GROVE STREET APARTMENTS - CERTIFICATE OF THE SECRETARY OF EEA ON NPC _.. _ The Common wea fth of 914assachusetts
i• __ V'` EXecutive Office of Energy anc EnvironmentafAffa rs
4 �4. 1.00 Cambridge Street, Suite 900
B0ff14
Charles D.Baker
.GOVERNOR APR 18 2023
Karyn E.Polito
L1EUTENANT'GOVERNOR CITY OF SALEM Tel:(617)026-1000
Matthew A.Beaton BOARD OF HEALTH Fax:(617)626-1081
SECRETARY http://www.,Mass.p-ov/eea
May 8,2015
CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS
ON THE
NOTICE OF PROJECT CHANGE
PROJECT NAME Mixed Use Development—Grove Street Apartments
PROJECT MUNICIPALITY : Salem
PROJECT WATERSHED :North Coastal
EEA NUMBER : 15043
PROJECT PROPONENT ; MRM Project Management, LLC
DATE NOTICED IN MONITOR :April 8, 2014
Pursuant to the Massachusetts Environmental Policy Act(M.G. L. c. 30, ss. 61-62I)and
Section 11.10 of the MEPA regulations (301 CMR 11.00),1 have reviewed the Notice of Project
Change(NPC). The NPC requested that I rescind the scope included in the May 2,2014
Certificate on the Draft Environmental Impact Report(DEIR). Based on review of the NPC and
consultation with State Agencies,I hereby determine that the changes to the project described in
the NPC will reduce the impacts of the project and that further analysis of the project in a Final
EIR is not warranted.
Project Description
As described in the Draft Environmental Impact Report(DEIR) and NPC,the project
consists of the redevelopment of the former Salem Oil & Grease factory site on Grove Street and
Harmony Grove Road.The project includes demolition of existing buildings,bridges, and a
chimney, and remediation of the site. The site is bifurcated by the North River Canal. South of
the canal,the Proponent will constructl29 apartments in three buildings,each with a gross floor
area of 45,256 square feet(sf) and a maximum height of 49.2 feet. The apartment buildings will
be located near an existing residential neighborhood along Beaver Street. Vehicular access to
the apartment buildings and their parking areas will be provided by a reconfigured entrance on
Grove Street south of the canal. The project will also include the re-use of an existing 17,000-sf
commercial office and storage building located on the north side of the canal. The commercial
building is located adjacent to Grove Street and existing commercial buildings. Vehicular access
EEA# 15043 NPC Certificate May 8,2015
to this portion of the site will be provided via an existing driveway on Grove Street north of the
canal. The project will also include a multi-use path along the canal with a non-vehicular bridge
crossing of the canal to provide pedestrian and bicycle access to Harmony Grove Road north of
the site.
Procedural History and Project Change
The Proponent filed an Environmental Notification Form(ENF)in April 2013. The
potential impacts of a proposed vehicular bridge over the North River Canal were identified
during the review of the ENF. The concerns related to the bridge included its potential to
exacerbate flooding along the North River and to reduce the feasible options available to the City
of Peabody and the Army Corps of Engineers in designing improvements to the North River
drainage system to address flooding. The Proponent was required to file a DEIR to further
analyze alternative project designs and access that would not require a vehicular bridge over the
North River Canal. The Proponent filed a DEIR in March 2014 that provided additional analysis
of the project and its impacts. The DEIR identified a project alternative that would not require
the Harmony Grove Road access,but concluded that this option was infeasible due to its
unfavorable traffic safety and operations compared to the Preferred Alternative,which would
provide access from the apartment buildings to Harmony Grove Road and Grove Street.
Comments from MassDEP continued to express concerns about the potential impacts of the
bridge and noted that the Proponent's alternatives analysis had not adequately demonstrated that
the bridge was water-dependent for purposes of Chapter 91 (c. 91)licensing. As a non-water-
dependent use,the bridge could not be authorized without a Variance.
The Scope for the FEIR focused on the need for a more robust analysis of alternative
access routes to the site that would not require a crossing of the canal. The scope also required
additional analysis of issues identified by MassDEP,including potential impacts to the canal
posed by the proposed stormwater management system and associated splash pads and outfalls;
additional information concerning the performance of the stormwater management system; and
design refinements necessary to meet c. 91 licensing requirements for ground floor uses and
pedestrian access. The scope also required additional analysis of the project's Greenhouse Gas
(GHG) emissions and mitigation measures.
As described in the NPC, several changes have been made to the project in response to
comments received from State Agencies during MEPA review. I note that the changes described
in the NPC are generally responsive to the key issues identified for further analysis in the FEIR
scope. The changes include:
• Elimination of vehicular access to Harmony Grove Road via a bridge across the North
River Canal;
• The existing bridge over the canal will be repaired to allowed pedestrian and bicycle
access across the river;
• The pedestrian bridge across the North River linking the residential and commercial
portions of the site has been eliminated from the project design;
• Two previously proposed stormwater outfalls in the North River have been eliminated
from the project and a new stormwater management system has been designed. It will
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EEA# 15043 NPC Certificate May 8,2015
convey drainage to the City of Salem's stormwater system through an existing box
culvert in Grove Street;
• The project will embed two concrete structures in the seawall lining the North River to
replace previously proposed splash pads in the river;
• The volume and flow calculations for the stormwater management system have been
revised,resulting in a new design of the stormwater management system including a
larger proprietary stormwater separator and changes to the elevations of certain bypass
weirs; and
• Additional energy efficiency measures will be incorporated into the building designs,
including the use of Package Terminal Heat Pumps with an Energy Efficiency Ratio
(EER)of 11.9,reductions in light power density in the residential buildings(0.55
watts/sf),and the use of programmable thermostats.
Eliminating the entrance on Harmony Grove Road necessitated other site design changes
to accommodate a single entrance/access for the residential component of the project. The
design of the Grove Street entrance to the apartment buildings and the residential parking lot at
the west end of the site have been modified to allow emergency vehicles to loop through the site.
In addition,the eastern portion of the previously proposed shared use pathway along the canal
will be widened from 10 feet to 14 feet to provide secondary access for emergency vehicles.
Additionally,the number of apartment units has been reduced from 141 to 129.
Environmental Iml2acts and Mitigation
According to the NPC,the changes will reduce the impacts of the project compared to
those described in the DEIR. The area of land alteration will be reduced from 5.9 to 5.7 acres.
