes, and an absence of stable cover which resulted in poor fish habitat. Below is a summary of the assessment:

Nemasket River (MA62-25) Use Summary:
Designated and Uses Status

Aquatic Life - SUPPORT*
Fish Consumption - NOT ASSESSED
Primary Contact (eg.swimming) - NOT ASSESSED
Secondary Contact (eg. canoeing) - NOT ASSESSED
Aesthetics - SUPPORT
*Alert Status issues identified.

Summary for Nemasket River (Segment MA62-26)
The Aquatic Life Use was not assessed for the Nemasket River Segment MA62-26 due to too limited quality-assured water quality data available to evaluate effects, if any, of the Midddleboro WWTP on the Nemasket River. See below for table summaries

Nemasket River (MA62-26) Use Summary Table
Designated Uses and Status

Aquatic Life - NOT ASSESSED
Fish Consumption - NOT ASSESSED
Primary Contact - NOT ASSESSED*
Secondary Contact - NOT ASSESSED*
Aesthetics - SUPPORT*
*Alert Status issues identified.

The above information was taken from the MADEP website. Click here if you would like to view the actual study for the Taunton River sub-basins.

Now I understand that all this probably seems irrelevant to many people, but I ask you to take into consideration the Middleboro Wastewater Treatment Plant (WWTP) discharges into the Nemasket River and subsequently the Taunton River. The Taunton River has been placed in the impaired category based on data from the MADEP water quality assessment study yet both rivers are enjoyed by outdoor enthusiasts. The quality of the discharge from the Middleboro WWTP is critical to the health of the Nemasket and the Taunton River.

According to the NPDES permit for the Middleboro WWTP, the total flow discharge limit to the Nemasket River is 2.16 Million gallons per day average over one year but is currently discharging 1.25 MDGP from existing users. To date, there is little to no data as to the effects of the discharge on the Nemasket River. Now take into consideration the casino “project”. If you read the section of the agreement regarding wastewater it states that the Tribe will be allotted a discharge to the treatment plant a maximum average daily volume of 500,000 gallons, with a maximum 24 hour volume of 1 million gallons. Gosh, that sounds eerily familiar…so does this….

Section 11 of the Intergovernmental Agreement– Sewer and Wastewater Service
The Tribe will investigate developing on-site wastewater reclamation capacity to reduce sewage flows to the Town’s publicly owned treatment works facility.

Okay…. According to the agreement, the Tribe will assume all costs for infrastructure improvements for the existing Middleboro WWTP to accommodate wastewater generated from the “project", but does this section also give the Tribe the option to build it’s own wastewater treatment facility? Will this discharge also be introduced into the Nemasket River? I don’t know…and neither does Middleboro since no one has yet to see or hear about any conceptual design. However, we do know according to the agreement, the maximum potential discharge for the casino “project” to the Middleboro WWTP is an average discharge of 500,000 GPD with an allotment of 1 million gallons over 24 hours….one facility (mega resort casino) has the potential to discharge in one day, almost the same amount of water as the entire town of Middleboro, as well as sections of Lakeville on an average day. Jeez, if the Tribe also plans to have private wells on top of their water usage from the Town supply, I guess they will need to have an on-site treatment plant for any potential excess wastewater that can’t be treated by the Town.

Here is another thought to consider…The WWTP is allowed under its existing permit, a maximum discharge of 2.16 MGPD. Currently the Treatment Plant receives wastewater from the existing sewer lines at a total of 1.25 MGPD. An additional 200,000 GPD has already been allocated for an existing permit commitment for an industrial user. Now add in the 500,000 GPD proposed by the casino project and the reserve capacity for future expansion of wastewater for the plant totals 210,000 GPD. In my opinion, that doesn’t leave a lot of room for future growth for homes or business for Middleboro or for Lakeville.

So I ask….with all this need for increased wastewater treatment for what I consider to be a totally irresponsible project, what will become of the nitrogen levels in the Nemasket river? I mean, there is no data supporting the idea that increasing the discharge into an already stressed watershed won’t have a negative impact - there isn't any data to say that it doesn't already. Are we going to dismiss the potential damages to the river as trivial or not of a concern - all for the sake of “entertainment”?

Once again, I need to point out that there are groups of private citizens who work tirelessly to protect the Taunton River Watershed. They are trying to protect the diverse ecology so that they, and generations after them may enjoy this beautiful region. There are so many people, residents of this region, that see the beauty of the rivers and what they have to offer in the form of entertainment. What they don’t see is an inexhaustible water supply ready for the taking by deep pocket investors. We cannot allow anyone to dismiss the efforts of local groups and private citizens who have worked tirelessly to save the Taunton River and the watershed and move forward with such a “project” without even thinking twice about what people in other towns care about. In my humble opinion, I do not believe that any agreement to build a mega-resort casino should have been signed by anyone until a proper regional impact study was completed and assessed. Let’s face it…as my friend Gladys has so clearly stated in one of her blogs …what happens in Middleboro won’t stay in Middleboro.

I will say that I am honestly hoping that the environmental hearings will shed light on this “project” and answer some troubling questions regarding quality of life issues…knowing the design of the “project” would greatly help in determining the depth of the environmental impacts to our rivers and streams and subsequent impacts on the aquatic life in those rivers and streams. Now if only the drawings were disclosed before the hearings with adequate time for review, then perhaps concerned groups like the Regional Task Force, who represent the residents of the entire surrounding region, would have a true opportunity to prepare for the hearings based on facts about the true scope of this “project” instead of having to rely on the elusive wording in the Middleboro Agreement and data from Connecticut and other States.

- be the change you want to see in the world-