i /'· united itatei environmental protection …of the pop, dated 1/29/86 and prepared by...

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i /"'· UNITED ITATEI ENVIRONMENTAL PROTECTION AGENCY ..EGlON I

J. F. KENNEDY FEDERAL BUILDING. BOSTON. MASSACHUSETTS 02203

June 26, 1986 Mrs. Norine Brodeur 3 waverly Ave. Lowell, HA 01852

Dear Mrs. Brodeur:

At your recent meeting with Michael Deland, our Regional Administrator, I reviewed EPA's response to a number of questions and demands you have posed over the recent months. Because our time was limited and we did not have the opportunity to discuss our responses, I feel i~ would be worthwhile to try .and do so in writing. I understand, however, that many of these items have been brought up and discussed at the monthly status meetings between EPA, the Silresim Trust, DEQE and the involved consultants, meetings to which you have been and will continue to be invited to represent the Silresim community.

) This letter responds to two of your request letters. I am responding to the third, a handwritten •Request for Information ­and Assistance• dated 6-2-86, by a separate letter.

Request tl - Comments on Community Relations, site Safety and sampling Plans

(This document is undated, but written under the heading of •Aye-.: City HomeC'\o•ners•)

COMMUNITY RELATIONS PLAN . ~ 1. Audio ' Visual Aids

The reference to ~udio and visual aids referred to in theI~ !

Community Relations Plan (CRP) apparently refers to Section 1.6 of the POP, dated 1/29/86 and prepared by representativesof the Silresim Trust. In that document it is stated that GZA (consultants to the Trust) would provide •slides or overheads• for formal data presentations, in the context of the regular status meetings and more formal public meetings.· There is no reference to preparing large scale maps. I do understand, however, that GZA has since provided you with 3' x 3' maps for your use.

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number of interested parties, including Philip Gschwend of MIT, whom we understand is your designated technical representative. The Trust has agreed RI/FS deliverable& copy to Mr. Gschwend, one one copy ~o ~ames Campbell at Can adequate distribution. t.ion ·of Mr• . ~schwend as your do •o in voting. ~ t~ · ~dditi~il reproducttonis not warranted.

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i ~ t , 2. EPA to tape status meetings

we have discussed this at length on several occasions. As noted in the CRP, the monthly status meetings are open to representatives of the community. Further, minutes of the meetings are prepared and sent to a number of interested parties, including yourself. I understand your position thatI: such minutes are not adequate and l have suggested that if you wish to present me with your alternate minutes for comparison, I will be happy to compare them and take any steps I feel necessary to improve any shortcomings. In addi­tion, we recently met and I agreed to look at some other ways to improve the minutes of these meetings. However, there is no legal requirement for EPA technical meetings and staff discussions to be taped or videotaped and we will not allow this to be done on a routine basis.

3. Monthly meetings have no agenda, etc.

Agendas for status meetings are frequently prepared as late as the day before or even the day of the meeting, to be sure the latest information is available. My review of the minutes of these meetings has shown that the first item at each meeting is a review of the agenda, followed by an opportunity to make corrections to the minutes of the prior meeting. If there are specific items you wish placed on the agenda, I suggest you contact the Site Manager several days prior to the meeting..J and I am sure he will be happy to include those items on the agenda. By doing so, we can be sure that anything you wish to add to the meeting will be brought up.

4. Citizens Clearing House and National Toxics Campaign need P.O.P.

We and the Trust already provide copies of all materials to a

to send one copy of all to you,.one copy to Lowell Fair Share, one

copy ~o Pollard Public Library and ~ty ·sall. We believe this .is

If you wish to change your ·designa­technical representative, please

:believe that the expense and time involved ~nd•ailing of documents to others

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technical documents. We set the collective technical judgement of EPA, based on what might be expected to be normal urbanized setting such as

3. Notification lists

Residents at the bottom of Main Street and Cottage Place have been added to the list of pcssible locations where need access for work,

4. 0.25 ppm is too high

If you have scientific info~ation to substantiate this, I .suggest you ask that the subject be included the next atatus meeting. not believe a change in this figure

Silresim Trust's consultant, GZA, _their work on •ite and have agreed

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6. :sa-.teie.·~fter.,.._.valuation

Upon completion of analyses and data validation, Laboratories dispose of . ~hese •amples•

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t ., S. Copies of all correspondence

We currently send copies of significant technical correspondence with the Trust, including comments on deliverable approvals and conditional approvals, to Philip Gschwend as the citizen's designated technical representative. We will continue to do so. However, correspondence not of a technical nature and that of a legal nature, such as access lettera, ~notice ~etters etc. will not be routinely copied.

SITE SAFETY PLAN

1. •oirections to saint Johns Hospital•

Directions have been corrected.

2. What is established background on site? Trigger of 10 ppm too high.

No single background level of total organic compounds has been established for the site. Background (upwind) levels are reported for each air monitoring event in various GZA

the trigger at 10 ppm based on DEOE and consultants

levels in an the Silresim location.

we nightand they have been notified.

on the agenda of Absent any supporting '"data, ··1 do

is warran~ed.

does maintain daily logs of to provide you with a copy.

our Contract

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7. ·Gas CJriven sampl.e ·data

GZA has agree() to proviCJe you with a copy of the report we useCJ in making this ' CJecision. 8. Air monitoring at Arrow

Your request for air monitoring in this area has been agree() to anCJ the work incorporate() into GZA's Phase II plans.

