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Forest River pool replacement RECEIVED i o n FEB 18 2020 ASSOCIATES I Iv c . CITY OF SALEM BOARD OF HEALTH February 13, 2020 PRINCIPALS Ms. Purvi Patel Theodore Barten,PE MEPA Office Margaret B Briggs 100 Cambridge St., Suite 900 Dale T Raczynski,PE Boston, MA 02114 Cindy Schlessinger Purvi.Patel@state.ma.us Lester B Smith,Jr Robert D O'Neal,CCM,INCE Via Fed Ex Michael D Howard,PWS Douglas J Kelleher Subject: EEA No. 16147—Forest River Pool Replacement,Salem, MA AJ Jablonowski,PE Stephen H Slocomb,PE Dear Ms. Patel: David E Hewett,LEED AP Thank you for arranging the MEPA Consultation Session on February 6,2020 at the Project Dwight R Dunk,LPD Site and an extension of the comment period until February 21, 2020. As was discussed David C Klinch,PWS,PMP during the Consultation Session,the MEPA Office requested: Maria B Hartnett • Additional detail on wetlands resource areas at the Project Site and the Project's compliance with the Wetlands Protection Act; ASSOCIATES . Preliminary description of construction sequencing; Richard M Lampeter,INCE • Anticipated post-construction monitoring;and, Geoff Starsiak, LEED AP BD+C • Additional detail on efforts to incorporate energy efficiency measures and on- Marc Bergeron,PWS,CWS site renewables. Alyssa Jacobs,PWS The requested information is provided below. Holly Carlson Johnston Brian Lever Additionally, based on feedback provided by Kathryn Glenn from the Massachusetts Office of Coastal Zone Management ("CZM") at the Consultation Session,the Proponent has incorporated the following adjustments to the Project: 3 Mill&Main Place,Suite 250 . The Proponent has eliminated all impacts to Salt Marsh described in the Maynard,MA 01754 Environmental Notification Form ("ENF"). The shoreline restoration component www.epsilonassociates.com of the Project, including temporary construction activities, will no longer extend 9788977100 seaward of the Limit of Work depicted on the attached figures. As a result, the FAx 978 897 0099 50 square feet ("sf") of Salt Marsh identified in the ENF will not be disturbed by the Project. The removal of concrete, gravel wash from the toe of the seawall, and other debris from below Mean High Water ("MHW") is reflected in the new Limit of Work. ­Ill EE.S 0 E91U7 RONMENTAL COMSLI rA..1 Forest River Pool Replacement(EEA#16147) 2 City of Salem February 13, 2020 • The Proponent is no longer proposing planting any vegetation seaward of the existing seawall (i.e., there is no longer any conversion of coastal beach to salt marsh proposed). • The proposed grading of the shoreline restoration area has also been further developed. As shown on the attached figures,the Project proposes restoring and expanding the Coastal Beach in areas temporarily impacted by the removal of the seawall. In order to remove the seawall, approximately 2,500 sf of Coastal Beach will be temporarily impacted during the construction process. Approximately 150 cubic yards ("cy") of fill located above MHW, largely consisting of coarse-grain gravel remaining from the pool's construction in the early 1970s, will be removed. No dredging is being proposed. • Landward of the existing seawall, once it has been removed, will be graded such that periodic tidal inundation will allow for high marsh species such as salt meadow hay(Spartina patens)and marsh elder (Iva frutescens)to flourish. Wetlands Resource Areas As noted above,the MEPA Office requested additional detail on wetlands resource areas at the Project Site and the Project's compliance with the Wetlands Protection Act. The Project has been designed to avoid alterations to wetland resource areas to the maximum extent practical. Portions of the proposed work will occur within Coastal Beach, Land Containing Shellfish,and Coastal Bank. Compliance with the state and local performance standards for each of these resource areas is described below. Coastal Beach Performance Standards In accordance with 310 CMR 10.27(3) through 10.27(7), activities conducted within coastal beach will contribute to the protection of the interests identified in the Wetlands Protection Act by complying with the following general performance standards: 310 CMR 10.27(3)_: "Any project on a coastal beach, except any project permitted under 310 CMR 10.30(3)(a), shall not have an adverse effect by increasing erosion, decreasing the volume or changing the form of any such coastal beach or an adjacent or downdrift coastal beach." ASSOCIATESF•NCIN€EqS F.N4I RORM Ek4 AL�QNS{I�iANTS Forest River Pool Replacement(EEA#16147) 3 City of Salem February 13, 2020 RESPONSE: The project satisfies this performance standard as it will not have an adverse effect by increasing erosion, decreasing the volume, or changing the form of the coastal beach or an adjacent or downdrift coastal beach. The proposed work within this resource area is limited to the removal of artificially placed materials including gravel fill and exposed concrete pipe. The slight change in elevation caused by the removal of these materials will restore the beach to its natural condition. 