SALEM-ENF-SANITARY SURVEY REPORT-COMPLIANCE PLANSalem Water Department Salem
PWS ID# 3258000 Survey Date: December 10, 2024
Public Water System Sanitary Survey Page 19
OUTSTANDING ACTIONS
ENFORCEMENT ACTIONS
INSPECTION ACTIONS
COMPLIANCE PLAN
Fill in the completion date for all required activities and return to MassDEP with the response sheet
and all required documentation. If the time required to complete the action is greater than 3 months, submit
quarterly progress reports and anticipated completion date. If projected completion dates are included in the
table, documentation must be submitted to the Department upon completion of all corrective actions.
TABLE A – VIOLATIONS*
This document also serves as a Notice of Noncompliance (NON) pursuant to M.G.L. c.21A, §16 and 310
CMR 5.00 for the following violations of the Massachusetts Drinking Water Regulations.
1 Citation: Violation: GWR SD/GWR TT†
310 CMR
22.22(13)(e)
Failed cross connection devices have not been
replaced or repaired and retested within 14
calendar days.
NA
Evaluation Checklist Section: Checklist #
Cross Connection / Backflow Prevention XC-10
Corrective Action: Due: Complete:
Salem shall develop internal procedures for taking action to require
device replacement, installation, or repair when necessary. The plan
shall be submitted to the Department after which Salem will implement
the plan. Salem shall submit a list of failed devices and schedule for
retesting devices once repaired or replaced within the 14 day
requirement.
February
28, 2025
The City made changes to the Cross Connection Control Program to better enforce the required re-testing after 14 days. The main changes are outlined in section VI.D., of the revised Cross ConnectionControl Program under attachment #1. These new procedures will also require changes to the City Ordinace to implement fines for non-compliance.Changing the City Ordinace is underway and requires working with the City Socilitor to present the changes to the City Council for their approval during one of the spring 2025 Council meetings.
2/27/2025
Attachment#1, below
Salem Water Department Salem
PWS ID# 3258000 Survey Date: December 10, 2024
Public Water System Sanitary Survey
TABLE B – DEFICIENCIES*
The following items do not reflect good water system practice and, if left unresolved, could compromise your
ability to provide safe drinking water. Uncorrected deficiencies may be elevated to violations if not corrected by
the action due date.
1 Citation: Deficiency: GWR SD/TT†
310 CMR 22.04(13)
& Guidelines
Chapter 12
Form ERP-CS-OT must be submitted to
MassDEP. NA
Evaluation Checklist Section: Checklist #
System Management/Operation OM-14
Corrective Action: Due: Complete:
If Salem has determined that the PWS does not have Operational
Technology (OT) connected to the system, then it must document its
determination in writing to MassDEP or and/or submit Form ERP-CS-
OT, which is available at: https://www.mass.gov/doc/cybersecurity-
statement-no-ot-risks-erp-cs-ot/download. PWS shall complete and
submit this form to the Program.Director-DWP@mass.gov email with
the Subject Line: “Cybersecurity Assessment Operational Technology
(OT) Not at a Cybersecurity Risk Statement - ERP-CS-OT” or contact
MassDEP’s Cybersecurity Technical Assistance Provider, Gufran Bulbul
at Gufran.Bulbul@mass.gov for further assistance within 30 days.
February
28, 2025
2 Citation: Deficiency: GWR SD/TT†
310 CMR
22.11B(5)(i) and
(6)(a)
The Department does not have a current Certified
Operator Compliance Notice or approved Staffing
and Comprehensive Operations Plan on file.
NA
Evaluation Checklist Section: Checklist #
Operator Compliance O-5, O-8, O-9
Corrective Action: Due: Complete:
PWS shall submit an updated Certified Operator and Compliance Notice,
and Staffing and Comprehensive Operations Plan to MassDEP
(enclosed). Staffing and Comprehensive Operations Plan Form Link,
Certified Operator Compliance Notice | Mass.gov
February
28, 2025
3 Citation: Deficiency: GWR SD/TT†
310 CMR 22.04(7)
and Guidelines
Chapter 8
Deficiencies were identified in the Tank 2
(Gallows Hill) Storage Tank during the
professional inspection that have not been
addressed.
NA
Evaluation Checklist Section: Checklist #
Atmospheric Storage Tanks AT-12
Corrective Action: Due: Complete:
Salem shall submit a plan to MassDEP with timelines to address the
recommended actions for maintenance of Tank 2 (Gallows Hill).
March 10,
2025
2/11/2025
Attachment#3, below
CSCAP submitted2/13/2025,
Attachment#2, below
2/27/2025Attachment#4, below
Page 20
Salem Water Department Salem
PWS ID# 3258000 Survey Date: December 10, 2024
Public Water System Sanitary Survey Page 21
4 Citation: Deficiency: GWR SD/TT†
310 CMR 22.19(6) MassDEP does not have a current distribution
map on file. NA
Evaluation Checklist Section: Checklist #
Distribution D-1
Corrective Action: Due: Complete:
Salem shall submit an updated electronic distribution map that includes
source intakes, pumping station, storage tanks, hydrants, pressure zones,
and valves.
March 25,
2025
5 Citation: Deficiency: GWR SD/TT†
310 CMR 22.04(7)
and Guidelines
Section 11.3.1
The Department does not a current Sub-delegation
Form on file. NA
Evaluation Checklist Section: Checklist #
Cross Connection / Backflow Prevention XC-2
Corrective Action: Due: Complete:
Salem shall submit a completed Sub-delegation form to delegate, sub-
delegate or contract for Cross Connection Surveyor responsibilities to
the Department. (Form Link)
February
28, 2025
6 Citation: Deficiency: GWR SD/TT†
NA
Evaluation Checklist Section: Checklist #
Corrective Action: Due: Complete:
TABLE C - RECOMMENDATIONS*
The following items are recommended actions/improvements in order to improve your ability to provide
safe drinking water. These items may be elevated to deficiencies in subsequent surveys.
Citation: Recommendation
1. Guidelines
Section 11.3.7
MassDEP recommends that PWS develop a plan to reduce UAW below 10%.
For a well-run PWS, the amount of unaccounted water should be below 10% of
total finished water distributed into the system.
2.
