Interstate Water Report - New England Interstate Water Pollution [PDF]

Volume 5, Number 1  Winter 2007– 08

Interstate Water Report T h e n e w s l e tt e r o f NE I W P C C – t h e N e w E n g l a n d I n t e r s ta t e W a t e r P o l l u ti o n C o n t r o l C o m m i s s i o n

Tale of a TMDL

NEIWPCC and States File High-Profile Plan to Reduce Mercury in Our Waters by Susy King, NEIWPCC

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In Pursuit of Mercury Control: A Power Plant’s Story........................... 3 Case for the Courts: The Battle Over EPA’s Mercury Rule....................... 8 A Promising New Stormwater Partnership....................... 9 Caught on Camera: NEIWPCC Marks a Milestone (or Two)................ 10 Anglers Help Sustain a Species........... 14 Frank Talk on Water Conservation...... 16 NEIWPCC Drinking Water and Tanks Programs in New Hands..................... 19

S. Hochbrunn/NEIWPCC

n October 24, after nearly two years of planning and preparation, NEIWPCC and the Northeast states officially submitted the Northeast Regional Mercury TMDL to the U.S. Environmental Protection Agency. The TMDL, which stands for Total Maximum Daily Load, identifies specific steps to be taken to reduce mercury in the region’s waters. By statute, EPA has 30 days after the submittal of a TMDL to either approve or disapprove it. If EPA rejects the plan, the agency has another 30 days to develop an alternative TMDL. As this issue of IWR went to press, EPA had yet to announce its decision on the mercury plan, but the delay was to be expected. In the past, EPA has taken longer than 30 days to consider a TMDL, particularly when the issues are complex—which is certainly the case with this submission. The TMDL is a new step in the fight against an old problem—mercury pollution in Northeast waterways. For years, mercury contamination has led states to issue guidelines on just how much of various types of fish can be safely eaten. Throughout those years the challenge has been how to solve the mercury problem so consumption advisories are no longer necessary. The Northeast states haven’t shied away from the challenge. Rather, they’ve put tremendous effort into successfully reducing mercury within their borders. But other parts of the country have been slow to follow— and that’s a problem when you consider how much of the mercury in the Northeast originates from sources outside the region. With the TMDL, the states are trying a powerful new tactic to reel in mercury emissions from sources

Inside

Aiming High Dramatically reducing the mercury emitted by coal plants across the country is a key goal of the Northeast Regional Mercury TMDL implementation plan.

near and far. The way the TMDL came together is a classic case study in what can be achieved when the states and NEIWPCC work together in pursuit of a common goal.

An Insidious Foe The Northeast states had long been aware of the problems caused by mercury, due to plentiful research show-

ing it to be a potent neurotoxin that poses a particular risk to developing fetuses. Concern increased as awareness grew of how easily mercury enters the environment and our bodies. Mercury primarily originates from air pollution sources such as coal-fired power plants, municipal waste combustors, and sewage sludge incinerators. Once in the air, it over time falls directly into surface waters or onto land, where it can be carried by runoff into waterways—a phenomenon known as atmospheric deposition. Once in the water, bacteria convert the metal to methylmercury, a form that bioaccumulates in fish and other aquatic organisms. When we eat the fish, we’re exposed to the mercury inside. With this information in mind, and a sense of the growing threat from mercury, the Conference of the New England Governors and Eastern Canadian Premiers (NEG-ECP) Committee on the Environment released a regional Mercury Action Plan in 1998. The plan identified steps to address those aspects of the mercury problem in the region that are within the region’s control or continued on page 4

Growing Concern

Forum in Maine Reveals What We Know About PPCPs by Stephen Hochbrunn, NEIWPCC

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o to the new Pharmaceuticals and Personal Care Products section on EPA’s website, click on “Frequent Questions,” and you find this: “The importance of individuals adding chemicals to the environment has been largely overlooked.” That appears to have changed. Judging by the number of people at the 2007 Northeast Water Science Forum and their intense interest in the discussions, the issue of PPCPs is not being overlooked anymore. “I want to be informed about PPCPs,” said Jeanne Christie, executive director of the Association of State Wetland Managers, and one of more than 150 conference-goers who filled an expansive room at the Holiday Inn By the Bay in Portland, Maine, for the forum on August 8 and 9. NEIWPCC took the lead role in developing and coordinating the event, which carried the theme “Pharmaceuticals and Personal Care Products: State of the Science.” It brought together scientists, regulators, water and wastewater professionals, environmental advocates,

industry experts, and others to disseminate and evaluate the latest scientific information on PPCPs in the water environment. “This conference is providing an opportunity for an interdisciplinary approach to PPCPs,” said Nicholas Anastas of the Massachusetts Department of Environmental Protection, and a member of the conference planning team. “It’s bringing together a wide Rapt Audience The seats are filled as the presentations begin at the 2007 Northeast Water Science Forum, which focused on pharmaceuticals and range of people to discuss an emerging issue personal care products. that needs attention.” Anastas, who also spoke at the conference, was looking to broaden his already groundwater, and their effects on aquatic and human extensive knowledge of the topic. Others, such health; what we’ve discovered about how to treat and as Christie, were there to get a basic understanding. remove them from the waste stream; and what we “I’m just trying to figure it all out,” she said. know about how to keep them out of wastewater in the Both came to the right place. Throughout the first place through drug take-back programs and other forum, the talk was about nothing but PPCPs—what we’ve learned about their presence in surface waters and continued on page 12 Page 

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From the Executive Director

The Climate Challenge

Executive Director Ronald Poltak Deputy Director Susan Sullivan Established by an Act of Congress in 1947, the New England Interstate Water Pollution Control Commission is a not-for-profit interstate agency that utilizes a variety of strategies to meet the waterrelated needs of its member states—Connecticut, Maine, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont. NEIWPCC coordinates activities and forums that encourage cooperation among the states, educates the public about key water issues, supports scientific research projects, trains environmental professionals, and provides overall leadership in water management and protection. While NEIWPCC’s initial emphasis was on surface water protection, the Commission now also devotes substantial attention and resources to such matters as wetlands restoration, nonpoint source pollution, water allocation, and underground storage tanks. New England Interstate Water Pollution Control Commission 116 John Street Lowell, MA 01852-1124 Tel: 978-323-7929 Fax: 978-323-7919 [email protected] www.neiwpcc.org

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t is impossible to go through any day, and certainly any week, and not be exposed to discussions in every medium of communication on the subject of global climate change. Two themes permeate these discussions. First, global warming is unequivocal; second, global warming may present the greatest challenge the civilized world has ever faced. In order to meet the challenge, we must change our habits and we must develop new technologies to drastically reduce greenhouse gas emissions. The majority of the scientific community has concluded that global climate warming is contributing to a myriad of serious impacts, both direct and indirect, on our natural resources. These include, but are not limited to: • Increased earth surface temperatures. • Increases in sea level. • Decreases in sea and land ice. • Increases in extreme weather events. • Increases in flooding and drought. • Population declines in native species; increases in invasive species. In 2001 the New England Governors and Eastern Canadian Premiers endorsed and adopted a climate change action plan. It was both strong and bold in pledging a regional commitment to address the issue. The plan called for the implementation of programs to substantially reduce the levels of greenhouse gas emissions in the region (mitigation), as well as a process to address the consequences of climate change (adaptation). While we in the region have been in many respects “out front” on this issue, and have as states committed significant resources to it over the past six years, much remains to be done. Most observers agree that damages will increase as warming continues. And many, if not most, of the change-related consequences are tied to water. For all of us who work for and care about our precious water resources, the challenge ahead is daunting. Simply stated, we must make it a top priority to develop mitigated water resource management strategies with a strong adaptive emphasis. To not do so would be to ignore what is increasingly undeniable—climate change is real and unavoidable. Sincerely,

Interstate Water Report

Ronald Poltak NEIWPCC Executive Director

Editor Stephen Hochbrunn, NEIWPCC Designer Ricki Pappo, Enosis – The Environmental Outreach Group Interstate Water Report (IWR) is published by NEIWPCC. It is funded by a grant from the U.S. Environmental Protection Agency and distributed free of charge to subscribers. To ­subscribe, contact NEIWPCC at the address above or fill out and return the subscription form in this issue. POSTMASTER: Send change of address forms to IWR/NEIWPCC, 116 John St., Lowell, MA 01852-1124. The opinions and information stated in IWR are those of the authors and do not necessarily reflect the opinions of NEIWPCC. Articles in IWR may be ­copied. Please give credit to NEIWPCC. Article submissions and questions or comments about IWR are welcome and appreciated. Please send material to [email protected]. All photos by NEIWPCC unless otherwise noted.

Printed on recycled paper.

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New Relationship

NEIWPCC Joins Research Foundation by Marianna Vulli, NEIWPCC

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s part of NEIWPCC’s commitment to the advancement of high-quality, applied water resources research, we have joined the Water Environment Research Foundation. WERF is a national leader in water quality research and supports millions of dollars of research annually on wastewater treatment and collection, watersheds and ecosystems, human health effects, and stormwater. This membership-driven, results-oriented organization, funds peer-reviewed research to advance science and technology and to find solutions for priority wastewater and water quality issues. In an exciting development, NEIWPCC’s Deputy Director Susan Sullivan has been invited to serve on WERF’s Research Council, which oversees the organization’s strategic direction and makes research funding decisions based on member priorities and environmental need. Sullivan will work to represent the Northeast states’ priority research needs as part of this group.

NEIWPCC feels strongly that our membership in WERF will promote our states’ research needs and enhance our states’ ability to make sound water resources policy and management decisions. For more information about WERF research, please visit www.werf.org. For information on NEIWPCC’s other research efforts, visit www.neiwpcc.org/research.asp. Marianna Vulli ([email protected]) is the coordinator of NEIWPCC’s Regional Research Initiative.

IWR, Winter 2007-08

Firsthand Look

How One New England Power Plant Plans to Get the Mercury Out by Stephen Hochbrunn, NEIWPCC

Eyeing the Output Harold Keyes, plant manager at Merrimack Station, checks the readings on the plant’s mercury continuous emissions monitors.

Photos by S. Hochbrunn/NEIWPCC

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s a rule, people don’t visit coal-fired power plants. We know they’re out there, we occasionally see them lurking heavily in the distance, but go to one? The grim, fortress-like structures seem to be telling us—stay away. Despite their central role in producing the nation’s power, we rarely even think of them. They cross our minds when there’s a problem—as on November 6, when three workers died in an explosion at the power plant in Salem, Mass. We may think of them when we hear of a mine collapse, of men dying in search of the raw material to electrify our homes, businesses, and iPods. But usually, they are far from our thoughts. And nowhere in our travels. That is, unless your goal is to find out exactly how a coal-fired power plant removes mercury from its emissions. The Northeast Regional Mercury TMDL urges EPA to enact a rule requiring all such plants to control mercury emissions by 90 percent. But it doesn’t specify how this is to be achieved, other than to say cost-effective and available technologies should be used. What are these technologies? It seemed there was no better way to find out than to do the unusual—visit a coal plant. And preferably one well down the road to employing mercuryreducing systems. We found one right in the neighborhood. An hour’s drive northwest of NEIWPCC’s Lowell, Mass., headquarters, along the west bank of the Merrimack River in Bow, N.H., sits a facility that burns through 4,000 tons of coal a day as it generates enough power to satisfy the needs of a third of New Hampshire’s population. Public Service of New Hampshire (PSNH), the state’s largest utility, owns and operates the plant, known as Merrimack Station. Since it burns coal, which contains a trace amount of mercury, the plant emits mercury into the atmosphere—not a lot compared with many other plants around the country, but it doesn’t take much to threaten the environment and public health.

Eye-Opening Visit A trip to Merrimack Station, a coal-fired power plant in Bow, N.H., revealed much about current methods for reducing a coal plant’s mercury emissions.

Reducing mercury emissions is now a priority at Merrimack Station, especially after the passing of strict legislation in New Hampshire in 2006. Of course, ­making something a priority doesn’t guarantee success. But interesting, innovative mercury strategies are being pursued at the plant. It’s just going to take time.

Close Encounter Located several miles to the east of the heart of Bow, Merrimack Station stands alone, its great mass towering over low, barren surroundings. The sheer hulk of the plant and its worn, drab skin make it appear primeval, as though forged in a bygone era. In truth, the plant is less than 50 years old. But on August 28, the day of our visit, it looked from the parking lot as if it had always been there—a fixed feature of the landscape, immovable, relentless and unceasing in the creation of its elemental product. It had been months since the initial request for a visit was posed to Martin Murray, who does media relations for PSNH. Given the bashing Big Coal has taken lately in the press and in Washington, the delay was understandable; clearly PSNH was in no particular hurry to entertain visitors at the plant, especially ones from an organization they’d never heard of. But our request must eventually have been deemed straightforward enough. Murray greeted us amiably, and introduced Harold Keyes, the plant manager. Keyes was prepared. He said he’d read the Mercury TMDL the night before, and posed pointed questions to NEIWPCC’s Susy King, an author of the TMDL who had come along on the visit. Her thoughtful responses diffused skepticism about our intentions, which were simple—to observe and to learn. Keyes warmed. He began speaking proudly of his plant, which stood silently, stolidly behind him, betraying none of the extreme ferocity of the process underway within.