310 CMR 10.27(4): "Any groin,jetty, solid pier, or other such solid fill structure which will interfere with littoral drift, in addition to complying with 310 CMR 10.27(3), shall be constructed as follows: a) It shall be the minimum length and height demonstrated to be necessary to maintain beach form and volume. In evaluating necessity, coastal engineering, physical oceanographic and/or coastal geologic information shall be considered. b) Immediately after construction any groin shall be filled to entrapment capacity in height and length with sediment of grain size compatible with that of the adjacent beach. c) Jetties trapping littoral drift material shall contain a sand by-pass system to transfer sediments to the downdrift side of the inlet or shall be periodically redredged to provide beach nourishment to ensure that downdrift or adjacent beaches are not starved of sediments." RESPONSE: This performance standard is not applicable since no groin,jetty,solid pier or other solid fill structure which might interfere with littoral drift is proposed. 310 CMR 10.27(5): "Notwithstanding 310 CMR 10.27(3), beach nourishment with clean sediment of a grain size compatible with that on the existing beach may be permitted." RESPONSE: This performance standard is not applicable since the project does not involve beach nourishment. 310 CMR 10.27(6): "In addition to complying with the requirements of 310 CMR 10.27(3) and (4), a project on a tidal flat shall if water-dependent be designed and constructed, using best available measures, so as to minimize adverse effects, and if non-water- dependent, have no adverse effects, on marine fisheries and wildlife habitat caused by: a) Alterations in water circulation; b) Alterations in the distribution of sediment grain size; and W. EMF€VEERS -r Fll bl R94 ME NTB CCU$ _,A.TS Forest River Pool Replacement(EEA#16147) 4 City of Salem February 13, 2020 c) Changes in water quality, including, but not limited to, other than natural fluctuations in the levels of dissolved oxygen,temperature or turbidity,or the addition of pollutants. RESPONSE: The Project involves minimal work below mean high water that includes removal of artificially placed materials such as gravel fill and exposed concrete pipe.These minor activities will restore the natural form of the beach and best available controls will be utilized to ensure that there will be no adverse effects on marine fisheries and wildlife habitat. 310 CMR 10.27(7): "Notwithstanding the provisions of 310 CMR 10.27(3) through (6), no project may be permitted which will have any adverse effect on specified habitat or rare vertebrate or invertebrate species, as identified by procedures established under 310 CMR 10.37. RESPONSE: The Project is not located in NHESP mapped habitat for rare species and thus it will not have an adverse effect on specified habitat of rare vertebrate or invertebrate species.Therefore,the Project satisfies this performance standard. Land Containing Shellfish Performance Standards In accordance with 310 CMR 10.34(4) through 10.34(8), activities proposed within land containing shellfish will contribute to the protection of the interests identified in the Wetlands Protection Act by complying with the following general performance standards: 310 CMR 10.34(4): "Except as provided in 310 CMR 10.34(5), any project on land containing shellfish shall not adversely affect such land or marine fisheries by a change in the productivity of such land caused by: a) alterations of water circulation; b) alterations in relief elevation; c) the compacting of sediment by vehicular traffic; d) alterations in the distribution of sediment grain size; e) alterations in natural drainage from adjacent land; or f) changes in water quality, including, but not limited to; other than natural fluctuations in the levels of salinity,dissolved oxygen, nutrients,temperature or turbidity, or the addition of pollutants. f N ASSOC1 NGINFEAS E3 FNVIRnkWEMlAL.CONSULTANTS Forest River Pool Replacement(EEA#16147) 5 City of Salem February 13, 2020 RESPONSE: The Project has been designed to not adversely affect land containing shellfish or marine fisheries. The only work proposed within this resource area is related to the removal of artificially placed materials that included exposed concrete pipe and gravel fill.The Project will not alter water circulation, relief elevation,distribution of grain size, or the natural drainage from adjacent land. The Land Containing Shellfish will experience no vehicular traffic, and the proposed activities will not change the water quality of the site beyond natural fluctuations of water quality parameters. Thus the Project satisfies this performance standard. 310 CMR 10.34(5): "Notwithstanding the provisions of 310 CMR 10.34(4), projects which temporarily have an adverse effect on the shellfish productivity but which do not permanently destroy the habitat may be permitted if the land containing shellfish can and will be returned substantially to its former productivity in less than one year from the commencement of work, unless an extension of the Order of Conditions is granted, in which case such restoration shall be completed within one year of such extension." RESPONSE: The Project will require work within mapped shellfish habitat but will ultimately enhance this habitat by removing exposed concrete pipe and other artificially placed materials from the intertidal zone. Given the small area affected by the proposed work in the intertidal zone the impact is regarded as minor and temporary, and the area is expected to be fully restored to its current productivity within one year of the commencement of work.Thus,the Project satisfies this performance standard. 