Guidelines
Chapter 11.3.4
and 11.3.7
Although Salem reported replacing service meters approximately 10 years ago,
Salem should consider developing a formal process for periodic replacement
and asset management.
3. MassDEP recommends that Salem continue with plans for replacement of the
Salem Rd. pump two, as stated.
4. Section 9.3,
System Design
MassDEP recommends that Salem conduct a hydraulic study to update current
static pressures, dynamic pressures, and flow throughout the city.
2/11/2025Attachment#6, below
2/26/2025Attachment#5, below
Salem Water Department Salem
PWS ID# 3258000 Survey Date: December 10, 2024
Public Water System Sanitary Survey Page 22
Citation: Recommendation
5.
Guidelines
Sections 9.3.9 and
9.13
MassDEP recommends flushing be conducted annually at a minimum, with
problem areas flushed twice annually. Although Salem has developed but was
not able to implement a unidirectional flushing program, Salem should continue
to evaluate unidirectional flushing program options in a modified or phased
process.
6.
Guidelines
Chapter 11.3.4
and 11.3.7
MassDEP recommends Salem develop a program to calibrate and, if necessary,
repair or replace water meters for each service on a 10-12 year cycle.
7. Guidelines
Chapter 11.3.1
Although Salem has written procedures for various maintenance activities to
include flushing, alarm testing and tank inspection and maintenance, Salem
should develop a formal written maintenance plan and schedule as outlined in
AWWA Standard G200-09, Distribution Systems Operation and Management.
8. 310 CMR
22.04(6)
It is recommended that all interconnections between Public Water Supplies be
metered.
9. Guidelines,
Appendix O Interconnections should be exercised so that they are functional if needed.
*MassDEP reserves the right to exercise its Order authority under M.G.L. Chapter 111, Section 160, or to take other
appropriate action as permitted by law, in order to prevent the pollution and to secure the sanitary protection of the
water supply and to ensure the delivery of a fit and pure water supply to all consumers, including without limitation if
sufficient progress to meeting a recommended deadline is not achieved.
†Ground Water Rule Significant Deficiency (GWR SD):
The EPA, as part of the Groundwater Rule (GWR), required states to identify specific Significant Deficiencies (GWR
SDs) that are related to the potential for fecal contamination of the water system. Significant deficiencies, when
identified at a PWS that is subject to the Groundwater Rule, are regulated under the treatment technique requirements of
the GWR.
Salem Water Department Salem
PWS ID# 3258000 Survey Date: December 10, 2024
Public Water System Sanitary Survey Page 23
WATER SUPPLIER RESPONSE AND CERTIFICATION FORM
Within 30 days of receipt of this inspection report, you must complete and submit this form if your
system has Table A – Violations and/or Table B – Deficiencies. Attach a copy of the completed table(s)
listing the date that the corrective action was/will be taken; include all required documentation as specified
in the table(s). Note that items with future dates require you to submit documentation of work at the
time of completion. If a specific form of documentation is not identified, an updated Compliance
Plan Table, letter, or email addressed to the inspector that the deficiency has been corrected may be
used.
The following corrective actions listed in the Compliance Plan Table A and/or Table B have
been taken by the Public Water System. (Please check all that apply).
My system has taken ALL of the corrective actions listed within the timeframes specified in the
Compliance Plan.
• I have listed the completion date for each item within the table(s).
• I have attached copies of supporting documentation as required.
My system has taken SOME BUT NOT ALL of the corrective actions listed within the
timeframes specified in the Compliance Plan.
• I have listed the actual or anticipated compliance date for each item within the table(s).
• I have attached copies of supporting documentation as required.
• I have attached a revised corrective action schedule establishing timelines for my system to
address outstanding items and I will submit a written progress report each quarter (every 3
months) until all items have been addressed. I understand that my system may be subject to
further enforcement.
My system is UNABLE to comply with some or all of the corrective actions within the
timeframes specified in the Compliance Plan. I understand that my system may be subject to
further enforcement.
• An explanation is attached.
I certify under penalties of law that I am the person authorized to fill out this form and the information
contained herein is true, accurate, and complete to the best extent of my knowledge.
Water Commissioner, Owner, Owner Representative, or Other Responsible Party:
Signature: Date:
Print Name: Title:
Return this form, a copy of the completed Compliance Plan, and all attachments to:
MassDEP
BWR Drinking Water Program
150 Presidential Way, Suite 300
Woburn, MA 01801
Attention: Sean Griffin
Giovanna Z. Recinos Water & Sewer Engineer
2/27/2025
Attachment #1
Cross Connection Control Program
Updated on February 27, 2025
A Program to Protect Public Health by Controlling Cross Connections
in the City of Salem Water Distribution System
For technical inquiries regarding these requirements of this program, please contact:
Giovanna Recinos
Water & Sewer Engineer
grecinos@salem.com
CITY OF SALEM
Engineering Department
98 Washington Street, 2nd floor
Salem, MA 01970
Phone: (978) 619-5673
Dominick Pangallo
Mayor
Deborah L. Duhamel, P.E.
City Engineer
Cross Connection Control Program February 27, 2025
Page 2 of 11
I. PURPOSE
A. To protect the potable water supply served by the Salem Water Department from
the possibility of contamination or pollution by isolating, within its customers' internal
distribution system, such contaminants or pollutants which could backflow or back-siphon
into the public water system.
B. To promote the elimination or control of existing cross connections, actual or
potential, between its customer’s in-plant potable water systems.
C. To provide for the maintenance of a continuing program of cross connection control
which will effectively prevent the contamination or pollution of all potable water systems
by cross connections.
II. AUTHORITY
A. The Federal Safe Drinking Water Act of 1974, and the Commonwealth of
Massachusetts Department of Environmental Protection Drinking Water Regulations, 310
CMR: Section 22.22, Cross Connections (310 CMR 22.22), require the protection of
sources of water from unapproved sources or any other substances from entering the public
water system.
B. City of Salem Code of Ordinances, Section 46-76. Cross connection charges.
III. RESPONSIBILITY
A. The City of Salem’s City Engineer (City) shall be responsible for the protection of
the public water system under its jurisdiction from any potential contamination or pollution
due to the backflow or back-siphonage of contaminants or pollutants through the water
service connections to the last free flowing outlet or consumer’s tap.
B. The Owner shall allow their property to be inspected for possible cross connections
and shall follow the provisions of the City's program and the Mass DEP's regulations, 310
CMR 22.22.
