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64-518 - 72 FLINT STREET - CONSERVATION COMMISSION /JJr __ __.____ �� _ .-.. ___ _.._ _ __-�_. -__ CITY OF SALEM e, CONSERVATION COMMISSION January 23, 2012 Scott Grover Timi, Quinn, Grover& Frey P.C. 27 Congress Street, Suite 414 Salem, Massachusetts 01970 Re: Order of Conditions—DEP #64-518-72 Flint Street (Former Salem Suede) Dear Mr. Gover: Enclosed, please find the Order of Conditions for the above referenced project. Following the 10-business-day appeal period (as of the postmark or hand delivery of this order), this document and the attached Special Conditions must be recorded at the Southern Essex County Registry of Deeds (Shetland Park 45 Congress Street, Suite 4100 Salem, Massachusetts). Once recorded, please return a copy of Page 12 of the Order, which will indicate to the Commission that the document has been recorded. As indicated in the Order, prior to any work commencing: 1. this Order must be recorded, 2, a sign shall be displayed showing DEP File# 64-518 within public view, and 3. contact me at least 48 hours prior to any activity to schedule a pre-construction meeting to review the Order with your hired contractor. Please note in the Order any additional conditions that must be complied with before the start of construction. If you have any further questions, please feel free to contact me at 978-619-5685. Sincerely, Tom Devine Conservation Agent/ Staff Planner Enclosures CC: DEP Northeast Regional Office Attachment to Order of Conditions # 64-518 la ;y. Page !of 6 SALEM CONSERVATION COMMISSION DEP FILE #64-518 72 Flint Street (Former Salem Suede) Salem Massachusetts ADDITIONAL FINDINGS Based on the Estimated Habitats of Rare Wildlife and Certified Vernal Pools Map (October I, 2008) from Natural Heritage & Endangered Species Program (NHESP) of the Massachusetts Division of Fisheries and Wildlife, it has been determined that this project does not occur near any habitat of state-listed rare wildlife species nor contain any vernal pools. This Order is issued under the Massachusetts Wetlands Protection Act,M.G.L. Chapter 131, Section 40 and the City of Salem Wetlands Protection Ordinance, Salem Code Chapter50. This Order permits the demolition of slabs and footings and removal of oily soil, landfill materials, and other contaminated materials from the above-mentioned site. Project must be executed per approved plans and comply with all conditions below and in the attached WPA Form 5. GENERAL CONDITIONS 1. This Order of Conditions must be recorded in its entirety at the Essex County Registry of Deeds or the Land Court for the district in which the land is located, after the expiration of the l0-business-day appeal period and within 30 days of the issuance. A copy of the recording information must be submitted to the Salem Conservation Commission before any work approved in this Order commences. 2. Approval of this application does not constitute compliance with any law or regulation other than M.G.L Chapter 131, Section 40, Wetlands Regulations 310 CMR 10.00 and the City of Salem Wetlands Protection Ordinance, Salem Code Chapter 50. 3. All work shall be performed in accordance with this Order of Conditions and approved site plan(s). No alteration of wetland resource areas or associated buffer zones, other than that approved in this Order, shall occur on this property without prior approval from the Commission. 4. Prior to any work commencing on site, a sign showing DEP File#64-518 must be installed at the entrance to the site and be visible from a public way, but not be placed on a living tree. 5. No work approved in this Order may commence until the ten(10)day appeal period has lapsed from the date of the issuance of this Order. 6. With respect to this Order, the Commission designates the Conservation Agent as its agent with powers to act on its behalf in administering and enforcing this Order. 7. The Commission or its Agent,officers,or employees shall have the right to enter and inspect the property at any time for compliance with the conditions of this Order,the Wetlands Protection Act MGL Chapter 131, �r V`+' Attachment to Order of Conditions # 64-518 Page 2of 6 Section 40,the Wetlands Regulations 310 CMR 10.00,and shall have the right to require any data or documentation that it deems necessary for that evaluation. 8. The term"Applicant"as used in this Order of Conditions shall refer to the owner,any successor in interest or successor in control of the property referenced in the Notice of intent, supporting documents and this Order of Conditions. The Commission shall be notified in writing within 30 days of all transfers of title of any portion of the property that takes place prior to issuance of the Certificate of Compliance. 9. It is the responsibility of the applicant to obtain all other applicable federal, state and local regulatory permits and approvals associated with this project. These regulatory permits may include but are not necessarily limited to the following: (1) Section 404 of the Federal Water Pollution Control Act(P.L. 92-500, 86 stat. 816), United States Army Corps of Engineers. (2) Water Quality Certification in accordance with the Federal Water Pollution Control under authority of sec. 27(5)of Chapter 21 of the Massachusetts General Laws as codified in 314 CMR 9.00. (3) Sewer Extension Permit from the DEP Division of Water Pollution Control under MGL. Ch. 21A ss7 and 314 CMR 7.00. Any Board of Health permit for septic system design for any portion of the septic system within 100 feet of wetlands shall be submitted to the Commission prior to construction initiation. (4) Design Requirements for Construction in Floodplains under the State Building Code(780 CMR 744.). 10. If there are conflicting conditions within this Order, the stricter condition(s) shall rule. H. All work shall be performed so as to ensure that there will be no sedimentation into wetlands and surface waters during construction or after completion of the project. 12. The Commission or its Agent shall have the discretion to modify the erosion/siltation control methods and boundary during any point in construction, if necessary. 13. The Commission reserves the right to impose additional conditions on portions of this project or this site to mitigate any actual or potential impacts resulting from the work herein permitted. 14. The work shall conform to the following attached plans: Final Approved Plans SITE PLAN; SALEM SUEDE, INC.; 72 FLINT STREET; SALEM, MA (Title) 1/9/2012 (Dated) None (Signed and Stamped by) City of Salem Conservation Commission (On file watt) Attachment to Order of Conditions # 64-518 Page 3;of 6 DETAIL SHEET; SALEM SUEDE; 72 Flint Street; Salem,MA (Title) 12/2011 (Dated) None (Signed and Stamped by) City of Salem Conservation Commission (On file with) SITE-SPECIFIC HEALTH AND SAFETY PLAN; 72 FLINT STREET; SALEM,MA 01970 (Title) Received 1/12/2012 (Dated) None (Signed and Stamped by) City of Salem Conservation Commission (On file with) Release Abatement Measure Plan for Former Salem Suede;72 Flint Street; Salem,MA; RTN 3-30380 (Title) 12-5-2011 (Dated) None (Signed and Stamped by) City of Salem Conservation Commission (Oa file with) 15. Any proposed changes in the approved plan(s)or any deviation in construction from the approved plan(s) shall require the applicant to file a Notice of Project Change with the Commission. The Notice shall be accompanied by a written inquiry prior to their implementation in the field, as to whether the change(s) is substantial enough to require filing a new Notice of Intent or a request to correct or amend this Order of Conditions. A copy of such request shall at the same time be sent to the Department of Environmental Protection, Northeast Regional Office. 16. In conjunction with the sale of this property or any portion thereof before a Certificate of Compliance has been issued, the applicant or current landowner shall submit to the Commission a statement signed by the buyer that he/she is aware of an outstanding Order of Conditions on the property and has received a copy of the Order of Conditions. h Attachment to Order of Conditions # 64-518 Page�',of 6 17. Condition Number_as indicated shall continue in force beyond the Certificate of Compliance, in perpetuity,and shall be referenced to in all future deeds to this property. PRIOR TO CONSTRUCTION 18. Prior to the commencement of any activity on this site other than activities listed above, there must be a Pre-Construction Meeting on site between the project supervisor, the contractor responsible for the work, and the Conservation Agent and/or a member of the Conservation Commission to ensure that the requirements of the Order of Conditions are understood. The staked erosion control line shall be adjusted, if necessary,during the pre-construction meeting. Please contact the Conservation Agent at (978)619-5685 at least forty-eight (48) hours prior to construction to arrange for the Pre- Construction Meeting. 19. Prior to the Pre-Construction Meeting and commencement of any activity on this site,sedimentation and erosion control measures must be installed as shown on the approval plan(s)and detail drawings. The Conservation Agent shall inspect and approve such installation at the Pre-Construction Meeting. 20. No clearing of vegetation, including trees,or disturbance of soil shall occur prior to the Pre-Construction Meeting. 'Minimal disturbance of shrubs and herbaceous plants shall be allowed prior to the Pre- Construction Meeting if absolutely necessary in order to install erosion control measures where required. 21. There shall be sufficient additional erosion control devices stored under cover on the site to be used for emergency erosion control purposes. EROSION CONTROL 22. Appropriate erosion control devices shall be in place prior to the beginning of any phase of construction, and shall be maintained during construction in any wetland resource area and/or buffer zones. The erosion control measures shown on the approval plan(s)and provisions in the Order will be the minimum standards for this project; the Commission or its Agent may require additional measures. 23. All debris, fill and excavated material shall be stockpiled a location far enough away from the wetland resource areas to prevent sediment from entering wetland resource areas. 24. Erosion and sedimentation control devices shall be inspected after each storm event and repaired or replaced as necessary. Any accumulated silt adjacent to the barriers shall be removed. 25. The area of construction shall remain in a stable condition at the close of each construction day. 26. Any de-watering of trenches or other excavation required during construction shall be conducted so as to prevent siltation of wetland resource areas. All discharge from de-watering activities shall be filtered through hay bale sediment traps, silt filter bags or other means approved by the Commission or its Agent. 27. Within thirty (30) days of completion of construction on any given portion of the project,all disturbed areas in the completed portion of the site shall be permanently stabilized with rapidly growing vegetative cover, using sufficient top soil to assure long-term stabilization of disturbed areas. 28. If soils are to be disturbed for longer than two (2) months, a temporary cover of rye or other grass should be established to prevent erosion and sedimentation. If the season is not appropriate for plant growth, exposed surface shall be stabilized by other appropriate erosion control measures, firmly anchored, to prevent soils from being washed by rain or flooding. �i"°q. Attachment to Order of Conditions # 64-518 i,�/ Page 5fof 6 DURING CONSTRUCTION 29. A copy of this Order of Conditions and the plan(s)approved in this Order shall be available on site at all times when work is in progress. 30. No alteration or activity shall occur beyond the limit of work as defined by the siltation barriers shown on the approved plan(s). 31. All waste products,grubbed stumps,slash;construction materials,etc. shall be deposited at least 100 feet from wetland resource areas and 200 feet from river. 32. Cement trucks shall not be washed out in any wetland resource or buffer zone area,nor into any drainage system. Any deposit of cement or concrete products into a buffer zone or wetland resource area shall be immediately removed. 33. All exposed sub-soils shall be covered by a minimum of three(3) inches of quality screened loam topsoil prior to seeding and final stabilization. 34. Immediately following drainage structure installation all inlets shall be protected by silt fence, haybale barriers and/or silt bags to filter silt from stormwater before it enters the drainage system. 35. There shall be no pumping of water from wetland resource areas. 36. All equipment shall be inspected regularly for leaks. Any leaking hydraulic lines,cylinders or any other components shall be fixed immediately. 37. During construction,all drainage structures shall be inspected regularly and cleaned as necessary. 38. The applicant is herby notified that failure to comply with all requirements herein may result in the issuance of enforcement actions by the Conservation Commission including,but not limited to,civil administrative penalties under M.G.L Chapter 2IA, section 16. AFTER CONSTRUCTION 39. Upon completion of construction and final soil stabilization, the applicant shall submit the following to the Conservation Commission to request a Certificate of Compliance(COC): (1) A Completed Request for a Certificate of Compliance form (WPA Form 8A or other form if required by the Conservation Commission at the time of request). (2) A letter from a Registered Professional Engineer certifying compliance of the property with this Order of Conditions. (3) An "As-Built" plan signed and stamped by a Registered Professional Engineer or Land Surveyor showing post-construction conditions within all areas under the jurisdiction of the Massachusetts Wetlands Protection Act. This plan shall include at a minimum: (a) All wetland resource area boundaries with associated buffer zones and regulatory setback areas taken from the plan(s)approved in this Order of Conditions; (b) Locations and elevations of all stormwater management conveyances,structures and best management designs, including foundation drains,constructed under this Order within any wetland resource area or buffer zone; l A'. Attachment to Order of Conditions # 64-518 Page(Sof 6 (c) Distances from any structures constructed under this Order to wetland resource areas- "structures"include,but are not limited to,all buildings, septic system components, wells, utility lines,fences, retaining walls,and roads/driveways; (d) A line delineating the limit of work-"work"includes any filling,excavating and/or disturbance of soils or vegetation approved under this Order; 40. When issued,the Certificate of Compliance must be recorded at the Essex County Registry of Deeds and a copy of the recording submitted to the Salem Conservation Commission. `41. If the completed work differs from that in the original plans and conditions, a report must specify how the work differs; at which time the applicant shall first request a modification to the Order. Only upon review and approval by the Commission, may the applicant request in writing a Certificate of Compliance as described above. 42. Erosion control devices shall remain in place and property functioning until all exposed soils have been stabilized with final vegetative cover and the Commission and/or its Agent has authorized their removal. ADDITIONAL CONDITIONS 43. Applicant shall submit to the Conservation Commission daily reports of all data recorded as part of the Air Monitoring Plan throughout the duration of activity on the site. Reports shall indicate when approved levels are exceeded. 44. Prior to start of activity, applicant shall submit to the Conservation Commission the approved site plan stamped by a registered engineer or licensed site professional. Locations where stabilized soil is to be reused onsite shall be overlaid on this plan. Stabilized material shall not be reused within the riverfronf resource area. 45. Prior to reusing any excavated material onsite, said material must be tested for suitability for reuse onsite. All such test results must be submitted to the Conservation Commission for review and approval prior to reuse of material onsite. 46. Prior to start of demolition or removal of slabs, a structural analysis of the riverbank and bulkhead shall be conducted by a registered structural engineer and be submitted to the Conservation Commission. If this analysis concludes that any site activity will impact the integrity of the bank or bulkhead,a work plan, stamped by a registered structural engineer, shall be submitted, describing how the integrity of the bank and bulkhead will be maintained. No activity that may impact the structural integrity of the bank or bulkhead may begin prior to the Commission's approval of said work plan. Massachusetts Department of Environmental Protection Provided by MassDEP: Bureau of Resource Protection - Wetlands 64-518 W PA Form 5 - Order of Conditions MassDEP File# Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eDEP Transaction# Salem City/Town A. General Information Please note` Salem this form has 1. From: been modified Conservation Commission with added 2.This issuance is for space to a.®Order of Conditions b. ❑Amended Order of Conditions accommodate (check one): the Registry of Deeds 3. To: Applicant: Requirements Michael O'Brien Important: a. First Name b. Last Name When filling out forms c.Organization on the 5 Broadmoor Lane computer, use only the d. Mailing Address tab key to Peabody MA 01960 move your e.City/Town I.State Zi Code cursor-do 9 P not use the 4. Property Owner(if different from applicant): reettu�rrrnnf key. _IAV a. First Name b.Last Name c.Organlzatwn reNn d.Mailing Address e.City/Town f.Stata g.Zip Code 5. Project Location: 72 Flint Street Salem a. Street Address b.City/Town 26 91 c.Assessors Map/Plat Number d.Parcel/Lot Number Latitude and Longitude, if known: d m s d In s d. Latitude e. Longitude wpalmm5.doc• rev.05/192010 Page 1 of 12 Massachusetts Department of Environmental Protection Provided by MassDEP: ` Bureau of Resource Protection - Wetlands 64-518 WPA Form 5 - Order of Conditions MassDEPFile# Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eDEP Transaction N Salem city/Town A. General Information (cont.) s. Property recorded at the Registry of Deeds for(attach additional information if more than one parcel): Southern Essex a.County b.Certificate Number(if registered land) 6690 89 c.Book d.Page 7. Dates: 10/11/2011 12/8/2011 12/12/2011 T Date Notice of Intent Filed b. Date Public Hearing Closed c.Date of Issuance s. .Final Approved Plans and Other Documents (attach additional plan or document references as needed): SITE PLAN: SALEM SUEDE, INC.; 72 FLINT STREET; SALEM MA a. Plan Title SP, INC. b. Prepared By c.Signed and Stamped by r p 1"=40' d.Final Revision Date e.Scale Release Abatement Measure Plan; RTN 3-30380 11/10/2011 f.Additional Plan or Document Title g. Date B. Findings t. Findings pursuant to the Massachusetts Wetlands Protection Act: Following the review of the above-referenced Notice of Intent and based on the information provided in this application and presented at the public hearing, this Commission finds that the areas in which work is proposed is significant to the following interests of the Wetlands Protection Act(the Act). Check all that apply: a. ® Public Water Supply b. ® Land Containing Shellfish c' ® Prevention of Pollution d. ® Private Water Supply e. ® Fisheries I. ® Protection of Wildlife Habitat g. ® Groundwater Supply h. ® Storm Damage Prevention i. ® Flood Control 2. This Commission hereby finds the project, as proposed, is:(check one of the following boxes) Approved subject to: a. ® the following conditions which are necessary in accordance with the performance standards set forth in the wetlands regulations. This Commission orders that all work shall be performed in accordance with the Notice of Intent referenced above, the following General Conditions, and any other special conditions attached to this Order. To the extent that the following conditions modify or differ from the plans, specifications, or other proposals submitted with the Notice of Intent, these conditions shall control. wpalorm5.doc• rev.05/19/2010 Page 2 of 12 Massachusetts Department of Environmental Protection Provided by MassDEP: Ll� Bureau of Resource Protection - Wetlands 64-518 WPA Form 5 - Order of Conditions MassOEP Ale Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eDEPTransactionft Salem City/Town B. Findings (cont.) Denied because: b. ❑ the proposed work cannot be conditioned to meet the performance standards set forth in the wetland regulations. Therefore, work on this project may not go forward unless and until a new Notice of Intent is submitted which provides measures which are adequate to protect the interests of the Act, and a final Order of Conditions is issued. A description of the performance standards which the proposed work cannot meet is attached to this Order. c. ❑ the information submitted by the applicant is not sufficient to describe the site, the work, or the effect of the work on the interests identified in the Wetlands Protection Act. Therefore, work on this project may not go forward unless and until a revised Notice of Intent is submitted which provides sufficient information and includes measures which are adequate to protect the Act's interests, and a final Order of Conditions is issued. A description of the specific Information which is lacking and why it Is necessary Is attached to this Order as per 310 CMR 10.05(6)(c). 3. ❑ Buffer Zone Impacts: Shortest distance between limit of project disturbance and the wetland resource area specified in 310 CMR 10.02(1)(a) a. linear feet Inland Resource Area Impacts: Check all that apply below. (For Approvals Only) Resource Area Proposed Permitted Proposed Permitted Alteration Alteration Replacement Replacement 4. ❑ Bank a. linear feet b.linear feet c.linear feet d. linear feet s. El Bordering Vegetated Wetland a.square feet b.square feet c.square feet d.square feet 8. ❑ Land Under Waterbodies and a.square feet b.square feet c.square feet d.square feet Waterways (i c/y dredged f.dy dredged 7. ❑ Bordering Land Subject to Flooding a.square feet b.square feet c.square feet d.square feet Cubic Feet Flood Storage e.cubic feet f.cubic feet cubic feet h.cubic feet e. ❑ Isolated Land g. Subject to Flooding a.square feet b.square feet Cubic Feet Flood Storage c.cubic feet d.cubic feet e.cubic feet f.cubic feel g. ® Riverfront Area 71,000 71,000 rnra�.. foot b.total sq.feet Sq It within 100 It 28,000 28,000 „ropy d.square feet , roar f.square feet Sq ft between 100- 43,000 43,000 200 It root h.square feet I,square feet wpalorm5.dw- rev.05/19/2010 Page 3 at 12 Massachusetts Department of Environmental Protection Provided by MassDEP: Bureau of Resource Protection - Wetlands 64-518 WPA Form 5 - Order of Conditions MassDEPFile# 1 Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eDEP Transaction# Salem Cityrrown B. Findings (cont.) Coastal Resource Area Impacts: Check all that apply below. (For Approvals Only) Proposed Permitted Proposed Permitted Alteration Alteration Replacement Replacement 10. [I Designated Port Areas Indicate size under Land Under the Ocean, below 11. ❑ Land Under the Ocean a.square feet b.square feet c.Gy dredged d.d/y dredged 12. ❑ Barrier Beaches Indicate size under Coastal Beaches and/or Coastal Dunes below 13. El Coastal Beaches cu yd cu yd a.square feet b.square feet c.nourishment d.nourishment 14. ❑ Coastal Dunes cu yd cu yd a,square feet b.square feet c.nourishment d.nourishment 15. ❑ Coastal Banks a. linearfeet b. linearfeet is. ❑ Rocky Intertidal Shores a.square feet b.square feet 17. ❑ SaltUnder a.square feet b,square feet c.square feet d.square feet 18. ❑ Land Under Salt Ponds a.square feet b.square feet a Gy dredged d.cry dredged 1s. El Land Containing Shellfish a.square feet b.square feet c.square feet d.square feet 20. ❑ Fish Runs Indicate size under Coastal Banks, Inland Bank, Land Under the Ocean, and/or inland Land Under Waterbodies and Waterways, above a.ay dredged b.cry dredged 21. ® Land Subject to 28,000 28,000 Coastal Storm a.square feet b.square feet Flowage wpafora,5.tlac• rev.05/19/2010 Page 4 of 12 Massachusetts Department of Environmental Protection Provided by MassDEP: Bureau of Resource Protection - Wetlands 64-518 WPA Form 5 - Order of Conditions MassDEP File# Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eDEP Transaction# Salem City(rown B. Findings (cont.) #22.If the project is for 22. ElRestoration/Enhancement': the purpose of restoring or a.square feet of BVW enhancing a q b.square feet of salt marsh wetland resource area 23. ❑ Stream Crossing(s): in addition to the square footage that a.number of new stream crossings b.number of replacement stream crossings has been entered in C. General Conditions Under Massachusetts Wetlands Protection Act Section B.5.c Bor .1To)(salt The following conditions are only applicable to Approved projects. Marsh)above, 1. Failure to comply with all conditions stated herein, and with all related statutes and other please enter the additional re ulator measures, shall be deemed cause to revoke or modify this Order. 9 y amount here. 2. The Order does not grant any property rights or any exclusive privileges; it does not authorize any injury to private property or invasion of private rights. 3. This Order does not relieve the permittee or any other person of the necessity of complying with all other applicable federal, state, or local statutes, ordinances, bylaws, or regulations. 4. The work authorized hereunder shall be completed within three years from the date of this Order unless either of the following apply: a. the work is a maintenance dredging project as provided for in the Act; or b. the time for completion has been extended to a specified date more than three years, but less than five years, from the date of issuance. If this Order is intended to be valid for more than three years, the extension date and the special circumstances warranting the extended time period are set forth as a special condition in this Order. 5. This Order may be extended by the issuing authority for one or more periods of up to three years each upon application to the issuing authority at least 30 days prior to the expiration date of the Order. 6. If this Order constitutes an Amended Order of Conditions, this Amended Order of Conditions does not extend the issuance date of the original Final Order of Conditions and the Order will expire on 12/12/2014 unless extended in writing by the Department. 7. Any fill used in connection with this project shall be clean fill. Any fill shall contain no trash, refuse, rubbish, or debris, including but not limited to lumber, bricks, plaster, wire, lath, paper, cardboard, pipe, tires, ashes, refrigerators, motor vehicles, or parts of any of the foregoing. 8. This Order is not final until all administrative appeal periods from this Order have elapsed, or if such an appeal has been taken, until all proceedings before the Department have been completed. wpafarm5.dac• revwi wo10 Page 5 of 12 Massachusetts Department of Environmental Protection Provided by MassDEP: Bureau of Resource Protection - Wetlands 64-518 WPA Form 5 - Order of Conditions MassDEPFile# Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eDEP Transaction# Salem City/Town C. General Conditions Under Massachusetts Wetlands Protection Act (cont.) 9. No work shall be undertaken until the Order has become final and then has been recorded in the Registry of Deeds or the Land Court for the district in which the land is located, within the chain of title of the affected property. In the case of recorded land, the Final Order shall also be noted in the Registry's Grantor Index under the name of the owner of the land upon which the proposed work is to be done. In the case of the registered land, the Final Order shall also be noted on the Land Court Certificate of Title of the owner of the land upon which the proposed work is done. The recording information shall be submitted to the Conservation Commission on the form at the end of this Order, which form must be stamped by the Registry of Deeds, prior to the commencement of work. 10. A sign shall be displayed at the site not less then two square feet or more than three square feet in size bearing the words, "Massachusetts Department of Environmental Protection" [or, "MassDEP"l "File Number 64-518 11. Where the Department of Environmental Protection is requested to issue a Superseding Order, the Conservation Commission shall be a party to all agency proceedings and hearings before MassDEP. 12. Upon completion of the work described herein, the applicant shall submit a Request for Certificate of Compliance (WPA Form 8A)to the Conservation Commission. 13. The work shall conform to the plans and special conditions referenced in this order. 14. Any change to the plans identified in Condition #13 above shall require the applicant to inquire of the Conservation Commission in writing whether the change is significant enough to require the filing of a new Notice of Intent. 15. The Agent or members of the Conservation Commission and the Department of Environmental Protection shall have the right to enter and inspect the area subject to this Order at reasonable hours to evaluate compliance with the conditions stated in this Order, and may require the submittal of any data deemed necessary by the Conservation Commission or Department for that evaluation. 16. This Order of Conditions shall apply to any successor in interest or successor in control of the property subject to this Order and to any contractor or other person performing work conditioned by this Order. 17. Prior to the start of work, and if the project involves work adjacent to a Bordering Vegetated Wetland, the boundary of the wetland in the vicinity of the proposed work area shall be marked by wooden stakes or flagging. Once in place, the wetland boundary markers shall be maintained until a Certificate of Compliance has been issued by the Conservation Commission. wpaforra5.4oc. rev.05/192010 Page 6 of f2 Massachusetts Department of Environmental Protection Provided by MassDEP: Bureau of Resource Protection - Wetlands 64-518 WPA Form 5 - Order of Conditions MassDEP File# Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eDEP Transaction# Salem Citylrown C. General Conditions Under Massachusetts Wetlands Protection Act (cont.) 18. All sedimentation barriers shall be maintained in good repair until all disturbed areas have been fully stabilized with vegetation or other means. At no time shall sediments be deposited in a wetland or water body. During construction, the applicant or his/her designee shall inspect the erosion controls on a daily basis and shall remove accumulated sediments as needed. The applicant shall immediately control any erosion problems that occur at the site and shall also immediately notify the Conservation Commission, which reserves the right to require additional erosion and/or damage prevention controls it may deem necessary. Sedimentation barriers shall serve as the limit of work unless another limit of work line has been approved by this Order. NOTICE OF STORMWATER CONTROL AND MAINTENANCE REQUIREMENTS 19. The work associated with this Order(the"Project") Is(1) ❑ Is not(2) ® subject to the Massachusetts Stormwater Standards. if the work is subject to the Stormwater Standards,then the project is subject to the following conditions: a) All work, including site preparation, land disturbance, construction and redevelopment, shall be implemented in accordance with the construction period pollution prevention and erosion and sedimentation control plan and, if applicable, the Stormwater Pollution Prevention Plan required by the National Pollution Discharge Elimination System Construction General Permit as required by Stormwater Condition 8. Construction period erosion, sedimentation and pollution control measures and best management practices (BMPs) shall remain in place until the site is fully stabilized. b) No stormwater runoff may be discharged to the post-construction stormwater BMPs unless and until a Registered Professional Engineer provides a Certification that: i. all construction period BMPs have been removed or will be removed by a date certain specified in the Certification. For any construction period BMPs intended to be converted to post construction operation for stormwater attenuation, recharge, and/or treatment, the conversion is allowed by the MassDEP Stormwater Handbook BMP specifications and that the BMP has been properly cleaned or prepared for post construction operation, including removal of all construction period sediment trapped in inlet and outlet control structures; ii. as-built final construction BMP plans are included, signed and stamped by a Registered Professional Engineer, certifying the site is fully stabilized; iii. any illicit discharges to the stormwater management system have been removed, as per the requirements of Stormwater Standard 10; iv. all post-construction stormwater BMPs are installed in accordance with the plans (including all planting plans) approved by the issuing authority, and have been inspected to ensure that they are not damaged and that they are in proper working condition; v. any vegetation associated with post-construction BMPs is suitably established to withstand erosion. wpafooa5.doc• rev.05/1M010 Page 7 of 12 Massachusetts Department of Environmental Protection Provided by MassDEP: Bureau of Resource Protection - Wetlands 64-518 WPA Form 5 - Order of Conditions MassDEP File p Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eDEP Transaction N Salem city/Town C. General Conditions Under Massachusetts Wetlands Protection Act (cont.) c) The landowner is responsible for BMP maintenance until the issuing authority is notified that another party has legally assumed responsibility for BMP maintenance. Prior to requesting a Certificate of Compliance, or Partial Certificate of Compliance, the responsible party(defined in General Condition 18(e)) shall execute and submit to the issuing authority an Operation and Maintenance Compliance Statement("O&M Statement) for the Stormwater BMPs identifying the party responsible for implementing the stormwater BMP Operation and Maintenance Plan ("O&M Plan") and certifying the following: i.)the O&M Plan is complete and will be implemented upon receipt of the Certificate of Compliance, and ii.)the future responsible parties shall be notified in writing of their ongoing legal responsibility to operate and maintain the stormwater management BMPs and implement the Stormwater Pollution Prevention Plan. d) Post-construction pollution prevention and source control shall be implemented in accordance with the.long-term pollution prevention plan section of the approved Stormwater Report and, if applicable, the Stormwater Pollution Prevention Plan required by the National Pollution Discharge Elimination System Multi-Sector General Permit. e) Unless and until another party accepts responsibility, the landowner, or owner of any drainage easement, assumes responsibility for maintaining each BMP. To overcome this presumption, the landowner of the property must submit to the issuing authority a legally binding agreement of record, acceptable to the issuing authority, evidencing that another entity has accepted responsibility for maintaining the BMP, and that the proposed responsible party shall be treated as a permittee for purposes of implementing the requirements of Conditions 18(f)through 18(k) with respect to that BMP. Any failure of the proposed responsible party to implement the requirements of Conditions 18(f) through 18(k)with respect to that BMP shall be a violation of the Order of Conditions or Certificate of Compliance. In the case of stormwater BMPs that are serving more than one lot, the legally binding agreement shall also identify the lots that will be serviced by the stormwater BMPs. A plan and easement deed that grants the responsible party access to perform the required operation and maintenance must be submitted along with the legally binding agreement. f) The responsible party shall operate and maintain all stormwater BMPs in accordance with the design plans, the O&M Plan, and the requirements of the Massachusetts Stormwater Handbook. wpaform5do rev.05/192010 Page 8 of 12 Massachusetts Department of Environmental Protection Provided by MassDEP: Bureau of Resource Protection - Wetlands 64-518 WPA Form 5 - Order of Conditions MassDEP File# Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eDEP Transaction# Salem City/Town C. General Conditions Under Massachusetts Wetlands Protection Act (cont.) g) The responsible party shall: 1. Maintain an operation and maintenance log for the last three (3) consecutive calendar years of inspections, repairs, maintenance and/or replacement of the stormwater management system or any part thereof, and disposal (for disposal the log shall indicate the type of material and the disposal location); 2. Make the maintenance log available to MassDEP and the Conservation Commission ("Commission") upon request; and 3. Allow members and agents of the MassDEP and the Commission to enter and inspect the site to evaluate and ensure that the responsible party is in compliance with the requirements for each BMP established in the O&M Plan approved by the issuing authority. h) All sediment or other contaminants removed from stormwater BMPs shall be disposed of in accordance with all applicable federal, state, and local laws and regulations. 1) Illicit discharges to the stormwater management system as defined in 310 CMR 10.04 are prohibited. j) The stormwater management system approved in the Order of Conditions shall not be changed without the prior written approval of the issuing authority. k) Areas designated as qualifying pervious areas for the purpose of the Low Impact Site Design Credit(as defined in the MassDEP Stormwater Handbook, Volume 3, Chapter 1, Low Impact Development Site Design Credits)shall not be altered without the prior written approval of the issuing authority. 1) Access for maintenance, repair, and/or replacement of BMPs shall not be withheld. Any fencing constructed around stormwater BMPs shall include access gates and shall be at least six inches above grade to allow for wildlife passage. Special Conditions (if you need more space for additional conditions, please attach a text document): See attached sheets wpalorm5.dm- rev.05/19/2010 Page 9 of 12 Massachusetts Department of Environmental Protection Provided by MassDEP: c Bureau of Resource Protection - Wetlands 64-518 WPA Form 5 - Order of Conditions MassOEP File# Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eDEP Transaction# Salem Citylrown D. Findings Under Municipal Wetlands Bylaw or Ordinance 1. Is a municipal wetlands bylaw or ordinance applicable? ® Yes ❑ No 2. The Salem hereby finds (check one that applies): Conservation Commission a. ❑ that the proposed work cannot be conditioned to meet the standards set forth in a municipal ordinance or bylaw, specifically: 1.Municipal Ordinance or Bylaw 2.Citation Therefore, work on this project may not go forward unless and until a revised Notice of Intent is submitted which provides measures which are adequate to meet these standards, and a final Order of Conditions is issued. b. ® that the following additional conditions are necessary to comply with a municipal ordinance or bylaw: Salem Wetlands Protection and Conservation Ordinance ch. 50 1.Municipal Ordinance or Bylaw 2.Citation 3. The Commission orders that all work shall be performed in accordance with the following conditions and with the Notice of Intent referenced above. To the extent that the following conditions modify or differ from the plans, specifications, or other proposals submitted with the Notice of Intent, the conditions shall control. The special conditions relating to municipal ordinance or bylaw are as follows (if you need more space for additional conditions, attach a text document): Attached special conditions are issued under the Wetlands Protection Act and are sufficient for compliance with the local ordinance wpaforro5.tloc• rev.05/19/2010 Page 10 of 12 Massachusetts Department of Environmental Protection Provided by MassDEP: Bureau of Resource Protection - Wetlands 64-518 WPA Form 5 - Order of Conditions MassDEP-File# Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eDEP Transaction# Salem City/TomE. Signatures This Order is valid for three years, unless otherwise specified as a special a I condition pursuant to General Conditions#4,from the date of issuance. 1. ate oJscuance Please indicate the number of members who will sign this form. S This Order must be signed by a majority of the Conservation Commission. 2.Number of Signers The Order must be mailed by certified mail(return receipt requested)or hand delivered to the applicant.A copy also must be mailed or hand delivered at the same time to the appropriate Department of Environmental Protection Regional Office, if not filing electronically, and the property owner, if different from applicant. Signature ,. V = ❑ by hand delivery on 4 by certified mail, return receipt requestedon Date T, �///� K Date F. Appeals The applicant, the owner, any person aggrieved by this Order, any owner of land abutting the land subject to this Order, or any ten residents of the city or town in which such land is located, are hereby notified of their right to request the appropriate MassDEP Regional Office to issue a Superseding Order of Conditions. The request must be made by certified mail or hand delivery to the Department, with the appropriate filing fee and a completed Request of Departmental Action Fee Transmittal Form, as provided in 310 CMR 10.03(7) within ten business days from the date of issuance of this Order. A copy of the request shall at the same time be sent by certified mail or hand delivery to the Conservation Commission and to the applicant, if he/she is not the appellant. Any appellants seeking to appeal the Department's Superseding Order associated with this appeal will be required to demonstrate prior participation in the review of this project. Previous participation in the permit proceeding means the submission of written information to the Conservation Commission prior to the close of the public hearing, requesting a Superseding Order, or providing written information to the Department prior to issuance of a Superseding Order. The request shall state clearly and concisely the objections to the Order which is being appealed and how the Order does not contribute to the protection of the interests identified in the Massachusetts Wetlands Protection Act(M.G.L. c. 131, §40), and is inconsistent with the wetlands regulations (310 CMR 10.00). To the extent that the Order is based on a municipal ordinance or bylaw, and not on the Massachusetts Wetlands Protection Act or regulations, the Department has no appellate jurisdiction. wpaform5.doc, rev.05/M010 Page 11 of 12 it I Massachusetts Department of Environmental Protection Provided by MassDEP: Bureau of Resource Protection - Wetlands 64-518 WPA Form 5 - Order of Conditions MassDEP-File# Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eCEPTransaction# Salem Cityfrown G. Recording Information Prior to commencement of work, this Order of Conditions must be recorded in the Registry of Deeds or the Land Court for the district in which the land is located, within the chain of title of the affected property. In the case of recorded land, the Final Order shall also be noted in the Registry's Grantor Index under the name of the owner of the land subject to the Order. In the case of registered land, this Order shall also be noted on the Land Court Certificate of Title of the owner of the land subject to the Order of Conditions. The recording information on this page shall be submitted to the Conservation Commission listed below. Conservation Commission Detach on dotted line, have stamped by the Registry of Deeds and submit to the Conservation Commission. --- ------------ -------------------- - -------------------------------------- To: Conservation Commission Please be advised that the Order of Conditions for the Project at: Project Location MassDEP File Number Has been recorded at the Registry of Deeds of: County Book Page for: Property Owner and has been noted in the chain of title of the affected property in: Book Page In accordance with the Order of Conditions issued on: Date If recorded land, the instrument number identifying this transaction is: Instrument Number If registered land, the document number identifying this transaction is: Document Number Signature of Applicant rvpaform5.duc rev.05/19/2010 Page 12 of 12 SP ENGINEERING, INC. P.O. Box 848 o Salem, Massachusetts 01970 • 'telephone" 978-745-4569 • Fax: 978-745-4881 01 'March 1, 2013 Kimberley Driscoll, Mayor City Hall 93 Washington Street Salem;MA 01970 RE: Release Abatement Measure Plan Former Salem Suede 72 Flint Street Salem, Massachusetts RTN 3-30380 Dear Mayor Driscoll: On behalf of Riverview Place, LLC, SP, Inc. hereby notifies you that a Release Abatement Measure (RAM)will be performed at the former Salem Suede facility at 72 Flint Street in Salem, Massachusetts (the "Site") in accordance with the Massachusetts Contingency Plan, 310 CMR 40.0000 for a release of oil and metals. The RAM will consist of the excavation and management of soil containing petroleum, ash, metals, and historic leather waste materials. SP, Inc. has prepared a.RAM Plan that has been submitted to the Massachusetts Department of Environmental Protection(DEP). A copy of the RAM Plan is available at the DEP Searchable Sites Waste Site List/Site Files web site http://Ptiblic.dei).state.ma.us/wscviewer/main.aspx under Release Tracking Number(RTN) 3-30380 or by contacting SP, Inc. at 508-745-4569. At this time, field activities for the RAM will be started upon approval of the RAM Plan by the DEP. If weather conditions permit, excavation will be upon notice of approval and the remediation will require several months to complete. Please do not hesitate to contact the undersigned if you should have any questions or require additional information. Sincerely, SP,INC. Fez,. Bruce M. Poole David L. Bramley, PE, LSP, LEP President � coauiTe AmCITY OF SALEM ,b � r CONSERVATION COMMISSION SITE VISIT FORM PROJECT LOCATION: �� r ^�S� '� S�^O �pATE OF SITE VISIT•' PROJECT PROPONENT: 011 O Ark,11 pp DEP FILE NUMBER: PROPOSEDI WORK: C fission Member /Agegt utters: 1 a ft 01k*-- , s.