Merrimack Station generates 478 megawatts— enough electricity for roughly 200,000 residential, commercial, and industrial customers—through a process that at its core features two boilers, where coal is burned around the clock at 3,500 degrees Fahrenheit. They’re called boilers because they contain tubes filled with water that, amid the intense heat, rapidly becomes steam, which is both exceedingly hot (1,000° F) and highly pressurized (2,400 lbs. per square inch). The searing steam screams through tubes to a turbine, where the blast of force is powerful enough to turn the turbine’s blades at 3,600 rotations a minute. It’s that rotation that creates electricity. Connected to the plant are six high-voltage transmission lines that carry the power to substations throughout the state. It’s a remarkable process, awesome in its brute ability to produce mass amounts of electricity. But you can’t ignore the downside: a coal-fired power plant without emissions controls emits dangerous levels of pollutants, including sulfur dioxide and nitrogen oxides, which cause acid rain and smog. At Merrimack Station, they’ve installed systems to reduce pollution, including two selective catalytic reduction systems, known as SCRs, that dramatically lower emissions of nitrogen oxides by inducing chemical reactions that turn the NOx into harmless water vapor and nitrogen gas. The plant also has two electrostatic precipitators, or ESPs, that impart a charge to the coal ash (or fly ash) in the plant’s exhaust so the potentially polluting ash sticks to metal plates instead of soaring out the smokestack. For several minutes, Keyes boasted about the progress the plant’s made on cleaning up emissions, and you couldn’t blame him. The plant after all has received two Environmental Merit Awards from EPA as well as a Governor’s Award for Pollution Prevention. continued on page 5 Page 

IWR, Winter 2007-08

Mercury TMDL continued from page 1 influence. The long-term goal was to virtually eliminate regional anthropogenic mercury emissions—that is, those emissions caused by human activity. To ensure progress, short-term goals were adopted. The Mercury Action Plan originally set a target of a 50 percent reduction in regional mercury emissions by 2003. In 2001, another interim goal was added: a 75 percent reduction by 2010. Fast forward to 2005: Implementation of the Mercury Action Plan had resulted in reductions of

water bodies. But the development of a Northeast Regional Mercury TMDL, which involved seven states and thousands of water bodies, was truly a unique case. It would be a true test of the effectiveness of regional collaboration. Thankfully, we had a precedent: the Minnesota Statewide Mercury TMDL. Although it was a state plan, not regional, the main goal was the same—to make reductions in the atmospheric deposition of mercury. It also had survived the scrutiny at EPA, which approved it in March. Hence, throughout the development process, we used the Minnesota TMDL as a model. For example, the TMDL process requires calculation of an allowable wasteload allocation (load from wastewater sources) and load allocation (load from nonpoint sources). As in Minnesota, we determined that the vast majority of allowable mercury load was in the load allocation. And since the majority of that allocation originates from atmospheric deposition, that was where the bulk of the reductions needed to be made.

Down to Business As a means of gauging how far we’d come on mercury, and how far we needed to go, we used a baseline year of 1998 to correspond with the beginning of the Briefing Session At NEIWPCC’s Commission Meeting in May in Salem, Mass., NEG-ECP Mercury Action Plan. Data NEIWPCC’s Susy King (left), the writer of this article, and Beth Card, NEIWPCC’s were compiled from a number of sources Director of Water Quality Programs, discuss the draft version of the TMDL. The to calculate the baseline mercury deposipresentation was one of many the two delivered across the region during develoption load, wastewater load, and fish tissue ment of the final version of the plan. concentrations. We then compared the regional mercury emissions of greater than 50 percent, existing fish tissue concentration to a target fish concenbut fish tissue mercury concentrations were still high tration to calculate the necessary reduction in mercury enough to require fish consumption advisories. It wasn’t loading and to establish the ultimate mercury goal. The hard to figure out why. Scientists know that airborne determination: a minimum reduction of 87 percent mercury can travel far from its source, and that air curin in-region and out-of-region anthropogenic sources rents often carry to the Northeast whatever’s in the air of mercury atmospheric deposition is needed to meet to the west. Combine that with the fact that mercury desired fish tissue levels. reductions outside the Northeast had not been nearly While the Northeast states have already accomas great as those within the region, and the conclusion plished atmospheric deposition reductions of more was obvious: the in-region progress on mercury was than 70 percent, a reduction of 87 percent or higher is being offset in part by a lack thereof elsewhere. If levels still a lofty goal. When taking into consideration that of mercury in fish were ever to decline to safe levels, we the reductions must also be accomplished for sources needed more aggressive out-of-region reductions. outside of the region, the task becomes even more chal-

lenging. To address this issue, we broke down implementation of the TMDL into three phases. The first two phases correspond with the timing and goals of the regional Mercury Action Plan. In Phase I, which began in 1998 and ended in 2003, we required reductions of 50 percent. Phase II runs from 2003 to 2010, and has a reduction goal of 75 percent. Phase III begins in 2010, but its final reduction goal and end date won’t be determined until Phase II is done, when evaluation of emissions, deposition, and fish tissue data could point to a need to revise the original reduction goals. How will these reductions be achieved? Within the region, states will continue on the mercury reduction paths they have already been following to virtually eliminate all in-region sources of mercury emissions and discharges. This includes implementation of legislation and regulations pertaining to emissions from coal-fired power plants, sale and disposal of mercury-containing products, and installation of dental amalgam separators. As for the rest of the country, the Northeast states are asking EPA to enact a rule that would require 90 percent mercury control from all coal-fired power plants as a first step. This would be an alternative to EPA’s Clean Air Mercury Rule currently in place that will result in a 70 percent reduction when fully implemented. (Many states, including all the Northeast states, are also involved in litigation against EPA on this issue. To learn more, see “Legal Lines” on page 8.)

In the Northeast, over 10,000 lakes, ponds, and reservoirs, and over 46,000 river miles are impaired for fish consumption due to mercury pollution.

Rewarding Process As the TMDL procedure requires that states release a draft for public comment prior to submitting a final TMDL to EPA, NEIWPCC and the Northeast states released a draft version of the Northeast Regional Mercury TMDL on April 11. The TMDL garnered media attention, with articles on its release appearing in the New York Times, Boston Globe, and other regional and national publications. To spread word about the TMDL

Devising a Strategy In December 2005, NEIWPCC and our member states—Connecticut, Maine, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont— began collaborating to develop a plan that would quantify the necessary reductions from mercury sources both within and outside of the region. While we were all motivated by the desire to reduce mercury in our waters, there was the added incentive of federal law. The Clean Water Act requires that states develop lists of impaired waters—waters that are not meeting their water quality standards—and develop Total Maximum Daily Loads, or TMDLs, for them. A TMDL is a calculation of the maximum amount of a pollutant that a water body can receive and still meet its water quality standards. The allowable amount of the pollutant is allocated to point and nonpoint sources. In the Northeast, over 10,000 lakes, ponds, and reservoirs, and over 46,000 river miles are impaired for fish consumption due to mercury pollution, so there was no question that a TMDL was required. But how to do it? In general, states develop TMDLs for individual water bodies or a small group of water bodies. In the case of Lake Champlain and Long Island Sound, two states worked together on TMDLs for large interstate Page 

Outside Influence Contributions of In-Region and Out-of-Region Sources to Northeast Mercury Deposition in 1998 and 2002

In-Region 43%

1998

Out-of-Region 57%

In-Region 19%

Out-of-Region 81%

2002

Modeling performed in 1998 by the Northeast States for Coordinated Air Use Management (NESCAUM) showed that 43 percent of the mercury deposited in the Northeast states originated from sources within the region. In 2002, NESCAUM’s models showed that in-region sources were responsible for only 19 percent of in-region deposition. The need for more stringent controls on out-of-region mercury sources was a main reason for the development of the Northeast Regional Mercury TMDL.

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Mercury TMDL continued from page 4 to the public, NEIWPCC and state staff conducted eight public informational meetings in five of the participating states. The public comment period lasted 59 days, with NEIWPCC and the states receiving comments from 14 different groups. After several months of revising the draft based on the feedback, we arrived at the final version of the plan, the one submitted to EPA on October 24. If approved and implemented, we can reasonably expect that one day everyone will once again be able to safely eat fish caught in the waters of the Northeast. That may seem hard to believe, given how accustomed we’ve grown to fish consumption advisories. But it’s believable and achievable—with the TMDL as our tool.

The complete text of the Northeast Regional Mercury TMDL is available at www.neiwpcc.org/mercury, where you can also access news related to this effort, such as any announcement from EPA, that may have occurred since the printing of this issue. Editor’s Note: Susy King ([email protected]), the writer of this article, is a NEIWPCC Environmental Analyst. She played a prominent role in the development of the Northeast Regional Mercury TMDL, as did Beth Card ([email protected]), NEIWPCC’s Director of Water Quality Programs. Both served on the project’s technical workgroup, which also included Traci Iott and Paul Stacey of Connecticut DEP; Andy Fisk and Barry Mower of Maine DEP; Rick Dunn, Russ Isaac, and C. Mark Smith

of Massachusetts DEP; Gregg Comstock, Bob Estabrook, and Peg Foss of New Hampshire DES; Jay Bloomfield, Dick Draper, Ron Entringer, and Scott Quinn of New York State DEC; Scott Ribas and Elizabeth Scott of Rhode Island DEM; and Tim Clear and Neil Kamman of Vermont DEC. Their contributions and the strong support of NEIWPCC’s Executive Committee were critical factors in the successful completion of this project. One final note: Among the many reporters that covered this story was Vermont Public Radio’s John Dillon. NEIWPCC’s Beth Card was among the subjects he interviewed, and Dillon included one of Card’s comments in his piece that aired on October 30. It can be heard online at www.vpr.net/news_detail/77965/.

Merrimack Station continued from page 3 small, it adds up in the environment—and to alarming levels. In March 2005, the Conservation Law Foundation, an environmental advocacy group, went on the offensive against Merrimack Station, saying its mercury emissions were enough to poison 60 million pounds of fish and threatening to sue the plant to force it to slash its mercury output. CLF and other likeminded groups weren’t particularly appeased five days later when EPA issued its Clean Air Mercury Rule, which aims to achieve a 70 percent reduction in total power plant mercury emissions by 2018 through a cap-and-trade approach: companies that reduce emissions can sell credits to those that don’t reduce them. Evolution of a Solution Environmental groups pushed for tougher Actually, Keyes should have seen it coming, and no restrictions, and in early 2006, state lawmakers in New doubt did. For years, environmental groups pushed for Hampshire upped EPA’s ante and passed legislation spemore aggressive government action on mercury emiscifically targeting Merrimack Station. The law prohibits sions by power plants. The power industry fought back, PSNH from buying credits to meet mercury emissions emphasizing that U.S. electric utilities contribute just restrictions, and mandates an 80 percent drop in the one percent of total global mercury emissions. But there plant’s mercury discharge by 2013. The law specifies how is no getting around disturbing data: according to the it’s to be done—through the installation of a wet flue gas latest EPA figures on mercury emitted by U.S. power desulphurization system. As the name implies, such sysplants, the top 50 mercury polluters sent almost 21 tons tems were designed to reduce sulfur dioxide, which they of mercury into the environment in 2005. The worst do very well. But they can also capture mercury, and at offender, the massive Martin Lake Steam Electric Station very high levels. in Texas, alone emitted more than 1,700 pounds of merKeyes quickly dashed our hopes of seeing signs of cury. this system under development during our visit. “We’re By comparison, Merrimack Station’s reported far from construction,” he said. “This is a very complicontribution of 130 pounds seems tiny—but it’s hardly cated project, and the amount of engineering required to insignificant. Mercury is highly bioaccumulative, meanmake it happen is immense.” ing its concentration increases as it moves up the food Keyes did come armed with a diagram (similar chain; that’s why levels in fish tissue are far higher than to the one on this page) that explained how the system, in the surrounding water. So while the amount of mercommonly called a wet scrubber, will work at Merrimack cury in coal is minute, and the amount being emitted Station. A boiler’s exhaust, or flue gas, will first pass at any given moment by a power plant is exceedingly through an ESP before being directed into a large vessel (the scrubber). There, the gas will be sprayed with a mix, or slurry, created at the plant by combining limestone and water. A chemical The Way It Works reaction ensues, in which This diagram, provided by PSNH, the slurry will absorb illustrates in simple terms how virtually all the sulfur the planned wet scrubber will dioxide and mercury in the reduce the mercury in Merrimack flue gas, removing them Station’s emissions. almost entirely from the emissions stream. Actually, mercury in its simple, elemental state isn’t captured in a wet scrubber. But if the mercury has been oxidized,

Public Service of New Hampshire

“Historically at Merrimack Station, they’ve been fairly proactive in responding to environmental concerns,” said Craig Wright, a permitting bureau administrator with the New Hampshire Department of Environmental Services’ Air Resources Division, in an interview before our visit to Bow. “They went way above and beyond [environmental regulations] with their SCR systems.” But Keyes knows all too well that there’s a new issue in town. “Just when we thought we were turning the corner environmentally,” he said, “mercury pops up.”

Positive Sign A silo stands ready to play its part in a governmentfunded research project at Merrimack Station that aims to reduce mercury by injecting activated carbon into the plant’s exhaust gases. The silo contains a sorbent that absorbs sulfur trioxide, which inhibits mercury from being captured by the injected carbon.

it’s captured very efficiently. How to accomplish the oxidation? Here, Merrimack Station gets off easy. It so happens that the mercury in its flue gas is already being oxidized as it passes through the plant’s SCRs, the units installed to reduce nitrogen oxides. PSNH expects to spend about $250 million on designing and building the wet scrubber and various projects related to it—a new chimney must be installed, and systems for handling the limestone, mixing the slurry, and removing the waste products must be developed. A scrubber of course doesn’t eliminate mercury; it just scrubs it, so to speak, out of a plant’s emissions. Just how PSNH will deal with its scrubber waste, and the very small amount of mercury within it, is still being determined. One option takes into account that the waste produced by a limestone-based scrubber is ­actually a synthetic gypsum, the very material used in the making of drywall, plaster, and other products. Although the mercury in the gypsum is a concern, and has been the focus of research, it’s hard to find any definitive conclusions about potential hazards. Other continued on page 6 Page 

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Merrimack Station continued from page 5 plants with scrubbers successfully sell the gypsum for industrial use, and PSNH is open to that idea. But Keyes emphasized it wouldn’t be a moneymaker. “We might be able to break even,” he said, “and cover the cost of transporting [the gypsum]. Selling it wouldn’t save us money, but it might prevent us from spending more.”