C. The City shall not permit a cross connection within the public water system unless
it is considered necessary and that it cannot be eliminated by replumbing, or re-piping. The
City shall have the authority to terminate any water service connections to any facility
where cross connections are found to be in non-compliance with 310 CMR 22.22.
IV. DEFINITIONS
A. AIR GAP: A physical separation sufficient to prevent backflow between the free-
flowing discharge end of the potable water system and any other system. Physically defined
Cross Connection Control Program February 27, 2025
Page 3 of 11
as a distance equal to twice the diameter of the supply side pipe diameter but never less
than one inch.
B. APPROVED: Accepted by the City of Salem City Engineer as meeting an
applicable specification stated or cited in this regulation or as suitable for the proposed use.
C. AUXILIARY WATER SYSTEM: Any water supply on or available to the
premises other than the purveyor's approved public potable water supply.
D. BACKFLOW: The flow of water or other liquids, mixtures or substances under
pressure into the distribution pipes of a potable water supply system from any source other
than its intended source.
E. BACKFLOW PREVENTER: A device or means designed to prevent backflow or
back-siphonage. Most commonly categorized as DCVA, PVB, or RPZ devices, defined as
follows:
1. DOUBLE CHECK VALVE ASSEMBLY (DCVA): An assembly of two
independently operating spring loaded check valves with tightly closing shut-off
valves on each side of the check valves, plus properly located test cocks for the
testing of each check valve.
2. PRESSURE VACUUM BREAKER (PVB) device containing one or two
independently operating spring-loaded check valves and an independently operated
spring-loaded air inlet valve located on the discharge side of the check or checks.
Device includes tightly closing shut-off valves on each side of the check valves and
properly located test cocks for testing of the check valve(s).
3. REDUCED PRESSURE ZONE (RPZ) also known as REDUCE
PRESSURE BACKFLOW PREVENTER (RPBP): An assembly consisting of two
independently operating approved check valves with an automatically operating
differential relief valve located between the two check valves, tightly closing shut-
off valves on each side of the check valves, plus properly located test cocks for the
testing of check valves and the relief valve.
F. BACKPRESSURE: A condition in which the Owner's system pressure is greater
than the supply system pressure.
G. BACK-SIPHONAGE: The flow of water or other liquids, mixtures or substances
into the distribution pipes of a potable water supply system from any source other than its
intended source caused by the sudden reduction of pressure in the potable water system.
H. CITY: The City of Salem, City Engineer, or his/her designee.
I. CONTAINMENT: A method of backflow prevention which requires a backflow
prevention device at the water service entrance, directly after the City water meter.
Cross Connection Control Program February 27, 2025
Page 4 of 11
J. CONTAMINANT: A substance that will impair the quality of water to a degree
that it creates a serious health hazard to the public leading to poisoning or the spread of
disease.
K. CROSS CONNECTION: Any actual or potential connection between the public
water supply and a source of contamination or pollution.
L. MASS DEP: The Commonwealth of Massachusetts Department of Environmental
Protection.
M. FIXTURE ISOLATION: A method of backflow prevention in which a backflow
preventer is located to correct a cross connection at an in-plant location rather than a water
service location.
N. OWNER: Any person who has legal title to property upon which a cross connection
inspection is to be made or upon which a cross connection is present.
O. PERSON: Any individual or partnership, company, public or private corporation,
political subdivision or agency of the State Department, agency or instrumentality of the
United States or any other legal entity.
P. PERMIT: A document issued by the City of Salem Engineering Department which
allows the use of a backflow preventer.
Q. POLLUTANT: A foreign substance, that if permitted to get into the public water
system, will degrade its quality so as to constitute moderate hazard or impair the usefulness
or quality of the water to a degree which does not create an actual hazard to the public
health but which does adversely and unreasonably effect such water for domestic use.
R. WATER SERVICE ENTRANCE: That point in the owner's water system beyond
the sanitary control of the City, generally considered to be the point of connection to the
City water main.
V. ADMINISTRATION
A. The City will operate a Cross Connection Control Program, to include the keeping
of necessary records, which fulfills the requirements of the Massachusetts Department of
Environmental Protection's Cross Connection Regulations and is approved by the
Department.
B. The Owner shall allow his property to be inspected for possible cross connections
and shall follow the provisions of the City's program and the Department's regulations.
C. The City will enter into a contract with a Cross Connection Consultant that is
Massachusetts Department of Environmental Protection (MassDEP) Certified in Backflow
Prevention Device Testing and Surveying to manage the Cross Connection Control
Cross Connection Control Program February 27, 2025
Page 5 of 11
Program including inspections and survey of facilities, backflow testing, record keeping
and creating all related correspondence on behalf of the City. .
VI. PROGRAM
A. NEW OR REMODELED FACILITIES AND FACILITIES WITH CHANGE IN
USE OR OWNERSHIP
1. A containment backflow prevention device will be required for all
commercial and mixed-use properties as well as residential buildings with ten or
more units. This device shall be installed directly after the City water meter and
must offer the same protection of the device of the highest degree of hazard within
the facility. Fixture isolation is still required within the premises to protect the water
supply within the building from any potential cross connections.
2. Any new or remodeled facility, or any existing facility wherein the use of
the building is proposed to change or when there is a change in ownership shall be
in compliance with the 310 CMR 22.22 and the City Cross Connection Control
Program. A Massachusetts licensed plumber or a Massachusetts licensed fire
sprinkler contractor shall determine whether additional backflow prevention
devices are required for the building other than those required above or the
appropriateness of the existing backflow preventer devices within the facility.
3. If a backflow device is required, the Massachusetts Licensed Plumber or
Massachusetts Licensed Fire Sprinkler Contractor shall complete and submit a
separate Backflow Prevention Device Design Data Sheet for each proposed device
using the online permitting system, VPC
(https://salemma.workflow.opengov.com/), with associated fee ($100 each) for
approval by the Engineering Department for compliance with these regulations .
4. If any device change is required, the owner shall submit plans depicting said
change, prepared by a licensed Massachusetts State plumber or contractor, for
approval by the Engineering Department for compliance with these regulations.
5. Upon approval of the device, the City shall issue a permit, on City of Salem
Letterhead, for the backflow prevention device.
