For: Scott W. Jellison, Chief Executive Officer, The Metropolitan District Commission, Hartford, Connecticut
From : Rivers Alliance of Connecticut
Thank you for the opportunity to comment on the MDC Long Term Control Plan (LTCP) Draft Update for control of its combined sewer overflows (CSOs). The mission of Rivers Alliance is to protect the health of all state waters. For 25 years, we have advocated directly or through our Board for cessation of the sewage spills from the MDC system. We appreciate that you have made progress, and urge you to pick up the pace.
The 2006 Consent Decree from the EPA and the CT DEP was long overdue. The schedule for remedial action was reasonable, and the state has responded positively to the MDC’s requests for help with the costs of the project. Nevertheless, the MDC is now proposing a dramatic slowdown in meeting the terms of the Consent Decree and the diversion of resources to other projects. It appears that the MDC wants to change the deadline for completion from 2029 to 2058. That’s another whole generation of people who will be exposed to raw sewage.
The MDC should proceed on the schedule for CSO work that it has agreed to. We oppose further delay. We support the points made by our expert colleagues at Connecticut Fund for the Environment/Save the Sound and at the Connecticut River Conservancy, and will not repeat them here. I am sure that we all agree to the overarching principle that it a basic social responsibility of individuals and communities not to subject their neighbors to raw sewage. Sewage treatment is expensive, for households as well as municipalities But it is not an obligation one can put off without serious consequences. Exposure to raw sewage is disgusting and dangerous. It is obviously harmful to human health. It is even more harmful (though less obviously) to aquatic life.
I’ve read comments sent you by the Jorgensen family on the North Branch of the Park River. Connecticut residents should not have put up with the constant close encounters with river sewage that they describe. Many MDC customers and visitors to the region praise the excellent quality of your drinking water. The same high professional standards should be applied in the wastewater side of your business. Those standards include, in our view, staying on schedule.
Thank you for your consideration.
Margaret Miner, Executive Director, Rivers Alliance of Connecticut
7 West Street, POB 1797
Litchfield, CT 06759
MDC Proposes Delayed Elimination of Combined Sewer Overflows
The Metropolitan District Commission (MDC) held a public hearing Dec 11 on it's proposal to modify it's 2014 agreement to eliminate combined sewer overflows (CSOs) by 2034 using a massive tunnel system under Hartford. MDC wants instead to separate the sanitary sewers from the stormwater drains in the north end of the city and put off building part of the tunnel system until well beyond 2034. It calls its plan their Clean Water Project.
In a 2017 letter to MDC, the CT Department of Energy and Environmental Protection (DEEP) reiterated the need to eliminate CSOs. Here's an excerpt:
"For the past eleven years, DEEP has worked with MDC in order to meet the changing needs of the Clean Water Project. DEEP modified Consent Order WC5434 and supported revisions to the LTCP that resulted in more cost-effective ways to meet the environmental goals. DEEP agreed to schedule modifications in the CO to extend compliance deadlines by eight years. DEEP agreed to merge the solution to salutary sewer overflows and CSOs into the South Hartford Conveyance and Storage Tunnel (SHCST) and provided a very favorable grant award for this project. To date, DEEP has provided $1.2B in financing to support MDC’s two funding authorizations of $1.6B, or 75% of project funding with CWF participation."
"DEEP intends to continue to work with MDC in implementing the approved LTCP and LTCP Updates as we move forward. We recognize future updates may include additional alternatives analyses evaluating means of keeping this project as cost-effective as possible. However, the standards of elimination of CSO’s tributary to the North Branch Park River and Wethersfield Cove and control of CSO to the one-year level, established in Consent Order WC5434, shall not change."
The deadline to submit public comments is December 13, 2018 at 6:00pm and may be submitted to the District Clerk via email at DistrictClerk@themdc.com or via mail at: The Metropolitan District 555 Main Street Hartford, CT 06103 Attn: District Clerk
The sewage spill Right To Know law was modified last legislative session, and improvements to the system continue to be implemented. Click here to go to the DEEP webpage that opens to a map of reported sewage spills that do not have a date the spill ended entered into the online system. You have to click on various tabs to make your own map showing archived spills to see all of them, then you can sort a table to find recent ones.
As an example of the information now available, here is our map of all reported sewage spills in towns along the Naugatuck River since those towns began using the electronic system. Note some reports have incorrect reported latitude or longitude that makes the symbol appear in the wrong location on the map. We are assured these errors will be fixed eventually.
