SOUTH RIVERKimberley Driscoll
Mayor
David H. Knowlton, P.E.
City Engineer
October 30, 2007
Mr. Kevin Brander, P.E.
City of Salem, Massachusetts
Wastewater Management Section Chief
Department of Environmental Protection
205B Lowell Street, Wilmington, MA 01887
Department of Public Services
120 Washington Street, 4th Floor
Tel. (978) 745-9595 Ext. 5670
Fax (978) 745-0349
Re: Notice of Noncompliance — NON -NE -07-1N007
Dear Mr. Brander:
This correspondence is in response to the above referenced Notice of Noncompliance (NON)
received by the City of Salem, Massachusetts on September 6, 2007. Please know that the City of
Salem takes the health of its storm water receiving water bodies very seriously, as evidenced by
our immediate voluntary notification to DEP and elimination response to the pollution source
found on the South River. As demonstrated, we have been and will remain aggressive in our
actions to identify and remove pollutant sources. We are confident that we can take the necessary
steps to locate and eliminate the pollution source at the Derby Street Outfall in a timely manner.
South River Illicit Connection Removal:
A final report on this project was transmitted to you on October 22, 2007. The pollution source
was identified and removed from the system. The City considers this project completed, with no
further action necessary.
Derby Wharf Illicit Connection Investigation:
Until receipt of the NON, the City was not aware that DEP sampled this particular location on June
21, July 2 and July 17, 2007 and found pollution at the outfall. The latest sampling data the City
had regarding pollution at Derby Wharf was in the form of the May 17, 2007 monitoring results
from Salem Sound Coastwatch (included for reference in the City's June 18, and 19, 2007 scope of
work submittal for the South River Project), which indicated only a slightly elevated level of 150
Notice of Noncompliance — NON-NE-07-IN007 October 30, 2007
Page 2
per 100 mL for Enterococci. In addition, historical sampling data showed no worse pollution
found at the Derby Wharf Outfall than any other of the multiple outfalls being monitored by Salem
Sound Coastwatch.
Upon receipt of the NON, the City immediately began its investigatory efforts to locate and
remove possible illicit connection(s) in the Derby Wharf system. The City will follow the same
scope of work on this system which successfully eliminated the illicit source on the South River,
and provides the following as a status report to DEP:
1. The drainage and sewer systems in the area have been mapped (copy attached), to establish
the limits of each.
2. All manhole and catch basin structures have been inspected to ascertain the connectivity of
both systems.
3. Stormwater sampling efforts, during both dry and wet weather periods have been
inconclusive (results attached).
4. During a September 27, 2007 City site visit to the outfall, tidewater was observed flowing
into the outfall pipe. Due to prevailing winds at the time, the tidewater was observed to
have extensive pollution floating in it, including a thick layer of scum, vegetable waste and
a skunk carcas, all of which were flowing in the direction of and into the outfall pipe as the
tide rose. These conditions were also observed by DEP personnel Joe Nerden and Greg
Tomasweski. All parties agreed that the inflow and outflow of this poor water adversely
impacts the water quality in the stormwater system and affects the reliability of sampling at
this location. At a minimum, future water quality sampling at this location needs to
reference the tide cycle, tide height, prevailing winds and surface water quality at the
outfall location.
Moving forward, the City will clean and internally inspect the stormwater system to further
identify potential pollution sources. It is anticipated that reliable sampling cannot be collected
from this location until the tidal debris is cleaned from the system and a tide gate is installed that
prevents pollution sources in the harbor from entering the system. Further investigatory efforts,
including, but not limited to dye tracing and flooding and smoke testing may also be utilized to
identify potential pollution sources in the system for removal.
The City is not yet confident that past sampling results were not impacted by the observed
conditions and hereby requests that this remaining issue of the NON be considered closed until
subsequent sampling can be correlated with the tide, wind and debris or ideally following the
installation of a tide gate. The City plans to continue its investigations and is confident that if any
pollution source is found in the drainage system, it will be eliminated through the scoped tasks
described herein.
Notice of Noncompliance —NON -NE -07-1N007 October 30, 2007
Page 3
As soon as we have further results to report, we will provide them to you. In the meantime, if you
have any further questions, or require additional information, please call.
S' cerely,^
vid H. Knowlton, PE
City Engineer
Attachments
Cc: Kimberly Driscoll, Salem Mayor
Jason Silva, Chief Administrative Assistant to the Mayor
Richard Rennard, Salem Director of Public Services
Joanne Scott, Salem Health Department Director✓
Eric Worrall, Deputy Regional Director; DEP, 205B Lowell Street, Wilmington, MA 01887
Todd Borci, US EPA Region One; 100 Congress Street, Suite 1100, Boston, MA 02114-2023
Matt Liebman, US EPA Region One; 100 Congress Street, Suite 1100, Boston, MA 02114-2023
Bill Dunn, Division of Watershed Management; DEPiCERo, 627 Main Street, Worcester, Massachusetts
01608
\\Salemdc0l\WaterAdmin\DKnowlton\My Documents\miscellaneous\response to DEP NON 10-26-07.doc
Derby Street Area, Salem, MA Test Locations
September, 2007
D2 24" outfall West of Derby Wharf , opposite Orange Street and the Custom House.
D3 Drain Manhole on Derby Street near Kosciusko Street
D4 Drain Manhole on Derby Street near Daniels Street
September 11, 2007 Test Times and Locations
Weather: Fog, 65° F; 0.5" rain ended 1 hr before test.
Loc. Time Results
D2 17:15 12,800
Low Tide Salem = 6:00, 0.4'
September 14, 2007 Test Times and Locations
Weather: Sunny, 70° F last rainfall 9-11-07
Loc. Time Results
D2 10:10 1,360
D3 16:50 920
D4 16:59 12,800
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