Lackawanna River Conservation Plan - 5. Water Quality and Quantity

The evolution of our understanding of clean water and water pollution issues during the Nineteenth and Twentieth centuries has led to the development of water, air and general environmental quality regulation in all developed countries. Gradually through legislation, regulation and appropriation, states and localities began to address issues like sewage treatment, erosion control, industrial waste, drinking water protection and here in the Anthracite Coal Region, acid mine drainage problems.

The Pennsylvania Clean Streams Act of 1937 mandated the elimination or control of pollution. The Act soon impacted local municipalities and businesses as various state agencies would issue orders for compliance from time to time. The anthracite coal industry, particularly older operations were exempt from many of the requirements of the Act and subsequent amendments. These exceptions gave the municipalities a significant reason for not developing modern sewer collection and treatment systems.

By 1960 the anthracite industry had declined to a point where it no longer generated water pollution as it had in the past. Commonwealth of Pennsylvania agencies such as the Sanitary Water Board of the Department of Health were finally able to prevail on local governments to begin the long over due cleanup of the Lackawanna. The incentive of matching federal and state grants was the final element inducing the cooperation of local municipalities.

With the development of municipally owned sewage treatment works, many private industrial discharges found it to their benefit to develop a pretreatment discharge program with the local sewer authority rather than develop and operate their own treatment works. With the Clean Water Act of 1972 and the inception of the National Pollution and Discharge System permits (NPDES), the incentives for industrial users to join municipal systems increased.

The late 1960’s and early 1970’s saw the creation of four initial sanitary treatment authorities:

· The Scranton-Dunmore Sewer Authority, also known as the Scranton Sewer Authority (SSA) was created. Between 1962 and 1966 it constructed a 22-million gallons-per-day plant on the Lackawanna River off Cedar Avenue in South Scranton. The SSA also developed a complex interceptor sewer collection system at that time.

· The Lackawanna River Basin Sewer Authority (LRBSA) was created by Lackawanna County to address treatment needs in twelve municipalities in the county as well as Forest City and Susquehanna County and Clinton Township in Wayne County. LRBSA operates plants in Clinton Township, Archbald and Throop.

The plants came online in early 1973. LRBSA originally operated a plant in the Borough of Moosic but it was closed and a treatment arrangement was instituted with the Lower Lackawanna system in 2000.

· The Lower Lackawanna Valley Sanitary Authority (LLVSA) also called “Lower Lack” was created by several municipalities in the lower watershed: Taylor and Old Forge in Lackawanna County joined with Avoca, Duryea, Hughestown, Dupont and Pittston Township in Luzerne County. The Lower Lackawanna plant is located on Coxton Road in Duryea one-half-mile upstream from the confluence of the Lackawanna and Susquehanna rivers. It came online in 1973.

· The Clarks Summit – Abington Joint Sewer Authority (CSAJSA) was created by a merger of the Clarks Green Treatment Works into a new multi municipal arrangement that built a new and larger plan at Chinchilla along Leggetts Creek on US Route 6. The CSAJSA plant came online in 1972. It provides service to a large area of Clarks Summit and Clarks Green boroughs and South Abington Township in the Leggetts Creek watershed.

As of 1990 several small treatment systems were permitted for private use or industrial waste treatment and discharge with individual NPDES permits. Most industrial and commercial discharges are discharging through pretreatment system plans into one of the municipal treatment works.

With the advent of urban/suburban sprawl-type growth in the previously agricultural or wooded uplands of the Lackawanna watershed from the 1970’s through the present, there have been increasing incidents of water supply, aquifer, lake and stream contamination from a growing number of on-lot septic systems which are compromised due to age, lack of proper maintenance or improper installation. Several developer-owned treatment plants have also failed leading to a serious threat of water supply contamination.

These facilities contributed in 1985 to the giardia cyst contamination of the urban water supply that is located in suburbanizing watersheds along the flanks of the Lackawanna Valley. The USEPA and the PA DER ordered several municipalities to update their Act 537 sewer facilities plans and begin to develop treatment plant and collector systems. New sewer authorities and plants have been developed during the 80’s and 90’s in Moscow Borough, Elmhurst, Roaring Brook, Spring Brook, and Covington townships in the North Pocono area.

Act 537 plan updates and plans for new systems have been stalled for over ten years in Jefferson Township in the North Pocono area and in Scott Township.