A Cheaper, Challenging Fix Any mercury reduction from a wet scrubber is a long way off—but evidence of another mercury project, smaller in scale but already underway, couldn’t be missed. A gleaming new silver silo stood out in sharp contrast to the largely colorless structures elsewhere. Keyes made it the first stop as we embarked on a tour of the plant. The silo, he explained, is an integral part of PSNH’s experimentation with activated carbon injection. In ACI, as it’s called, powdered carbon is injected into a power plant’s flue gas, and if it’s working right, the mercury in the flue gas is adsorbed by the carbon sorbent— that is, it collects on the surface of the carbon particles. The mercury-laden particles are then carried off with the rest of the flue gas into whatever system a plant is using to remove particulates, which in Merrimack Station’s case, is an ESP. There, the carbon, along with its adsorbed mercury, is trapped like any other particle. ACI is a fairly well established technology; it’s been employed at plants across the country and more often than not achieves high mercury removal rates. But it can be tricky. There are different types of carbon sorbents, and no guarantees about their effectiveness. “A sorbent that works on one plant,” Keyes said, “may not work on another. They’re site specific.” That’s because not all coal-fired power plants are alike. The boilers at Merrimack Station, for example, are cyclone boilers, which are hardly commonplace. In a cyclone boiler, circulating air spins the coal as fast as 100 miles per hour to maximize combustion. The plant’s SCR units also affect the chemical makeup of its flue gas—in a good way for scrubbers in that they oxidize mercury, but in a bad way for ACIs. The SCR process creates sulfur trioxide, which interferes with the adsorption of mercury by the carbon particles. Merrimack Station’s two ESPs are also unusual—most plants have just one—but for an ACI system, that comes in handy. Before embarking on its first ACI test, PSNH decided to inject the carbon between the two ESPs. To understand why, consider how the ESPs work together: the first one knocks out a lot of the fly ash in the flue gas, the second one collects what’s left. Put your ACI in between, and you end up with a lot less ash containing mercury and increased carbon levels than if you’d injected before the entire ESP process. That’s important since post-ACI ash has to be disposed of properly, and can’t be sold for use in concrete as can regular fly ash. The first test of an ACI system at Merrimack Station proved to be disappointing, with mercury emissions reduced by just 15 percent. So PSNH applied to the U.S. Department of Energy for a grant to try again—and got the money. In February 2006, DOE announced a $2.5 million award for full-scale ACI field testing at the plant. PSNH kicked in $1.5 million of its own, and ADA Environmental Solutions, the Coloradobased contractor selected for the project, put up $300,000. A new round of tests began. Again, disappointment. “We were nowhere near the 70 to 90 percent [mercury] reduction we’d hoped for,” Keyes said. The problem was the sulfur trioxide from the SCRs. Keyes and his cohorts decided on a new approach: to inject not just carbon into the flue gas, Page 

Nerve Center Plant manager Harold Keyes (right) speaks with an operator in Merrimack Station's large, spotless control room.  

but also a sorbent specifically for the SO3. It was that sorbent that was being stored in the new silver silo that we admired as Keyes told his tale—a tale which, at this point, got vague, intentionally. “We did get better results [in the second DOE test],” he said. “But if I told you what they were, I’d have to kill you.” Hyperbole of course, but not without some truth. The DOE grant stipulates that anything learned from the testing must be shared freely with all interested parties, but that only DOE can disseminate the information. In the spring of 2007, PSNH began a long-term six-month test of the ACI system, but quickly suspended the test as the plant underwent annual maintenance procedures. The test was still on hold during our visit, but Keyes said he hoped to restart it in October. If the long-term test reveals acceptable mercury removal rates, PSNH plans to keep the system running—at least until the wet scrubber comes on line.

Learning Excursion After our stop at the ACI silo, our tour continued on to the rest of the plant—though from a mercury standpoint, there was little more to see. Keyes did take us into the cramped area that houses the base units of the plant’s two mercury continuous emissions monitors, made by Waltham, Mass.-based Thermo Fisher Scientific. He called their performance a work in progress, and said he wasn’t sure when they’d be ready for “prime time”—that is, January 1, 2009, when EPA’s strict new requirements for mercury monitors go into effect. As the tour went on, the focus on mercury waned amid the astonishing nature of what we were seeing and feeling: the blanketing heat as we walked in the building’s bowels, near the base of a boiler; the small, thick window through which molten residue from the coalburning could be seen falling in fiery vertical streams; the cleanliness in this place of epic combustion (“We work hard to keep it that way,” Keyes said); the control room where operators monitored all that occurred in the vast complex, eyes fixed on screens to catch the slightest deviation from the norm. Outside the plant, we strode aside railroad tracks, upon which twice a week rumble trains 90 cars long, each car holding 100 tons of coal from mines in Pennsylvania, West Virginia, and two sources in South America. We looked out at a yard where mountains of coal lay on standby. Like any coal-fired power plant, Merrimack Station is vulnerable to strikes in the railroad and mining industries; regulations require that it keep 300,000 tons of coal always on hand, just in case. Emerging from our immersion in the plant’s operations, the talk returned quickly to mercury. Will it really be 2013 before the wet scrubber is up and running?

“If we were the only ones building a scrubber,” Keyes said, “we could get it done a lot quicker. We’re trying to build in the biggest scrubber boom this country’s ever had.” The wait for scrubber parts, he said, can last as long as two years. Still, the New Hampshire law contains incentives for early compliance with the mercury reduction targets. “If we can do it sooner, we will,” Murray said. Not long after our visit came evidence that the process of building a scrubber was indeed moving along. On October 3, Washington Group International, a Boise, Idaho-based firm, announced it had entered into a contract with PSNH to manage the scrubber project. In an email in early November, Murray wrote that Washington Group had already started engineering and design work for the job. As for the ACI system, Murray wrote that the long-term test had yet to resume, but should soon. He blamed the delay on the need to buy new equipment to dispose of the ash collected by the second ESP, ash that will contain the injected carbon and mercury. The new equipment, Murray wrote, will be used to moisten the ash so it can be used as a landfill cover.

Promising Progress The mercury technologies being implemented at Merrimack Station are not the only options available to power plants; there are others with exotic names—corona discharge, circulating fluid bed, electro-catalytic oxidation. But they’ve yet to catch on to the extent of ACI and wet scrubber systems. For now, PSNH’s actions on mercury at Merrimack Station have placated its critics. The Conservation Law Foundation never has filed its threatened suit against the plant, and in a November interview, Melissa Hoffer, the director of CLF’s New Hampshire Advocacy Center, said it appeared that PSNH was moving in the right direction. “We’re aware they’ve been making some significant investments at Merrimack,” Hoffer said, “and we remain hopeful that the ACI and other actions they’re taking will reduce mercury emissions.” With the ACI system on hold, and the wet scrubber many years from completion, hopeful is about all anyone can be. As we stood in the parking lot again, our tour complete, it was clear that despite the impressive projects outlined by Keyes, no mercury reduction was being done at that moment. As much was being emitted by the plant’s ominous smokestack as ever had been. That didn’t seem to bother Keyes. He’s got his plans. And his pride in his company’s environmental record. “We’ve done everything we’ve been told to do,” he said, “and often gone beyond that. Our job is to provide electricity, and to provide it in a clean way.” Given it’s coal we’re talking about, not solar or wind power, Keyes might have worded that differently: can burning fossil fuels for power ever really be clean? The best we can hope for is to make the inherently dirty process as clean as possible, to keep emissions of its hazardous by-products such as mercury to a bare minimum. Keyes knows this of course, and it’s hard to fault him for indulging in a little PR-speak toward the end of a long interview. The line about clean power sounded like one he’d uttered hundreds of times, in contrast to the unrehearsed feel that had permeated our conversation. He deserves credit for that open exchange, just as PSNH deserves credit for the work being done: at Merrimack Station, they are moving ahead with strategies proven to reduce mercury. Visiting the plant made that perfectly clear. True, the progress may be happening a little later than some would have liked. But it’s happening. That was good to see.

IWR, Winter 2007-08

Local Impact

Study of Mercury Hotspots Reveals Effects of In-Region Sources by Emma Downs

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iven all the environmental issues that require attention, it would be helpful if new research on mercury in our region revealed the problem wasn’t as serious as previous studies have indicated. Unfortunately, the opposite is occurring. In early 2007, the release of a study by a group of prominent researchers pointed to the growing need to address the issue now, before it gets worse—and not to overlook the contributions from mercury sources within our region. As the Northeast Regional Mercury TMDL points out, sources outside our region are having a growing influence on the mercury in our waters. But the impact from in-region sources, while shrinking, remains a serious issue. Nine scientists from the Hubbard Brook Research Foundation (HBRF) made a new assessment of fish, birds, and mammals in the Northeastern United States and Southeastern Canada and found mercury levels in many areas higher than predicted. They identified five confirmed biological mercury hotspots: the west and central Adirondack Mountains; the Upper Connecticut River; the middle and lower portions of the Merrimack River; the upper portions of the Androscoggin and Kennebec Rivers; and in Canada, Kejimkujik National Park and central Nova Scotia. The researchers also identified nine suspected hotspots, seven of which are in NEIWPCC’s member states.

What Makes a Hotspot Hot The HBRF scientists define a biological mercury hotspot as a location where mercury concentrations in fish, birds, or mammals exceed established thresholds for human or ecological health compared to the surrounding landscape. Mercury is deposited in a watershed by outside sources and processed by specialized bacteria to become methyl mercury, a form that is more easily absorbed by animals. Hotspots occur when this process happens at an accelerated rate. Several factors cause this acceleration. One is proximity to large emission sources, as we see in the lower Merrimack River. Also, some watersheds are particularly sensitive to mercury pollution due to the nature of their landscape; acid deposition, low nutrient inputs, forest cover, shoreline wetlands, and forest clearcutting can increase mercury accumulation in an area. Reservoirs with frequent fluctuations in water level are also susceptible to mercury buildup because the continual exposure and rewetting of shore land provides prime conditions for bacteria that produce methyl mercury. There’s another key point: Because mercury is a fundamental element, it doesn’t break down or degrade, so it can travel long distances. Hence, mercury was long considered a “global” pollutant that travels far from its source. Its effects on its immediate environment were thought to be minimal. Emerging science, however, shows that’s not the case. The reach of mercury’s effects depends on the type of mercury that is present. Elemental mercury (Hg0) is relatively inert and thus can travel great distances, accounting for mercury’s often noted global effect. This species of mercury makes up half the emissions of mercury from pulp and paper plants and utility oil boilers, 80 percent of the emissions from landfills, and 30 percent of the emissions from coal-fired electric utilities. Reactive gaseous mercury (RGM) is more chemically reactive and thus deposits

Biological

Mercury HoT The HBRF team sPoTs used a new met hod to determ mercur y hotspo ine biological mer t of human hea lth cur y hotspots. yellow perch con concern occurs In this method where there are centrations abo , a biologic ve 10 or more inde 30 minutes). A biological mercur 0.3 ppm within grids that ave pendent sites with al rage 890 square y hotspot of eco common loons miles in size (30 sampled in a grid logical concern minutes by eme containing at leas rges where 25 t 14 samples hav percent or mo re of the e blood mercur y levels above 3.0 ppm.

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relatively close to its source. It accounts for 68 percent of mercury emissions from coal-fired electric utilities in the Northeast, and over half the emissions from municipal waste incinerators nationwide. Because of its short range and high rate of production in our region, RGM is the most abundant form of mercury pollution in the Northeast. Particulate mercury (PHg) can travel short to moderate distances. The least common form of mercury emitted, PHg makes up 20 percent of the mercury in discharges from utility oil boilers, municipal waste incinerators, and pulp and paper production.

S S

4a 4b 4c

The HBRF study proposes that mercury deposition near large emission sources can be greater than levels previously predicted by national or regional models. Using a computer model designed to capture the impact of local emission sources, the HBRF team found that in an area near Concord, N.H., in the vicinity of the Merrimack Station coal-fired power plant (see page 3), the local deposition was four to five times higher than EPA’s estimate for the region. The scientists also used the model to generate other conclusions that suggest EPA may have underestimated the impact of coal-fired power plants on mercury deposition in areas near large emission sources. The study did include some encouraging news. An analysis of monitoring data suggests that as mercury emissions and depositions from local sources decline, mercury levels in fish and wildlife decrease rapidly. For example, between 1997 and 2002, mercury emissions upwind of the hotspot in New Hampshire declined 45 percent. In roughly the same period, average blood mercury concentration in loons from ten study lakes in the hotspot decreased 64 percent and yellow perch showed a 32 percent drop. These reductions were much

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t NY Mountains – cent ral NY 2. Upper Con necticut River NH, VT 3a. Merrimack Rive r – middle NH 3b. Merrimack River – lower MA, NH 4a. Upper Androsc oggin River ME, NH 4b. Upper Kenneb ec River – west ME 4c. Upper Kenneb ec River – east ME 5a. Kejimkujik Nat ional Park NS 5b. Central, Nov a Scotia NS 1b. Adirondack

Conclusions and Considerations

5b

S S

Yellow Perch Average (ppm)

0.73 0.54 0.35 0.78 0.65 0.44 0.40 0.38 0.50 0.58

Common Loo

Range (ppm)

0.57 - 0.96 0.39 - 0.80 0.14 - 0.58 0.05 - 5.03 0.23 - 3.81 0.21 - 1.25 0.24 - 0.52 0.14 - 0.72 0.14 - 0.85 0.14 - 3.79

Average (ppm)

1.5 2.0 1.1 2.6 no data 1.9 3.1 2.2 5.5 no data

Range (ppm)

1.1 - 2.1 0.3 - 4.1 0.1 - 2.9

n % of loons > adverse effect level

0% 25% 0%

0.7 - 7.1

28%

0.15 - 5.5

14%

0.6 - 14.2 0.6 - 4.1 2.9 - 7.8

43% 26% 93%

Graphic text P , map, and tabl e courtesy of Brook Resear the Hubbard ch Foundation

age

15

greater than those observed elsewhere in the Northeast. Coincidence? Unlikely. Far more likely is that the data analysis provides one more reason to do all we can to keep mercury out of our waters. Emma Downs, a student at the University of Massachusetts Amherst, wrote this article during an internship at NEIWPCC’s Lowell headquarters. Editor’s Note: After the release of the report on the HBRF study, the Electric Power Research Institute, which is funded by a consortium of electric power producers, issued a statement strongly criticizing a number of the team’s conclusions. That statement plus HBRF’s responses and all other materials pertaining to the study are available at www.hubbardbrookfoundation.org.

Success Stories In conjunction with the development of the Northeast Regional Mercury TMDL, NEIWPCC and our sister interstate agencies, the Northeast States for Coordinated Air Use Management (NESCAUM) and the Northeast Waste Management Officials’ Association (NEWMOA), collaborated to produce four reports that document the impressive results of regional mercury reduction programs. The report seen here, “Northeast States Succeed in Reducing Mercury in the Environment,” provides an overview of the innovative and effective programs that are resulting in tangible, significant progress on reducing mercury from in-region sources. The other three reports go into greater detail about the accomplishments in the air, water, and waste arenas. All four reports can be accessed at NEIWPCC’s mercury web page (www.neiwpcc.org/mercury).