The number of vehicular trips will be reduced from 1,144 average daily trips(adt)to 1,061 adt;
and the number of parking spaces will be reduced from 237 spaces to 227 spaces. The project
will use less water,29,280 gallons per day(gpd)compared to 32,000 gpd,and generate 27,450
gpd of wastewater compared to 30,000 gpd. Impacts to to wetlands resource areas have been
reduced. It will impact 60 linear feet of Bank and 50 sf of Land Under Water(LUW)as
compared to 1501f and 850 sf,respectively,described in the DEIR. The project change will
slightly reduce the area of nonwater-dependent use of tidelands from 0.7 acres to 0.6 acres.
Impacts that remain unchanged from the DEIR include the addition of 1.03 acres of impervious
area for a total of 3.2 acres and alteration of 80,000 sf of Bordering Land Subject to Flooding
(BLSF). The project does not meet or exceed any mandatory EIR thresholds pursuant to 301
CMR 11.03.
Project Site
The project site consists of five parcels located at 60 and 64 Grove Street and 1, 3, and 5
Harmony Grove Road in Salem. The total site area is 8.3 acres. It is bounded by Beaver and
Silver Street residential neighborhoods to the south and west,by Harmony Grove Road and
Harmony Grove Cemetery to the north,by commercial and industrial buildings to the northeast,
and by Grove Street to the east. There is a significant change in grade from the project site to the
higher elevation along Beaver Street and Silver Street.
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EEA# 15043 NPC Certificate May 8,2015
The Salem Oil&Grease Company occupied the site for 95 years,until 2006.The site
comprises 2.15 acres of impervious surfaces,consisting of roadways and parking areas,office,
industrial and storage buildings,wood and metal bridges,and other infrastructure.The site
includes buildings listed on the Inventory of Historic Assets of the Commonwealth and is
included within the Blubber Hollow historic area(SAL.A). The Salem Oil&Grease Company
(MHC# SAL.A376)at 60, 64/69 Grove Street,including a commercial building on the north side
of the river and a large industrial building on the south side are included in the Inventory of
Historical and Archeological Assets of the Commonwealth.
The North River Canal flows through the site from the west to the east. It is identified in
the MassDEP Final Massachusetts 2010 Integrated List of Waters as a Category 5 impaired
water body due to taste and odor,sedimentation/siltation,phosphorus,nitrogen,
foam/floc/scum/oil slicks,aquatic macroinvertebrate bioassessments,debris/floatables/trash,and
fecal coliform. Approximately 2.04 acres of the site is located within filled tidelands.The site
includes various wetland resource areas.The Federal Emergency Management Agency's
(FEMA)Flood Insurance Rate Maps(FIRM)for Essex County indicate the 100-year floodplain
elevation 10.0 NGVD on the project site. Areas of Salem and Peabody adjacent to the North
River have experienced considerable flooding due to constrictions that reduce the hydraulic
capacity of the North River.
The site is regulated under the Massachusetts Contingency Plan(MCP)and three Release
Tracking Numbers(RTNs)have been assigned to the site(3-2131,3-22167,and 3-24908).The
site plans identify three Activity and Use Limitation Areas (AULs)associated with RTN#3-
2131.
Permitting and Jurisdiction
The project is undergoing MEPA review and is subject to an Environmental Notification
Form(ENF)pursuant to 301 CMR 11.03 (3)(b)(1)(e),(3)(b)(5),(6)(b)(14), and(10)(b)(1)
because it requires a State Agency Action and it proposes new fill or structure in a regulatory
floodway,new non-water dependent use of waterways or tidelands, generation of 1,000 or more
new average daily vehicle trips(adt)on roadways providing access to a single location and
construction of 150 or more new parking spaces at a single location,and demolition of historic
structures listed in the Inventory of Historic and Archaeological Assets of the Commonwealth.
The project requires a Chapter 91 License(c.91)from MassDEP. It also requires a Superseding
Order of Conditions(SOC)from MassDEP because MassDEP appealed the Order of Conditions
issued by the Salem Conservation Commission. It requires a license(Application for Entry upon
MBTA Railroad,Transit or other Property)from the Massachusetts Bay Transportation
Authority(MBTA).
The project requires a General Permit(Category 2)from the US Army Corps of
Engineers(ACOE)and a National Pollutant Discharge System(NPDES)Construction General
Permit(COP)from the US Environmental Protection Agency(EPA).Also,it will be reviewed
by the Massachusetts Historical Commission(MHC)acting as the State Historic Preservation
Officer(SHPO)pursuant to the National Historic Preservation Act of 1966,as amended(36 CFR
800).
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EEA# 15043 NPC Certificate May 8,2015
MEPA jurisdiction is limited to the subject matter of required State Agency Actions.
Because the project requires a c.91 License for a portion of the site,subject matter jurisdiction is
functionally equivalent to full scope jurisdiction, in accordance with 301 CMR 11.0 1(2)(a)(3).
Therefore,MEPA jurisdiction for this project extends to all aspects of the project that are likely,
directly or indirectly,to cause Damage to the Environment as defined in the MEPA regulations.
These include wetlands, waterways,traffic/transportation,historic resources,contamination,and
construction period impacts.
Review of the NPC
I commend the Proponent for constructively responding to concerns about its potential
for exacerbating flooding.The project changes also eliminate proposed structures in the canal
that are not permittable. I appreciate the Proponent's commitment to additional measures to
increase energy efficiency and further minimize the project's GHG emissions.The NPC is
responsive to the primary issues identified in the FEIR Scope. Outstanding issues,including the
design of the stormwater management system,can be addressed by MassDEP in permitting.
Wetlands, Waterways, and Water Quality
Comments from MassDEP noted that the NPC did not provide detailed information about
the project changes including repairs to the existing bridge over the canal necessary to support
the multi-use path. The NPC also did not provide a detailed description of concrete structures to
be embedded in the seawall in place of the previously proposed splash pads or how these will be
installed. MassDEP stated that it could not comment on the adequacy of the stormwater
management system or the degree to which the project will comply with the performance
standards of the Wetlands Protection Act Regulations. The NPC also did not indicate whether
the proposed widening of the multi-use path would require additional compensatory flood
storage.