✓K fJrd�sv� I _ (,� Applicant/Property Owner/Representative: ❑Request for Deiermination ❑Abbreviated Notice of Resource Area Delineation Notice of Intent ❑Certificate of Compliance ❑Enforcement/Violation ❑Emergency Informal INLAND RESOURCE AREAS COASTAL RESOURCE AREAS ❑Bank ® Land Subject to Coastal,❑Land Under_•the'Ocean Storm Flowage " ❑Bordering Vegetated Wetland - �? _ 1!1Designated Port Area ❑Coastal Beach ❑Land Subject to Flooding 1:1 Coastal Dune El Barrier Beach ElLand Under Water Bodies or Waterway Name: ❑ Coastal Bank ❑Rocky Intertidal Shore EZ[.Riverfront Area ❑ Salt Marsh ❑ Land Under Salt Pond ❑Vernal Pools ❑ Land Containing ❑Anadromous/Cata- Shellfish dromous Fish Run ❑ Bordering Vegetated Wetland in Coastal Area t ❑Water Body ❑ Bordering Vegetated Wetland ❑ Bank ❑ Coastal Beach ❑Coastal Dune Protection of Water Supply ®Protection of Groundwater Supply ❑Flood Control Storm Damage Prevention ©Prevention of Pollution Protection of Fisheries 12 Protection of Wildlife Habitat Protection of Land Containing Shellfish Is this an exempt project: If so,why? /v J Are resource area boundaries delineated correctly? If not,explain. \(g-S SIT�'� ©GU ,E. 11`x...•,'. Photos Usite Map ❑Other: �E�VAtIaNS*; :, Take into account relevant aspects or features such as: natural or piped drainage or obvious pollution; topography; existing vegetation; possible alternative sites; signs of wildlife, possible vernal pools, rare species habitat; landmarks; recent or historical disturbances; proximity to other water bodies or drainage areas; adjacent land uses. x �•� i6l'I L s (Po, y MA DEP http://public.dep.state.ma.us/wetland/wetland.aspx 'r Public Access to Wetland Notices of Intent Search Criteria:Instructions eDEP File Notices arltl Region: Filed YOGr,! egpn Orders Online -: .......... City/Town: SALEM Start Date. 10/8/2010 End Date 1111812011 - Results per page'. 100 Search;,.-Clear The leach remmed 10resp pat Displaying 10(Drecords per page. N01 FIe# Filinp Applicant's Abolio is Location Geography Repio Town constraints :pate First Nacre Nam �� 0644516 tO11240t1 MICHEAL 0BRIEN 72 FLINT RIVERVIEW NE SALEM NC Co R E STREET GLACE LLC r064051] 6/152011 :DAVID ttNJWLTON , CRV NE SALEM MARLBOROUGH EPGINEER END i ROADI NO Commonly ATH PARK) 10640516 5/132011 ROBERT HCBBMD -,STREET GROVE IMRM ANAGEM ECi SALEM) STREETAND 3 MANAGEMENT HARMOW LLC NO Comments _ .GROVE ROAD 0640515 i4/B20fl '.PETER^_GOLDEN (BAKERS ISLPND� SALEM, 0040514 314M11 yPATRICA LEAVENWORTH:ROUTEtAN13 M4SSAc TS:NE ISALEM MfhmGIS shournes 5 ft Mother TORNG AVE) IGHWAY ": in the location of the rPrap AT TLE 1 VISION MaRDOT most clarify if salt FORES ER i rrarch's present in ae xorN ` area.Riphip should net be € ( placed on coastalbank or in iIARhams h ha lmeelI m aperformance 'standards o31 A 10.50(lu(B)and 1be evaluated A ss anamtontive means to Vass,the eaVdi book trop: the coastalbank and l',I. orvoltmeter Transistor,dpi �E;st sued an aamam the motor- pe i seders omoundi erf ank,b evas tiled or. ' any commentb s a'I me has R PI 1 ry i.i .. . rIf it I should saran the should be laapme 1 1 order Ie al I _ - .............. ... 11 Bl- I-a -___ 0640513 .11212011 LEWI3 LEGON 144 COLUMBIR PATRICIA jNE SALEM:FAddorgive M mplyich E AVENUE IBERttWG ;FEM4'a ofteralc irudion i manual 0 n 0640512 12292010 FRANK LArl X23 PPALEE NE SA r STREET ,NO Comments 0640511 111302010 CRAIG BU3NHAM 810FRANKL N4TESON NE 5ALEMi NO Comments ST REALTY TRUST t `<0640510 11242o1010AVID WEIN 16 RAV NEW I NE SALEM�IIwrk bl1. nhOh lkl ` CIRCLE 1 a404 WOCl h US Army l eorpv may p red 0040509 1018201 BARBARA BOWMAN BDEARBORN NE SALEM1 Applicath h- Ihhr LANE ( 1 kerns pl f r g II it .and veli ash notest t of seadall seen,back landeard.ft prep not be placetl on beach.In cannot wards thus,cannot be aenaea beyond entre veavau locator Tne same '::, I goes for the Grarre steps. Wooden steps enols be i /... acceptable ; 1; r I of 1 11/8/2011 1:56 PM Salem Sue=de cleanup is close>> SalemNews.com, Salem, MA http://www.salemnews.com/local/x205477899/Salem-Suede-cleanup... SalemNews.com, Salem, MA January 11, 2012 Salem Suede cleanup is close By Tom Dalton Staff writer SALEM—Largely dormant for the past few years, a housing development along the North River canal is stirring to life. Riverview Place, a 130-apartment complex proposed at the former Salem Suede factory site on Flint Street, is seeking final approvals from a city board. The Conservation Commission,which meets tomorrow tight, has been asked to approve the environmental cleanup of the nearly 4-acre site,which was the home of leather tanneries for more than 100 years. All the Salem Suede factory buildings ate down,but the developer must clean up land along the canal that is dotted with building foundations, piles of bricks, concrete slabs and other debris. There is also contaminated soil to be taken to landfills or stabilized. Mike O'Brien, one of the developers, estimated the cost of this phase of the cleanup at $250,000 or more. Pending approval by the Conservation Commission, the developers ate hopeful they can begin tlus final cleanup by early spring. Within the next month, Riverview Place LLC expects to take ownership of the former Salem Suede site and the adjoining Bonfanti factory, which runs along Mason Street and will be razed to clear the way for construction. "Both sellers have been extremely patient only because they know what we've gone through," O'Brien said. Among other obstacles, the project wound up in Massachusetts Land Court when neighbors and residents of a nearby historic district,upset about the size of the development, challenged variances granted by a city board. The legal case was resolved in 2010. Other than the final city approval, the project also needs a state waterways license. Riverview Place would have 75 two-bedroom apartments and 55 one-bedroom units. While predominantly market-rate, 13 apartments would be affordable.A small retail space is planned. 1 of 1/11/20129:50 AM Salem Suede cleanup is close>> SalemNews.com, Salem, MA http://www.salemnews.com/local/x205477899/Salem-Suede-cleanup... There would be more than 300 parking spaces, including 12 set aside for neighbors who live on congested streets with little parking. O'Brien said he is hopeful the cleanup can be completed mahout six months. Construction could start in the late summer or fall. However, O'Brien also knows that this development has been in the works for more than four years and has moved along slowly. "That's our goal," he said of the timetable. "Will that be met? I don't know." Having come this far, though, and having invested a lot of money in demolition, cleanup and lawyers, O'Brien said they plan to see it through. "I guess the best way to describe it is in Texas Hold 'em terms," he said. "At one point, you're all in." 2of2 1/II/20129:50AM Mack Park Condominium Trust 75-77 Mason Street Salem, MA 01970 Salem Suede, Inc. 72 Flint Street Salem MA 01970 Phone: 978.744.1303 s Fax: 978.745.8044 and Bruce M Poole SP Engineering, Inc. PC Box 848 45 Congress Street Salem MA 01970 December 8, 2011 Dear owner and Mr. Poole: We represent the owners of the Units at the Mack Park Condominiums, located at 75-77 Mason Street, Salem, that directly.abuts the property at 72 Flint Street(parcel and lot#26-0091-0). We understand that you will be excavating, storing and then removing contaminated soil and debris from the property. We are not opposed to the proper improvement of the property, but we wish to be assured that our property and health, as well as our neighbors, will not suffer during your demolition phase. In a previous letter sent to numerous city leaders dated September 14, 2009 we expressed the following concerns: Please avoid trash and contaminated/chemical materials storage or accumulation close to our fence. We need to be sure that there are no releases of asbestos or other environmental pollutants into the air or ground near our property. We would like to be sure that there will be no adverse impact on our building's foundation and subsurface support from any excavation or construction on your property. We are very concerned about the storage of chemical materials, generation of dust, noise from generators and vibration from the constant movement of heavy trucks especially because our windows and back doors are directly abuts to your property. For these reasons, we would like to ask you to relocate the storage area to alternative location (may be behind the Bonfanti building)which we discussed with you at the meeting on December 3, 2011. We would be interested in meeting with you to discuss your plans regarding our outlined concerns. Please email with your availability- MackParkC@gmaiLcom. Sincerely, Mack Park Condominium Trust MackParkC@gmaiLcom cc: Marcy D. Hauber at Tinti, Quinn, Grover& Frey P.C. David Greenbaum, Salem Board of Health -Acting Health Agent Thomas St. Pierre, Director of Inspectional Services Kimberley Driscoll, Mayor Jason Silva, Chief Administrative Aide Paul C. Prevey, Ward 6 City Councilor Tom Devine, Conservation Agent/Staff Planner Attorney of Mack Park Condominium Trust l r AIR MONITORING PLAN RIVERVIEW PLACE LLC 72 FLINT STREET, SALEM PARAMETER FRED. WORKER PROPERTY CORRECTIVE ACTION TEST UNIT LIMIT LIMIT DUST PART. CONT.* 10 mg/cm 1.0 mg/cm STOP EXCAVATION/LOADING TSI 8530 DUSTTRAK II WET SURFACES WAIT FOR LESS WIND COVER PILES HOURLY ODOR, SULFIDE 2X/DAY 10/15 ppm 1.0 ppm STOP EXCAVATION/LOADING ISTMX 412 MULTIGAS SPREAD LIME WAIT FOR COLD/LT RAIN MOVE PILE, COVER HOURLY SPRAY DEODORANT VOLATILE ORGANICS NAPTHALENE 2X/DAY 10/15 ppm 1.0 ppm STOP EXCAVATION/LOADING MINIRAE PID IDENTIFY SOURCE COVER AND CONTAIN ,y_ SPREAD PEAT OR CKD NOISE 2X/DAY 120 Db 80 db STOP EQUIPMENT QUEST Q-400 SLOW DOWN OPERATION DOSIMETER PLACE MATS ON SLABS * THERE WILL BE 4 MONITORING STATIONS,3 BETWEEN THE WORK AND RESIDENCES,AS SHOWN ON THE PLAN AND 1 BESIDE THE RIVER. THE DUST MONITORING IS CONTINUOUS DURING DEMOLITION, SOIL EXCAVATION, STABILIZATION AND TRUCK LOADING AND RESULTS ARE BASED ON A TIME WEIGHTED AVERAGE (TWA). THE PORTABLE AIR QUALITY MONITORS WILL BE USED AT THE WORK AREAS FOR WORKER SAFETY AND 2X/DAY READINGS WILL BE TAKEN AT THE 4 STATIONS,WITH THE RESPONSES LISTED ABOVE IF THE LIMITS ARE EXCEEDED. Massachusetts Department of Environmental Protection Provided by MassDEP: Bureau of Resource Protection - Wetlands 64-518 WPA Form 5 - Order of Conditions MassDEP File# Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 eDEPTransaction# Salem City/Town G. Recording Information Prior to commencement of work, this Order of Conditions must be recorded in the Registry of Deeds or the Land Court for the district in which the land is located, within the chain of title of the affected property. In the case of recorded land, the Final Order shall also be noted in the Registry's Grantor Index under the name of the owner of the land subject to the Order. In the case of registered land, this Order shall also be noted on the Land Court Certificate of Title of the owner of the land subject to the Order of Conditions. The recording information on this page shall be submitted to the Conservation Commission listed below. Conservation Commission Detach on dotted line, have stamped by the Registry of Deeds and submit to the Conservation Commission. To: Gni t-r- S� - Conserva on Commission Please be advised that the Order of Conditions for the Project at: 7k =1117 f S-F . 67g-5y Project Location MassDEP File Number Has been recorded at the Registry of Deeds of: Css,ex S u 7A {?Sis A//c t— 3/Z55 1�0 Sp County Vl /Giagl./ for: Property Owner and has been noted in the chain of title of the affected property in: Book Page In accordance with the Order of Conditions issued on: Date If recorded land, the instrument number identifying this transaction is: Instrument Number If registered land,the document number identifying this transaction is: 4r, *AplcantZ��/ wpaformsdoc• rev.05/19/2010 Page 12 of 12 Page 1 of 1 Tom Devine From: Brucepoolesp@aol.com Sent: Thursday, January 05, 2012 3:56 PM To: mackparkc@gmail.com Subject: Re: SP Engineering demolition Dear Members, I have received input from the second Con. Com. meeting as well as your Dec. 8 letter and would be glad to meet with any members after the Jan. 10 normal meeting to explain the changes we have made to address your concerns. We have moved the soil storage piles and concrete piles away from the residences, we will have locked trailers for all chemical storage, another for spill control materials, safety equipment, air monitors and decontamination gear and a lined covered dumpster will be used for trash, suits, wipes and debris. To further protect the residents and their property we have developed an air monitoring plan for the site to test for dust, odor compounds (sulfides) and noise. We would place 4 Dustracker automatic analyzers at locations near the property line by residences; sulfide and noise levels would be monitored at the stations several times per day and during work at the excavations. I would welcome the opportunity to discuss these items of our Health and Safety Plan and other issues at a time of your convenience. Please cal me at 978-745-4569 if you have any questions. Best Regards, Bruce Poole 1/5/2012 y Release Abatement Measure Plan for Former Salem Suede 72 Flint Street Salem, Massachusetts RTN 3-30380 Prepared for: Michael O'Brien Riverview Place LLC 5 Broadmoor Lane Peabody, Ma. 01960 Prepared by: S P Engineering, Inc. 45 Congress Street Salem. Ma. 01970 November 10, 2011 Modified January 22, 2013 ENGINEERING, INC. P.O. Box 848 • Salem, Massachusetts 01970 • 'Telenhone: 978-745-4569 • Fax: 978-745-4881 January 22, 2013 Department of Environmental Protection Northeast Regional Office 205B Lowell Street Wilmington, MA 01888 Attention: Ms. Leticia Ruiz-Boyle Subject: Release Abatement Measure Plan Former Salem Suede 72 Flint Street Salem, Massachusetts RTN 3-30380 Dear Ms. Ruiz-Boyle: Enclosed is a Release Abatement Measure (RAM) Plan for the property located at 72 Flint Street in Salem, Massachusetts. SP, Inc. prepared this document on behalf of our client, Riverview Place, LLC. This document has been revised since the initial submittal on November 10, 2011. The modifications incorporate findings of the Phase H subsurface investigation conducted by Weston& Sampson(W&S). The W&S assessment was conducted in conjunction with a Brownfrelds grant administered by the Metropolitan Area Planning Council (MAPC). The Site has been identified as a strategic location to restore and reuse to support the redevelopment of adjacent parcels. It also addresses the concerns of the Massachusetts Department of Environmental Protection (MA DEP)regarding the following issues: ➢ site history ➢ site characterization ➢ constituents of concern ➢ confirmation sampling and analytes ➢ soil solidification/stabilization ➢ groundwater quality and monitoring ➢ air monitoring ➢ disposition of excavated soil Soils containing petroleum, metals, ash, and historic leather waste have been encountered during subsurface evaluations that have been performed as due diligence assessment and as site characterization. The results of assessments indicate that extractable petroleum hydrocarbons (EPHs), including polycyclic aromatic hydrocarbons (PAHs), dioxins, furans and the metals arsenic, cadmium, chromium,nickel and lead are present at concentrations greater than the applicable Reportable Concentrations in soil and groundwater at the Site. j r i The source of the constituents of concern is historic tanning operations and fill deposited in conjunction with the construction of the tanneries that occupied the Site. On October 12, 2011, SP, Inc. submitted a Release Notification Form (RNF)to the Massachusetts Department of Environmental Protection(DEP)on behalf of Riverview Place, LLC for these reportable release conditions. In addition, during the W&S assessment, soil containing arsenic at a concentration greater than the Imminent Hazard threshold was encountered in two locations(in close proximity to each other). An Immediate Response Action that included completion of the fence surrounding the Site and covering the area containing the elevated concentrations was completed. The findings of the W&S subsurface investigation has resulted in modifications to the RAM Plan that include an IH condition and new removal Area H. The RAM is being conducted to remove the affected soils and treat affected groundwater that may be generated during dewatering of the excavation. We believe that the additional information included herein addresses the concerns of the DEP and we request approval of the Plan so that remediation can begin. Please do not hesitate to contact the undersigned if you have any questions regarding this submittal. Sincerely, SP,INC. Bruce M. Poole David L. Bramley, PE, LSP, LEP President Enclosure cc: Michael O'Brien w/enclosure TABLE OF CONTENTS SECTION PAGE 1.00 INTRODUCTION............................................................................................................... 1 2.00 DESCRIPTION OF SITE CONDITIONS AND RELEASE.............................................. 1 2.10 Site Description.......................................................................................................... 1 2.20 Background................................................................................................................2 2.30 Former Process Operations........................................................................................ 3 3.00 PREVIOUS ASSESSMENTS............................................................................................4 3.10 1999 Limited Release Action 4 3.20 2005 Subsurface Assessment..................................................................................... 5 3.30 2009 Subsurface Assessment.....................................................................................5 3.40 2010 Immediate Response Action 6 3.50 2012 Weston& Sampson Brownfields Assessment..................................................7 4.00 RELEASE ABATEMENT MEASURE PLAN.................................................................. 8 4.10 Objectives .................................................................................................................. 8 4.20 Constituents of Concern........................................................................................... 10 4.30 Soil Excavation and Confirmation Sampling .......................................................... 14 4.35 IH Soil Management 15 4.40 Oily Soil Management............................................................................................. 15 4.50 Ashy Soil Management............................................................................................ 17 4.50.1 General......................................................................................................... 17 4.50.2 Solidification/Stabilization.......................................................................... 17 4.60 Lagoon Soil Management........................................................................................20 4.70 Historic Fill Management........................................................................................21 5.00 SITE MONITORING........................................................................................................21 5.10 Air Sampling 22 5.20 Dust Control.............................................................................................................25 6.00 MANAGEMENT OF REMEDIATION WASTE............................................................28 7.00 POST REMEDIATION MONITORING.......................................................................... 28 8.00 PERMITS,APPROVALS, AND NOTIFICATIONS.......................................................29 9.00 PROPOSED SCHEDULE................................................................................................ 30 FIGURES Figure 1 Site Locus Figure 2 SP Site Investigations Plan Figure 3 Site Plan Figure 4 Site Scoring Map Figure 6A Proposed Phase H Site Investigation Plan (W&S) Figure 6B Proposed Imminent Hazard Investigation Plan (W&S) TABLE OF CONTENTS (continued) SECTION PAGE TABLES Table 1 - Soil Borings Locations Table 2 - Soil Analytical Results 2005 (Borings) Table 3 - Groundwater Analytical Summary Table 4 - Test Pit Locations Table 5 - Soil Analytical Results 2009 (Test Pits) Weston& Sampson Tables Table 2 Soil Boring Analytical Results (August 6, 2012) Tables 3a—3d Test Pits—Preliminary Analytical Results (August 21, 2012) Tables 4a—4b Imminent Hazard Investigation—Draft Analytical Results (August 9, 20 12) Table 6 Summary of W&S TCLP Analyses APPENDIXES Appendix A - BWSC-106, Release Abatement Measure Transmittal Form Electronic submittal summary and receipt Appendix B—Boring and Test Pit Logs Appendix C - Laboratory Analytical Reports Appendix D - Public Notification Letters 1.00 INTRODUCTION The purpose of this document is to present a Release Abatement Measure (RAM) Plan for the excavation and relocation, or removal of soil petroleum hydrocarbons,PAHs, and containing metals at concentrations greater than the applicable cleanup standards at the property located at 72 Flint Street in Salem,Massachusetts (the "Site"). SP, Inc. (SP)prepared this document on behalf of our client, Riverview Place,LLC: A Site Locus is included as Figure 1, and a Site Plan is presented as Figure 2. This document and the Bureau of Waste Site Cleanup (BWSC)RAM Transmittal Form BWSC-106 were filed electronically using eDEP on November 10, 2011. A copy of the BWSC Form and the electronic submittal receipt are included in the client copy of the document. A modified document was filed on February 27, 2012. The party assuming responsibility for conducting the RAM is: Mr. Michael O'Brien Riverview Place, LLC 5 Broadmoor Lane Peabody, Massachusetts 01960 978-979-4072 The Licensed Site Professional (LSP)for the RAM is: David L. Bramley, LSP (No. 7639) SP, Inc. 45 Congress Street Salem,MA 01970 978-745-4569 2.00 DESCRIPTION OF SITE CONDITIONS AND RELEASE 2.10 Site Description The Site is located on the east side of Flint Street, south of Mason Street, and north of the North River Canal in a primarily residential area of Salem, Massachusetts. The generally rectangular lot contains 3.69 acres and it is identified on Map No. 6 as parcel 26-0091-0. The Site originally contained several interconnected multi-story structures that were demolished in 2009. The first and second stories were of brick construction. The upper floors were of wood framing and sheathing. There is a large paved area at the Flint Street entrance and a paved driveway access from Mason Street. The site slopes toward the North River and approximately one-third of the property is in the Zone A floodplain. Based on the topography of the Site, groundwater the groundwater flow direction is southerly toward the North River. The industrial buildings along the North River were placed on the Most Endangered List in 2000 due to constant threat of demolition. Since that time, three of the industrial buildings, including Salem Suede,have been demolished; another, Bonfanti Leather is to be demolished in conjunction with the redevelopment of the Salem Suede parcel. The North River has been a 72 Flint Street, Salem, MA _ December 3, 2012 Page 2 center of commerce since Salem's earliest days. Before it was successively filled in the 19th and 20th centuries,the North River was navigable and served as a location for loading and unloading goods from the late 18th century into the 19th century. Currently,the Salem Suede portion of the Site is vacant. Concrete slabs from the former buildings and miscellaneous debris from the demolition project remain on the Site. The Bonfami Leather building that was north of the Site was demolished in October 2012. Riverview Place, LLC, the developer,has received approval from the Salem Planning Board to redevelop the Site with a 136-unit residential housing complex that will include a parking structure. Remediation of the Site will begin after approval of this RAM Plan by the DEP and when weather conditions are acceptable. 2.20 Background Sanborn Insurance Maps map show the area was heavily industrialized with tanneries, oil processors, and wood workers in the late 1800s. The site was occupied by the J.Gibney Tannery in 1890. The large Patrick O'Keefe tannery, existed behind(to the south)and to the east along with other leather industries and dwellings. Tannery wastewater was discharged to the North River until the 1950s. The Site and the surrounding area had been filled by the early 1800s to support the construction of the tannery buildings. Fill materials commonly included leather scraps, buffing dust, coal ash, and tanning barks. The most prevalent fill material was red fiber, which is spent hemlock, mimosa, quabracco, and wattle barks that were used before chromium to dye the leather red and brown without chemicals (vegetable tanning). The facility burned coal in the early 1900s and a layer of coal ash was encountered a Boring No. 5 adjacent to the boiler room. By 1906 the buildings on the site were gone due to the Great Salem Fire of 1904. Dwellings still were located along the Flint Street and the Broadly Leather Co. was in operation to the east. The 1925 Sanborn map shows the buildings as they existed prior to demolition with a side building, extending to the east. Subsequent to the fire, the original tannery on the site was Leach and Heckel, Inc., which was a full cowhide tannery. The company conducted leather beaming, tanning, coloring and finishing operations. The buildings that were demolished in 2009 were constructed in 1925. A 10,000- gallon heating oil tank formerly was present in the front (west) portion of the Site that was removed in 1999. Photographs from 1954 show the presence of a lime or wastewater pit adjacent to the North River in the south corner of the property. As of 1970, the buildings remained the same and surrounding uses were consistent with 1950-1970. In 1978 the tannery was purchased by Salem Suede Inc. and an entrance from Mason Street was created. In the early 1980s a steel sided warehouse was constructed on the east property line. Wastewater from the tannery has been treated at the South Essex Sewerage District since 1965, when an interceptor was installed in Bridge Street. The facility installed a wastewater 72 Flint Street, Salem, MA January 22, 2013 Page 3 pretreatment system in 1984,to remove solids, BOD, chromium and grease from the manufacturing effluents. According to the DEP Priority Resource Map for the Site and vicinity, the Site is not located within a current or potential drinking water source area as defined in the Massachusetts Contingency Plan (MCP). However,much of the Site is located within a 200-foot Riverfront Area and a 100 foot Wetland Buffer Zone. According to personnel at the Salem Board of Health, private, potable water wells are not known to exist within 500 feet of the Site. Therefore, groundwater at the Site is classified as GW-2 and GW-3. 2.30 Former Process Operations Tanning is a general term used for the process of converting animal skins to finished leather. Animal hides and skins absorb tannins to keep them from decaying and to keep them pliable. Technically,the term "tanning" refers to the process by which collagen fibers in a hide react with a chemical agent(tannin, alum or other chemicals), but the term leather tanning also commonly refers to the entire leather making process. First animal skins or hides are 'cured" by wet-salting or brine-curing. Then the hides are soaked in water for several hours or days after which the remaining flesh is removed. At that point,the hair is removed by soaking the hide in a mixture of lime and water and then removing the hair from the hide. After the hide is cleaned, the hides are delimed in an acid vat and treated with enzymes to smooth the grain and make the leather soft. At thisoint the hides are "tanned". Traditionally,raditionally, leather was tanned using vegetable tannins. This process is still used for some hard leathers. In vegetable tanning, hides are hung on large frames, located inside large vats, and exposed them to tannin, a natural product found chestnut, oak and hemlock trees. Hides are transferred to many different bins during this step, each containing a stronger solution of tannin. By the early 1900s, chromium salts were used instead of vegetable tannins for much of the leather production. In this process, hides are pickled in an acid and salt mixture and then soaked into a chromium-sulfate solution. This process is much faster than vegetable tanning, often completed in one day. After tanning,the hides then go through a dying process which adds moisture back into the skin. Hides which have been vegetable tanned are bleached and them soaked with oils, soaps, greases and waxes to make them more pliable. The leather is then rolled through a machine, stretched and dried. The final step in the tanning process is called finishing the skin. The grain surface is covered with a chemical compound and brushed. At the very end, waxes,pigments, dyes, glazes, oils, waxes and other solutions are also added to make the leather depending on what is needed in the final product. 72 Flint Street, Salem, MA January 22, 2013 Page 4 Salem Suede was a traditional chrome tanning facility. Available information indicates that vegetable tanning was not a process operation,therefore, bleaching was not conducted at the facility and the formation of dioxins from bleaching operations is not a process of concern. At some tanneries, phenols/cresols were used in the tanning process, as tanning agents and fungicides, respectively. Dioxin was not used in the tanning process but is a common impurity in chlorinated phenols that were used in some tanneries. The four-story building closest to the North River was used for beaming and tanning the leather. This involved removing the hair and fat with lime and sulfide baths, followed by a degreasing process called bate which used ammonia and enzymes to open the pores of the leather. The hide was fleshed after beaming and then pickled in sulfuric acid and salt. Trivalent chromium solutions were added to the large drums to tan the leather. Review of available data indicates that bleaching of the hides was not a process operation. The chromium penetrates the leather and binds to the protein to act as a mordant for dyes and pigments. The process is aided by the addition of phenolic syntans. These first steps of the process were discontinued by 1984, as pretreatment regulations were implemented. Subsequently,the facility purchased blue stock (tanned) sides and splits to color, fat liquor and finish. The center four story building was used for coloring the leather. Aniline and cationic dyes of all colors were applied in formic acid or ammonia baths to combine with the chromium. The fat liquors were sulfonated animal and fish oils that were applied to the leather in warm baths to restore suppleness, flexibility and water resistance. The finishing of leather occurred in the upper two stories and in the building to the north. Finishing was conducted using spray equipment to apply clear, colored or pigmented coatings to the top grain side of the leather for the polished appearance in shoes,pocketbooks, belts and garments. The finish operations used small amounts of toluene and xylene solvents as well as butyl acetate, glycol esters and other water-based emulsions. The buildings to the east were constructed of concrete block and the steel-sided warehouse structures were used to store raw blue stock and wet color stock. 3.00 PREVIOUS ASSESSMENTS 3.10 July 1999 Limited Removal Action Based on a review of information provided to Weston& Sampson by SP Inc. in May 2012, a Limited Removal Action (LRA)was performed at the Site in conjunction with the removal of a former No. 6 heating oil tank in July 1999. According to the site plan prepared by SP hic.,the dimensions of this former tank were 9 feet in diameter and 21.5 feet in length. These dimensions equate to an approximate volume of 10,000 gallons and the tank was oriented in a southwest- northeast axis. The LRA included the excavation of approximately 120 tons of soil, which was stockpiled and characterized for off-site disposal. The stockpile was subsequently removed and disposed at the Bandon Trimount(currently Aggregate Industries) Salem, Massachusetts facility. The post excavation confirmatory soil analytical results collected from the tank grave sidewalls 72 Flint Street, Salem, MA January 22, 2013 Page 5 indicated total petroleum hydrocarbon (TPH) concentrations ranging from 1,560 milligrams per kilogram (mg/kg)to 117,000 mg/kg. Based on a review of MassDEP regulatory files, it does not appear that LRA activities were continued as a Release Abatement Measure (RAM) as specified in the MCP. 3.20 2005 Subsurface Assessment A modified Phase I—Environmental Site Assessment(ESA) was prepared by SP, Inc. in June 2005. The Phase I—ESA included the drilling of eleven soil borings, six of which were completed as groundwater monitoring wells. The soil logs are contained in Appendix B. The locations of the borings and monitoring wells are shown on Figure 2. The purpose of the assessment was to evaluate the potential for the release of hazardous material or oil and to characterize subsurface conditions at the Site. Observation of the soil samples collected indicates that the area was filled with soil and red tanning fiber, leather scraps, cinders, and coal ash from the late 1800s. The underlying native soils are grey and tan sand and silt. The borings and monitoring wells were installed in areas where former Site activities or process features were conducted. The Site owner provided information on former Site features to assist in selecting soil boring locations. Table 1 presents an identification of the boring and monitoring well locations and the reason for selecting the location. A summary of the soil and groundwater analytical results is contained in Table 2 and Table 3, respectively. The analytical data have been compared to the applicable cleanup standards. Except for two exceedances of the Method 1 S-1, GW-2 cleanup standards, one for Benzo(a)pyrene and for Dibenzo(a,h)anthracene, the concentrations of the PAHs are less than the applicable cleanup standards. However,there are numerous exceedances of the cleanup standards for the metals of concern,particularly chromium as would be anticipated at a leather tannery. There also are exceedances of the cleanup criteria for cadmium in two soil samples and lead in three soil samples. The laboratory analytical reports are included in Appendix C. Analyses of groundwater samples from monitoring wells MW-3, MW-4, and MW-5 for PAHs did not detect an exceedance of the GW-2 or GW-3 cleanup criteria. However, exceedances of the chromium and lead cleanup criteria were detected in the samples. 3.30 2009 Subsurface Assessment In December 2009 a second subsurface investigation was conducted to assess whether there had been a release of oil or hazardous materials to the soil below the floor slabs of the former tannery building. With the removal of the superstructures, the excavation of test pits through the concrete floors of the various operating areas of the tannery could identify affected soil that might result in a release to the environment during demolition of the slabs. The test pit logs are included in Appendix B. 72 Flint Street, Salem, MA January 22, 2013 Page 6 A total of nine test pits were excavated in eight separate areas. Two test pits (TP-3 and TP-3A) were excavated in the vicinity of the boiler room. Table 4 identifies the locations of the test pits and the rationale for the location. During excavations natural alluvial soils, fine sand, grey clay,peat, and green silt were encountered at depths of approximately six to ten feet below grade. Red tanning bark, which was used to color leather in the 1800s before chromium mordants were developed, was deposited on the native soil at a depth of three to six feet below grade. Above this layer were large rocks, . gravel, ash, bricks, and wood that are present as a result of the Salem fire, and leather, concrete, coal ash and other miscellaneous fill materials. A summary of the analyses of the samples for metals is presented in Table 5. The concentrations of lead range from 11.4 to 145 mg/kg, which is less than the Method 1 S-1 cleanup standard of 300 mg/kg. The range of concentrations of cadmium is 0.26 to 11.6 mg/kg compared to the Method 1 S-1 cleanup standard of 2 mg/kg and the S-2 cleanup standard of 30 mg/kg. The chromium concentrations varied widely due to the presence of pieces of leather, leather shavings, buffing dust and trimmings included with the fill deposited before the 1925-era structures were constructed. These chromium-containing waste streams were delisted as hazardous wastes by the EPA in 1985 because the chromium is exclusively trivalent and non-toxic when bound to leather. 3.40 February 2010 Immediate Response Action In February 2010, the Salem Fire Department reported to MassDEP two Threat of Release (TOR) conditions from separate sources located in different areas of the Site (i.e., a former wastewater treatment system aboveground storage tank(AST) located on the southern portion of the property, and animal oil storage ASTs situated on the central portion of the property). Consequently, MassDEP assigned Release Tracking Number(RTN) 3-29082 for the wastewater treatment system AST and RTN 3-29083 for the four-in-series animal oil ASTs. Response actions were managed by Alliance Environmental Group, Inc. (AEG) under an orally approved Immediate Response Action (IRA)Plan and included the pumping to frac tanks of liquid waste, and the cleaning and removal for off-site disposal of tank sludges and solids. Following the development of appropriate application information, AEG obtained authorization from the South Essex Sewer District(SESD)for continuous monitored discharge to the sewer of free liquids from the former wastewater system. AEG filed an IRA Completion and Class A-1 Response Action Outcome (RAO) Statement with the MassDEP on February 22, 2011 to achieve regulatory closure for RTNs 3-29082 and 3-29083. The IRA Completion and RAO Statement were completed to show a threat of release had been eliminated at the Site. Information provided on the MassDEP Waste Site/Reportable Releases Look Up website did not identify any outstanding regulatory compliance issues for RTNs 3-29082 and 3-29083. It should be noted that AEG attributed soil contamination in the areas proximate to the former wastewater treatment system to "fill materials and activities within the area."Furthermore, AEG stated that "the findings of the wastewater treatment area assessment will be subject to a 120- day notification process and reported under a new RTN."A new notification to MassDEP under the I - 72 Flint Street, Salem, MA January 22, 2013 Page 7 120-day regulatory requirements (i.e., 310 CMR 40.315), and subsequent assignment of a new RTN was completed later in 2011. 3.50 2012 Weston & Sampson Brownfields Assessment In August 2012 Weston& Sampson(W&S) conducted a Phase H Subsurface Assessment to further evaluate the nature and extent of the affected soil and groundwater identified during the previous subsurface investigations. The W&S assessment was conducted under Brownfields grant No. BF96113201 administered by the Metropolitan Area Planning Council(MAPC). The Site has been identified as a strategic location to restore and reuse to support the redevelopment of adjacent parcels. A proposed 136 unit residential development is proposed for the Site. The relationship of the proposed buildings to the former building is shown on Figure 3 by Eastern Land Survey. The locations of the test pits, borings, and monitoring wells are shown on W&S Figures 6A and 6B. Summaries of the soil analytical data are presented in W&S Table 2, Tables 3a through 3d, and Tables 4a and 4b. The scope of the assessment included the drilling of twelve soil borings (that were completed as monitoring wells) and the excavation of fourteen test pits. Analyses of the soil samples collected during this investigation detected elevated concentrations of arsenic and chromium in several samples. The chromium was reported as total chromium rather than differentiated between trivalent and hexavalent chromium. As a result of the first phase of the investigation, nineteen additional surficial soil samples were collected. Volatile organic compounds and PCBs were nor detected. The constituents of concern are EPH and PAH and metals which is consistent with the conclusions of the 2005 and 2009 assessments. The Imminent Hazard(IH)threshold concentration of arsenic of 40 mg/kg was exceeded in two soil samples. The concentration in the samples from sampling points SB-204 and SB-208 are 51 and 120 mg/kg respectively. An Immediate Response Action that included installing a six-foot high chain link fence around the perimeter of the Site that was not previously fenced and posting of warnings signs was completed on September 21, 2012. Additional analyses of the samples containing elevated concentrations of chromium confirmed that there is no exceedance of the IH threshold because the chromium is trivalent chromium. In addition, elevated concentrations of nickel and mercury were detected as well as several polycyclic aromatic hydrocarbons (PAHs) in the sample from boring SB-103 and several of the test pits. The dioxin 2,3,7,8 TCDD was detected in the soils at concentrations less than the MCP standard of 20 (pictograms per.gram(pg/g). The concentrations ranged from 0.48 to 9.28 pg/g with the concentration in the sample from TP-109D at 0-3' being the highest. Other less toxic and non- regulated dioxins and furans were detected in the soils with background levels of 1,2,3,6,7,8 HXCOD at 20-30 pg/g present in most samples. The concentration is the samples from TP-107, 109 and SB-208 was ten times the background values at 214-613 pg/g. Analyses for these compounds were not conducted previously but they often are found on heavily industrialized sites. The buildings on this Site were destroyed by fire in 1914 and the bum debris was buried on-Site. 72 Flint Street, Salem, MA January 22;2013 Page 8 The soils with elevated concentrations of dioxins correspond with areas of historical fill and solid waste in the southwest corner that previously had been identified for off-site removal because of the presence of other contaminants,particularly chromium, arsenic, lead and nickel. The analytical results will become part of the waste profile submitted to the disposal facilities. The dioxin impacted soils would not be stabilized for use on-site. The locations of TP-107, 109 and SB-208, as overlaid in Figure 5B correspond with removal areas; Area B is the location of the former wastewater treatment system, and Area H is the area with elevated concentrations of arsenic. The isolated area of SB-213 on the North property line will be removed and consolidated with Areas B+H. This removal will eliminate the soils with the ten-times concentration dioxin compounds (compared to site background). In Area G, W&S found a vat system underneath the former tan room that had been used for chromium recycling and contained residue. The residue will be removed before demolition of the concrete as part of the soils removal in G. The investigation also confirmed the presence of leather scrap, shavings and solid waste in Area F. The site has been filled six to ten over the last 150 years and the contaminated soils are in zero to six foot stratum. The soil beneath the tanks will be analyzed and removed if necessary. Analyses of groundwater samples collected by W&S did not detect the constituents of concern at concentrations greater than the applicable GW-2 and GW-3 cleanup standards. 4.00 RELEASE ABATEMENT MEASURE PLAN 4.10 Objectives The objective of this RAM is to excavate and remove the soils that contain historic fill and sludges and have been affected by oil, dioxins, furans and heavy metals at concentrations greater than the applicable Method 1, S-1/GW-2 criteria from the areas A-H identified on the Site Plan Figure 2. The excavated soil will be recycled at a licensed off-Site facility,transported to a licensed disposal facility, or stabilized and reused on the Site. The purpose of the stabilization and solidification process would be to convert certain on-site materials to structurally suitable underlayment that would be placed under the parking garage and other suitable locations. There are two types of soils on the site that would be suitable for reuse. The first is the coal ash and the gravel found in area E. The ash is found in layers that probably originated from before 1940 when fuel oil was first used. The other areas, F and to a lesser extent G contain leather scrap,buffing dust and shavings mixed with gravel,rock and soil. The leather pieces were broken down over time and resulted in the elevated chromium concentrations. Both soil types would compact well, have low organic content and would stabilize with cement, gravel and/or lime. While the soils currently pass the TCLP leachability criteria the stabilization and placement of the material above the groundwater table and under impervious surfaces will minimize the potential for metal or organic release to the groundwater. 