Page 

IWR, Winter 2007-08

Legal Lines

Katrina continued from page 5

Courts to Settle Dispute Over Mercury Strategy by Beth Card, NEIWPCC

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ou may have a noticed a theme in this edition of IWR—a lot of talk about mercury, most of which enters the environment through atmospheric deposition. Now, you might be inclined to think this is an air problem, and if it is, to question why it’s a big deal for NEIWPCC. The reality is, mercury poses a threat to both air and water resources, and the Northeast states have been investigating the regulatory tools available to address the problem. It turns out that both the Clean Air Act (CAA) and Clean Water Act (CWA) may be able to offer remedies. On the CWA side, the obvious tool is a TMDL, and the Northeast Regional Mercury TMDL that was submitted to EPA on October 24 focuses on mercury reaching our waters via atmospheric deposition and notes that these contributions are primarily from outof-region sources (see article on page 1). With regard to the CAA, a legal challenge is underway, with the states citing a need for EPA to implement more stringent controls. The legal maneuvering is the latest development in a story that began long ago—17 years ago to be exact.

Roots of the Rules In 1990, the CAA was amended to require among other things that EPA study the health hazards of electric utility steam generating units (EGUs), otherwise known as power plants, and determine whether the agency deemed it appropriate and necessary to regulate the emissions of hazardous air pollutants (HAPs) under Section 112 of the CAA. This section of the act regulates HAPs and provides a list of all of the pollutants regulated under this category. EPA conducted the study and in 2000 released its report. It stated that “mercury from coal-fired utilities is the HAP of greatest potential concern” and said it was indeed necessary to regulate those emissions. This determination triggered the requirement to set plantspecific emissions standards based on maximum achievable control technology (MACT). To develop standards using MACT for a particular source category, EPA looks at the best level of emissions reductions achieved on similar sources through clean processes, control devices, work practices, and other methods. These emissions levels set a baseline, often referred to as the “MACT floor,” for the new standard. At a minimum, a MACT standard for mercury and other HAPs emitted from power plants would need to achieve, throughout the industry, a level

New from NEIWPCC

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of emissions control at least equivalent to the MACT floor for those contaminants. Ultimately, EGUs were added to the Section 112 list of source categories and had to be regulated accordingly. The states were, and still are, of the opinion that this was the way to go. EPA’s decision to change course is in part what is now being litigated. Years after releasing the 2000 utility report, EPA drafted two proposed rules and in March 2005 released them for public comment. The two rules are known as the Clean Air Mercury Rule (CAMR) and the Clean Air Interstate Rule (CAIR). EPA said the two rules build off each other to “significantly reduce emissions from coal-fired power plants” and said that “when fully implemented, these rules will reduce utility emissions of mercury from 48 tons per year to 15 tons, a reduction of nearly 70 percent.” This sounds like the solution the Northeast states are looking for, but according to the calculations presented in the Regional Mercury TMDL, the reductions aren’t enough to make our fish safe to eat again. Also, the deadline for the reductions to be implemented is 2018, and many feel that is too long to wait.

States Make Their Case Of the two rules, it’s the CAMR that has been the main focus of the legal debate over controlling atmospheric mercury. The original proposal included two options: one maintained the listing of EGUs and sought to regulate them under Section 112 by using MACT standards or a cap-and-trade program; the other proposed to remove EGUs from the Section 112 list and instead regulate them through a cap-and-trade program under Section 111, which is the section that provides standards of performance for new stationary sources. EPA ultimately chose the latter approach, leading a number of parties to petition for the rules to be reconsidered. While EPA did grant that reconsideration on a number of issues, the agency issued a final rule in June 2006 with only a few changes. CAMR remained a rule that utilized authority under Section 111 and was intent on implementing a cap-and-trade program. Capand-trade, whereby there’s a limit on total emissions but individual plants can buy and sell pollution credits, is an approach that NEIWPCC’s member states unanimously oppose because of concerns over the increased potential for localized mercury deposition hotspots. Our member states that have EGUs to regulate have all developed New England Interstate Water Pollu tion Control Commission www.neiwpcc

116 John Stree t Lowell, Mass achusetts 01852-1124

L.U.S.T.LINE .org/lustline.ht

A Report On

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Bulletin 57 November 2007

d Storage Tanks

It’s Always Something n November, we published the latest issue of LUSTLine, which ! That Element of Surprise in Analyzing for since 1985 has been covering the issues of importance to the Gasoline Compounds underground storage tanks community. (LUST stands for leaking P underground storage tank.) The new LUSTLine features a detailed look at developments in analyzing for and monitoring various chemical components in fuels that can cause environmental problems if a tank has leaked. The coverage includes contributions by Patricia Ellis, Delaware Department of Natural Resources and Environmental Control, and Mark Toso, Minnesota Pollution Control Agency, who reveal their experiences with high levels of tert-butyl alcohol (TBA) and 1,2-dichloroethane (1,2-DCA) at some of their LUST sites. The current issue of LUSTLine and all issues since June 2004 can be accessed in their entirety at www.neiwpcc.org/lustline, where you can also download the new version of the LUSTLine Index. The index provides a comprehensive list of every article ever printed in LUSTLine and the issue in which it appeared. Archive issues unavailable on our website can be ordered by calling NEIWPCC at 978-323-7929. etroleum produ cts—gasoline , diesel fuel, heatin are composed of hundreds of chemicals, some g oil— are present in crude oil and of various classes some not. Fuels which of contain posed of petrol compounds. The bulk of the fuel is comeum hydrocarbon either presen constituents t in crude oil that are or in very simila produced by refining (e.g., r compounds blend these compo iso-octanes). What is in these gasolin The to complex require unds into a finished produ refineries e free-product sample ct according s—BTE MtBE? TBA? 1,2 DCA? type, component ments derived from regula tion, crude-oil TAME? DIPE? EDB? ETBE?… X? abundance, and Additives are operating charac ethanol, and used for a wide methanol can for example, variety of purpo teristics. also be found leum products. are ses. Some, in various petroAmendments detergents required by the As we’ve learne (CAAA) of 1990. Clean Air Act d from New Englan proprietary, we Because fuel Polluti additives are on Control Comm know little about d Interstate Water ronmental behavi their properties ission survey gram experiences, or. s of state LUST and envimany proAt the beginn states don’t compounds. analyz (See LUSTL gram our approa ing of the underground storag ine #56, “The e for these NEIWPCC’s ch to site assessm e tank pro2006 Survey Results of was to look ent at a fuel-re of Tank Progra the ethers are for benzene, lease site ms…”) Becau used to boost toluene, ethylb xylenes (BTEX se octane, they have conventional ). This was a gasoline. Some been used in logical approa enzene, and reasons: benzen states they didn’t have ch for three key e is a carcin these chemicals that may have thought pounds have ogen; many required have gasoline combecause they a very low effecti been surprised. were not highly volatil ve water solubi And e compounds we’re on lity; and are phere. Howe scavengers. These the verge of another surpri ver, this appro quickly lost to the atmos se—the lead compounds, ach began to methyl tert-bu which were used tyl chang until the common in reformether (MtBE) usage and release e when ulated gasolin s ■ continued CAAA. on page 2 e after the passag became e of the Inside Most of us now 2 TBA, Go Away! know that MtBE octane booste was used earlier r to 5 as an What About warnings about replace leaded additives. 1,2-DCA? Although some MtBE were LUST progra 7 Musings on m were unawa raised, most people in the the UST Challen re of the impen this chemical ges of the Future ding problems would cause. 9 The Gospel According to And MtBE isn’t additive whose Phil the only fuel use has resulte 13 Egads, Not ethers such as a Test! tert-amyl methy d in unpleasant surprises: ether (DIPE), l ether (TAME 14 California Field and ), di-isopropyl Study on ATG (ETBE), and alcohoto a lesser degree ethyl tert--b and LLD System 14 Update on Bad s utyl ether ls such as tertiary Gas in West -butyl alcoho Virginia l (TBA), 16 STI Online Recerti fication for Cathodic-Prot

Page 

ection Testers

their own rules for coal-fired utilities, and none allow trading of mercury emissions. Because of their concerns, our states and several others (16 in all) joined together to petition EPA’s final agency action on CAMR. In the states’ opening brief dated January 11, 2007, they presented three main arguments to the U.S. Court of Appeals for the D.C. Circuit. Their arguments are summarized as follows: • EPA exceeded its statutory authority and violated the CAA by removing EGUs from the CAA Section 112 list without complying with the mandated procedure. CAA Section 112 doesn’t give EPA authority to rescind its determination. • EPA’s action violates the CAA by exempting EGUs from Section 112 based on an erroneous “new interpretation” of Section 112(n) and CAMR and CAIR. The revised determination under Section 112 of what is appropriate and necessary is contrary to Congressional intent. There is no basis in CAIR or CAMR by which EPA can revise its determination of “appropriate and necessary.” • CAMR’s regulation of mercury under Section 111 is contrary to the statute. The scope and requirements of cap-and-trade under Section 111 is misused. Section 111(d) limits this section to those pollutants that are not emitted from a source category which is regulated under Section 112. Mercury is a HAP under Section 112. EPA stated its position in a reply brief on May 4, 2007. One of its main points in response to the states’ argument about delisting EGUs from Section 112 of the CAA was that the original 2000 finding lacked foundation, and thus the determination was wrong. EPA further stated that the agency “reasonably determined that it is not appropriate to regulate power plant mercury emissions under Section 112 because hazards to public health are not reasonably anticipated to occur as a result of power plant mercury emissions following implementation of Act requirements.” With regard to the cap-and-trade strategy, EPA said that “a significant advantage of a cap-and-trade approach to regulation, such as that established in CAMR or CAIR, is that it limits the overall amount of emissions from the industry, regardless of how many new sources are built, whereas a Section 112 approach would just limit emissions from particular sources and would not preclude overall emissions from increasing beyond a cap as new sources went into operation.”

Waiting Game The list is long of areas where the states, environmental advocacy groups, industry, and EPA disagree on the best way to regulate air emissions and control mercury pollution. And while opening arguments in the appellate court should have already begun by the time you are reading this article, we will likely not see a final decision until Spring. So it’s wait-and-see again, not only on the outcome of this legal battle but also the Northeast Regional Mercury TMDL. The two certainly go hand in hand, as the TMDL makes statements consistent with those made by the Attorneys General on behalf of the states in the CAMR litigation—that is, that the necessary reductions are possible if MACT standards under CAA Section 112 are implemented at 90 percent. How will it all play out? Hard to say. But one thing’s for certain—the outcome will be an important factor in determining how, and when, we see significant reductions in the mercury in our waters. Beth Card ([email protected]) is NEIWPCC’s Director of Water Quality Programs and a licensed attorney in Massachusetts.

IWR, Winter 2007-08

Winning Combination

NEIWPCC Collaborating with UNH Stormwater Center by Laura Chan, NEIWPCC

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t sounds like an ideal partnership: A university center specializing in stormwater treatment technologies teams up with an interstate agency with expertise in water quality outreach and education. And so far, so good. “For stormwater research, the combination of NEIWPCC and the University of New Hampshire Stormwater Center is a slam-dunk,” said Dr. Robert Roseen.

ative to helping the center remain focused on the most critical research areas,” Dr. Roseen said. But this relationship is not just about communication. Under the Assessment and Watershed Protection Program Grant, U.S. EPA has awarded funds to NEIWPCC for a project with the center to investigate the nutrient removal mechanisms of constructed gravel wetlands used for stormwater control in a northern climate. NEIWPCC is managing the project and providing

Sharing the Knowledge Members of NEIWPCC’s Stormwater Workgroup were among those listening as Dr. Robert Roseen (right), director of the UNH Stormwater Center, conducted a BMP Technology Demonstration Workshop at the center’s field site in Durham, N.H.

Dr. Roseen is the director of the UNH Stormwater Center, which is located on the UNH campus in Durham, N.H., and is the only facility of its kind in the nation. Its mission: to further the research and development of stormwater treatment systems and to provide resources to communities that are designing and implementing measures to meet federal stormwater regulations. Currently, the center is conducting side-byside comparison tests of 15 stormwater management systems, under strictly controlled conditions. Since its founding in 2004, the center has proven itself to be an effective and valuable resource for the investigation and promotion of innovative stormwater management strategies. But it’s a small operation, and can’t do everything. The center’s directors are now seeking to increase its effectiveness at communicating its research to government agencies, non-profit organizations, and other stakeholders working to protect the health of watersheds. That’s where NEIWPCC comes in. For years, our Stormwater and Nonpoint Source Pollution Workgroups have brought together state and federal regulators from the New England states and New York State for discussions of key issues. Through this workgroup framework and our related outreach activities, NEIWPCC is well positioned to facilitate a dialogue between the UNH Stormwater Center and watershed stakeholders. This communication is not simply a oneway dialogue. We present our Stormwater and Nonpoint Source Workgroup members with important findings and results from the center, while collecting and compiling feedback from workgroup members on the needs and goals of state programs regarding stormwater research, education, training, and outreach. “Input on the current and pressing research needs from state and federal regulators in this region is imper-

Expert Explanation During the workshop, Dr. Roseen (center) described the workings of a tree box filter that treats stormwater runoff from a UNH parking lot.

input from state and federal regulators for overall project direction. The center is providing technical expertise and oversight of the project, with its researchers utilizing the constructed gravel wetlands at the center’s field site and directing the laboratory analysis of samples. Both organizations will disseminate the results of the project in the technology transfer phase. As with all NEIWPCC projects, the needs expressed by our member states were the driving force. A survey of state and federal stormwater and nonpoint source coordinators conducted by NEIWPCC’s Regional Research Initiative Steering Committee showed that among the states’ highest priorities was research to dem-

The Green Corner

onstrate the effectiveness of best management practices (BMPs) in reducing stormwater and nonpoint source pollution. That finding sparked our initial conversations with Dr. Roseen, which already have borne fruit as we work together to increase knowledge of stormwater management, particularly Low Impact Development (LID) technologies. NEIWPCC and the UNH Stormwater Center will continue to work towards the common goal of providing watershed stakeholders with the information required to make important environmental decisions related to stormwater management. We are working together to conceptualize projects and actively seek funding opportunities to pursue necessary research. The partnership has shown that by working collaboratively

New IWR Feature! by Susy King, NEIWPCC

At NEIWPCC, we have long focused on improving water quality in our member states, but we must admit that we have not always focused on the impacts that our organization has on the environment. We are now working to correct that oversight. Recently, we formed a sustainability committee at our Lowell headquarters to implement new policies and practices that will make our workplace more environmentally friendly. Committee members are working on projects that will reduce waste and energy use by encouraging paper recycling, the use of non-disposable plates and utensils, and less reliance on bottled water. In addition, each issue of IWR will now include a new feature that will provide tips for leading a more

on stormwater research, we can accomplish more than if each organization acted alone. The UNH Stormwater Center is funded by the Cooperative Institute for Coastal and Estuarine Environmental Technology (CICEET) and the National Oceanic and Atmospheric Administration (NOAA). For more information, visit www.unh.edu/erg/cstev/. Laura Chan ([email protected]) is a NEIWPCC Environmental Analyst and the coordinator of all of our NPDES and stormwater-related activities, including our Stormwater and NPS Workgroups and our work with the UNH Stormwater Center. sustainable life. In this inaugural “Green Corner,” we bring you a brief quiz that focuses on ways to be more environmentally conscious in the workplace. The answers are on page 17. 1. Paper represents what percentage of office waste? A. 5 B. 15 C. 50 D. 70 2. If one million people shut down their office computers overnight, how many tons of carbon dioxide emissions would be eliminated per year? A. 1,000 B. 20,000 C. 45,000 D. 1,000,000 3. Compact fluorescent light bulbs (CFLs) use what fraction of the energy of incandescent light bulbs? A. 1/10 B. 1/4 C. 1/2 D. 3/4 Page 

IWR, Winter 2007-08

Birth Record On July 31, 1947, members of the U.S. Senate and House of Representatives passed the legislation that established NEIWPCC. Shown at left is page one of the four-page compact, and as can be seen, only Connecticut, Massachusetts, and Rhode Island had ratified it at the time of passage. Shortly thereafter, however, Vermont, Maine, New Hampshire, and New York formally joined the Commission.

