Engineering • Construction • EH&S • Energy

Waste • Facility Services • Laboratory

VIA E-Mail

September 7, 2017

EPA Region New England 5 Post Office Sq., Suite 100 Boston, Massachusetts, 02109-3912

Attn: Joseph LeMay P.E.

RE: Comments with Respect to Remediation Program Wells G&H – Southwest Properties

Dear Mr. LeMay:

Thank you for the opportunity to provide written comment regarding the proposed remediation of the Wells G&H Southwest properties as described in the Proposed Plan document distributed in July 2017. Loureiro Engineering Associates (Loureiro) submits these comments on behalf of the current owner, 280 Salem Street, LLC, of both the former Aberjona Auto Parts property and of the property currently referred to as the Holland Arena.

As you are aware, 280 Salem Street, LLC purchased these properties in roughly 2001 and immediately commenced improving both properties. At the Aberjona Auto Parts property these improvements included the removal of several hundred junk automobiles including parts, abandoned storage containers, boats, solid waste and other miscellaneous debris. 280 Salem Street, LLC also constructed an ice rink, referred to as Holland Arena, at the previously vacant property immediately abutting the former auto parts property. All activities were conducted in cooperation with, and in accordance with permits and agreements issued by the U.S. Environmental Protection Agency (USEPA), Massachusetts Department of Environmental Protection (MassDEP), as well as numerous local agencies and departments. 280 Salem Street, LLC has significantly improved the conditions at the properties and improvements have contributed to the reduction of risks associated with any pre-existing contamination.

In providing these comments, 280 Salem Street, LLC reminds the USEPA that the LLC did not cause, contribute to, or exacerbate any of the releases of oil or hazardous materials identified at the properties. All releases identified at the properties occurred decades prior to the LLC’s acquisition of the properties. Further, in providing these comments 280 Salem Street, LLC is not accepting responsibility for the performance of, or costs associated with any of the response actions taken or proposed or waiving any of its rights regarding the properties.

Loureiro Engineering Associates, Inc. 800 Hingham St., Suite 202S • Rockland, MA 02370 • 781.878.1272 • Fax 781.871.0991 • www.Loureiro.com

AN EMPLOYEE-OWNED COMPANY

http:www.Loureiro.com

Engineering • Construction • EH&S • Energy

Waste • Facility Services • Laboratory

LeMay – USEPA September 7, 2017 Page 2 of 4

Loureiro’s comments are limited to the information provided in the Proposed Plan described in the Wells G&H Superfund Site update distributed in July 2017. Loureiro has not had the opportunity to review the significant documentation prepared over the many years of investigation of these properties. Loureiro’s comments are further limited to those elements of the proposed remediation that have a direct effect on activities at 280 Salem Street, LLC’s properties, generally referred to in the July 2017 document as the Aberjona Property.

The Proposed Plan describes remediation on 280 Salem Street, LLC’s properties as generally including:

• Excavation and off-site disposal of approximately 300 cubic yards of soil from the former Aberjona Auto Parts property; and

• Installation of a cap over the area where soil excavation has occurred; and

• Installation of groundwater recovery wells across the former Aberjona Auto Parts property and construction of trenching to convey groundwater from these wells to a water treatment facility; and

• Construction and operation of a groundwater treatment facility in an area proposed for development north of the Holland Arena.

Comments regarding each of these activities are provided below.

Excavation of Soil and Cap.

The Proposed Plan describes the excavation of approximately 300 cubic yards of soil from the Aberjona property. This soil excavation is intended to remove soil exceeding cleanup levels. The proposed plan also describes the construction of a cap in this area and the need to remove soil to allow for the construction of the cap while not reducing flood storage capacity associated with the Aberjona River. The former Aberjona Auto Parts property is currently used for several businesses including automobile repair businesses, a used car sales business and storage for new vehicles. This area is heavily used throughout the day as automobiles are delivered, repaired, stored and returned to business patrons. The proposed excavation and cap construction activities would occur in an area that these businesses use and as such construction would cause significant business disruption to the property.

