Document 2qg2YpYzaE1awXmG6zyV8kVra

UNITED STATESUNITED STATES ENVIRONRMEEGINOTN A1L PROTECTION AGENCY Laboratory Services and Applied Science Division ENVIRONMENT11 TecNhorntho Chlelomsgfoyrd , MDasrsaichvuseett s 01863-2431 ENTAL PROTECTION Drafted Date: 5/25/2022 Finalized Date: 7/7/2022 Subject:Sampling Inspection Report Clean Water Act - National Pollutant Discharge Elimination System City of Lawrence, MA From:Shannon Brunelle, Inspector Laboratory Services and Applied Science Division (LSASD) Field Services Branch (FSB) Reviewed By:Jerome Keefe, Investigations Team Leader, LSASD - FSB To:Denny Dart, Water Compliance Section Chief, Enforcement and Compliance Assurance Division (ECAD - EWC) CC:Todd Borci, Inspector, ECAD - EWC I. Facility Information A. Facility Name: City of Lawrence, MA B. Facility Location: 200 Common St, Lawrence, MA 01841 C. Facility Contact: Brian Pena, Water & Sewer Commissioner bpena@cityoflawrence.com (978) 620-3110 D. NPDES Permit ID: MAR041201 (MS4) II. Background Information A. Date / Start time of sampling inspection: 05/24/22 09:00 AM B. Weather conditions: 65 F, sunny C. USEPA Representatives: Michelle Coombs, Shannon Brunelle D. State / Local Representatives: N / A E. Federally Enforceable Requirements Investigated: Stormwater discharges and certain non - stormwater discharges from the City of Lawrence, MA (the City's) Municipal Separate Storm Sewer Systems (MS4) are authorized by the National Pollutant Discharge Elimination System (NPDES) General Permit for the Discharge of Stormwater from Small MS4 (hereinafter, the Permit), issued by the Environmental Protection Agency (EPA) Region 1. The City obtained coverage under the Permit with NPDES Permit ID MAR04120. F. Pollutants Sampled: Pharmaceuticals and Personal Care Products (PPCPs), E. coli / Enterococcus, Ammonia (nitrogen), Total Chlorine, and Surfactants ED_019088A_00004633-00001 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection III. Disclaimer: Unless otherwise noted, this report describes conditions at the facility / property as observed by EPA inspector(s), and / or through records provided to and / or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. IV. Type and Purpose of Inspection(s) The purpose of the compliance sampling inspection was to identify potential illicit connections or illegal discharges within the Lawrence, MA MS4 that may adversely impact the water quality in the Merrimack River, Spicket River and Shawsheen River. Samples were collected from 6 locations in accordance with the FSB Investigations Team Stormwater Program Plan. V. Permittee Details The City of Lawrence occupies approximately 7.4 square miles in Essex County, Massachusetts, approximately 30 miles from, north of Boston, MA. The City shares borders with the municipalities of Methuen to the north and northwest, North Andover to the east, and Andover to the south and southwest. According to the 2020 U.S. Census, the population of Lawrence was 89,143. The Merrimack River, Spicket River and Shawsheen River are listed as MS4 receiving waters in the city Notice of Intent (NOI) for coverage under the permit. VI. 05/24/22 Sampling Inspection Summary On May 24, 2022, EPA employees Michelle Coombs and Shannon Brunelle (" the EPA Inspection Team ") conducted an unannounced compliance sampling inspection of the Lawrence, MA MS4 at the locations described in Section VII. They were not accompanied by any city or state representatives. The inspection started at northeastern side of the parking lot located at 1 Essex St at approximately 09:00 AM. At the time of the inspection, the weather was sunny and approximately 65 F. According to National Weather Service for the Lawrence Municipal Airport (KLWM), the last precipitation event prior to the inspection occurred on 05/22/22, with 0.22 inches recorded. There was 0.22 inches precipitation recorded within the 72 hours before the inspection. According to the National Weather Service, in the month of May, the City observed 1.85 inches of rain, which is approximately 54% of the 30-year normal value of 3.39 inches. According to the US Drought Monitor, as of 5/25/22, Essex County is experiencing abnormally