THE COMMONWEALTH OF MASSACHUSETTS
WATER RESOURCES COMMISSION
100 C A M B R ID G E S TR EET , B O S TO N MA 02114
REPORT OF THE FINDINGS, JUSTIFICATIONS AND DECISION
OF THE WATER RESOURCES COMMISSION
Relating to the Approval of the
Auburn Water District’s Request for an Interbasin Transfer
Pursuant to M.G.L. Chapter 21 § 8C
DECISION
On April 14, 2022, by a nine to one (9-1) vote, the Water Resources Commission (WRC)
approved, with Conditions, the Auburn Water District’s request for an Interbasin Transfer to
purchase 0.54 million gallons per day (MGD) of water from the City of Worcester. This vote
was taken after review of the facts provided by the applicant, analysis of the associated data, and
consideration of comments received concerning this proposal.
INTRODUCTION
On April 8, 2020, the Massachusetts Water Resources Commission (WRC) received a request from
the Auburn Water District (AWD) for approval of an action to increase the present rate of
interbasin transfer under the Interbasin Transfer Act (ITA) (M.G.L. Chapter 21 §§ 8B-8D) as part of
a Draft Environmental Impact Report (DEIR) submitted to the Massachusetts Environmental Policy
Act (MEPA) office. The DEIR proposed a water supply transfer through a new interconnection to
the City of Worcester’s water system. Additional information was requested by the WRC and
received in the Final EIR, submitted in September 2021. The Secretary’s Certificate on the FEIR
was issued on October 29, 2021. The WRC accepted AWD’s application as complete at its
December 9, 2021 meeting.
AWD is proposing to purchase a maximum of 0.54 MGD of water from Worcester to supplement
its existing groundwater supply sources. AWD’s average day demand (ADD), based on the years
2010 to 2020, has ranged from 0.99 MGD to 1.33 MGD, while the maximum day demand (MDD)
for the same time period has ranged from 1.36 MGD to 2.12 MGD.
This interconnection triggers the ITA because some of Worcester’s sources are located in the
Nashua River Basin. Auburn has land area in the Blackstone and French River basins and
discharges its wastewater to the Upper Blackstone Water Pollution Abatement District
(UBWPAD). Worcester also has sources in the Blackstone River basin, but because Auburn
returns water from these sources back to the basin of origin, the portion of water derived from
Worcester’s Blackstone River basin sources is not jurisdictional under the ITA. Also, since
wastewater from the Town of Auburn and City of Worcester is currently treated at the
UBWPAD and discharged in the Blackstone River Basin, no interbasin transfer of wastewater is
expected due to this water supply transfer from Worcester to Auburn.
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A summary of the facts described in the application is as follows:
1. AWD has its distribution system mainly in the Blackstone River Basin, with a small
portion in the French River Basin.
2. AWD’s existing sources consist of twelve groundwater wells.
3. These wells are vulnerable to contamination due to the proximity of multiple major
roadways. Deicing chemicals and fuel spills are of concern.
4. AWD is proposing to purchase water from the City of Worcester, which has its sources in
the Blackstone River Basin and the Nashua River Basin.
5. Because Worcester has some of its sources in the Blackstone River Basin and the AWD
is in the Blackstone River Basin, only the portion of Worcester’s water supply from the
Nashua River Basin (0.36 MGD, apportioned based on major basin storage) is
jurisdictional under the ITA.
6. A MEPA environmental review, pursuant to M.G.L. c. 30, §§ 61-62I, was required for this
proposed action. The ITA application was submitted as part of the DEIR for this project
(EOEEA #16070). Additional information for ITA review was requested through the
MEPA process and provided in the FEIR.
7. The Secretary’s Certificate on the FEIR was issued on October 29, 2021, stating that no
further MEPA review was needed.
8. Two required public hearings were held virtually via Zoom to take comment on this
application, for the donor basin on January 20, 2022 and for the receiving basin on
January 26, 2022. Written public comments were accepted until February 2, 2022.