The development of the watershed’s sewer systems is a study in contrast. The early systems in the urban corridor were built with 80% federal grants and subsidized loans. The authority’s were formed through intergovernmental cooperation and have benefited from certain economies of scale. These systems developed interceptor pipelines to basically retrofit the old municipal sewers and convey that daily flow to a treatment plant. These systems have relatively affordable rates and have been on occasion re-capitalized with regular maintenance and enhancements to capacity and capability. Both the plants and the interceptor systems are showing their age. The Scranton system especially is in need of major upgrades. The LRBSA system has under gone significant upgrades in recent years.

By contrast, the newer suburban systems have been built with a greater percentage of loans versus grants. Efforts at inter municipal cooperation have not succeeded in creating a single North Pocono Sanitary Authority. Each municipality has gone its own way, building and operating its own system, with the exception of Roaring Brook/Elmhurst and Roaring Brook/ Spring Brook where some cooperation has occurred. These newer systems also serve a wide geographic and topographic area making operation and maintenance problematic. There have not been any significant economies of scale with these disjoined systems.

One distinction with these new systems is that by and large they have separate sewage collection and conveyance systems not tied into older combined storm and sanitary sewers as is the case on the urban systems. High precipitation periods have resulted in some plant overflows, an indication that there may be some storm water inputs in the system. A likely source is rain gutters tied into area drains at some residential and commercial properties.

There have been significant costs associated with building and operating treatment plants and developing and maintaining extended collection systems across rolling topography serving sprawl and strip developments in the suburbanizing watersheds and headwaters areas along the rim of the Lackawanna watershed. These costs and problems of rate payer affordability, the decline in the rural/village character, and issues of sprawl-type growth have caused and continue to cause a great deal of acrimonious disagreement among the body politics of many communities engaged in updates of their Act 537 sewage facilities plans. These disagreements have forced the near bankruptcy of several sewer authorities. The successional scrapping and revision of various plans, the hiring and firing of consultants, solicitors, the appointment and resignation or termination of numerous authority members as well as influences on the election or retention of township supervisors are characteristic of the dissension associated with these Act 537 plans.

These conflicts have been ongoing in Jefferson Township in the North Pocono area on the east side of the Lackawanna Valley and Scott Township in the Abington area on the west side of the Lackawanna Valley for much of the past ten years. Both townships lie partially in the Lackawanna watershed and partially in the Tunkhannock (Scott) and the Wallenpaupack (Jefferson). In both townships the proposed central collector systems were extensive and were designed to feed treatment plants deemed unaffordable by many residents. The Jefferson project has also been tied into controversies related to the conservation of the Moosic Mountain barrens natural areas.

The latest revision (2001) of the 537 plans for Jefferson propose a collection system and pumping station with a trans-mountain pipeline to convey waste water over Moosic Mountain along PA Route 247 for treatment through the Scranton Dunmore system. The economies of this plan and the utilization of the Scranton treatment plant seem to meet both affordability and water quality attainment criteria.

The most recent consultant proposal for Scott Township would entail development of collection systems, pumping stations and connections to the LRBSA and CSAJSA systems. Again, economies of scale, affordability and attainment of water quality goals seen possible with the proposal.

Both of these proposals will mean there will not be new sewage treatment plants discharging into high quality headwater streams. Treatment will occur at long established plants discharging into the Lackawanna that may have a greater capacity to absorb the total maximum daily load (TMDL) from these additional sources.

LRCA remains concerned that the TMDL for Leggetts Creek is being reached or exceeded especially during summer months during low flow/low precipitation periods. The urban, CSO and AMD influences on the Lackawanna may cause similar exceedences in TMDL. More assessment work on Lackawanna watershed TMDL’s is needed to help influence decision-making regarding treatment and collection system upgrades.

The inputs of suburban wastewater will only be marginal constituents of CSO events but the LRBSA, SSA and LLSSA systems have a disproportionate number of combined overflow discharge points. According to their NPDES permits, the systems have the following permitted CSO discharges:

LLSSA	45
SSA	68
LRBSA	45
Total CSOs on Lackawanna River	158

The Lackawanna receives a total of 158 CSO discharges for a period of minutes or hours during and after each precipitation event. While the combined sewage and storm water discharges into the river, greater hydraulic flows from natural storm runoff as well as urban storm flows contribute to flushing and diluting the CSO flows. Operational malfunctions such as debris accumulation often cause a continued sewage discharge from given points on the CSO system. Lack of line maintenance, difficulty in accessing, inspecting and maintaining some discharge chambers often accentuate the problem. During the most recent permit period all sewer authorities have been required to be more rigorous in inspecting and maintaining their CSO’s. All CSO’s have been numbered and posted with identification placards.