B. EXISTING FACILITY SURVEYS
1. The City shall have cross connection surveys, performed by MassDEP
Certified Cross Connection Surveyor, of all commercial, industrial, institutional
and municipal facilities that have connections to the City water system. Once a
cross connection survey has passed, it will not need to be surveyed again for five
years unless the facility changes ownership or business type.
2. Surveys shall be performed in accordance with Mass DEP regulations 310
CMR 22.22. The City’s cross connection consultant is the only surveyor that will
Cross Connection Control Program February 27, 2025
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be allowed to perform the inspection surveys for the City of Salem to meet
compliance with 310 CMR 22.22.
3. On an annual basis, the City of Salem shall review the current Assessors
database of properties in the City for land use changes and identify any new
facilities requiring surveys. Any facilities identified shall be surveyed within the
first 3 months of the year.
4. As a result of the survey, the City will determine, and inform the Owner of,
the appropriateness of the existing, or need for new or modified, backflow
prevention device. The Owner will take immediate action to install or modify the
device. Typically, 30 days will be allowed by the City to make the required
changes; however, that time may be shortened by the City depending on the degree
of hazard involved.
5. At the completion of any required changes, or upon completion of a
satisfactory survey (no changes needed), the City shall issue a permit for the
backflow prevention device.
C. EXISTING BACKFLOW PREVENTION DEVICES
1. Any existing backflow preventer shall be allowed by the City to continue in
service unless the degree of hazard is such as to supersede the effectiveness of the
present backflow preventer or results in unreasonable risk to the public health.
Where the degree of hazard has increased, as in the case of a residential installation
converting to a business establishment, any existing backflow preventer must be
upgraded to a reduced pressure principle device, or a reduced pressure principle
device must be installed in the event that no backflow device was present.
A list of the types of backflow preventer devices requiring inspection and testing is
included in Appendix A.
D. ROUTINE TESTING OF EXISTING BACKFLOW PREVENTION DEVICES
1. Reduced pressure zone (RPZ) backflow devices shall be inspected and
tested at least semi-annually by the City, but not sooner than within 5 months after
the first inspection. Double check valve assembly (DCVA) and pressure vacuum
breaker (PVB) devices shall be inspected and tested annually. In cases where the
City feels that due to the degree of hazard involved, additional testing is warranted,
backflow prevention devices will be tested more frequently. Costs of the annual test
and additional tests will be borne by the Owner.
2. Routine testing shall be performed by the City's MassDEP Certified Tester
or its delegated representative who shall be a Mass DEP certified tester. The City’s
Cross Connection Control Program February 27, 2025
Page 7 of 11
cross connection consultant is the only tester that will be allowed to perform the
tests for the City of Salem to meet compliance with 310 CMR 22.22.
3. The testing shall be conducted during the City's regular business hours.
Exceptions to this, when at the request of the Owner, may require an additional
charge to cover the increased costs to the City. Any device located in a confined
space will be covered in a separate contract and the owner’s responsibility.
4. Any backflow preventer which fails during a routine test shall be
immediately repaired or replaced, at the Owner’s expense. High hazard situations
will not be allowed to continue unprotected if the backflow preventer fails the test
and cannot be repaired immediately. In other situations, a compliance date of not
more than 14 calendar days after the test date will be established, per 310 CMR
22.22 (13)(e). The Owner is responsible for repairs/replacement of the failed
device. Parallel installation of two devices is an effective means of the Owner
insuring that uninterrupted water service during testing or repair of devices and is
strongly recommended when the Owner desires such continuity. After a backflow
test fails the original inspection/ test, the City will return 14 calendar days after the
initial failed test to re-test the device. If that test passes during the reinspection, it
is considered a retest not a scheduled test which means it clears up the initial
violation. If that device fails again during the reinspection, the City will return
seven calendar days after the re-test to perform a second reinspection, and the
owner will be subject to a fine. If that device fails again during the second
reinspection, the City will issue a notice to terminate the water service to the
property due to non-compliance and the owner will be subject to a non-compliance
fine. Please note that if the device is an RPZ or other high hazard device it will still
need to be tested again within 5 months or the original test to meet MA DEP
Regulations, 310 CMR 22.22 (13)(d).
VII. RESPONSIBILITIES
A. CITY OF SALEM
1. The City will issue permits for all backflow prevention devices.
2. The City will not allow any cross connection to remain unless it is protected
by an approved backflow preventer for which a permit has been issued, and which
will be regularly tested to ensure satisfactory operation.
3. The City shall inform the Owner, by letter or email, of any failure to comply
with these regulations. In the event that the Owner fails to comply with the
necessary corrective action, the City will inform the Owner, by letter, that the water
service to the Owner's premises will be terminated within a period not to exceed
five days. In the event that the Owner informs the City that extenuating
Cross Connection Control Program February 27, 2025
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circumstances, as to why the correction has not been made, a time extension may
be granted by the City, but in no case will exceed an additional thirty calendar days.
4. If the City determines at any time that a serious threat to the public health
exists, the water service will be terminated immediately.
5. The City shall have on its staff, or shall have a delegated representative,
who is a Mass DEP certified backflow device tester and/or surveyor.
6. The City will have inspections of premises initiated to determine the nature
of existing potential hazards, in accordance with 310 CMR 22.22.
7. The City shall establish and maintain a Cross Connection Control Program
for residential users which shall include an educational component.
B. OWNER
1. The Owner shall be responsible for allowing the premises to be inspected
by the City and shall be responsible for the elimination or protection of all cross
connections on their premises. If access is denied by the Owner, the City shall
consider the test and/ or survey failed and notify the Owner accordingly.
2. The Owner, after having been informed by letter from the City, shall, at
their expense, install, maintain and pay for any required testing, any and all
backflow preventers on his premises.
3. The Owner shall correct any malfunction of the backflow preventer which
is revealed by routine testing.
4. The Owner shall inform the City of any proposed or modified cross
connections and also any existing cross connections of which the Owner is aware
but has not been found by the City.
5. The Owner shall not install a bypass around any backflow preventer unless
there is a backflow preventer of the same type on the bypass. Owners who cannot
shut down operation for testing of the device(s) must supply additional devices
necessary to allow testing to take place.
6. The Owner shall install backflow preventers in a manner approved by the
City and in accordance with 310 CMR 22.22.
