Well 3A New Source

May 13, 2015
Matthew Beaton, Secretary
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114
Attn: Purvi Patel, MEPA Office
Environmental Notification Form, Well3A New Source Replacement Well, Norfolk, MA,
EOEEA No. 5360
Dear Secretary Beaton:
The Charles River Watershed Association (CRWA) submits the following comments on the Environmental
Notification Form for the above project.
Well #3A, while not increasing the total authorized withdrawal for MCI Norfolk (0.49 mgd), requires new
source approval and a new or amended Water Management Act permit.1 Accordingly, it will, contrary to the
statement on p. 1 of the ENF, require a DEP permit. It is subject to the recently promulgated revisions to the
Water Management Act regulations. It would have been helpful if the ENF had included a map with the
location of the existing MCI wells in relation to well 3A.
Well 3A is located in subbasin 21134, classified as Groundwater Withdrawal Category 4 (25-55% August
percent alteration in flow) and Biological Category 5 (greater than 65% fluvial fish alteration) under the
streamflow criteria in the new regulations. The net groundwater depletion for this subbasin is 25%, which
under the new regulations requires minimization of the impacts of the withdrawal “to the greatest extent
feasible.” See 310 CMR 36.22(5). The proponent should analyze potential minimization measures. We do
not know based on the information in the ENF whether the “baseline” withdrawal for MCI Norfolk is
exceeded or indeed, whether the mitigation requirement in the regulations would be triggered.
The draft Zone II delineation provided by the proponent includes the Stony Brook drainage and extends to
the Stop River, a tributary to the Charles which suffers from low flow in the summer. We have concerns
about the validity of the pump test given the extensive alteration of the area by the Mosquito Control
Program shortly before the pump test. As the proponent acknowledges, this “affected the hydrology of the
area considerably.” Appendix C at 2-1.
Please feel free to call me if you have any questions at 781-788-0007 ext. 234.
According to the proponent’s consultant, the project is not being permitted as a “replacement well.”
Charles River Watershed Association
190 Park Road Weston, MA 02493
t 781 788 0007
f 781 788 0057
e [email protected]
Margaret Van Deusen
Deputy Director and General Counsel
Kevin MacKinnon
Duane Levangie
Charles River Watershed Association
190 Park Road Weston, MA 02493
t 781 788 0007
f 781 788 0057
e [email protected]