72 Flint Street, Salem,MA January 22, 2013 Page 9 The Site Plan,Figure Two submitted with the RAM was/is the approved plan for the Wetlands Act Order Of Conditions issued on January 23, 2012 as DEP File# 64-518. The plan is highly detailed because of modifications developed during the 6 month permitting and public hearing process. At that time in 2011 many of the structures, tanks, debris and solid wastes were still on the property and were therefore shown on the plan. By the spring of 2012 all structures were demolished,the transformers, chemical drums,tanks, pallets of blue bellies and buffing dust bags had all been removed. To explain the changes over the last years we modified the original 1999 Site plan to show the past conditions,Figure 3 and locations of potential release sources; ie, the wastewater treatment system, dumpster,chemical storage area, chromium tanks, fuel UST, former lagoon and process areas. In that drawing we have removed the "on-site disposal cell"which is proposed not existing,the equipment/truck cleaning area and the WW storage tank(which was a portable sealed tank used to hold the washwater generated by high pressure washing). This process of equipment decontamination is outlined in the RAM Plan section 6.00. Also for clarification,the eastern berms shown in Figure 2 are temporary structures placed between the excavations and the River to control runoff during rain events while soil removal is occurring. To show current conditions Figure 4 another site plan has been prepared to show the remaining concrete slabs. That plan identifies the soil removal areas A-H,the contaminants of concern, soil stockpile locations and the UCL exceedances in the arsenic impacted areas. The W&S investigation identified two isolated areas containing metals, dioxins and PAI-Is by the north property line and east corner. The top layers (0-3') around SB-213 to SB-103 shown in current conditions and will be removed and consolidated with Area H because of dioxin presence. The other isolated areas at SB-112, TP-114 and TP-108 will be removed to the extent of the fill, as this will become public green space in the future development. Additional data points by W&S have increased the size of removal Area D and A as EPH compounds and metals were found outside of the estimated excavation boundaries. These extensions are shown in Figure 4 current conditions and would increase the volumes removed by approximately 300 cy. The third plan was taken from the approved Eastern Land Survey Planning Board documents and contains the proposed future conditions, Figure 5 with buildings, roads, garage and the location of the proposed on site disposal cell. Part of the rationale for the extent of remediation is related to the ultimate configuration of the development. Certain"site wide" contaminants such as PAHs and trivalent chromium are not economically feasible to remove from the site, but pose minimal exposure and health risk if they are; 1. found greater than 3' below grade, 2. are beneath concrete building slabs or 3. are contained by pavement and structural fill. Areas designated to be cleaned completely to 3' or suitable soils are; all public walks, dog exercise areas, landscaped fringes and flower gardens. Utility easements for electrical, water, sewer and stormwater will also be completely cleaned to the extent of utility excavation. While the Site Floodplain(Zone A) at 10.3'EL (inside the 100' buffer) will remain at current elevation, developed parts of the site will receive 2'-4' of crushed concrete and fill. The floor elevations of buildings 1 and 2 is 11.5'. The access road at Flint Street starts at elevation 9' and grades to elevation 18' on the north side. 72 Flint Street, Salem, MA January 22, 2013 Page 10 The 4-5 story buildings would be slab on grade construction supported by pilings. It will not be necessary to remove perimeter soils for spread footings. The complexity of the site will require a Method 3 Risk Assessment to achieve a RAO. The original plan "of record"with the Conservation Commission, has been updated to show the new Area H that was impacted by arsenic at levels above the UCL. 4.20 Constituents of Concern Several assessments have been conducted on the property. In addition, SP provided environmental support services for the Salem Suede facility when it was operating. The following constituents of concern have been identified through knowledge of process and Site soil and groundwater sampling and analyses. To a lesser extent cadmium and nickel were found in some areas and the health affects would be similar to the lead impacts listed below. Arsenic Breathing high levels of inorganic arsenic can cause a sore throat or irritated lungs. Ingesting very high levels of arsenic can result in death. Exposure to lower levels can cause nausea and vomiting, decreased production of red and white blood cells, abnormal heart rhythm, damage to blood vessels,and a sensation of"pins and needles" in hands and feet. Ingesting or breathing low levels of inorganic arsenic for a long time can cause a darkening of the skin and the appearance of small "corns"or"warts"on the palms, soles, and torso. Skin contact with inorganic arsenic may cause redness and swelling. The Massachusetts Contingency Plan (MCP) cleanup concentration for residential uses is 20 mg/kg. ACGIH notes that arsenic is a confirmed human carcinogen. The following are exposure limits for inorganic arsenic in air: REL Ceiling: 0.002 mg/m3 15 min(Ca) PEL: 0.010 mg/m3 IDLH: 5mg/m3(Ca); TLV: 0.010 mg/m3(Al) Chromium Chromium is the most common heavy metal waste from the tanning process. In the environment, chromium can be present in two different forms: trivalent chromium and hexavalent chromium. Determining the form of chromium is important because trivalent chromium is much less toxic than hexavalent chromium. In fact,the EPA delisted trivalent chromium as used in the tanning process as a hazardous waste. 72 Flint Street, Salem, MA January 22, 2013 Page 11 Typically,nearly all of the chromium present in tannery sludge is present in the relatively non- toxic trivalent form. This is consistent with the fact that almost all of the chromium used in leather tanning is trivalent. Analytical data(Appendix C) collected in conjunction with an assessment of the soil and contents of the former wastewater treatment tank in the southwest corner of the Site show detections of hexavalent chromium only at very low concentrations, two orders of magnitude less than the applicable cleanup standard. Therefore, while there are elevated concentrations of total chromium in some areas of the site, they are still below levels of health concern because the chromium is mostly in the trivalent form. Exposure to chromium can occur through breathing, eating or drinking, and through skin contact with chromium or chromium compounds. The level of chromium in air and water generally is low. In drinking water the level of chromium usually is low as well. For most people eating food that contains chromium(Ill) is the main route of chromium uptake, as chromium(III) occurs naturally in many vegetables, fruits, meats,yeasts and grains. Various ways of food preparation and storage may alter the chromium contents of food. When food is stored in steel tanks or cans chromium concentrations may be higher. Chromium(1II) is an essential nutrient for humans and shortages may cause heart conditions, disruptions of metabolisms and diabetes. But the uptake of too much chromium(III) can cause health effects as well, for instance skin rashes. Chromium(VI) is a danger to human health, mainly for people who work in the steel and textile industry. People who smoke tobacco also have a higher chance of exposure to chromium. It is known to cause various health effects. When it is a compound in leather products, it can cause allergic reactions, such as skin rash. Other health problems that are caused by chromium(VI) are: ➢ Skin rashes ➢ Upset stomachs and ulcers ➢ Respiratory problems ➢ Weakened immune systems ➢ Kidney and liver damage ➢ Alteration of genetic material ➢ Lung cancer ➢ Death The following are exposure limits for chromium III compounds in air: REL: 0.5 mg/m3 PEL: 0.5 mg/m3 IDLH: 25 mg/m3(Cr III) Lead Lead is a soft metal that has known many applications over the years. It has been used widely since 5000 BC for application in metal products, cables and pipelines, but also in paints and 72 Flint Street, Salem, MA January 22, 2013 Page 12 pesticides. Lead is one out of four metals that have the most damaging effects on human health. It can enter the human body through uptake of food(65%), water(20%)and air(15%). Lead occurs naturally in the environment. However, most lead concentrations that are found in the environment are a result of human activities. Due to the addition of lead in gasoline an unnatural lead-cycle has resulted. In car engines lead is burned,producing lead salts (chlorines, bromines, and oxides). These lead salts enter the environment through the exhausts of cars. The larger particles will drop to the ground immediately and pollute soils or surface waters,the smaller particles will travel long distances through air and remain in the atmosphere. Part of this lead is deposited during precipitation. Foods such as fruit, vegetables, meats, grains, seafood, soft drinks and wine may contain significant amounts of lead. Cigarette smoke also contains small amounts of lead. Lead can enter (drinking) water through corrosion of pipes. This is more likely to happen when the water is slightly acidic. That is why public water treatment systems are now required to cavy out pH- adjustments in water that will serve drinking purposes. Lead can cause several unwanted effects, such as: • Disruption of the biosynthesis of hemoglobin and anemia • A rise in blood pressure • Kidney damage • Miscarriages and subtle abortions • Disruption of nervous systems • Brain damage • Declined fertility of men through sperm damage • Diminished learning abilities of children • Behavioral disruptions of children, such as aggression, impulsive behavior and hyperactivity The MCP cleanup concentration for residential uses is 300 mg/kg. The following are exposure limits for lead released into the air: PEL: 0.05 mg/m3 REL: 0.10 mg/m3 IDLH: 100 mg/m3 (Pb) No.4 Oil Fuel oil numbers 4, 5, and 6 are commonly known as "residual oils" since they are manufactured in whole or in part from distillation residues from refinery processing. These three heavy fuel oils are also known as gas oils and are composed of hydrocarbons ranging from C19 to C25- 72 Flint Street, Salem, MA January 22, 2013 Page 13 Residual oils are complex mixtures of relatively high molecular weight compounds and are difficult to characterize in detail. No. 4 fuel oil is a mixture of No. 2 and No. 6 oil which intended for use in atomizing type burners that atomize oils of higher viscosity than domestic burners can handle. The permissible viscosity ranges of no. 4 fuel oil allow it to be pumped and atomized at relatively low storage temperatures. Therefore, in any weather(except extreme cold), it requires no preheating for handling in these burners. No. 4 oil can be directly toxic to some forms of aquatic life, can coat birds, and is of concern as a potential source of polycyclic aromatic hydrocarbons (PAHs), a potentially harmful class of aromatic hydrocarbons. Chronic effects of some of the constituents in No. 4 oil (such as naphthalenes) include changes in the liver and kidney. Due to their relative persistence and potential for various chronic effects (like carcinogenicity), PAHs(and particularly the alkyl PAHs) can contribute to long-term (chronic)hazards in contaminated soils, sediments, and groundwater. Certain components of No. 4 oil, such as PAHs, may be carcinogenic to animals and humans. There is evidence for the carcinogenicity in experimental animals of residual (heavy) fuel oils and cracked residues derived from the oil refining of crude oil. Residual (heavy) fuel oils are possibly carcinogenic to humans. Polycyclic Aromatic Hydrocarbons The term polycyclic aromatic hydrocarbon(PAH)refers to a group of several hundred chemically-related environmentally persistent organic compounds of various structures and varied toxicity. Benzo[a]pyrene commonly is used as an indicator species for PAH contamination and most of the available data refer to this compound. PAHs maybe formed during natural processes such as incomplete combustion of organic materials such as coal and wood, or during forest fires. PAHs are released during industrial activities such as aluminum, iron and steel production in plants and foundries, waste incineration, mining or oil refining. PAHs have also been detected at low levels in cigarette smoke and motor vehicle emissions. They are persistent organic pollutants and are slow to degrade in the environment. PAHs also are present in asphalt. PAHs have been found to be present in very small amounts in some foods including meat, fruit, vegetables and cereals. Various cooking processes such as charbroiling, frying or grilling, as well as barbequing or smoking also increases the amount of PAHs in food. Overall,the major route of exposure to PAHs in the general population is from breathing ambient and indoor air, eating food containing PAHs, smoking cigarettes, or breathing smoke from open fireplaces. The presence of PAHs in the environment does not always lead to exposure as there must be contact with the chemical. There may be exposure via breathing, eating, or drinking the 72 Flint Street, Salem,MA January 22, 2013 Page 14 substance or by skin contact. Following exposure to any hazardous chemical,the adverse health effects depend on several factors, including the amount of exposure (dose), the duration of exposure, the method of exposure, and exposure to other chemicals. Some PAHs caused tumors in animals when they breathed, ate, or had skin contact for long periods. Studies in humans have shown that breathing or skin contact for long periods may cause lung or skin cancer. Several PAHs have been classified by the International Agency for Research on Cancer(IARC) as being carcinogenic in humans. Dioxins and Furans These compounds are found on heavily industrialized sites as trace contaminants in pesticides, pentachlorophenol and other chlorinated phenolics. They are persistent contaminants and degrade slowly in the environment. Studies have shown that exposure by breathing, consumption or skin contact may cause cancer in animals and human. The current standard for 2,3,7,8 TCDD dioxin is 20pg/g. The recent investigation found 0.48-9.28 pg/g, and larger concentrations of other related compounds. 4.30 Soil Excavation and Confirmation Sampling Approximately 2855 cubic yards (approximately 3,500 tons) of soil affected by petroleum, ash, metals,leather wastes, or lime have been identified. Approximate) 200 cubic ands 270 tons of Y Y ( ) arsenic-containing soil is present in the IH area designated as Area H. The W&S data indicated EPH and metal impacted soils beside Area A+D that will be removed as well. The areas where theses wastes are present and the estimated quantities are listed below and are shown on Figure 2. Two isolated areas in the east comer and north property line will also be removed and placed with the appropriate waste stream. Oily soil Area D 180 cubic yards (approx 240 tons) Ashy soil Areas B, C, and E 515 cubic yards (approx 620 tons) Lagoon Area A 710 cubic yards (approx 850 tons) Historic fill Areas F and G 950 cubic yards (approx 1,150 tons) Arsenic fill IH Area H 200 cubic yards (approx. 270 tons) W&S soils Iso Area, D+A 300 cubic yards (approx. 360 tons) 2855 cubic yards SP, Inc will arrange for a licensed contractor to excavate,transport, and dispose of the affected soil as discussed in the following sections. Soil excavation will be monitored by a representative of SP. As VOCs have not been identified as constituents of concern, use of a photoionization detector(PID) will not be effective in establishing the limits of the excavation. Rather, visual assessment(and odor at some locations) and a multi-gas meter for sulfides and methane will be used to estimate the limits of excavation and suitability of the soil for on-site reuse. Confirmation soil samples will be collected to support the effectiveness of the excavation activities. Confirmation soil samples will be collected at a minimum of one per each sidewall 72 Flint Street, Salem, MA January 22, 2013 Page 15 and one from the bottom of the excavation. For excavations with extended sidewalls in the horizontal direction, confirmation soil samples will be collected at a frequency of one sample at 25 feet on center. Bottom confirmation samples will be collected at a frequency of one sample per approximately 500 square feet. For example, an excavation with dimensions of 100 feet long by 40 feet wide would require 12 sidewall samples and 8 bottom samples. Composite samples of specific areas will be prepared for the PCB, VOC, dioxin and furan analyses. Confirmation soil samples will be analyzed for one or more of the following constituents of concern depending on the location on the Site. The analyses proposed for each specific area are shown below. Although VOCs have not been identified as constituents of concern, confirmation analyses will include VOCs and dioxins for representative soil samples. Also, laboratory analyses of soil samples collected during Site assessments did not identify the presence of PCBs at concentrations greater than the laboratory reporting limit. However,where appropriate in areas with historic fill, analyses for PCBs will be included in the confirmation samples analyses. 4.20 Confirmation Analyses Areas Tested ➢ MCP metals by EPA Method 6010 A-H ➢ VOCs by EPA Method 8260B A, D ➢ PAHs.by EPA Method 8270C A, B, C, E ➢ EPH by DEP Method 04-1 D ➢ PCBs by EPA Method 8082 A, D ➢ Dioxins by EPA Method 8290 A, B, H 4.35 Imminent Hazard (IH) Soil Management The recent study by W&S found an additional area of arsenic impacted soil at SB-204 and SB- 208 that exceeded the UCL and resulted in an Immediate Response Action to deal with the"IH condition. The site was fenced around the perimeter and the IH area covered with 8-12" of clean soil. Designated Area H, these soils (-200cy)will be removed to 3' below grade before confirmatory sampling. As Areas B and C also contain arsenic in the soils, they may be removed subsequent to Area H under the same profile. The plan is to gain acceptance for the disposal on current data, supplemented by stockpile characterization and load trucks for transport to the Turn Key facility in NH. 4.40 Oily Soil Management Current estimates based on the subsurface investigations conducted to date indicate that approximately 180 cubic yards of oily soil will require excavation. Test pit# 3 found oily soil at 1-4' below grade (high groundwater level)mixed with large concrete, stone and burn debris that will have to be separated and cleaned before disposal. If additional affected soil is encountered during excavation,the soil will be characterized and removed for proper disposal. 72 Flint Street, Salem, MA January 22, 2013 Page 16 Oily soil excavation activities will begin with the removal of the oily soil. This soil will be staged on 6-mil polyethylene sheeting on an existing concrete slab located outside of the 200-foot Riverfront Zone and as far from residences as possible. The location to be used will be selected to be as far as practicable from the North River to minimize the potential for runoff from the stockpile reaching the North River. SP will ensure that the soil stockpile location is consistent with the provisions of the Order of Conditions (OOC)that have been issued for the excavation activities by the Salem Conservation Commission. The stockpile also will be covered with 6-mil polyethylene sheeting to limit exposure potential. Prior to stockpiling,the contractor will encircle the stockpile with hay bales or hay tubes that will be maintained during the duration of the project. SP, Inc. anticipates that the soil will be transported off-Site for recycling to Aggregate Industries in Stoughton, MA,using the Massachusetts Bill of Lading (BOL)process. During removal of the soil SP, Inc. will use an Industrial Scientific Model TMX412 Multi-Gas Monitor to screen for the presence of combustible gases (or methane) and hydrogen sulfide. Based on visual observations of the in-situ materials, confirmation soil samples will be collected from the sidewalls and bottom of each excavation for laboratory analyses at the frequency as described above and as discussed above to evaluate post-excavation soil quality. Due to the proximity of the Site to the North River, SP, Inc. anticipates that groundwater will be encountered in the excavations that will require management. SP, Inc. will coordinate the dewatering activities with the contractors on Site. Depending on the quantity of groundwater encountered, one or more of the following groundwater management techniques will be ,implemented. The subsurface investigations that have been conducted indicate that oil, if encountered, likely will be No.4 heating oil, which is only slightly miscible with water. The first management option will involve the installation of a three-foot diameter infiltration manhole in the center of the excavation. The sidewalls of the manhole will be perforated to allow the entry of groundwater.. A minimum six-inch thick layer of 3-inch stone will be placed around the manhole to reduce the accumulation of solids. If non-aqueous phase liquid(NAPL) is present, it will be skimmed from the surface of the excavation and manhole. The collected oil will be transported to Cyn Environmental Services or a similar disposal facility under a Hazardous Waste Manifest. Free product that accumulates to a thickness of more than 1/2- inch requires reporting as a new condition. If this condition is encountered a new Release Notification Form will be submitted in accordance with 310 CMR 40.0300. We anticipate however, that anew Release Tracking Number for NAPL would be linked to the primary RTN. If the volume of water and NAPL that is encountered is greater than can be managed as described above,then the groundwater may be pumped from the excavation into a fractionation tank to allow for solids to settle and oil to rise to the surface. With this option, SP, Inc. will collect a sample of the effluent for laboratory analyses prior to initiating discharge. A 48-hour turnaround 72 Flint Street, Salem, MA January 22, 2013 Page 17 time will be requested from the laboratory on this sample. Excavation will be suspended until the analytical results are available. If the concentrations of the constituents of concern indicate that contaminants are not present above the applicable Reportable Concentrations for groundwater classified as GW-2 (RCGW-2),the treated water will be discharged to the subsurface during periods of low tide. The clarified water will be discharged at a low flow rate so that the discharge can be incorporated into the low tide groundwater regime without creating a mounding condition at the discharge location. hi addition, the discharge would be only a temporary condition that would occur during excavation of the oily soil. If a small mound were to develop it would dissipate soon after the discharge ceased. Alternately, petroleum-containing groundwater or non-aqueous phase liquid(NAPL) encountered during the RAM activities, may be pumped from the excavation into a vacuum truck and disposed off-Site under a Hazardous Waste Manifest. Upon completion of the excavation and removal of the petroleum-containing soil from the Site, the removal of the concrete slabs will be undertaken to afford access to the other underlying affected soil. The excavated concrete either will be crushed on-Site and reused as fill or transported to a recycling facility following characterization. 4.50 Ashy Soil Management 4.50.1 General Ashy soil has been encountered in the borings and excavations conducted in the south and southwest portions of the Site where fill was placed near the North River. Layers of coal ash and gravel were found in areas B, C and E at 14' below grade. The ash-containing soil will be excavated after the oily soil has been removed from the Site. It will be stockpiled at the north end of the Site where the oily soil had been stored. It will be staged on and covered with 6-mil polyethylene sheeting to minimize exposure. Based on the results of successful pilot testing of the soil using the Solidification/Stabilization (S/S)process, this soil will be reused on the Site as fill below the parking garage structure. The S/S process that is proposed will be conducted generally in accordance with the guidance and criteria contained in the EPA publication"Technology Performance Review: Selecting and Using Solidification/Stabilization" and the document by the Interstate Technology& Review Council (ITRC): "Development of Performance Specifications for Solidification/Stabilization". 4.50.2 Solidification/Stabilization S/S is a widely used treatment technology to prevent migration of and exposure to contaminants in a contaminated medium (e.g. sediment, sludge, etc.). Solidification refers to a process that binds a contaminated medium with a reagent that changes the physical properties of the medium. Stabilization refers to the process that involves a chemical reaction that reduces the leachability of the contaminant. Data developed by the EPA have shown the Solidification/Stabilization 72 Flint Street, Salem, MA January 22, 2013 Page 18 (S/S)process to be effective remedial technology for metals, halogenated and non-halogenated semivolatile organic compounds, PCBs, and pesticides. The soils chosen for the S/S treatment evaluation include the coarse coal ash materials found in Areas B, C, and E as well as the soils mixed with particles of leather,buffing dust and shavings found in Areas F and G. Trivalent chromium is relatively non-toxic and non-carcinogenic and widespread in the environment and foods and creates minimal risk when managed properly. Gas release and metal leaching normally doesn't occur in stabilized, compacted dry soils. The goal of the solidification process is to create a material with sufficient structural stability to support Site uses in the areas where it will be placed. It will be used to increase the compressive strength of the ashy material and create a structurally sound material to be reused as appropriate on the Site. The goal of the stabilization process is to immobilize metals and other constituents that are associated with the ash present in the soil to prevent leaching to groundwater. S/S uses chemically reactive formulations that form stable solids that are non-hazardous. The process involves mixing multiple binding agents and reagents into contaminated media to immobilize the contaminants within the treated material. Solidification refers to the physical changes in the contaminated material when a certain binding agent is added. These changes include an increase in compressive strength, a decrease in permeability, and condensing of hazardous materials. Stabilization refers to the chemical changes between the stabilizing agent (binding agent) and the hazardous constituent. Common bonding agents include, but are not limited to, Portland cement, lime, limestone, fly ash, slag, clay, and gypsum. Most binding , agents used are a blend of various single binding agents, depending on the material to be treated. Portland cement has been used to treat more contaminated material than any other S/S binding agent because of its ability to bind free liquids, reduce permeability, encapsulate hazardous materials, and reduce the toxicity of certain contaminants. Lime can be used to adjust the pH of the substance of drive off water by using high heats of hydration. Limestone can also be used to adjust the pH. Pilot testing, as described below, will be conducted using the Site-specific materials before a full-scale project is initiated. S/S has been tested and evaluated for its effectiveness in containing and treating a wide array of contaminants, such as metals including lead, arsenic and chromium, and organic contaminants, such as creosote and petroleum products found at sites. S/S is selected most often for treatment of these metals because metals form insoluble compounds when combined with appropriate additives, such.as Portland cement. According to the EPA ASR 12`h Edition, S/S treatment was selected for source treatment of metals on 180 projects from 1982 to 2005. Performance Criteria Specifications for S/S projects generally include physical or chemical properties. The commonly specified physical tests include hydraulic conductivity and unconfined compressive strength (UCS). Typical S/S specifications that are recommended in the EPA publication "Technology 72 Flint Street, Salem, MA January 22, 2013 Page 19 Performance Review: Selecting and Using Stabilization/Solidification Treatment for Site Remediation", are provided below. The most commonly specified chemical test is the Toxicity Characteristic Leaching Procedure (TCLP). The TCLP test is used because it is linked to regulations in the EPA RCRA program. The TCLP procedure relies on extracting sample of the waste with a diluted organic acid, simulating conditions in a landfill. Due to questions regarding the applicability of the TCLP test to the use of the S/S technology, an alternative, the Synthetic Precipitation Leaching Procedure (SPLP), often is applied in place of the TCLP. The SPLP is designed to simulate waste exposure to acid rain.. Typical Sohdtficatron/Stabihzatton 7, a y � a Specilicahgns " t PsAverageYaluer Test Method ._ Unconfined Compressive Strength Pounds per Square Inch >50 ASTM D1633 _Hydraulic Conductivity Centimeters per Second <IXIO-6 ASTM D5084 Leaching Tests Milligrams per Liter Site Specific TCLP and SPLP -Usually stated as"the average value of all treated waste must equal'(usually a 20%allowance is permitted for individual samples.) TCLP Toxicity Characteristic Leaching Procedure SPLP-Synthetic Precipitation Leaching Procedure Pilot Testing The ratio of reagents to unstabilized material to achieve target goals typically is determined by bench or pilot-scale treatability studies. However, field treatability studies usually are used to develop information relative to the implementability of a S/S technology. Pilot tests will be performed to determine and optimize the method of reagent addition and the selection of and dosage of fixation agent(s). The following activities or(similar)will be undertaken during pilot testing: ➢ A temporary stockpile area will be constructed. ➢ A small representative amount of soil will be excavated using a backhoe and placed in the stockpile area. ➢ Measured amounts of material will be fixated in a small concrete mixer with various types and concentrations of fixation agents. ➢ Soil samples from each batch will be analyzed using the TCLP test. After the sample results are obtained, the data will be used to determine the optimal mixing ratio and fixation agent to be used during full-scale operations. Considerations will include effectiveness, ease of mixing, and cost. 72 Flint Street, Salem, MA January 22, 2013 Page 20 Remediation Process Excavated soils will be placed in temporary stockpiles designed to optimize remediation processing. Stabilized soil batches will be tagged and maintained as discrete stockpiles until cleared by TCLP. Temporary stockpiles for contaminated material will be established in the north portion of the Site as far from the North River as practical: Stabilized material will be stockpiled as necessary to support hauling operations in a clean area near Mason Street. Pre-screened oversized rocks and cobbles will be stockpiled on-Site for reuse as directed by SP, Inc. Stockpile areas will be level and maintained on the Site for as short a period of time as possible. Stockpiles that are not situated on concrete slabs will be located on minimum 6-mil polyethylene sheeting. The same material will be used to cover the stockpiles. At the end of each workday stockpiles will be covered. Covers will be secured with tires, concrete rubble, ropes,or other devices as necessary to prevent wind or storm damage. Stockpile maintenance will be performed as necessary throughout the project duration. S/S will be accomplished using a backhoe, mechanical mixing, or a pug mill mixer. Screened soil and fixation agent(s)will be mixed on an existing concrete slab in the mixing area or loaded into the hopper of the pug mill and mixed together. The stabilized material will then be placed in temporary, tagged stockpiles. During the process, care will be taken during loading to avoid spillage of material. Dust suppression will be accomplished using spray bars and hoses. The S/S process will result in soil which does not fail the TCLP test for the constituents of concern. The pH of the soil will be maintained between 6 and 9. If the native soil is outside this range, the pH will not be allowed to change more than one pH unit. Additionally, the stabilization process will not cause the soil to exceed any criteria or to cause the soil to be classified as a Federal RCRA hazardous waste or to be classified as a Massachusetts Hazardous Waste. The stabilized material will be a dry, inert material that will be evaluated for reuse as fill in the eastern portion of the Site below the proposed parking garage and below parking areas. Alternately, if the material is not suitable for use as fill on the Site due to structural considerations, it will be transported off-Site for disposal in a landfill such as the Turnkey Landfill in Rochester,NH or the Pine Tree Landfill in Camden,ME or to ARC. If it is not suitable because the concentrations of the constituents of concern in the leachate are greater than the regulatory limits, it will be transported to a licensed hazardous waste disposal facility such as Chemical Waste Management in Model City,New York under a Hazardous Waste manifest. 4.60 Lagoon Solids Management The portion of the Site designated as Area A is thought to have been the location of a lime or wastewater lagoon used by the Leach and Heckel tannery based on a 1954 aerial photograph. The depths of fill, lime and sludge ranges from 2-7' on the west side to 1-5' on the east side. The area 72 Flint Street, Salem, MA January 22, 2013 Page 21 is approx. 100'X 40' and accounts for 700-1000 cubic yards of the total to be removed from the Site. In conjunction with the removal of the concrete slabs, material from this area will be excavated and removed from the Site. Because the material is organic, an application of lime to the exposed surfaces may be necessary to control odor. The material from the lagoon will be stockpiled on the concrete slab at the north end of the Site where the oily soil had been stored. The soil will be placed on and covered with 6-mil polyethylene sheeting to minimize exposure. Samples will be submitted for disposal characterization in accordance with the provisions of the disposal facility, as discussed in Section 4.30. Upon completion of characterization activities it will be transported to Turnkey Landfill in Rochester,New Hampshire or Aggregate Recycling Corporation(ARC) in Eliot, ME for disposal under a BOL. 4.70 Historic Fill Management Historic fill containing leather pieces, shavings, buffing dust and trimmings is present in the north portion of the Site (Area F) and the south central portion of the Site (Area G). The fill in Area F is at 0-2' on the west end and 24' deep on the east end. Area G fill is found at 24' and extends to 6' near the river. The primary constituent of concern in Areas F and G is the occurrence of chromium due to the presence of the leather waste. The constituents of the waste streams identified in these areas were delisted by the EPA in 1985 because the chromium was shown to be exclusively trivalent and non-toxic and non-leachable when bound to the leather. These areas will be excavated last and an assessment will be conducted on the suitability of the excavated materials for stabilization. Alternately, if the material is not suitable for use as fill on the Site, it will be transported off-Site for disposal in a landfill such as the Turnkey Landfill in Rochester,NH or the Pine Tree Landfill in Camden, ME. 5.00 SITE MONITORING The use of the areas to the north and to the west of the Site primarily is residential. An air monitoring program will be implemented to prevent nuisance conditions from affecting off-Site receptors. Four dust monitoring stations will be established. Three stations will be situated between the Site and the abutters. The fourth station will be located between the Site and the North River. The monitoring stations will be self-contained DUSTRAKER II Model 8530 units that will record particulate concentrations at I minute intervals, store the data on an integral drive, and calculate Time Weighted Averages (TWAs). The other monitoring apparatus and operational descriptions are contained in the table at the end of this section. Action levels are presented following the discussion of dust control in Section 5.10. The results of the air monitoring will be provided to the Board of Health in a weekly summary report. The dust and particulate monitoring activities address potential impacts to Site workers and the neighboring community. The objectives of this monitoring plan are to: 72 Flint Street, Salem MA January 22, 2013 Page 22 ➢ Define the methods and procedures to be employed to monitor concentrations of dust during remediation ➢ Establish health-protective"action levels"for dust, arsenic, chromium, and lead in air for community members that live, work, or attend school adjacent to the project ➢ Provide a mechanism to adjust and enhance, as necessary, dust control measures that are defined as a component of the construction activities ➢ Document observations and findings of the dust and air monitoring activities SP, Inc. is designated as the consultant that is responsible for implementing dust control measures to stabilize exposed surfaces and minimize activities that suspend or track dust particles. Work activities will be conducted in a manner that includes adequate measures to minimize and control dust within the site. The specific dust control measures and procedures to be employed are identified in the following paragraphs. As such, construction activities will be in compliance with applicable Massachusetts Ambient Air Quality Standards. The MAAQS has a 24-hour TWA threshold of 150 micrograms per cubic meter (µg/ru ) of PM10. Dust control measures will be adjusted as maybe necessary based on the results of dust monitoring, on-site activities, type and location of operations, and the prevailing wind direction. In general, the dust control measures shall include,but not be limited to,the following: ➢ Provide wet suppression of exposed soils as necessary during construction activities (e.g., excavation of impacted soil, soil loading for off-site transport, excavation backfill and compaction operations, and rough grading upon completion)that may result in the generation of dust. ➢ Reduce speed on unpaved areas, and limit on-site traffic speed ➢ Cover and secure stockpiles and exposed areas at the end of each workday Continuous visual monitoring of dust (particulate) levels will also be conducted and recorded by the Contractor. If visible dust conditions are sustained for more than one minute within the active . Work Zone, the Contractor will implement dust suppression methods (i.e., water spray) or other appropriate measures to reduce airborne dust levels. 5.1 Background Monitoring Prior to beginning remedial operations at the Site, air quality monitoring will be performed for several consecutive days at one upwind and one downwind air monitoring station at the Work Zone Perimeter. The seven days of monitoring results will be used to establish relative baseline levels: On any particular day, the upwind monitor will record background levels and will be compared with the data from the downwind monitor during Site remedial operations. The monitoring will be used to document dust conditions at upwind and downwind locations to ensure that the work activities are not causing dust to migrate outside of the Work Zone. 72 Flint Street Salem, MA January 22, 2013 Page 23 5.2Perimeter Monitoring Four dust monitoring stations will be established. Three stations will be situated between the Site and the abutters. The fourth station will be located between the Site and the North River. The monitoring stations will be self-contained DUSTRAKER 11 Model 8530 units that will record particulate concentrations continuously, store the data on an integral drive, and calculate Time Weighted Averages (TWAs). The results of the air monitoring will be provided to the Board of Health in a weekly summary report. Real time monitoring will be completed at each Work Zone Perimeter air monitoring station. In addition, during the workday,the readings on the monitors will be visually checked and recorded in the field logbook. At the end of each day,this data will be used to calculate an 8-hour time- weighted average (TWA) concentration for each air monitoring station. All data will be archived in a central computerized database for reporting purposes. Any significant change in the wind direction during the day will be noted in the field logbook to ensure an understanding of the possible variations in wind direction over the course of the day. 5.3 Work Zone Monitoring Work activities will be conducted in a manner that includes adequate measures to minimize and control dust within the site. As such, construction activities will be in compliance with applicable Massachusetts Ambient AirQuality Standards. The MAAQS has a 24-hour TWA threshold of 150 micrograms per cubic meter(pg/m3) of PMio. Real-time continuous air monitoring will be conducted within each active Work Zone for worker protection during remedial operations as described in the Site HASP using appropriate monitoring instruments. The instruments designed for continuous monitoring use light scattering photometry sensing technology to measure particulate matter in the size range of 0.1 to 10 micrometers (µm) at concentrations between 0.001 and 400 milligrams per cubic meter(mg/m). Real-time air monitoring of total dust will be performed using real-time aerosol monitors [MIE Personal Data Rams (PDR)] with data loggers to provide immediate information for the total dust levels present. The lower detection limit for the operating range of the PDR is 0.001 milligrams per cubic meters (mg/m3). The particle size maximum range of response for the PDR is 0.1 to 10 micro meters (µm). The PDRs will be checked approximately every hour during the work day by an on-site SP representative to verify equipment operation and compliance with the target action levels. 5.4 Air Sampling To document workers exposures, the contractor will collect personal air samples during the course of remediation activities as described in the HASP on workers who have the greatest potential for exposure to Site contaminants within each active Work Zone. These samples will be submitted for arsenic and lead analyses. 72 Flint Street, Salem, MA January 22, 2013 Page 24 Results of the Work Zone air monitoring, dust observations and personal sampling will be correlated to demonstrate that managing particulate levels within the work zone also maintains the arsenic and lead concentrations within acceptable limits. If arsenic or lead concentrations indicate an exposure at or above the OSHA Action Levels,the Contractor will continue to monitor dust and review and amend control procedures as needed. If arsenic or lead concentrations reach the OSHA permissible exposure limits (PELs),the contractor will cease operations and evaluate site controls. Additional provisions may be implemented for the workers including upgrade of PPE. The following provides an overview of the methodology used to calculate a surrogate concentration of dust in air that is protective for potential exposures to chromium, lead, and arsenic in air. This approach is conservative in that it uses the maximum concentration of chromium, lead, and arsenic detected in any of the historical soil sampling activities as the presumed concentration in dust. Equation Action Level =REL/(Csoil max x 1/CF) Symbol and Description Units Value REL=0.10 µg/m3 PEL Csoil max= Maximum Concentration of arsenic in soil 122 mg/kg Csoil max=Maximum Concentration of arsenic in soil 122,000 µg/kg CF = Correction factor mg soil/kg soil 1.00E+06 Action Level (Dust) =0.82 mg/m3 dust in air Similarly,the Action Level for lead is as follows: Lead REL=0.15 µg/m3 MA Ambient Air Quality Standard Csoil max= Maximum Concentration of lead in soil 713 mg/kg Csoil max =Maximum Concentration of lead in soil 713,000 gg/kg Action Level (Dust)=0.21 mg dust/m3 air As shown above, the lowest dust concentration derived from this approach is 0.21 milligrams per cubic meter(mg/m)for lead, referred to as the Dust Action Level (Dust). An exceedance of the Dust Action Level will determined from the difference between the upwind and downwind samples collected by the Dust Trak units. Upon identification of an exceedance of the Action Level,the contractor will be notified will be notified and additional dust suppression measures will be employed. 