The LRCA and the Corps of Engineers had identified the CSO’s as a major water quality problem in the 1993 Lackawanna River Greenway Reconnaissance Study. The Study offered several recommendations to reduce and eliminate the CSO problems. Some funding is presently available through the USEPA / Lackawanna County Lackawanna Watershed 2000 program. The complete treatment of the CSO’s on the Lackawanna is estimated to cost from three to four-hundred-million-dollars.

The Pennsylvania Department of Environmental Protection (PA DEP) through its Environmental Futures Planning process (EFP 2) has prioritized a reduction in CSO in the Lackawanna watershed by 50% during the next ten years.

Flooding from tropical storms, heavy winter and spring storms and flash flooding from summer cloudbursts has always been problematic in the Lackawanna watershed. With steep forested mountainsides and built-up communities along the flood plains of the river and tributaries, runoff from storms quickly reaches and inundates low lying areas. In the Nineteenth Century, a clear-cut timber harvest for the building construction, rail and coal mining industry greatly diminished the forest cover in the Lackawanna watershed. During the Twentieth Century, strip mining and culm dumps caused further impacts to the watersheds natural functions.

Historic floods of record occurred in 1902, 1922, 1936, 1942, 1954, 1955, 1972, 1985 and 1996 in the Lackawanna watershed. The floods resulted in million of dollars of property damage, the loss of life and the disruption of economic and domestic activities. Local, state and federal agencies have responded first with emergency actions and then with engineered solutions such as flood control dams (Stillwater – 1960, Aylesworth – 1970) and numerous levee and floodwall projects.

As Lackawanna County began to anticipate greater economic development in the 1980’s, the County Regional Planning Commission took the lead in developing a storm water management plan for the entire Lackawanna River watershed. This work was implemented through, Act 67, the Pennsylvania Storm Water Management Act. The Lackawanna River storm water management plan and ordinance program was one of the first such plans completed under Act 67. The intent of the plan is to insure that storm water discharge from a developed property does not exceed its predevelopment volumes or rates. Storm water is required to be collected and channeled to a detention basin for gradual discharge into a natural stream or a constructed drainage system leading to a natural stream.

The Lackawanna storm water plan has been implemented through municipal ordinance and has at least been successful in preventing inundation of adjoining properties to large residential and commercial developments. In practice however, the engineering communities initial response to the ordinance requirements has been to design engineered, structural, volumetric systems consisting of curbed gutters, grated concrete catch basins and culvert lines discharging into mostly dry rip rap stone-lined trapezoidal storm water detention basins. These basins have become ubiquitous features at new developments. Often surrounded by chain link fences, they have been referred to as rock-filled ice cube trays devoid of many of the natural values and functions found in a natural system. Some engineers have recognized opportunities to use more natural design features and recreate a naturally appearing water amenity as well as meet the storm hydrologic requirements. The further development of these systems, especially in areas of reclaimed mine land, can help to retro fit and restore many of the natural values and functions once obtained with small wetlands and vernal ponds perched at locations from the valley floor to the ridge line.

An integration of storm water systems can also serve to restore or maintain greenways and natural habitat corridors throughout the watershed. Lackawanna County is considering an update of the Act 67 plan in a few years. The update process will provide opportunities to address natural values and functions, water quality of discharge and the effect on TMDL’s in the watershed.

The Lackawanna watershed has been affected by the negative environmental impacts of coal mining. The anthracite coal industry was active in the watershed from the 1820’s to the 1960’s. Since 1960 active coal mining has consisted of a few marginal strip mines, re-mining previously strip mined and underground mined sites.

The impacts to the watershed from mining and a description of the acid mine drainage problems are contained in the Lackawanna River Watershed Mine Reclamation Plan which is published as a supplemental volume, as part of this report (see Appendix B).