310 CMR 10.34(6): "In the case of land containing shellfish defined as significant in 310 CMR 10.34(3)(b)(i.e., those areas identified on the basis of maps and designations of the Shellfish Constable), except in Areas of Critical Environment Concern, the issuing authority may, after consultation with the Shellfish Constable, permit the shellfish to be moved from such area under the guidelines of, and to a suitable location approved by, the Division of Marine Fisheries, in order to permit a proposed project on such land. Any such project shall not be commenced until after the moving and replanting of the shellfish have been commenced." RESPONSE: The intertidal area to be affected by the project is mapped as suitable habitat for spawning and settlement of European oyster and soft shell clam. No relocation of shellfish is currently proposed since the area is closed to shellfishing, but if required the resident shellfish within the identified work limits will be removed and relocated to a suitable area prior to construction. 310 CMR 10.34(7): "Notwithstanding 310 CMR 10.34(4)through (6), projects approved by the Division of Marine Fisheries that are specifically intended to increase the productivity of land containing shellfish may be permitted. Aquaculture projects approved by the appropriate local and state authority may also be permitted." � � MG lNE ERS ©ENVI RbA MENYAL CBNSU TAN TS Forest River Pool Replacement(EEA#16147) 6 City of Salem February 13, 2020 RESPONSE: The proposed Project is not designed to increase the productivity of land containing shellfish, however by removing exposed concrete pipe and other artificially placed materials from the intertidal zone it is expected that the habitat will be improved. 310 CMR 10.34(8): "Notwithstanding the provisions of 310 CMR 10.34(4) through (7), no project may be permitted which will have any adverse effect on specified habitat of rare vertebrate or invertebrate species, as identified by procedures established under 310 CMR 10.37." RESPONSE: The Project site is not located in NHESP mapped habitat for rare species and thus it will not have an adverse effect on specified habitat of rare vertebrate or invertebrate species.Therefore, the Project satisfies this performance standard. Coastal Bank Performance Standards The coastal bank at the Project site is stable and non-eroding and is therefore considered significant to storm damage prevention and flood control because it provides a vertical buffer to storm waters. In accordance with 310 CMR 10.30(6)through 10.30(8),activities conducted within a non-eroding coastal bank will contribute to the protection of the interests identified in the Wetlands Protection Act by complying with the following general performance standards: 310 CMR 10.30 6 : "Any project on such a coastal bank or within 100 feet landward of the top of such coastal bank shall have no adverse effects on the stability of the coastal bank." RESPONSE:The Project includes the alteration of approximately 40 linear feet of coastal bank where the proposed grades will be blended into the existing topography.The work to be performed within 100 feet of the coastal bank is not expected to adversely affect its stability. In fact, the Project will create a continuous coastal bank that will provide enhanced storm damage prevention and flood control at the site.Thus,this performance standard is satisfied. 310 CMR 10.30(7): "Bulkheads, revetments,seawalls,groins or other coastal engineering structures may be permitted on such a coastal bank except when such bank is significant to storm damage prevention or flood control because it supplies sediment to coastal beaches, coastal dunes, and barrier beaches." RESPONSE: This performance standard is not applicable since no groin,jetty,solid pier or other solid fill structure which might interfere with littoral drift is proposed. EPSILON ASSOCIATES INC. EkGINEERS 13 EkJJR9h MENTAL CCNSN,.TAkTS Forest River Pool Replacement(EEA#16147) 7 City of Salem February 13, 2020 310 CMR 10.30(8): "Notwithstanding the provisions of 310 CMR 10.30(3)through (7), no project may be permitted which will have any adverse effect on specified habitat sites of rare vertebrate or invertebrate species,as identified by procedures established under 310 CMR 10.37." RESPONSE: The Project site is not located in NHESP mapped habitat for rare species and thus it will not have an adverse effect on specified habitat of rare vertebrate or invertebrate species.Therefore,the Project satisfies this performance standard. Construction Sequencing At this stage of the Project design, construction sequencing and management protocols have not been fully developed. During the procurement and permitting processes the City will work with the contractors selected to perform the work,the Salem Conservation Commission and regulatory agencies, as necessary, to establish and further define construction sequencing and management protocols. The City anticipates that once the required approvals have been secured, upland site work, including restoration of the bathhouse and removal of portions of the existing pool structure will commence first. Proposed construction mitigation measures include the use of best management practices ("BMPs") to minimize construction related impacts. To protect the environment during the construction phase, measures to control stormwater in the work zone and construction staging and