Chlorinated Water Being Dumped into Sligo
- FoSC Letter to WSSC -

Dear Ms. Montgomery;

The Friends of Sligo Creek thank you and Washington Suburban Sanitary Commission (WSSC) staff for taking the time to meet with us on January 20, 2006. We believe the meeting was helpful in filling in details about the major discharge of chlorinated water into Sligo Creek between Thursday, January 5 and Monday, January 9, and about WSSC plans to address the problems created by the release. In this letter, we would like to present information that should aid your investigation, and comment on remedies that could help prevent a similar occurrence in Sligo Creek or other streams that may be affected by WSSC actions.

The Friends of Sligo Creek is a volunteer organization that looks after the creek. Since it was organized in January of 2000, The Friends of Sligo Creek (FoSC) has been very active in holding events that enhance the natural aspects of the park, educate the community, or appreciate the park. We regularly work with the State and Counties as well as other volunteer organizations to further our mission "to restore the health and water quality, natural habitat, and ecological well-being of the Sligo Creek watershed by bringing neighbors together to build awareness, improve natural habitat, and protect our community's heritage." FoSC has been commended for its efforts by Montgomery County and other entities. Our group is just one of a number of citizen groups that is concerned about the Anacostia River, Rock Creek, and Potomac River watersheds. Some are quite newly minted, while others such as the Anacostia Watershed Society and the Audubon Naturalist Society have a long history.

Sligo Creek is a heavily used suburban park. Although much degraded from its natural condition, through the efforts of the State of Maryland and the Counties, as well as volunteers, the watershed is rebounding. Improvements have been made in such things as stream quality, tree cover, removal of fish barriers, and in re-establishing native fish species. Consequently, it came as quite a blow to find out that a massive release of chlorinated water had killed fish and other stream species in as much as a mile of the upper portions of the stream. As I am sure you can appreciate, we are determined to see that the stream recovers and that a similar assault is prevented.

To begin with, from our meeting and a letter that you shared with us [letter of January 18, 2006, from Ramona Montgomery to Dave Lyons, Maryland Department of the Environment (MDE); "PAF 06- WSSC Discharge from Water Utilities into Sligo Creek"], I would like to summarize what WSSC believes to have occurred:

• On January 5, at approximately 11:00 a.m., a WSSC maintenance crew started the draining of a 36-inch water main into Sligo Creek near 1615 Ladd Street. According to WSSC records, the total length of the water main is approximately 7200 feet, extending back to the Wheaton Water Storage Facility.
• On January 9th, at approximately 9:30 a.m., despite the fact that the main was not completely drained, a WSSC crew terminated the drainage into Sligo Creek. Mr. Rudy Chow of WSSC, estimates that the discharge rate was approximately 50 gallons per minute (gpm) for a period of 94.5 hours, resulting in a total discharge of approximately 300,000 gallons of water.
• WSSC admits the discharged water may have been inadequately dechlorinated by the maintenance crew. WSSC believes this was likely due to their inability to use the preferred Best Management Practice (BMP) for discharges. As described to FoSC at the meeting, this would have entailed attaching a section of 15" diameter pipe packed with dechlorination tablets ( these were explained by WSSC to be sodium sulfite tablets, brand name "DeChlor") to the outlet. As there was no way to attach the plastic pipe to the discharge outlet at Sligo Creek, the crew used another BMP technique in which they hung a woven bag of tablets at the outflow and laid another in the creek some 50 feet downstream.
• After the discharge was shut down, the Montgomery County Department of Environmental Protection and the Maryland Department of the Environment notified WSSC that hundreds of dead fish, salamanders, tadpoles, and other stream organisms were found by them in site visits on January 9th and 10th The fish kill included at least seven species. Dead organisms were found from near the discharge point to above Dennis Avenue, about a mile downstream.