72 Flint Street, Salem, MA January 22, 2013 Page 25 Odor As described in a previous section, VOC, methane and sulfide monitoring will be conducted to detect odorous compounds at the property perimeter, in the excavation for worker safety and in removed soils. Soils with elevated gases from chemicals or organics would not be reused on site. Removal areas that have been identified for off-site disposal are the lagoon solids Area A, burn debris in Area G, oily soil in Area D and the arsenic UCL in Area B and H. An Industrial Scientific Model TMX412 Multi-Gas Monitor will be used to monitor excavation activities for odor using hydrogen sulfide as the indicator parameter. The TMX412 Multi-Gas Monitor may be configured to continuously monitor one,two,three or four gases in any combination of the following: ➢ VOCs ➢ Combustible gases (% LEL) or methane (percent by volume CH4) ➢ Any two of the following toxic gases: • Carbon Monoxide • Hydrogen Sulfide • Sulfur Dioxide • Chlorine Noise Noise levels will be monitored using a Genrad Model 1954-9730 Noise-Exposure Monitor that integrates noise in accordance with ISO 1999. The integrated level is stored in a low-powered MOS-type counter that is connected to the battery. The monitor can be converted in the field by changing plug-in jumpers to provide an 80, 85, or 90 dB threshold and an exchange rate of either 3 or 5 dB. AIR MONITORING PLAN Parameter/ Frequency Worker Limit Abutter Limit Corrective Action Instrument Dust/TSI 8530 Continuous As-0.82 mg/m3 1.0 mg/m Stop soil movement; DUSTRAK II Water for dust suppression; Or MID Personal Pb—0.21 mg/m3 Wait for less wind; Data Ram Cover soil piles Odor(Sulfide) Twice/day 10 ppmv 1 ppmv Stop soil movement ISTMX 412 Multi- unless more Spread time; gas meter frequent is Spray deodorant; appropriate Wait for lower temperature; Cover soil pile VOCs Twice/day 10 ppmv 1 ppmv Stop soil movement; (Naphthalene)/ unless more Identify source; ISTMX 412 frequent is Cover and contain; appropriate Noise/Quest-400 Twice/day 95 db 75 db Slow operations; dosimeter unless more Replace equipment frequent is Place mats over slabs 72 Flint Street, Salem, MA January 22, 2013 Page 26 Action Levels Contaminant Instrument Action Level Combustible Gas Multi-Gas Monitor <10%Lower Explosive Limit(LEL) is normal 10%LEL requires immediate Site evacuation Dust DUSTTRACK 5.0 Mg/M3 re uires half or full-face respirator Noise Genrad Dosimeter >85 decibels requires hearing protection Oxygen Oxygen Meter 19.5%to 23% is normal Odor(Hydrogen Multi-Gas Monitor >10ppmv requires full-face respirator Sulfide Volatile Organic PID >50 ppmv requires full-face respirator Compounds Reporting Results obtained from the Work Zone monitoring and sampling will be reviewed on an on-going basis: Any field measurements or analytical data results exceeding the Site action levels will be reported immediately to the Site Superintendent so that actions can be implemented to control dust emissions. Evaluation of the air monitoring and sampling data collected at the Site will be conducted daily to verify that controls implemented at the Site are effective in preventing migration of Site contaminants off the Site. This data will be checked to ensure it meets the Site data quality objectives by verifying the following: ➢ Air monitoring instruments are properly calibrated at the required frequency ➢ Samples for arsenic and lead were collected and analyzed according to the approved NIOSH method (7300) and that the appropriate detection limits were achieved to allow comparison of sample results with Site action levels. ➢ Verifying that field and laboratory QC results are within acceptable criteria, including reviewing blank data for contamination. Information recorded during each work day and sampling event will include weather data(wind speed and direction,temperature, relative humidity, and precipitation), and the presence of potential sources of the Site contaminants (e.g., vehicle exhaust). Analysis of the effects of these conditions on the air monitoring and sampling results will be included in a report discussion, if applicable. A weekly air monitoring report will be prepared and will include the following information: ➢ Summary of the air monitoring stations used each day and their location relative to the site (e.g., upwind, downwind, etc.) 72 Flint Street, Salem, MA January 22, 2013 Page 27 ➢ Summary of 1-minute data from each perimeter monitoring station ➢ Summary of calculated TWA dust concentrations per station monitored ➢ Summary of calculated arsenic and lead concentrations, including detection limits, per sample collected. ➢ Contractor's field sampling and calibration data sheets for each high-volume air sampler ➢ Calibration calculations for each high-volume air sampler. A point of contact will be identified to provide air monitoring data information to the MA DEP on a weekly basis during construction activity. Following sample data validation and review,the results of the Site air monitoring will be summarized in an electronic spreadsheet and provided to the Salem Health Department and the MA DEP. 6.00 MANAGEMENT OF REMEDIATION WASTE This RAM addresses the excavation and management of approximately 3000 cubic yards of soil containing a variety of constituents of concern including; dioxins, furans, petroleum, metals, and historic leather waste products. Excavated soil will be stockpiled at the Site pending waste characterization analyses and authorization for transportation to the receiving facility. Stockpiles will be situated as far from the North River as possible and as far as possible from nearby residences. Stockpiles will be placed on 6-mil polyethylene sheeting and covered with the same sheeting. The sheeting will be secured with tires,concrete debris that is present on the Site, or ropes. Removal Areas B+H that have been identified as containing arsenic levels above the UCL and elevated dioxins will be segregated from other materials. The stockpiles will be removed from the Site as quickly as possible. The timing of the removal will depend on the capacity available at the various disposal facilities. Samples will be collected from the stockpiles for analyses for disposal characterization. Disposal characterization requirements differ among the potential disposal facilities. For example, ARC requires the complete of characterization forms specific to the type of waste to be disposed. The characterization form for Aggregate Industries is generalized to encompass a wide variety of wastes. SP,Inc. anticipates that the oily soil will be transported to Aggregate Industries in Stoughton, MA for recycling. The material from the lagoon in Area A may be transported to Aggregate Recycling Corporation(ARC) in Eliot, ME, the Turnkey Landfill in Rochester,NH, or the Pine Tree Landfill in Camden, ME. The stabilized materials may be reused on the Site if they are shown to be suitable as fill. If they are not suitable, they likely will be transported to Turnkey Landfill in Rochester,NH or the Pine Tree Landfill in Camden, ME, or to ARC. As previously indicated,the excavated soil will be stockpiled temporarily at the Site in accordance with the MCP and the Order of Conditions issued by the Conservation Commission. The soil will be transported off-Site using a BOL. 72 Flint Street, Salem, MA January 22, 2013 Page 28 If petroleum-containing groundwater or LNAPL is encountered during the RAM activities, it will treated and disposed on the Site or be pumped from the excavation into a vacuum truck and disposed off-Site. 7.00 POST-REMEDIATION MONITORING Previously, six monitoring wells were present on the Site. Table 3 presents a summary of the analyses of the groundwater samples collected from the MWs in 2005. Exceedances of the Method 1 GW-3 groundwater standards for chromium were detected in the samples from monitoring wells MW-4 and MW-5 and for lead in MW-3, MW-4, MW-5,and MW-6 in 2005. Although every effort will be made to protect these monitoring wells,most of them have been damaged or destroyed. Consequently, W&S installed eleven new monitoring wells in the locations that are shown on their Figure 2. The monitoring wells that abut the North River will be installed prior to the start of the remedial activities to allow the development of pre- remediation downgradient baseline groundwater quality. A set of samples from the new monitoring wells was collected by W&S prior to the start of remediation and analyzed for the following parameters: ➢ EPH by MA DEP Method 04-1 ➢ PAHs by EPA Method 8270C ➢ PCBs by EPA Method 8082 ➢ 13 MCP metals by Method 6010 (including hexavalent chromium) There were no exceedances of the GW-2/3 Standards discovered in the fust test series. Subsequently, groundwater samples will be collected from all monitoring wells every three months to assess the effectiveness of the remediation. Hexavalent chromium and PCBs were not detected above the laboratory reporting limit during the fust sampling event,therefore these parameters will be eliminated from future analyses as they have not been identified and constituents of concern. 7.10 Sediment sampling The requirement for North River sediment and surface water sampling and analysis is more suited for the RAO and completion statement rather then the RAM submittal because the tannery had not discharged to the river since the 1950s and the presence of contaminants in the sediment could not be directly attributed to the Salem Suede facility as it began operations in the 1970s. Over thirty tanneries existed in the North River watershed and would have discharged similar constituents. Also the North River adjacent to the site was dredged and the rip rap/bulkheads were rebuilt in 2004 removing a considerable amount of sediment containing metals. The sampling plan prepared for the Conservation Commission consisted of 3 sediment sampling stations; upstream, beside the site and downstream sampled at the completion of the remediation to establish general environmental conditions. The sediment would be analyzed for the 8 RCRA metals and EPH compounds. 72 Flint Street, Salem, MA January 22, 2013 Page 29 8.00 PERMITS,APPROVALS,AND NOTIFICATIONS Formal approval of this RAM plan by DEP is not anticipated to be required pursuant to 310 CMR 40.0443(2). Much of the excavation and dewatering activities are located within the buffer zone of the North River and the 200-Foot Riverfront Area. As previously indicated, the Salem Conservation Commission issued an Order of Conditions for the excavation project. Additional permits are not anticipated to be necessary to conduct the RAM. A filing fee for this RAM Plan in the amount of$800.00 has been submitted to the DEP. SP, Inc. will provide written notice of the proposed RAM to the office of the Mayor of Salem and Board of Health within 20 days of implementation of the RAM field activities pursuant to 310 CMR 40.1403(3)(d). A copy of the notification letter is included as Appendix D. 9.00 PROPOSED SCHEDULE The Salem Conservation Commission has issued an Order of Conditions for the project. A building permit has been obtained for the slab demolition. SP, Inc. intends to implement RAM activities upon approval of the RAM Plan by the DEP; after authorization to transport the excavated material to the receiving facilities is obtained; and as the weather permits. The excavation,off-Site recycling, and on-Site stabilization and reuse are anticipated to require several months to complete. The tentative schedule for remediation is as follows; March 2013 Excavate the dioxin and arsenic-containing soil in Area H to three feet below grade or as necessary to comply with the Method 1 S-1 cleanup standards. Remove soil in the SB-112 & SB- 213 areas and consolidate with H soils. Area Bl +B2 by the North River was the location of the wastewater treatment system and soil removal will be difficult because the concrete debris from tank demolition was mixed with and placed over the soils. Use of a vacuum truck to extract soils without the concrete may be necessary. The tank bottoms remain in place. The concrete pieces will be placed in the tanks during soil removal. Because the concentration of arsenic is elevated in this area,the material will be stockpiled on plastic and transported for landfill disposal. Separate concrete from soil in Area B, remove soils to 3'. After excavation sample the soil from the bottoms and sidewalls. March 2013 Excavate oily soils from former tank grave to groundwater table in Area D. Separate large rock, wood timbers and concrete footings. Include adjacent area TP-103+105. If floating product is visible, skim excavation groundwater with a vac truck and transport to Cyn Oil for processing. Install oil collection manhole if necessary. Stockpile soil on and cover with plastic for soil characterization as required by the receiving facility. Transport under DEP Bill of Lading to Aggregate Industries in Stoughton 72 Flint Street, Salem, MA January 22, 2013 Page 30 April 2013 Excavate former lagoon,Area A, two to seven feet below grade or as necessary. Stockpile soil on and covered with 6-mil polyethylene.sheeting. Load into trailers (estimated 25 loads) and transport to New Hampshire or Maine for landfill disposal. Backfill with crushed concrete April 2013 After removal of the tan room floor, clean residue in recycle vats before excavating soil and. debris from Area G. Sample soil below the vats. Separate debris, fire burned wood, large rock, concrete and stockpile soil in plastic. Evaluate need for stabilization and on site reuse under parking area and garage. Excavate previously identified coal ash Areas C and E also additional ash at TP-114, 108 and SB-103 identified by the Weston and Sampson 2012 investigation. Contain in plastic and evaluate need for stabilization or reuse at ARC facility in Elliot Maine May 2013 Excavate leather solid wastes in Area F,to three feet below grade or as necessary. Consolidate in plastic and evaluate for off-site disposal or stabilization. Concurrently begin stabilization of suitable coal ash or soils, and after TCLP testing, place and compact in the designated areas. June 2013 Compile remaining soil data, prepare tables calculate EPC's, assemble manifests. Prepare RAM completion report, LSP opinion, Site-Wide Risk Assessment and RAO statement. RAM status reports will be submitted in accordance with 310 CMR 40.0445 until response actions have been completed. If the laboratory analytical data indicate that additional response actions are not necessary,then the RAM activities will be documented in a RAM Completion Statement and Response Action Outcome determination. 4 i Release Abatement Measure Plan for Former Salem Suede 72 Flint Street Salem, Massachusetts RTN 3-30380 Prepared for: Department of Environmental Protection Bureau of Waste Site Cleanup Northeast Regional Office 205B Lowell Street Wilmington, MA 01888 Prepared by: SP, Inc. 45 Congress Street Salem. MA 01970 November 10, 2011 November 10, 2011 Department of Environmental Protection Northeast Regional Office 205B Lowell Street Wilmington, MA 01888 Subject: ' Release Abatement Measure Plan Former Salem Suede 72 Flint Street Salem,Massachusetts RTN 3-30380 Dear Sir or Madam: Enclosed is a Release Abatement Measure (RAM)Plan for the property located at 72 Flint Street in Salem,Massachusetts. SP, Inc. prepared this document on behalf of our client,Riverview Place,LLC. Soils containing petroleum, metals, ash, and historic leather waster were encountered during a subsurface evaluation that was performed as part of a due diligence assessment. The results of assessment indicate that extractable petroleum hydrocarbons(EPHs), including polycyclic aromatic hydrocarbons (PAHs) and the metals arsenic, chromium and lead e are present at concentrations greater than the applicable Reportable Concentrations in soil and groundwater at the Site. The source of the constituents of concern is historic tanning operations and fill deposited in conjunction with construction activities. On October 12,2011, SP, Inc. submitted a Release Notification Form (RNF) to the Massachusetts Department of Environmental Protection (DEP)on behalf of Riverview Place,LLC for these reportable release conditions. The RAM is being conducted to remove the affected soils and treat affected groundwater that may be generated during dewatering of the excavation. Please do not hesitate to contact the undersigned if you have any questions regarding this submittal. Sincerely, SP,INC. Wt Bruce M.Poole David L. Bramley, PE,LSP, LEP President Enclosure c: Michael O'Brien w/enclosure TABLE OF CONTENTS SECTION PAGE 1.00 INTRODUCTION............................................................................................................... 1 2.00 DESCRIPTION OF SITE CONDITIONS AND RELEASE.............................................. 1 2.10 Site Description.......................................................................................................... 1 2.20 Background...............................................................Error! Bookmark not defined. 2.30 Former Process Operations........................................................................................ 3 3.00 PREVIOUS ASSESSMENTS............................................................................................... 3 3.10 2005 Subsurface Assessment.....................................................................................3 3.10 2009 Subsurface Assessment.....................................................................................4 4.00 RELEASE ABATEMENT MEASURE PLAN..................................................................... 5 4.10 Objectives ..................................................................................................................5 4.20 Soil Excavation and Confirmation Sampling............................................................ 5 4.20.1 Oily Soil......................................................................................................... 5 4.20.2 Ashy Soil........................................................................................................6 4.20.3 Historic Fill....................................................................................................6 4.30 Management of Remediation Waste..........................................................................7 3.40 Permits,Approvals, and Notifications.......................................................................7 5.00 PROPOSED SCHEDULE.................................................................................................. 8 FIGURES Figure I - Site Locus Figure 2 - Site Plan TABLES Table I —Soil Borings Locations Table 2- Soil Analytical Results 2005 (Borings) Table 3—Groundwater Analytical Summary Table 4—Test Pit Locations Table 5 —Soil Analytical Results 2009 (Test Pits) APPENDIXES Appendix A -BW SC-106, Release Abatement Measure Transmittal Form Electronic submittal,summary and receipt Appendix B—Boring and Test Pit Logs Appendix C -Laboratory Analytical Reports Appendix D -Public Notification Letters 1.00 INTRODUCTION The purpose of this document is to present a Release Abatement Measure(RAM) Plan for the excavation and removal of soil containing metals and petroleum hydrocarbons at concentrations greater than the applicable cleanup standards at the property located at 72 Flint Street in Salem, Massachusetts (the "Site"). SP, Inc. (SP)prepared this document on behalf of our client, Riverview Place, LLC. A Site Locus is included as Figure 1, and a Site Plan is presented as Figure 2. November 10, 2011, this document and the Bureau of Waste Site Cleanup (BWSC) RAM Transmittal Form BWSC-106 were filed electronically using eDEP. A copy of the BWSC Form and the electronic submittal receipt are included in the client copy of the document. The party assuming responsibility for conducting the RAM is: Mr. Michael O'Brien Riverview Place, LLC 5 Broadmoor Lane Peabody,Massachusetts 01960 978-979-4072 The Licensed Site Professional (LSP)for the RAM is: Mr. David L. Bramley,LSP (No.7639) SP, Inc. 45 Congress Street Salem, MA 01970 978-745-4569 2.00 DESCRIPTION OF SITE CONDITIONS AND RELEASE 2.10 . Site Description The Site is located on the east side of Flint Street, south of Mason Street, and north of the North River Canal in a primarily residential area of Salem,Massachusetts. The generally rectangular lot contains 3.69 acres and it is identified on Map No. 6 as parcel 26-0091-0. The Site originally contained several interconnected multi-story structures that were demolished in 2009. The first and second stories were of brick construction. The upper floors were of wood framing and sheathing. There is a large paved area at the Flint Street entrance and a paved driveway access from Mason Street. The site slopes toward the North River and approximately one-third of the property is in the Zone A floodplain. Based on the topography of the Site, groundwater the groundwater flow direction is southerly toward the North River. The industrial buildings along the North River were placed on the Most Endangered List in 2000 due to constant threat of demolition. Since that time,three of the industrial buildings, including Salem Suede,have been demolished; another, Bonfanti Leather is to be demolished in 72 Flint Street, Salem, MA November 10, 2011 Page 2 conjunction with the redevelopment of the Salem Suede parcel. The North River has been a center of commerce since Salem's earliest days. Before it was successively filled in the 19th and 20th centuries,the North River was navigable and served as a location for loading and unloading goods from the late 18th century into the 19th century. 2.20 Background Sanborn Insurance Maps map show the area was heavily industrialized with tanneries, oil processors, and wood workers in the late 1800s. The site was occupied by the L Gibney Tannery in 1890. The large Patrick O'Keefe tannery, existed behind (to the south) and to the east along with other leather industries and dwellings. Tannery wastewater was discharged to the North River until the 1950s. By 1906 the buildings on the site were gone due to the Great Salem Fire of 1904. Dwellings still were located along the Flint Street and the Broadly Leather Co. was in operation to the east. The 1925 Sanborn map shows the buildings as they existed prior to demolition with a side building, extending to the east. Subsequent to the fire, the original tannery on the site was Leach and Heckel, Inc., which was a full cowhide tannery. The company conducted leather beaming, tanning, coloring and finishing operations. The buildings that were demolished in 2009 were constructed in 1925. A 10,000- gallon heating oil tank formerly was present in the front(west) portion of the Site that was removed in 1999. Photographs from 1954 show the presence of a lime or wastewater pit adjacent to the North River in the south corner of the property. As of 1970, the buildings remained the same and surrounding uses were consistent with 1950-1970. In 1978 the tannery was purchased by Salem Suede Inc. and an entrance from Mason Street was created. In the early 1980s a steel sided warehouse was constructed on the east property line. Wastewater from,the tannery has been treated at the South Essex Sewerage District since 1965, when an interceptor was installed in Bridge Street. The facility installed a wastewater pretreatment system in 1984, to remove solids, BOD, chromium and grease from the manufacturing effluents. According to the DEP Priority Resource Map for the Site and vicinity, the Site is not located within a current or potential drinking water source area as defined in the Massachusetts Contingency Plan(MCP). However,much of the Site is located within a 200-foot Riverfront Area and a 100 foot Wetland Buffer Zone. According to personnel at the Salem Board of Health, private, potable water wells are not known to exist within 500 feet of the Site. Therefore, groundwater at the Site is classified as GW-2 and GW-3. 72 Flint Street, Salem,MA November 10, 2011 Page 3 2.30 Former Process Operations The four-story building closest to the North River was used for beaming and tanning the leather. This involved removing the hair and fat with lime and sulfide baths,followed by a degreasing process called bate which used ammonia and enzymes to open the pores of the leather. The hide was fleshed after beaming and then pickled in sulfuric acid and salt. Trivalent chromium solutions were added to the large drums to tan the leather. The chromium penetrates the leather and binds to the protein to act as a mordant for dyes and pigments. The process is aided by the addition of phenolic syntans. These first steps of the process were discontinued by 1984, as pretreatment regulations were implemented. Subsequently,the facility purchased blue stock(tanned) sides and splits to color, fat liquor and finish. The center four story building was used for coloring the leather. Aniline and cationic dyes of all colors were applied in formic acid or ammonia baths to combine with the chromium. The fat liquors were sulfonated animal and fish oils that were applied to the leather in warm baths to restore suppleness, flexibility and water resistance. The finishing of leather occurred in the upper two stories and in the building to the north. Finishing was conducted using spray equipment to apply clear, colored or pigmented coatings to the top grain side of the leather for the polished appearance in shoes,pocketbooks, belts and garments. The finish operations used small amounts of toluene and xylene solvents as well as butyl acetate, glycol esters and other water-based emulsions. The buildings to the east were constructed of concrete block and the steel-sided warehouse structures were used to store raw blue stock and wet color stock. 3.00 PREVIOUS ASSESSMENTS 3.10 2005 Subsurface Assessment A modified Phase I—Environmental Site Assessment (ESA)was prepared by SP, Inc. in June 2005. The Phase I—ESA included the drilling of eleven soil borings, six of which were completed as groundwater monitoring wells. The soil logs are contained in Appendix B. The locations of the borings and monitoring wells are shown on Figure 2. The purpose of the assessment was to evaluate the potential for the release of hazardous material or oil and to characterize subsurface conditions at the Site. Observation of the soil samples collected indicates that the area was filled with soil and red tanning fiber, leather scraps, cinders, and coal ash from the late 1800s. The underlying native soils are grey and tan sand and silt. The borings and monitoring wells were installed in areas where former Site activities or process features were conducted. The Site owner provided information on former Site features to assist 72 Flint Street, Salem, MA November 10, 2011 Page 4 in selecting soil boring locations. Table 1 presents an identification of the boring and monitoring well locations and the reason for selecting the location. A summary of the soil and groundwater analytical results is contained in Table 2 and Table 3, respectively. The analytical data have been compared to the applicable cleanup standards. Except for two exceedances of the Method 1 S-1, GW-2 cleanup standards, one for Benzo(a)pyrene and for Dibenzo(a,h)anthracene,the concentrations of the PAHs are less than the applicable cleanup standards. However, there are numerous exceedances of the cleanup standards for the metals of concern,particularly chromium as would be anticipated at a leather tannery. There also are exceedances of the cleanup criteria for cadmium in two soil samples and lead in three soil samples. The laboratory analytical reports are included in Appendix C. Analyses of groundwater samples from monitoring wells MW-3,MW-4, and MW-5 for PAHs did not detect an exceedance of the GW-2 or GW-3 cleanup criteria. However, exceedances of the chromium and lead cleanup criteria were detected in the samples. 3.20 2009 Subsurface Assessment In December 2009 a second subsurface investigation was conducted to assess whether there had been a release of oil or hazardous materials to the soil below the floor slabs of the former tannery building. With the removal of the superstructures,the excavation of test pits through the concrete floors of the various operating areas of the tannery could identify affected soil that might result in a release to the environment during demolition of the slabs. The test pit logs are included in Appendix B. A total of nine test pits were excavated in eight separate areas. Two test pits(TP-3 and TP-3A) were excavated in the vicinity of the boiler room. Table 4 identifies the locations of the test pits and the rationale for the location. During excavations natural alluvial soils, fine sand, grey clay,peat, and green silt were encountered at depths of approximately six to ten feet below grade. Red tanning bark, which was used to color leather in the 1800s before chromium mordants were developed, was deposited on the native soil at a depth of three to six feet below grade. Above this layer were large rocks, gravel, ash,bricks, and wood that are present as a result of the Salem fire,and leather, concrete, coal ash and other miscellaneous fill materials. A summary of the analyses of the samples for metals is presented in Table 5. The concentrations of lead range from 11.4 to 145 mg/kg, which is less than the Method 1 S-1 cleanup standard of 300 mg/kg. The range of concentrations of cadmium is 0.26 to 11.6 mg/kg compared to the Method 1 S-1 cleanup standard of 2 mg/kg and the S-2 cleanup standard of 30 mg/kg. The chromium concentrations varied widely due to the presence of pieces of leather, leather shavings, buffing dust and trimmings included with the fill deposited before the 1925-era structures were 72 Flint Street, Salem, MA November 10, 2011 Page 5 constructed. These chromium-containing waste streams were delisted as hazardous wastes by the EPA in 1985 because the chromium is exclusively trivalent and non-toxic when bound to leather. 4.00 RELEASE ABATEMENT MEASURE PLAN 4.10, Objectives The objective of this RAM is to excavate and remove the soils that have been affected by oil,that contain historic fill and sludges at concentrations greater than the applicable cleanup criteria from the areas identified on Figure 2. The excavated soil will be recycled at a licensed off-Site facility, transported to a licensed disposal facility, or stabilized and reused on the Site. 4.20 Soil Excavation and Confirmation Sampling Approximately 2,365 cubic yards(approximately 3,500 tons)of soil affected by petroleum, ash, metals, leather wastes, or lime have been identified. The areas where theses wastes are present and the estimated quantities are listed below and are shown on Figure 2. Oily soil Area D 180 cubic yards(approx 240 tons) Ashy soil Areas B, C,and E 515 cubic yards (approx 620 tons) Lagoon and historic fill Areas A, F, and G 1,670 cubic yards(approx 2,000 tons) SP, Inc will arrange for a licensed contractor to excavate,transport, and dispose of the affected soil as discussed in the following sections. 4.20.1 Oily Soil Current estimates based on the subsurface investigations conducted to date indicate that approximately 180 cubic yards of soil will require excavation. If additional affected soil is encountered during excavation,the soil will be characterized and removed for proper disposal. The soil excavation will begin with the removal of the oily soil. This soil will be staged on 6-mil polyethylene sheeting on the existing concrete slab located in the northwest center portion of the Site behind the Bonfanti building. This location will be used because it is the farthest from the North River and the potential for runoff from the stockpile reaching the North River will be minimized. SP,Inc. will ensure that the soil stockpile location is consistent with the provisions of the Order of Conditions(OOC) that will be issued for the excavation activities by the Salem Conservation Commission. The stockpile also will be covered with 6-mil polyethylene sheeting to limit exposure potential. Prior to stockpiling,the contractor will encircle the stockpile with hay bales or hay tubes that will be maintained during the duration of the project. SP, Inc. 72 Flint Street, Salem,MA November 10, 2011 Page 6 anticipates that the soil will be transported off-Site for recycling using the Massachusetts Bill of Lading(BOL)process. During removal of the soil SP, Inc. will use a 10.2 eV photoionization detector(PID) calibrated to an isobutylene reference and the jar-headspace method to monitor the progress of the soil excavations by screening soil samples for the presence of total organic vapors(TOVs). Soil samples will be collected from the excavations and screened using the PID. When acceptable PID concentrations(less than five parts per million)are indicated, confirmation soil samples will be collected from the sidewalls and bottom of each excavation for laboratory analyses. The samples will be analyzed for EPHs, including the PAH analytes by DEP Method 04-1 and the metals of concern, arsenic, cadmium, chromium, and lead to evaluate post-excavation soil quality. Due to the proximity of the Site to the North River, SP, Inc. anticipates that groundwater will be encountered in the excavations that will require management. SP,Inc. will coordinate the dewatering activities with the contractors on Site. Depending on the quantity of groundwater encountered, one or more of the following groundwater management techniques will be implemented. The subsurface investigations that have been conducted indicate that oil, if encountered, like will be No.4 heating oil, which is only slightly miscible with water. The first management option will involve the installation of a three-foot diameter infiltration manhole will be installed in the center of the excavation. The sidewalls of the manhole will be perforated to allow the entry of groundwater. A minimum six-inch thick layer of 3-inch stone will be placed around the manhole to reduce the accumulation of solids. If non-aqueous phase liquid(NAPL) is present, it will be skimmed from the surface of the manhole. The collected oil will be transported to an appropriate disposal facility under a Hazardous Waste Manifest. If the volume of water and NAPL that is encountered is greater than can be managed,then the groundwater may be pumped from the excavation into a fractionation tank to allow for solids to settle and oil to rise to the surface. With this option, SP, Inc. will collect a sample from the effluent for laboratory analyses prior to initiating discharge. A 48-hour turnaround time will be requested from the laboratory on this sample. Excavation will be suspended until the analytical results are. If the concentrations of the constituents of concern indicate that contaminants are not present above the applicable Reportable Concentrations for groundwater classified as GW-2 (RCGW-2), the treated water will be discharged to the subsurface during periods of low tide. Alternately,petroleum-containing groundwater or non-aqueous phase liquid (NAPL) encountered during the RAM activities, may be pumped from the excavation into a vacuum truck and disposed off-Site under a Hazardous Waste Manifest. 72 Flint Street, Salem, MA November 10, 2011 Page 7 Upon completion of the excavation and removal of the petroleum-containing soil from the Site, the removal of the concrete slabs will be undertaken to afford access to the underlying affected soil. The excavated concrete either will be ground on-Site and reused as fill or transported to a recycling facility following characterization. 4.20.2 Lagoon The portion of the Site designated asArea A is thought to have been the location of a lime or wastewater lagoon used by the Leach and Heckel tannery based on a 1954 aerial photograph. In conjunction with the removal of the concrete slabs, material from this area will be excavated and stabilized on the Site. The stabilized material then will be evaluated for reuse as fill in the eastern portion of the Site below the proposed parking garage. Alternately, if the material is not suitable for use as fill on the Site, it will be transported off-Site for disposal in a landfill. 4.20.3 Ashy Soil and Historic Fill Ashy soil has been encountered in the borings and excavations undertaken in the south and southwest portions of the Site where fill was placed near the North River. The ash-containing soil will be excavated after the oily soil.has been removed from the Site. The ashy soil also will be stockpiled on the concrete slab at the north end of the Site where the oily soil had been stored. The soil will be placed on and covered with 6-mil polyethylene sheeting to minimize exposure. Upon completion of characterization activities it will be transported off the Site for disposal under a BOL. Historic fill containing leather pieces, shavings, buffing dust, and trimmings is present in the area in the North portion of the Site(Area F)-and the south central portion of the Site (Area G). Lime sludge is present in the location of the former settling lagoon designated as Area A. The primary constituent of concern in Areas F and G is chromium that is present due to the presence of the leather waste. The constituents of the waste streams identified in these areas were delisted by the EPA in 1985 because the chromium was shown to be exclusively trivalent and non-toxic and non-leachable when bound to the leather. These areas will be excavated last and the excavated materials will be stabilized on-Site. The stabilization process will be similar to the process used at the former Salem Shoe site by United Retek in 2003. Stabilization results in chemical changes to the hazardous constituents in a waste, including converting the contaminants into a less soluble, mobile, or toxic form. For example, heavy metals may be precipitated from contaminated soils through the conversion of soluble heavy metal salts to insoluble salts, and these salts can in turn be bound in permanent matrices. 72 Flint Street, Salem, MA November 10, 2011 Page 8 The process involves mixing multiple binding agents and reagents into contaminated media to immobilize the contaminants within the treated material. The resulting chemical reactions and physical immobilization within the material destroys or binds the contaminants, and so removes the risks of exposure to humans, animals, and plant receptors. The additives can include asphalt emulsions,phosphates,pH buffers, oxidizers, fillers, cement, cement kiln dust(CKD), lime, lime kiln dust(LKD), limestone, fly ash, slag and gypsum. Due to the variation of waste constituents and media, a mixture of reagents and processing conditions typically are required. Such site- specific treatments are based on mixes derived from a database of formulae compiled from the treatment of contaminated wastes in similar situations. The process will be conducted using standard construction equipment, augmented with process- specific equipment, e.g. pug mill, as necessary. The material to be stabilized will be excavated and stockpiled. The process has the ability to immobilize free water so a separate dewatering process is not required. Upon excavation,the material will be placed into windrows. The stabilization materials will be added to the windrows,mixed,and the material will be allowed to cure. The speed of the process depends on the nature and chemical characteristics of the material to be stabilized, the access constraints of the site, and the disposition of the finished product. The completed product will be a dry, inert material that will be used as fill below the proposed parking garage. 4.30 Management of Remediation Waste This RAM proposes to excavate and manage approximately 2,365 cubic yards of soil containing a variety of constituents of concern included petroleum, metals, and historic leather waste products. Excavated soil will be stockpiled at the Site pending waste characterization analyses and authorization for transportation to the receiving facility. SP, Inc. anticipates that the oily soil will be transported to Aggregate Industries in Stoughton,MA for recycling. The ash-containing soil may be transported to Aggregate Recycling Corporation(ARC)in Eliot, ME, the Turnkey Landfill in Rochester,NH,or the Pine Tree Landfill in Camden, ME. The stabilized materials will be reused on the Site As previouslyindicated,the excavated soil will be stockpiled temporarily at the Site in accordance with the MCP and the OOC issued by the Conservation Commission. The soil will be transported off-Site using a BOL. If petroleum-containing groundwater or LNAPL is encountered during the RAM activities, it will treated and disposed on the Site or be pumped from the excavation into a vacuum truck and disposed off-Site under a Hazardous Waste Manifest. 72 Flint Street, Salem, MA November 10, 2011 Page 9 4.40 Permits,Approvals,and Notifications Formal approval of this RAM plan by DEP is not anticipated to be required pursuant to 310 CMR 40.0443(2). Much of the excavation and dewatering activities are located within the buffer zone of the North River and the 200-Foot Riverfront Area. As previously indicated,the Salem Conservation Commission is expected to issue an OOC for the excavation project. Additional permits are not anticipated to be necessary to conduct the RAM.A filing fee for this RAM Plan in the amount of$800.00 will be submitted to the DEP. SP, Inc. will provide written notice of the proposed RAM to the office of the Mayor of Salem and Board of Health within 20 days of implementation of the RAM field activities pursuant to 310 CMR 40.1403(3)(d). A copy of the notification letter is included as Appendix D. 5.00 PROPOSED SCHEDULE SP, Inc. intends to implement RAM activities after the Order of Conditions is issued by the Conservation Commission and after authorization to transport the excavated material to the receiving facilities is obtained. The excavation, off-Site recycling, and on-Site stabilization and reuse are anticipated to require several months to complete. RAM status reports will be submitted in accordance with 310 CMR 40.0445 until response actions have been completed. If the laboratory analytical data indicate that additional response actions are not necessary,then the RAM activities will be documented in a RAM Completion Report. FIGURES Boat � —• � � 1 t I�\��Gotf Cwrse��\ � �` �i `� ' fry � _D i .fir '..� 1 i•"'� TI '�- r �. _ ;� •S a �� „ .�� .,?t '.,•� t 1 I � pa/me n lj"/•t >F Point. "al ?t' i/ / �/J �� `,,♦ ,F y � � � � .Narks �•_ L`3vf�k .n N SCALE SITE LOCUS w E 72 FLINT STREET v - 1,800, 5 SALEM,MASSACHUSETTS FIGURE NUMBER DATE 1 10/8/2011 RAM SOIL REMOVAL' � % •TP-1 1\ Al CY SOIL STOCKPILE EQUIP 710 ♦ FINISHING DECONTA NATION a ♦ T BI 155 SLAB AREA B2 178 C 90 C3 RIGHT OF D 178 ♦ F TP 2 ♦ OTB-7 -__ J % E 17 0' 2' Vacuum pp 2' ' F 592 OFFICES uellies O7B-9 B ae emw G 355 / . . --- P6: p p BePons 234_6 CY TOTAL !/ ♦ / I i w I R�S� j .J TP 0 / T 3A TB-6 A g'waer u_>_ MW-4 '� %.-200' T8'1 Uli�erproura9lvopeTmbNo.I —rte— i • + t r I DRIVER 9'-0A x21'-647 / { L---, pl' Dumps 2_7 MW-5 Fence Co. / BUFFER ZONE 1 REMOVE 6-991 r - 4"WpM1r Llna / I E >9 F t TOOL o ♦ AFL � �m / Tn 9"9printkr � oo _ Liqu � ROOM VFF j�-r c TB w,,Iw ual e ♦`M u _ T ♦ • N roun"IOU lewpll, Top of roll . wroen TP-8 �Ig000paI,Npel knx rlrh l2 x EL 19.5' 4' - - F.. I D2'x4'enclowre doo Formica Fat �$ t'' E Z (9 w"e• Liquors Pw O PT_ e4jP 11.O B _,�+°-"°'WE�H�D��r e • ��TS-10 , 2 r i 11 TP-7 - ♦ MW6 X100 _ t„d„ , BUFFER Jwo.ln,ir - "w$leox. ' E MW __ 111 G Qrmr ' Ii OTB-11 4 I MOM ` oiI �.E,eRp,Ol e SIONFFLeO.G Bogs of II l I ,B ap8 ai o Slutlee ButlrV ut iI _ EROSION LOG TP-8 /irMnm.w - ------ Progrry LnOSITE PLAN e% �OOr xlm,o�er qlw,. T - w.xr.so. eaa.m aonx pug TB-TEST BORE v SALEM SUEDE,INC. MW.MONITORING WELL - - - RIVER CANAL (tidd1) 72 FLINT STREET SS-SURFACE SOIL SAMPLE ,NORTH SALEM,MA 2009 TEST PITS SCALE I"=40' --�FUTURE PHASE H . TP-I TOB• REPORT 2011 SP INC, 25 TEST BORES ♦ FIGURE 2 2-21-11 10-10-11 10 MON. WELLS - _ TABLES Table l Soil Borings Locations Former Salem Suede 72 Flint Street Salem, Massachusetts Boring No. Location Rationale TB-1 Northwest corner of Site adjacent to Flint Street Assess potential effects of grit and material storage TB-2 W-1 West central portion of Site east of Flint Street Assess potential effects of fill materials used TB-3 (MW-2) Between sludge tank, clarifier, and buffing dust u Assess potential releases from treatment system components and from the presence of waste materials present TB-4 At the mixing tank and drum storage area Assess potential releases from storage practices Downgradient of former heating oil tank grave Assess potential residual effects of former 10,000-gallon heating oil UST and TB-5 (MW-3) and transformers transformers TB-6 MW-4 Vicinity of dum ster and loading dock Assess otential for impacts from spills TB-7 Northeast portion of the Site in the vicinity of wet Assess potential for impacts from hide storage hide storage TB-8 (MW-5) East central portion of the Site Assess potential effects of fill materials used and potential materials storage TB-9 Northeast portion of the Site at ROW Assess potential effects of fill materials used and potential materials storage TB-10 (MW-6) Southeast corner of the Site Assess potential effects of fill materials used and potential materials storage TB-11 Southeast corner of the Site Assess potential effects of fill used and of materials storage Tabk 1 Soil Ar htid Summary(U,u.9u) Fomler Salem Suede 72 Plhd Street Salem.Meamchu cm Sam kID: TB-1 TB-2 TB-3 TB< TE-5 TB-6 TB-] TB-8 TB-9 T&10 TB-11 MCP CID Stmdmde Dam Sam kd: 515105 Sly/OS 315105 $/5/US 5/5105 5/5/OS 5/5105 5/5/05 SISM9 SIS/OS 5/5I05 5/5/O5. 5/5/05 f/5/O5 513105 5/5/05 Sly/OS 5/5/OS SIS/OS SISIUS 5/5/05 &1 - 9-E De h ket 0.5 5.10 0-5 5.10 0.5 5-10 0.5 5.10 N5 540 10-IS 0.5 5-7 0-5 5.10 0-5 0.5 0.5 5-10 5-IS 5.10 GW--2 OW-3 GW-2 GW-3 EPH m -DEP Method 04.1 -C Ali hexa NA NA NA NA 12NA A NA <IUO NA NA <IUU NA NA NA NA NA NA NA NA NA NA ''1000:- X4000 3000- :3000 C Alihatke NA NA NA NA A NA <I00 NA NA <100 NA NA NA NA NA NA NA NA NA NA 3000 3,000 5,000 5,000 C Ammadce NA NA NA NA A NA <100 NA NA <I00 NA NA NA .NA NA NA NA NA NA NA .10004 -1000' `3.000 3,000 PAW -EPA Melhod 8170C Aumhll2 NA NA NA NA A NA ND NA NA ND 0.013 NA NA NA NA NA NA NA NA NA `-1000 -FOW 3,000 3000 Au hth kre NA NA I NA NA NA NR NA NA NR NR NA NA NA NA NA NA NA NA NA - 600 -J0 600. - 30 Mlhreccne NA NA NA NA NA ND NA NA ND 0,25 NA NA NA NA NA NA NA NA NA 41000 1,000 3,000 `3000' Benm a endt.m. NA NA NA A NA 1.06 NA NA 05 ND NA NA NA NA NA NA NA NA NA ] ] 40 40 - Bcuma rom NA NA NA A NA L65 NA NA 3,6 U,03 NA NA NA NA NA NA NA NA NA '2 2 1 4-" Have h fluotmiNem NA NA NA A 14NA 1.26 NA NA 1.39 0.49 NA NA NA NA NA NA NA NA NA -:r]. -Y.