stockpiling area(s)will include sedimentation control barriers installed around erodible stockpiled materials. Contractors will also be required to perform periodic inspections to ensure compliance with the anticipated conditions of the Project's Order of Conditions. Prior to removal of the seawall and any work seaward thereof, the City expects to field locate all areas of salt marsh within proximity of the work area and install flags or other symbolic stakes around the perimeter of the salt marsh identified during the delineation process. Siltation barriers, coir rolls,and other protective measure, as necessary,will be installed. To the extent feasible, site grading and non-structural stabilization landward of the existing seawall will be performed prior to removal of the seawall. The City will work with contractors to minimize the duration of construction activities in wetland resource areas and will ensure that equipment access routes to those areas are located to minimize construction impacts to the extent practicable. To that end, contractors will be expected to define manageable work areas seaward of the seawall in which activities can be completed within three hours of either side of low tide. Work seaward of the existing seawall will be timed to commence once tidal waters have fallen sufficiently and at no time work will occur within open water of the intertidal area. The use of mechanical ICI M£ERS®EM-ROAMER- C. U IA.TS Forest River Pool Replacement(EEA#16147) 8 City of Salem February 13, 2020 equipment within wetlands resource areas will be minimized and the removal of existing concrete debris and gravel washed from the toe of the seawall, for example, will be removed by hand when feasible. Priorto planting the high marsh and coastal bank species landward of the existing seawall, the area will likely be stabilized with a biodegradable erosion control blanket overlaid by a layer of coir fabric, both of which will be anchored to the top of the bank. The high marsh and upper elevations of the coastal bank will be nourished with imported materials, as necessary, to establish the plantings and provide stability. The blankets, mats and imported material will serve to hold the growing medium in place until the plants become established. Pre-vegetated coir fiber rolls underlain with coir fabric may be installed at the toe of the bank, to improve stability, protect to the toe of a bank, and provide a window of opportunity to establish vegetation. An anchoring system appropriate for the expected site conditions will be installed across the face of the rolls and into the undisturbed soil below. Work will begin at the toe of the bank with higher density rolls and proceed landward. Compatible sediment will be used to provide cover for the rolls. A temporary, automated above-ground irrigation system may be necessary in the first growing season while plants are establishing. If an irrigation system is required, it will be removed after the plants have taken hold. Temporary "snow-fencing" will be placed at the top of the bank and seaward of the high marsh area and kept in place during the growing season (mid-April to mid-October).The fencing on the seaward side will serve to prevent materials from floating into the planting area while the landward fencing will prevent people from entering. Anticipated Post-Construction Monitoring Following construction, the restoration area will be monitored by qualified personnel from the City of Salem. The specific details of the monitoring protocol will be developed in consultation with the Salem Conservation Commission and resource agencies. Annual Monitoring Years 1 to 3 Field inspections are anticipated to occur twice per year forthree years(spring and August or September in Years 1 through 3) and then annual inspections going forward, as described below. Maintenance inspections during this three-year period will focus on the general health and vigor of plant stock; substrate settling; coir placement/condition; erosion/deposition; and impacts from wave action. Invasive plants, i.e. Phragmites australis and Lepidium latifolium (pepperweed), if present, will be controlled by hand pulling and proper disposal as soon as noticed to avoid any long-term degradation of the ! E.NFfNE ER&�FNVf RONM4 N4A1 GONSII..TANTS Forest River Pool Replacement(EEA#16147) 9 City of Salem February 13, 2020 marsh area. Any loose netting material, anchors, stakes or other material installed to support the restoration area will be examined and fixed, as necessary. Large debris and trash will be removed from the restoration area. Additionally, the August/September inspection will include the documentation of plant species present and percent coverage. As noted above, the specific details of the monitoring protocol will be developed in consultation with the Salem Conservation Commission and resource agencies and, in general, a target of 75% cover by native salt marsh plant species will likely be the measurement of restoration success. Photographs of the restoration area will be taken from fixed stations to document the coverage and plant species during each monitoring event. Semi-quantitative estimates of species cover will be achieved by a standard point-intercept survey method; and/or vegetation quadrats to quantify the percent cover of marsh vegetation. Transects may be used for replicable measurements. Written reports summarizing the