1. We suggest that based on eye-witness accounts from residents at the scene that the flow rate was likely much higher than the 50 gpm estimate made by Mr. Chow. Edward Murtagh, Katherine Michels, and Doree Huneven visited the discharge site numerous times from Saturday afternoon until the discharge was turned off on Monday. The flow was consistently high throughout that time. It could be heard from nearby portions of Ladd Street, and to observers, the flow from the pipe was clearly overwhelming the natural stream flow. On Sunday, Katherine Michels inserted a 70 gallon rain barrel under the flow and found that the barrel was filled in approximately six seconds. This last week she returned with Doree Huneven to simulate what a flow of 50 gpm might look like by pouring five gallons of water from a bucket in four seconds (i.e., a little more than one gallon per second). As you can see in the enclosed photos, the flow from the pipe during the actual discharge into the creek is considerably greater. We believe WSSC should further investigate the flow rate and total volume, since it is important to find out whether the volume was as much as ten-fold higher, and if so, how that happened.
2. At our meeting, WSSC seemed to be unaware of the contacts made by residents on the weekend of the discharge. Here is our time-line of that period:
   • Between 2:30 and 3:30 on Saturday afternoon, Katherine Michels, Doree Huneven, and Edward Murtagh became aware of the discharge. All three separately called WSSC at 301-206-4002 and discussed the matter with a female representative, indicating they were worried about the adverse effects on life in the stream.
   • At approximately 4:30 p.m. Saturday, two WSSC staff came to the site where Doree talked to one about neighborhood concern that the discharge might be harmful to the stream. The WSSC representative assured her that the work was safe and routine. Although he noted that the bag of tablets was not contacting the discharge he did not remedy the situation nor promise a remedy. Neither did he remove the open container of "DeChlor" on the ground near the site.
   • On Sunday, as Doree observed that the flow had not abated and chlorine gas was noticeable, she again called 301-206-4002 at WSSC. She talked to a woman identifying herself as "Sharina" (she declined to give a last name). Despite Doree's expressed concerns about possible environmental harm to the creek, Sharina assured her that the situation was not a threat. No staff were apparently sent from WSSC to the site. Doree also left a message with Min Lwin, the WSSC Unit Coordinator, but he did not and has not responded to her call at this date.
   • On Monday morning (January 9) at approximately 9:00 a.m., Katherine and Doree noticed a WSSC crew at the site. They talked to David Goad of WSSC about the situation (it is possible that Min Lwin was there as well). In the conversation that ensued, David Goad said that little or no dechlorination might have occurred over the weekend since the bag was not in the water flow. He justified leaving the bucket of "DeChlor" by saying he thought no one would be near the site. He also said that the storm water management pond should take care of the ill effects of the discharge. Doree and Katherine pointed out to him that the main pond was being drained and stream water diverted from it. He seemed unaware of that.
3. In the WSSC letter to the Maryland Department of the Environment referenced above, WSSC states that the "drainage of this pond [a Montgomery County Department of Environmental Protection managed storm water pond] may have had some role in the fish kill observed by MCDEP." In as much as fish kills were observed upstream from the pond, it appears to us that the discharge of chlorinated water by WSSC was sufficient to explain the vast majority of dead organisms found by the County and the State.

We would like to close with a few comments on the "Mitigation Actions" noted in your letter to the MDE. We applaud the five actions listed. They cover appropriate revising of best management practices for discharge, surveying and fixing discharge pipes that do not accept preferred dechlorination techniques, emphasis on using sanitary sewers rather than streams for "dewaterings", refresher training, and your commitment to a "thorough fact finding investigation."

Added to these actions we would strongly recommend:

• training of employees in the whys and wherefores of environmental stewardship and sensitivity,
• empowering maintenance personnel to shut down an action when an environmental problem may be resulting from a WSSC action, and
• implementing effective communication with government agencies such as the MCDEP, and your customers and area residents (e.g., through a website and telephone recording) when discharges or similar actions are planned or occurring (this should include placing of signs at sites with 24-hour contact numbers. Clearly, had MCDEP been contacted, WSSC would have been aware of the draining of the storm water pond, and MCDEP could have worked with WSSC to avoid the harm that resulted to life in the creek and damage to MCDEP work on the storm water pond.

Thank you for hearing our thoughts and concerns about the unfortunate discharge of chlorinated water into our creek. The membership of the Friends of Sligo Creek are encouraged by the apparent commitment of WSSC to investigate and remedy the matter. We look forward to working with the WSSC on outcomes that fully and truly benefit the community.

Sincerely,

Bruce A. Sidwell
President of the Friends of Sligo Creek
7209 Spruce Avenue
Takoma Park, MD 20912

photographs enclosed

e-mail copies (w/o encl.) sent to:
Andrew Brunhart, General Manager WSSC
Anacostia Watershed Society
Audubon Naturalist Society
Eyes of Paint Branch
Friends of Rock Creek
Honorable Douglas M. Duncan
Maryland Department of the Environment
Montgomery County Council
Montgomery County Department of Environmental Protection
Neighbors of Northwest Branch