Because spills are often in the same location, you have to zoom into a particular town, then click on a symbol to get details. For example, clicking on a symbol near Waterbury's treatment plant pops up a box that says "1 of 5", then you can click on the arrow to see the next description.
Click the >>>> symbol to see some controls for turning features on or off, click the >> mark next to the feature to see the symbol for that feature. double-click on the map away from a symbol to zoom in. Click on a symbol for a pop-up box with more information.
Below is a map made from CT Department of Energy and Environmental Protection (DEEP) data that shows sewage spills reported to CT DEEP during the storms of Oct 1-3, 2018. If no town names and location symbols appear at first, try refreshing the page. You can zoom in by double-clicking between symbols. If you click on a symbol and the pop-up box is too small to read, try the "enlarge" button in the upper right of the box.
If you click the link above or below the map, it should open a new, larger page that can be zoomed, adjusted for better viewing, and clicked on for more information.
Heavy rainfall that gets into sewage treatment systems through damaged pipes, leaky manhole covers, illegal connections from storm drains, and other ways, often causes sewage to overflow at treatment plants or from manholes, or to back up into the basements of homes and businesses. Most sewage treatment systems now report these "bypasses" to the CT DEEP, and then they are mapped out on DEEP's Sewage Right To Know website.
The DEEP sewage mapping system is still under development. If you are concerned about unreported sewage spills into a particular river, call your local treatment plant.
Also, there are places in Connecticut where the storm drains and the sewage pipes are combined into one system. With high rainfall, many of these combined pipes are designed to overflow into rivers and streams so the wastewater treatment plants are not overwhelmed. The DEEP has a map of Combined Sewer Overflows that shows the six urban areas where these can occur. Zoom in to any of them to see exactly where the combined flow may enter streams and rivers. Not every rain event is enough to cause these overflows, but it's a good idea to avoid contact with the water downstream of them after significant rain until you can confirm if there were any sewage spills.
Sep 9, 2018
MDC and DEEP in Ongoing Discussions Re Landfill
The Metropolitan District Commission (the Hartford–based regional water utility) has backed off its threat to cease working with the Department of Energy and Environmental Protection for the disposal of wastewater from the Hartford Landfill. For now, the two parties are discussing the issue. Here’s how the Courant article on the outbreak of peace negotiations. http://www.courant.com/news/connecticut/hc-news-mdc-deep-sewer-vote-20180905-story.html
July 31, 2018
MDC Threatens to End Landfill Discharge Sept. 1 if CT DEEP Doesn’t Pay Disputed Sewer Fees
Is CT DEEP discharging pollutants from the now-closed Hartford Landfill into the sewer system operated by the Metropolitan District Commission? The MDC says yes, a position DEEP vigorously opposes. A three-year dispute over this issue has recently culminated in MDC’s issuing an ultimatum to DEEP: As of Sept. 1, MDC will terminate the discharge into its system unless DEEP either finds an alternative to using MDC’s system or pays the outstanding sewer fees of nearly $6 million that MDC claims DEEP owes.
Before mid-2016, MDC had charged DEEP the normal rate for “ordinary domestic sanitary sewage.” But the commission claims that testing of the discharge revealed the presence of ammonia-nitrogen, and subsequently began charging the much higher rate for discharges requiring remediation. As a result, DEEP’s bill for the discharges rose from roughly $10,000 a month to nearly $270,000 month – a 27-fold increase, which DEEP Commissioner Robert Klee called “unconscionable.”
DEEP insists that the discharge is “environmentally appropriate,” according to a July 9, 2018, letter Commissioner Klee sent to MDC Chairman William DiBella. Commissioner Klee also said the nature of the discharge has not changed since MDC assumed responsibility from the former Connecticut Resources Recovery Authority for the Hartford Landfill discharge into its water pollution control facility. Consequently, DEEP refuses to pay the increased fee.
Several years ago, the state legislature turned legal obligations and control over the Hartford Landfill to DEEP.
Sewage Spills in CT Reported Electronically
in the Last Three Days
(refresh to see updated map)
This is an experimental map based on information available publicly from a file automatically updated by the GIS people at the CT Department of Energy and Environmental Protection. Please keep in mind that not all facilities and treatment systems report electronically, and this data has not been verified by either DEEP or Rivers Alliance. Also shown are public water supply watersheds in blue and aquifer protection zones in red. Click the >>>> symbol to see the legend and some controls for turning features on or off.