7. The Owner shall install only backflow preventers approved by the City.
8. Residential private wells or other private water sources cannot be connected
to the City System. Any other owner having a private well or other private water
source must have a permit if the well or source is cross connected to the City
system. Permission to cross connect may be denied by the City. The Owner may be
Cross Connection Control Program February 27, 2025
Page 9 of 11
required to install a backflow preventer at the service entrance if a private water
source is maintained, even if it is not connected to the City's system.
9. In the event the Owner installs plumbing to provide potable water for
domestic purposes which is on the supply side of the backflow preventer, such
plumbing must have its own backflow preventer installed, if required.
10. The Owner shall be responsible for the payment of all fees for permits, site
inspections, device testing, re-testing in the case that the device fails to operate
correctly, failure due to non-responsiveness to test and second re-inspections for
non-compliance with City requirements.
11. It shall be the property owner’s responsibility to properly install and test
cross connection systems for residential fire protection systems and residential lawn
irrigation systems to remain in compliance with 310 CMR 22.22.
VIII. DEGREE OF HAZARD
A. The City recognizes the threat to the public water system arising from cross
connections. The degree of hazard will be determined at the time of the cross connection
survey.
IX. NOTIFICATIONS
A. On an annual basis, the City shall provide notification to consumers and public
officials of the requirements of the distribution system Cross Connection Control Program,
including the Mayor, City Council, Fire Chief, Health Department, Plumbing and Building
inspectors, and Local State Representative. Notification shall be made in the Annual
Consumer Confidence Report for Salem water customers, created by the Salem Beverly
Water Supply Board.
B. The Engineering Department shall prepare and post the notification on its website
for consumers, and distribute it to the Mayor, City Council, Fire Chief, Health Department,
Plumbing and Building inspectors by interoffice mail. US Mail will be used to distribute
the notification to the Local State Representative.
X. RESIDENTIAL PROGRAM
A. The City shall establish a residential backflow education program, to be
administered by the City Engineering Department, for residential users which shall include
bill inserts, website information, etc., that addresses hose bib applications and the need for
inspection and testing of residential backflow preventers.
XI. FEES
Cross Connection Control Program February 27, 2025
Page 10 of 11
A. Please refer to the City of Salem Code of Ordinances, Section 46-76. Cross
connection charges and fines. Note that every re-inspection/ re-test will be charged the
same fee established under the City of Salem Code of Ordinances.
XII. RECORDS AND REPORTS
A. RECORDS
1. The City Engineering Department will initiate and maintain the following:
a) Master files on customer cross connection tests and/or inspections.
b) Copies of permits and permit applications.
c) Copies of lists and summaries supplied to the Mass
XIII. VIOLATION OF THIS PROGRAM
A. No person or corporation shall directly or knowingly permit an employee, agent or
servant to violate any of the provisions of this program. Please refer to the City of Salem
Code of Ordinances, Section 46-76. Cross connection Charges and fines
Cross Connection Control Program February 27, 2025
Page 11 of 11
APPENDIX A
310 CMR 22.22 and Cross Connection Control Manual
Failed Devicess as of 2.25.25.xlsx
Due Date Facility Name Address Last Work Date Seasonal Retest Time Frame / Notes
01/31/2025 University Square 124 Ocean Avenue 07/31/2024 No will be scheduled for a March 2025 re-test
01/31/2025 University Square Apartments 136 Canal Street 07/31/2024 No will be scheduled for a March 2025 re-test
02/01/2025 Flatbread Company & Derby Street Lanes-Vacant 311 Derby Street 08/01/2024 No building is vacant in person attempt
02/28/2025 Temporary Meter- 160 Federal Street 160 Federal Street 08/28/2024 No will be scheduled for a March 2025 re-test
03/02/2025 Temporary Meter- 17 Hawthorne Blvd 17 Hawthorne Blvd 08/30/2024 No will be scheduled for a March 2025 re-test
05/20/2025 City of Salem (Captain John Bertram Athletic Park)0 Powder House Lane 11/20/2024 No will be scheduled for a March 2025 re-test
06/09/2025 Salem Hospital (Wheelock Bldg)81 Highland Street 12/09/2024 No scheduled for March retest
06/09/2025 Salem Hospital (Wheelock Bldg)81 Highland Street 12/09/2024 No scheduled for March retest
06/09/2025 Salem Hospital (Wheelock Bldg)81 Highland Street 12/09/2024 No scheduled for March retest
06/09/2025 Salem Hospital (Wheelock Bldg)81 Highland Street 12/09/2024 No scheduled for March retest
06/10/2025 Woman's Friend Society 12 Hawthorne Boulevard 12/10/2024 No as of 1/28/25 failed device has not been repaired plumber is waiting for part
07/01/2025 Burger King 259 Highland Avenue 07/01/2024 Yes seasonal device May / June retest date
07/01/2025 City of Salem (Forest River Park)98 West Ave 07/01/2024 Yes seasonal device May / June retest date
07/01/2025 City of Salem (Juniper Playground Rear)(locked box)31 Juniper Avenue REAR 07/01/2024 Yes seasonal device May / June retest date
07/01/2025 City of Salem (Lafayette Park)124 Lafayette Street 07/01/2024 Yes seasonal device May / June retest date
07/02/2025 Burger King 259 Highland Avenue 01/02/2025 No scheduled for March retest
07/02/2025 Market Basket 227 Highland Avenue 01/02/2025 No scheduled for March retest
07/02/2025 Market Basket 227 Highland Avenue 01/02/2025 No scheduled for March retest
07/02/2025 McDonald's Restaurant 150 Canal Street 01/02/2025 No will be scheduled for a March 2025 re-test
07/03/2025 IHOP Restaurant 2 Traders Way 01/03/2025 No will be scheduled for a March 2025 re-test
07/03/2025 IHOP Restaurant 2 Traders Way 01/03/2025 No will be scheduled for a March 2025 re-test