9. A Staff Recommendation to approve the request was presented to the WRC on February
10, 2022.
10. A public hearing on the Staff Recommendation was held virtually via Zoom on March 2,
2022. Written public comments were accepted until March 9, 2022.
11. Responses to comments received through the public comment periods are available in a
separate report from the WRC.
EVALUATION OF THE PROPOSED INTERBASIN TRANSFER
This Interbasin Transfer application was reviewed on its own merits and is applicable solely to
AWD’s purchase and use of Worcester’s water supply in the amount of 0.54 MGD. This
Decision is made based on facts contained in AWD’s MEPA submissions and additional
information submitted at the WRC’s request during the MEPA process and during staff review.
The application was evaluated against the seven Criteria outlined in the ITA regulations (313
CMR 4.09), as well as the ITA Performance Standards and with consideration of comments
received from the agencies and through the public comment process.
SYNOPSIS OF THE EVALUATION CRITERIA (313 CMR 4.05)
Criteria Application Meets?
Criterion #1: MEPA Compliance Yes
Criterion #2: Viable In-Basin Sources Yes
Criterion #3: Water Conservation Yes, with conditions
Criterion #4: Forestry Management Not Applicable
Criterion #5: Reasonable Instream Flow Yes
Criterion #6: Impacts of Groundwater Withdrawals Not Applicable
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 Criterion #7: Cumulative Impacts Yes
BASIS FOR THE WRC DECISION
This application was reviewed by Executive Office of Energy and Environmental Affairs (EEA),
WRC staff at the Department of Conservation and Recreation’s (DCR) Office of Water
Resources, Department of Environmental Protection (MassDEP), and Department of Fish and
Game’s (DFG) Division of Fisheries and Wildlife. This Decision was made after an evaluation
of AWD’s application and compliance with the five applicable Criteria of the ITA regulations
and the ITA Performance Standards. The following section describes in detail compliance with
the Criteria.
Figure 1: Auburn Water District’s and City of Worcester’s Sources
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Criterion #1: Compliance with MEPA
An environmental review, pursuant to MEPA (M.G.L. c. 30, §§ 61-62I) and the MEPA regulations,
301 CMR 11.00, was required for this proposed transfer. The ITA application was submitted as
part of the DEIR for this project (EOEEA #16070). The FEIR was submitted in September 2021.
The FEIR Certificate was issued on October 29, 2021 and stated that no further MEPA review was
necessary.
Criterion #2: Viable In-Basin Sources
AWD had to demonstrate that it has made all reasonable efforts to identify and develop all viable
sources in the receiving area. Several studies and reports have been prepared for AWD under
past MassDEP Water Management Act (WMA) Grant projects that discussed and analyzed
alternative water supply sources, both in-basin and out of basin. AWD evaluated several
alternatives to provide additional reliable sources of water, to be used when supplies are offline
for maintenance or potential contamination, during periods of high demand, and to prepare for
future demands. These alternatives included implementing enhanced treatment for existing
sources, activating permitted but currently inactive new water supply sources, and exploring in-
basin/out of town connections. However, none of these alternatives was deemed an acceptable
solution that would provide the capacity needed. Following is a summary of all issues
considered relating to viability.
