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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION I

J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211

YIA OVERNIGHT KAIL

June 6, 1991

Anthony DinapoliL'Energia Incorporated c;o Bio-Developaent CorporationThree Executive Park Drive

])(/)Bedford, New Hampshire 03102 OH ::Ir H::ORe: Silresi~ Superfund Site. L9Well. Massachusetts ZITI H(/1 (/IH

Dear Mr. Dinapoli: -13 ::0 ])() -l:l:As you know, the L'Energia Co-generation facility intended for HITI

construction at 2 Tanner street ITIH

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in Lowell, Massachusetts abuts <:I real estate that is part of a Superfund hazardous waste site known as the Silresim Site. Information relevant to yourupcoming activities at 2 Tanner street waa provided to EPA during recent telephone conversations with members of your development team and the Scannell family. EPA has several concerns regardingthis information that warrant our attention. EPA also believes that you should be aware of certain facts pertaining to the Silresim Site that could affect your future activities.

.__..// EPA's paramount concern relates to your potential future use of a portion of the Silresim Site for the storage of vehicles and equipment during the construction phase of your project (seeExhibit 1). There are two facts of which you may be unaware and should be alerted to. The first is the existence of a variety of chemical compounds in the soil of this parcel which pose current and future potential risks to human health. A Remedial Investigation (RI) was conducted for the Silresim Site to primarily determine the nature and extent of contamination and the risks that Site contaminants pose to human health and the environment (March, 1990). The current potential exposure risks that Site contaminants pose to human health include dermal absorption and ingestion of surficial soils on Lowell Iron and Steel's property by children and adults (see volume's I-III of the RI). Please note that the characterization of surficial soils north of the Silresim fence is presently inaccurate because that parcel was regraded by the Scannell's in 1990. However, because soil was not removed froa this property, the detected contaminants and potential exposure risks remain unchanged.

In addition to the potential exposure risks noted above, if this parcel were to be utilized for storage of construction vehicles and equipment, the conveyance of contaminated soil off-site from the tires of these vehicles would pose an additional exposure risk of an unknown character (unless the vehicles were to be decontaminated).

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Our second concern pertains to the numerous monitoring wells and piezometers that have been installed in the vicinity ot the Silresim Site, which are used to characterize the nature and extent of the contamination. These wells are sampledperiodically to track migration of the Silresim contaminated plume. In addition to the wells having a considerable monetaryvalue (equal to replacement cost), EPA places equal value on the ability to track temporal trends in the aquifer by sampling the same set of wells over time. There are several monitoring wells that could either be destroyed or damaged as a result of yourupcoming .activities. Existing monitoring wells that will be located below your intended plant should be properly abandoned according to specifications of the Massachusetts Department of Environmental Protection. Those wells projected to remain under a paved area or in the path of construction vehicles should be refitted flush with the paved surface or ground surface with a locked cap to avoid damage.

Enclosed is an exploration location plan from the Silresim RI which details the location and type of each well associated with the Silresim Site (Exhibit 2). This should assist your project team in ensuring that each well is adequately accounted for and protected. In order for EPA to determine whether your proposedactivities will have an impact on any future response activities at Silresim, we request that you provide us with a copy of general plans and specifications related to your upcomingactivities.

You should also be aware of an agreement for access between EPA and the Scannells which permits unlimited access by EPA to the Scannells' property for purposes of conducting responseactivities at the Site. This access agreement provides that the Scannells cannot obstruct, impede, and/or interfere in any way with EPA's conduct of response activities. EPA has issued a Proposed Plan for remediating the Silresim Site which includes a preferred alternative that will have a long-term impact on the portion· of the Scannells' property which is part of the Silresim Superfund Site (see enclosure). In the future, therefore, EPA or its representatives will be conducting long-term remedial activities on the portion of the Scannells' property which is part of the Silresim Site. This, in turn, may have an impact on your projected use of that property. EPA also has the authority to order access to a site under Section 104 of the ComprehensiveEnvironmental Response, Compensation and Liability Act (CERCLA),42 u.s.c. Section 9604.

Finally, EPA would like to remind you that the Silresim contaminated plume has been detected in close proximity to the site of your projected soil excavations (see exhibit 3). The most recent groundwater sampling effort in the shallow aquifernortheast of the Silresim property was in late 1988. Althoughthe data indicates that the Silresim plume has not migrated into the area of your planned excavations, our data is more than two years old. Therefore, we cannot ascertain that the edge of the

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plume is not under your property. EPA therefore requests that you exercise caution when excavatinq soil at your site.

· ~. As outlined above, EPA has some qenuine concerns about projectedactivities at the Silresim Site. If you have any questions reqardinq these matters, please contact RuthAnn Sherman at (617)565-3666 who .is the EPA attorney for this Site or myself at (617)573-9689. For your information, we are also aendinq a copy of this letter to the Scannell& and their attorney, Mr. James Thompson.

Sincerely,

~~JtLvVL-Leslie McVickar Remedial Project Manaqer

cc: RuthAnn Sherman, Office of Reqional counsel Timothy Conway, Office of Reqional Counsel Philip Scannell III James Thompson, Pepe & Hazard

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) I. FIGURE IS A MOOIFICATION OF FIG-6· 19(GZA,19119J.

FOil ADDITIONAL IHFOIIMATION,SEE FIGURE 1-1 . S'noii!OLS MAY NOT liE THE SAME AS SIClWN IH FIGURE 1-1

2. ANA!.YSIS OF SAIA.ES CQ..LECTED BY GZA (1985,191!6,198B ~,NUS I1983', AND COM (1991).

3 ~~~r~Cffl'~C=_J,1::_yARJ,.~~~~ORATIONS AND AR£ SUI.IECT TO CHANGE WITH Tr•E .

LEGEND:

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TOTAL VOLATILE OIIGANfc OOMf'OlJNDS(IO:'SIIN GROUNDWATER

\!;l~~AL'i'~IC COMI'OUNOS(VOCSIIN ~ONATEP ~ LISTED IH CIOEll OF INCREASING tEP!H '-"' MULTILE\oe. W£'_LSI ·•

@:'1x,1 AI'PAO-TE TOTAL 10: LEVEL BASf:> ON GC SCREENING RES.l.T'S.

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API'fiOI(IMATE OW«;£ OF TOTl'oL IIOC LEVEL (o...J BASED CIN GC SCRUNING RCIJLTS

IHDCATES NOT tETECTED

INDICATES NOT ANALYZED

CXJNT'Ol-"S OF ECUOU. CONCENTRATION OF TOTAL VOLATLE ORGANIC CllMPQ.IHDS 11111111 HIGHEST VOC Qli\ICDITRATION AT EACH LOCATICIN USED FOil CONTOLR f'UIPOSE S

RANGE OF VOC LEVELS BASED CIN loiUTII\.< SA""'-ES

o' 100' 'l!JO'

SILRESIM SITE LOWELL loiAS$ACt1USETTS

SrTE PLAN SHOWING

DISTRIBUTION OF TOTAL VOC'S IN GROUNDWATER (AFTER GZA, 1989)

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