The NPC stated that stormwater calculations have been updated and that the first inch of
stormwater will be treated,but did not provide a detailed description or plans showing the
changes to the stormwater management system MassDEP had previously identified questions
regarding the stormwater management system that was proposed,with more detail, in the DEIR,
including documenting groundwater conditions in support of the project's treatment of
discharges from a Land Use with Higher Potential Pollution Load(LUHHPL); additional
information concerning the size and TSS removal ratings of the proposed stormwater Best
Management Practices(BMPs); and providing additional documentation concerning the
suitability of the design, and possible need for a setback of the infiltration field proposed on the
steep slope at the south side of the site.
MassDEP identified a parking area proposed for the existing commercial building that
cannot be authorized under c. 91 in its proposed location. MassDEP had previously requested
more information about the landscaping and design of the riverfront open space and pathway and
what measures may be necessary to ensure safe pedestrian and bicycle access in the vicinity of
the railroad tracks. This information should be provided with the c. 91 license application.
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EEA# 15043 NPC Certificate May 8,2015
I strongly encourage the Proponent to carefully review comment letters,to develop
information necessary to address MassDEP comments and to consult with MassDEP prior to
filing permitting applications.
Massachusetts Contingency Plan (MCP)
MassDEP issued a Notice of Audit Findings to the Proponent on April 16,2015,which
concluded that certain response actions have not been performed in compliance with the MCP.
MassDEP's letter included a schedule for providing additional information,including a
Imminent Hazard soils evaluation,soil sampling in the southern portion of the site,additional
data concerning Total Petroleum Hydrocarbons(TPH)found at the site,documentation of the
extent and nature of tannery wastes found underneath a building to be demolished,and analysis
of surface sediments from the North River. The results of the data collection and analysis may
require an update of the Phase III Remedial Action Plan.
Mitigation
The Proponent has identified the following measures to avoid,minimize and mitigate
project impacts:
• A 10-to 14-foot wide public shared-use pathway and repair the existing bridge across the
North River to provide pedestrian and bicycle access to Harmony Grove Road;
• A new stormwater management system that will meet the requirements of MassDEP's
Stormwater Regulations;
• Implement a Long Term Pollution Prevention Plan to ensure maintenance of the
stormwater management system;
• Implement a Stormwater Pollution Prevention Plan(SWPPP)to minimize water quality
impacts of construction-period stormwater discharges;
• Employ noise and vibration reduction measures during construction,including using
mufflers and muffling enclosure to reduce equipment noise,using quieter operations and
techniques where feasible, and prohibiting the idling of engines in excess of five minutes;
• Employ dust control measures during construction,including spraying building with
water during demolition,street cleaning,and monitor and control spread of exposed soils;
• Resuse or recycle demolition debris to the maximum extent feasible;
• Restore approximately 6,000 sf of Riverfront Area;
• Avoid in-water work in the North River from March 1 to June 1 to prevent impacts to
diadromous fish;
• Remediate contaminated soils adjacent to the river;
• Replace water and sewer utilities at the project site;
• Upgrade sidewalks along Grove Street;
• Upgrade signage and markings at the Grove Street railroad crossing;
• Improve signage at the Grove Street,Mason Street,and Beaver Street intersection;
• Provide a$100,000 contribution to the City for roadway improvements in the area;
• Secure,weather-protected bicycle storage;
• Rehabilitate the 60 Grove Street building which is listed on the Inventory of Historical
and Archeological Assets of the Commonwealth; and
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EEA# 15043: NPC Certificate May 8,2015
• ;Include energy-efficiency measures meeting the Stretch Energy Code into the design of
the buildings to reduce Greenhouse Gas(GHG)emissions,including Package Terminal
Heat Pumps(EER 11.9);reduced light power density(0.55'watts/sf);programmable
thermostats; double-pane, low-e glass with a U value of 0.35;R-30 roof insulation;R-23
wall insulation; cool roofing materials;High-efficiency heating systems using electric
heat pumps with a coefficient of performance(COP) 10 percent more efficient than the
base building code;LED fixtures in the parking lots; and Energy STAR appliances to
reduce plug loads by at least 10 percent below the base building code.
Conclusion
Pursuant to 301 CMR 13.02,I am declining to require a Public Benefit Review for the
project, I am satisfied that the project's impacts to tideland resources can be adequately
addressed during the permitting process.
Based on the information presented in the NPC and consultation with State Agencies,I
find that additional MEPA review,in the form of a Final EIR,is not warranted. MassDEP has
identified information:that will be necessary for permitting of the project. These issues can be
addressed during State Agency permitting.
May 8 2015
Date Matthew A.Beaton.
Comments received:
04/22/2015 Division of Marine Fisheries (DMF)
04/28/2015 Massachusetts Department of Environmental Protection(MassDEP)/Northeast
Regional Office(NERO)
7
Strysky,Alexander(EEA)
From: Carr,Jillian(FWE)
Sent: Wednesday,April 22,20151:38 PM
To: Strysky,Alexander(EEA)
Subject: EEA#15043 Grove Street Apartments
Hi Alex,
MarineFisheries has the following comments regarding the NPC for Grove Street Apartments in Salem(EEA#15043):
• If any in-water or silt producing work is necessary for the proposed repairs of the existing pedestrian bridge
over the North River Channel,MarineFisheries recommends the time of year restriction that has been
previously suggested for the protection of migrating smelt(Mar 1—June 1). We recommend this restriction be
added as a condition to any permits.
• We continue to recommend maintaining a vegetated buffer along the river bank for stormwater dissipation and
aquatic habitat improvement.
• We are pleased to see the elimination of splash pads and widening of the channel,as well as the redesign of
stormwater diversion to the existing municipal system.
Please get in touch with any questions regarding this review,and thank you for considering our comments.
Jill
Jilllan Carr
MA Division of Marine Fisheries
Annisquam River Field Station
30 Emerson Ave
Gloucester,MA 01930
(978)282-0308 x108
(617)727-3337 fax
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}
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Commonwealth of Massachusetts
Executive Office of Energy &Environmental Affairs
LLDepartment of Environmental Protection
,,.I- Northeast Regional Office•2058 Lowell Street,Wilmington MA 01887.978.694-3200
t
i
charies D.Baker Matthew A.Beaton
Governor Secretary
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Karyn E.Polito Martin Struberg,
Ueutenant Governor Commissroner.