Loureiro further questions the need for the soil excavation and construction of the cap as it is currently designed. Loureiro acknowledges the presence of soil at concentrations exceeding applicable cleanup standards however we conclude that adequate risk reduction can be achieved through the maintenance of the existing paved surface and controls on future development through deed restrictions (i.e., Activity and Use Limitation, AUL). Maintenance of the existing asphalt surface would both obviate the need for soil excavation and cap construction thus

Engineering • Construction • EH&S • Energy

Waste • Facility Services • Laboratory

LeMay – USEPA September 7, 2017 Page 3 of 4

eliminating the disruption to the auto repair operations, and would provide the necessary barrier between contaminated soil and those who might become exposed to such contaminants. Finally, the existing asphalt cap would provide the same reduction in contaminant migration as the USEPA hopes to achieve with the construction of the proposed cap.

Groundwater Wells.

The Proposed Plan describes the installation of shallow, intermediate and deep groundwater wells on the Aberjona Property. The cited purpose of these wells is to provide points through which groundwater from the site can be collected and treated as part of the overall approach to reduce concentrations of oil and hazardous materials at the properties and to assure that off-site plume migration does not occur. Loureiro understands that several of all of these wells may already exist on the properties. The Plan also briefly describes the installation of trenches and piping to create a network connecting these wells to a groundwater treatment facility to be constructed on the Holland Arena property which is scheduled to be developed.

For reasons noted above, Loureiro and 280 Salem Street, LLC are concerned about the significant business interruption associated with the installation of the wells and trench/piping network. The proposed plan describes a network that would extend across the center of the Aberjona property where a significant number of the automobiles are stored and where effectively all of the traffic associated with site activities must pass. Loureiro recommends that any such piping and well installation work be carefully considered and coordinated in a manner that does not interfere with daily site activities.

Treatment Facility.

Figure 3 of the Proposed Plan depicts the proposed construction of a Treatment Plant to the northwest of the existing Holland Arena. Recognizing that the Figure indicates that the location is “to be determined” 280 Salem Street, LLC is opposed to its placement on the arena property because it is proposed in the location scheduled for an addition to the arena. Holland Arena has proposed its second phase of development on the parcel with a new building and ice surface.1 The plan will expand the arena toward the northwest. As you are aware, the southern portion of this narrow property is occupied by parking and stormwater management structures that support the arena operations. The only portion of the property available for the expansion is toward the northwest. Placement of the Treatment Plant is not compatible with and will interfere with the expansion of the arena facility which is planned for the spring of 2018. Spring construction is scheduled to avoid conflicts with existing ice operations that take place nine (9) months of the year, excluding April, May and June. The cost of the design, permitting and construction of this building and ice surface will exceed One Million ($1,000,000.00) Dollars. Loureiro suggests that it would be appropriate to place the Treatment Plan on either the northwestern portion of the Whitney Barrel property or the Murphy Waste Oil property. Both of these properties will be

1 The LLC’s intent to construct more than one rink on the site was acknowledged by EPA in its letter to the LLC dated May 7, 2004 from Susan Studlien.

http:1,000,000.00

Engineering • Construction • EH&S • Energy

Waste • Facility Services • Laboratory

LeMay – USEPA September 7, 2017 Page 4 of 4

locations where significant groundwater remediation is necessary owing to the presence of both dissolved-phase and non-aqueous phase contaminants in groundwater. It is more appropriate, practicable and equitable that as the bulk of the groundwater contamination is present on these properties. The Treatment Plant should be placed on one or both of these properties rather than on the arena property, which is relatively clean.

Finally, a dog daycare business has been in operation at the property for more than ten years. The dog daycare facility is located inside the building as well as an extensive outside area covered with artificial turf on which the dogs are exercised. The activities proposed at the Aberjona property as well as the other Southwest Properties will significantly disrupt this business’ ability to operate during the proposed two year construction period. First, the work will prevent the use of the site for the daycare business. Second, excavation activities will damage the artificial turf. In all likelihood, the responsible parties will be required to replace the expensive artificial turf in its entirety rather than patch it. Third, the construction activities will be disruptive to property access and egress. Finally, the construction equipment noise will be significantly disruptive to the animals.