dry drought conditions. The sampling locations described in Section VII were field screened using test kits for ammonia (nitrogen), surfactants, and total chlorine. In - situ measurements for specific conductivity, salinity, and temperature were also measured using a YSI water quality meter and recorded. Field data were recorded on field data sheets. Samples were delivered to and analyzed for E. coli, Enterococcus and PPCPs at the EPA New England Regional Laboratory (NERL) in North Chelmsford, MA. Table 1 below summarizes the sampling and analytical data. Page 2 of 17 Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00002 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection VII. Description of Sampling Locations (in order of collection time) Photographs depicting each sample location are included in Appendix A of this report. Market01: a single, plastic, circular outfall, approximately 36 inches in diameter, located near the eastern side of the parking lot at 1 Essex Dr. Discharge flow was approximately 5-7 gallons per minute (gpm) into Shawsheen River. Sample was collected at the mouth of the outfall. Dark green / brown algae growth was observed on rocks and a brown film was observed on the pipe. Trash was observed downstream of the outfall. A sewage odor was observed upstream of the outfall. The upstream infrastructure, a manhole and a secondary unseen source, was observed to be leaking onto the ground. Sample preserved with ammonium acetate due to the presence of elevated levels of total chlorine. Law02: a single concrete, circular outfall, approximately 48 inches in diameter, located at the north - west corner of sports field behind 165 Crawford St. Discharge flow was approximately 8-10 gallons per minute (gpm) into Shawsheen River. Sample was collected at the mouth of the elliptical structure surrounding the outfall. A musty odor was detected. Brown algae growth was observed inside outfall. Trash and rags were caught on the grate at the mouth of the outfall. SPI07: a single, concrete, rectangular culvert, approximately 6ft by 4ft in size, located near the southeastern side of the parking lot adjacent to 14 Vine St. Discharge flow was approximately 10 gallons per minute (gpm) into Spicket River. Sample was collected approximately 10 feet downstream of culvert opening. Trash was observed downstream. Some suds and brown algae growth were observed inside culvert. Dup01 collected with sample. MM01: a single, concrete, circular outfall, approximately 26 inches in diameter, located at southern western corner of the bridge located in the parking lot of 550 Broadway St. Discharge flow was approximately 8-10 gallons per minute (gpm) into Spicket River. Sample was collected at the mouth of the outfall using sampling pole. Sudds and trash observed downstream of outfall. Orange staining observed on pipe. Law05A: a single, concrete, circular outfall, approximately 30 inches in diameter, located at 1 Eaton Street, near the north - eastern side of the parking lot adjacent to the Merrimack River. The outfall was 7/8 submerged into the Merrimack River. Sample was collected at the mouth of the outfall. A sheen was observed on the surface of the water inside the outfall. Law05: a single, circular outfall, approximately 48 inches in diameter, located at the left- hand side of the parking lot entrance to 1 Eaton St. Discharge flow was approximately < 1 gallon per minute (gpm) into an unknown tributary adjacent to the merrimack river. Sample was collected at the mouth of the outfall. A milky color and consistency was observed in pool downstream Outfalls not sampled: Law07: Outfall inaccessible therefore no sample collected during sampling event. Page 3 of 17 Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00003 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection Map of Sample Locations Note: the locations on the map were estimated using Google Earth and are used for display purposes only. way ZHowe Hampshire Road Marston Corners 213 113 125 Cross Broadway Prospect SStt SMitl kOaSkt Methuen Pleasant Jackson View St PeSlt h amE aHs t St 28 Holy Family Hospital 110 adow Methuen Spi07 St Railroad Broadw StLawrence LowMM01e