April 28,2015
Matthew A.Beaton,Secretary e
Executive Office of RE: Salem
Energy&Environmental Affairs Mixed Use Development-Grove Street
100 Cambridge Street. Apartments t
Boston MA,02114 Grove Street
EEA# 15043
Attn:MEPA Unit
Dear Secretary Beaton;
The Massachusetts Department of Environmental Protection has reviewed the Notice of
Project Change(NPQ submitted by MRM Project Management,LLC for the proposed 152,768 sf
apartment complex and office project on an 8.3 acre site that straddles the North River in Salem
(EEA #15043). The primary change is the elimination of the access road and pedestrian bridge i
across the North River. There also is a reduction in. apartment units from 141 to 129 in three
buildings. In addition,the reuse of an existing 17,000 sf office building and 227 parking spaces are j
proposed. Until 2006,the project site was occupied by the Salem Oil &Grease factory for almost
100 years.Approximately two acres of the project site are filled tidelands.The site is bisected by
the North River Canal. MassDEP provides the following comments.
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Wetlands And Stormwater
Given the limited information in the Notice of Project Change, MassDEP was not able to
evaluate the changes in the project in sufficient detail to determine whether the project complies
with the wetlands regulations and stormwater management standards.
I
The NPC indicates that eliminating the vehicular bridge across the North River would have `
fewer impacts on wetlands resources, including a reduction of inland bank from 150 linear feet(If)
to 60 If, and a reduction of impact to land under water from 850 sf to 250 sf_The impacts to BLSF
remain at 80,000 sf. While this revision to the proposed project is commendable,the NPC has not
explained or shown on plans the revised work that impacts inland bank and land under water, t
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Mixed Use Development-Grove Street Apartments EEA# i 5043
In addition, the Current Proposed Plan (March 2015) shows a 14 foot wide bituminous
concrete path and emergency lane that appears to be wider than previous plans. It is not clear
whether there would be additional filling within the floodplain for this road It also is not clear j
whether this access way will require additional compensatory flood storage or have an adverse j
effect on the previously proposed compensatory flood storage. Given the discrepancies found i
during MEPA reviews in the early plans for compensatory flood storage, this issue should have
been addressed in the NPC. This information is required to understand the potential for
environmental damage and for permitting.
Floodway Encroachment
With the elimination of the new crossings of the North River,the proponent is proposing to
repair the existing bridge for bicycle and pedestrian use. The NPC,however,has not provided plans I
or a description of the repairs proposed. Therefore,it was not possible to evaluate the potential for
wetlands and/or flooding impacts. This information is required to understand the potential for '
environmental damage and for permitting.
Stormwater
It is reported that rip-rap splash pads and new outfalls to the North River are no longer
proposed. Elimination of the new outfalls with rip-rap will address MassDEP's DEIR comments
that the previous stormwater design was not in compliance with Standard 1 in the Stormwater
Management regulations.
The NPC reports that concrete structures will be installed in the
p granite wall to replace �
the riprap pads (under item 6, page 5). Because the design of these structures has not been
described or shown on plans, it has not been demonstrated that the revised outfall design would
conform to the applicable stormwater management standards, and particularly Standard 1.
Therefore,additional information is needed to address this issue.
The NPC has limited content on stormwater, and has not addressed all of MassDEP's
DEIR comments on the proposed stormwater management system. The following comments
from the DEIR have not been addressed.
I
The Stormwater Management Plan Report states, "(s)tommwater infiltration at other
locations on the project site is not practicable due to numerous Activity and Use Limitations
(AUL) areas." The document also clarifies, "The existing paved areas and industrial building
near proposed Outfall #1 are recorded as Activity and Use Limitation (AUL) areas. The gravel i
area between the existing Finishing Building and Building No. 59 near proposed Outfall #2
contain buried drums filled with boiler ash that will be removed as part of the site remediation I
program. The area near Outfall #3 A-9 is documented as containing tannery sludge infiltration
beds that will be remediated.The area near Outfall#4 also is designated as an AUL area." These
areas constitute a Land Use with Higher Potential Pollutant Load (LUHHPL), as explained in
MassDEP comments on the ENF. The stormwater management system needs to be designed to
comply with this standard fully for the areas of new development, and if the standard cannot be ,
met fully for the redevelopment portions of the site,there must be a clear demonstration that the
proposed system includes the best of the best management practices that are practicable. Data I
for three test pits were provided, with notations reporting that the estimated seasonal high j
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Mixed Use Development-Grove Street Apartments EEA# 15043
groundwater table (ESHGW) ranges from elevation 5.9 NGVD to 7.6. However, the plans
provided after the data do not show the location of these test pits, and it is unclear when the test
pits were dug,and how the ESHGW was determined. This should be addressed.
The stormwater management system has been changed since the ENF review.
Downstream Defender and First Defense proprietary separators are now proposed. The
Stormwater Management study provides some information on TSS removal efficiency, including
third-party evaluations for the Downstream Defender, but no information on First Defense was
provided. There also is no information on the sizes of units that are proposed. Therefore,
MassDEP advises the proponent's consultants to review the technology evaluation information
on the UMASS stormwater technology database clearinghouse (www.mastep.nety, as explained
in the Stormwater Management Handbook,Volume 2, Chapter 4 to address the deficiencies. In
consideration of the third-party provided and the rating of 2 on the UMASS website for both
devices, the proponent's consultants should be cautious in the use of the study results when
redesigning the stormwater management system. Although both devices may have a removal
efficiency as high as 70 percent,their sizing,design,and BMP maintenance must adhere as much
as possible to the recommendations in the third-party evaluations and the caveats provided in the
MASTEP Technology Reviews. The total suspended solids (TSS) calculations will need to be
revised to reflect the third-party evaluations, and guidance provided by MASTEP, recognizing 1
that the TSS removal ratings were based on laboratory conditions using a synthetic sand/soil I
mixture.
As explained in the.DEIR,there are limited opportunities for low impact development on
the project site, as currently proposed. Even so, in uncontaminated areas of the site, the
landscape plan could include tree box filters, and walkways and surface parking could be
pervious to minimize the runoff that would contribute pathogens and contaminants. By reducing
the volume of runoff to the North River, these LID measures would be appropriate for
consistency with the Total Maximum Daily Loads for Pathogens within the North Coastal
Watershed. i
The siting of the infiltration basin, within.a steep slope at the property line is reported to be
acceptable because the guidance in the Stormwater Management Handbook,Volume 2, Chapter 2, j
page 104-106 does not have a specific slope setback requirement or restrictions. However,the same
issues appear to be applicable, irrespective of whether the infiltration basins is a surface or a
subsurface basin, and no information is provided in the DEIR to show that the subsurface i
infiltration system will perform as required, that nearby structures will be protected, and that the
slope will remain stable. Unless slope stability calculations demonstrate that the design and slope
will not be compromised, infiltration practices should be set back, a minimum horizontal
distance of about 50 feet from slopes greater than 15 percent.