07/06/2025 New England Veterinary Clinic 204 Highland Ave 01/06/2025 No will be scheduled for a March 2025 re-test
07/08/2025 Salem Public Schools- Carlton Innovation School 10 Skerry Street 01/08/2025 No will be scheduled for a March 2025 re-test
07/09/2025 Weatherly Drive Condo Trust 70 Weatherly Drive 07/09/2024 No will be scheduled for a March 2025 re-test
07/09/2025 Weatherly Drive Condo Trust 70 Weatherly Drive 07/09/2024 No will be scheduled for a March 2025 re-test
07/09/2025 Weatherly Drive Condo Trust 70 Weatherly Drive 07/09/2024 No will be scheduled for a March 2025 re-test
07/09/2025 Weatherly Drive Condo Trust 70 Weatherly Drive 07/09/2024 No will be scheduled for a March 2025 re-test
07/09/2025 Weatherly Drive Condo Trust 70 Weatherly Drive 07/09/2024 No will be scheduled for a March 2025 re-test
07/09/2025 Weatherly Drive Condo Trust 70 Weatherly Drive 07/09/2024 No will be scheduled for a March 2025 re-test
07/11/2025 City of Salem (Hawthorne Island)20 Hawthorne Boulevard 07/11/2024 Yes seasonal device May / June retest date
07/12/2025 Salem Maritime NHS 1 Derby Wharf 07/12/2024 Yes seasonal device May / June retest date
07/15/2025 City of Salem (John P. Riley Memorial)(locked box)212 Washington Street 07/15/2024 Yes seasonal device May / June retest date
07/16/2025 City of Salem (McGlew Park)(locked box)201 1/2 North Street 07/16/2024 Yes seasonal device May / June retest date
07/16/2025 City of Salem (McIntire Dist. Memorial Park)309 Essex Street 07/16/2024 Yes seasonal device May / June retest date
07/17/2025 City of Salem (Splaine Park) (Locked box)23 Rear May Street 07/17/2024 Yes seasonal device May / June retest date
07/23/2025 MBTA - Commuter Parking Garage 242 Bridge Street 07/23/2024 No will be scheduled for a March 2025 re-test
07/24/2025 Dube's Seafood 317 Jefferson Avenue 01/24/2025 No will be scheduled for a March 2025 re-test
07/28/2025 Safe Harbor Hawthorne Cove 10 White Street 01/28/2025 No scheduled for March retest
07/30/2025 AdviniaCare Salem 7 Loring Hills Avenue 07/30/2024 Yes seasonal device May / June retest date
07/30/2025 Woodlands Road 10 Woodlands Road 07/30/2024 No will be scheduled for a March 2025 re-test
07/31/2025 93. Canal St Apts 93 Canal Street 07/31/2024 No will be scheduled for a March 2025 re-test
08/01/2025 Woodlands Road 2 Woodlands Road 08/01/2024 No will be scheduled for a March 2025 re-test
08/02/2025 1 South Ridge Circle 1 South Ridge Circle 08/02/2024 No will be scheduled for a March 2025 re-test
08/02/2025 Crescent Trust 10-12 Lynde Street 08/02/2024 No will be scheduled for a March 2025 re-test
Page 1 of 2
Failed Devicess as of 2.25.25.xlsx
Due Date Facility Name Address Last Work Date Seasonal Retest Time Frame / Notes
08/02/2025 Woodlands Road 3 Woodlands Road 08/02/2024 No will be scheduled for a March 2025 re-test
08/06/2025 85 Lafayette Street(north shore bank)85 Lafayette Street 08/06/2024 Yes seasonal device May / June retest date
08/07/2025 Essex Builders (New construction)64 Grove Street 02/07/2025 No
was scheduled for 2/24, The retest was canceled because their sewer configuration was
denied. The City doesn't want to proceed with turning on the water until everything is in
place and approved.
08/07/2025 Witch side Tavern 283 Derby Street 02/07/2025 No will be scheduled for a March 2025 re-test
08/07/2025 Woodlands Road 6 Woodlands Road 08/07/2024 No will be scheduled for a March 2025 re-test
08/09/2025 Anastasi Realty 100 Jackson Street 08/09/2024 No will be scheduled for a March 2025 re-test
08/09/2025 RCG (The Derby & Adriatic)189 Washington Street 08/09/2024 Yes seasonal device May / June retest date
08/12/2025 Atlantic Medicinal Partners (AMP cannabis )- Salem 297 Highland Avenue 02/12/2025 No will be scheduled for a March 2025 re-test
08/14/2025 1 Jefferson Avenue 1 Jefferson Avenue 02/14/2025 No will be scheduled for a March 2025 re-test
08/18/2025 Salem State Univ. (Harrington Bld)11 Harrison Rd 02/18/2025 No will be scheduled for a March 2025 re-test
08/18/2025 Salem State Univ. (North Dining Common)354 Lafayette Street 02/18/2025 No will be scheduled for a March 2025 re-test
08/18/2025 Salem State Univ. (Sullivan Building)352 Lafayette Street 02/18/2025 No will be scheduled for a March 2025 re-test
08/19/2025 Salem Hospital (Davenport)81 Highland Avenue 02/19/2025 No scheduled for March retest
08/29/2025 Prime Storage Shetland, LLC (Bldg 4)45 Congress Street 08/29/2024 No will be scheduled for a March 2025 re-test
09/20/2025 Kimco 15 Paradise Road plaza 09/20/2024 Yes seasonal device May / June retest date
10/07/2025 Hall Company (PIT CS)96 Swampscott Road 10/07/2024 Yes seasonal device May / June retest date
10/07/2025 Hall Company (PIT CS)96 Swampscott Road 10/07/2024 No confined space
10/07/2025 Hall Company (PIT CS)96 Swampscott Road 10/07/2024 No confined space
12/10/2025 293 Jefferson Avenue 293 Jefferson Avenue 12/10/2024 No will be scheduled for a March 2025 re-test
01/03/2026 IHOP Restaurant 2 Traders Way 01/03/2025 No will be scheduled for a March 2025 re-test
01/08/2026 Salem Public Schools- Horace Mann Laboratory School 79 Willson Street 01/08/2025 No will be scheduled for a March 2025 re-test
01/09/2026 North Shore opco llc 331 Highland Avenue 01/09/2025 No scheduled for March retest
01/15/2026 Salem Public Schools- Bentley Academy Innovation School 25 Memorial Drive 01/15/2025 No will be scheduled for a March 2025 re-test
01/17/2026 Traders Way Limited Holdings, LLC- Building 60 45 Traders Way (40 First Street)01/17/2025 No will be scheduled for a March 2025 re-test
01/20/2026 All Creatures Veterinary Hospital 20 Commercial Street 01/20/2025 No scheduled for March retest
01/24/2026 Barrio Tacos 41 Lafayette Street 01/24/2025 No will be scheduled for a March 2025 re-test
01/24/2026 Barrio Tacos 41 Lafayette Street 01/24/2025 No will be scheduled for a March 2025 re-test
01/28/2026 Star Dry Cleaner 84 Highland Avenue 01/28/2025 No device retested on 1/28/25 and refailed, will be scheduled for a March 2025 re-test