· SAMPLING PLAN

1. State to take random split samples

we have spoken to DEOE about this. The state feels that to CJo so woulCJ merely CJuplicate work now being CJone by EPA anCJ that is therefore not needed.

2. •split Samples in our presence and evaluated by people of our choosing":

EPA cannot agree to this. First, •in our presence• would require that GZA or EPA could only do field work when you are there. Second, EPA has a long standing position of using our Contract Lab Program to do our analytical work. The . participating laboratories have been selected under competitivebidding, as required by law, and must follow specific protocols

assure validity of the data.

Comments on well locations

Your specific suggestions as well as suggestions by DEOE, EPA and USGS have been presented and discusseCJ at the monthly ststus ~eetings. We will welcome your comments on the well locations presenteCJ in the Phase II sampling plan. However, it is unrealistic to expect that wells will be CJeveloped in every location that the above parties feel would yieldadditional information about the site•

Original buCJget, etc.

see respons~ to Request 12, below.

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Request t2 - UnCJateCJ letter to EPA anCJ Trustees from Nerine Brodeur

Original budget anCJ quarterly:···

· your request ~~or information on ~he buCJget ~or the RI/FS being CJone b~ QZA ~nCJer ~ontract with the Trust has been given to the Trust. · I ~nCJerstand they have provided you with quarterly Yeports. However, this is up to the Trust as it relates to a private contract.

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2a. Contract between EPA and GCA

· t We do not have copies of this national contract in the RegionalI Office. Nancy Piligian of my staff has already provided you

with information on how to obtain a copy from our Headquarters.

2b. Contract between Trust and GZA

By copy of this letter, I am referring this to the Trust. That contract "is not subject to EPA review and it is up to the Trust to decide if the~ wish to provide you a copy.

3. Map of proposed well locations

This was noted •Received too late• in my copy of your ~equest, so I assume it refers to the large maps you requested earlier. The technical staff involved felt that the maps available ­were adequate for selecting general well locations, recognizingthat changes might have to be made in the field to meet particular situations.

4. Copies of correspondence - notification of well changes

EPA intends to continue its practice of noticing any changesI ~ at well and sampling locations at the monthly oversight and

I planning meeting and not necessarily through written . ._) correspondence or telephone calls. With respect to well

locations, changes often have to be made in the field. In one case, after well locations were agreed to at the monthly meeting, we were notified by GZA that one well had been sited above a sewer pipe. David Webster, our Site Manager, made an immediate visit and relocated the well. The drillers were already in place, so we could not provide advance notification of the changes.

s. state to take split samples l i" -· -see item tl, Sampling Plan, •arlier.

we al8o want to take samples ­-6.

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item 17, Site Safety Plan, earlier

lnput ·on ~11 ·placeaent during next phase

There are two ways of providing your input. We urge your participation in the monthly status meetings. Further, we

~-::-t:-_,.eend -copies :,of .•ll plans .to Phil~p Gschwend, your technical :_-- : .consUltant, --~or 'ilia cCIIUia8nts.

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-6­~~ . ,, ' 9. Log book at site we see no need to provide a log of all persons coming on and going off the site. · As noted earlier in Item ts, Site Safety Plan, GZA has agreed to provide you with a copy of their daily log of work on the site.

10. •Lock the Gate• sign

GZA has asked the Lowell Police Department to check the _gate locks on Turner Street. We believe this will prevent any reoccurrence of that incident when you did discover the gateleft unlocked.

11. Response in writing

By this letter, I am trying to meet this request.

12. Set Agenda for public meeting agreeable to all concerned

EPA's public meetings are designed as a way for us to tell the community what is happening, and hence may not necessarily be "agreeable to all concerned" because we have information we wish to present. If you have items you wish included, I suggest you contact the Site Manager in advance and I ~~ sure he will incorporate your suggestions, to the extent they involve presenting information related to the purpose of the public meeting.

13. Contract B&M to place well on property

This is being done. We expect a well will be sited on B&M property during Plase II.

14. Changes in work plan

Procedures for changing the work plan as developed by CDM are included in the Administra.tive Order issued to Silresim Trust, which was .made available for public comment prior to its becoming effective. Specifically, -see Paragraph S.A ~Modification of Work Plan• of the Agreement to Perform the Remedial Investigation and Feasibility Study work Plan for

·~ the Silresim Chemical corporation Site in Lowell, Massachusetts •\: Appended to 'the Administrative Order, ··a copy of which you

received ·in the summer of .1985.

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~· 15. Access to site to monitor and sample

EPA and its designated representatives have access to the site under the statutory provisions of CERCLA (Superfund), but those provisions do not apply to citizen representatives.If you wish access, you must request it of the site owner.

In the event you are given access, we urge that any monitoringand/or sampling you do meet our OA/OC requirements. Otherwise, we would be unable to utilize or report any data collected.

Sincerely,

~s/.4__Merrill s. Hohman, Director Waste Management Division

cc: J. Balmat S. Bullard, OSWER

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