Waterways,Chapter 91 License
The project will require authorization through a Chapter 91 (c.91)Waterways License as
a portion of the site remediation, the maintenance and improvement of an existing pedestrian
crossing,and the construction and maintenance of a paved publicly-accessible pathway is located
on filled tidelands of the North River. The exact amount of filled tidelands has not been
calculated by the proponent and should be provided in their future c.91 license application. After
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Mixed Use Development-Grove Street Apanments EEA# 15043
reviewing the NPC it appears that only a small portion of 8.3 acre project site is located within
c.91 jurisdiction and the VW acknowledges that only the portions of the project site within c.91 4
jurisdiction must conform to the various performance and substantive standards of the
Waterways Regulations at 310 CMR 9.00.
I
Water Denendency and WRP Comments: 1
The NPC includes a number of changes to the DEIR Certificate issued by the Secretary on
May 2, 2014. Those items within c.91 jurisdiction include: the vehicular access from Harmony
Grove Road and the associated 24-foot wide vehicular crossing over the North River Canal
between 1 and 3 Harmony.Grove Road parcels have been eliminated. Instead,the existing 10-foot
wide crossing is proposed to be repaired and improved for bike/pedestdan access; the previously
proposed 5-foot wide pedestrian crossing over the North River Canal between 60 and 64 Grove
Street parcels has been eliminated; the previously proposed stormwater outfall pipes and rip-rap
splash pads have been eliminated;the previously proposed bituminous concrete path that runs from
the bike/pedestrian crossing along the southern side of the North River Canal to Grove Street is
now shown on the NPC plans as a 10-foot wide concrete path that transitions into a 14-foot wide
bituminous concrete path and emergency lane; installation of a new,proposed 3.5-foot high fence
is planned atop both sides of the existing granite block canal walls; and,there also is an installation
of a 6-foot high fence along side of the existing railroad tracks traversing the project site.
Because the previously proposed 24-foot wide vehicular crossing has now changed to a
repair of the existing 10-foot wide crossing to accommodate bikes and pedestrians, the
Department has determined that this component of the project is now water-dependent, along
with the 10 to 14-foot wide bike/pedestrian path located on the southern side of-the North River
Canal at 64 Grove Street, pursuant to 310 CMR 9.12(2)(a)(4). The remediation of the site
includes the demolition of existing buildings except for the commercial building located on the
northern side of the North River Canal at 60 Grove Street. Said building is located on filled
tidelands and is currently vacant. The associated parking is considered nonwater-dependent
pursuant to 310 CMR 9.12(2)(f)(3). Given that the project site located within c.91 jurisdiction
does not consist entirely of water-dependent uses, the Department has determined that the
proposed project is a nonwater-dependent use project and the standards at 310 CMR 9.51
through 9.52 shall apply.
A portion of the existing commercial building and associated parking at 60 Grove Street
is located within the Water Dependent Use Zone (WDUZ). Because 60 Grove Street lot is
irregularly shaped and fluctuates between 10-95 feet in lot depth,the minimum WDUZ standard
of 25 feet pursuant to 310 CMR 9.51(3)(c)(1) shall apply. As previously stated, said building's
structure will be unaffected, as only new or expanded buildings are prohibited in the WDUZ;
however, the associated parking located within 25-feet of the project shoreline does not comply
with 310 CMR 9.51(3)(c)and 310 CMR 9.32(2)(d),as no parking facility at or above grade for any
use is permitted within the WDUZ. Accordingly, the existing and/or future parking for said
property located within the WDUZ cannot be authorized under c.91 and must be relocated outside
the 25 foot WDUZ.
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Mixed Use Devela ment-Grove Street Aoartmeni s EEA# 15043
Ch_aoter 91 Waterways License Application:
The Department awaits the filing of a c.91 Waterways License Application which meets the
minimum filing standards as set forth in 310 CMR 9.11(3) and includes the Secretary's Certificate
concluding the MEPA review process.
Greenhouse Gas(GHG)Emissions
The NPC indicates that the GHG analysis was revised and now the project"(s)ubstantially
exceeds the requirements of the Stretch Code." There is no supporting information to substantiate
the statement,however.
Massachusetts Contingency Plan/M.G.L.c.21E
The proponent was advised in a correspondence from MassDEP (April 16, 2015) of
deficiencies in prior submittals that must be addressed in a .Supplemental Phase lI
Comprehensive Site Assessment. A copy of that correspondence is attached.
The MassDEP appreciates the opportunity to comment on this proposed project. Please
contact Heidi.Davis(r�state.ma.us, at (978) 694-3255 for further information on the wetlands
issues and if have any questions regarding the Chapter 91,waterways comments please feel free to
contact frank.taormina state.ma.us at (617) 292-5551. For general questions regarding these
comments,please contact Nanc .Baker iDstate.ma.us ,MEPA Review Coordinator at(978) 694-
3338.
Si ely
Viola
Deputy Regional Director
Attachment
cc: Brona Simon,Massachusetts Historical Commission i
Ben Lynch,Frank Taormina,Tom Maguire,MassDEP-Boston
Rachel Freed,Heidi Davis,Joanne Fagan,Chris Pyott,MassDEP-NERD
City of Salem,Planning Board,DPW,Conservation Commission i
City of Peabody,Planning Board,DPW
James Treadwell lI
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Commonwealth of Massachusetts
n
Executive Office of Energy&Environmental Affairs
Department of Environmental Protection"'
Northeast Regional Office-20.513 Lowell Street;Wilmington MA.ol 887 978-094-3k()
Charles 0.Baker
Governor MatthfttA.Beaton
Karyn E.Polito Secretary
Lieutenant Governor Martin Sudberg
Conlinil"nor
Certified Mail 7013 0600 0002 3018 2665 APRIL 16,2015
MRM Project Management,LLC Re:Salem—60 Grove Street
9 Abbott Street
Former Salem oil &Grease
Beverly,MA 01915 RTN 3-2131
Phase R Report
Attn:Mr.Michael Hubbard
NOTICE OF AUDIT FINDINGS
FILE REVIEW AUDIT
PHASE 11 COMPREHENSIVE SITE ASSESSMENT
Dear Mr,Hubbard:
The Massachusetts Department of Environmental Protection(the Departinent or MassDEP)has
conducted an audit of the Phase 11 Comprehensive Site Assessment Reports(Phase II)filed for
the subject site on January 16, 1992 and March 15,2013. The March 15,2013 Phase 11 report
was prepared on your behalf by Luke Fabbri,Licensed.Site Professional(LSP 9988),and was
required by the Administrative Consent Order(ACO-NE-12-3 C004)entered into by MRM
Project Management LLC(MRM)and MassDEP on November 6,2012. MassDEP previously
completed an audit of these reports that was limited in scope,and evaluated if assessment of site
conditions were completed to adequately determine if an Immediate Response Action is
required,pursuant to 310 CMR40.0411(7). The results of that evaluation were previously
submitted to you in a Notice of Audit Findings(NOAF)letter dated August 21,2014. MassDEP has had supplemental discussions with Mr.Fabbri regarding the conclusions of the al
NOAF letter,and has conducted a complete audit of the Phase 11 reports to ensure I original
e that the entire
-npliance with all the requirements listed at 310 CMR 40,0830.