- 400 400 Bei h i NA NA NA A .63 NA NA 1164 0.00] NA NA NA NA NA NA NA NA NA 1000.: :1000: 3,000 3,000 Bente fumumthem NA NA NA NA .37 NA NA 4.92 0.006 NA NA NA NA NA NA NA NA NA 70 70 400 -,400 ch'..0 NA NA NA A 111 NA NA ND 0.081 NA NA NA NA NA NA NA NA NA r.]0 +]0' 400'. 400. Oiknzo hanthmcere NA NA NA A 09 NA NA 066 ND NA NA NA NA NA NA NA NA NA -Ol. - 0.7 ' : 4 : '- 4 Pluotmtkw NA NA NA 1.89 NA 14 NA NA 0.36 0.002 NA NA NA NA NA NA NA NA NA `1,000: 1000' 3000 3000 Mu. NA NA NA 0.4] NA ND NA NA ND 0.022 NA NA NA NA NA NA NA NA NA "1000:. IOa0. 3000: 3,000 kWcno 1234 ne NA NA NA 0313 NA 96 NA NA 0.30 ND NA NA NA NA NA NA NA NA NA '- ]: ] 40' 40 Na hOWtm NA NA NA ND NA ND NA NA ND 0.02 NA NA NA 0.1fi NA NA NA NA NA ''40 500' 40 - 1,000 Pkiuntluene NA NA NA 09] NA 1,2] NA NA ND ND NA NA NA NA NA NA NA NA NA ':5GO - 300 '1,000: 1,000 m NA NA NA Ill NA .94 NA NA ND 195 NA NA NA NA NA NA NA NA NA 1000"1.000. 3000' 3.000 2-Meth hf . NA NA NA ND NA ND NA NA ND ND NA NA NA NA NA NA NA NA NA 80 300 -. 6o' 500 Memk Arsenic NA NA NA NA 19 NA NA 6.2] NA 28.6 NA NA NA NA NA NA NA NA NA - 20 20- 30- 20 Cadmium 0.9 001 Ofi2 356 022 NA Il 06 <0.01 09 <q.01 3.63 0.76 035 0.31 0.]5 092 0.61 0.9] -:1' 2 - ` 30 . 30 Chromium 10 152 174 1113 1 35 NA 274 927 725 760 139 1999 141 674 74.4 548 789 d6 346]123 2]6 102 174 25.6 NA 292 154 146 152 BOA 135 J82 JIO 121 13J 143Menu NA NA NA NA 0.113 NA NA <002 NA .0.113 NA NA NA NA NA NA NA NA NA -20' '20. 30 30 MS44=m111igmm9 Pet ldbBmm(parts Put mi8iov,ppm) EPW=Sx Dtble N.D.Hydmmrbom PAW=Palysychc Aromadc H>drorabom Bold values t.td av appkablu It.,m utd. ND=CPmpoaM ml dekcmd N dm labotamry repartk8 NR=Not Reposed Table 3 Groundwater Analytical Summary Former Salem Suede 72 Flint Street Salem,Massachusetts Sample ID: MW-1 MW-2 MW-3 MW-4 MW-5 MW-6 MCP Cleanu Date Sampled: 5/5/05 5/5/05 5/5/05 5/5/05 5/5/05 5/5/05 Standards '6W-2' GW-3 EPH(µg/1)-DEP Method 04.1 Cy-Cj8 Aliphatics NA NA <500 <500 NA NA 5,000 50,000'. C19-C36 Aliphatics NA NA <2,000 <2,000 NA NA NA 50,000: CII-C22 Aromatics NA NA <I00 2,550 NA NA 50,000 5,000-•' PAHs( g/1)-EPA Method 8270C Acenaphthene NA NA <2 2,640 NA NA NE' 6;000 Acenaphthalene NA NA <2 <2 NA NA 1.0;000: " 40 Anthracene NA NA <2 <2 NA NA NE 30' : Benzo(a)anthracene NA NA <2 13 NA NA NE 1,000-`s Benzo(a)pyrene NA NA <2 5 NA NA NE 500.. - Benzo(b)fluoranthene NA NA <2 <2 rNA NA NE 400 -- Benzo(g,h,i)perylene NA NA <2 6 NA NE: ' 20-', :. Benzo(k)fluoranthene NA NA <2 <2 NA NE: - 100 Chrysene NA NA <2 6 NA :-,.NE *,30 Dibenzo(a,h)anthracene NA NA <2 <2 NA NE`' 40.0 Fluoranthene NA NA <2 <2 NA NE 200 Fluorene NA NA <2 <2 NA NE •, „40 Indeno(1,2,3-cd)pyrene NA NA - <2 <2 NA NA NE,; a -100. Naphthalene NA NA <2 <2 NA NA 1,000' 20,000 Phenanthrene NA NA <2 19 NA NA NE 10,000 Pyrene NA NA <2 16 NA NA NE 20 2-Methylnaphthalene NA NA <2 <2 NA NA 2,000 . 20,000' Metals(µg/1) Arsenic NA NA NA NA NA NA NE., 900 Cadmium 3.7 1.4 3 1.9 2.5 2.6 NE 4 Chromium 66 92 117 517 491 23 NE-: 300 Lead <10 9.1 50 50 44 17 NE 10 Mercury NA NA NA 0.186 NA NA NE 20',- µg/1 =micrograms per liter(parts per billion,ppb) EPHs=Extractable Petroleum Hydrocarbons PAHs=Polycyclic Aromatic Hydrocarbons Bold values exceed an applicable cleanup standard. ND=Compound not detected at the laboratory reporting NR=Not Reported Table 4 Test Pit Locations Former Salem Suede 72 Flint Street Salem, Massachusetts Boring No. Location Rationale TP-1 North portion of the facility adjacent to Mason Sti Assess potential effects'of potential releases from Finishing processes TB-2 North portion of the facility south of TP-1 Assess potential effects of Coloring processes TP-3 North central portion of the facility south of TP-2 Assess potential releases from the Boiler Room TP-3A East of TP-3 Assess extent of p2troleurn affected soil at Boiler Room and Coloring process TB-4 Central portion of the facility Assess potential residual from trench collections stems (Tanning processes) Assess potential for releases from the Beaming process and from the TP-5 Central portion of the facility, south of TP-4 chemical Stora a tanks area TP-6 South central portion of the facility Assess potential for releases from the Beaming process TB-7 Southeast potion of the facility Assess potential effects of potential releases from the Hide Storage area Southeast corner of the Site in the former fence TB-8 company building Assess Dotential effects of fill materials used and potential materials storage Table 5 Soil Analytical Summary(Test Pits) - - - Former Salem Suede 72 Flint Street Salem,Massachusetts - P-1 . TP•3 TP-5 TP-6 T -7 T -8Sam leII): TP-2CP Clem Standards Date Sampled: 12/3/09 12/3/09. 12/3/09 12/3/09 12/3/09 12/3/09 12/3/09 12/3/09 12/3/09 ' -S-1.�. . ,- .�' S-2 Depth feet : 0-4 0.4 0-6 04 04 2-5 4.6 0-6 0-6 GW-2 +GW-3 r::GW-2 7M.3 EPH m -DEP Method 04.1 C,- Ali hatics NA NA 2,750 1,880 NA NA ND <100 NA 1000` :1-,000 , 3,000"� '3000 - C19 C36 Ali hatics NA NA 3,890 2,990 NA NA ND <100 NA `3 000' x 3 000 11,. "'51000 5000. CII CrAromatics NA NA 2,170 3,710 NA NA ND <I00 NA1000 .:1;000 . ';3000 3000 PAHs m -EPA Method 8270C Acenaphthene NA NA 1 11.6 NA NA 0.013 NA I <0.1 NA 1,000,1 -A 1000 1 3;000 3,000 Acenaphthylene NA NA 15.1 NA NA NR NA <0.1 NA 600- 1,.:.40 %"600 10' Anthracene NA NA 11.7 NA NA 0.25 NA <0.1 NA 1,000 .1;000 - :3000 3000 Benzo(a)anthracene NA NA 11.5 NA NA <0.1 NA <0.1 NA 7 - .7 40 40' ` Benzo(a)pyrene NA NA <0.1 NA NA 0.02 NA <0.I NA 2 ^.`.2 -4.' 4 Benzo fluoranthene NA NA 11.2 NA NA 0.49 NA <0.1 NA 7 -7 - :: 400 X400 Benzo ,h,i e lene NA NA <0.1 NA NA 0.007 NA <0.1 NA .1000 - ;1000 •3000 ,3000. Benzo fluoranthene NA NA 10.7 NA NA- 0.006 NA <0.1 NA : 70 70 'r•.--400 . 400 Chrysene NA NA 21.1 NA . NA 0.081 NA <0.1 NA 70 70 =400 400 Dibenzo a,h anthracene NA NA <0.1 NA NA <0.1 NA <0.1 NA 0.7 0.7 -4 4 Fluoranthene NA NA 24 - NA NA 0.002 NA <0.1 NA 1,000 "1,000 .,3,000 3,000 Fluorene NA NA 20.4 NA NA 0.022 NA <0.1 NA 1 1000 . :4'000 i .3,000 3,000 . Indeno(1 2,3-cd) ne NA NA <0.1 NA NA <0.1 NA <0.1 NA 7 _7 40-. - 40 Naphthalene NA NA 0.5 NA NA 0.02 NA <0.1 NA 40 :.500 40 1 e 1,000 Phenanthrene NA NA 27.3 NA NA ND NA <0.1 NA 500 +x '500 ; --1000 >.1,000 Pyrene NA NA 34.3 NA NA 195 NA <0.1 NA 1000: -1,000 3,000 :.3000 2-Methylnaphthalenc NA- NA 0.3 NA NA <0.1 NA <0.1 NA 80 300 80 500= - Metals Arsenic NA NA NA NA NA NA NA NA NA 20 ' 20,," ''20 20 Cadmium 0.6 0.26 2.82 0.37 11.6 1.27 1.1 0.56 0.86 2' -2 .30 30'_ -Chromium 15.1 2 260 73 9 1 510 915 897 65.7 196. 30 � 30 ' ;"200 200:: : - Lead 27.3 15.4 140 11.4 24.4 120 145 12.2 47.8 - 300': 300 " -300 '300, - Mercury NA NA NA NA NA NA NA NA NA '. 20 ' 20 30, 30 mg/kg=milligrams per kilogram(parts per million,ppm) EPHs=Extractable Petroleum Hydrocarbons PAHs=Polycyclic Aromatic Hydrocarbons Bold values exceed an applicable cleanup standard. ND=Compound not detected at the laboratory reporting NR=Not Reported. Release Abatement Measure Plan for Former Salem Suede 72 Flint Street Salem, Massachusetts RTN 3-30380 Prepared for: Department of Environmental Protection Bureau of Waste Site Cleanup Northeast Regional Office 205B Lowell Street Wilmington, MA 01888 Prepared by: SP, Inc. 45 Congress Street Salem. MA 01970 November 10, 2011 November 10, 2011 Department of Environmental Protection Northeast Regional Office 205B Lowell Street Wilmington, MA 01888 Subject: Release Abatement Measure Plan Former Salem Suede 72 Flint Street Salem, Massachusetts RTN 3-30380 Dear Sir or Madam: Enclosed is a Release Abatement Measure (RAM) Plan for the property located at 72 Flint Street in Salem, Massachusetts. SP, Inc. prepared this document on behalf of our client, Riverview Place, LLC. Soils containing petroleum, metals, ash, and historic leather waster were encountered during a subsurface evaluation that was performed as part of a due diligence assessment. The results of assessment indicate that extractable petroleum hydrocarbons (EPHs), including polycyclic aromatic hydrocarbons (PAHs) and the metals arsenic, chromium and lead are present at concentrations greater than the applicable Reportable Concentrations in soil and groundwater at the Site. The source of the constituents of concern is historic tanning operations and fill deposited in conjunction with construction activities. On October 12, 2011, SP, Inc. submitted a Release Notification Form (RNF)to the Massachusetts Department of Environmental Protection (DEP)on behalf of Riverview Place, LLC for these reportable release conditions. The RAM is being conducted to remove the affected soils and treat affected groundwater that may be generated during dewatering of the excavation. Please do not hesitate to contact the undersigned if you have any questions regarding this submittal. Sincerely, SP, INC. Bruce M. Poole David L. Bramley, PE, LSP, LEP President Enclosure c: Michael O'Brien w/enclosure TABLE OF CONTENTS SECTION PAGE 1.00 INTRODUCTION............................................................................................................... 1 2.00 DESCRIPTION OF SITE CONDITIONS AND RELEASE.............................................. 1 2.10 Site Description.......................................................................................................... 1 2.20 Background...............................................................Error! Bookmark not defined. 2.30 Former Process Operations........................................................................................3 3.00 PREVIOUS ASSESSMENTS............................................................................................... 3 3.10 2005 Subsurface Assessment.....................................................................................3 3.10 2009 Subsurface Assessment.....................................................................................4 4.00 RELEASE ABATEMENT MEASURE PLAN..................................................................... 5 4.10 Objectives .................................................................................................................. 5 4.20 Soil Excavation and Confirmation Sampling ............................................................ 5 4.20.1 Oily Soil......................................................................................................... 5 4.20.2 Ashy Soil........................................................................................................6 4.20.3 Historic Fill.................................................................................................... 6 4.30 Management of Remediation Waste.......................................................................... 7 3.40 Permits, Approvals, and Notifications....................................................................... 7 5.00 PROPOSED SCHEDULE.................................................................................................. 8 FIGURES Figure 1 - Site Locus Figure 2 - Site Plan TABLES Table l —Soil Borings Locations Table 2 - Soil Analytical Results 2005 (Borings) Table 3 —Groundwater Analytical Summary Table 4—Test Pit Locations Table 5 —Soil Analytical Results 2009 (Test Pits) APPENDIXES Appendix A - BWSC-106, Release Abatement Measure Transmittal Form Electronic submittal summary and receipt Appendix B—Boring and Test Pit Logs Appendix C - Laboratory Analytical Reports Appendix D - Public Notification Letters 1.00 INTRODUCTION The purpose of this document is to present a Release Abatement Measure (RAM) Plan for the excavation and removal of soil containing metals and petroleum hydrocarbons at concentrations greater than the applicable cleanup standards at the property located at 72 Flint Street in Salem, Massachusetts (the "Site"). SP, Inc: (SP) prepared this document on behalf of our client, Riverview Place, LLC. A Site Locus is included as Figure 1, and a Site Plan is presented as Figure 2. November 10, 2011, this document and the Bureau of Waste Site Cleanup (BWSC) RAM Transmittal Form BWSC-106 were filed electronically using eDEP. A copy of the B WSC Form and the electronic submittal receipt are included in the client copy of the document. The party assuming responsibility for conducting the RAM is: Mr. Michael O'Brien Riverview Place, LLC 5 Broadmoor Lane Peabody, Massachusetts 01960 978-979-4072 The Licensed Site Professional (LSP) for the RAM is: Mr. David L. Bramley, LSP (No. 7639) SP, Inc. 45 Congress Street Salem, MA 01970 978-745-4569 2.00 DESCRIPTION OF SITE CONDITIONS AND RELEASE 2.10 Site Description The Site is located on the east side of Flint Street, south of Mason Street, and north of the North River Canal in a primarily residential area of Salem, Massachusetts. The generally rectangular lot contains 3.69 acres and it is identified on Map No. 6 as parcel 26-0091-0. The Site originally contained several interconnected multi-story structures that were demolished in 2009. The first and second stories were of brick construction. The upper floors were of wood framing and sheathing. There is a large paved area at the Flint Street entrance and a paved driveway access from Mason Street. The site slopes toward the North River and approximately one-third of the property is in the Zone A floodplain. Based on the topography of the Site, groundwater the groundwater flow direction is southerly toward the North River. The industrial buildings along the North River were placed on the Most Endangered List in 2000 due to constant threat of demolition. Since that time, three of the industrial buildings, including Salem Suede, have been demolished; another, Bonfanti Leather is to be demolished in 72 Flint Street, Salem, MA November 10, 2011 Page 2 conjunction with the redevelopment of the Salem Suede parcel. The North River has been a center of commerce since Salem's earliest days. Before it was successively filled in the 19th and 20th centuries, the North River was navigable and served as a location for loading and unloading goods from the late 18th century into the 19th century. 2.20 Background Sanborn Insurance Maps map show the area was heavily industrialized with tanneries, oil processors, and wood workers in the late 1800s. The site was occupied by the J.Gibney Tannery in 1890. The large Patrick O'Keefe tannery, existed behind (to the south) and to the east along With other leather industries and dwellings. Tannery wastewater was discharged to the North River until the 1950s. By 1906 the buildings on the site were gone due to the Great Salem Fire of 1904. Dwellings still were located along the Flint Street and the Broadly Leather Co. was in operation to the east. The 1925 Sanborn map shows the buildings as they existed prior to demolition with a side building, extending to the east. Subsequent to the fire, the original tannery on the site was Leach and Heckel, Inc., which was a full cowhide tannery. The company conducted leather beaming,tanning, coloring and finishing operations. The buildings that were demolished in 2009 were constructed in 1925. A 10,000- gallon heating oil tank formerly was present in the front(west) portion of the Site that was removed in 1999. Photographs from 1954 show the presence of a lime or wastewater pit adjacent to the North River in the south comer of the property. As of 1970, the buildings remained the same and surrounding uses were consistent with 1950-1970. In 1978 the tannery was purchased by Salem Suede Inc. and an entrance from Mason Street was created. In the early 1980s a steel sided warehouse was constructed on the east property line. Wastewater from the tannery has been treated at the South Essex Sewerage District since 1965, when an interceptor was installed in Bridge Street. The facility installed a wastewater pretreatment system in 1984, to remove solids, BOD, chromium and grease from the manufacturing effluents. According to the DEP Priority Resource Map for the Site and vicinity, the Site is not located within a current or potential drinking water source area as defined in the Massachusetts Contingency Plan (MCP). However, much of the Site is located within a 200-foot Riverfront Area and a 100 foot Wetland Buffer Zone. According to personnel at the Salem Board of Health, private, potable water wells are not known to exist within 500 feet of the Site. Therefore, groundwater at the Site is classified as GW-2 and GW-3. n 72 Flint Street, Salem, MA November 10, 2011 Page 3 2.30 Former Process Operations The four-story building closest to the North River was used for beaming and tanning the leather. This involved removing the hair and fat with lime and sulfide baths, followed by a degreasing process called bate which used ammonia and enzymes to open the pores of the leather. The hide was fleshed after beaming and then pickled in sulfuric acid and salt. Trivalent chromium solutions were added to the large drums to tan the leather. The chromium penetrates the leather and binds to the protein to act as a mordant for dyes and pigments. The process is aided by the addition of phenolic syntans. These first steps of the process were discontinued by 1984, as pretreatment regulations were implemented. Subsequently,the facility purchased blue stock(tanned) sides and splits to color, fat liquor and finish. The center four story building was used for coloring the leather. Aniline and cationic dyes of all colors were applied in formic acid or ammonia baths to combine with the chromium. The fat liquors were sulfonated animal and fish oils that were applied to the leather in warm baths to restore suppleness, flexibility and water resistance. The finishing of leather occurred in the upper two stories and in the building to the north. Finishing was conducted using spray equipment to apply clear, colored or pigmented coatings to the top grain side of the leather for the polished appearance in shoes, pocketbooks;'belts and garments. The finish operations used small amounts of toluene and xylene solvents as well as butyl acetate, glycol esters and other water-based emulsions. The buildings to the east were constructed of concrete block and the steel-sided warehouse structures were used to store raw blue stock and wet color stock. i 3.00 PREVIOUS ASSESSMENTS 3.10 2005 Subsurface Assessment A modified Phase I— Environmental Site Assessment(ESA) was prepared by SP, Inc. in June 2005. The Phase I— ESA included the drilling of eleven soil borings, six of which were completed as groundwater monitoring wells. The soil logs are contained in Appendix B. The locations of the borings and monitoring wells are shown on Figure 2. The purpose of the assessment was to evaluate the potential for the release of hazardous material or oil and to characterize subsurface conditions at the Site. Observation of the soil samples collected indicates that the area was filled with soil and red tanning fiber, leather scraps, cinders, and coal ash from the late 1800s. The underlying native soils are grey and tan sand and silt. The borings and monitoring wells were installed in areas where former Site activities or process features were conducted. The Site owner provided information on former Site features to assist 72 Flint Street, Salem, MA November 10, 2011 Page 4 in selecting soil boring locations. Table 1 presents an identification of the boring and monitoring well locations and the reason for selecting the location. A summary of the soil and groundwater analytical results is contained in Table 2 and Table 3, respectively. The analytical data have been compared to the applicable cleanup standards. Except for two exceedances of the Method I S-1, GW-2 cleanup standards, one for Benzo(a)pyrene and for Dibenzo(a,h)anthracene, the concentrations of the PAHs are less than the applicable cleanup standards. However, there are numerous exceedances of the cleanup standards for the metals of concern, particularly chromium as would be anticipated at a leather tannery. There also are exceedances of the cleanup criteria for cadmium in two soil samples and lead in three soil samples. The laboratory analytical reports are included in Appendix C. Analyses of groundwater samples from monitoring wells MW-3, MW-4, and MW-5 for PAHs did not detect an exceedance of the GW-2 or GW-3 cleanup criteria. However, exceedances of the chromium and lead cleanup criteria were detected in the samples. 3.20 2009 Subsurface Assessment In December 2009 a second subsurface investigation was conducted to assess whether there had been a release of oil or hazardous materials to the soil below the floor slabs of the former tannery building. With the removal of the superstructures,the excavation of test pits through the concrete floors of the various operating areas of the tannery could identify affected soil that might result in a release to the environment during demolition of the slabs. The test pit logs are included in Appendix B. A total of nine test pits were excavated in eight separate areas. Two test pits (TP-3 and TP-3A) were excavated in the vicinity of the boiler room. Table 4 identifies the locations of the test pits and the rationale for the location. During excavations natural alluvial soils, fine sand, grey clay, eat, and green silt were encountered at depths of approximately six to ten feet below grade. Red tanning bark, which was used to color leather in the 1800s before chromium mordants were developed, was deposited on the native soil at a depth of three to six feet below grade. Above this layer were large rocks, gravel, ash, bricks, and wood that are present as a result of the Salem fire, and leather, concrete, coal ash and other miscellaneous fill materials. A summary of the analyses of the samples for metals is presented in Table 5. The concentrations of lead range from 11.4 to 145 mg/kg, which is less than the Method 1 S-1 cleanup standard of 300 mg/kg. The range of concentrations of cadmium is 0.26 to 11.6 mg/kg compared to the Method l S-1 cleanup standard of 2 mg/kg and the S-2 cleanup standard of 30 mg/kg. The chromium concentrations varied widely due to the presence of pieces of leather, leather shavings, buffing dust and trimmings included with the fill deposited before the 1925-era structures were 72 Flint Street, Salem, MA November 10, 2011 Page 5 constructed. These chromium-containing waste streams were delisted as hazardous wastes by the EPA in 1985 because the chromium is exclusively trivalent and non-toxic when bound to leather. 4.00 RELEASE ABATEMENT MEASURE PLAN 4.10 Objectives The objective of this RAM is to excavate and remove the soils that have been affected by oil, that contain historic fill and sludges at concentrations greater than the applicable cleanup criteria from the areas identified on Figure 2. The excavated soil will be recycled at a licensed off-Site facility,transported to a licensed disposal facility, or stabilized and reused on the Site. 4.20 Soil Excavation and Confirmation Sampling Approximately 2,365 cubic yards (approximately 3,500 tons) of soil affected by petroleum, ash, metals, leather wastes, or lime have been identified. The areas where theses wastes are present and the estimated quantities are listed below and are shown on Figure 2. Oily soil Area D 180 cubic yards (approx 240 tons) Ashy soil Areas B, C, and E 515 cubic yards (approx 620 tons) Lagoon and historic fill Areas A, F, and G 1,670 cubic yards (approx 2,000 tons) SP, Inc will arrange for a licensed contractor to excavate, transport, and dispose of the affected soil as discussed in the following sections. 4.20.1 Oily Soil Current estimates based on the subsurface investigations conducted to date indicate that approximately 180 cubic yards of soil will require excavation. If additional affected soil is encountered during excavation,the soil will be characterized and removed for proper disposal. The soil excavation will begin with the removal of the oily soil. This soil will be staged on 6-mil polyethylene sheeting on the existing concrete slab located in the northwest center portion of the Site behind the Bonfanti building. This location will be used because it is the farthest from the North River and the potential for runoff from the stockpile reaching the North River will be minimized. SP, Inc. will ensure that the soil stockpile location is consistent with the provisions of the Order of Conditions (OOC) that will be issued for the excavation activities by the Salem Conservation Commission. The stockpile also will be covered with 6-mil polyethylene sheeting to limit exposure potential. Prior to stockpiling, the contractor will encircle the stockpile with hay bales or hay tubes that will be maintained during the duration of the project. SP, Inc. 72 Flint Street, Salem, MA November 10, 2011 Page 6 .anticipates that the soil will be transported off-Site for recycling using the Massachusetts Bill of Lading(BOL) process. During removal of the soil SP, Inc. will use a 10.2 eV photoionization detector(PID) calibrated to an isobutylene reference and the jar-headspace method to monitor the progress of the soil excavations by screening soil samples for the presence of total organic vapors (TOVs). Soil samples will be collected from the excavations and screened using the PID. When acceptable PID concentrations (fess than five parts per million) are indicated, confirmation soil samples will be collected from the sidewalls and bottom of each excavation for laboratory analyses. The samples will be analyzed for EPHs, including the PAH analytes by DEP Method 04-1 and the metals of concern, arsenic, cadmium, chromium, and lead to evaluate post-excavation soil quality. Due to the proximity of the Site to the North River, SP, Inc. anticipates that groundwater will be encountered in the excavations that will require management. SP, Inc. will coordinate the dewatering activities with the contractors on Site. Depending on the quantity of groundwater encountered, one or more of the following groundwater management techniques will be implemented. The subsurface investigations that have been conducted indicate that oil, if encountered, like will be No.4 heating oil, which is only slightly miscible with water. The first management option will involve the installation of a three-foot diameter infiltration manhole will be installed in the center of the excavation. The sidewalls of the manhole will be perforated to allow the entry of groundwater. A minimum six-inch thick layer of 3-inch stone will be placed around the manhole to reduce the accumulation of solids. 1f non-aqueous phase liquid(NAPL) is present, it will be skimmed from the surface of the manhole. The collected oil will be transported to an appropriate disposal facility under a Hazardous Waste Manifest. If the volume of water and NAPL that is encountered is greater than can be managed, then the groundwater may be pumped from the excavation into a fractionation tank to allow for solids to settle and oil to rise to the surface. With this option, SP, Inc. will collect a sample from the effluent for laboratory analyses prior to initiating discharge. A 48-hour turnaround time will be requested from the laboratory on this sample. Excavation will be suspended until the analytical results are. If the concentrations of the constituents of concern indicate that contaminants are not present above the applicable Reportable Concentrations for groundwater classified as GW-2 (RCGW-2),the treated water will be discharged to the subsurface during periods of low tide. Alternately, petroleum-containing groundwater or non-aqueous phase liquid (NAPL) encountered during the RAM activities, may be pumped from the excavation into a vacuum truck and disposed off-Site under a Hazardous Waste Manifest. 72 Flint Street, Salem, MA November 10, 2011 Page 7 Upon completion of the excavation and removal of the petroleum-containing soil from the Site, the removal of the concrete slabs will be undertaken to afford access to the underlying affected soil. The excavated concrete either will be ground on-Site and reused as fill or transported to a recycling facility following characterization. 4.20.2 Lagoon The portion of the Site designated as Area A is thought to have been the location of a lime or wastewater lagoon used by the Leach and Heckel tannery based on a 1954 aerial photograph. In conjunction with the removal of the concrete slabs, material from this area will be excavated and staff on t— h� The stabilized material then will be evaluated for reuse as fill in the eastern portion of the Site below the proposed parking garage. Alternately, if the material is not suitable for use as fill on the Site, it will be transported off-Site for disposal in a landfill. 4.20.3 Ashy Soil and Historic Fill Ashy soil has been encountered in the borings and excavations undertaken in the south and southwest portions of the Site where fill was placed near the North River. The ash-containing soil will be excavated after the oily soil has been removed from the Site. The ashy soil also will be stockpiled on the concrete slabat the north end of the Site where the oily soil had been stored. The soil will be placed on and covered with 6-mil polyethylene sheeting to minimize exposure. Upon completion of characterization activities it will be transported off the Site for disposal under a BOL. Historic fill containing leather pieces, shavings, buffing dust, and trimmings is present in the area in the North portion of the Site (Area F) and the south central portion of the Site (Area G). Lime sludge is present in the location of the former settling lagoon designated as Area A. The primary constituent of concern in Areas F and G is chromium that is present due to the presence of the leather waste. The constituents of the waste streams identified in these areas were delisted by the EPA in 1985 because the chromium was shown to be exclusively trivalent and non-toxic and non-leachable when bound to the leather. These areas will be excavated last and the excavated materials will be stabilized on-Sites The stabilization process will be similar to the process used at the former Salem Shoe site by United Retek in 2003. �! Stabilization results in chemical changes to the hazardous constituents in a waste, including converting the contaminants into a less soluble, mobile, or toxic form. For example, heavy metals may be precipitated from contaminated soils through the conversion of soluble heavy metal salts to insoluble salts, and these salts can in turn be bound in permanent matrices. 72 Flint Street, Salem, MA November 10, 2011 Page 8 The process involves mixing multiple binding agents and reagents into contaminated media to immobilize the contaminants within the treated material. The resulting chemical reactions and physical immobilization within the material destroys or binds the contaminants, and so removes the risks of exposure to humans, animals, and plant receptors. The additives can include asphalt emulsions, phosphates, pH buffers, oxidizers, fillers, cement, cement kiln dust(CKD), lime, lime kiln dust(LKD), limestone, fly ash, slag and gypsum. Due to the variation of waste constituents and media, a mixture of reagents and processing conditions typically are required. Such site- specific treatments are based on mixes derived from a database of formulae compiled from the treatment of contaminated wastes in similar situations. The process will be conducted using standard construction equipment, augmented with process- specific equipment, e.g. pug mill, as necessary. The material to be stabilized will be excavated and stockpiled. The process has the ability to immobilize free water so a separate dewatering process is not required. Upon excavation, the material will be placed into windrows. The stabilization materials will be added to the windrows, mixed, and the material will be allowed to cure. The speed of the process depends on the nature and chemical characteristics of the material to be stabilized, the access constraints of the site, and the disposition of the finished product. The completed product will be a dry, inert material that will be used as fill below the proposed parking garage. 4.30 Management of Remediation Waste This RAM proposes to excavate and manage approximately 2,365 cubic yards of soil containing a variety of constituents of concern included petroleum, metals, and historic leather waste products. Excavated soil will be stockpiled at the Site pending waste characterization analyses and authorization for transportation to the receiving facility. SP, Inc. anticipates that the oily soil will be transported to Aggregate Industries in Stoughton, MA for recycling. The ash-containing soil may be transported to Aggregate Recycling Corporation (ARC) in Eliot, ME, the Turnkey Landfill in Rochester,NH, or the Pine Tree Landfill in Camden, ME. The stabilized materials will be reused on the Site As previously indicated,the excavated soil will be stockpiled temporarily at the Site in accordance with the MCP and the OOC issued by the Conservation Commission. The soil will be transported off-Site using a BOL. If petroleum-containing groundwater or LNAPL is encountered during the RAM activities, it will treated and disposed on the Site or be pumped from the excavation into a vacuum truck and disp—os—eT—off-Slazar ous Waste Manifest. 72 Flint Street, Salem, MA November 10, 2011 Page 9 4.40 Permits,Approvals,and Notifications Formal approval of this RAM plan by DEP is not anticipated to be required pursuant to 310 CMR 40.0443(2). Much of the excavation and dewatering activities are located within the buffer zone of the North River and the 200-Foot Riverfront Area. As previously indicated, the Salem Conservation Commission is expected to issue an OOC for the excavation project. Additional permits are not anticipated to be necessary to conduct the RAM. A filing fee for this RAM Plan in the amount of$800.00 will be submitted to the DEP. SP, Inc. will provide written notice of the proposed RAM to the office of the Mayor of Salem and Board of Health within 20 days of implementation of the RAM field activities pursuant to 310 CMR 40.1403(3)(d). A copy of the notification letter is included as Appendix D. 5.00 PROPOSED SCHEDULE SP, Inc. intends to implement RAM activities after the Order of Conditions is issued by the Conservation Commission and after authorization to transport the excavated material to the receiving facilities is obtained. The excavation, off-Site recycling, and on-Site stabilization and reuse are anticipated to require several months to complete. RAM status reports will be submitted in accordance with 310 CMR 40.0445 until response actions have been completed. If the laboratory analytical data indicate that additional response actions are not necessary, then the RAM activities will be documented in a RAM Completion Report. • • • RECEIVED JAN 12 2012 • DEPT.OF PLANNING& • oommtJr rf DEVELOMENT • SITE-SPECIFIC • HEALTH AND SAFETY PLAN 72 FLINT STREET SALEM, MA 01970 • • • • • • PREPARED FOR: RIVERVIEW PLACE, LLC 5 BROADMOOR LANE PEABODY, MASSACHUSETTS 01960 • • PREPARED BY: • • DAVID L. BRAMLEY LSP • BRUCE M. POOLE • SP ENGINEERING, INC • 45 CONGRESS STREET • SALEM, MA 01970 • • • 1 • • I • • Health and Safety Plan 72 Flint Street, Salem,MA TABLE OF CONTENTS SECTION PAGE • 1.0 INTRODUCTION................................................:...................................................................1 2.0 BACKGROUND......................................................................................................................1 • 3.0 HEALTH AND SAFETY PLAN (HASP)...............................................................................2 • 3.1 General...........................................................................................................................2 • 3.2 Information Program......................................................................................................2 3.2.1 Contaminants of Concern....................................................................................3 3.3 Hazard Evaluation and Communication......................................................................10 • 3.4 Excavations..................................................................................................................11 • 3.5 Work Zones..................................................................................................................14 3.5.1 Exclusion Zone..................................................................................................15 3.5.2 Personal and Equipment Contaminant Reduction Zone...................................16 3.5.3 Support Zone.....................................................................................................17 • 3.6 Personal Protection......................................................................................................17 3.6.1 Personal Protection in the Support Zone...........................................................18 3.6.2 Personal Protection in the Contaminant Reduction Zone.................................18 3.6.3 Personal Protection in the Exclusion Zone.......................................................20 3.6.4 Perimeter Air Monitoring .................................................................................22 3.7 Safety Practices and Worker Protection......................................................................23 3.8 Communications and Emergency Procedures .............................................................24 3.9 Record Keeping ...........................................................................................................28 4.0 LIMITATIONS - 28 I � i � I � Health and Safety Plan • 72 Flint Street, Salem,MA • 1.0 INTRODUCTION SP Engineering, Inc. has prepared this Health and Safety Plan(HASP)to identify procedures to be followed during contaminated soil removal, and other planned activities at the former Salem • Suede;facility located at 72 Flint Street in Salem Massachusetts (hereinafter the "Site"j. Any • construction, excavation or remediation activities that may involve soil disturbance or removal and/or contact with groundwater at the Site must be conducted in accordance with the procedures outlined herein for the protection of human health and safety. 2.0 BACKGROUND The Site is located on the east side of Flint Street, south of Mason Street,and north of the . North River Canal in a primarily residential area of Salem,Massachusetts. The generally rectangular lot contains 3.69 acres and it is identified on Map No. 6 as parcel 26-0091-0. The Site originally contained several interconnected multi-story structures that were demolished in 2009. The first and second stories were of brick construction. The upper floors were of wood framing and sheathing. There is a large paved area at the Flint Street • entrance and a paved driveway access from Mason Street. The site slopes toward the North • River and approximately one-third of the property is in the Zone A floodplain. Based on the • topography of the Site, groundwater the groundwater flow direction is southerly toward the North River. The industrial buildings along the North River were placed on the Most Endangered List in 2000 due to constant threat of demolition. Since that time,three of the industrial buildings, including Salem Suede, have been demolished; another, Bonfanti Leather is to be demolished in conjunction with the redevelopment of the Salem Suede parcel. The North River has been a center of commerce since Salem's earliest days. Before it was successively filled in the 19th and • 20th centuries,the North River was navigable and served as a location for loading and unloading goods from the late 18th century into the 19th century. • Current plans for the Site include the construction of 130 units of residential rental housing and a parking garage. 1 Health and Safety Plan • 72 Flint Street,Salem,MA • 3.0 HEALTH AND SAFETY PLAN (HASP) y 3.1 General • This HASP is designed to establish policies and procedures for protecting the health and safety of the public and workers.during operations associated with, excavation and stockpiling contaminated soil and other activities that may result in soil disturbance, contact with groundwater, or entry into confined subsurface spaces(utility work, etc.). Due to the unpredictable and dangerous nature of these operations, identification, evaluation, and control all possible hazards is not possible. Strict adherence to this plan will reduce, not eliminate,the • potential for injury. Consequently, SP Inc. cannot and does not guarantee the health and safety of on-Site personnel or the public. It shall be the responsibility of on-Site personnel to report all potential hazards to the Project Superintendent (PS), or the Site Health and Safety Representative (HSR). 3.2 Information Program • To insure that all employees, contractors and subcontractors are aware of all dangerous • substances, health hazards, and other hazards they may encounter while working at the Site, SP Inc.has organized an Information Program (IP). • SP Inc. shall assist the Contractor in notifying employees, contractors and subcontractors of the nature, level and degree of exposure likely as a result of operations at the Site. This plan is intended to cover workers who are exposed to greater hazards than the general employee population. Consequently, Ancillary personnel who do not enter the operations shall not be covered under this HASP. Employees who regularly enter the operations areas of the Site, such • as supervisors, surveyors, laborers,trades people and others who are exposed to levels • significantly above background are covered. • This HASP concentrates on those substances that will create the greatest risk to employees. Risk assessment considers the following: substance toxicity, potential for exposure,proximity to toxic substance, and availability of controls. For example, a level of exposure of a general population that is not likely to exceed background levels would not normally require notification. Similarly, I � 2 Health and Safety Plan • 72 Flint Street,Salem,MA • a level of exposure above background but below established permissible exposure limits also would not require specific notification. As a precaution, however, if levels are unknown, • employees, contractors and subcontractors shall be informed of the potential for exposure. Employees shall be required to use appropriate protection until the area can be characterized through air monitoring. The Site owner shall also designate the HSR who shall be selected prior to the start of Site work. The HSR shall be responsible for overseeing the daily operations on the Site, air monitoring and implementing the HASP. The HSR shall be responsible for ensuring that all workers and all • on-Site operations are in full compliance with the HASP as well as all OSHA and USEPA • regulations and requirements. The HSR shall be present at the Site during any work that is covered by this HASP. The HSR and PS shall be familiar with all the conditions of this HASP and testify to this through the Plan Approval Agreement,which is included in Appendix A. The HSR shall ensure that all employees on-Site, who are covered by this Plan, read and understand this HASP. These employees are required to sign the Compliance Agreement Form, which is • included in Appendix B. • 3.2.1 Contaminants of Concern Considerable subsurface assessment has been conducted on the property. The four-story building that was closest to the North River was used for beaming and tanning the leather. This involved removing the hair and fat with lime and sulfide baths, followed by a degreasing process called bate which used ammonia and enzymes to open the pores of the leather. The hide was • fleshed after beaming and then pickled in sulfuric acid and salt. Trivalent chromium solutions • were added to the large drums to tan the leather. The chromium penetrates the leather and binds to the protein to act as a mordant for dyes and pigments. The process is aided by the addition of phenolic syntans. The center four story building was used for coloring the leather. Aniline and cationic dyes of all colors were applied in formic acid or ammonia baths to combine with the chromium. The fat liquors were sulfonated animal and fish oils that were applied to the leather in warm baths to • restore suppleness, flexibility and water resistance. The finishing of leather occurred in the 3 Health and Safety Plan • 72 Flint Street,Salem,MA • upper two stories and in the building to the north. Finishing was conducted using spray • equipment to apply clear, colored or pigmented coatings to the top grain side of the leather for • the polished appearance in shoes,pocketbooks, belts and garments. The finish operations used small amounts of naphthalene, toluene and xylene solvents as well as butyl acetate, glycol esters and other water-based emulsions. Based on the historic operations and results of the subsurface assessments, the contaminants of concern include the heavy metals, arsenic, chromium, and lead. In addition, fill was placed on the Site to raise the grade. This fill contains a variety of materials including demolition debris and ash which results in the presence of polycyclic aromatic hydrocarbons (PAHs). The Site also • contained an underground storage tank for the fuel oil (No. 4) used to heat the facility. Releases • over time have resulted in the presence of petroleum hydrocarbon compounds in the on-Site soils surrounding the boiler area. Also,the Site once contained a wastewater treatment lagoon that contained lime wastewater and sludge primarily from the beaming operations. The lime sludge is characterizes by a high pH. Although compounds that contained volatile organic compounds • (VOCs) were used in the leather finishing process, these compounds were used in small quantities . and generally were not discarded except as solid waste in empty or used containers that were removed from the Site. The only volatile found in the soil was naphthalene at levels below thw the S-1 criteria. Heavy Metals Arsenic: Arsenic is a silver-gray or tin-white brittle, odorless metal that is notorious for its use as a poison. Lead hydrogen arsenate has been used, well into the 20th century, as an insecticide on fruit trees (sometimes resulting in brain damage to those working the . sprayers), and Scheele's Green(a copper arsenate)has even been recorded in the 19th • century as a coloring agent in sweets. The application of most concern to the general public is probably that of wood that has been treated with chromated copper arsenate (CCA). CCA timber is still in widespread use in many countries, and was heavily used during the latter half of the 20th century as a structural and outdoor building material,where there was a risk of rot, or insect infestation in untreated timber. Bans on the use of CCA followed the • publication of studies that showed leaching from treated wood into surrounding soil,though 4 I � Health and Safety Plan • 72 Flint Street,Salem,MA the most serious risk is presented by the burning of CCA-treated wood. • Breathing high levels of inorganic arsenic can cause a sore throat or irritated lungs. Ingesting • very high levels of arsenic can result in death. Exposure to lower levels can cause nausea and • vomiting, decreased production of red and white blood cells, abnormal heart rhythm, damage to blood vessels, and a sensation of"pins and needles" in hands and feet. Ingesting or breathing low levels of inorganic arsenic for a long time can cause a darkening of the skin and the appearance of small "corns" or"warts" on the palms, soles, and torso. Skin contact with inorganic arsenic may cause redness and swelling. The Massachusetts Contingency Plan(MCP)cleanup concentration for residential uses is 20 mg/kg. ACG1H notes that arsenic is a confirmed human carcinogen. The following are exposure limits for inorganic arsenic in air: REL Ceiling: 0.002 mg/m3 15 min(Ca) • PEL: 0.010 mg/m3 • IDLH: 5mg/m3(Ca); TLV: 0.010 mg/m3(Al) Chromium: Chromium is a lustrous,brittle,hard metal. Its color is silver-gray and it can be highly polished.It does not tarnish in air, when heated it bums and forms the green chromic • oxide. Chromium is unstable in oxygen, it immediately produces a thin oxide layer that is • impermeable to oxygen and protects the metal below. Exposure media include dust, soil particulates, and water solution. Chromium main uses are in alloys such as stainless steel, in chrome plating and in metal ceramics. Chromium plating was once widely used to give steel a polished silvery mirror coating. Chromium is used in metallurgy to impart corrosion resistance and a shiny finish. • Trivalent chromium is used in dyes and paints, its salts color glass an emerald green and it is • used to produce synthetic rubies; as a catalyst in dyeing and in the tanning of leather and to make molds for the firing of bricks. 