(Note that after this article was written, the Litchfield Water Pollution Control Facility reported a raw sewage bypass during the major rain event 1/23/2018 from a manhole near Tapping Reeves condominiums at 354 Bantam Rd, Litchfield. They estimated from 1,001 to 5,000 gallons of raw sewage entered Moulthtop Brook because of "Line Blockage - Grease." Moulthrop Brook leads to Little Pond and the Bantam River upstream from Bantam Lake. They note that a resident noticed an odor on Monday, Jan. 22, 2018 and they contacted the sewer department on Tuesday, Jan. 23. The estimated amount of sewage that leaked was based on visual observations at the time of the repair and the length of time that had passed since the odor was first noticed. Also that day leaks of 501 to 1,000 gallons were reported by Norwalk, and 51 to 500 gallons were reported by Meriden.)
Force main sewer lines are a topic of attention here in CT partly because a new force main is being proposed by the Woodridge Lake Sewer District to fix problems with their treatment plant in Goshen by pumping their sewage to an existing sanitary sewer line on the west side of Torrington. Part of that force main would pass through a portion of the watershed of one of Torrington Water Company's reservoirs. Woodridge Lake Sewer District insists that leaks (such as Nantucket's) are very unlikely. The City of Torrington has scheduled a Jan. 31 presentation and a Feb. 20 hearing on the Woodridge Lake Sewer Discharge Permit.
What information is available about the frequency of sanitary sewer failure in Connecticut?
According to DEEP’s Bypass and CSO Events Public Viewer, since September 2016 from 116,993 to 641,250 gallons of sewage spilled into our waterways from places in public wastewater systems other than at the treatment plants and were not connected with rain or snowmelt. Here’s the breakdown:
5,262 to 12,600 gallons spilled from 13 incidents reported on Sewer Mains caused by Mechanical Equipment Failure (1 incident) Sewer Line Blockage – Other (4 incidents) or Unknown (8 incidences).
111,731 to 628,650 gallons spilled from 32 spills from manholes caused by Mechanical Equipment Failure (2 spills), Sewer Line Blockage – Grease (14 spills), Sewer Line Blockage – Other (11 spills), Sewer Line Blockage – Roots (3 spills), Unknown (2 spills).
A 5-million gallon spill from the Waterbury wastewater treatment plant on October 9 made headlines and prompted calls for major improvements in the utility’s emergency response plan. (Click here for that story.)
But the Metropolitan District Commission (MDC) in Hartford put up much more impressive numbers in October. On October 29th and 30th, the overflow of sewage in the MDC Hartford system was 94 million gallons (!) into the three Park River drainage districts; it was 27 million gallons elsewhere in the system. In the MDC West Hartford system, on the same two days, sewage bypasses delivered 1 million gallons into Piper Brook and 1.37 million gallons into Trout Brook.
Note, MDC Combined Sewage Overflows are common, and this utility declines to file its reports electronically, preferring the older paper filing (and less timely public notice). MDC is building a giant tunnel and holding tank system it calls The Clean Water Project to address the problems that occur when it rains in Hartford.
Want the raw (sewage) data? Click the following links for:
Sewage in our rivers has been in the news recently because of the big spills in October, especially from the Waterbury system and from the Metropolitan District Commission systems in Hartford and West Hartford. These events are more common than most people realize. They average about one a day, but they cluster around heavy rainfalls and around a minority of plants. Still, annual totals run to hundreds of millions of gallons of untreated or partially treated sewage going into state waters each year.
Following passage of a Sewage Right to Know law in 2012, the CT Department of Energy and Environmental Protection (DEEP) has taken several steps to try to post online more-timely information for the public. Unfortunately, the maps and data are confusing to access and are often incomplete or incorrect. DEEP is working daily to improve this reporting. Some matters are beyond their control. For example, the DEEP website postings only use data reported electronically. But a significant number of treatment plants do not report electronically. Most notable are plants owned by the Metropolitan District Commission, the giant Hartford area utility (see our report above).
We at Rivers Alliance will be happy to answer questions you may have. Here follows some basic information on state reporting of sewage spills. But if you can’t find what you want or the answer looks off-target, calls us at 860-361-9349; ask for Tony.
Types of sewage spills:
DEEP lists spills of untreated sewage into our state's waters under two categories: "Bypass Events" and "Combined Sewer Overflows (CSOs)." At the DEEP website, both categories must be searched for total spill volumes because DEEP rarely combines the lists.
Connecticut has been working with considerable success to eliminate CSOs, but several large cities still have them.