investigation was completed in col
MassDEP staff at the Northeast Regional Off-ice performed the audit. This Notice serves to
revise req4ircinents established,in the August 21,2014 NOAF, and to inform You of the results
of MassDEP's expanded audit of the Phase 11 Reports.
This information is avallai)io in niternnto format.cnii micliollo waters.r-
kalleill,Diversity Director,at 617-202-5751.MY AlassRelaY Service 1-800-439-2370
MassDEP Wellsile:vAWI-MM.90videp
PfInled on flacyclatt paper
2 RTN 3-2131,60 Grove Street,Salem !
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AUDIT OF PHASE II REPORT
The site is approximately 6.7 acres and was historically used as a sand pit,a tannery,a gasoline
storage facility,and most recently for the manufacturing of leather conditioning oil. The
previous industrial operations conducted at the Site have been inactive since 2002,and today the
site consists of six vacant buildings,two concrete slab remnants from historic building
demolition,one large concrete loading dock area,paved areas,a covered bridge,and limited
perimeter fencing. The assessment included testing of soils within the various areas of concern
identified below,and also included limited testing of surface sediments within the adjacent North
t of shallow soils and sediments are outlined
River Canal. The details of the Phase II assessmen
below.
Former Tannery Infiltration Area:
The Phase Il assessment included the collection of soil samples from the former tannery infiltration
(FTI)area. Soil samples were collected from various depth intervals up to a maximum of 6 feet
below grade,and analyzed for various parameters including Extractable Petroleum Hydrocarbons
(EPH),RCRA-8 metals,Volatile Organic Compounds(VOCs),Polyaromatic Hydrocarbons
(PAHs),and Fat-Oil-Grease. The sampling program identified contaminated soils and tannery
sludge that contained very elevated concentrations of arsenic and chromium. Arsenic was identified
at concentrations as high as 440 mg/icg in a soil sample collected from a depth of 0-5 feet below
grade at location FTI-TP-7A. Total chromium was also identified in the FTI area at concentrations
as high as 22,000 mg/lcg in a soil sample collected from a depth of 0-6 feet below glade at location
FTI-TMMW-1.
On September 17,2014,Mr.Fabbri collected 2 additional soil samples from depths of 2 to 4 feet
fi-om within the FTI area. The samples were analyzed for pentachlorophenol(PCP)using EPA
Method 82701). No PCP was identified with a detection limit of 5.6 milligrams/kilogram-
Former.Boiler Ash/Buried Drum Area:
The Phase II assessment included the collection of soil samples from the former boiler ash/buried
drum (BABD)area. Soil samples were collected from 0-3 feet below grade and analyzed for the
same contaminants of concern as identified above. The sampling program identified
contaminated soils that contained elevated concentrations of arsenic and chromium. Arsenic was
identified at concentrations as high as 1,100 mg/kg at BABD-TP-S. Total chromium was
identified at concentrations as high as 510 mg/kg at location BABD-TP-6.
Other Upland Areas of the Site:
The Phase 11 assessment included the collection of soil samples from other areas of the site,as
identified in the Phase II Report, including AUL Area 2,AUL Area 3, Warehouse, SESD Pile,
Site-Wide Samples, the former Tannery Area, and the Finishing Building. Arsenic was
identified at a concentration of 180 mg/kg in a sample collected from 0-3 feet at SW-SB7 near
the Finishing Building, at a concentration of 130 mg/kg in a sample collected from 0-3 feet at
3 1 RTN 3-2131,60 Grove Street,Salem
SW-SB1 near AUL Area 2, and at a concentration of 44 mg/kg in a sample collected from 0-3
feet at SW-SB4 in the AUL 3 Area. Chromium was identified at a concentration of 3,300 mg/kg
in a soil sample collected fiom 1-3 feet at SESD-TP-1 within the SESD soil pile area, and at a
concentration of 230 mg/kg in a soil sample collected from 0-3 feet at FTA-MW2 within the
Former Tannery Area.
North River Canal:
According to a Site Evaluation Report completed by Gulf of Maine Research Center,Inc.in
1988,the Hawthorne tannery at one time discharged liquid wastes directly to the North River
Canal. The length of time for which this direct discharge occurred is not clearly defined in the I
record. At some point in time wooden settling basins were installed adjacent to the North River I�
Canal in the FTI Area.Liquid wastes were discharged to the settling basins,where the solid
particles settled out into the basins,and the liquid was discharged to the South Essex Sewer
system.The highly contaminated soil and sludge that remains in the wooden settling basins is i
evidence of the extent to which this area was used for waste disposal. In the 1992 Phase II i
Report,Weston and Sampson indicate that wooden containment structures are evident,and the
level of contamination drops significantly outside the confines of these structures;however,
reports of direct discharge of waste to the North River Canal highlights the importance of
determining-the nature and extent of contamination released to this water body. In addition,
during a site inspection on April 4,2014,MassDEP observed a pipe protruding from the river
bank,to the southeast of the building that contained the former Cooperage Room.Very little
testing has been completed to determine the extent to which the North River Canal has been
contaminated fiom historical site use,but sediment samples that were collected show elevated I
levels of PAHs and metals.
Tannery Waste Disposal
A review of the Phase II Comprehensive Site Investigation(Phase II)that was completed by
Gulf of Maine Research Center,Inc.in December of 1991,indicates that tannery waste was `
identified in many locations across the property. Leather scraps were identified in the Former
Tannery Area,the Boiler Ash/Buried Drum Area,within the SESD Pile,and beneath the
Finishing Building. In fact,the Gulf of Maine Report indicates that the Finishing Building
Basement Area may have been used by the former leather tannery as a disposal area.