5 Health and Safety Plan • 72 Flint Street,Salem,MA Chrome tanning is performed using a one-bath process that is based on the reaction between the • hide and a trivalent chromium salt, usually a basic chromium sulfate. In the typical one-bath • process, the hides are in a pickled at a pH of 3 or lower,the chrome tanning materials are introduced, and the pH is raised. Following tanning,the chrome tanned leather is piled down, wrung, and graded for the thickness and quality, split into flesh and grain layers, and shaved to the desired thickness. Exposure to chromium can occur through breathing, eating or drinking, and through skin contact with chromium or chromium compounds. The level of chromium in air and water • generally is low. In drinking water the level of chromium usually is low as well. For most • people eating food that contains chromium(III) is the main route of chromium uptake, as • chromium(III) occurs naturally in many vegetables, faits,meats, yeasts and grains. Various ways of food preparation and storage may alter the chromium contents of food. When food is stored in steel tanks or cans chromium concentrations may rise. Chromium(III) is an essential nutrient for humans and shortages may cause heart conditions, disruptions of metabolisms and diabetes. But the uptake of too much chromium(III) can cause health effects as well, for instance skin rashes. Chromium(VI) is a danger to human health, mainly for people who work in the steel and • textile industry. People who smoke tobacco also have a higher chance of exposure to • chromium. It is known to cause various health effects. When it is a compound in leather products, it can cause allergic reactions, such as skin rash. Other health problems that are caused by chromium(VI) are: ➢ Skin rashes ➢ Upset stomachs and ulcers • ➢ Respiratory problems ➢ Weakened immune systems ➢ Kidney and liver damage • ➢ Alteration of genetic material • ➢ Lung cancer • ➢ Death 6 Health and Safety Plan . 72 Flint Street, Salem,MA The health hazards associated with exposure to chromium depend on its oxidation state. The • metal form is of low toxicity. The hexavalent form is toxic. Adverse effects of the hexavalent . form on the skin may include ulcerations, dermatitis, and allergic skin reactions. Inhalation of hexavalent chromium compounds can result in ulceration and perforation of the mucous membranes of the nasal septum,irritation of the pharynx and larynx, asthmatic bronchitis, bronchospasms and edema. Respiratory symptoms may include coughing and wheezing, shortness of breath, and nasal itch. • Chromium and most trivalent chromium compounds have been listed by the National Toxicology . Program(NTP)as having inadequate evidence for carcinogenicity in experimental animals.According to • NTP,there is sufficient evidence for carcinogenicity in experimental animals for the hexavalent • chromium compounds. The International Agency for Research on Cancer(IARC)has listed chromium • metal and its trivalent compounds within Group 3 (The agent is not classifiable as to its carcinogenicity to . humans.) Chromium is not regulated as a carcinogen by OSHA(29 CFR 1910 Subpart Z). ACGIH has . classified chromium metal and trivalent chromium compounds as A4,not classifiable as a human • carcinogen. Chromium has been delisted as a hazardous material by the EPA. . The following are exposure limits for chromium III compounds in air: REL: 0.5 mg/m3 PEL: 0.5 mg/m3 IDLH: 25 mg/m3(Cr III) The following are exposure limits for water-soluble chromium VI compounds in air: TLV: 0.05 mg/m3 (Al) • Appearance and odor vary depending upon the specific chromium compound. Excavated soil is • considered a hazardous waste when the leachable concentration of chromium lead exceeds 5.0 • mg/L. . Lead: A soft, heavy, toxic and malleable poor metal, lead is bluish white when freshly cut,but tarnishes to dull gray when exposed to air. Lead is used in building construction, lead-acid batteries, bullets and shot, weights, and is part of solder,pewter, and fusible alloys. This true metal is highly resistant to corrosion, and because of this property, it is used to contain corrosive 7 Health and Safety Plan . 72 Flint Street,Salem,MA liquids (e.g. sulfuric acid). Lead usually is found in ore with zinc, silver and (most abundantly) • copper, and is extracted together with these metals. The main lead mineral is galena,which • contains 86.6 percent lead. Other common varieties are cerussite and anglesite. Lead pollution in U.S. environment largely is a result of earlier uses. Lead in paint and gasoline together may account for most of the lead now in the human environment. In terms of raw tonnage,the amount of lead in gasoline over only the 57 years of its use from 1929 to 1986 roughly equals all of the lead in paints in 94 years of lead-based paint production, from 1884 to . 1978 • Lead is a potent neurotoxin that accumulates in soft tissues and bone over time. Excavated soil is considered a hazardous waste when the leachable concentration of lead exceeds 5.0 mg/L. The following are exposure limits for lead released into the air: PEL: 0.05 mg/m3 REL: 0.10 mg/m3 • IDLH: 100 mg/m3(Pb) • No.4 Oil Fuel oil numbers 4, 5, and 6 are commonly known as "residual oils" since they are manufactured in whole or in part from distillation residues from refinery processing. These three heavy fuel e oils are also known as gas oils and are composed of hydrocarbons ranging from C19 to C25- Residual oils are complex mixtures of relatively high molecular weight compounds and are . difficult to characterize in detail. Molecular types include asphaltenes, polar aromatics, naphthalene aromatics, aromatics, saturated hydrocarbons and heteromolecules containing sulfur, i oxygen, nitrogen, and metals. No. 4 fuel oil is a mixture of No. 2 and No. 6 oil which intended f for use in atomizing type burners that atomize oils of higher viscosity than domestic burners can handle. The permissible viscosity ranges of No. 4 oil allow it to be pumped and atomized at • relatively low storage temperatures. Therefore, in any weather(except extreme cold), it requires no preheating for handling in these burners. 8 Health and Safety Plan . 72 Flint Street,Salem,MA • No.4 oil can be directly toxic to some forms of aquatic life,can coat birds, and is of concern as a • potential source of polycyclic aromatic hydrocarbons (PAHs), a potentially harmful class of aromatic hydrocarbons. Chronic effects of some of the constituents in No. 4 oil (such as naphthalene) include changes in the liver and kidney. Due to their relative persistence and potential for various chronic effects (like carcinogenicity),PAHs (and particularly the alkyl PAHs) can contribute to long-term(chronic)hazards in contaminated soils, sediments, and . groundwater. Certain components of No. 4 oil, such as PAHs, may be carcinogenic to animals and humans. • There is evidence for the carcinogenicity in experimental animals of residual (heavy) fuel oils • and cracked residues derived from the oil refining of crude oil. Residual (heavy) fuel oils are possibly carcinogenic to humans. Polycyclic Aromatic Hydrocarbons • The term polycyclic aromatic hydrocarbons (PAHs)refers to a group of several hundred chemically-related environmentally persistent organic compounds of various structures and varied toxicity. Benzo[a]pyrene commonly is used as an indicator species for PAH contamination and most of the available data refer to this compound. PAHs may be formed during natural processes such as incomplete combustion of organic materials such as coal and wood, or during forest fires. PAHs are released during industrial • activities such as aluminum,iron and steel production in plants and foundries, waste incineration, • mining or oil refining. PAHs have also been detected at low levels in cigarette smoke and motor vehicle emissions. They are persistent organic pollutants and are slow to degrade in the environment. PAHs also are present in asphalt. PAHs have been found to be present in very small amounts in some foods including meat, fruit, vegetables and cereals. Various cooking processes such as charbroiling, frying or grilling, as well . as barbequing or smoking also increases the amount of PAHs in food. 9 • Health and Safety Plan • 72 Flint Street,Salem,MA Overall, the major route of exposure to PAHs in the general population is from breathing • ambient and indoor air, eating food containing PAHs, smoking cigarettes, or breathing smoke • from open fireplaces. • The presence of PAHs in the environment does not always lead to exposure as there must be • contact with the chemical. There may be exposure via breathing, eating, or drinking the • substance or by skin contact. Following exposure to any chemical,the adverse health effects depend on several factors, including the amount of exposure (dose), the duration of exposure, the method of exposure, and exposure to other chemicals. • • Some PAHs caused tumors in animals when they breathed, ate, or had skin contact for long periods. Studies in humans have shown that breathing or skin contact for long periods may cause lung or skin cancer. Several PAHs have been classified by the International Agency for Research on Cancer(IARC) as being carcinogenic in humans. • • 3.3 Hazard Evaluation and Communication • • The activities that will be conducted on Site are likely to involve disturbance or removal of soil and exposure to groundwater in which the concentrations of the constituents of concern exceed • certain MADEP risk standards. The contamination discovered at the Site to date consists of ` Extractable Petroleum Hydrocarbons (EPH), polycyclic aromatic hydrocarbons (PAHs), and the metals arsenic, chromium, and lead in the soil and groundwater. A summary of analytical results • from soil and groundwater samples at the Site is included in Tables 1, 2, and 3, along with the • applicable MADEP standards(Method 1 Risk Standard for Soil category S-2, Groundwater category GW-2 and GW-3, as per the Massachusetts Contingency Plan [MCP, 310 CMR 40.0000]). Certain PAHs can pose a risk to human health, through dermal contact, inhalation, • and ingestion. Because the EPH compounds are not volatile, inhalation is the secondary • exposure pathway of concern. The primary exposure path way is through the dermal contact with contaminated soil. Respiratory precautions and monitoring must be conducted at all times • for those personnel who will work in and around any areas of excavation, as detailed in • Section 3.6, Personnel Protection. • • 10 • • • Health and Safety Plan • 72 Flint Street,Salem,MA All employees shall be informed of the potential hazards and trained in appropriate practices through the HASP. In this HASP,the following items are addressed: 1. Specific requirements and safety standards S 2. Nature of dangerous substances in the workplace • 3. Protection from hazards and spill control 4. Access to information through Technical documents, Industrial Hygiene sheets 5. Employee rights During initial training,all employees covered by this Plan shall be trained in hazard recognition and label interpretation as well as understanding the information provided in the HASP. An MSDS shall be required for identified materials brought onto or discovered on the Site. All MSDSs shall be kept in a central file on Site and shall be available to all employees. The • documents pertinent to contamination identified at the Site are enclosed in Appendix C. If any • new hazards are encountered,the relevant toxicity data shall be reviewed with the employees in a safety meeting. . 3.4 Excavations i Trenches and excavations are to be inspected daily for indications of possible cave-ins, hazardous atmospheres, failure of protective systems, or other unsafe conditions, to protect • workers and prevent material release. • How To Avoid Hazards • Inspect excavations: • Before construction begins • Daily before each shift • As needed throughout the shift • Following rainstorms or other hazard-increasing events (such as a vehicle or other equipment approaching the edge of an excavation) 11 Health and Safety Plan • 72 Flint Street,Salem,MA Inspections must be conducted by a competent person who: • • Has training in soil analysis • Has training in the use of protective systems Is knowledgeable about the OSHA requirements • Has authority to immediately eliminate hazards Excavated materials (spoils) are dangerous if they are placed too close to the edge of a trench or excavation. The weight of the spoils can cause a cave-in, or spoils and equipment can roll back on top of workers, causing serious injuries or death. How To Avoid Hazards • Provide protection by one or more of the following: • • Set spoils and equipment at least 2 feet back from the edge of the excavation. • Use retaining devices, such as a trench box, which will extend above the top of the trench e to prevent equipment and spoils from falling back into the excavation. • Where the Site does not permit a 2-foot setback, spoils may have to be moved to another location. • Cave-ins may be the most feared trenching hazard, but other potentially fatal hazards exist, • including asphyxiation due to lack of oxygen in a confined space, inhalation of toxic fumes, drowning, etc. Electrocution or explosions can occur when workers contact underground utilities. • All excavations are dangerous because they inherently are unstable. If they also are restricted spaces they present the additional risks of oxygen depletion, toxic fumes; and water accumulation. If protective systems or equipment are not being used while working in trenches or excavations, there is danger of suffocating, inhaling toxic materials, fire, drowning, or being crushed by a' cave-in. • How To Avoid Hazards • Pre-job planning is vital to accident-free trenching; safety cannot be improvised as work progresses. The following concerns must be addressed by a competent person: 12 Health and Safety Plan • 72 Flint Street, Salem,IIIA • • Evaluate soil conditions and select appropriate protective systems. • Construct protective systems in accordance with the standard requirements. • Preplan; contact utilities (gas, electric)to locate underground lines,plan for traffic control if necessary, and evaluate proximity to structures that could affect choice of protective system. • Monitor for low oxygen concentration, fumes, and toxic gases, especially when gasoline engine-driven equipment is running, or the soil has been contaminated by leaking lines or • storage tanks. Ensure adequate ventilation or respiratory protection if necessary. • • Provide safe access into and out of the excavation. • Provide appropriate protections if water accumulation occurs. • Inspect the Site daily at the start of each shift, following a rainstorm, or after any other hazard-increasing event. • Keep excavations open the minimum amount of time needed to complete operations. • To avoid fall injuries during normal entry and exit of a trench or excavation, ladders, stairways, or ramps are required. In some circumstances, when conditions in a trench or excavation become dangerous, survival may depend on how quickly escape is possible: • Provide stairways, ladders,ramps, or other safe means of egress in all trenches that are four feet deep or more. • • Position means of egress within 25 lateral feet of workers. • • Structural ramps that are used solely for access or egress from excavations must be • designed by a competent person. 13 L Health and Safety Plan • 72 Flint Street,Salem,NU • When two or more components form a ramp or runway,they must be connected to • prevent displacement, and be of uniform thickness. • • Cleats or other means of connecting runway components must be attached in a way that would not cause tripping(e.g., to the bottom of the structure). • Structural ramps used in place of steps must have a non-slip surface. • Use earth ramps as a means of egress only if a worker can walk them in an upright position, and only if they have been evaluated by a competent person. 3.5 Work Zones • Because of the extent of contamination at the Site, clear definition of the work areas for each stage of excavation is important. The boundaries of these zones shall be determined by the HSR at the Site, and shall be adjusted to reflect each stage of work. The work zones shall be defined each time an excavation is planned in any area of the Site. The zones will allow workers to understand where excavations will occur,what areas will be influenced by the contamination and • what protective equipment, and safety precautions shall be necessary. SP Inc. uses a three-zone approach in controlling Site activities. This approach is designed to prevent possible exposure of unprotected Site personnel to the constituents of concern in the Site materials and to prevent the removal or migration of contaminants from the Site. The three zones consist of the Exclusion Zone, Contamination Reduction Zone and Support Zone. • These zones shall be designated using cones, barrier tape, or security fencing. Movement of personnel and equipment between these zones and onto the Site shall be strictly regulated through access control points. The different excavation areas are shown in Figure 2, Site Plan. The actual size of these work zones will depend on several factors including scope of work, contaminants encountered, as well as environmental and Site conditions. The HSR or PS will be responsible for continually evaluating and determining the appropriate size and location of the work zones, as well as the location of the specific access control points. 14 Health and Safety Plan • 72 Flint Street,Salem,MA 3.5.1 Exclusion Zone The Exclusion Zone is the Zone where substantial contamination does or likely exists;which will correspond to the area surrounding any subsurface excavation at the Site. All personnel entering the Exclusion Zone shall wear prescribed levels of protection. An entry and exit check point • shall be established at the periphery of the Exclusion Zone to regulate the flow of personnel and • equipment into and out of the Zone and to verify that the procedures established to enter and exit are followed. • The outer boundary of the Exclusion Zone shall be established according to the location of substances containing the constituents of concern, ash, leather, oily soil and any visual or olfactory signs of contamination. Additional factors that are considered include the distances needed to prevent fire or an explosion from affecting personnel outside the Zone, the physical • area necessary to conduct operations,and the potential for fugitive emissions release. The • boundary of the Exclusion Zone shall be called the Hotline. The Hotline is generally the • excavation and a 10 foot perimeter. which when established, shall be physically marked with tape or cones or otherwise well defined. All individuals entering the Exclusion Zone shall have the proper training, appropriate personal protective equipment(as specified in Section 3.6), and medical authorization. Personnel protective equipment shall be designated based on Site-specific conditions including the type of work to be done and the hazards that may be encountered. Levels of protection are based on. • anticipated or measured concentrations of substances,potential for contamination, known or • suspected presence of ash and landfill materials, and the task being conducted within an area. The HSR shall be responsible for evaluating available information and establishing appropriate levels of protection. 15 L• Health and Safety Plan • 72 Flint Street,Salem,MA • 3.5.2 Contamination Reduction Zone Between the Exclusion Zone and the Support Zone is the Contamination Reduction Zone. This area provides a transition between contaminated and clean Zones. This Zone serves as a buffer to further reduce the possibility of the clean Zone becoming contaminated or being affected by + existing hazards. It provides additional assurance that the physical transfer of contaminating • substances is limited through a combination of decontamination, distance between Exclusion and Support Zones, air dilution, Zone restrictions, and work functions. At the boundary between the Exclusion and Contamination Reduction Zones,a Contamination Reduction Corridor(decontamination station) shall be established. Depending on the size of the operation, more than one corridor may be necessary. As operations proceed,the area around the decontamination station may become contaminated, but to a much lesser degree than the • Exclusion Zone. On a relative basis,the amount of contaminants should decrease from the • Hotline to the Support Zone due to the distance involved and the decontamination procedures • used. • Access to the Contamination Reduction Zone from the Support Zone shall be through a control point. Personnel entering this location shall wear the proscribed personnel protective equipment for working in the Contamination Reduction Zone. Entering the Support Zone shall require decontamination and removal of any protective equipment worn specifically for work in the Contamination Reduction Zone. All used suits, gloves, plastic and soiled materials shall be • placed in a lined covered dumpster along with common trash and food. If rodents are observed • then poison bait boxes shall be placed and maintained by the dumpster and along the property line. Windblown plastic, leather pieces, glass and trash shall be collected daily and placed in the covered dumpster. Truck and equipment decontamination will also occur on a lined concrete slab in this area. Equipment and trucks leaving the Site, especially during loading and transport to the disposal . facility, shall have all loose soil manually brushed or swept from the tracks, rails, sides, chassis • and tires. This material is collected and returned to the pile. Should oil or sludge have smeared 16 Health and Safety Plan • 72 Flint Street,Salem,MA • on the sides or tires,then the units shall be pressure washed and wiped with the liquid collected • in the lined sump, as shown in Figure 3, Decontamination area. The liner and the sump shall be • sprayed down every day and the washwater transferred to a Frac tank for storage, chemical �. analysis and ultimate disposal when the project is finished. As the sump is cleaned after use the rainwater is released to the Site grounds for infiltration. Runoff from the hillside and Bonfanti factory shall de directed away from the decontamination and support zones. • 3.5.3 Support Zone The Support Zone shall be the area most remote from the area(s)being remediated and is considered a non-contaminated area. Support equipment(chemical storage trailer, equipment and spill control trailer,personal hygiene facility, etc.)will be located in this Zone, and traffic • shall be restricted to authorized personnel. Since normal work clothes are appropriate within this • Zone, potentially contaminated personal protective equipment, clothing, and samples will not be permitted in this area. The location of a equipment trailer and other support facilities within the Support Zone will depend on a number of factors, including: Accessibility: topography; open space available; or other limitations Wind direction: preferably,the support facilities shall be located upwind of the Exclusion Zone. However, shifts in wind direction and other conditions may be such that an ideal location based . on wind direction alone does not exist. • Resources: adequate access, power,water, and shelter 3.6 Personnel Protection Proper security will be provided on-Site to ensure that unauthorized persons do not wander or 0 drive onto the Site, especially during soil disturbance or removal activities. Site security shall consist of a six-foot high chain-link security fence or other approved barrier,which shall be • secured at night. 0 17 • • �_ Health and Safety Plan 72 Flint Street,Salem,MA I � The presence of PAHs and metals in the Site soils poses a threat in the event of inhalation, ingestion, or dermal contact. As such, precautions shall be taken to minimize direct exposure to • the contaminated groundwater and soil. Based on an evaluation of the anticipated hazards, requisite personnel protective equipment shall be defined for each of the designated work zones. • In addition to the equipment described below,the Site contractor may issue other personnel protection equipment such as hard hats, fall protection belts, safety footwear, and noise protection as part of the overall General Safety Program, which is not covered in this plan. Use of personal protective equipment during excessively hot weather could result in heat stress. The HSR shall be responsible for monitoring potential heat stress problems and adjusting any work practices as needed. For example,the HSR shall institute frequent water breaks, or require that short-sleeved clothing be worn under outer protective layers, as needed. For the protection of workers, lunch facilities shall be established in a clean area away from the sources of contamination. Contaminated disposable coveralls shall be removed and hands and • face shall be washed prior to eating, drinking or smoking. • Finally, SP Inc. has prepared the following list of Site hygiene rules,to ensure the safety of • personnel. 1) Only appropriate protective clothing shall be worn during work activities. • 2) All work clothing shall be brushed for loose dust prior to leaving the work area. 3) Hands and face shall be washed before eating, drinking or smoking. 4) Eating surfaces shall be cleaned before and after eating. 5) Smoking, eating, use of cosmetics or tobacco products, food, and cosmetics shall be prohibited on the Site, except in designated areas. • 3.6.1 Personnel in the Support Zone All personnel on the Site who are covered by this HASP will be required to have level D protection. This protection is acceptable for all tasks in which workers will not directly 18 . Health and Safety Plan 72 Flint Street,Salem,MA encounter contaminated soil, such as surveyors, supervisors, etc. Level D protection is defined • by OSHA as the use of a normal work uniform. This shall include standard work attire with a minimum of long pants, short sleeved-shirts, and closed-toed shoes. • Visitors to the Site who will only enter the Support Zone shall be informed that the HASP is in • effect at the Site. However,this HASP does not cover such visitors performing clerical work in the Support Zone. Site personnel who regularly work throughout the Site are covered by this HASP. All Site personnel who are covered by the HASP are required to wear Level D protection and are required to be informed of this HASP and sign the Compliance Agreement Form. 3.6.2 Personnel in the Contamination Reduction Zone Personnel may be present in the Contamination Reduction Zone to assist in decontamination procedures. Personnel assisting in decontamination may come in contact with contamination through splashed decontamination water or direct contact with contaminated persons. As such, these persons are expected to wear modified Level D Protection. Modified Level D Protection is • defined as precautionary protection against potential exposure to contamination. It consists of the following personnel protection equipment: • Coveralls/uniform • Safety boots • Gloves • Eye protection • . Hard hats All personnel traveling from the Contamination Reduction Zone to the Support Zone must pass through one access control point. Prior to leaving the Contamination Reduction Zone all • personnel must brush themselves down. Personnel must then remove their Tyvek® suits, and gloves for disposal with other contaminated material. Only after decontamination may a worker enter the Support Zone. 19 Health and Safety Plan • 72 Flint Street,Salem,MA • All personnel traveling from the Contamination Reduction Zone to the Exclusion Zone must pass • through one access control point. All personnel entering the Exclusion Zone must be properly outfitted with the protective equipment identified in Section 3.5.3. No workers may pass directly from the exclusion Zone to the Support Zone without fust passing through the Contamination Reduction Zone. 3.6.3 Personnel in the Exclusion Zone • All personnel working in the Exclusion Zone are in danger of coming in contact with • contaminated soil and/or groundwater; this includes heavy equipment operators, any workers who will enter the excavation, and any supervisors who will oversee the excavation. All personnel entering the Exclusion Zone are expected to wear modified Level D protection as defined above, as well as a TyveO suits and rubber boots. • Coveralls/uniform • Safety boots • Gloves • Eye protection • Hard hats • Tyvek suits • Rubber boots All personnel entering the Exclusion Zone must be prepared to wear a respirator if the HSR deems it is necessary. The HSR shall be responsible for air monitoring in and around the Exclusion Zone. Air monitoring shall be conducted both upwind and downwind of the Exclusion Zone, in the excavation as well as in the operating compartments of any heavy • equipment in the Exclusion Zone. While identified materials such as ash and leather wastes are • not odorous the removal of lagoon sludges and landfill has the potential to release organic and • inorganic osmogenes such as mercaptans, thioamines and sulfides. Air monitoring for odors (hydrogen sulfide)will be conducted using a Model TMX412 Multi-Gas Monitor by Industrial Scientific. Dust monitoring will be conducted using Model 8530 DUSTTRAKTm II Aerosol Monitor by TSI. The only Volatile Organic detected in the soil was naphthalene and these 20 Health and Safety Plan . 72 Flint Street,Salem,MA • compounds will be monitored with a MiniRae ppb PID meter. If the contaminant concentrations • listed in the following table are detected in the breathing zone for one minute, the workers will upgrade from Level C PPE to Level B PPE. • Action Levels Requiring PPE Upgrade Contaminant Instrument Action Level • Combustible Gas Multi-Gas Monitor 100/,Lower Explosive Limit(LEL)is normal 10%LEL requires immediate Site evacuation Dust DUSTTRACK 10.0 mg/m3 mg/m3requires half or full-face res irator Noise Quest 400Dosimeter >85 decibels requires hearing protection . Oxygen Oxygen Meter 19.5%to 23%is normal • Odor(Hydrogen Multi-Gas Monitor >10 ppmv requires full-face respirator Sulfide Volatile Organic PID >50 ppmv requires full-face respirator • Compounds If the conditions so warrant,the HSR may require personnel within the Exclusion Zone to wear a • respirator with specific cartridges for dust, volatiles and inorganics (sulfides). Therefore, these • workers shall receive training in the proper use, cleaning and storage of respirators from the HSR. Any employee using a respirator shall be responsible for cleaning and storing the respirator. Cleaning shall also occur if an employee is giving his respirator to a different individual. A special wash/decontamination area shall be provided on the Site for this purpose. During cleaning,respirators shall also be inspected for any defects or warn parts that may need • replacement. Extra filters shall be provided and shall be replaced as needed to allow easy • breathing by the user. The HSR shall be responsible for conducting inspections to make sure that all respirators are being cleaned properly and expended cartridges, wom parts are appropriately replaced. A Respirator Inspection Report sheet is enclosed as Appendix D. Finally, within the Exclusion Zone, some personnel may'enter excavations. All personnel who will enter an excavation must have on-site training on the specific hazards, and must have read and agreed to the conditions of this HASP. Whenever any worker is to enter an excavation,the HSR shall be notified in advance. Additionally, while any worker is within an excavation, air • monitoring must be conducted to monitor his/her exposure to volatile contaminants. 21 Health and Safety Plan • 72 Flint Street,Salem,MA • 3.6.4 Perimeter Air Monitoring • The area surrounding the Site is primarily residential and a program of Air monitoring is proposed to protect the neighbors from nuisance conditions. The Plan calls for 4 stations, 3 between the Site and the residences and 1 between the Site and the North River. An environmental enclosure and tripod would be set up next to the property line with • DUSTTRACKER 11.8530 units that measure particulates and stores the data to calculate a time • weighted average,(TWA) for daily activities. The units would operate continuously during • excavation, demolition, stabilization and truck loading. If values of 1.0 mg/cm TWA over background(which is determined weekly) are detected, then work will stop and the corrective actions listed below will be taken. The portable meters used for worker safety will also be used 2 times per day at all stations to measure sulfides,volatiles and noise that could impact residents. The Action Levels are shown below and the corrective actions include; wet down surfaces,wait • for better weather, cover piles hourly, spread lime or CKD to dewater and raise pH, spray i deodorant at the excavation, cover with peat moss, etc. The results of the Air Monitoring shall be reported to the Board of Health in a weekly report. AIR MONITORING PLAN PARAMETER FREO. WORKER PROPERTY CORRECTIVE • TEST UNIT LIMIT LIMIT ACTION • DUST PART. CONT.* 10 mg/cm 1.0 mg/cm STOP EXCAVATION/LOADING TSI 8530 DUSTTRAK H WET SURFACES • WAIT FOR LESS WIND • COVER PILES HOURLY • ODOR, SULFIDE 2X/DAY 10/15 ppm 1.0 ppm STOP EXCAVATION/LOADING ISTMX 412 MULTIGAS SPREAD LIME WAIT FOR COLD/LT RAIN • MOVE PILE,COVER HOURLY SPRAY DEODORANT 22 L _ Health and Safety Plan • 72 Flint Street,Salem,MA VOLATILE ORGANICS NAPTHALENE 2X/DAY 10/15 ppm 1.0 ppm STOP EXCAVATION/LOADING MINIRAE PID IDENTIFY SOURCE COVER AND CONTAIN ` SPREAD PEAT OR CKD NOISE 2X/DAY 120 Db 80 db STOP EQUIPMENT QUEST Q-400 SLOW DOWN OPERATION • DOSIMETER PLACE MATS ON SLABS • * THERE WILL BE 4 MONITORING STATIONS,3 BETWEEN THE WORK AND • RESIDENCES,AS SHOWN ON THE PLAN AND 1 BESIDE THE RIVER.THE DUST • MONITORING IS CONTINUOUS DURING DEMOLITION,SOIL EXCAVATION, • STABILIZATION AND TRUCK LOADING AND RESULTS ARE BASED ON A TIME • WEIGHTED AVERAGE (TWA).THE PORTABLE AIR QUALITY MONITORS WILL BE • USED AT TIRE WORK AREAS FOR WORKER SAFETY AND 2X/DAY READINGS WILL BE TAKEN AT THE 4 STATIONS,WITH THE RESPONSES LISTED ABOVE IF THE LIMITS ARE EXCEEDED. 3.7 Safety Precautions and Work Practices • SP Inc. is committed to developing and maintaining strong safety awareness on all job sites. A • list of standing orders has been developed to ensure that all persons are cognizant of potential hazards. These orders shall be distributed to persons entering the Site and shall be conspicuously posted. The standing orders shall be reviewed by the PS or HSR. Any changes in the orders shall be announced officially during the daily safety meeting. The following orders apply: ➢ Smoking, eating and drinking shall be strictly prohibited in areas of exposed contaminated soil. 23 Health and Safety Plan . 72 Flint Street,Salem,MA ➢ Proscribed personal protective equipment shall be worn as directed by the HSR or PS. • ➢ If the protective clothing should tear, it shall be replaced immediately. ➢ Assumptions shall not be made concerning the nature of materials found on the Site. If unusual situations occur, operations shall cease and the HSR or the PS shall be contacted immediately for further direction. . ➢ Consultation with the PS shall be made to verify any uncertainties. ➢ The PS or HSR shall be informed when: • Unusual odors, emissions, or signs of chemical reaction shall be reported • immediately. 0 Workers shall minimize contact with contaminated materials by: 0 Avoiding areas of obvious contamination 0 Using polyethylene sheeting to help contain contaminants • Avoiding contact with contaminated materials • ➢ Only essential personnel shall be permitted in the work zones. 0 ➢ Whenever possible,personnel shall be located upwind during material handling. ➢ At the first sign of odors detected inside the face-piece of a respirator,the employee shall leave the area of contamination and report the incident to the HSR or PS. 0 ➢ If an employee begins experiencing any signs or symptoms of exposure to Site toxic 0 material(this information shall be discussed during the daily meeting and/or can be found 0 on the appropriate MSDS(s)),the employee shall leave the area immediately and report 0 the incident to the HSR or PS. 0 3.8 Communication and Emergency Procedures • • The following items shall be located and discussed with all field personnel prior to the initiation 0 of work at the Site. • 1) Health and Safety Plan 0 • 2) Personal protective equipment 3) On-Site Health and Safety Representative contact 24 • 0 LO_ Health and Safety Plan . 72 Flint Street,Salem,MA • 4) Location of nearest telephone In the event of an emergency, development of dangerous Site conditions, or significant changes . in the work plan, communication shall be established as soon as is practicable. If a worker • discovers a fire, chemical spill or release or other upset,he/she shall immediately notify the HSR or PS,who shall decide whether to evacuate the Site or take other action. In an emergency that requires evacuation, personnel shall be alerted with THREE LONG BLASTS OF A COMPRESSED AIR HORN. Upon this alarm notification, all personnel shall proceed to the nearest Site exit and mobilize to a safe distance area associated with the evacuation route. • Personnel shall remain in this safe area until the re-entry alarm(single blast of air hom) is • sounded. • Should any worker become injured or develop unusual symptoms while working on-Site, he/she • shall be immediately transported to the nearest hospital,the Salem Hospital. Figure 1 provides a map including the Site and this location, illustrating the proposed route of travel from the Site. Directions to the hospital are provided below. tIICSfllem HOspltal k Mgliland Street,Salem MA S i �4 'r i 1�rz�,Ss il` iri 77i, . 1. Exit the Site onto Mason • 2. Turn left on Mason Street 3. Turn left onto Flint Street 4. Follow Flint Street southeast to Essex Street 5. Turn right onto Essex Street 6. Follow Essex Street southwest. Essex Street becomes Highland Avenue(Route • 107)at Boston Street 7. Follow Highland Street to the Hospital on the left L � Any worker who becomes ill or requires emergency medical treatment while within the area of contaminated soil shall first be decontaminated to the maximum extent possible. For a minor injury, full decontamination shall be completed and fust aid administered. In the event of a 25 Lo Health and Safety Plan • 72 Flint Street,Salem,MA serious condition,at least partial decontamination shall be completed(for example, disrobing of • the individual and wrapping in a clean blanket). Prior to work on Site, contact with the local hospital shall occur in order to advise the emergency room of the nature and type of contaminants victims may have been exposed to while on the Site. In the event of a fire,the local Fire Department shall be notified immediately. The PS or HSR shall advise the Fire Department of the location and nature of the fire and shall assist the Fire Department in any possible. In the event that an employee discovers a spill or leak,he/she shall immediately inform his/her supervisor. If safely possible, trained personnel should attempt to locate the source of the spill or • leak, stop the flow and contain the released material,then begin recovery of spilled/released • material for disposal or future re-use. Should the spill pose a significant hazard to, or be beyond the capability of immediate personal, the HSR or PS shall be notified immediately. The HSR or PS shall obtain the following information: / 1) The material spilled or released • 2) The location of the spill or release 3) An estimate of the quantity released and the rate of release 4) Any injuries that have occurred 5) The possibility and scope of a fire or explosion Upon assessment of the situation,the HSR or PS shall determine an area of isolation around the spill. Only those people involved in the emergency cleanup operations shall be allowed within this designated hazard area. If possible, a physical barrier shall indicate the boundaries of this . area. The HSR or PS shall be responsible for notifying the proper authorities and, if necessary, the surrounding community. If control and cleanup is within the capabilities of Site personnel, then the police or emergency management personnel shall not be notified unless the release migrates beyond the Site perimeter. Reporting of spills or releases in accordance with federal, state and local regulation shall be the responsibility of the HSR or PS. The PS shall have primary responsibility for responding to emergency situations. This includes 26 Health and Safety Plan 72 Flint Street,Salem,MA taking any measures necessary to protect the safety of both on-Site personnel and the public. • Following an emergency, the PS is responsible for any corrective measures that shall be implemented. The PS shall verify regularly that all prevention devices and equipment(air hom, radio,mobile phone, emergency vehicles, directions to hospital, etc.) are available to all personnel and in full working condition. The following emergency equipment shall be located at the field decontamination station: • 1) First aid kit 2) Fire extinguisher 3) Sink with running ring water 4) Two-way radio or mobile phone The PS shall establish a clear line of communication with the local hospital and government agencies. All employees shall be trained as to specific emergency plans and shall have access to the following phone numbers. TELEPHONE ' r sgAGENCY i . ALL EMERGENCIES 911 Salem Hospital 978-741-1200 • Salem Police Department 978-744-0171 Salem Fire Department 978-744-6990 Salem Water and Sewer 978-619-5675 Boston Gas 978-745-5737 National Grid 1-800465-1212 • Dig Safe 1-88&DIG-SAFE (1-888-344-7233) MA DEP Hotline (617) 338-2255 " EN42ONMENTAL'FHtMP TELEPHONE , -M,.7: , �,24 " �h� t.... Z9" f s i,.r u . SP Engineering, Inc. (978) 745-4569 27 Health and Safety Plan • 72 Flint Street,Salem,MA • 3.9 Record Keeping Thorough records and reports shall be maintained and modified as the project progresses in compliance with local, state and federal regulations. These records shall include: certificates for • clearance for respirators, air sampling results, certification of training, inspections for proper use • and maintenance of respirators, monthly HASP compliance reports by the HSR, and employment records. These records shall be maintained for each employee for at least thirty years. Non- individual records will be maintained indefinitely. 4.0 LIMITATIONS The HASP is provided to the Contractor to be used as the Contractor deems appropriate to supplement Health and Safety procedures that the Contractor already has instituted and to meet • requirements imposed on the project by OSHA and the MADEP. It is the responsibility of the • Contractor to review this HASP to determine if they are workable and if they are in conformance with the Contractor's policies and procedures. SP Inc. does not assume any liability for any injuries or health effects claimed by workers or visitors to the Site. Information regarding other safety protections presented herein is presented only for the convenience of the Contractor, who is responsible for implementing such protections that, in the Contractor's judgment, are • applicable and necessary. In preparing this HASP, all readily available pertinent information has been collected from • previous Site investigations and local authorities. This information has been accepted as • accurate. Prepared under the direction and supervision of: SP Engineering, Inc. • (3 tM . Bruce M. Poole David L. Bramley • President LSP 28 • Health and Safety Plan • 70 Flint Street, Salem, MA 0 FIGURES • Dnvmg Directions trom /U Ylmt Jt,Jalem,Massachusetts UlY/U to X1 Higmanct Ave,Ja... rage L of G • • Total Travel Estimate:0.82 miles-about 2 minutes • if • tl J 1141 w Salem ,.I I <' ss > ♦. E 'o ' 1 • ssr c fdS} t 6 .