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ram, EPA ES Permit Prog PD N al ip ic un M is Tom , Chief, chnology. At left econd from left) ient removal te Roger Janson (s tr nu on n sio . us ds a disc EIWPCC ite Programs, N New England, lea water and Ons te as W of or ct Groves, Dire

Page 10

2007: A Milestone Year by Stephen Hochbrunn, NEIWPCC

T

hroughout NEIWPCC’s history, it has never been the organization’s style to bring attention to itself. What has always been important is the work, the progress toward cleaner water— not the need to bask in the spotlight. But occasionally we reach milestones that point to the central role that NEIWPCC has played for so many years in the world of water pollution control. In 2007, we reached two such milestones: we marked our 60th year in existence, and held the 200th meeting of our Commissioners. As you might expect from a humble organization, we didn’t throw a big party—we’ll save that for our 100th anniversary—and instead chose to celebrate this important year in our history in more subtle ways. Our graphic designer, Cindy Barnard, designed the eye-catching logo that appears on this page and which has graced our website throughout the year. We resurrected and reread the compact that formed NEIWPCC in 1947 (the first page of which is reproduced here), noting how true the organization has stayed over the years to its original mission. We also chose to fully document our 200th meeting in pictures, a number of which you see here. Space doesn’t permit us to include all of our favorite shots of the meeting, which took place on May 17-18 at the Hawthorne Hotel in Salem, Mass. If you’d like to see a more representative ­compilation, visit our website at www.neiwpcc.org/newsroom/200thphotos.

Partners in Progress Participants in NEIWPCC’s 200th Commission Meeting strike a pose in the lobby of the Hawthorne Hotel in Salem, Mass. Seated (left to right): Tom Groves, Becky Weidman, Beth Card, Susy King, Susan Sullivan (all NEIWPCC), Denise Springborg (formerly NEIWPCC, now MassDEP). Standing (left to right): Al Curran, Maine; Frank Thomas, N.H.; Bill Taylor, Maine; Leo Hetling, N.Y.; Nelson Thibault, N.H.; Alicia Good, RI DEM; Charlie Button, Mass.; Astrid Hanzalek, Conn.; Dick Svenson, NYSDOH; Sandi Allen, NYSDEC; Ron Poltak, NEIWPCC; Jeanette Bengtson, NEIWPCC; Roger Janson, EPA; Bob Varney, EPA; Stephen Perkins, EPA; Clough Toppan, ME DHHS; Harry Stewart, NHDES; Yvonne Bolton, CT DEP; Andy Fisk, ME DEP; Les Sutton, Mass.; Don Pryor, R.I.; Mike Jennings, NEIWPCC; Al Bromberg, N.Y.

Director, an, Deputy iv ll u S tor, n sa Su Fisk, Direc , and Andy C C P ty, Maine li IW a E u N d Water Q n a d n a L rotection. Bureau of onmental P ir v n E of t Departmen

Harry Ste wart, Dir ector, Wate Hampshir r Division e Departm , New ent of Env Services, a ironmenta nd NEIW l PCC Cha ir (2006-2 007).

IWR, Winter 2007-08

As for what it was like to actually be at the meeting, we asked our Chair, Harry Stewart of the New Hampshire Department of Environmental Services, to provide his thoughts. “It was a privilege to preside over the 200th Commission meeting,” Stewart said. “NEIWPCC meetings provide an outstanding opportunity to exchange ideas and approaches to water quality challenges on a regional basis. Looking back at the history, the most impressive thing about NEIWPCC is how the focus has evolved, as the regional and national issues and needs have changed. For example, in the early years, the focus was on basic pollution control in interstate waters. Sixty years later, NEIWPCC has just completed arguably the most successful specialty conference to date for state regulators on the emerging issue of the potential water quality impacts of pharmaceuticals in wastewater discharges [see article on page 1]. NEIWPCC will continue to be a leading edge organization on environmental policy issues and professional training into the future.” Thank you, Harry, for the kind words. And thank you to all of you who have played a part in NEIWPCC’s success, who have joined with us over the years in our efforts to serve and assist our member states in their pursuit of clean water. We’ve come a long way since 1947. We couldn’t have done it without you.

Ron Polta k

, Executiv e Director,

NEIWPC

C.

Beth Card (left), Director of Water Quality Programs, NEIWPCC, with Alicia Good, Assistant Director, Water Resources, Rhode Island Department of Environmental Management, and incoming NEIWPCC Chair. Good will be the first female Chair in NEIWPCC’s history.

ew ator, EPA N l Administr a n C io C eg P R , IW in NE Bob Varney participant t en Chair in u r eq ou fr s a ey served England. A rn ew a V , gs n er of the N Meeti Commission s Commission a w e . h es ic en tal Serv 996, wh nvironmen 1995 and 1 rtment of E a ep D e ir Hampsh

Dick Kotelly, N EIWPCC’s Trea surer, delivers th 2006 audit, in w e results of our hich the audito Fiscal rs once again ga opinion an orga ve us the highes nization can re t ceive.

anagement and Chief, Materials M u rea al Bu , ft) (le n ent of Environment Yvonne Bolto Connecticut Departm u, rea Bu 93 e 19 nc ra ce su sin As er Compliance IWPCC Commission trid Hanzalek, a NE Protection, with As rshed Council. nnecticut River Wate Co e th of air ch r and forme

One sweet celebration! Page 11

IWR, Winter 2007-08

Katrina PPCP Conference continued from continued page 5from page 1 “There are no benefits from triclosan for the average consumer,” Halden said. “Regular soap works just as well as an antimicrobial, plus we know it’s benign environmentally and has been used safely for centuries.”

Information Source

known to harm aquatic life. “But we do have a long way to go in terms of setting standards for other PPCPs.” To set standards, EPA needs data, and the Office of Water has embarked on several key projects, including a national pilot study of PPCPs in fish. Researchers are sampling for 37 PPCPs in fish tissue from five U.S. streams at locations where the effluent from a wastewater treatment plant dominates the flow. According to Conerly, that analysis should be finished by the end of the year. The Office of Water is also sampling for pharmaceuticals, including steroids and hormones, in the influent, effluent, and sludge of a number of publicly owned wastewater treatment plants around the country. Look for that study to be complete by December 2009. Will we ever move from research to regulation? At a Congressional hearing in Washington in late 2006, lawmakers chided EPA officials, including Assistant Administrator for Water Ben Grumbles, for taking too long to determine if the presence in the Potomac River of male fish with female sexual characteristics was a sign that PPCPs were in the water at a level that could harm

The U.S. Geological Survey cosponsored the Portland forum, no surprise given it’s produced some of the finest and most influential research to come out on PPCPs. In 2002, USGS published a landmark study showing that half of the 139 streams the agency sampled nationwide contained seven or more organic wastewater contaminants, including antibiotics and synthetic hormones. USGS has also conducted significant research on contaminants known as endocrine disruptors, because they can interfere with horPoints of Consideration Pat Phillips of the U.S. Geological Survey, monal activity and disrupt functions such as a leading expert on PPCPs and their environmental impact, delivers a reproduction. In January 2007, for example, the ­presentation on organic wastewater contaminants in the Lake Champlain basin. agency reported that endocrine disruptors such as flame retardants and a banned fungicide were found ­initiatives. As the conference went on, one thing became in Potomac River tributaries, and clear: while there’s a lot we know about PPCPs, there’s a that the chemicals may be to blame lot left to be learned. But to wait to do anything about for all the male smallmouth bass in them until our knowledge base is complete would be a the waters that are exhibiting female mistake. characteristics. As Robert Varney, EPA New England’s Regional In his presentation at the Administrator, said in his opening remarks, “We know forum, USGS’s Edward Furlong there are significant data gaps that need to be filled. We didn’t touch on the January report, recognize there are many unknowns. But let’s move forbut did discuss several USGS studward while the questions are being answered.” ies currently underway. In Boulder Creek, Colorado, samples taken at a Grounds for Examination wastewater treatment plant’s point As a field of research, the study of PPCPs in the enviof discharge showed a surge in levels ronment is relatively young. The term PPCP itself has of the female sex hormone estradiol only been in use since 1999, when it appeared in a in the water. “Downstream, there review published in the journal Environmental Health were still significant levels,” Furlong Perspectives. Around some basic details, there is no said, “and they were always above dispute. PPCPs, which include everything from antithe effects level.” depressants to caffeine and the chemicals in your favorOn-Air Exposure Maine Public Broadcasting Network’s Jeanne Baron (right) interFurlong was referring to levviewed Dr. Rolf Halden of Johns Hopkins University (center) after his presentation at the ite shampoo, are produced and used in large quantities. conference. The interview aired on MPBN on August 8 and can still be heard online at els that could potentially affect fish, They enter the environment when they are excreted, www.mpbn.net/asx/070808chemicals.asx. Also pictured, NEIWPCC’s Marianna Vulli, the but among the public, the burning flushed down the toilet, rinsed down the drain, or put organizer of the forum and coordinator of our Regional Research Initiative. question is whether people can posin the trash. Once in the environment, the chemicals sibly be affected. On its website, EPA appear in very low concentrations. What researchers emphasizes that, “to date, no evidence has been found of are still trying to determine is the specific risks the low humans. U.S. Rep. Jim Moran, D-Va., was quoted as sayhuman health effects from PPCPs in the environment.” concentrations pose, to both aquatic organisms and to ing, “It seems [the EPA] looks for any excuse it can find But the impact on humans is still an open question, and humans. to delay the implementation of regulations that could scientists—in the United States and elsewhere—are conOne of those researchers, Dr. Rolf Halden of affect public health.” Grumbles acknowledged the continually learning more about PPCPs and their effects. Johns Hopkins University, delivered the conference’s cerns, but emphasized that the issues were complex, that Are we in the U.S. learning fast enough? For years, first presentation. “Most of the chemicals in your shammore information was needed about how compounds some of the best research on PPCPs has come out of poo and other personal products,” Halden said, “have interact. Europe—as USGS’s Pat Phillips, one of the Northeast’s not been adequately tested for toxicity.” EPA has also taken criticism from some corners top experts on the environmental impact of PPCPs, As an example, he cited triclosan, the active ingrefor its work with other government agencies on new pointed out during an IWR interview in November dient in popular soaps labeled “antibacterial.” According guidelines for the disposal of unused prescription drugs. 2005. At the Portland forum, Phillips said during an to Halden, a study in Maryland found that all but 3 The guidelines, which were released under the banner interview that the amount of PPCP research in this percent of the triclosan entering a wastewater treatof the White House Office of National Drug Control country is improving. ment plant was removed in the treatment process, but Policy, include a list of drugs that the government “We’re starting to do better,” said Phillips, who that doesn’t mean it all disappeared. He said about half advises users to flush down the toilet rather than throw spoke at the forum and also served on the planning of the triclosan in the influent ended up in the plant’s in the trash. The list includes notoriously abused drugs team. “The Europeans are progressing too, but we’re biosolids, the treated sludge destined to be applied to such as OxyContin; the Office of National Drug Control catching up.” farmland as fertilizer. Policy believes that by flushing them, they won’t end up “This may not be a problem, but maybe it is,” in the wrong hands. The National Association of Clean Federal Attention Halden said. “What is the half life of triclosan? Are there Water Agencies criticized the idea for its potential to The presence of EPA officials at the forum spoke to that earthworms ingesting it, which are then eaten by birds, increase the flushing of all drugs, not just those on the agency’s growing interest. In addition to Varney, Octavia and the chemical makes its way up the food chain?” list. Flushing of course puts drugs in the waste stream, Conerly from EPA’s Office of Water in Washington delivHalden is seeking the answers, and like Varney, where they all too easily end up in waterways. ered a presentation. Her focus—the work done and yet he’s urging action while the research advances. Educate During an interview at the forum, EPA’s Conerly to be done. people about the potential toxicity of triclosan, he said, said the agency had to go along with the flushing guide“We did recently set a standard for nonylphenol,” and they may decide against paying a premium to buy lines. “The Food and Drug Administration wants [the Conerly said, referring to EPA’s release in 2006 of the products containing it—especially when they realize 13 drugs on the list] to be flushed,” she said. “Right now, safe levels in water for one particular chemical that’s what that premium’s buying them. we had no other choice.” Page 12

IWR, Winter 2007-08

But Conerly said EPA wants to come up with a better solution. “We need to come up with a way that the public can dispose of the drugs,” she said, “maybe through a national take-back program. That would be a multi-agency effort.” With multiple agencies involved, such a federal program is a long way off, if it happens at all. But takeback programs on a smaller scale already exist, and were a hot topic at the forum. Ann Pistell of Maine’s Department of Environmental Protection spoke about Maine’s pharmaceutical mail-back legislation and the state’s practice of holding large one-day drug collection events. Rebecca Walter of the Minnesota Pollution Control Agency discussed that state’s impressive Healthcare Hazardous Waste Initiative. Through educational workshops and enforcement actions, Minnesota has dramatically reduced the amount of pharmaceuticals and other hazardous wastes improperly disposed of by healthcare facilities. For example, Minnesota is now recycling the 25,000 gallons of formalin, a hazardous fixative, that used to end up in its sewers every year.