Erosion and sedimentation is a natural phenomena where flowing water wears away rock and soil and carries these materials as bed load or suspended in the water column. As the flowing water moves downstream, over time it looses velocity and its ability to move or carry material is diminished. These materials are deposited in the streambed or along adjacent plains.

Human generated earth disturbance activities such as farming, road and building construction, timber harvest, mining and quarrying and off-road recreation vehicle use are the major sources of erosion affecting watersheds. All of these activities occur in the Lackawanna and all in various ways negatively impact the river, its tributaries, their water quality and aquatic habitat quality. Erosion in the Lackawanna effects the water and aquatic habitat quality of the Susquehanna River and the Chesapeake Bay.

Soil particles eroded upstream and carried in suspension become a matrix for nutrient pollution as nitrogen and phosphorous molecules become attached to suspended solids. The suspended solids and nutrients combine to serve as a media for algae growth that becomes especially prevalent in summer.

Numerous state and federal regulations govern the various activities and practices that often result in erosion or contribute to the potential for erosion. In Pennsylvania the conservation districts are the primary permitting, inspection and enforcement agency for earth disturbance permits. The minimum threshold of acreage requiring a permit is five acres. The permit process requires the filing of a soil erosion and sedimentation control plan that demonstrates the application of current best management practices to prevent, control and direct any erosion potential through a construction or earth disturbance site drainage control system.

The conservation districts approve and issue permits based on information provided by the applicant. The districts do not always have the capacity to monitor and inspect each project to insure complete compliance. District staff do inspect larger projects that may demonstrate the likelihood of site or developer-based compliance issues.

Earth disturbances under five acres are not presently required to obtain a permit under state regulations. Compliance is often governed through local zoning, land use, subdivision and/or storm water management ordinances. Many municipalities may not have the resources or staff to adequately interpret, review and monitor compliance practices for erosion and sedimentation and other environmental impact control issues.

In the Lackawanna Valley there are a large number of small lot, five acres or less subdivisions under development through zoning permits at any given time. There are an even larger number of un-permitted earth disturbance activities of various sizes whereby property owners solicit the public with signs such as “clean fill wanted.”

There are dozens of examples of cut and fill operations on steep hillsides and along river and tributary flood plains in each and every municipality in the watershed. These type of operations which fall in a regulatory gray area below a threshold requiring some type of permit and review are widespread across this and other watersheds.

These operations often contribute to several endemic problems in the Lackawanna watershed.

Abandoned mine lands in the Lackawanna watershed contain upwards of 25- to 30-thousand-acres of un-vegetated soils, culm banks, stripping overburden piles, silt basins and impacted water courses. There are numerous large culm banks and coal silt deposits in/on and adjacent to watercourses. Erosive drainage swales and sheet flow cross upland areas of these sites. These abandoned coal lands are also common sites for unregulated “clean fill” activities, auto junkyards, illegal dumping and off-road vehicle activity. These activities and the ambient condition of these lands are significant contributors to the erosive suspended and mobilized bed load of the Lackawanna. A sediment transport and output study would be useful in determining the total volume of sedimentary output of the Lackawanna. Such a study could serve as a benchmark to measure the effectiveness of future control strategies.

The water supply in the Lackawanna watershed has a complex set of physical, political and economic management variables related to the historic development and settlement patterns which themselves have been influenced by geology and typography. A more recent political, economic and resource management variable has been the sale of 45-thousand acres of previously regulated water utility company (The Pennsylvania Gas and Water Company, PG&W) property to a private non-utility owner, Theta Corporation.

The Department of Environmental Protection (PA DEP) is presently (2001) conducting a statewide drinking water source water assessment program (SWAP). The Pennsylvania American Water Company (PAWC) is the operator of the water supply utility in the urban area of the Lackawanna watershed. PAWC acquired the water utility, 8,000 acres of buffer land, 36 reservoirs, pipelines and water supply filtration plants from PG&W (later PG Energy, now a subsidiary of Southern Union Gas Company) in 1996. PG Energy kept the balance of 45,000 acres and transferred title into Theta Corporation, a PG Energy affiliate in 1999. After the merging of PG Energy’s parent company Pennsylvania Enterprises Incorporated (PEI) with Southern Union in late 1999, Southern Union sold the stock in Theta Corporation to an unnamed purchaser in February 2000 for $12.3-million.