01/28/2026 THE COVE HOTEL 40 Bridge Street 01/28/2025 No will be scheduled for a March 2025 re-test
02/03/2026 Mother Theresa of Salem LLC 34 St Peter Street 02/03/2025 No retested on 2/3/25 re failed, will be scheduled for a March 2025 re-test
02/04/2026 Witch’s Brew Café 156 Derby Street 02/04/2025 No building under construction as of 2/4/25
02/05/2026 Lifebridge 56 Margin Street 02/05/2025 No as of 2/5/25 device is being worked on will call back when done
02/07/2026 Merck Ink Tattoo Studio 266 Essex Street 02/07/2025 No made several attempts to contact have not responded
02/12/2026 Atlantic Medicinal Partners (AMP cannabis )- Salem 297 Highland Avenue 02/12/2025 No will be scheduled for a March 2025 re-test
02/12/2026 Pickering Wharf Realty Tr (63 Wharf)63 Wharf Street UBA 02/12/2025 Yes seasonal device May / June retest date
02/12/2026 Pickering Wharf Realty Tr (71 Wharf)71 Wharf Street UDA 02/12/2025 No will be scheduled for a March 2025 re-test
02/12/2026 Pickering Wharf Realty Tr (72 Wharf)72 Wharf Street UJB 02/12/2025 No will be scheduled for a March 2025 re-test
02/12/2026 Pickering Wharf Realty Tr (94 wharf)94 Wharf Street UAA 02/12/2025 Yes seasonal device May / June retest date
02/14/2026 1 Jefferson Avenue 1 Jefferson Avenue 02/14/2025 No will be scheduled for a March 2025 re-test
02/19/2026 Salem Hospital (North Shore Childrens)81 Highland Avenue 02/19/2025 No scheduled for March retest
Page 2 of 2
Attachment #2
3 | P a g e
Table B: ACTION TO BE COMPLETED
This table lists any findings identified during the cybersecurity portion of the sanitary survey. PWS must update the MassDEP/DWP
on your PWS plan of action to address the findings by completing and submitting this Table and the certification form to
MassDEP/DWP by the date specified in the column 3 below. Please only submit a completed Tables B, C and refrain from
sharing additional documents or sensitive information.
1
Citation
2
Findings
3
MassDEP Deadline
4
Action(s) Completed By PWS, Date(s)
310 CMR
22.04(13)(c)
Findings as
identified in the
cybersecurity
assessment
report dated
12/05/24.
By February 16, 2025,
confirm your intent to address
all findings by completing
column 4 with the timeline of
your plan. Submit this
completed Table B and signed
certification to MassDEP
Drinking Water Program
program.director-
dwp@mass.gov, Subject
CSCAP.
To protect sensitive data your
PWS email response should
not include any sensitive
information.
On or by 2027 my PWS will take/took the
following checked action(s):
A. My PWS addressed all identified areas of concerns/findings
and incorporated all applicable recommendations listed in the
report.
Or
B. My PWS addressed findings that required immediate
attention.
And
My PWS will address all remaining identified areas of
concern/findings and incorporate all applicable recommendations
listed in the report:
Within one year of date on CSCAP
Within two years of date on CSCAP
Before the MassDEP/DWP next sanitary survey schedule
And
My PWS will notify MassDEP /DWP in writing (with the
statement “All cybersecurity items addressed”) at
program.director-dwp@mass.gov, Subject: CSCAP, when all
findings have been addressed.
To protect sensitive data your PWS email response should not
include any sensitive information.
The following items are recommended to improve your PWS cyber program and ability to provide safe drinking water. These
recommended items are not required. However, if MassDEP/DWP determines at the next inspection/survey or at a later date that the
item(s) is necessary to improve your systems cybersecurity program the item(s) may be elevated to Table B findings. Please indicate
(by checking the box) your PWS plan of action for the following recommendations by checking the boxes for each
recommendation your PWS plans to take or utilize.
Table C: RECOMMENDATIONS
MassDEP/DWP Recommendations
Apply for MassDEP DWP Cybersecurity Improvement Grant: https://www.mass.gov/info-details/public-water-
suppliers-cybersecurity-improvements-grant-program
MassDEP DWP Self-Paced Course on Basic Cybersecurity Measures for Water and Wastewater Systems in
Massachusetts (1 TCH) - Enroll Here Free: https://classes.wateroperator.org/courses/cybersecurity
Sign up for the federal Cybersecurity and Infrastructure Security Agency (CISA) no cost vulnerability scanning
subscription service: https://www.cisa.gov/resources-tools/services/cisa-vulnerability-scanning
Apply Today for Municipal Cybersecurity Awareness Grant Program (MCAGP) and Receive Free Cybersecurity
Training for Your Staff https://www.mass.gov/info-details/municipal-cybersecurity-awareness-grant-program
4 | P a g e
Free Cybersecurity Health Check Program- Office of Municipal and School Technology (OMST)
https://www.mass.gov/info-details/cybersecurity-health-check-program
Use MassDEP/DWP PWS Cyber incident plan Template - https://www.mass.gov/doc/cybersecurity-incident-response-
template/download
The Mass Cyber Center: MA Municipalities-Cyber Resilient Massachusetts Grant Program. Learn More & Apply
Here: Notice of Funding Opportunity for Cyber Resilient Massachusetts Grant Program | MassTech
Sign up for Multi-State Information Sharing and Analysis Center (MS-ISAC)- Free for U.S. State, Local, Tribal &
Territorial Government Entities https://www.cisecurity.org/ms-isac
Use the EPA Water Utility Response On-The-Go Plus Mobile Application- tool designed for water utilities responding
to emergency incidents including cybersecurity: https://www.epa.gov/waterutilityresponse/water-utility-response-go-
plus-mobile-application
Review the cybersecurity attachment in the MassDEP/DWP biweekly newsletter. This newsletter includes important
information, including security updates, resources, and alerts https://www.mass.gov/info-details/in-the-
main#cybersecurity,-emergency-preparedness,-and-you!-
Review MassDEP/DWP Cybersecurity Resource Hub: Include resources and alerts for PWS to improve cybersecurity
defenses, mitigate cyber-attack risks, and enhance overall resiliency and compliance.