Learning Experience With more than 30 presentations over two days, the forum provided participants with a lot of information to absorb. Too much, perhaps, had it not been for the ardent interest. Throughout the conference, the long rows of chairs stayed filled as speakers such as the Silent Spring Institute’s Laurel Standley engaged listeners with stories and science. “Clearly we have a link,” Standley said, as she described a study of contamination in ponds on Cape Cod that are fed primarily by groundwater, rather than rivers and streams. “In ponds surrounded by residential development serviced by septic tanks, we found hormones and pharmaceuticals in the water, at low levels.” The link was so clear because few if any PPCPs were found in ponds in low residential density areas.

Obviously PPCPs were moving through septic systems to groundwater and into ponds, with the potential for biological implications. What about drinking water wells that might pull from the same groundwater? “It’s best to locate wells as far from septic systems as possible,” Standley said. “But that’s hard to do in high residential density areas.” At this stage in this field of study, nobody has all the answers—especially when there are so many questions. The issue of PPCPs in biosolids, which Rolf Halden raised in the opening presentation, came up again on the second day as USGS’s James Gray delivered a compelling talk on his research. Gray and his research partners collected and analyzed liquid and solids samples from five U.S. wastewater treatment plants to determine how different treatment processes affected the degradation of hormones. While the study won’t be published until 2008, Gray discussed some preliminary results. He’s found that while the plants’ biological treatment can remove up to 90 percent of hormones from liquids, the plants’ treated biosolids are enriched in hormones by comparison. Of course, we’re talking about very low levels, but the levels don’t have to be high to be a concern. “I wouldn’t say this issue has been overlooked,” said Gray in an interview. “But we now have the analytical technology for measuring these compounds at the very low levels where they are biologically relevant. It’s very challenging though, and we’re still refining the methods.” EPA is also looking closely at this issue; earlier this year, the agency added PPCPs to the contaminants it’s looking for in biosolids examined in its National Sewage Sludge Survey. Contrary to Gray’s research, however, EPA’s results are not expected anytime soon. Spirited question-and-answer sessions followed each presentation, and NEIWPCC’s Marianna Vulli, the coordinator of our Regional Research Initiative, moved

quickly about the room, bringing a microphone to the questioners. Vulli displayed the same energy she showed throughout the preparations for the conference, as she led the effort to make it a reality. The end result was clearly appreciated. “It’s great that NEIWPCC put this conference together to allow us all to share information,” said Shayne Mitchell of New York State’s Bureau of Water Permits. Praise came from the private sector attendees as well. “It’s good to get a background about the problem,” said Hatim Fadlalla of the environmental engineering firm, Wright-Pierce. “We are anticipating that this will be a hot issue in the years to come.” “It was a terrific two days,” said NEIWPCC’s Vulli. “I was thrilled by the greater than excepted turnout, which tells me that we made the right decision to dedicate this forum to this topic at this time. And we couldn’t have done it without our planning team, which succeeded in developing a robust agenda that brought together a terrific group of speakers. I believe we achieved what we set out to do, which was to provide attendees with a foundation for understanding the issue of PPCPs in the water environment.” This was the first Northeast Water Science Forum, and its success invigorated plans to make it a regular event. NEIWPCC is now exploring topics for the next edition, and as details become available, they will be posted on our website (www.neiwpcc.org). For more on the PPCP forum, including access to many of the presentations and a directory of attendees, go to www.neiwpcc.org/ppcpconference. At NEIWPCC we are committed to following developments in the PPCP arena, and to keeping our member states informed through our website, publications, and Commission and workgroup meetings. As was made clear by the experience in Portland, it’s a topic people want to know about and need to know about. Overlooked? No more.

Version 3.0

Revealing Findings in Latest NEIWPCC Tanks Survey by Kara Sergeant, NEIWPCC

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ow many states have standards for ethanol? You can find that information and much more in the results of the third version of a national survey NEIWPCC first conducted in 2000. While the content of the surveys has evolved over the years, the primary goal has remained the same: to get a national snapshot of assessment and remediation issues related to leaking underground storage tanks (LUSTs) across the country. The latest survey builds upon the information gained in the previous editions. In 2000, the focus was on methyl tertiary-butyl ether (MtBE), while the 2003 survey emphasized all fuel oxygenates. Our focus in 2007 is captured in the survey’s title: “State Experiences with Petroleum and Hazardous Substance Releases at LUST Sites, Heating Oil Tanks, and Out of Service Tanks.” Because this was our third survey, we were able to compare results from the previous editions and note changes. NEIWPCC’s contractor on the project, Ellen Frye of Enosis – The Environmental Outreach Group, developed the questions with Pat Ellis of Delaware’s Department of Natural Resources and Environmental Control. Several state LUST program staff reviewed the questions for clarity and content. The survey was divided into 12 areas: state standards for specific gasoline additives/blends, fuel blend/additive analysis, site assessment, drinking water impacts, remediation,

remediation cost impacts, vapor-intrusion pathway, hazardous substance USTs, heating oil tanks, out-of-service tanks, ethanol, and miscellany. State LUST managers from all 50 states responded electronically through a password-protected website. Among the findings: Remediation Cost: Gasoline plumes from leaking tanks are expensive to cleanup, but how much does gasoline composition matter with respect to cost? MtBE has traditionally been seen as a driver in remediation costs because it is highly mobile in groundwater and often expensive to treat. But the survey showed most states do not feel MtBE increases a site’s cleanup costs, though the chemical continues to be a concern because of its well deserved reputation for being difficult to remediate and its potential impact on drinking water wells and human health. Did the increased use of other oxygenates impact cleanup costs? Again, the states said no. So if gasoline composition doesn’t impact cleanup costs, what does? The survey showed the key factors are the length of the contamination plumes and the need for monitoring. The longer the plume, and the more extensive the monitoring, the higher the cost. Ethanol: The increase in nationwide ethanol consumption is clear. According to the survey results, there are E85 (85 percent ethanol) gas stations in 34 states. Despite the increase in use, only seven states indicated

they have standards for ethanol, only a slight increase from 2003. In states without standards, there is no requirement to look for ethanol contamination, so potential problems may go unnoticed. Drinking Water Impacts: The ability of a state to prevent drinking water contamination from LUSTs and to prioritize cleanups is enhanced when information is shared between a state’s drinking water/ source water protection program and its UST/LUST programs. In the survey, many states said there was some communication between these areas, but the responses underscored the need to do more in this area. NEIWPCC will continue to explore opportunities to encourage cross-program coordination. In recent years, we have held meetings in Massachusetts, Illinois, and Minnesota that brought together state UST, LUST, State Fund, and groundwater and source water program staff in an effort to foster greater collaboration. These are only a few highlights from the extensive survey results, which will be useful to state and federal government staff as well as industry personnel interested in LUST trends. For the complete results, visit the survey section on our website (www.neiwpcc.org/mtbe.asp), where you can also find detailed information on the 2000 and 2003 surveys. Kara Sergeant is a NEIWPCC Environmental Analyst, and was the coordinator of the 2007 survey. For more information about the survey and the results, contact her at [email protected]. Page 13

IWR, Winter 2007-08

Fishing for Data

The Hudson River Striped Bass Cooperative Angler Program by Kris McShane, NEIWPCC/Hudson River Estuary Program

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he recovery over the last 15 years of the once decimated striped bass (Morone saxatilis) population has led to a large recreational fishery on the Hudson River. But to sustain a thriving and healthy striped bass population in the Hudson, it is critical that the species not be overfished. To do that requires detailed, accurate information on the fish and the fishing. Who better to provide it than those reeling in the lines? In the Hudson estuary, some of the necessary data is indeed coming from recreational anglers, thanks to a program that solicits them to voluntarily record information about their fishing trips in a logbook.

from the data, fishing regulations are proposed to prevent overfishing and maintain the stocks of fish at sustainable levels. The ASMFC can also mandate that a state agency run a specific sampling program to gather important data needed to manage a particular stock of fish. Such a mandate is in place for striped bass in the Hudson for good reason: the river has the only estuary on the coast where fishing of striped bass is allowed when the fish are on their spawning grounds. This heavy fishing pressure could have an effect on the stock of striped bass that spawn in the Hudson and then migrate along the Atlantic coast. As a result, the ASMFC requires

used, length and weight of fish caught, total number of hours fished, and any additional remarks. Although the focus of the CAP is striped bass, anglers are asked to record all their Hudson River fishing trips. Having all trips recorded gives biologists an estimate of how often striped bass are the target species and how often they are caught as bycatch (fish caught when the angler is targeting a different species). While the information in the 2007 diaries is still being analyzed, the 2006 diaries have been thoroughly reviewed—and the findings are revealing. (2006 was the first year in some time that a CAP was run on the Hudson due to shortfalls in budget and staffing.) Fifty-three of the anglers contacted agreed to become volunteers and were sent diaries, but only 19 diaries were returned. However, those 19 anglers provided good information on the Hudson’s spring recreational fishery. The 19 fishermen totaled 253 fishing trips, and logged information for 576 anglers who fished for a total of 3,405 angler hours. Of the trips, 248 targeted striped bass and five targeted river herring (blueback herring or alewives) to be used as bait for striped bass. All the trips occurred between mid-March and midJune. Of the 248 fishing trips targeting striped bass, 177 (71.4 percent) were successful, meaning at least one striped bass was caught. In total, anglers caught 622 bass, of which 124 were kept and 496 released. Anglers recorded measurements of 580 individual bass. Of these, 501 (87 percent) were longer than the minimum legal size limit of 18 inches. Probably due to the one-fish-per-day regulation, many anglers practiced “catch and release” even when a legal fish was caught. Of the 501 legal stripers caught, 380 (76 percent) were released and 21 were kept. The diaries showed the majority of the striped bass fishing on the Hudson in 2006 was done from a boat and that the terminal tackle of choice was natural bait, primarily herring.

Journaling for a Cause In a project coordinated by NEIWPCC staff, anglers who fish the Hudson River use diaries to provide data on their trips. The data is part of a pool of information used by officials to set effective regulations for managing the East Coast’s stock of striped bass.

Moving Target An angler diary program is particularly important with striped bass because it’s an anadromous fish species, meaning the fish spend all or part of their adult life in salt water and return to freshwater streams and rivers to spawn. That makes it difficult for fisheries managers to manage the population. Striped bass in the Atlantic Ocean migrate along the East Coast from North Carolina to Maine, and spawn in the major estuaries, primarily Chesapeake Bay and the Delaware and Hudson River estuaries. The long migratory route means the species must be managed on a coastwise basis. Handling this task is the Atlantic States Marine Fisheries Commission (ASMFC), which consists of three members from each state on the East Coast, from Maine to Florida. The members of a state’s coalition include the director of the state’s marine fisheries management agency, a state legislator, and an individual appointed by the governor. Fisheries biologists provide ASMFC members with summaries of species-specific fisheries data from the myriad of sampling programs run by state agencies along the coast. Based on the information derived Page 14

the Hudson River Fisheries Unit of the New York State Department of Environmental Conservation to conduct a Cooperative Angler Program (CAP) to gather information on the recreational striped bass fishing that occurs in the river each spring.

Diarist’s Dream Brian Brockett of Otisville, N.Y., a participant in the angler diary program, shows off a striper caught in May 2006 near Kingston, N.Y. The fish, which weighed more than 47 pounds, earned Brockett first place in the Annual Hudson River Striped Bass Derby.

Written Records The CAP, also known as the angler diary program, is a valuable tool used by fisheries biologists to evaluate fish populations. It is a cost-effective way for biologists to gather an important, and often difficult to collect, set of data used when studying the dynamics of a fish population. Information from the diaries is used to estimate harvest rates, catch rates, mortality rates, and population size. It can be used for analyzing current fishing regulations and developing future rules. The Hudson River Striped Bass CAP for the 2007 fishing season had more than 100 volunteer fishermen who kept records of their fishing trips on the river and reported the information to the fisheries unit. The diary entries include the date of each trip, location, start and end time, target species, fishing method, type of hook

Angler diary programs are utilized by states and agencies across the country to track the populations of many different fish species in both inland and marine systems, and to gauge the fishing pressure on them. If you fish and are willing to log your fishing trips (even those where you catch nothing), contact the fisheries unit of your state’s conservation department. You may be able to help protect the fish that provide you with enjoyment and sustenance. Kris McShane ([email protected]) is a NEIWPCC Environmental Analyst who works with NYSDEC’s Hudson River Fisheries Unit. His many projects include coordinating the Cooperative Angler Program.