The sale has generated significant public controversy. Theta originally restricted public access at many stream access points and other areas popular for fishing and hunting. The PA Game Commission and Theta Corporation announced a cooperative agreement to allow hunting on the properties (August 2001).

The water supply for the urban/coal mine corridor of the valley is predominantly served by reservoirs located in upland areas of the watershed on tributary streams or at the headwaters of the river above Stillwater Dam. The surface supply reservoirs were developed between the 1870’s and 1930’s to compensate for the loss of source water supply, groundwater and stream flow in the lower river corridor due to coal mining impacts to groundwater and the river as well as sewage contamination in the river by the 1890’s.

The investor-owned water companies that developed in the 1880’s were gradually merged into the Scranton, Spring Brook Water Company by 1928; becoming the Pennsylvania Gas and Water Company in 1960 to 1996. The PG&W Company responded to state mandated water filtration after an outbreak of giardia cyst contamination in 1984 and 85. PG&W capitalized $400-million to construct eleven new state of the art water filtration plants. This program led to the reconfiguration of the water supply system and a move by PG&W to sell the water business, eventually to PAWC and spin off the (“surplus”) watershed lands.

LRCA had intervened in the regulatory process before the PUC in 1996. A consent decree was negotiated whereby the intervention was dropped in exchange for PG Energy’s development of a watershed land use plan and advisory committee. The committee was empowered and a plan developed with the Company and its consultants in 1997-98. With the merger of PG Energy into Southern Union and the sale of Theta Corporation and its real estate assets, the legal status of the plan and its recommendations is unclear. It can serve as a primary planning instrument for the municipalities to plan, zone, and regulate subsequent use of these lands.

There are a significant number of concerned parties, public and private which are interested in the permanent conservation of these lands. There are a number of activities underway related to these properties at the present time including related open space plans being developed by Lackawanna and Luzerne counties with the participation of several state agencies and conservation organizations, including the LRCA and Pennsylvania Environmental Council (PEC).

While all of this serves as context to place the water supply and reservoir areas both physically and politically, the business of supplying safe drinking water continues by the PAWC. In the Lackawanna watershed PAWC reservoirs and filter plants provide approximately 50-million gallons per day in this area. PAWC has rebuilt many miles of pipeline and service mains. During the past six years these improvements have reduced water losses by approximately 15 to 20-million gallons per day.

There are also several smaller water companies serving the watershed. National Utilities operates the Moscow Water Company and a small reservoir along a tributary to Roaring Brook in Covington Township. Several small residential subdivisions in the Abington and North Pocono areas are served by small developer-built and owned systems primarily supplied by wells.

The balance of the rural areas in the watershed are served by private wells. The water quality of some wells is affected by leaching from malfunctioning on-lot septic systems. Other wells have been compromised by illegal dumping of chemicals (Covington Township) migration of road salt storage leachate (Jefferson Township), draw down of commercial wells and golf course irrigation (South Abington, Newton, Covington).

The public perception of its water supply was shaken during the giardia crisis in 1985. There remains a severe and widespread distrust of the water supply. There has long been a disconnect between the consumers of surface supply (the urban residents) and the stewards of the supply, the citizens and local governments in the upland areas of watershed and the water companies. With the contamination of groundwater now becoming a significant issue along with the problems of safeguarding surface supplies, there may be opportunities for our communities, water companies and property owners to cooperate on watershed protection measures that have proven useful in other areas of Pennsylvania and across the United States.

Issues related to water supply quantity have also been advanced after droughts in the 1990’s caused water use restrictions. While the Lackawanna watershed has been relatively a water rich area, severe drought has been known to pinch local supplies. The potential for continued suburban sprawl and the creation of more impervious surfaces with higher runoff coefficients remains a challenge to water quality that needs to be addressed both through municipal ordinance and regional comprehensive planning to insure appropriate growth management and best management practices in development design.

Local municipalities may benefit from water conservation and water supply protection concepts that have been discussed in a statewide series of public meetings held by PA DEP during 2001. Further enhancements to public policy through regulatory and legislative recommendations generated from this process are likely.

The Lackawanna was known historically as a vibrant brook trout fishery (Hollister, 1887). Shad may also have been a seasonal fishery on the Lackawanna, as it was a significant fishery in the Wyoming Valley in colonial times into the 1820’s when dam construction downstream closed off the Susquehanna to these anadromous fish.