MassDEP/DWP posters with cybersecurity tips to inform your staff and help keep your systems
secure https://www.mass.gov/info-details/public-drinking-water-system-operations#cybersecurity-
Join MassWARN at https://www.mawarn.org/
Other:
Section III- Certification
I certify under penalties of law that I am the person authorized to fill out this form and the information contained herein is true, accurate,
and complete to the best extent of my knowledge and my PWS will annually update MassDEP DWP when changes are made to our ERP
including cybersecurity by completing the form https://www.mass.gov/doc/emergency-response-plan-erp-compliance-checklist/download
and submitting it along with our Annual Statistical Report required by 310 CMR 22.15(5)e.
Water Commissioner, Owner, Owner Representative, or Other Responsible Party:
Signature: Date: 2/13/2025
Print Name: Giovanna Z. Recinos
Section IV- For MassDEP DWP Use
Title: Water & Sewer Engineer
Attachment #3
Attachment #4
Gallows Hill Tank Recommendations.xlsx
Report Section Recommendation Category Priority Proposed Timeline to address recommendation
Exterior Ladder We recommend installing a lockable ladder guard at the bottom of this ladder to deter
unauthorized access of this structure.Security 2 by November 2025
Exterior Ladder We recommend installing a flexible cable safety climb fall protection device to meet OSHA
1910.28 Personal Fall Arrest & Ladder Safety Systems.Safety 2 by November 2026
Exterior Overflow
EPA requires all overflows to terminate within 12"-24" above an inlet structure, splash pad or
engineered rip-rap to protect against the inhalation of contamination and prevent erosion that
could washout the tank supports or foundation. We recommend modifying this overflow to meet
these requirements.
Sanitary 2 by November 2027
Interior Floor
We recommend washing these surfaces using an NSF 60 approved cleaning agent to remove
the stain/biofilm from these surfaces, followed by a clean water rinse to remove all cleaning
residue.
Sanitary 2 by 2029 during next interior inspection***
Exterior Roof Establish scope of work for remedial repairs or maintenance. Continue to monitor condition.Coatings 3 by 2029
Exterior Roof We recommend pressure-washing surfaces to include an environmentally approved cleaning
agent for improving aesthetics and to preserve the protective coating.Coatings 3 by 2029
Exterior Wall We recommend pressure-washing surfaces to include an environmentally approved cleaning
agent for improving aesthetics and to preserve the protective coating.Coatings 3 by 2029
Interior Floor Establish scope of work for remedial repairs or maintenance. Continue to monitor condition.Coatings 3 by 2029 during next interior inspection
Interior Manway Establish scope of work for remedial repairs or maintenance. Continue to monitor condition.Coatings 3 by 2029 during next interior inspection
Interior Piping Establish scope of work for remedial repairs or maintenance. Continue to monitor condition.Coatings 3 by 2029 during next interior inspection
Interior Wall
We recommend washing these surfaces using an NSF 60 approved cleaning agent to remove
the stain/biofilm from these surfaces, followed by a clean water rinse to remove all cleaning
residue.
Sanitary 3 by 2029 during next interior inspection
Interior Wall Establish scope of work for remedial repairs or maintenance. Continue to monitor condition.Coatings 3 by 2029 during next interior inspection
Interior Ladder
We recommend installing a non-corrodible ladder having a non-corrodible OSHA approved fall
prevention device throughout its length to provide safe access and egress when entering and
exiting the tank.
Safety 5 by 2029 during next interior inspection
***City is currently having conversation with the vendor that completed the inspection to better understand the findings and if there is a different method we could use to clean the
tank wihout the need to have an empty tank
Attachment #5
Attachment #6
ccdeleg.doc • 05/2012 Page 1 of 1
Massachusetts Department of Environmental Protection
Bureau of Resource Protection – Drinking Water Program
Request for Public Water System Authorization to Delegate, Sub-delegate,
Contract, or Sub-contract Cross Connection Surveyors Responsibilities
Public water systems (PWS) requesting authorization to delegate, or sub-delegate, contract, or subcontract
the review and approval of design data sheets and plans for proposed new installations of reduced pressure
backflow preventers and double check valve assemblies must complete this form in its entirety to satisfy
the requirements of 310 CMR 22.22(3)(q).
1. Public Water System (PWS) Information
Important:
When filling out
forms on the
computer, use
only the tab key
to move your
cursor - do not
use the return
key.
PWS Name
PWS ID #
City/Town
The above named public water system requests the authorization to delegate, or sub-delegate, contract
or subcontract the responsibilities for the review and approval of the design data sheet and plans for the
installation of backflow prevention devices for the protection of cross connections. In approving any
such contract arrangement, the Department requires that all recommendations or findings made by the
contracted certified surveyor, when reviewing and approving data sheets and plans, be submitted on
the public water system letterhead and signed by an authorized person of the public water system.
2. Cross Connection Control Program Contracted Certified Surveyor
The services of the Massachusetts Certified Cross-connection Surveyor named below will be retained
by the public water system to review and approve the design data sheet and plans for the installation of
backflow prevention devices for the protection of cross connections as specified at 310 CMR
22.22(3)(q).
Certified Surveyor Name
Company Name
Street Address
City
State
Zip Code
Phone Number
Cell Phone Number
Email (optional)
Fax Number (if available)
MassDEP Surveyor Certificate Number
Expiration Date
Certification
I certify under penalties of law that this document and that the information contained herein is true,
accurate and complete to the best of my knowledge and belief. The public water system understands
that this completed form will be incorporated into its cross connection control program plan as
previously approved by the Department.
PWS Owner Signature
Date
Print Name
Title
Phone #
Email
MassDEP Use Only:
Reviewed by: (Print Name)
Title
Received on (Date)
Approved on (Date)
Comments
Salem Water Department 3258000
Salem
2/11/2025
Giovanna Z. Recinos Water & Sewer Engineer
978-504-6402 grecinos@salem.com