IWR, Winter 2007-08

From the Hill The Court Has Spoken – Now It’s Everybody Else’s Turn by Beth Card, NEIWPCC

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tions. In other words, the federal government has to figure out which waters are regulated and protected under the terms of the U.S. Supreme Court. The guidance was released in June, with the comment period ending on January 21, 2008. The guidance can be downloaded at www.epa.gov/owow/wetlands/guidance/CWAwaters.html. The legislative branch is also weighing in. This spring, U.S. Representatives Oberstar (D-MN), Dingell (D-MI), and 170 cosponsors introduced the Clean Water Restoration Act; U.S. Senator Feingold (D-WI) introduced a similar bill in the Senate. The proposed legislation would amend the Clean Water Act by striking the phrase “navigable waters,” which is currently defined as waters of the United States and territorial seas, and replace it with the phrase “waters of the U.S.” That phrase would have a statutory definition based on current Corps and EPA regulations. This definition is very specific and contains the usual suspects such as lakes, rivers, and streams, but goes on to include wetlands, sloughs, and prairie pot holes in the definition, just to name a few. Environmental groups, states, and industry are all reacting to the proposed bill—some in favor, some unequivocally opposed. The Association of State Wetlands Managers, many state agencies, and environmental advocacy groups support the move as a way to ensure that sensitive water body systems such as headwater streams and isolated wetlands are protected. Industry groups—the National Association of Homebuilders and the American Farm Bureau Federation among them—

n the last edition of IWR, we examined Clean Water Act jurisdiction and the ramifications of the U.S. Supreme Court decision in the cases of Rapanos and Carabell. Governmental agencies and interest groups across the country continue to carefully track this issue, as questions surrounding significant nexus, continuous flow, adjacency and all the scenarios in the Supreme Court opinions are being interpreted, twisted, turned, and reexamined in lower courts across the country. So much confusion exists over what the Scalia plurality meant or didn’t mean, over whether the Kennedy test could also be applied, and over how these tests ought to work in the field that it seems no clear answer exists. How are regulators and land owners to know when permits are needed for development, and what waters are protected or not protected? The Supreme Court’s opinions further muddied the already murky waters on Clean Water Act jurisdiction and left more than enough room for further legal challenge. But remember what you learned in grade school about American government and our system of checks and balances? Since the judicial branch has spoken and continues to speak, it was to be expected that the executive and legislative branches would also have something to say. From our partners in the executive branch: the U.S. EPA and the Army Corps of Engineers released a guidance memorandum on how their regional and field office staff should interpret and apply the Rapanos/ Carabell decision in making jurisdictional determina-

Enduring Tradition

Beth Card ([email protected]) is NEIWPCC’s Director of Water Quality Programs.

from NEIWPCC’s YEP Coordinator, Bryan Hogan. The lessons covered such topics as the water cycle, tide pools, water quality, water pollution and prevention, and microorganisms that live in water. “It was great interacting with the kids, just amazing,” said Hogan. “The best part of it was watching them go from not caring about wastewater treatment or even the environment to beginning to understand how important they are.” The group also went on educational field trips to the Seacoast Science Center in Rye, New Hampshire; the Squam Lake Natural Science Center in Holderness, New Hampshire; and the Massachusetts Water Resources Authority’s Deer Island Sewage Treatment Plant. For more information on the Youth and the Environment Program, contact NEIWPCC’s Mike Jennings at 978-323-7929 or [email protected].

YEP Introduces Urban Youth to Environmental Opportunities by Stephen Hochbrunn, NEIWPCC

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he best description of this year’s Youth and the Environment program in Lowell, Mass., came from Fred Hamel, an engineering technician at the Lowell Regional Wastewater Facility. During a ceremony at NEIWPCC headquarters in August to honor this year’s graduates, Hamel called the program a “win-win.” “The students got a lot of work done around the plant, and we benefited from that,” Hamel said. “But they learned a lot too—about the wastewater field and about the environment. And that’s a big benefit to them.” Since 1990, NEIWPCC, EPA, and the Lowell Regional Wastewater Utility have collaborated in conducting the Youth and the Environment summer program in Lowell, Mass. The program, which is part of a national effort by EPA, stresses hands-on work experience and academic training to introduce disadvantaged inner-city high school students to professional opportunities in the environmental field. Emphasis is placed on careers in the wastewater industry, which is experiencing a shortage of young people entering its workforce. The participants are paid as they gain new knowledge, learn new skills, and find out about a rewarding career path. “It was a lot of fun,” said Enock Mukiibi, one of the students in this year’s program, at the graduation

argue the legislation will impede development and cause permits to be required in cases where they were never required before. And a handful of states see the legislation as unnecessary and intrusive on state programs. Further concerns exist over how the legislation may impact NPDES permitting requirements, even though the bill does include a clause that prevents any change in federal authority over agricultural irrigation, stormwater runoff at oil and gas exploration sites, and 404 requirements related to silviculture, ranching, and many other activities. So, should we be concerned? Does this proposed legislation cast a wider net over what is covered under federal jurisdiction? To answer that, I urge you to keep in mind two things. First, this definition is not new. It already exists in EPA and Corps regulations. What is new is the idea of putting the definition into statute, making it part of the Clean Water Act. Second, the purpose of the legislation is to take the guessing game out of some of these cases. Certainly there will always be instances where a jurisdictional determination can or should be challenged, but the clearer the statute, the less room for argument. At this juncture, much remains to be seen. We will wait and watch whether the sponsors in the House can acquire a simple majority (218 out of 435) to move the bill to the Senate. There are many, many more steps that need to happen before the Clean Water Act is amended and the definition of waters of the United States put into place. So much could happen along the way. We’ll keep you posted.

Rewarding Experience The 2007 Lowell Youth and the Environment Program students at the Seacoast Science Center in Rye, N.H. Clockwise from left: Sabrina Tuy, Michael Lam, Enock Mukiibi, Esthelver de Jesus.

ceremony. “Really, it was a great job. Thank you for the opportunity.” During the six-week program, the students spent most of their days at the Lowell facility, working in a variety of the wastewater plant’s operations, including pretreatment, maintenance, landscaping, and lab work. In the afternoons, they gathered to hear lessons on wastewater treatment and other environmental issues

Productive Partnership At the graduation ceremony, NEIWPCC Youth and the Environment Program Coordinator Bryan Hogan presents a plaque of appreciation to Fred Hamel, Lowell Regional Wastewater Facility.

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IWR, Winter 2007-08

Talking Sprinklers, Desal, and Water Reuse A Conversation with Conservation Expert Amy Vickers by Stephen Hochbrunn, NEIWPCC

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my Vickers doesn’t have anything against lawns. But her vast knowledge of the way we use and misuse water in this country has led her to crusade against an all too common practice— overwatering. “Lawns aren’t the problem,” Vickers said during a phone interview. “It is the relationship to them that is sick. And it’s getting more unhealthy every day. Sadly, in New England, outdoor water use is the primary source of water waste in many communities.” Based in Amherst, Mass., Vickers is an engineer, water conservation consultant, and author of the Handbook of Water Use and Conservation (WaterPlow Press, 2002), which the American Water Works Association has called “the most thorough reference ever published” on the topic. For decades, she has advised water supply systems, government agencies, businesses, and other organizations on ways to better manage their water. As a speaker, she is in demand. In March 2007, Vickers delivered the keynote address at the “Water for Rhode Island—Today and Tomorrow” conference in Providence, R.I., and her lucid comments there inspired our desire to hear more. We spoke with her by phone over the summer. IWR: If everyone in New England, including those with private wells, suddenly cut back on lawn watering to just once a week, would that do away with the concerns in many communities about having enough water to meet demand? Vickers: It seems like a real possibility. We don’t know as much as we need to know about why 70 percent of the river basins in Massachusetts are flow stressed. But a lot of anecdotal evidence from water managers in New England, particularly in Massachusetts and Rhode Island, points to one thing as being the likely culprit— automatic irrigation systems. Certainly we need to dig more to get hard facts rather than anecdotal evidence. But we should be on that road [to reducing lawn watering] because if we aren’t, we are going to continue to witness the diminishment of our fresh water here in New England. And that is totally unnecessary. IWR: Aren’t many people already fairly responsible with their water use? Vickers: The good news is that the average person tends to be more efficient, not wasteful in their use of water. It is the top users that we need to focus on, those homes where per capita water use is two, three, sometimes four times the average. I did a study for the city of Dallas, and found that the top 10 percent of users demand more than 400 gallons per capita per day, compared to the average demand of 110 to 115 gallons. When we really narrow in and focus on the problem, it is actually a minority of water users who are truly the problem. Those are the people we need to target with a conservation program. IWR: But as you said in your speech in Providence, changing the behavior of the top users isn’t easy. Vickers: They tend to be affluent, and the affluent typically don’t care about the cost of water. Raising the price won’t provide an incentive to cut back on use. I feel strongly that we need statewide rules on water restriction that are fair and apply equally to rich or poor. I know of at least one town that has an ordinance stating that if its watering limits are violated three times, the violator’s irrigation system is shut off. I think that is reasonable. People have to be given fair warning that

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they are flouting necessary conservation restrictions, but if they continue to do so, it is reasonable to shut off their irrigation system without shutting off their water lifeline. That being said, I think part of the reason that watering rules aren’t always honored is that the public doesn’t understand them. When the public understands the reason for the rules, I think you see higher compliance. IWR: Is reducing water use and waste sometimes not enough? In Brockton [Mass.], officials say they’ve done all they Speaking Sense Water conservation expert Amy Vickers talks with an attendee can to restrict outdoor water use and fix after her keynote address at the “Water for Rhode Island—Today and Tomorrow” leaky old water pipes, but they say they still conference in Providence, R.I., on March 1, 2007. need more water. They’re going to get it by buying water from a desalination plant IWR: Speaking of waste, how do you feel when it’s pourbeing built on the Taunton River. Is that ing rain and you pass a home with its automatic sprinacceptable to you? klers on? Vickers: I can’t comment on Brockton specifically Vickers: The irrigation industry has been irresponsible because I don’t know all the details. What I would say is in promoting products that were never meant to be used that no community in America has yet to exploit its full by the average consumer. The industry needs to grow up, potential for water efficiency. Where we see desalinaget with the 21st century, and design irrigation products tion in the United States I think we’re seeing a failure in light of the reality of today’s water supply issues. in responsible water management, i.e., not investing in I’ll mention something I’m working on in Florida, a comprehensive water conservation program. I think which requires rain sensors [on automatic sprinklers so there are still some water managers who are promoting they don’t irrigate during and after a rainfall]. You know water conservation with bumper stickers and blue balwhat the problem is? A lot of the rain sensors don’t loons during National Water Week. work out of the box. They’re made with cheap materials. Today the fields of water efficiency and water They never function right. They’re not designed for the conservation are far more sophisticated than they were average consumer to install and operate properly. So, in even five years ago. They’re a science and an art today, Orange County, Florida, we’re working to get an amendand there really are no water systems in this country that ment to require a working rain sensor. have tapped every opportunity for conservation and effiIWR: Should we require rain sensors in New England? ciency. System leakage is still a common problem in New Vickers: Yes, working ones. Actually, I think we need to England and across the country. And many systems still step back on that issue. We need to be discouraging peodon’t report accurately their true water losses. We need a ple and developers from installing automatic irrigation fuller accounting of how well, or not well, water is mansystems at all, because that is where the problem starts. A aged before we put the seal of approval on desalination person standing in their front yard with a hose is generas our only remaining choice. ally an efficient irrigation system. They don’t use a lot IWR: What about water reuse, that is, reclaiming wasteof water. If everyone watered like that, we would not be water by treating it so it can be reused for toilet flushing where we are today. The problem is one of a misapplicaand other nonpotable purposes? Is that a viable option tion of technology. These automatic irrigation systems for easing the strain on water supplies? are too powerful and often too poorly designed and too Vickers: We are already seeing sophisticated water difficult to properly install, so they have low distribution recycling systems in the high-tech and pharmaceutiuniformity. There are overlapping sprays, overspray, the cal industries, so they can use water and energy more whole bit. Much of the water, at least half, is wasted. efficiently and to insure a reliable stream of high quality Remember too that healthy turf grass wants to go water. In that regard industrial reuse makes a lot of sense. brown. It wants to go through a dormant phase. That’s But we are also starting to see, in Florida and Texas and part of a healthy plant cycle. the Southwest, the use of reclaimed water for landscape IWR: Is your message sinking in? irrigation. Now, if water conservation is your goal, absoVickers: Yes. The growing public awareness about clilutely it makes sense to reuse water. The problem is that mate change and the limited petroleum reserves at our in practice I think reuse has given people a license to use disposal are making people more aware of water, food, more. If you look at the per capita water use in Orange and other natural resources. County, Florida—and I am doing a study on this right The good news is America is blessed with abunnow—you’ll see it has some very high use levels because dant water resources. But we have a distorted view of its reclaimed water is often underpriced. It is viewed as how much water we need compared with how much unlimited, so there is not an ethic about it. water we’re currently using. If we cut in half the amount If we eliminated water waste and just targeted our of water we’re wasting outdoors, the stories in the media reclaimed water for high usages, such as industry, I don’t that say we’re running out of water would go from the think we’d have to bear the cost of plumbing commufront page to the back page. nities so reclaimed water could be used for irrigation. This is a problem we’ve created. It’s disturbing to I would say we have enough water already, if we really see the damage being done, and we need to stop it. scale back from the waste we now see.

IWR, Winter 2007-08

We Remember Eugene L. “Gene” Dube

Gene Dube was a businessman first and foremost. But his business benefited the environment, by Stephen Hochbrunn, NEIWPCC and you could tell he felt good about that. He enjoyed sharing with others what he’d learned over the s anyone who ever met him would say: years, and he participated as an instructor in several there was nothing pretentious about NEIWPCC workshops on fats, oil, and grease. He was Gene Dube. Nothing artificial, nothing also an instructor in many septage workshops run by forced. In an interview for IWR in the summer Maine’s Joint Environmental Training Coordinating of 2005, he spoke frankly, as to a friend, with a Committee (JETCC), which NEIWPCC has managed rough-edged, natural storytelling grace. He didn’t since 1985. try to charm or impress—there was no need to. When Dube died on April 24, his family lost a His work spoke for itself. husband and a father, and many others lost a friend As president of Pat Jackson, Inc./Tri-City and mentor. If you’re wondering, as we were, about Septic Tank Service in Belgrade, Maine, Dube was Farewell to a Friend Gene Dube, in an IWR photograph taken in his business, it remains intact, with his widow Pauline 2005, admired the compost created by his company, PJI/Tri-City, from an innovator in a field where innovation can have now in the president’s chair. In a phone conversation septage, grease, and pine shavings. a major environmental impact. He was the driving in November, PJI/Tri-City’s dispatcher Sharon Smith force behind the company’s development of a syssaid, “We’re trying to keep the company going, just tem for collecting septage and grease and turning it into compost that can be used the way it was before he passed.” Does she miss him? “I’ve got tears in my eyes right on everything from hay fields to home gardens. In doing so, he solved two problems now, sir.” faced by so many communities—what to do with the septage pumped from septic Dube’s death had that effect on people. You knew someone very real, very tanks, and how to safely dispose of the fats, oil, and grease generated by restaurants, genuine was gone. At NEIWPCC and at JETCC, we miss him too. which if poured down the drain can lead to damaging sanitary sewer overflows.

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What’s It Like Out There?