Existing Sources
The AWD water system includes 12 active drinking water supply wells, three water storage
tanks, and 70 miles of water distribution mains. The majority of AWD’s water supply wells are
vulnerable to potential contamination due to the proximity of numerous major highways (i.e., I-
90, I-290, I-395, SR 20, SR 12). Potential contamination sources include sodium and chloride
loading from winter road salting and fuel spills from frequent accidents. Accidents are most
frequent on I-90. Water supply wells have not yet been directly contaminated from fuel spills,
but each occurrence requires select wells to be taken offline as a precautionary measure
whenever they may be potentially impacted by a spill. Wells may remain offline for weeks to
months at a time pending environmental and water quality testing. The wells are returned to
service once the release extent has been determined and mitigated. For example, Wells No. 1
and 3 were temporarily taken offline in 1999 as a precautionary measure when there was a fuel
spill at the intersection of I-90 and I-290. This spill resulted in fuel reaching Dark Brook, which
is in proximity to the wells. The wells were returned to service after 6 months of water quality
testing performed in the brook and TPH (total petroleum hydrocarbons) levels had returned to
pre-release baseline levels. Additionally, many AWD water supply wells have elevated levels of
sodium and chloride resulting from their proximity to major highways. Ongoing sampling data
shows increasing levels of sodium and chloride that eventually may lead to the loss of these
wells. One well with the highest measured levels of sodium and chloride was taken offline and
is no longer pumped into the distribution system. The loss of this well in conjunction with
frequent fuel spills further stress the AWD’s water supply system by concentrating groundwater
withdrawals among fewer sources.
MassDEP established a drinking water guideline of 20 mg/L for sodium and a Secondary
Maximum Contaminant Level (SMCL) of 250 mg/L for chloride. Most of AWD’s wells
consistently exceed the sodium guideline and Wells No. 1, 2 and 3 exceed the chloride SMCL.
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Additionally, the World Health Organization (WHO) has established a taste threshold for sodium
of 150 mg/L. Sodium levels in Wells No. 1, 2, 3, 4, and 13 consistently exceed this level. In
response to the drinking water guidelines, AWD issues public notification in its annual consumer
confidence report. AWD stopped pumping Well No. 2 into the distribution system in the 1990’s
since it has the highest levels of sodium and chloride contamination. Water from this well is
pumped to Dark Brook in an effort to intercept groundwater with the highest sodium and
chloride levels before it reaches Wells No. 1 and 3. While it is believed that this effort has
helped to abate some of the sodium and chloride contamination of Wells No. 1 and 3, the levels
in these wells have continued to rise. In May 2013, sodium in Wells No. 1, 2 and 3 reached 180,
470 and 140 mg/L respectively and chloride in Wells No. 1, 2 and 3 reached 338, 867 and 265
mg/L respectively. AWD has concerns that Wells No. 1 and 3 may need to be taken out of
service in the future unless measures are taken to prevent the continued influx of sodium and
chloride.
Due to close proximity to I-290, Wells No. 4 and 13 are vulnerable to contamination from fuel
spills caused by accidents on the highway. If there was to be a significant spill on I-290 in the
area, Wells No. 4 and 13 may need to be taken out of service until the contamination is
remediated.
AWD’s distribution system has two pressure zones, the High-Pressure Zone and the Low-
Pressure Zone. The High-Pressure Zone is serviced by Wells No. 1 and 3 and Wells No. 11 and
12, all of which are vulnerable to fuel spills that may occur on I-90. If either or both well
systems were to be taken offline, AWD’s system would not be able to meet the demands in the
High Zone.
AWD’s system can typically meet water demands while sustaining normal pressures during a
maximum demand week; however, if one or two wells are rendered inoperable, storage tanks
may not recover during a maximum demand week. This could result in water shortages and/or
decreased water pressure below normal levels. MassDEP concurs that AWD has difficulty
meeting demand when wells are offline and needs another source to provide AWD with water
for emergencies and to improve resiliency.
Alternatives Analysis
An alternatives analysis was performed to identify, evaluate, and select potential supplemental
water supply alternatives. Six alternatives, including a no-action alternative, for supplemental
water supply were reviewed for AWD’s needs. Methods for maintaining water supplies included
implementing additional treatment for existing sources, bringing new sources online, and
purchasing water from the City of Worcester or surrounding towns.
Selection for the proposed design was based on several factors which included cost, construction
and phasing feasibility, environmental concerns, and hydraulic design requirements. Of
particular importance is that the selected alternative has the ability to offset any losses from
AWD’s largest producing well while providing an additional margin of safety should another
source go down simultaneously. Required range is at least 500 gpm to 750 gpm for 12 hours per
day, 365 days per year.