� �r St"7h r t nx s I • _ y G7 cud c� � �'` {., • � �h4 ri1a 'J v 'mer._: I • d. • ' ; tj y_1 Jr" p " d ¢ • mamues[ 3 i • @2011 MaPQue><tj,Pmtia�re t'V AYTEO Inter—PI • - 02011 MapQuest,Inc.Use of Alrecbons and maps is subject to the MapQuest Terms of Use.We make no guarantee of the accuracy of their oontwL road condi0ons or route usability.You assume as riskof use:+�r_�zym_I u_,ls^ • • • • • • • G '1 • http://www.mapquest.com/print?a=app.core.c5475076dece3fc7512cc887 12/7/2011 • • • Health and Safety Plan • 70 Flint Street, Salem,MA L TABLES i � Table 2 - Soil Analytical Summary(Test Pits) Former Salem Suede 72 Flint Street Salem,Massachusetts Sample ID: TP-1 TP-2 TP-3 TP-3A TP-4 TP-5 TP-6 TP-7 TP-8 MCP.Clean up Standards+ Date Sampled: 12/3/09 12/3/09 12/3/09 12/3/09 12/3/09 12/3/09 12/3/09 12/3/09 12/3/09 °S•1 - '. s S•2 b Depth feet: 0.4 04 0-6 0-4 0-4 2-5 4-6 0-6 0-6 >`GW-2 - GW-3 �GW-2 -GW3. EPH m -DEP Method 04.1 C,-C,,Ali hatics NA NA 2,750 1880 NA NA ND <100 NA 1000 . -`1000 -3,000 :3,000. C,CAli hatics NA NA 3,890 2,990 NA NA ND <100 NA ;S 3.000; :3,000- 51000 5,000 C1 -C22 Aromatics NA NA 2,170 - 3,710 NA NA , ND <I00 NA a>1000', `1900 3,000 3000 PAHs m -EPA Method 8270C Acenaphthene NA NA 11.6 NA NA 0.013 NA <0.1 NA 1,000 `.:1,000 '.3,000J,30O0 Acena hth lene NA NA 15.1 NA NA NR NA <0.1 NA 600 . 10 "600 Anthracene NA NA 11.7 NA NA 0.25 NA <0.1 NA 1,000 :1000. 3;000 ' Benzo a anthracene NA - NA 11.5 NA NA <0.1 NA <0.I NA 7 -;/7 ".40'Benzo a ne NA NA <0.1 NA NA 0.02 NA <0.1 NA 2 -- 2 4.Benzo fluoranthene NA NA 11.2 NA NA 0.49 NA <0.1 NA s: ;7 >7 'r 400'=Benzo ,h,i a lene NA NA <0.I NA NA 0.007 NA <0.1 NA -.}1 000 `'1'000 -.3 000 Benzo k fluoranthene NA NA 10.7 NA NA 0.006 NA <0.1 NA 70', .::70 400 400 Ch Bene NA NA 21.1 NA I NA 0.081 NA <0.1 NA 70 -.70 400, 400. Dib"enzo a,h anthracene NA NA <0.1 NA NA <0.1 NA <0.1 NA - '0.7 "1.07 '4 4:.- Fluoranthene NA NA 24 NA NA 0.002 NA <0.1 NA A1000 - 1,000 3,000 3,000 Fluorene NA NA 20.4 - NA NA 0.022 NA <0.1 NA 1,000 1;000 3;000 3,000 lndeno 000Indeno(1,2,3-cd) ne NA NA <0.1 NA NA <0.1 NA <0.1 NA 7. 7 r "40 ° 40 '. Naphthalene NA NA 0.5 NA NA 0.02 NA <0.1 NA 40 +-500 -40- '.1,000 Phenanthrene NA NA 27.3 NA NA ND NA <0.1 NA - -:500 r 500 '.:1000 '-11000 Pyrene NA NA 34.3 NA NA 195 NA <0.1 NA >_"1,000 1(0(10 3,000 3,000 2-Methylnaphthalene NA NA 0.3 NA NA <0.1 NA <0.1 NA 80 ":300 80' 500- Metals m Arsenic NA NA NA NA NA NA NA NA NA " 20 '`"20 -20: _ 20--- Cadmium 0.6 0.26 2.82 0.37 11.6 1.27. 1.1 0.56 0.86 2 2' -•30. 30., Chromium 15.1 2,260 73 9 1,510 915 897 65.7 196 30 �:'30 ,200 200 Lead 27.3 15.4 140 11.4 24.4 120 145 12.2 47.8 '300 - - 300 ::300. 300 Mercu NA NA NA NA NA NA NA NA NA 20 20 ' l 30- 30 mg/kg=milligrams per kilogram(parts per million,ppm) EPHs=Extractable Petroleum Hydrocarbons PAHs=Polycyclic Aromatic Hydrocarbons _ Bold values exceed an applicable cleanup standard. . ND=Compound not detected at the laboratory reporting NR=Not Reported - Table I Sail Ar4tical Summery(Bomigs) Former Salem Suede 72 Flint Street Salem.Mmeadmeaes Som Ie ID: TB-1 TB-2 TB-3 T84 T245 TB-6 TB-] TB4 TB-9 TB-10 TB-11 --MCP Clemti Stdiidmd,' Dete Sem led: 515105 5/5/05 SSNS 15/5/OS1 5/51.5 515105 5/5105 5/5105 5/5105 5/5/05 515105 5/5N5 5/5/05 5/5/05 5/5/05 5/5/05 515105 5/5105 5/5/05 5/5/05 5/5/05 S-1 5-2 O O fini,t) 1 0-5 5-10 0.5 I 5-10 0-5 5.10 0.5 5-10 0.5 5-10 10.15 0-5 5.7 0.5 540 0.5 o-5 0-5 5-10 5-15 540 'GW-2 -.GW-3 GW-2 GW-3: BPH -DEP Method 041 CL Ali hetics NA NA NA NA 1100 NA NA 1100 NA NA <IN NA NA NA NA NA NA NA NA NA NA '1000`. I:OW '300 ,3 WO' _ C -C AV htice NA NA NA NA 679 NA NA 1100 NA NA 1100 NA NA NA NA NA NA NA NA NA NA -3000 30W SOOO 3000'. C C Ammietice -NA NA NA NA 512 NA NA 1100 NA NA 1100 NA NA NA NA NA 'NA NA NA NA NA -11000 . IOW 3000-`9000 PARS -EPA Methal 827K Acme hOme NA NA NA NA ND NA NA ND - NA NA ND 0.013 NA NA NA NA NA NA NA NA NA 1 N0 1.00 3,000 3.100 Aron h Ime NA NA NA NA NR NA NA NR NA NA NR N0. NA NA NA NA NA NA NA NA NA '6W 10: 600' 10 A,O,ecene NA NA NA NA 88 NA NA ND NA NA ND 0.25 NA NA NA NA NA NA- NA NA NA '.'1000 -1ON 3000 -3000- Bmz a Omen NA NA NA NA 2.69 NA NA 1.0 NA NA 05 ND NA NA NA NA NA NA NA NA NA 7 7 ;.qp 40 Benz a rens NA NA NA NA 1.57 NA NA 1.65 NA NA 3.6 0.02 NA NA NA NA NA NA NA NA NA v.'2 2 4 - g3.00O B bflunmOme NA NA NA NA 3.84 NA NA 136 NA NA 3.32 049 NA NA NA NA NA NA NA NA NA 'Z 5 -]' 400 B 4rne NA NA NA NA 1.84 NA NA 4fi2 NA NA 1.84 b.W] NA NA NA NA NA NA NA NA NA 1,000 h00. '300p Bmea k BmrmOene NA NA NA NA 2.91 NA NA 2.37 NA NA 4.92 0.006 NA NA NA NA NA NA NA NA NA ''7U IU 400.. C sem NA NA NA NA 3.68 NA NA 1.21 NA NA ND 0.081 NA NA NA NA NA NA NA NA NA 70 - 70r 400 Dibe=e.h mlhrmem NA NA NA NA 0.69 NA NA 2.W NA NA 0.66 ND NA NA NA NA NA NA NA NA NA U:7" 0.7- -4 Plaoranlhma NA NA NA NA 1.99 NA NA 14 NA NA 0,36 O.W2 NA NA NA NA NA NA NA NA NA J WO - I WO 3,000 Flmrem NA NA NA NA 047 NA NA ND NA NA ND 0022 NA NA NA NA NA NA NA NA NA .1000 .1000-. 3,000 IMam I SJ<d rme NA NA NA NA 0.313 NA NA 0.96 NA NA 0.30 ND NA NA NA NA NA NA NA NA NA '] ] .W N hNelene NA NA NA NA NO NA NA NO NA NA ND 0.02 NA NA NA Olfi NA NA NA NA NA 40 - 500. 40 PhrnmOuene NA NA NA NA 0.97 NA NA 1.27 NA NA NO, ND NA NA NA NA NA NA NA NA NA 500 - 500 ' IOW Pvrane NA NA NA NA 1.71 NA NA 0.94 NA NA ND 195 NA NA NA NA NA NA NA NA NA 1000 ]NO 3 000 2-MaNybuophthelew NA NA NA NA ND NA NA ND NA NA ND ND NA NA NA NA NA NA NA NA NA 80'. 300 90 5W Melela Aremic NA NA NA NA NA 19.9 122 NA NA 6.27 NA 28.8 NA NA NA NA NA NA NA NA NA .20 - 20 20 20' Codire. 09 0.02 M 0G1 336 032 1.46 NA 1.7 0.6 10.01 0.57 <O.01 2.6J 0]6 0.35 031 0.75 0.92 0.81 0.97 2 2. 30' 30 Chromium 10 152 959 1 17.4 11 2,113 1 1,935 2 9 NA 27.4 92.7 735 064 129 1989 241 674 74.4 518 099 4.6 2,467 30 ' 30. 200. 2W Lord123 23G 422 102 174 25.8 713 NA 292 154 146 152 804 135 482 310 121 134 143 13 186 '300 310 300 3W Mem NA NA NA NA NA 0.113 0.18(+ NA NA <0.02 NA 0.113 NA NA NA NA NA NA NA NA NA '20 20 30 JO mghg-millig per A logmm(mrb per mfl imM ppm) EPHs=EztmNO,l a Petroleum Hydrum PAH,=Pobryclic Ammalic HYdm.1Nm Bold velum ecc«d m applicable clomup naulord. ND-Compomd rot delected L the le motmy rom mg NR=Nat Reported . Table 3 • Groundwater Analytical Summary Former Salem Suede 72 Flint Street • Salem,Massachusetts • Sample ID: MW-1 MW-2 MW-3 MW-4 MW-5 MW-6 MCP'Cleanu Date Sampled: 5/5/05 5/5/05 5/5/05 5/5/05 5/5/05 5/5/05 . . - Standards GW-2 GW-3 • EP14(µg/1)-DEP Method 04.1 Cv-Cls Aliphatics NA NA <500 <500 NA NA 5,000" 50,000. • C19-C36 Aliphatics NA NA <2,000 <2,000 NA NA NA 50,000 CII-C22 Aromatics NA NA <100 1 2,550 NA NA -50,000 5,000 PAHs(µg/1)-EPA Method 8270C Acenaphthene NA NA <2 1 2,640 NA NA NE ' 6,000 -s • Acenaphthalene NA NA <2 <2 NA NA 10,000 a 40 • Anthracene NA NA <2 <2 NA NA NE, 30 Benzo(a)anthracene NA NA <2 13 NA NA NE ' 1,000 Benzo(a)pyrene NA NA <2 5 NA NA ;, NE. . 500=x;'' • Benzo(b)fluoranthene NA NA <2 <2 NA NA 'NE ,', 400".i:` • Benzo(g,h,i)perylene NA NA <2 6 NA NA NE 20 Benzo(k)fluoranthene NA NA <2 1 <2 NA NA ;NE ''- 100' Chrysene NA NA <2 6 NA NA �NE 70 • Dibenzo(a,h)anthracene NA NA <2 <2 NA NA NE: > >.40.0 • Fluoranthene NA NA <2 <2 NA NA Fluorene NA NA <2 <2 NA NA NE'- ",402 Indeno(1,2,3-cd)pyrene NA NA <2 <2 NA NA NE ` ' 100 .S • Naphthalene NA NA <2 <2 NA NA .1,00V .120,000`', • Phenanthrene NA NA <2 19 NA NA NE• 10,000 ' Pyrene NA NA <2 16 NA I NA NE, 20 2-Methy1naphthalene NA NA <2 <2 2,000 * 204000 Metals(pgll) Arsenic NA NA NA NA [KNANA NE. 900 ,.",p Cadmium 3.7 1.43 1.9 " NEChromium 66 92 117 517 NE300Lead <10 9.1 50 50 Mercury NA NA NA 0186 • µg/1 =micrograms per liter(parts per billion,ppb) EPHs=Extractable Petroleum Hydrocarbons PAHs=Polycyclic Aromatic Hydrocarbons • Bold values exceed an applicable cleanup standard. • ND=Compound not detected at the laboratory reporting • NR=Not Reported Health and Safety Plan • 72 Flint Street,Salem,NU APPENDIX A I � PLAN APPROVAL AGREEMENT The following individuals have reviewed the Site-specific HASP for the former Salem Suede facility at 72 Flint Street in Salem,MA. They are responsible for implementing and enforcing the procedures and items covered by this Plan. In addition, SP Inc. Manager, Occupational Health and Safety, must approve any revisions or alterations to this Plan before implementation. • Notify Bruce M. Poole, of any alterations or deviations from the procedures, requirements, etc., • listed in this Plan. (Return a signed copy of this document to SP Inc. Site Health& Safety Representative Date • Printed Name &Title Project Manager Date • Printed Name& Title Health and Safety Plan • 72 Flint Street,Salem,MA APPENDIX B Health and Safety Plan 72 Flint Street,Salem,MA COMPLIANCE AGREEMENTS All on-Site personnel, (i.e. Employees and Subcontractors), covered by this Plan shall complete and sign this section before the commencement of Site activities for the former Salem Suede facility at 72 Flint Street, in Salem, MA. (Return a signed copy of this document to SP Inc). I have read and understood the contents of this Site-specific Health and Safety Plan and have had • all relevant questions answered to my satisfaction. In addition, I agree to comply with the • conditions/provisions outlined herein. NAME (PRINT) SIGNATURE COMPANY DATE • • Health and Safety Plan • 72 Flint Street,Salem,NM • • • • • • • • • • • • s • APPENDIX C • • • • • • • • • • • • • • • • • • • • 310 CMR: DEPARTMENT OF ENVIRONMENTAL PROTECTION Aga NEG-5 • 7.08: continued j • (1) No person shall cause, suffer,allow,or permit the operation of any hazardous waste • incinerator unless said operation is in conformance with the following: 1. During start-up and shutdown,hazardous waste shall not be fed into the incinerator • unless the incinerator is operating within the conditions of operation as specified in the Department's approval;and • 2. Fugitive emissions from the combustion zone shall be controlled by: a. keeping the combustion zone totally sealed against fugitive emissions;or • - - b. maintaining a combustion zone pressure lower than atmospheric pressure;or c. an alternative means of fugitive emissions control equivalent to maintenance of combustion zone pressure lower than atmospheric pressure as approved by the • Department;and • 3. Each hazardous waste incinerator shall be equipped with a functioning system to automaticallycease operation ofthe incineratorwhen change(s)in waste feed,incinerator • design,or operating conditions exceed limits as designated in a Department approval. Each such systems,and each alarm associated therewith,shall be tested at least weekly • to verify operability;and • 4. At least once each day during which it is operated,each hazardous waste incinerator and associated equipment(e.g.pumps,valves;conveyors,and pipes)shall be subjected • to thorough visual inspection for leaks,spills,fugitive emissions,and signsoftampering; • and 5. All monitoring and inspection data shall be recorded and the records shall be placed • in the operating log required by 310 CMR 30.542. (m) No incinerator for the burning of polyhalogenated aromatic hydrocarbons shall be • constructed,substantially reconstructed,altered,or operated except in compliance with the • following requirements: 1. Polyhalogenated aromatic hydrocarbons maybe burned only after the Department has • expressly and in writing approved the burning of such material,and only to the extent and only while such approval is in effect. The application to the Department for such • approval shall expressly state that approval is sought to bum polyhalogenated aromatic hydrocarbons. • 2. The burning of polyhalogenated aromatic hydrocarbons shall achieve a destruction • and removal efficiency,as determined pursuant to 310 CMR 7.08(4)(h)l,of 99.9999% for each POHC,based on burning materials more difficult to bum than tetra-,penta-,and • hexachlo-rodibenzo-p-dioxin and dibenzofurans. • 7.09: U Dust,Odor,Construction,and Demolition _k (1) No person having control of any dust or odor generating operations such as,but not limited • to asphalt batching plants, asphalt roofing materials manufacturing plants, asphalt blowing plants,foundries,chemical products manufacturing plants,incinerators,fuel utilization facilities, • - petroleum products manufacturing plants,aggregate manufacturing plants,food preparation or • processing facilities, wood products plants, dry cleaning establishments, paint and varnish manufacturingplants, paper manufacturing plants, leather manufacturing plants, concrete • batching plants,metal coating and treating plants,land clearing operations,construction work, dump operations,agricultural operations and street sweeping shall permit emissions therefrom • which cause or contribute to a condition of air pollution. (2) No person responsible for any construction or demolition of an industrial,commercial,or • institutional building or residential building with 20 or more dwelling units,shall cause,suffer, allow,or permit emissions therefrom which cause or contribute to a condition of air pollution. • Said person shall notify the Department in writing ten working days prior to the initiation of said _ • construction or demolition operation.The ten working day advance notice period will be waived in the event of emergency demolition necessary to prevent a public health or safety hazard. • • • • 310 CMR: DEPARTMENT OF ENVIRONMENTAL PROTECTION • 7.09: continued • (3) No person responsible for an area where construction or demolition has taken place shall • - cause, suffer, allow, or permit particulate emissions therefrom to cause or contribute to a _ condition of air pollution by failure to seed,pave,cover,wet,or otherwise treat said area to • prevent excessive emissions of particulate matter. • (4) No person shall cause,suffer,allow,or permit the handling,transportation,or storage of any • material in a manner that results or may result in emissions therefrom which cause or contribute to a condition of air pollution. - (5) No persons responsible for any construction or demolition ofa structure that contains friable asbestos material shall fail to comply with 310 CMR 7.09(2) and 310 CMR 7.02. (National • Emission Standards for Hazardous Pollutants) , • .(6) No person shall cause,suffer,allow,or permit the operation of mechanized street sweeping • equipment that is not equipped with a suitable dust collection or dust suppression system which is maintained in good operating condition and is operated continuouslywhile the street sweeping • equipment is in use to prevent conditions of air pollution. • (7) 310 CMR 7.09(1)through 7.09(4)and 7.09(6)are subject to the enforcement provisions • specified in 310 CMR 7.52. . 7.10: U Noise • (1) No person owning,leasing,or controlling a source of sound shall willfully,negligently,or • through failure to provide necessary equipment,service,or maintenance or to take necessary precautions cause,suffer,allow,or permit unnecessary emissions from said source of sound that • may cause noise. • (2) 310 CMR 7.10(1) shall pertain to, but shall not be limited to, prolonged unattended • sounding ofburglar alarms,construction anddemolition equipmentwhich characteristically emit sound but which maybe fitted andaccommodated with equipment such as enclosures to suppress • sound or may be operated in a manner so as to suppress sound,suppressible and preventable industrial and commercial sources of sound,and other man-made sounds that cause noise. • - (3) 310 CMR 7.10(1)shall not apply to sounds emitted during and associated with: • - (a) parades, public gatherings, or sporting events, for which permits have been issued • provided that said parades,public gatherings,or sporting events in one city or town do not cause noise in another city or town; • (b) emergency police,fire,and ambulance vehicles; (c) police,fire,and civil and national defense activities; • - (d) domestic equipment such as lawn mowers and power saws between the hours of 7:00 - • A.M.and 9:00 P.M. • (4) 310 CMR 7.10(1)is subject to the enforcement provisions specified in 310 CMR 7.52. • 7.11: U Transportation Media • (1) Motor Vehicles. • (a) All motor vehicles registered in the Commonwealth shall comply with pertinent regulations of the Registry of Motor Vehicles relative to exhaust and sound emissions. . (b) No person shall cause,suffer,allow,or permit the unnecessary operation of the engine _ • of a motor vehicle while said vehicle is stopped for a foreseeable period of time in excess of five minutes. 310 CMR 17.11 shall not apply to: • 1. vehicles being serviced, provided that operation of the engine is essential to the • proper repair thereof,or • • • - MassDEP • tz -„`-chi —�cp�r.: enc t -nv�r•_nm ,tafPr�trc �_�. • • Particle Pollution and Air Quality • '�, • Particle pollution(also known as"particulate matter"or PM)includes a mixture of solids and liquid droplets.Some particles are emitted • directly;others are formed in the atmosphere when other pollutants react.Particles come in a wide range of sizes. • Fine Particles(PM2.5).Particles up to 2.5 microns in diameter are called"fine"particles.These particles are so small they can • be detected only with an electron microscope.All sources of fuel combustion,including power plants,cars,buses,trucks and • wood burning,as well as some industrial processes,generate fine particles.Because of their miniscule size,these particles can penetrate deeply into the lungs and accumulate in the respiratory system.Large concentrations of fine particles can be seen as • haze. • • vxz52006.anss06l5.t39Trrl• Coarse Particles(PM10).Particles between 2.5 and 10 microns in diameter are referred to as roar "coarse."These come from a variety of sources,including natural wind erosion of soil and •. UST 0% airborne residue from commercial and industrial operations.Individual particles cannot be • �o seen with the naked eye,but collectively can (fmaas,Co� y , y appear as haze,dust or soot. ROA so-r • 37% Particle pollution can be bad at any time or location,but especially: AREA• / 63% !J� When the weather is calm,allowing pollution to buildup. • Q 4% 4% • OFF-ROAD� Around factories,during rush hour and near busy roads. a% • When there is smoke in the air from wood stoves,fireplaces,forest fres or burning vegetation Health Effects of Particle Pollution & Who is Most at Risk aExposure to particle pollution can affect both your lungs and your heart.Health research suggests that short-term exposure to coarse • particles can lead to coughing,minor throat irritation and reduced lung function,while long-term exposure may increase the rate of respiratory and cardiovascular illness.A large number of scientific studies have definitively linked fine particles with a number of • significant health problems,including: _ • • Asthma and chronic bronchitis • • • Acute respiratory symptoms,such as coughing and chest tightness • • Decreased lung function,experienced as shortness of breath • Heart attacks • - • Premature death in people with heart or lung disease • These conditions contribute to work and school absences,emergency room visits,and hospital admissions.Long-term exposure can • make existing conditions worse and even reduce life expectancy. • The following"sensitive groups"are particularly susceptible to health problems when fine particle levels are high: • Children,because their lungs are still developing • • Elderly,particularly those with or prone to cardiovascular disease • • People with asthma or other respiratory ailments Otherwise healthy adults who exert themselves during periods of elevated fine particle concentrations also may be affected because the' tend to breathe more while working or exercising. • • Environmental Effects of Particle Pollution • Vast quantities of coarse and fine particles can produce haze that can impair outdoor visibility,reducing visual range by as much as 70 percent from natural conditions.Airborne particles and droplets also tend to remain suspended in the air for extended periods of time and • can travel long distances. When they eventually settle to the surface,they can damage property,acidify lakes and streams,and harm • plants and animals. Particle Pollution Standards There are currently two sets of National Ambient Air Quality Standards(NAAQS)for particle pollution: one for coarse particles(PM10) and the other for fine particles(PM2.5). •• The health-based primary standard for PMl0 is 150 micrograms per cubic meter(ug/m_)averaged over a 24-hour period.The primary standards for PM2.5 are 15 ug/m_averaged over an entire year and 35 ug/m_averaged over a 24-hour period. For both pollutants,the secondary standards for protection of crops,vegetation and buildings are the same as the primary standards Long-Term Particle Pollution Trends • Since the 1960s,MassDEP has been monitoring ambient air quality for a variety of pollutants,including coarse particles,with a network • of monitors across Massachusetts.The agency began measuring fine particle concentrations in 1999.Based on recent advances in • monitoring technology,the agency now issues a daily fine particle forecast for various regions in Massachusetts. • As the charts below demonstrate,PMI0 pollution tends to fluctuate from year to year and site to site,but has shown an overall decline in • Massachusetts over the years.On the other hand,PM2.5 pollution occasionally approaches levels of concern,particularly in urban and high-traffic commercial areas,and can pose health risks for sensitive populations,particularly people with asthma. • • PMro Trends 1989-2007 Annual Arithmetic Mean • 4]D,';- 30A 0 g �. 20 [ .� d ®�M-a �=`~+'�-Q .�. .:..� � r,�.zs a ,0'.:•., r,�..` 10 • 89. 90. 91 92 93 94 95 96 97 98 99 CO 01 02 03 04 05 06 07 • ti...•-..BOSTt]t' C ty Sq) -.■:._ BMTOtAColunbus Ave) ♦- SWTONKenrrare Sq) • BOSTOht(Southhaffoon St) 8WTMKPI2 i*en Ave) a 40 , • 30 _. 10 • 89 9D 91 92 93 94 95 96 97 96 99 00 01 02 03 04 05 08 07 .._.�—SPAGtti0(EC01unI=Ave) -.rA-:SPRGPLO(1rlain St) SPROPLO(Howara Sl) WO MTER .h-.0 WARE.- - Data gathered from the state monitoring network in recent years have indicated that Massachusettse meets National Ambient Air Qualit Standards(NAAQS)for both coarse and fine particles. - • • • • • D • OCUMENTATION • • OF THE • THRESHOLD LIMIT VALUES • FOURTH EDITION • • • • • • • • AMERICAN CoAml Fy CONFERENCE • .fie OF • ofGOVERNMEN�p` GOVERNMENTAL y y INDUSTRIAL • aG�rR�al N�G`��` HYGIENISTS INC. • CINCINNATI, OHIO • • • NUISANCE PARTICULATES 3. The tissue reaction is potentially reversible. • TLV,10 mg/m3 or 30 mppcf-Total Dust < 1% quartz Excessive concentrations of nuisance dusts in the work- room air may seriously reduce visibility, may cause un- 15 mg/m3—Respirable Dust pleasant deposits in the eyes,ears and nasal passages (Port- land Cement dust), or cause injury to the skin of mucous • In contrast to fibrogenic dusts which cause scar tissue membranes by chemical or mechanical action per se or by to be formed in lungs when inhaled in excessive the rigorous skin cleansing procedures necessary for their • amounts, so-called "nuisance" dusts have a long history removal. • of little adverse effect on lungs and do not produce sig- Total dust as described in this limit include the air-sus- nificant organic disease or toxic effect when exposures pended particles greater than respirable diameter.A TLV of • are kept under reasonable .control. The nuisance dusts 10 mg/m3, or 30 mppcf,of total dust >1% quartz is recom- have also been called (biologically) "inert" dusts, but the mended for substances in this catagory. If particles of res- latter term is inapprpriate to the extent that there is no pirable diameter only are present or collected, a TLV of 5 dust which does not evoke some cellular response in the mg/m3 must be used. These limits, for a normal workday, lung when inhaled in sufficient amount. However, the do not apply to brief exposures at higher concentrations. • lung-tissue reaction. caused by inhalation of nuisance Neither do these limits apply to those substances which dusts has the following characteristics. may cause physiologic impairment at lower Concentra- • 1. The architecture of the air spaces remains intact. tions, and for which threshold limits have not yet been • 2. Collagen (scar tissue) is not formed to asignificant recommended. . extent. - • . PORTLAND CEMENT ed in mining, quarrying or crushing silica-containing raw materials. • - Containing <I%quartz The TLV for Portland cement has been set at 30 mppcf, • - TLV,30 mppcf that of an inert dust, based on these studies. • - Portland cement refers to a class of hydraulic cements References: • which are odorless,gray powders with less than 1%crystal- 1. Miller,f.W.,Sayers,R.R.: Pub. Health Repts. 56:264 (1941). • line silica. The two essential constituents of Portland ce- 2. Thompson,L.R.,Brundage,D.K.,Russell,A.E.,Bloomfield,I.).: ment are tricalcium silicate(3Ca0•5i02)and dicalcium sili- Pub. Health Bull. #176,U.S. Pub. Health Service (1928). • tate (200•SiOz) with varying amounts of alumina, 3. Russell,A.E.:Am.J.Med. Sci. 765:330(1933). • ,. tricalcium aluminate and iron oxide. The vapor pressure is 4. Gardner,L.U.,Durkan,T.M.,Brumfiel,D.M.,Sampson,H.L:I. approximately 0 mm Hg at 20°C and are insoluble in water. Ind. Hyg. & Tox.11:279(1939). • Miller and Sayers(') described an absorptive reaction S. Vaccarezza, R.A.: Buenos Aires, Ed. Guillermo Kraft Ltd. when cement dust was introduced intraperitoneally in (1950).Quoted by Sander in ref.9. • guinea pigs. 6. Parmeggiani,L: Rass. Med. Ind.20.400(Turin) (1951). • Gardner et a/(3) found no pneumoconiosis.due to expo- 7. Guiliani,V.,Belli,R.:Med.d. Lavoro 46:715(1955).Abstr. Bull. sure to finished Portland cement in 17 cement plants with Hyg.31:544 (1956). • 2,278 workers, despite heavy and prolonged exposures. 8. Prosperi,G.,Barsi,C.: Rass.Med. Ind. 1:16(Turin) (1957). This has been confirmed by other studies.(2s.7,9,30) Conflict- 9. Sander,O.A.:Arch. Ind. Health 17:96(1958). ing reports(6,8)appear related to exposures having occur- 10. Bloomfield,I.1•: Personal communication quoted in ref.9. • • • • • •'t • • • • • HYDROGEN SULFIDE spiratory irritant. It is reported that pulmonary edeme and • - H25 bronchial pneumonia may follow prolonged exposure at concentrations of the order of 250-600 ppm.(;) At low con- TLV,10 ppm (- 14 mg/m3) centrations the effects on the eye predominate, with con- junctivitis the most common effect, while keratitis fre- quently occurs.(4s) Poda,l61 however, in summarizing the • effects of 174 exposures to HZS in a heavy water plant,stat- Hydrogen sulfide is a colorless gas with an offensive ed that eye irritation was relatively uncommon.More com- odor suggesting rotten eggs. It has a molecular weight of mon findings were nervousness, cough, nausea, headache • 34.08 and a density of 1.19 (air=7.00). It boils at -60.2°C and insomnia. The reported LCs , one hour inhalation ex- and freezes at -83.81C. Hydrogen sulfide is flammable posure, for rats was 713 ppm and 673 ppm for mice(7) with explosive limits by volume in air of 4.3 and 46%. At - The concentrations at which eye effects occur have • 0°C, 437 cc of HZS will dissolve in 100 mL of water, at been variously reported as 100 ppm;81 30 ppm19,101 20 40°C, 180 cc. ppm,nll 13 ppm;lZ) above 10 ppm;13) 10 ppm, or even 5 • Hydrogen.sulfide has been widely employed as a reag- ppm1141 4-15 ppm.11sl ent in analytical chemistry, and is used in the manufactur In view of the fact that five different sources reported •- of heavy water. It is a source of elemental sulfur. The ma- eye effects at 20 ppm or below, a TLV less than this level • -jority of occupational exposures to HZS, however, have re- would seem to be indicated. In addition,the experience of sulted from its occurrence in petroleum, natural gas, soil, three members of the TLV Committee (*) tends to confirm • sewer gas,and as a byproduct of chemical reactions, such .the reports that conjunctivitis may result from exposures at • as may takeplace in the viscose rayon and certain leather 20 ppm. The limit of 10 ppm corresponds to the working -tanning processes. level of 10 ppm used in a heavy water plant, according to • In high concentrations(500-1000 ppm) hydrogen sulfide Poda.t7t • acts primarily as a systemic poison, causing uncon- In its criteria documentl16l NIOSH quoted two addition- sciousness and death through respiratory paralysis.111 A al references117,181 in which eye effects from HZS at concen- . case of polyneuritis and encephalopathy from one day's trations of 20 ppm or less were reported..It also comment- exposure to a concentration-insufficient to cause loss of ed that exposure at low concentrations for a few hours has • consciousness has been reported.(2) In lower concentra- been associated with headache, sleep disturbances,-nau- • tions (50-500ppm) hydrogen sulfide acts primarily as a re- sea, weight loss and other signs and symptoms suggestive • of possible brain damage, as well as corneal injury. The 8. Deveze,G.A.: Rev.Med.Miniere 414(1956).Abstr. in gull.of • NIOSH recommendation of a ten minute ceiling of 10 ppm Hyg.32:677 (1957). for hydrogen sulfide is based on these subacute effects as 9. Mayers,M.R.: Personal communication, N.Y. Dept. of Labor, • well as acute eye irritation. NY(1937). • It is.recommended that the 10 ppm TLV be retained as a 10. Barthelemy,H.L.:1. Ind. Hyg. & Tox.21:141 (1939). time-weighted average; in addition,'a short term exposure 11. Brieger, Dr. H.: Private communication quoting French au- limit (STEL) of 15 ppm is proposed thorities in the viscose industry (1964). Other recommendations: Cook (1945) and Smyth (1956) 12. Kranenbur& W.R.H., Kessener, H.: Zen(. Gewerbehyg. Un- 20 ppm; Elkins (1959). 10 ppm; USSR (1967) and Czechoslo- fallverhut. 2:348 (1935); quoted in Pub. Health Rep. Reprint- . , vakia (1969) 7 ppm;-ANSI (1966) 10 ppm; East.Germany #2256,Nail. Inst. Health,Washington, DC (1941). (1973),West Germany (1974) and Sweden (1975) 10 ppm. 13. Am. Ind. Hyg. Assoc.: Hygienic Guide Series-Hydrogen Sul- *Elkins, Grabois, Mastromatteo. fide(revised 1962). • References: 14. Elkins,H.B.: Chemistry of Industrial Toxicology,p.232,Wiley & Sons, NY (1950). • 1. Milby,T.H.: J. Occup..Med.4:431 (1962). 15. Masure, E.: Rev. Belg. Path.2Q297 (1950); quoted in Carson, 2. Zeyer, H.G.: Arch. Gewerbepath. u. Gewerbehyg. 13: M.B.: Ind.Med. &Surg.32:63 (1963). • 687 (1955). 16. NIOSH: Criteria for a Recommended Standard-Occupational. 3. Patty, E.A.: Industrial H Exposure to Hydrogen Sulfide, DHEW(NIOSH) Pub. No. 77- Vol. Hygiene & Toxicology, 2nd ed., 158(1977). • Vol..l 1, P. 898, Interscience,NY (1963). 17. Nesswetha, W.: Arbeitsmed. Sozialmed. Arbeitshyg. 4:288 . 4. Beasley, R.W.R.: Brit.). Ind. Med. 20.32 (1963). (1969). Cited in ref.15. . 5. Carson, M.B.: Ind. Med. &Surg. 32:63 (1963). 18. Hays, E.L.: Studies of the Effects of Atmospheric Hydrogen . 6. Poda, G.A.: Arch. Env. Health 12:795 (1966). - Sulfide in Animals, thesis. Columbia, University of Missouri 7. Merck Index, 9th ed., p. 633, Merck & Co., Inc., Rahway, NI Graduate School (1972). Ibid. • (1976). • • • • • • • • NAPHTHALENE a • - GoHa 6 . TLV,10 ppm ( 50 mg/m3) • STEL,15 ppm ( z 75 mg/m3) • Naphthalene occurs commonly as white, crystalline Hyatt and Milligan.(9) Robbins not however, reported that • flakes which have a strong coal tar odor. It has a molecular concentrations in excess of about 15 ppm resulted notice- weight of 128.16 and a specific gravity of 1.145. It melts at able irritation of the eyes. • 80.2°C,boils at 21756°C and has a vapor pressure at 25°C Gerardentl also suggested 25 ppm as a tentative limit, • of approximately 0.087 mm Hg.'The open cup flash point is noting that it represents 25% of the concentration of na- 176°F and closed cup is 190°F. Insoluble in water, it dis- phthalene vapor in air saturated at 25° C. . solves in most organic solvents. In view of thefact that irritation is experienced at 15 • Crystalline naphthalene finds household use as a month ppm and that continued exposure may result in fairly seri- repellent, scientific use in scintillation counters. It is an ous eye effects, a limit lower than 25 ppm would seem in . important raw material for the manufacture of phthalic order. The value of 10 ppm TLV and 15 ppm STEL are rec- anhydride, naphthol, hydrongenated naphthalenes and ommended to prevent ocular effects, but possibly not • halogenated naphthalenes; it or its derivatives are em- blood changes in hypersusceptibles. ployed in dyes, explosives, lubricants, tanning agents and emulsion breakers. - Other recommendations: Wes[ Germany, 10 ppm; East • Germany and USSR, 4 ppm. According to Flury and Zernikm and Patty;2l the inhala- tion of naphthalene vapor may cause headache, loss of ap- petite and nausea. Optical neuritisand injuries to the cor- References: nea and, in addition, kidney damage have also been 1. Flury,F.,Zernik,F.:Schadliche Gase,p.290,1.Springer,Berlin • reported. Ghetti and Marianiol reported opacities of the (1931). lens in 8 of 21 workers who had been exposed to naphthal- 2. Patty, F.A.: Industrial Hygiene & Toxicology, Vol. II, p. 770, • ene for about five years. Ingestion of naphthalene inrela- Interscience, NY(1949). • tively large amounts has reportedly caused severe hemo- 3. Ghetti,G.,Mariani,L.: Med. d. Lavoro 47:533 (1956). lytic anemia and hemoglobinuria.(4) A hypersusceptibility, 4. Zuelzer,W.W.,Apt,U 1.A.M.A. 141:185 (1949). • probably genetically based, is recognized.(5) S. Stokinger,H.E.,Mountain,J.T.:Arch. Env.Health 6:495(1963). • The oral LD50 for rats is 1760 mg/kg.(6) It was used as an 6. NIOSH: Registry of Toxic Effects of Chemical Substances anthelmintic for many years at dose levels, for adults,of 0.1 (1977). • to 0.5 gram three times a day,vl several times higher than -7. Am. Ind. Hyg. Assoc.: Hygienic Guide Series-Naphthalene the lowest reported lethal dose for man of 50 mg/kg.(6( An (1%7). • incident in which blankets containing naphthalene caused & Values,T.,Doxiadis,S.A.,Fassas,P.:J. Ped.63:904(1963). Cit- acute hemolytic effects in infants, in some cases fatal, has ed in ref.7: - been described.(a( 9. Hatt,-E.C., Milligan, M.F.: Am. Ind. Y 8 Hyg. Assoc. Q. 14:289 • Patty suggested 25 ppm as a tentative limit for naphthal- (1953). • ene vapor.in air. He noted that this corresponds to a satura- 10. Robbins,M.C.: Arch. Ind. Hyg. &Occup. Med.4:85 (1951). tion pressure of approximately 25% at 25°C.This value has 11, Gerarde, H.W.: Toxicology& Biochemistry of Aromatic Hy- been used at the Los Alamos Laboratories, according to drocarbons, p.230, Elsevier Pub.Co.,NY(1960). • BENZENE • C6H6 - specific gravity of 0.87865 at the same temperature. Ben- • zene has a flash point of-11.1°C(closed cup, 12°F), mak- TLV,10 ppm ( z 30 mg/m3),Appendix A2— Suspected ing it a dangerous fire hazard. It was formerly derived al- Carcinogen most exclusively by distillation of coal tar, but now comes primarily from petroleum, either by extruction or by dealk- ylation of toluene. Benzene is slightly soluble in water, but • soluble in all proportions in alcohol,acetone and ether. . • Benzene is a colorless, non-polar liquid, with an odor At one time benzene was an important solvent, espe- characteristic of aromatic hydrocarbons. It has a molecular cially for rubber,as a diluent in lacquers,and in painYrem- • .weight of 78.17, a boiling point of 80.1'C, a melting point overs. At present such uses are minimal; most benzene is • of 5.5°C. a vapor pressure of 75 mm Hg at 20°C and a consumed in the chemical industry, as a raw material for • 37 • • 8. Guides for the Evaluation.of Hearing Impairment. Trans- 15. Some Damage Risk Criteria for Exposure to Sound. Draft of • actions of the Am. Acad. of Ophthalm. and Otoloryngol. Technical Report, CHABA Working Group, St. Louis, MO • (1%4). (1956). 9G9ides to the Evaluation of Permanent Impairment - Ear, 16. Baughn, W.L.: Relation Between Daily Noise Exposure and Nose, Throat and Related Structures. )AMA 777:489-501 Hearing doss,Aerospace Medical Research Lab.AMRL-TR-73- • (1961). 53 (June 1973). - . 10. Suter, A.H.: The Ability of Mildy Hearing-Impaired Individ- 17. Burns,W.and D.W.Robinson: Hearing and Noise in Industry. uals to Discriminate Speech in Noise. EPA 550/9-78-100 Her Majesty's Stationery Office (H.M.5.O.) (1970). • (1978). 18. Yerg,R.A.,J.Sataloff,A.Glorig and H.Menduke: Inter-Indus- 11. American Standards Assoc.: The Relations of Hearing Loss to try Noise Study.). Occ. Med. 20(5) (1978). Noise Exposure.Z24-X-2 Committee Report,New York(1954). 19. Berger,E.H.,L.H.Royster and W.G.Thomas:Presumed Noise- 12. Guide for.Conservation of Hearing in Noise. rev. Rochester, Induced Permanent Threshold Shift Resulting from an Expo- MN, Am Acad.of Ophthalm. and Otolaryngol. (1964). sure to an A-Weighted Leq.of 89 dB.J.Acoust.Soc.Am.64(7) • 13. International Organization for Standardization: Draft Propos- (July 1978). • al for Noise Rating Numbers with Respect to Conservation of 20. Guide for the Evaluation of Hearing Handicap. Otolaryngol. Hearing. Speech Communication and Annoyance, Helsinki Head Neck Surg.87:539-551 (July-August 1979). 14. Kryter, K.D.: Exposure to Steady-State Noise and Impairment • of Hearing.). Acoust.Soc. Am. 35(757) (1963). • IMPULSIVE OR IMPACT NOISE Documentation for Impulsive or Impact Noise The Threshold Limit Value for impulsive noise refers to a • It is recommended that exposure to impulsive or impact discrete noise (or a series of such noises) of short duration noise shall not exceed the limits listed in Table 8 or taken (less than a second), in which the sound pressure level •� from Figure 7. No exposures in excess of 140 decibels peak rises very rapidly (less than 500 ms, sometimes less than 1 • sound pressure level are permitted. Impulsive or impact ms) to a high peak level before decaying to a level below noise is considered to be those variations in noise levels the level of background noise. The decay is frequently os- that involve maxima at intervals of greater than one per cillating because of sound reflection and reverberation in second. Where the intervals are less than one second, it which case the spectrum of the oscillation may also be • should be considered continuous. important in determining the hazard to hearing. Some au- TABLE 8 thors distinguish reverberant impulse as impact noise(typi- Threshold Limit Values cally produced by metal to metal impact as in industrial l Impulsive or Impact Noise forging),to distinguish it from simple oligophasic impulses + Permitted Number (typified by gunshot in the open at Sound Level of Impulses or Impulsive (impuse and/or impact) noise can produce • dB' Impacts per day temporary (TTS) and permanent threshold shift (PTS) . 140 100 which resembles that produced by continuous noise. Im- 130 1000 pulsive noise (like continuous noise) can produce patho- • 120 10,000 _ logical changes in the inner ear (cochlea) of mammals, no- 'Decibels peak sound pressure level, re 20 Pa. tably degeneration and destruction of the hair cells. A quantitative relationship between the amount of visible • damage to the cochlea and the amount of PTS has not yet been established.(') • The following parameters can be used to characterize • ..o - impulsive noise: • 1. Peak SPL (in dB re 20µPa [0.00002 N/m21) • W 2. Effective duration (milliseconds) 3. Rise time(milliseconds) cno Other factors which may effect injury are: • a 1. Number of repeated impulses in a daily exposure. 2. Simultaneous exposure to continuous noise at TTS- producing levels. . ° 3. Intervals or average interval between impulses. • :o 4. Action of acoustic reflex. 5. Individual susceptibility. i • loo row igow NUMBER OF IMPULSES OR IMPACTS PERDAY(N) Based on TTS data from rifle shooters, Kryter and Garin- Figure 7-Threshold Limit Values for Impulse/impact Noise. ther(3) estimated permanent hearing levels expected to re- 470 • • • suit from daily exposure to a nominal one-hundred rounds duration B impulses and may be too conservative for A • of rifle shooting noise in 10% of those exposed to be as impulses. This has been done because of the difficulty in follows: measuring duration which require oscillographic tech- niques and is difficult to perform at the work site. Audiometric Test At the present time the Committee has established a • Frequency Permanent Hearing Level TLV for continuous noise and a TLV for impulsive noise. Hz dB re ASA: 1951 The Committee has reviewed various methods of evaluat- 1000 0 ing the hazard of exposure to both simultaneously and • 2000 5 - have not found one which appears satisfactory. 3000 10 Some studies have shown that the effects of combined • 4000 30 6000 q5 impulsive and continuous noise are additive.(9)Other stud- 6000 have shown that rapidly repeated impulses(8)and simul- Hazard increases with the effective duration of impulses.(4) taneously continuous noise(10) in some cases provide up to Impulse duration is defined according to the type of im- 10 dB of protection. • pulse (A, simple peak, or B, oscillatory decay).(5) For effec- tive durations much above 1 ms, a more stringent limit References: should be applied to reverberant oscillations (e.g., metallic 1. Poche, L.B.,C.W.Stockwell and H.W.Ades: Cochlear Hair- impact in industry) than to simple A-type.impulses. When Cell Damage in Guinea Pigs after Exposure to Impulsive the type of impulse cannot be determined, it is conserva- Noise. d Acoust. Sac.Am. 46:947-951 (1969). • - tive to assume the B-duration. In 1968(6) CHABA gave a 2. Guignard,f.C.:A Basis for Limiting Noise Exposure for Hear- gross estimate of safe.limits of exposure for A or simple ing Conservation.Aerospace Med. Res. Lab.,Wright-Patter- peak—152 d6 and for longer duration B -138 dB. son AFB,OH,AMRL-TR-73-90(1973). • TTS.(and, by inference PTS) increases linearly with the 3. Kryter,K.D. and G.Garinther: Auditory Effects of Acoustic • number of impulses in a series, or linearly with time when Impulses from Firearms.Acta Otolarying.,SuppL 211,Stock- the rate of impulses is constant,(7) CHABA(6) recommended holm (1965). • an allowance of-5 dB for every tenfold increases in.num- 4. Loeb,M.and I.L.Fletcher:Impulse Duration and Temporary ber of impulses in a daily exposure. Coles and Rise(8) con- Threshold Shift.J.Acoust. Sac.Am.44:1524-1528(1968). . tend that this rule is underprotective for large numbers of S. Coles, R.H.A., G.R. Garinther, D.C. Hodge and C.G. Rice: impulses. The equal energy rule (10 d6 weighting for each. Hazardous Exposure to Impulsive Noise, Ibid. 43:336-343 tenfold increase in N) appears to fit the existing data toler- ably well and is easy to apply in practice,but may underes- 6. Ward,W.D. et al: Proposed Damage-Risk Criterion for Im- timate the hazard for numbers of impulses substantially pulsive Noise (Gunfire). Report of Working Group 57,+ NAS- NRC Committee on Hearing,Bioacoustics and Bio-Mechan- less than 100 (isolated impulses). ics CHABA (1968). Considering the above data the TLV for impulsive noise 7. Ward, W.D., W.-Selters and A. Glorig: Explanatory Studies has been recommended as shown in the table below: on Temporary Threshold Shift from Impulses.J.Acoust.Sac. S - - Am.33:781-793 (1%1). • Peak Sound Pressure Level Permitted Number of 8. Coles, R.R.A. and C.G. Rice: Assessment of Risk of Hearing dB re 20 Pa Impulses per day Loss Due to Impulse Noise.Occupational Hearing Loss,pp. . 140 100.or less - 71-77, D.W. Robinson,Ed.,Academic Press, London & New 130 1000 York (1971). • 120 10,000 9. -Okada, A., K. Fukada and K. Yamamura: Growth and Re- covery of Temporary Threshold Shift at 4 kHz Due to a • No exposure in excess of 140 dB peak sound pressure level Steady Slate Noise and Impulse Noises. Int. z Angew. Phy siol. 30105-111 (1972). are permitted. 10. Cohen, A., B. Kylin and P.J. LaBenz: Temporary Thresholc • Peak sound pressure levels can be measured with readi- Shifts in Hearing from Exposure to Combined Impact, • ly available peak reading sound level meters. The limits .Steady-State Noise Conditions.1.Acoust. Sac. Am.401371 have been established to provide protection from longer 1379 (1966). • NOISE ity to hear and understand normal speech. Prior to 1979, • the medical profession had defined hearing impairment as These Threshold Limit Values (TLVs) refer to sound pres- an average hearing threshold level in excess of 25 decibels • sure levels and durationsof exposure that represent condi- (ANSI-S3.6-1%9) at 500, 1000 and 2000 Hz and the limits tions under which it is believed that nearly all workers may which are given have been established to prevent a hear- be repeatedly exposed without adverse effect on their abil- ing loss in excess of this.levelTA)The values should be used • 466 • • • • • • as guides in the control of noise exposure and,due to indi- tion of hearing. In occupational health,the term "noise" is vidual susceptibility, should not be regarded as fine lines used to denote unwanted sound. Noise induced loss of . between safe and dangerous levels. - hearing has been recognized and reported for several hun- • It should be recognized that the application of the TLV dred years. However, prior to about 1950 reliable dose-ef- for noise will not protect all workers from the adverse ef- fect data were not available. Before World War II, due to • fects of noise exposure. A hearing conservation program lack of uniformity in instrumentation and related units and • with audiometric testing is necessary when workers are ex- scales,studies from various parts of the world often yielded posed to noise at or above the TLV levels. a significant difference in result. Present day American and • European standardsM relating to the instrumentation and Continuous or Intermittent - methodology of both noise and hearing acuity measure- The sound level shall be determined by a sound level ment are now in reasonable accord. Unfortunately, the in- meter, conforming as a minimum to the requirements of terpretation of results from hearing testing—pure tone au- • the American National Standard Specification for Sound diometric testing. — in terms of degree of hearing . Level Meters, S1.4 (1971) Type 52A, and set to use the A- impairment, remains the subject of controversy. This dis- weighted network with slow meter response. Duration of agreement plus the fact that results from long term (>30 • exposure shall not exceed that shown in Table 7. years) prospective studies employing the modern stan- . These values apply to total duration of exposure per dards, techniques, and units, are not yet available, have working day regardless of whether this is one continuous presented difficulties in the formulation of acceptable exposure or a number of short-term exposures but does criteria particularly in the case of long term exposure . not apply to impact or impulsive type of noise. groups. Before 1950, overall sound pressure levels, in decibels, . When the daily noise exposure is composed of two or were used to define the noise aspect of damage risk crite- more periods of noise exposure of.different levels, their ria!zt Following recognition that the overall intensity of a . combined effect should be considered, rather than thein- noise, by itself,was not sufficient to describe the potential • inal effect of each. If the sum of the following frac- tions: for damage,and that the frequency characteristic must also [ions: be considered, subsequent criteria incorporating spectral iC, C C, levels—usually octave band levels—,were then developed. 