results of these monitoring events will also be prepared. Annual Monitoring(Years 4 and 5) Annual monitoring of the salt marsh will likely be conducted during post-construction Years 4 and 5 during the months of August or September to document plant species present and percent coverage. The specific details of the monitoring protocol will be developed in consultation with the Salem Conservation Commission and resource agencies and,in general,a target of 75%cover by native salt marsh plant species will likely be the measurement of restoration success. Photographs of the restoration area will be taken from fixed stations to document the coverage and plant species during each monitoring event. Semi-quantitative estimates of species cover will be achieved by a standard point-intercept survey method; and/or vegetation quadrats to quantify the percent cover of marsh vegetation.Transects will be used for replicable measurements. Written reports summarizing the results of these monitoring events will also be prepared. EnergV Efficiency Measures and On-site Renewables As noted in the ENF, the City is focused on minimizing the Project's contributions to climate change by striving to achieve net zero energy consumption by incorporating sustainable and energy efficient building design measures and systems across all elements of the Project. The City is evaluating means to rehabilitate the bathhouse as a net zero building that will not consume fossil fuels on-site and will achieve certifiability under the Sustainable Sites Initiative ("SITES") V2 Rating System through strategies that include: reduction in water demand, filtration and reduction of stormwater runoff, reduced energy consumption, and increased recreational opportunities. FhtC,i.IiF CAC F&tit-R63 fY iIiENTA[.Cd N4U."A AsT• Forest River Pool Replacement(EEA#16147) 10 City of Salem February 13, 2020 The pool and bathhouse are intended for seasonal use and, during the shoulder seasons, limited areas of the bathhouse,including the proposed community room,will be available for public and private functions. Most of the bathhouse will not be heated during the off- season and those portions of the building will not require an insulated thermal envelope. For the purpose of achieving lower temperatures within the bathhouse during the summer season, a minimum of R-20 roof insulation and high albedo roofing covering will likely be installed. It is anticipated that air conditioning and heating are both required to condition the community room,entryvestibule,office,two bathrooms,and the controller room. In those spaces,wall and roof structures will be constructed with a minimum R-32 and R-50,respectively. Air source heat pumps("ASHPs")are being evaluated to condition those spaces. An energy recovery ventilator("ERV") is being evaluated for reclaiming up to 80% of the energy required to heat and to cool incoming outside air to comfort conditions. Ventilation for the public bath and shower rooms may function using only passive means for the required air flows and a back-up fan powered system will be included to help enhance drying of wet surfaces. All heating, ventilation and air conditioning ("HVAC") systems will likely use energy efficient electronically commutated motors ("ECMs"), and temperature and ventilation controls will be used to minimize operation. High-performance windows and thermal curtains will likely be installed in the community room. For heating domestic hot water ("DHW"), an ASHP making use of ambient warm air may be used to supply the DHW to code required temperatures during the summer months. Solar thermal systems are also being evaluated for DHW while instantaneous electric resistance DHW heaters will likely be used at the two year-round bathroom sinks. The lowest feasible water use/flow fixtures will be used to reduce water consumption and heating energy for DHW. To the extent feasible, lighting for interior and exterior illumination will use LED fixtures and lamps. Lighting controls will include occupancy and daylight sensors as well as time switches to limit on-times for exterior fixtures. Although no fossil fuels are planned to be consumed on site, electrical power is required for DHW, space conditioning, lighting and motive power (pumps and fans). In order to construct a net zero facility, solar electric photovoltaic ("PV") systems will be used to offset the predicted annual consumption. The size of the PV system will be calculated once a final design approach is selected for the electrical systems and an estimate of annual consumption can be calculated. It is anticipated that the bathhouse and life guard shelter will host roof-top PV systems and additional PV, if necessary, can be installed on shade structures or other appurtenances. Preliminary analyses of on-site PV capacity suggest the facility's annual electric demand can be met on site. EPSILONENGINEERS F.NYf R9NM£NTaM1 t.CCNSUI.,rANTS Forest River Pool Replacement(EEA#16147) 11 City of Salem February 13, 2020 The Proponent thanks the MEPA office and CZM for their thoughtful review of the Project. Should you have any further questions please feel welcome to contact me at your convenience at: erexford@epsilonassociates.com or 978-897-6241. Sincerely, Erik Rexford,Senior Planner EPSILON ASSOCIATES, INC. Cc ENF Circulation List Edward Reiner, US EPA Eric Carlson, MassDCR N.Tay Evans, MassDMF FNfIN F_HS FNVIRfkfd FNTAt..G9HSN_iAHRS