DETERMINATIONS
As a result of the audit,MassDEP has determined that response actions were not performed in
compliance with the requirements of the Massachusetts Contingency Plan(MCP). Violations
were identified that require additional actions to be taken under the supervision of a Licensed
Site Professional(LSP)in order to come into compliance with the MCP. The violations that
were identified are described below. !
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(A) Violation of 310 CMR 40.0411 )
7 — RP's, PRPs and Other Persons undertaking
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response actions.under the provisions of 310 CMR 40.0000 shall continually assess
and evaluate release and site conditions in order to determine if an Immediate
Response Action is required.
MassDEP's original NOAF letter stated that"MRM is in noncompliance with the Massachusetts
Contingency Plan(MCP)for failure to assess and evaluate site conditions in surface soils(0-12
inches),in order to determine the potential for Imminent Hazard(IA)conditions to exist at this site.
In the March 15,2013 Phase lI Comprehensive Site Assessment Report,that was completed on
behalf of MRM by Luke Fabbri,contamination was identified above potential IH concentrations
provided at 310 CMR 40.032.1(2)(b)in several soil samples that were not collected exclusively from
the top 12-inches of the ground surface,but included that interval. In some of these areas,
contamination was identified above Upper Concentration Limits listed at 310 CMR 40.0996. Based
on these elevated soil contaminant concentrations observed at the site,there is a high probability
that contamination is present in soils within the top 12-inches of the surface at concentrations that
could pose an IH to human health.This condition,if present,would requite a new notification
pursuant to 310 CMR 40.0300,and the completion of an Immediate Response Action including an i
IH Evaluation in accordance with 310 CMR 40.0410 and 40.0950."
MassDEP discussed the findings listed above in a meeting with Mr.Fabbri and you on September
10,2014. Mr.Fabbri presented information to MassDEP that indicated he collected soils from
within the top 3 feet of the ground surface firm the most highly contaminated areas,and despite the
very elevated concentrations of arsenic and chromium that were identified,it is highly unlikely that
an IH to human health was present,because no IH condition was identified using MassDEP'S Ili
Evaluation short forms. MassDEP has reviewed this information,and determined that although
MRM is still in noncompliance with the MCP for not collecting surface soil samples,the existing
information is sufficient to support that it is highly unlilely that IH conditions at the site exist due to
arsenic and chromium in surface soils. However,based on the historic use of the majority of the
property as a tannery,MassDEP remains concerned that dioxin could be present in surface soils in
certain areas of the site at concentrations that could pose an IH to human health.Historically,
pentachlorophenol(PCP)was often used as a preservative and biocide in the treatment of animal
hides. A variety of dioxin compounds are commonly found as impurities in technical grade PCP,so
it is not uncommon for dioxin to be found in soil at former tannery sites where high chromium and
arsenic contamination have been identified. The site is not completely secured with fencing and
residential neighborhoods border the site directly to the south and west,so it is critical to identify the
extent to which dioxin contamination may be present in surface soils at this property.
It should be noted that MassDEP completed research on the sampling of sludge from the former FTI
Area for analysis of PCP in order to rule out the presence of dioxins. Although no PCP was
identified in the samples that were collected,this research indicates that PCP degrades relatively
quickly within soils in the environment,and its lack of detection today does not provide evidence
that is was not used historically at the Site and that dioxins,which are persistent in the environment,
do not remain in soil.
5 RTN 3-2131,60 Grove Sheet,Salem
(B) Violation of 310 CMR 40.0833(1)—A Phase II Comprehensive Site Assessment shall
collect, develop and evaluate sufficient information to support conclusions and Opinions
regarding:
a. the source, nature, extent, and potential impacts of releases of oil and/or
hazardous material;
b. the risk of harm posed by the disposal site to health,safety,public welfare and the
environment;and
c. the need to conduct remedial actions at the disposal site.
MassDEP has reviewed all of the information in the site file and determined that the complete I
nature and extent of contamination has not been evaluated at the former Salem Oil & Grease
facility. The required actions necessary to fill the data gaps that have been identified are listed in
the following section. i
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ACTIONS TO BE TAKEN AND DEADLINE FOR TAKING SUCH ACTIONS
Actions are required to correct the violations identified herein. In order to return to compliance,
the following•documents must be submitted to MassDEP within the deadlines established below:
1. A Supplemental Phase II Scope of Work pursuant to 310 CMR 40.0834 must be i
submitted to MassDEP within 30 days of the date of this Notice. At a minimum,the
Scope of Work must include the following details along with a schedule for i
implementation and completion of the specified activities: j
Data Collection-Phase II Comprehensive Site Assessment !
a) Surface Soils-III Evaluation j
• A soil sampling plan is required to assess surface soils(0"-12")for the presence of
dioxins and to determine if an III condition exists at the Site. An acceptable option to I
consider is the use of an XRF field sampling protocol to test surface soils for total i
chromium,with 20%of samples sent in for laboratory analytical confirmation. The total 1
chromium data may be used as a guide to determine the appropriate locations for the '
collection of surface soil samples for analysis of dioxin. MassDEP recommends a 40
foot by 40 foot grid using composite sampling mainly in the Former Tannery Infiltration }
Area,the Former Tannery Area,and the Boiler Ash Buried Drum Area,with an 80 foot
by 80 foot grid for the remainder of the site. The investigation must include the hill slope
area that is closest to the residences,which should also be sampled using a minimum 80
foot by 80 foot grid approach. No sampling needs to be completed in areas covered by
buildings,solid pavement,or along the eastern end of the property which are completely
fenced in. The data for total chromium must be reviewed and 6 samples with the highest
total chromium concentrations must be analyzed for dioxin,with an additional 6 samples
tested for dioxin spread across the remainder of the site. The dioxin data must be
evaluated to determine if it is present at concentrations that pose an Imminent Hazard to
human health in accordance with 310 CMR 40.0426 and 40.0950. If dioxin is found to
be a contaminant of concern,its full nature and extent must be evaluated as part of the
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Phase 1I investigation. It should be noted that MassDEP recommends that congener I
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analysis of dioxins and furans should be completed using USEPA Method 8290.