Lalwrenlce Park ASt iStgrton pBerkoeleryMutnici pal Elm BarkeHamrpshireH Sto Laswrepncei Getneraal lLaw renSce tMun icipSal tAir portGreat Pond Rd St CBeemeltlee Sv uLaewStr eHn cMe aUinjsotn on SuttSoutnto ns OMisllsg ood Haverhills TOWEERs sHeIxL MLeorwreilmla cSkt SCta nParle sSctotStt Ave Rd Riverside Dr OliveS Market StLAW02 Parker Salem StMain LAW07 BroadLwAoW0 5SAt Chicker SOUTH COMMON Massachusetts River RdAve 1114 33 Pleas LAW05MoQunOt VVeEr!no n WPaarkvNeorrtlh eAnydo vSert St St Market01Glenn MOUNT VERNON $ 2 NSorCth SMtoVuernnotn MUanAnidoovenr JSohtns on ChR and dl er 1 St1 4 Shawsheen Villone Page 4 of 17Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00004 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection Table 1: Summary of Sampling and Analytical Data Site ID Market01 Law02 SPI07 Dup01 Location Sample Date 05/24/22 05/24/22 05/24/22 05/24/22 Sample Time 09:05 09:35 10:52 10:52 Coordinates North42.682495 42.695437 42.715216 42.715216 (decimal degrees) West-71.148770 -71.146327 -71.154100 -71.154100 Salinity, ppt. 0.7 0.8 0.7 N / A YSI MeterTemperature, C13.214.316.1N / A Conductivity, S / cm 1390 1583 1373 N / A Field Test Kits (mg / L) Ammonia 0.25 0.00 0.25 N / A Total Chlorine 0.12 0.00 0.00 N / A Surfactants 0.25 0.50 0.50 N / A BacteriaE. coli 1642 3683 318 N / A (MPN / 100mL) Enterococcus 185 987 96 N / A Cotinine 6.0 1.8 7.5 8.3 Acetaminophen 300 29 32 35 Paraxanthine 100 7.4 3.8 4.1 PPCPs (ng / L)Atenolol 8.5 ND ND ND Caffeine 130 48 32 35 Metoprolol 6.3 2.5 ND ND Diphenhydramine 1.8 0.56 ND ND Abbreviations and Notes: Carbamazepine 3.2 16 0.45 0.48 1. The coordinates listed in Table 1 were derived from the map created in Google Earth, therefore the coordinates are estimates of the actual locations. N / A: Not Analyzed ND: Not Detected above Reporting Limit E. Coli / Fecal Coliform: Red > 10,000 col / 100ml, Orange > 1,260 col / 100ml, Yellow > 410 col / 100ml, Black < 410 col / 100ml Entero: Red 1,000 col / 100ml, Orange > 350 Yellow > 130 col / 100ml, Black < 130 col / 100ml NH3: Red >6 mg / L, Orange > 0.5 mg / L, Yellow > 0.25 mg / L, Black < 0.25 mg / L Cl2: Red 1.0 mg / L, Orange > 0.3 mg / L, Yellow > 0.02 mg / L, Black < 0.02 mg / L Surfactants: Red > 1.0 mg / L, Orange > 0.5 mg / L, Yellow > 0.25 mg / L, Black < 0.25 mg / L (may give false positive at salinity greater than 1 ppt) PPCPs: Dark Pink 2100x the RL; Pink > 10x the RL; Light Pink 23x the RL; No Pink < 3x the RL * * See Reporting Limit (RL) values for each compound in attached Laboratory Report for Source Tracking EPA notes while there are currently no numerical standards to compare pharmaceutical results against, it is EPA's experience that acetaminophen is the single best bacterial source tracking compound of those listed above, and any detection of this compound may indicate a source of sanitary sewage. With respect to all of the above compounds, when a sanitary sewage source is present, depending on the type of source, distance from the sample location, and the strength of the source, concentrations of these compounds may range from the low ng / l range up to thousands of ng / L. Page 5 of 17Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00005 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection Table 1: Summary of Sampling and Analytical Data, cont. Site ID MM01 Law05A Law05 Location Sample Date 05/24/22 05/24/22 05/24/22 Sample Time 11:45 12:40 12:55 Coordinates North42.714613 42.692848, 42.692145 (decimal degrees) West-71.178635 -71.175273 -71.175708 Salinity, ppt.0.4N / AN / A YSI MeterTemperature, C14.2N / AN / A Conductivity, S / cm875N / AN / A Field Test Kits (mg / L) Ammonia 0.25 0.25 0.25 Total Chlorine 0.00 0.00 0.00 Surfactants 0.25 0.25 0.35 Bacteria E. coliND 16 6932 (MPN / 100mL) Enterococcus10ND135 Cotinine 0.76 1.9 4.6 Acetaminophen ND ND 170 Paraxanthine ND 8.0 21 PPCPs (ng / L) Atenolol ND 13 4.2 Caffeine ND 23 110 Metoprolol ND 11 3.5 Diphenhydramine ND 6.5 0.48 Abbreviations and Notes: Carbamazepine 0.95 3.7 1.5 1. The coordinates listed in Table 1 were derived from the map created in Google Earth, therefore the coordinates are estimates of the actual locations. N / A: Not