Outfall of Brockton Wastewater Treatment Plant
The City of Brocktons waste water treatment plant is situated on the Salisbury Plain River off Oak Hill way near the West Bridgewater town line. It discharges an average of twenty one and a half million gallons of effluent per day into the Salisbury Plain River. Peak flows from the plant sometimes reach seventy million gallons per day. The plant is designed to handle an average daily flow of eighteen million gallons per day, and peak flows of fifty million gallons per day. At a recent public meeting on the proposed update to this facility the senior engineer from the cities engineering firm Camp Dresser & McKee said there are "significant violations" of the U.S. Clean Water Act at the Plant. What does that statement tell us?
The original plant was constructed in the 1960's. It was upgraded in the 1970's and again in the 1980's. Not long after the major upgrade to the plant in the 1980's the city in 1988 entered into a consent decree with the Ma Department of Environmental Protection and the EPA. This consent decree is an admission by the city that they are violating their discharge permit, however it does not require them to fix the problems. The consent decree is somewhat similar to a chapter 11 bankruptcy filing. In that it allows the plant to keep operating in violation of its permit while politicians, lawyers and regulatory agencies argue about what to do about it. In the mean time the rivers continue to be polluted. Since this consent decree in 1988 the city has often been operating their plant in violation of their discharge permit. In 1999 the city was issued a new discharge permit which was somewhat more stringent than their previous one. In November of 2001 the MA DEP issued a Notice of Non-Compliance to the city. This means that the talk has stopped and the city must clean up its act or suffer the consequences.
The cities response to this notice was to hire the engineering firm Camp Dresser & McKee to design an update to the plant. In May of 2002 the draft report on the proposed update to the plant came out for public comment. Although many improvements were included in the update at an estimated cost of fifty two million dollars, many others were not.
The update is flawed in that it is based on the requirements of the current discharge permit which was issued in 1999 and expires in September of 2003. These discharge permits are issued in three year cycles by the EPA and are referred to as National Pollution Discharge Elimination System Permit or NPDES.
The EPA has indicated to the city both in it's 1999 permit and in a recent letter that the next NPDES permit to be issued in 2004 will have far more stringent limits on phosphorus and nitrogen. The proposed update to the plant can not meet these limits. The update would require additional treatment processes to meet these limits.
If the city fails to address these issues and goes ahead with this proposed update (which is not scheduled to be completed until 2008) it will only continue the on going confrontation that has troubled this plant for the past twenty odd years. More importantly (because sometimes we lose sight of this) our rivers from the Salisbury Plain on down to Mount Hope Bay will continue to be fowled by this plants discharge.
It has been a source of frustration for us that communities down stream from the plant have not taken an active role in this process. For all practical purposes the City of Brockton has turned the Salisbury Plain and Matfield Rivers into open pipelines or sluice ways for their liquid waste. Because of this about eight miles of a once diverse and beautiful river system in the towns of West Bridgewater, East Bridgewater and Bridgewater have been made unusable for recreation. As we have said in other parts of this web site the negative effects of this plant also impact communities all the way to Mount Hope Bay.
Unlike a pipe line the city pays nothing to use these rivers as sluiceways to dispose of their liquid waste. There were no construction costs. There is no maintenance cost or taxes to pay on this sluiceway. Neither does the city suffer the ill effects of the plants outfall, because the plant is on the West Bridgewater town line. If this waste was solid rather than liquid the down stream communities would certainly not tolerate it flowing through their towns. Given these circumstances the one cost and obligation that the City of Brockton does have is to make their liquid waste outflow as clean as possible. The upgrade to the plant as currently proposed by Camp Dresser & McKee and the City of Brockton simply does not do this.
Looking upstream from the plants outfall