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Church Street Wells Treatment
The three existing Church Street Wells have a combined flow capacity of approximately 850
gpm: Wells No. 1, 2, and 3 have pumping rates of 500 gpm, 150 gpm, and 200 gpm,
respectively. The Church Street Wells are currently impacted by increasing amounts of sodium
and chloride contamination from nearby roads. Well No. 2 is no longer pumped into the
distribution system since it has the highest levels of sodium and chloride contamination. In an
effort to intercept groundwater with the highest sodium and chloride levels before it reaches
Wells No. 1 and 3, groundwater from Well No. 2 is pumped to an adjacent brook (Dark Brook)
instead of the distribution system. Despite these efforts, the sodium and chloride levels in Well
No. 1 and 3 have continued to rise as evidenced by ongoing sampling efforts performed by
UMass. In addition to sodium and chloride contamination, frequent vehicle accidents on
Interstate I-90 (MassPike) threaten the Church Street Wells from potential fuel spill
contamination.
Church Street Wells No. 1 and 3 currently supply approximately 150 million gallons of water per
year. By implementing treatment, approximately 150-200 gpm of capacity could be regained for
AWD’s system; however, given the relatively low efficiency of reverse osmosis treatment
processes, it is likely that the regained capacity would be lower. This expected capacity would
not be adequate to offset losses from AWD’s largest producing well while providing an
additional margin of safety should another source go down simultaneously (i.e., 500-750 gpm,
12 hours per day, 365 days per year). Expected yield would also be limited by factors such as
water quality, physical limits and recharge of the well, and authorized permitted withdrawals for
the system.
Implementation of Silver Street Wells
The three Silver Street Wells have been permitted and approved for a combined flow capacity of
390 gpm. These wells are permitted but not currently active. The permanent wells are in place;
however, the pumping and treatment facilities have not yet been constructed. Implementation of
these wells would help recover more than the lost capacity from Church Street Well No. 2. A
test well program was previously conducted at the Silver Street site. The results of this test well
program indicated that manganese in all three wells exceeds the Secondary Maximum
Contaminant Level (SMCL) of 0.05 mg/L and the Health Advisory Level (HAL) of 0.3 mg/L.
Therefore, treatment removal for iron and manganese will be required.
The combined pumping rate of the Silver Street Wells is 390 gpm; however, the Silver Street
Wells cannot supply more than the safe yield of the wells, which is 300 gpm for 16 hours per
day. If the Silver Street wells were to operate at this rate year-round, the wells could supply
approximately 105.1 million gallons of water per year. This is approximately 61.3 million
gallons more than the Church Street replacement well. This expected capacity, however, would
not be adequate to offset losses from AWD’s largest producing well while providing an
additional margin of safety should another source go down simultaneously (i.e., 500-750 gpm,
12 hours per day, 365 days per year). Expected yield would also be limited by similar factors
such as water quality, physical limits and recharge of the well, and authorized permitted
withdrawals for the system. Additionally, the Zone I of the wells crosses the Lower Stoneville
Reservoir and covers portions of parcels on the eastern shore of Lower Stoneville Reservoir not
currently owned by AWD. AWD would need to work with the owners of these properties to
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procure the needed pieces of these parcels prior to activation of these supplies. MassDEP will
not approve construction of the permanent pumping facilities until all of the Zone I is owned or
controlled by AWD.
Other Sources to Avoid an Interbasin Transfer
In addition to the City of Worcester, the Town of Auburn is bordered by the Town of Millbury,
Town of Leicester, and Town of Oxford. Oxford is entirely within the French River Basin.
Therefore, only Millbury and Leicester could be potential in-basin sources that would avoid an
interbasin transfer.
The Town of Millbury’s water system is opera