Analyzed ND: Not Detected above Reporting Limit E. Coli / Fecal Coliform: Red > 10,000 col / 100ml, Orange > 1260 col / 100ml, Yellow > 410 col / 100ml, Black < 410 col / 100ml Entero: Red 1,000 col / 100ml, Orange > 350 Yellow > 130 col / 100ml, Black < 130 col / 100ml NH3: Red >6 mg / L, Orange > 0.5 mg / L, Yellow > 0.25 mg / L, Black < 0.25 mg / L Cl2: Red 1.0 mg / L, Orange >0.3 mg / L, Yellow > 0.02 mg / L, Black < 0.02 mg / L Surfactants: Red > 1.0 mg / L, Orange > 0.5 mg / L, Yellow > 0.25 mg / L, Black < 0.25 mg / L (may give false positive at salinity greater than 1 ppt) PPCPs: Dark Pink > 100x the RI; Pink > 10x the RL; Light ight Pink > 3x th the RL; No Pink < 3x the RL * See Reporting Limit (RL) values for each compound in attached Laboratory Report for Source Tracking EPA notes while there are currently no numerical standards to compare pharmaceutical results against, it is EPA's experience that acetaminophen is the single best bacterial source tracking compound of those listed above, and any detection of this compound may indicate a source of sanitary sewage. With respect to all of the above compounds, when a sanitary sewage source is present, depending on the type of source, distance from the sample location, and the strength of the source, concentrations of these compounds may range from the low ng / l range up to thousands of ng / L. Page 6 of 17Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00006 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection VIII. Appendix Appendix A: Photograph Log IX. Attachments Attachment A: Laboratory Report for PPCPs (Source Tracking) Analysis Attachment B: Laboratory Report for E. coli Analysis Attachment C: Laboratory Report for Enterococcus Analysis End of Report Page 7 of 17 Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00007 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection Appendix A Photograph Log Page 8 of 17 Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00008 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection Market01 (photo taken 05/24/22 at 09:05 AM) Outfall located near the eastern side of the parking lot at 1 Essex Dr into an unnamed stream into the Shawsheen River. Sample point is indicated by a red x. Page 9 of 17 Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00009 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection Law02 (photo taken 05/24/22 at 09:35 AM) located at the north - west corner of sports field behind 165 Crawford St into the Shawsheen River. Sample point is indicated by a red x. Page 10 of 17 Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00010 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection SPI07 (photo taken 05/24/22 at 10:52 AM), located near the southeastern side of the parking lot adjacent to 14 Vine St into the Spicket River. Sample point is indicated by a red x. Page 11 of 17 Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00011 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection MM01 (photo taken 05/24/22 at 11:45 AM) located at southern western corner of the bridge located in the parking lot of 550 Broadway St into the Spicket River. Sample point is indicated by a red x. Page 12 of 17 Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00012 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection Law05A (photo taken 05/24/22 at 12:40 PM) located at 1 Eaton Street, near the north - eastern side of the parking lot adjacent to the Merrimack River into the Merrimack River. Sample point is indicated by a red x. Page 13 of 17 Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00013 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection Law05 (photo taken 05/24/22 at 12:55 PM) located at the left - hand side of the parking lot entrance to 1 Eaton St. into an unknown tributary. Sample point is indicated by a red x. Page 14 of 17 Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00014 City of Lawrence, MA (MAR041201) EPA MS4 Compliance Sampling Inspection Attachment A Laboratory Report for Source Tracking Analysis Author: LSASD Laboratory Services Branch Pages: Page 15 of 17 Sampling Inspection Date: May 24th, 2022 ED_019088A_00004633-00015