• It should be noted that MassDEP considered a proposal presented by Mr.Fabbri in a
meeting held in the Northeast Regional Office on January 15,2015,to only collect 2
samples of sludge from the FT1 Area and analyze them for dioxin. Mr.Fabbri proposed
to analyze these samples first,and only expand the investigation if elevated
concentrations of dioxin are identified. Based on the widespread presence of tannery
waste documented in the Gulf of Maine Phase II,the more site wide approach defined
above is necessary.The two samples proposed by Mr.Fabbri,can be included as part of
the overall investigation defined above.
b) Upland Areas
• An evaluation must be completed to determine if contamination exists in surface and
subsurface soil located within the hill slope area on the southern portion of the property, I
beneath and surrounding the Sulfonation building,beneath and surrounding the Pre-
Treatment Facility,and beneath and surrounding Building 59 all the way to and including
the wooded hill slope. MassDEP recommends that at a minimum the soil samples
collected should be analyzed for arsenic and chromium. The sampling beneath the
buildings may be implemented following building demolition.
• TPII above Upper Concentration Limits was identified in surface soils within the
basement of the Office Building and the Cooperage Room. The record shows that the
extent of this contamination was determined to extend 2-3 feet below the ground surface. I
However,there appears to be no analytical data to support this conclusion. The full
extent of this petroleum contamination must be documented,including potential impacts I
to groundwater. MassDEP recommends that at a minimum,all samples collected should
be analyzed for EPH and semi-volatile organic compounds. This work may be
implemented following building demolition. It should be noted that MassDEP
considered information provided by Mr.Fabbri at the January 15,2015 meeting,that the
TPH analytical data was indicative of material such as fish oil which did not present any i
risk to human health. A detailed review of the Phase N completed by the Gulf of Maine i
Research Center,Inc.in 1991,and referenced previously in this letter,indicates that the
type of TPH in these areas was fingerprinted and determined to be paint thinner and
paraffin wax in the soils within the Office Building Basement,No.2 oil or diesel fuel in
soils beneath the Cooperage Room and Finishing Building Basements,and lubricating oil
beneath the Sulfonation Building Basement. Therefore,the work defined above is
necessary,and must be implemented.
• Tannery waste has been identified beneath the Finishing Building. Following building
demolition,the full nature and extent of tannery waste and associated contamination in
this area must be evaluated.
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c) North River Canal
• MassDEP recommends that dioxin analysis be completed for surface sediment samples at
the 5 previously established sampling stations within the North River Canal,with one
additional sample collected and analyzed for dioxin along the bend in the river where the
rail line bridge crosses the canal,because this is a sediment deposition area. This work is
considered necessary,because direct discharge of liquid waste to the North River Canal is j
documented in the site file.
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• It is MassDEP's understanding that you believe contamination identified in the sediments
of the North River Canal is consistent with Local Conditions. In order to provide
evidence for this theory,arsenic and total chromium must be tested in surface sediments
located in the top 0-1 foot of the North River Canal upstream,downstream,and adjacent
to the facility. A statistically significant number of samples must be collected from these
3 areas in order to compare and contrast the 3 populations of data mathematically. The
assessment of these metals will help reduce the cost of this effort,but still supply
MassDEP with enough information to support the Local Conditions argument. The
sample collection areas adjacent to the facility must include the bend in the River where
the rail line bridge crosses the canal,because this is a sediment deposition area.
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2. A Supplemental Phase II Report pursuant to 310 CMR 40.0830 must be submitted
to MassDEP within 180 days of the date of this Notice.The Supplemental Phase II
Report most include the results of the above assessment activities and a Rislc
Characterization pursuant to 310 CMR 40.0900.
PHASE III REMEDIAL ACTION PLAN
The results of the additional Phase II evaluation work may result in necessary modifications to
the Phase III Remedial Action Plan. For instance,the soils contaminated with TPH above UCLs
that have been identified within the basement of the Office Building and Cooperage Room are
not accounted for in the original Phase Ill. If the findings of the additional Phase II work
identified above have an impact on the remedial plan,the Phase III report must be updated.
ADMINISTRATIVE CONSENT ORDER
The March 15,2013 Phase II Report was submitted to meet one of the requirements of
Administrative Consent Order#ACO-NE-12-3C004,which was reached between MRM Project
Management LLC and MassDEP on November 6,2012. Because of the violations noted above,
you are not in compliance with Section III of the Administrative Consent Order(ACO),thus
exposing you to stipulated penalties in the amount of$1,000 per violation for each day,or
portion thereof,that each violation continues. MassDEP will not assess penalties for the
violations cited above,provided that the actions outlined in this Notice are completed by the
listed deadlines established above.
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POST AUDIT COMPLETION STATEMENT REQUIRED
You do not need MassDEP approval to take the actions specified. However,to avoid further i
enforcement actions,you must correct the violations and submit a Post Audit Completion i
Statement in accordance with 310 CMR 40.1170. A copy of the Post Audit Completion
Statement(BWSC-111)can be found at
http://www.mass.gov/deplcleanup/approvaisthforms.htm. I
LICENSED SITE PROFESSIONAL
A copy of this notice has been sent to Luke Fabbri,LSP 9988,the LSP-of-Record for the disposal
site. However,you,not your LSP,are responsible for responding to this notice of audit findings
and correcting the violations identified herein.
LIMITATIONS&RESERVATION OF RIGHTS }
The MassDEP's findings were based upon the accuracy and certainty of the information
reviewed during the audit. These findings do not:(1)preclude future audits of past,current,or
fixture actions at the site;(2)apply to actions or other aspects of the site that were not reviewed in
the audit;(3)in anyway constitute a release from any liability,obligation,action or penalty
under M.G.L.c.21E,310 CMR 40.0000,or any other laws,regulations,or requirements;or(4) I
limit the MassDEP's authority to take or arrange or to require any Responsible Party or .
Potentially Responsible Party to perform any response action authorized by M.G.L.C.21E,
which the MassDEP deems necessary to protect health,safety,public welfare or the !
environment.
If you have any questions regarding this letter or any requirements contained in it,please contact
Christopher Pyott at(978)694-3353. Please reference Release Tracking Number(RTN)3-3121 in
any future correspondence to the MassDEP regarding the site. I
Sincerely,
Stephen M.John on j
Deputy Regional Director
Bureau of Waste Site Cleanup
cc: Salem Board of Selectmen,a-copy/Board of Health,a-copy
Luke Fabbri,LSP#9988,a-copy
NERO/Data Entry: PHASE II/ACTAUD,AUDCOM/NAFVIO j
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