Bypass Events are basically spills of any kind other than those happening through a CSO structure. A bypass spill usually happens when a wastewater control facility directs sewage past its treatment system directly into a receiving water. The reason for the bypass may be a problem with the plant operation. Often, however, the reason for the bypass is flawed old infrastructure that allows stormwater to infiltrate the wastewater pipes and pumping systems. For example, a heavy rainfall into saturated ground will force water into any leaky pipe that is in the ground; water can also enter through cracked or ill-fitted manhole covers. As a result, more water arrives at pump stations and treatment plants than the equipment can handle. Leaks elsewhere in the sanitary sewer system also get listed as Bypass Events.
A completely tight, non-CSO system should not be affected by stormwater and should not have routine bypass events.
This page has two tabs. One is supposed to show only “active” events, that, is recent spills. This map is somewhat useful but presently incomplete because for various reason data reports may not reach the site and because the MDC and a few other utilities do not report their data electronically. Also, some old events may still be listed. Click here for a list of utilities that DO report their spills electronically.
The second tab is for all events since the site was launched. It is potentially useful to study individual facilities and for similar research. But it is complicated, with glitches; it is also incomplete because many treatment plants to not file reports electronically yet. If you have difficulty finding what you are looking for, contact Ann Straut at DEEP (email@example.com) or Tony Mitchell at Rivers Alliance (firstname.lastname@example.org).
Rivers Alliance Executive Director Margaret Miner was recently interviewed (and photographed) for an investigative story in the Republican-American newspaper that appeared as the front page top headline on Sunday, Nov 19, 2017. Click here for the article summary on their website. Reading the full article may require a subscription to their newspaper.
The Republican-American has been dogged in their pursuit of information regarding Waterbury's regional treatment facility, which treats wastewater from several surrounding towns and accepts sewage sludge from a large portion of the state. Details of the 5 million gallon spill was available in the print version of the paper long before there was any public notice by government agencies.
As part of the Republican-American's investigations, they looked the state's website for reporting sewage overflows for others that have occurred in the area. Rivers Alliance was contacted regarding 9 Bantam River sewage events in Litchfield that spilled an estimated 1,450,058 to 2,300,500 gallons of untreated sewage from April through October, plus an unknown amount during a five-day problem in May. See below for our guide to using the state's webpage to search for reported sewage spills.
A search for "sewage" on the Republican-American website reveals their comprehensive coverage.
Reading these articles may require a subscription to the newspaper.
Consent Order CO WRMU 17003 was issued to the City of Waterbury by the state Department of Energy and Environmental Protection (DEEP) that specifies a cleanup schedule, procedures to implement in the future, restocking of fish in the river, and
"On or before May 12, 2018, the Respondent shall, in coordination with the Fisheries Division of the CT DEEP, sponsor a family fishing day along the Naugatuck River"
Five-Million-Gallon Sewage Spill in Naugatuck River
Recent rains have increased flow in the Naugatuck River, but bacteria levels are not expected to fall by much because runoff itself contributes bacteria to rivers and streams. Bacteria levels are often high for 48 hours after heavy rain, and some parts of the Naugatuck River watershed north of Waterbury received over two inches of rain Oct 24-25.
On October 9, Waterbury's wastewater treatment plant lost power resulting in a release of untreated and partially treated sewage into the river. This major spill (into a low-flowing river) received little attention. The Waterbury Republican-American newspaper has been reporting the problem regularly, but the best non-subscription news source we have found so far is an article from the Waterbury Observer Oct 23. Best Facebook coverage so far is from the Naugatuck River Revival Group and Waterbury Observer. On October 20, the Department of Energy and Environmental Protection (DEEP) advised us that bacteria counts were still high, and people should avoid contact with the river water.
Here's what has been reported. On Monday, October 9, a live wire was cut in a construction site at the City of Waterbury's wastewater treatment plant, which caused the entire plant to lose power. The company that cut the wire could not work on restoring power while plant mangers were trying to start the backup generator. The Waterbury-Republican article stated that "hours later" the plant had to start putting untreated sewage into the Naugatuck River at a rate of 1 million gallons per hour until power was restored five hours later. The article further stated that on Wednesday, Oct 11, DEEP reported it did not know why dozens of fish turned up dead downstream of the treatment plant, in the City of Naugatuck. On October 13, Waterbury's Public Health Department put up three signs advising no swimming or other contact with river water after tests showed elevated bacteria levels. On October 18, additional tests showed bacteria levels remained high.
Kevin Zak of the Naugatuck River Revival Group reported to Rivers Alliance on October 23 that two of the signs were damaged. Rivers Alliance estimated that on October 9, the day of the spill, the flow in the river below the treatment plant was approximately 30 to 40 percent sewage.