Loureiro appreciates the opportunity to provide these comments and to alert the EPA as to present and proposed activities on the properties.

If you have any questions, please contact the undersigned at 781-878-1272.

Sincerely,

LOUREIRO ENGINEERING ASSOCIATES, INC.

Samuel W. Butcher, LSP Vice President

Attachment

cc: 280 Salem Street LLC

' ' \ ' __J

' \ '

188.5' 64·9'

,.._

- INDUS711IAL PARK 1I-P)

REQUIRED EXISTlNG

MIN. LOT AREA, S.F. 40,000 55,834±

MIN. LOT WIDTH, FT. 40 86.8±

MIN. FRONTAGE, FT. 125.0 221.99

FRONT SETBACK, FT. 25 88.1

SIDE SETBACK, FT. 25 25.8

REAR SETBACK, FT. 25 188.5

HEIGHT. FT. 80 22±

HEIGHT. STORIES 7 1

FLOOR AREA RA TIO 0.50 0.18±

LANDSCAPE USEABLE 30% 40% OPEN SPACE (MIN)

@

-------@

EL. 5CJ,53

N

E

38/01/06 N/F

280 Salem St.,LLC 280 Salem St.

No Date Description

Revisions

~ e ·e ~ -~ e w e

VNle C>'.. CB ro Dci N TMH--ii .2 e-t 'll FAB

0 ~ RD1 • i!i E ~ ill ~

"' ~ e.. 0

~ , ~

~ i'e'.. ~..

27.1'

ZONING TABLE

_..---:::

it. Cone. r ment

DOOR SILL EL. 50.34

38/01/05

55,834 sq.ft. 1.28 acres

#270

Bit. Cone. Parking -- / /

/

@

HOLLAND ARENA

LEGEND WATER GATE

HYDRANT

MANHOLE

CATCH BASIN

TELEPHONE MANHOLE

DRAIN MANHOLE

CLEAN OUT

CURB STOP

SEWER MANHOLE GAS SERVICE GA TE UTILITY POLE UTILITY POLE W/LIGHT GUY WIRE HANDICAPPED PARKING

FIRE ALARM BOX

ROOF DRAIN

PROPERTY LINE CHAIN LINK FENCE

-100- CONTOUR LINE

HIGHWAY GUARDRAIL

G UNDERGROUND GAS LINE

ow OVERHEAD WIRE

38/01/04 N/F

Ruth Whitney 256 Salem St.

PLAN REFERENCES & NOTES: 1. MSRD Deed Bk. 33882, Pg. 233

Record Owner: 280 Salem Street LLC

2. MSRD Land Court Plan #3507C MSRD Plan #1251 of 1959.

3. Zoning District: 1-P

4. Existing conditions survey performed by LeB/onc Survey Associates, Inc. on April 6, 2017.

5. City of Woburn FEMA Flood Insurance Rate Map (Map # 25017C0407E, June 4, 2010) indicates that the site is located within a Zone X, which is areas determined to be outside the 0.2% annual chance floodplain.

6. This plan is not to be used to determine exact property lines, nor is it suitable for filing in the registry of deeds.

/ ,,,_%., / $~~

DOOR SILL / EL. 50.35

/ /

DOOR SJL(

~ Griffin w~ Engineering

Group, LLC

495 Cabot Street, 2nd Floor Beverly, MA 01915

Tel: 978-927-5111 Fax: 978-927-5103

HOLLAND ARENA 270 SALEM ST.

WOBURN, MA

SITE PLAN

s~ 1·=20·

Job No.: C-1File Nmne:

D.m; 4/25/17

/ /

/

/ /

GRAPHIC SCALE 20 0 10 20 40 BO

I c----- I I I I ( IN FEET ) 1 inch = 20 ft.

0

EPA Holland Comment Let 090717 2IceArena-270Salem-042717c

barcode: *622330*barcodetext: SEMS Doc ID 622330