Anecdotal evidence suggests the Lackawanna was still a viable trout fishery into the early Twentieth Century. By that time the accumulation of mining impacts and urban sewage flows had completely degraded the aquatic habitat of much of the Lackawanna and numerous reaches of its tributaries. The Upper Lackawanna and upper reaches of tributary streams continued to harbor vestiges of the native brook trout fishery. Wild native brook trout and other non game fish can still be found in these waters (PA F&BC 1992, PA F&BC & LRCA 1996).

Since the closure of the anthracite collieries in 1960 and the installation of public-owned sewage treatment works by 1972, the river’s aquatic habitat began a slow recovery. Efforts of local civic and fishing clubs to stock the Lackawanna further demonstrated its resurgence as a sport fishery by the mid 1980’s. Fishery and aquatic habitat studies conducted by PA F&BC and LRCA in the 1990’s built on the work of fishing clubs and sportsmen to recognize the Lackawanna had in fact become a vibrant wild brown trout fishery especially in the twelve-mile reach between Carbondale and Olyphant. This reach as well as upstream reaches from Carbondale to Stillwater contain riffle and pool structures with a mix of boulders, cobble, ledges and woody debris, which constitute classic coldwater fishery habitat.

This reach is now classified as a Class A trout water and is attracting angling interest from throughout the region. The base of the food chain supporting the fishery is a healthy and diverse macro invertebrate population. The LRCA volunteers have monitored macros at twelve stations on the Lackawanna tri-annually since 1990. These macro studies show improving ambient water quality and habitat quality as far downstream as North Scranton. Through Scranton and downstream communities of Taylor, Moosic and Old Forge, macro studies suggest a stabilization of improvement in aquatic health. Embededness assessments at many Scranton and downstream reaches show a higher proportion of embededness of the benthic substrate relative to upstream reaches. The principle sources of the fine silts, sands and clays is sedimentation from un-vegetated mine spoil areas, construction sites and road grit from urban storm and combined storm sewage flows, (LRCA/NOAA study 1996 & stream walk surveys 2000).

The Upper Lackawanna fishery is influenced by the presence of Stillwater Dam and metal loadings from the Clinton Forest City Treatment plant operated by LRBSA. (Townsend/Trout Unlimited study, 1995). The Lackawanna presents several anomalies that influence its fishery. Where one would normally expect a good reproducing fishery in the upstream reaches and an adequate fishery downstream where a stream begins a transition from a cold to warm water fishery, the Lackawanna offers several surprises.

The Townsend/TU study indicated higher ambient upstream temperatures; the suggested influence being the shallow pools at Stillwater and Old Stillwater dams. PAF&BC and private assessments on the east and west branches demonstrate adequate conditions for a reproductive fishery exist in these reaches above Stillwater. Townsend suggests the temperature influence of Stillwater result in warmer downstream flows and lower dissolved oxygen (D.O.) availability. While these conditions are acceptable for adult trout they mitigate against hatchlings and fingerlings reaching adolescence.

Downstream of Carbondale, although there are increasing urban and abandoned mine land impacts, the macro population remains as vibrant as in the Forest City area. Herein lies the anomaly, large flows of mine drainage into the river in Simpson, Jermyn and Archbald may actually lower the river’s ambient summer temperature helping it to retain the dissolved oxygen so necessary for all aquatic species. Conversely the cold flows, even though they are mine drainage, do not contain the metal loading or acidity they once had thus the flows do not mitigate against aquatic habitat.

Further information on LRCA River Watch volunteer water quality monitoring program as well as other LRCA conducted water quality and habitat assessments is available on the LRCA website: www.lrca.org.

The good news for the Lackawanna fishery upstream of Scranton contrasts sharply with that downstream. While the river tends towards warm water fishery in its lower reaches, there is still the potential for a mix of cold and warm water fisheries below Scranton. For its final three miles from Old Forge through Duryea to the confluence at Coxton, the Lackawanna is essentially a dead-water, suffocated with the D.O. consuming iron and acid load from the Old Forge Bore Hole AMD. Over 100-million gpd of mine water loaded with 3,000 pounds of iron oxides enters the river from the Bore Hole near the Luzerne–Lackawanna county line.

The Duryea AMD at Coxton Bridge adds another 30-million-gallons per day of AMD loading. These discharges have been referred to as the largest visible point sources of pollution in the entire Chesapeake Bay watershed.