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Managing NPDES Permit Challenges in Massachusetts Fish Hatcheries

This report details the recent NPDES permit renewals for four Massachusetts Division of Fisheries and Wildlife trout hatcheries: Sandwich, Sunderland, Palmer, and Montague. It provides insights into the impact of effluent sampling and formalin use on hatchery operations, highlighting reduced production capabilities, changes in operations, and the critical nature of maintaining compliance with discharge limits. The report emphasizes the necessity for effective relationships with regulatory bodies and ongoing development of Best Management Practices to adapt to new environmental standards.

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Managing NPDES Permit Challenges in Massachusetts Fish Hatcheries

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  1. MDFW Hatchery NPDES ProgramKen SimmonsChief of Hatcheries/Trout Project Leader

  2. MDFW HATCHERIES • Sandwich Hatchery (1912) -Trout* • Sunderland Hatchery (1913) - Trout* • Palmer Hatchery (1914) - Atlantic salmon • Montague Hatchery (1917) - Trout* • McLaughlin Hatchery (1969) - Trout* *NPDES permit required

  3. NPDESFour MDFW Trout Hatchery Permits Renewed in Past Year • Observations on the process • Formalin Discuss Today

  4. Impact on Hatchery Operations • Discharge limits were not substantially changed • Frequency of effluent sampling was reduced • Effluent sampling quarterly and only during major cleaning operations continued

  5. Impact on Hatchery Operations • Increased use of settling pools at 3 older DFW facilities • Reduced production at 3 older facilities • Greatly altered operations at 3 older facilities • Formalin use all but eliminated at 3 older facilities

  6. Impact on Pounds of Trout Produced

  7. Flow BOD TSS pH Dissolved oxygen Total ammonia nitrogen, as N* Residual chlorine* Total phosphorous* Formaldehyde Whole Effluent Toxicity - chronic** Whole Effluent Toxicity - acute** Effluent Monitoring *Not at all facilities **New to current permit

  8. Effluent Sampling • Quarterly (except pH, formalin & chlorine) • Three of the quarterly samples must be taken when conducting pool breakdown and/or settling pool or quiescent zone cleaning • One quarterly sample must be taken during annual pool breakdown/cleaning • Composite samples -- 1 per hour for 8 hours

  9. Formalin Use • Discharge limit of 0.74 mg/l (formaldehyde) at all facilities • Developed formalin use plan for each hatchery as part of B.M. P. • Do not know if it will work except at McLaughlin Hatchery

  10. Formalin Use Problems • 0.74 mg/l limit effectively eliminates use at 3 of 4 facilities due to flow patterns and dilution factors • Difficult to retain a certified lab that can analyze formaldehyde with E.P.A. methods on short notice • W.E.T. tests - labs to conduct work on short notice • Cost of tests

  11. Whole Effluent Toxicity (%) Acute (invertebrates only) *If formalin is used

  12. Whole Effluent Toxicity (%) Chronic (invertebrates only) *If formalin is used

  13. Agency must play an active role in the process Develop & maintain a professional working relationship with the regulators Be honest and forthcoming with information Do not hesitate to ask questions or seek clarification of issues Exercise your right to seek change and/or clarification of pre-public draft permits Tremendous amount of work involved My Thoughts

  14. Summary • We do not yet know if we will be able to meet new effluent limits at all stations but have developed BMP’s with that goal • Formalin use at 3 of 4 hatcheries is all but impossible • Formalin use at McLaughlin Hatchery is feasible but with constraints

  15. FLOW (MGD)

  16. BOD (mg/l) *During cleaning operations

  17. TSS (mg/l) *During cleaning operations

  18. Total Phosphorous (mg/l) *During cleaning operations ***No limit issued

  19. Total Ammonia Nitrogen, as N (mg/l) *During cleaning operations ***No limit issued

  20. Total Residual Chlorine (ug/l)

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