An Intern (and Aspiring Chemist) Visits a WWTP Lab by Emma Downs

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s a junior at the University of Massachusetts Amherst, majoring in chemistry, I am not yet sure what path my career will take. It is a time for exploring possibilities. One option I hadn’t considered was working in the wastewater treatment industry. But through my internship at NEIWPCC, I’ve been exposed to the wastewater field. And through a visit with Karen Driggers at the Greater Lawrence Sanitary District plant in North Andover, Mass., I got a firsthand look at a fascinating position in the industry. Driggers never planned on working in a wastewater treatment facility. Though she had always worked in the environmental field, wastewater wasn’t a particular interest. Then, in 1991, a friend who worked at the GLSD told her about a job opening at the plant. “The doors were open for me,” Driggers said. She was hired as a lab technician at the GLSD and later promoted to her current position, chief lab technician and instrumental chemist. “It’s fun and exciting work,” she said. “Otherwise I wouldn’t have been here for 17 years.” About 30 percent of Driggers’s duties involve in-house process control, making sure all parts of the plant are doing their jobs. Each day the lab tests levels of bacteria, residual chlorine, total suspended solids, biochemical oxygen demand, and pH. When the results for bacteria exceed the guidelines, the results are reported and appropriate advisories are issued for water users downstream. This happens occasionally, especially during heavy rains. In addition to routine testing, Driggers sometimes gets the chance to try out and even develop new methodology. It’s her favorite part of the job. “I like the challenges,” she said. I watched as she prepared to perform a test made necessary by a new requirement in the plant’s National Pollutant Discharge Elimination System (NPDES) permit, which specifies everything the plant must do in return for being allowed to discharge its treated water into the Merrimack River. The new requirement stipulates that the plant must monitor the total phosphorus levels in its effluent. It’s Driggers’s job to run the monitoring tests and report the results.

On the day of my visit, she was still developing the process. Since she had no idea what phosphorus levels to expect in the effluent, she didn’t know where to set her control samples. As it turned out, the levels in the test samples ended up higher than those in the control samples, so the results were invalid. Tweaking the process to ensure valid results in the future is what Driggers gets paid to do. Another large part of her work is industrial monitoring. Many companies in the five towns served by the GLSD—Andover, Lawrence, Methuen, and North Andover in Massachusetts, and Salem in New Hampshire—pretreat and discharge their own processed wastewater to the plant. Driggers Close Inspection Karen Driggers checks the total phosphorus levels in and others at the GLSD sample this industrial efflu- samples of the Greater Lawrence Sanitary District plant’s effluent. ent for pollutants such as cyanides, oil and grease, “Every day is a different day,” she said. “There’s suspended solids, and heavy metals. The monitored always something to do.” companies include makers of textiles, dairy products, While my visit to the GLSD lab was very interesting, and pharmaceuticals, as well as metal finishers, and only I can’t say it made my career path any clearer. But it did rarely does the sampling process reveal any violation of give me one more entry on my list of possibilities. pollutant limits. When violations do occur, the GLSD quickly informs the responsible party and works to get Emma Downs, a student at the University of Massachusetts the problem resolved cooperatively. Amherst, wrote this article during an internship at For Driggers, working in the wastewater industry NEIWPCC’s Lowell headquarters. means never running out of work to be done.

The Green Corner

Answers by Susy King, NEIWPCC

1. Paper represents what percentage of office waste? D. 70 percent Always use recycled paper. For every ton of recycled paper used instead of non-recycled stock, the electricity saved is enough to power a three-bedroom house for an entire year. For additional waste and energy savings, print and copy on both sides of a page before recycling.

Source: Live Earth (www.liveearth.org/crisis_solutions.php)

2. If one million people shut down their office computers overnight, how many tons of carbon dioxide emissions would be eliminated per year? C. 45,000 tons To further reduce energy use and carbon dioxide emissions during the work day, use your computer’s sleep function instead of a screen saver. It reduces electricity use by 70 percent. 3. Compact fluorescent light bulbs (CFLs) use what fraction of the energy of incandescent light bulbs? B. 1/4 Using CFLs can also reduce lighting costs by 50 percent. It is important to note, however, that CFLs contain mercury and must be disposed of properly. Page 17

IWR, Winter 2007-08

In the Spotlight NEIWPCC’s slate of Commissioners includes a number of new additions including Laurie Burt, Commissioner, Massachusetts Dept. of Environmental Protection; Alexander “Pete” Grannis, Commissioner, New York State Dept. of Environmental Conservation; John Sayles, Deputy Secretary, Vermont Agency of

Natural Resources; John Auerbach, Commissioner, Massachusetts Dept. of Public Health; and Richard Daines, Commissioner, New York State Dept. of Health. Glenn Haas and Sandi Allen will retain their roles at NEIWPCC Executive Committee and Commission meetings as representatives of the MA DEP and

NYSDEC Commissioners, respectively. Dick Svenson will continue to represent the NYSDOH Commissioner. In a related development, Frank Thomas, a non-agency NEIWPCC Commissioner from New Hampshire, is retiring as director of public works in Manchester, N.H., effective December 31.

Conference Alerts 3rd Northeast Onsite Wastewater Treatment Short Course and Equipment Exhibition March 11 – 13, Mystic Marriott Hotel and Spa, Groton, Connecticut The anticipation is building for the third edition of this event, which brings national experts to our region to lead educational sessions on the latest developments in the onsite wastewater treatment industry. Through field trips and the equipment exhibition, attendees also see firsthand the innovative technologies that are changing the way water resources are protected. The topics for the 2008 sessions are diverse, ranging from the “Benefits and Limitations of Test Center Data” to “Troubleshooting Nitrification.” Two prominent experts in the field—Richard J. Otis of Otis Environmental Consultants and George Tchobanoglous, professor emeritus at the University of California at Davis—will deliver keynote addresses. The Northeast Onsite Short Course is held every three years and, as NEIWPCC did in 2002 and 2005, we are coordinating all logistics, including developing and maintaining the conference website. For more information, including registration details, visit the site at www.neiwpcc.org/onsiteshortcourse.

20th Annual National Tanks Conference and Exposition March 17 – 19, Sheraton Atlanta Hotel, Atlanta, Georgia Produced annually by NEIWPCC in conjunction with EPA’s Office of Underground Storage Tanks and the Association of State and Territorial Solid Waste Management Officials, this event provides the underground storage tanks community with a unique learning and networking experience. In 2008, our cosponsor and host is the Environmental Protection Division of the Georgia Department of Natural Resources. As usual, the conference will focus on a wide range of tanks-related issues, with the overall intent being to find new and better ways to work together to protect human health and the environment from tank releases. Three ­concurrent session tracks will be offered—Contamination and Cleanup, Prevention, and Policy—along with a number of outstanding workshops and visits to two impressive brownfield redevelopment projects. The Expo will feature booths from states, tribes, and federal agencies, as well as vendors displaying the latest tanks-related products and services. More information, including online registration, is available at www.neiwpcc.org/tanksconference.

19th Annual Nonpoint Source Pollution Conference May 19 – 21, Mystic Marriott Hotel and Spa, Groton, Connecticut The theme of the 2008 NPS conference is “Progress Through Partnerships: Collaborating to Protect Our Watersheds,” and it is our privilege to once again cosponsor this important annual event. Since 1990, NEIWPCC, in partnership with the NPS programs of the New England states, New York State, and EPA Regions I and II, has been coordinating the NPS Conference, which has grown into the premier forum in our region for sharing information and improving communication on NPS pollution issues and projects. The three-day conference brings together all those in New England and New York State involved in NPS pollution management, including participants from state, federal, and municipal governments, private sector, academia, and watershed organizations. The Connecticut Department of Environmental Protection is our cosponsor for this year’s conference, which will feature presentations, discussions, and field trips, as well as a full-day Stormwater Funding and Utility Development Workshop taught by Andrew Reese, PE, and Charlene Johnston of AMEC Earth and Environmental. More ­information is available at www.neiwpcc.org/npsconference.

17th Annual State Fund Administrators Meeting June 8 – 11, Francis Marion Hotel, Charleston, South Carolina NEIWPCC is once again playing a key role in planning this event, which we have cosponsored since 1992. The conference focuses on issues of interest to state fund administrators, who manage state funds generated by gasoline taxes earmarked for covering the costs of cleaning up leaks and spills at underground storage tank sites. Conference planning team members are meeting in January to develop the agenda and coordinate plans for the Charleston event. As more information becomes available, it will be posted on the conference website at www.neiwpcc.org/statefund.

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IWR, Winter 2007-08

In the Spotlight continued After serving for many years as Executive Director of Minnesota’s Petroleum Tank Release Cleanup Fund, Jim Pearson has joined NEIWPCC as our Director of Drinking Water and Underground Storage Tanks Programs. This is the first time that we have placed the drinking water and tanks programs under one person, and it’s not a light load. Pearson will plan and facilitate meetings of our various workgroups in these arenas, manage multiple projects including the creation of guidance documents, and support state and federal staff on the development and implementation of programs and regulations. He’ll do everything from coordinating regional comments on federal policy initiatives to overseeing preparations for such events as the National Tanks Conference. Pearson should be served well by his vast experience in state government in Minnesota, where he established a reputation for successfully building consensus around tough policy issues. His achievements included designing and implementing a statewide abandoned UST removal program that led to the removal of over 100 tanks. Pearson can be reached at 978-323-7929 ext. 233 or via email at [email protected].

NEIWPCC’s Tom Groves, our Director of Wastewater and Onsite Programs, had the honor of being invited to speak at Italy’s First National Workshop on Decentralized Systems, held in Venice on October 3-5. The conference attracted speakers from all over the world, including Japan and Australia. Groves appears sixth from left in the photo below, which was taken at the conference. He spoke about the management of decentralized systems in the United States.

New from NEIWPCC

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n November, NEIWPCC released a new and entirely revamped version of our Resource Catalog. It features short descriptions and ordering instructions for a vast array of publications, CDs, videos, and other resources available from NEIWPCC, most of which we developed. The materials listed are diverse, ranging from complex operations guides to curriculum supplements. They can be used by a wide variety of audiences, www.neiwpcc.o including environmental professionals, government rg agencies, water and wastewater treatment facilities, schools, and the public. We plan to produce a very limited number of hard copies of the catalog, which will primarily be used as a display piece at our booth at conferences and other events. If you would like to order a hard copy, contact NEIWPCC at 978-323-7929. You may also download the catalog from the Publications and Resources section of our website (www.neiwpcc.org/publications.asp) or simply browse that section itself, which is being revised to mirror the structure and content of the printed catalog. New Eng lan d

Inte rsta

te Wat er Poll 116 John Stree utio n Con trol t, Lowell, MA 0185 2-1124 Tel: 978/3 23-7929 Fax: 978/3 23-79

Com mis sion

19 mail@neiw pcc.org

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n behalf of New Hampshire’s Department of Environmental Services, NEIWPCC staff wrote and designed a guide that provides transient non-community water supplies (gas stations, restaurants, etc.) with basic information on operating a system and meeting state and federal Safe Drinking Water Act requirements. While the guide was developed for a New Hampshire audience, the information can certainly be helpful to readers elsewhere in the region. It too can be downloaded from the Publications and Resources section of our website. NEIWPCC is currently developing a similar publication for regional use that will provide guidance specifically targeted at owners and operators of gas stations that have their own water supply. As with the NH DES guide, it will explain drinking water regulations and provide instructions on how to comply with them. Publication is expected in early 2008.

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GOVERNMENT AGENCY Kerry Strout, a NEIWPCC Environmental Analyst and coordinator of all our wetlands programs, has been named a non-voting member of the board of the Association of State Wetland Managers. Strout is the only board member representing a region rather than a state. Also on the board are NH DES’s Collis Adams and VT DEC’s Alan Quackenbush, both of whom are members of NEIWPCC’s Wetlands Workgroup, which Strout coordinates.

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calendar of Events Please note that NEIWPCC workgroup meetings are designed to foster focused small-group discussions among workgroup members on specific issues. Workgroup members are drawn from state and federal regulatory agencies and NEIWPCC staff. For general ­information about our workgroups and their points of focus, please visit our website (www.neiwpcc.org) or call 978-323-7929.

January

February

March

State Fund Administrators Planning Team Meeting January 10 – 11 Charleston, S.C.

NYWEA 80th Annual Meeting and Exhibition February 4 – 6 New York, N.Y.

ASIWPCA Mid-Year Meeting March 2 – 4 Arlington, Va.

9th Annual Northeast Aquatic Plant Management Society Conference January 14 – 16 West Dover, Vt.

NACWA’s 2008 Winter Conference February 5 – 8 Phoenix, Ariz.

10th Annual State Onsite Regulators Alliance Conference March 3 – 6 Point Clear, Ala.

NEIWPCC Drinking Water Administrators Workgroup Meeting January 17 NEIWPCC Executive Committee and Commission Meeting January 17 – 18 ASDWA Security Meeting January 22 – 25 New Orleans, La.

NEIWPCC Wetlands Workgroup Meeting February 6 Sustainable Water Sources: Conservation and Resources Planning (AWWA Specialty Conference) February 10 – 13 Reno, Nev. The Utility Management Conference 2008 (WEF/AWWA Specialty Conference) February 24 – 27 Tampa, Fla.

NEIWPCC Stormwater Workgroup Meeting January 23 NEIWPCC Nonpoint Source Workgroup Meeting January 24 Membrane Technology 2008 (WEF Specialty Conference) January 27 – 30 Atlanta, Ga. 2008 NEWEA Annual Conference and Exhibition January 27 – 30 Boston, Mass.

Check the NEIWPCC 24-Hour Training and Events Hotline for the latest information on NEIWPCC activities, such as cancellations due to ­weather or instructor illness, and date or location changes. Call 1-866-824-9656.

3rd Northeast Onsite Wastewater Treatment Short Course and Equipment Exhibition March 11 – 13 Groton, Conn. 2008 ASDWA Member Meeting March 12 – 14 Annapolis, Md. NEIWPCC Executive Committee Meeting March 13 20th Annual National Tanks Conference and Expo March 17 – 19 Atlanta, Ga. 2008 AWRA Spring Specialty Conference: GIS and Water Resources V March 17 – 19 San Mateo, Calif. Annual Conference of the New England Association of Environmental Biologists (NEAEB) March 26 – 28 Bartlett, N.H. Residuals and Biosolids 2008 (WEF Specialty Conference) March 30 – April 2 Philadelphia, Pa.

To check for additions or changes to these listings, and to access links to conference websites, see the Calendar at NEIWPCC’s website (www.neiwpcc.org/calendar.asp). Contributions to IWR are welcome and appreciated. Please submit articles or story ideas to: Stephen Hochbrunn, IWR Editor E-mail: [email protected] ◆ Phone: 978-323-7929, ext. 235

New England Interstate Water Pollution Control Commission 116 John Street Lowell, MA 01852-1124 Address service requested.