7i +_ .TZ + Tn Many of these are summarizedin the NIOSH Criteria Doc- ument tat An octave band analysis is a relatively lengthy exceeds unity,then,the mixed exposure should be consid- procedure requiring expensive instrumentation, and there ered to exceed the threshold limit value, C, indicates the was some concern that the layman had difficulty in inter- total duration of exposure at a specific noise level, and T, preting the results. Recognizing the desirability of a single indicates the total duration of exposure permitted at that- reading - single number, the Intersociety Committee in level. All on-the-job joise exposures of 80 dBA or greater 1%7 proposed the use of A-weighted sound levels in the shall be used in the above calculations. development of criteria!<t The A-weighted characteristic of a sound level meter is designed to approximate the fre- Documentation for Noise _ quency selective response of the human ear at moderate intensities. In one report. Botsford demonstrated that A- Airborne sound can be described as propagated fluctua- weighted levels are as reliable as octave band levels in the . tions in atmospheric pressure capable of causing the sensa- prediction of effects on hearing in 80%of the occupational • noises considered,and slightly more conservative in 16%of the cases.t5t Passchier-Vermeertbt and Cohen et aUtl Simi- TABLE 7 larly demonstrated that A-weighted levels provide a rea- Threshold Limit Values sonable estimate of the hazard to hearing in most industri- Duration per day Sound Level . al environments. The abbreviation dBA is used to denote • Hours dBA(b) decibels A-weighted and can be described as a unit of 16 80 measurement of sound level corrected to the A-Weightec . - 8 85 scale as defined in ANSI S1.4 1971. Today A-weightec 4 90 sound levels are in general use in hearing risk criteria. • 2 95 Permanent noise induced hearing loss is related to the • 1 100 1/2 105 intensity and frequency distribution of the noise, the time 1/4 110 pattern and duration of exposure,and individual suscep[i • 1/8 115• bility. The ability to hear and understand everyday speed • under normal conditions is regarded as the most importan No exposure to continuous or intermittentin excess of 114 function of the hearing mechanism.Thus most present-da, • dBA studies focus on the resultant or predicted hearing loss ii • a In 1979, the American Academy of Ophthalmology and Oto- the speech frequency range. laryngology (AAOO) included 3000 Hz in their hearing im- Audiometric testing is carried out to determine a.. • pairment formula.tZnl individual's hearing threshold for pure tones. In this [est b Sound level in decibels as measured on a sound level meter, -ing, a series of tones are presented to the subject throug • conforming as a minimum to the requirements of the Ameri- earphones.. Each ear is tested in turn. The test tones not can National.Standard Specification for Sound Level Meters,• 51.4 (1971) Type S2A,and set to use the A-weighted network malty used are 500,1,000,2,000,3,000,4,000,6,000 and 8,OC with slow meter response. hertz(Hz). The intensity of each tone is adjusted until th 4f • subject indicates that he can just hear the signal. The band noise. Permissible temporary threshold shift (TTS) + threshold of hearing for each tone, in decibels, is then rec- was considered, and a series of curves based on the aver- • orded. The amount in decibels by which the subject's age level of the 300-600,600-1200,and 1200-2400 Hz octave threshold exceeds the zero setting on the audiometer is bands was suggested to provide an estimate of permissible • then called the hearing threshold level, or loss,at that par- exposure to intermittent noise.03) ticular frequency.The zero settings on the audiometer are In 1963 K.D. Kryter proposed a family of 1/3 octave and based on response levels derived from the testing of large octave band curves based on predicted TTS in the speech • groups of young people. There is general agreement that frequencies. The slope of the curves varied significantly progression in hearing loss at 500,1,000 and 2,000 Hz even- from those of ISO. The criteria provided limits for daily . tually results in impaired hearing, i.e. ability to hear and exposure times ranging from 1.5 minutes or less (ceiling), . understand speech. The Subcommittee on Noise of the up to 8 hours.(14) Kryter's criteria are the same as those con- American Academy of Ophthalmology and Otolaryngology tained in the draft of Technical Report of the Armed • P (AAOO)ta) and,subsequently, the American Medical Asso- Forces, National Research Council Committee on Hearing ciation(9) defined estimated hearinglevel for speech as the and Bi.o-Acoustics (CHABA).ns) . simple average of hearing levels at the three frequencies The level of Octave Band (O.B.) mid-frequency 1,000 Hz . 500, 1,000 and 2,000 Hz. The point at which impairment (85db)for 8 hour exposure, is the same for both Kryter and begins was then set at the 25 decibel average hearing level the ISO criteria. • (adjusted to the ANSI 1%9 Audiometer.Standard 53.6.)This is now referred to as the hearing loss index (�5 2) or HLI The Intersociety Committee on Guidelines for Noise Ex- (0.5,1,2)= 25 db. There is also general agreement that the Posure Control,in 1967,reviewed published data and some . hearing level at 3,000 Hz is related to the hearing and un- private communications and provided an estimate that at derstanding of speech, particularly in the presence of 85 dBA, in terms of percentage risk, some 3 percent of a noise. In 1978, in the summary of an investigation by Alice population exposed throughout a working life time would H. Suter it is reported that, suffer some hearing impairment (HLI [0.5,1,2] >_ 25 d6). In • "Correlation tests revealed that frequency combing- view of the data scatter,however,the committee indicated • tions that included frequencies above 2000 Hz were - that this was at sifnifperce At 90 dBA the percentage risk significantly better predictors of speech discrimina- nifi approximately 10 percent, and this was felt to be sig- , tion scores than the combination of 500, 1,000 and nifican[!4) 2,000 Hz.'110) In May 1967, the American Conference of Governmen- tal Industrial Hygienists, which had representation on the However there is no consensus regarding its inclusion in a Intersociety Committee, formed the TLV Committee for • formula such as the HLI (-)' ). The inclusion, (or ex- Physical Agents. The Committee recommended a limit of clusion) of 3,000 Hz in an impairment definition is particu- larlyimportant when one considers that in almost all cases t • noise induced hearingloss first a basis that this should protect 90 percent of the long term appears in the frequency exposure group. For exposures less than 8 hours per day • range from 3,000 to 6,000 Hz..With continued exposure the the Committee recommended that for each halving of the loss in hearing eventually spreads to the lowr_ frequencies exposure time the limit be increased by 5 dBA (5 dBA • of 500,1,000 and 2,000 Hz. Clearly it is necessary to define slope). Equal-Energy proponents claim that damage to the the beginning of impairment before one can propose a hearing mechanism is directly related to the acoustical en- damage risk criterion, either in terms of a zero-riskcrite- ergy involved. On this basis, the limit should be increased • rion such that the prevalence of impairment in an exposed by only 3dBA (3 dBA slope) for each halving of exposure group is no greater than the prevalence in a control, or time. While there is some substantiation for the 3 dBA • no-noise, group; or interms of a percentage-risk criterion slope for uninterrupted exposure to steady state noise the which would provide an estimate of the increase in the Committee felt that, based on TTS and animal studies, the • number of impaired subjects in a group exposed to noise ear can tolerate more acoustical energy briefly than it can • levels in a stated excess of the zero-risk criterion. - for-)continuous eight hour exposure. Further, the Commit- In 1954 the Z 24 X 2 Committee reported the need for tee felt that, in most plant situations, rest periods plus • definition of hearing impairment and protection goals. equipment shutdowns contribute to interruptions in expo- There was some indication that exposure to octave band sure which significantly increases the ear's tolerance. This levels in excess of 80 decibels could cause some loss of first TLV (90 dBA) was subsequently adopted in May 1971. • hearing.(") In 1967, Dr. Baughn first presented data, later published • In 1957 the AAOO Subcommittee on Noise reported in a final report,n61 that, based on the evaluation of audiograms of 6,835 noise exposed workers.This was one of the largest . "If the sound energy of the noise is distributed more groups studied to that time.There were some stated lack of or less evenly throughout the eight octave bands and controls in the study. Acknowledging this constraint, the . if a person is to be exposed to this noise regularly for indication was that at 85 dBA there was an 8 percent risk of • many hours-a day, five days a week for-many years, hearing impairment and that at 90 dBA and the risk factor then if the noise level in either the 300 to 600 Hz or was increased to 18 percent. the 600 to 1200 Hz band is 85 dB, the initiation of A study by Burns and Robinson(17)in 1970 included such noise exposure control and tests of hearing is advisa- factors as: use of dBA (supported), variability in audiome- ble.'112) - tric measurement,relationship of temporary threshold shift • The ISO/TC 43, in 1%1, published a series of noise rat- to permanent loss, and use of the.equal-energy approach. • ing curves and proposed that the noise rating curve N85 be The results from the study are discussed in the following used as the limit for habitual workday exposure to broad- section under NIOSH. • 468 • . The National Institute for Occupational Safety and ferent from the hearing levels in the low intensity group, Health (NIOSH), in 1972, published criteria for a recom- (b) differences between females in the exposed and con- mended standard standard on occupational.exposure to noise.(;)Au- trot group were not statistically significant, and (c) differ- • - diometric and noise exposure data were obtained from 792 ences between males exposed to 82 to 92 dBA and their noise exposed workers from various industries and 380 controls were small and were not statistically significant at . - non-noise exposed workers from the same industries. An 500, 1,000 and 2,000 Hz. Levels in the noise-exposed group analysis of the data indicates approximately 10 percent risk significantly exceeded those in the control group at 3,000, • of impairment (HLI (0.5,1,21 >_ 25 dB) for workers exposed 4,000, and 6,000 Hz by approximately 6 to 9 dB. • for more than 30 years to 85 dBA. The NIOSH document The Berger et al report(19) is notable for the precise mea- contained a comprehensive review of published data from surement and steady state characteristic of the plant noise. . other studies. The NIOSH percent risk values for long term Following careful screening during the study period only • exposures to various noise levels were compared with 100exposedsubjects (42 male, 58 female) were retained .those derived from 3 other studies: the Intersociety, the from an original group of 459 employees. The conclusion • ISO Recommendation R1999 and the Burns Robinson. The was that, . ISO risk values were similar to those of NIOSH. When the "Averaging the results for all 700 subjects, in.order to Burns Robinson audiometric data were adjusted to con- make comparisons to other available data,yielded re- form with the audiometric baseline normally present in sults in close agreement to predictions based upon United States studies,the risk values were comparable.The the work of Burns and Robinson, Baughn, NIOSH Intersociety risk values were significantly lower.This differ- and Passchier-Vermeer,indicating that 10 years of ex- ence was attributed to several factors including a) use of posure to a daily Leq. of 89 dBA causes measurable results from one ear only, b) non separation of experience hearing loss at 4 kHz." groups, c) use of speech interference levels, and subse- Reference is made to the lack of consensus regarding • quent conversion into approximate dBA values,and d) use the formula for determining hearing impairment.The main of a dissimilar composite population, in the Intersociety point re issue wasthe at inclusion, or exclusion, of the hear- study. The importance of 3,000 Hz in the hearing and un- ing threshold level a[ 300 Hz in such a formulae. derstanviewed. It of speech under everyday conditions was re- In 1979,The American Academy of Otolaryngology de- be It was concluded that HLI (1 z 3) > 25 d6 should be accepted as the beginning.of impairment. veloped a new formula for determining hearing impair- ment(20)The formula includes the 300 Hz frequency,and is In 1974, having reviewed the published data, the TLV as follows: Committee felt that 85 dBA provided an appropriate limit 1 The average of the hearing threshold levels at 500, for an 8 hour day,5 day week, long term exposure to occu- pational ccu- 1000, 2000, and 3(700 Hz should be calculated for • pationalnoise.On the basis of HLI (0.5,1,2) >_ 25 dB;the 85 I dBA limit should ensure the protection of approximately each ear. 90% of exposed workers. 2. The percentage of impairment for each ear should be Concerning "uninterrupted" exposures to steady state calculated by.multiplying by 1.5 percent the amount noise of less than 8 hours per day the Committee favoured by which the average hearing threshold level exceeds • the retention of the 5 d6 slope. Concerning intermittent a low fence of 25 dB. The impairment should be cal- exposures throughout a work day the Committee proposed culated up to 100 percent, reached at a high fence of a simple summation of such episodes over the work day. 92 dB. While the 5 dB doubling rate may be overly permissive in 3. The impairment then should be calculated by multi- some plant situations for continuous exposure, in the case plying the percentage of the better ear by five, add- of intermittency it would tend to make some allowance for ing this figure to the percentage from the poorer ear, • the recovery periods between exposures. The Committee. and dividing the total by six. • recognized the need for more field study in this area. A notice of intended change, incorporating the above limits,was then made, and the 1974 proposals,were subse- References: quently adopted. 1. American National Standards Institute: ANSI 57.4-7977, ANS . Two recent studies published in 1978 are of interest. S3.6-1969(R1972).International Electrotechnical Commission The Inter Industry Noise,(18) IEC 123, IEC 177. . started in 1974, collected 2 Olishifski, 1. and E. Harford: Industrial Noise and Hearin, • data on male and female workers exposed to steady state Conservation,Chap: II H. Jones). National Safety Counc noise in the range of 82 to 92 dBA. The protocol was de- "(1975) • signed to ensure rigorous control of both exposed and 3. NIOSH: Criteria for a Recommended Standard for Occupz control groups. tional Exposure to Noise(1972). • The exposed workers were divided into groups accord- 4. Intersociety Guidelines for Noise Exposure Control: Am. Iru • ing to sex and to plant noise level,e.g., low intensity group Hyg.Assoc.J.28:418 (1967). 82 to 85 dBA, and high intensity group 86 to.92 dBA. How- S. Botsford, J.H.: Simple Method for Identifying Acceptabl ever subsequent to the start of thestudy, repeat checks on Noise Exposures,J.Acoust. Soc.Am.46:418(1967). . the plant noise levels revealed that in some cases there was 6. Passchier-Vermeer, W.: Hearing Loss Due to Exposure i a marked change in these levels. Thus there was some Steady-State Broadband Noise. Report No. 235, Inst. for Put • movement of subjects between the high and low groups lic Health Engineering,The Netherlands(1968). during,and presumably before,the study period. The con- 7, Cohen, A., J.R. Amticaglia and P. Carpenter: Tempora • clusions drawn from this study were that; (a) the hearing Threshold Shift in Hearing from Exposure to Different Noi • levels in the high intensity group were not observably dif- Spectra at Equal dBA Level.J. Acout.Soc. Am.57: 503 (197: 4 • • • • L • LEAD average concentration of lead dust and fume at or below • - - 0.5 mg/m3, combined with a medical program, would as- Ph sure adequate control.Weber(8)considered the 0.15 mg/m3 too low, but stipulated that 0.3 mg/m3 should not be ex- Inorganic Compounds, Dust and Fume, as Pb ceeded (as time-weighted average). He found that an at- TLV,0.15 mg/m3 - mospheric concentration of 0.43 mg/m3 corresponded to • - 0.20 mg/L of urine, a level considered by some investiga- STEL,0.45 mg/m3 _ tors to represent the upper limit of safety. Elkinsl9tassem- bled the data available on lead in air and lead in urine and • Lead is a metallic element; atomic number.82, atomic concluded that a urinary lead concentration of 0.20 mg/L • weight 207.2, in Group IVB. of the periodic table. This would, on the average, correspond to an air-lead value of heavy, ductile, gray metal has a specific gravity of 11.35, 0.20 mg/m3. • melting point of 3274°Cand a boiling point of 1755°C. Its On the basis of these reports and unpublished data vapor pressure becomes significant, from a health stand- from several sources, the TLV for lead was increased from point, only above 500°C. Only a few lead compounds are 0.15 to 0.20 mg/m3 in 1957. Some authorities continued to S appreciably soluble in water, but many are dissolved by use the previous limit,however.00t Schrenknit implied that - acids and most are sufficiently soluble in body fluids to be the 0.15 mg/m3 value was to be preferred.The preponder- • toxic, especially when inhaled in finely divided form. ance of American opinion,however,seemed to be that the Metallic lead finds wide industrial use where its proper- 0.2 mg/m3 limit was adequate to prevent episodes of lead ties of high density,softness, low melting point, resistance intoxication. Thus Kehoe,02) in a discussion of threshold • to corrosion and/or opacity to gamma and X-rays are need- limits for lead, stated that: "Evidence of the validity of the • ed. It is a major component of many alloys such as solder, standard (0.2 mg/m3) has been provided elsewhere and type metal and many bronzes. Lead compounds have a need not be enlarged upon here."He went on to warn that . wide variety of uses, especially as paint pigments, in stor- this value is adequate only if ingestion of lead is prevented. agebatteries and ceramics. Johnstone and Miller(13) referred to the 0.2 mg/m3 limit as • Despite the tremendous importance of lead as an occu- generally accepted. . pational hazard, only a handful of papers in the volumi- More recent comparisons of atmospheric and urinary nous literature on lead poisoning present meaningful data lead concentrations have indicated conflicting results. Berg relating to the threshold limit value. The chief reason for and Zenz,t14t in a foundry study, found that air-lead con- this situation is probably the fact that most autorities rely centrations between 0.14-and 0.18 mg/m3 resulted in.uri- primarily,if not exclusively,on other tests for estimation of nary lead values below 0.15 mg/L;0.28 mg/m3 was associat- the degree of lead hazard. Urinary and blood leads,urinary ed with 0.17 mg/L of urine. coproporphyrin and delta aminolevulinic acid, as well as Tsuchiya and Harashima(t5) concluded that for a 48- to • blood examination for stippled cells and other abnormali- 60-hour work week, an average air-lead concentration of • ties, are among the preferred procedures. 0.10 mg/m3 would bring about an average urinary lead lev- A limit of 0.5 mg/m3 for lead in air was proposed by el of 0.15 mg/L; and 0.12 mg/m3 to 0.20 mg/L. Concentra- Legge in 1912, with the comment that, if adhered to, cases tions of 0.12 to 0.14 mg/m3 resulted in increased urinary of encephalopathy and paralysis would never,and cases of coproporphyrin,some stippling of blood cells and anemia. colic would very rarely, occur.['[ The data of Duckering's Most extensive lead exposure studies have involved • experiments on the quantities of lead in the air from vari- lead oxide dust or the fume of metallic lead. Some reports ous industrial processes are given as evidence.izt This value have indicated that the dusts of certain insoluble lead • (0,5 mg/m3) was quoted by Alice Hamilton in 1925, with a compounds,such as the sulfidet16t and chromate,were less. similar commenU3) hazardous than more soluble forms of lead. Thus Harrold In 1933 Russell et al,t4t following a U.S. Public Health and associates(17,18) studied a group of painters exposed to • Service survey of a lead storage battery plant, proposed a mists of lead chromate in concentrations averaging be- limit of 0.15 mg/m3 for lead dust and fume in this industry. tween 1..2 and 12 mg of lead per cubic meter of air, and Eight years later Dreesseri et al(5) published results of a fol- found little evidence of lead absorption or intoxication. • low-up study and considered that their findings confirmed They also suggested that lead titanate would present rela- this value. In 1943 Kehoe and other members of the Com- tively little hazard, due to its very low solubility. • mittee on Lead Poisoning of the American Public Health On the other hand, Hartogenesis and Zielhuis(19) found . Association recommended 0.15 mg/m3 as a time-weighted blood changes in workers exposed to lead chromate dust average Iimit161 at levels above 0.2-mg/m3 (as lead) and doubtfulchanges • A number of investigators found the 0.15 mg/m3 value between 0.1 and 02 mg/m3.They consider that the TLV for • difficult to achieve in many industries, and observation of lead chromate should be the same as that for other inor- workers,.combined with lead urinalysis and similar studies ganic lead compounds. convinced themthat this limit was unnecessarily stringent. Curiously there is evidence that lead fume is less harm- Winn and Shroyerf71 concluded that maintenance of the ful than equal amounts of the dust of relatively soluble • 243 • • • lead compounds.IZOI This is presumed to be due to a lesser below 80µg/100 grams are also few in number. Findings of retention of the extremely fine particles present in the changes in urinary ALA and coproporphyrin, erythrocyte • fume. protoporphyrin and zinc protoporphyrin in blood, Nemo-The International Subcommittee for Occupational globin decreases and altered spermatogenesis are reported Health of the Permanent Commission and International As- in conjunction with likely "excessive absorption", as evi- • -sociation of Occupational Health, at a meeting in Amster- denced by blood leads between 40 and 60 µg/100 grams. • dam in November 1968, recommended a limit of 0.15 The proposed standard apparently would not recognize Mg/M3 for a 40-hour week. This conclusion represented these effects as inconsistent with a satisfactory state of • the concensus of 20 experts from 12 nations.I21,22I health. Unacceptable lead absorption, with blood leads in In an extremely thorough study of atmospheric lead ex- excess of 60µg/100 grams (mostly, but not entirely, below posures and biochemical criteria, Williams et ane» found 80 Pg) are associated with CNS effects,peripheral neuropa- among 39 battery workers in England high correlation coef- thy,gastrointestinal disturbances and anemia,according to ficients between air concentrations and blood lead (r = one reference.I28t Another paper(29)cited reported evidence `. 0.9): urinary lead (r = 0.82): urinary coproporphyrins (r - of renal damage in six of thirteen-workers, one with a 0.82) and urinary dALA (r = 0.68). Lower correlations were blood lead of 98 µg/100 grams, one with 66 µg, and the • found for punctate (stippled) basophilic count (r = 0.45) remainder below 60 µg/100 grams of blood. An unpub- and percent hemoglobin (r = 0.09). Furthermore, they ob- lished NIOSH report(m) found renal damage and anemia in • served that in every, case the upper 95% confidence limit similarly exposed (blood leads above 60µg/100 grams, but • considerably exceeded the safe limits,when the air limit is presumably not over 80µg) workers, but no details are giv- 0.2 mg/m3, but approximates it when the air limit is 0.15 en. Mg/M3. - Perhaps the strongest case for the reduced limit is pre- In view of these data using improved biochmical indica- sented in a paper on nerve conduction velocities,t331 in • tors of lead exposure, clearly showing that the TLV of 0.2 which decreases (mostly minimal,but in one system signif- mg/m3 had little or no margin of safety for some workers, icant) were found in workers with maximal blood leads • the limit was reduced back to 0.15 mg/m3 in 1971. between 50 and 70 µg/100 grams. The authors felt that In its firs[ criteria document on inorganic lead, pub- these findings were more serious than the -alterations in ani • lished. in 1972, NIOSH recommended the animg/m3 TLV heme synthesis, demonstrated by biochemical measure- 0.15 as a workplace standard;241 but emphasized that reliance mems, since the regenerative capacity of the nervous sys- temshould be placed primarily on biological measurements, is relatively slow. • especially blood:lead; for which the limit of 0.08 mg/100 The Committee is not convinced that the biochemical • grams was endorsed. A revised document appeared in changes found due to low level lead absorption are incom- 1978, however, in which a lower limit,0.1 mg/m3,was pro- patible with good health. It has not adopted,or proposed, • posed.asi The maximum permissible blood lead level was a biologic TLV for lead, nor has it accepted the NIOSH also reduced, to 0.06 from 0.08 mg/100 grams. hypothesis that an air TLV must be set at a level at which Emphasis in the document is placed on findings of ad- most workers (i.e., 90-95%) do not exceed a specified bio- verse effects among workers with blood leads below 0.08 logic TLV. mg/100 grams, but generally above 0.06 mg. In view of the notation in the title of the consultant's • - Although the updated document contains 185 addition- review of the recent literature in the revised NIOSH docu- al references (most published since 1971), only five relate mentt25t that it is to "support the update" of the criteria • - directly to atmospheric lead concentrations, and these are document, one wonders if the citations are chosen and • all given as support for the amazing statement that "it has their contents summarized without bias. • been shown that 7µg lead/ntt in air contributes about 1-2 For the present, the TLV of 0.15 mg lead/m3 and the µg lead/100 grams of blood" Amazing,that is, until exami- STEL of 0.45 mg lead/m3 in air are retained. • nation of the references indicates that four of them deal Other recommendations: The American National Stan- with continuous exposures of the public, or volunteers, to dard Institute's Z-37 Committee established 0.2 mg/m3 as • lead in air levels of the order of 0.01 mg/m3 or less. Only its acceptable concentration for lead in 1969. Smyth (1956) . one(26) related to occupational exposure; a mean lead in air suggested that even the 0.15 mg/m3 value was not low concentration in one department of a rubber hose and tire enough to prevent mild intoxication. More recent values • company in Japan of 0.0579 mg/m3 (based on 34 tests) was are: USSR (1977) 0.01 mg/m3; Hungary (1974) 0.02 mg/m3; - . associated with a mean blood lead level, in 20 workers, of Czechoslovakia (1976),Poland (1976)and OSHA(1978)0.05 51.8µg/100 grams. mg/m3; Romania (1975),Sweden (1975)and West Germany • In addition,testimony of the Deputy Director of NIOSH -(1978) 0.1 mg/m3; East Germany (1973), Finland (1975) and at an OSHA hearing refers to an unpublished battery plant Yugoslavia (1971) 0.15 mg/m3. • study in which average exposures of workers, using per- sonal monitors, were below 0.1 mg/m3 in all.departments References: except pasting and grid casting, where.exposures were • generally below 0.15 mg/m3.(271 Blood levels in over 90%of 1. Legge,T.M., Goadby, K.W.: Lead Poisoning& Lead Absorp- the workers were 60µg/100 grams or less. tion,p.207, Edward Arnold, London (1962). • 2. Duckering,G.E.:J. Hyg. 7:474 (1908). The findings of these two reports are hardly adequate to . justify the proposed reduction in thelimit for lead in work- 3. Hamilton,A.: Industrial Poisons in the U.S.,p.57,MacMillan, room air. NY (1925). . - 4. Russell,A.E.,Jones,R.R.,Bloomfield,Id.,Britten,R.H.,Thomp- The papers on effects assocaited with blood lead levels son,L.R.: Public Health Bull. No. 205(1933). • 244 • Spray workers exposed at 0.5% Dursban emulsion in References: field trials for malaria control on premises showed a mea- surable decrease in plasma and red cell cholinesterase lev- 1. Martin, H.: Pesticides Manual, 2nd ed., British Crop Protec- • els 00) In this study,5 of 7 sprayersshowed more than 50 per Sn Council (1971). • cent reduction in cholinesterase within two weeks after 2. .Sppencer, E.Y.: Guide to the Chemicals Used in Crop Protec- the spraying program began. In another study,(6) human Canada Dept.of Agriculture (1968). volunteers were exposed to thermal aerosols containing 3. Merck Index,9th ed., p. 281, Merck & Co., Inc., Rahway, N) • Dursban insecticide for one period. Exposures of 3 to 8 Gray, minutes at concentrations of about 0.8 AM/M3 in air pro- 4. Gray,H.E.: Down to Earth 27:26 (1965).A Dow Chemical Co. • !+ P Publication. duced no significant alteration of cholinesterase levels. 5. Gaines,T.B.: Tox. an, Pharm. 14:515 (1969). This concentration resulted from the recommended appli- • cation rate in thermal fogging. 6. Ludwig. P.O., Kilian, D.1, Dishburger, H.L, Edwards, H.N.: gg g� Mosquito News 30.346 (1970). Available studies indicate that Dursban is rapidly meta- 7• FAO/WHO Pesticide Residue Report, No. FAD/RES/72.6a bolized in the animal body.(s) (November 1972). There was evidence of teratologic or reproductive ef- 8. The Dow Chemical Company: Personal communication to • fects in male and female rats fed 1.0 mg/kg per day during TLV Committee, Midland,MI (1973). a three-generation reporduction and fertility study.01) 9.- Griffin, T.B. et al: Soc. Tox. Abstract No. 32, Atlanta, GA • A TLV of 0.2 and a STEL of 0.6 mg/m3 are recommended (March 1976). • to prevent any measurable decrease in plasma cholinester- 10. Eliason,D.A.,Cranmer,M.F.,vonWindeguth,D.C.,Kilpatrick, ase activities and provides a very wide margin of safety in 1•W,Sugs,I.E.,School,H.F.: Mosquito News 291.591 (1969). preventing cholinergic symptoms or organic injury. 11. The Dow Chemical Company: Communication to the TLV Committee of unpublished data (1972). • CHROMIUM 2. Divalent chromium compounds Cr2+ Cr compounds) �- This grouping includes chromous chloride (CrClz) • Metal and Inorganic Compounds,as Cr and chromous sulfate (CrSO4). 3. Trivalent chromium compounds (Cr3+) (Chromic • TLV,0.5 mg/m3- Metal compounds) • 0.5 mg/m3-Cr 11 Compounds This grouping includes chromic oxide (Cr203), 0.5 mg/m3-Cr III Compounds chromic sulfate (Cr2[50413),chromic chloride (CrC13), • chromic potassium sulfate (KCr[S0412)-and chromite 0.05 mg/m3 -Water Soluble Cr VI Compounds ore (FeC-0203). 0.05 mg/m3,Appendix Ala-Recognized Carcinogen 4. Hexavalent chromium compounds (Ci6+) • -Certain Water Insoluble Cr VI Compounds This grouping includes chromium trioxide (Cr03) - the anhydride of chromic acid - chromates (e.g., • Chromium is a metallic element; atomic number 24, Na2004), dichromates (e.g., Na2Cr20r) and polych- • atomic weight 57.9%, in Group VIB of the periodic table. It romates. Certain hexavalent chromium compounds is a steel-gray,lustrous metal, with a specific gravity of 7.20. have been demonstrated to be carcinogenic on the • , The melting point is 1900°C and boils at 2642°C. The basis of epidemiological investigations on workers metal reacts with dilute hydrochloric acid and sulfuric and experimental studies in animals. In general,these • acid, but not with nitric acid. - compounds tend to be of low solubility in water and • Chromium metal was first isolated in 1798. The chief thus may be subdivided into two subgroups: • uses of chromium and chromium compounds are in stain- (a) Water soluble hexavalent chromium com- less and alloy steels, refractory products,tanning agents for pounds leather, pigments, electroplating, catalyst and in corrosion These include chromic acid and its anhydride, resistant products. Chromium is obtained from chromite and the monochromates and dichromates of • ores (FeO-Cr2O3). Relatively large deposits of chromite ore sodium, potassium, ammonium, lithium, cesi- were found near Baltimore in the United States but no um and rubidium. mining has taken place there since 1%1. (b) Water insoluble hexavalent chromium com- Chromium can have a valence of 2, 3 or 6, and a wide pounds range of chromium alloys and inorganic chromium com- These include zinc chromate, calcium chro- • pounds are encountered in the workplace. These chromi- mate, lead chromate, barium chromate, stron- . um compounds vary greatly in their toxic and carcinogenic tium chromate and sintered chromium triox- effects. For this reason it is necessary to divide chromium ide. • and its inorganic compounds into a number of groupings . -each with its specific TLV based on available toxicologi- Hexavalent Chromium cal and epidemiological evidence These groupings are: The first cases of occupational health effects from hexa- 1. Chromium metals and alloys valent chromium were reported in 1827(2) by Cumin, who I This grouping includes chromium metal, stainless observed cases of skin ulceration and dermatitis in dye steels and other chromium-containing alloys. workers handling potassium dichromate. Mackenzie(3) in 98 1884 reported that perforation of the nasal septum oc- mates, are carcinogenic, whereas the soluble forms are curred in workers exposed to potassium bichromate. Da- noU20) Royle,(21) however, has reported an increase in lung Costa et an41 in 1916 described chrome ulcers in tanners and other cancers in chrome platers in England. • and dryers. Parkhurst(5) in 1925 reported chrome dermatitis Hexavalent chromium compounds have been said to in blueprint workers exposed to potassium dichromate. also cause kidney damage in workers(22,23) where absorp Bloomfield and Blumt6t reported on their study of electro- tion through damaged skin has occurred. • _ platers exposed to acidic mist of hexavalent chromium The TLVs for hexavalent chromium compounds are rec- compounds. They noted that 20 or 23 workers examined ommended as follows: showed evidence of perforated or ulcerated nasal septa and skin ulcers(chrome holes).The Factory Inspectorate in (a) Water soluble hexavalent chromium com- • Great Britain(7) reported in 1930 on the results of medical pounds (see examples noted above). A TLV of examinations of 223 persons engaged in chromium plating; 0.05 mg/m3 as water soluble Cr6+ is considered 42.6%had dermatitis or skin ulcersand 52% had perforated adequate to protect against irritation of the re- or ulcerated nasal septa. spiratory tract and possible kidney and liver • The occupational health literature affords abundant evi- damage. NIOSH in the criteria document on . chromic acid(24) recommended that occupa- dence that hexavalent chromium compounds may cause tional exposures be controlled to prevent expo- - irritant and allergic contact dermatitis, skin ulcers, and na- sures above 0.05 mg/m3 TWA. In a later criteria sal irritation varying from rhinitis to perforation of the nasal document on hexavalent chromiUmr25t NIOSH . septum. Dermatitis from exposure to soluble hexavalent recommended a permissible exposure limit of • chromium has been reported in Iithographersf8,91 diesel re- 0.025 mg/m3. pair shop workersti0i and leather workers(") Soluble chro- mates in cement have been stated to be the cause of ce- (b) Certain water insoluble hexavalent chromium ment dermatitis in some workets!121 compounds (see examples noted above).A TLV . of 0.05 mg/m3 as water insoluble Cr6+ and in- Attempts have been made to correlate the airbornelev- sertion in appendix Ala is recommended.There • els of hexavalent chromium with irritation of the nasal mu- is, unfortunately,little previous environmental Cosa. In the study by Bloomfield and Blum! TU • alpha hthyl-thiourea • C„H,oNz NHCSNH, Skin / \ TLV,0.3 mg/m3 • STEL,0.9 mg/m3 \ / '. . ANTU is an odorless gray der. Its molecular weight formed on workers handling thiourea products showed • is 202.27 and the melting point °C with decomposi- ready penetration through the skin, leading to destructive tion occuring upon boiling. Inso in water and only changes in the thyroidglandsa5i • very slightly soluble in most organic Is. ANTU has been implicatedtbl as a causative agent in oc- • The principle use of ANTU is as an to cide. cupational bladder tumors because of its content of beta McClosky et al(l) reported that the acute oxicity of naphthylamine as an impurity in alpha naphthylamine from �. ANTU varies greatly among different species, ra dogs which.ANTU is made. At the TLV of 0.3 mg/m3 it is be- being the most susceptible (LD5o,30-50 mg/kg)an its lieved that the amount of beta naphthylamine exposure the least (1000 mg/kg). Later studies showed an acut would pose no carcinogenic risk provided skin contact is LD50 for monkeys of 4,250 mg/kg. The acute toxicity avoided. Other adverse effects of ANTU are believed to be • ANTU for man is believed to lie somewhere between these rotected-against by the recommended TLV and the STEL • extremes. A dietary level of 50 ppm for two years (approxi- 9 mg/m3. • mately 2.5 mg/kg per day, equivalent to 170 mg/man/day) _ produced tissue damage in rats.l21 Refe • Evaluation of the toxicity data for threshold limit rec- 1. Mcclo .T., Smith, M.I., Lillie, R.D.: Pub. Health Reports ommendation is further complicated by the cumulative ac- 6..1101 (1 tion of ANTU on the endocrine systems(thyroids and adre- 2 Lehman,A.1•: 1.Assn. Food Drug Off. U-S. 16:47 (1952). ' nals) leading to hypothyroidism upon repeated exposure, 3. Fairchild, E.J. It.: nal communication to TLV Committee whereas a tolerance to certain of the acute effects of ANTU member (July 1959). • (pulmonary effusion) likewise occurs.(3) 4. LaubI in,H.: Berylsde n,1.154 (1962). , . A case of contact eczema due to handling a rat poison 5. Kosova,L. Gig. 1 Sanit., 70). containing ANTU as a base has been reported J4) Tests per- 6. Case,R.A.M.:Ann. Roy. Coll. Su . 39(4):213 (1966). ARSENIC AND COMPOUNDS cal synthesis; the gaseous tri- and pentafluorides apparently have no important commercial uses. Many or- As ganic arsenic compounds, however, have been employed in medicine, or as war gases. - • Soluble Compounds,as As As with other metallic poisons, the toxicities,especially • TLV,0.2 mg/m3 _ - the acute toxicities, of arsenic compounds are related to their solubility in water. Thus most arsenates and arsenites • are acute poisons,while the sulfides are probably less toxic Arsenic, an element with atomic number 33, atomic inan acute sense, but may be equally hazardous on pro- weight 74.92, is. in Group VA of the periodic table. The longed exposure. Elemental arsenic is also less acutely toxic • most common form of the element is a gray brittle crystal- than its oxides, except for the rare yellow arsenic which is line solid with a specific gravity of 5.72, which sublimes at highly toxic, possibly similar to yellow phosphorus in some •. 613°C. It also exists in amorphous forms: black, specific of its properties. gravity of 4.7 and yellow, specific gravity of 2.0, which is Systemic arsenic poisoning is rarely seen in industry, relatively volatile. Yellow arsenic is soluble in carbon disul- and still more rarely is it severe in character. According to fide,the other forms are insoluble in water or solvents,but Hardy,0) it is hard to explain the difference between Indus-dissolved by oxidizing acids. trial and nonindustrial arsenic poisoning, but such varia- . Elemental or metallic arsenic is employed as an alloying tion is recorded in all industrialized countries. The usual • agent for heavy metals, in special solders, and as a doping effects on workers are local, on skin and mucous mem- agent in silicon and germanium solid state products. braves, etc. A hoarse voice is characteristic of an arsenic • In addition to arsenic compounds discussed separately worker, and a perforated nasal septum is a common result • (As203, ASH3 and lead arsenate, q.v.) many others find of prolonged inhalation of white arsenic dust or fume. A commercial application.The arsenites are important herbi- few documented cases of cirrhosis of the liver, however, • - cides,calcium and other arsenates are insecticides;sulfides due to occupational exposure to arsenic, have been rec- • are pigments, rodenticides and used in pyrotechnics; galli- orded.M -um arsenide is in semiconductors; arsenic trichloride,a liq-_ Although the epidemiologic evidence is not complete, uid with a boiling point of 130.5 C, is employed in chemi- arsenic is considered by some to be a carcinogen,certainly . 24 • • of the skin, and perhaps of the bronchi.(2.3) Cancers from 0.25.115) The urinary excretion, in mg/liter, of elements that �. exposure to arsenic have followed: 1) the internal use of are freely eliminated by this route,such as fluorine, mercu Fowler's Solution,an aromatic solution of potassium arsen- ry and arsenic, is at most 2.5 to 5 times the occupational- . ite;(4)2) inhalation and skin contact with sheep-dust,a mix- exposure in mg/cubic meter of air.06) It is apparent that - ture of sodium arsenite and sulfur;(5)3)the combined inha- biological monitoring for arsenic by urinalysis would be of lation of A5203, SO2 and other particulates from the limited value in determining whether or not the NIOSH smelting of ores containing arsenic (see documentation, recommended standardwas being met or exceeded. arsenic trioxide production). Experimental cancers in ani- According to the 1977 compilation of occupational ex- trials have not been produced from As203 despite several posure limits of the International Labour Office, the fol- attempts(6-8) and the conclusion of Vallee et alter was that lowing countries had adopted the previous TLV of 0.5 "it is improbable that arsenic(per se)plays asignificant role mg/m3: Australia, Finland,Japan, Holland, Switzerland and • in the generation of cancer."The belief that other occupa- Yugoslavia. Czechoslovakia, East Germany, Hungary and • tional factors are necessary for the development of cancer, Poland specified the USSR MAC of 0.3 mg/m3; Romania 0.2 in addition to arsenic exposure, has been expressed by and Sweden 0.05 mg/m3. Only three of 18 countries (West • othersJ9) Germany, Italy and Sweden) designated arsenic and com- - . A search of the world literature reveals no reports of pounds as carcinogens, although Belgium and the Nether- industrial or experimental exposures solely to arsenic com- lands so characterized arsenic trioxide. • - pounds which contain both environmental and toxicologi- It is possible that some arsenic compounds, the trichlo- ral criteria from which a TLV can be unequivocally based. ride for example, might produce certain toxic effects at Watrous and McCaughey(10) found concentrations of ar- concentrations below 0.2 mg/m3 of arsenic. Data to sub- • senic in a pharmaceutical plant averaging about 0.2 mg/m3, stantiate this speculation are lacking. The contrary situa- with no definite evidence of intoxication. PintoandMcGill tion,that some compounds, or the metal itself, are chroni- • studied a group of smelter employees and found an aver- cally less toxic than As203, the form for which most infor- age urinary arsenic excretion of 0.8 mg/L 01). The chief mation is available, seems more probable in the light of • - manifestation of toxic exposure was dermatitis,with perfo- present knowledge., Therefore, a TLV of 0.2 mg.As/m3 for • ration of the nasal septum, pharyngitis andconjunctivitis soluble compounds of arsenic is recommended. noted less frequently. A reasonable interpretation of the • - urinary arsenic levels wouldindicate an averageexposure of about 0:2:mg/m3 of arsenic in air..Since individual.con- centrations as High. as 4 mg/L ofurinewere found, it is References: • probable that many workers were exposed at higher con- 1. Hamilton,A.,,Hardy;H.L.: Industrial Toxicology, 3rd ed.; pp. centrations. 31-39, Publishing Sciences Group,Acton, England (1974). • - In its criteria document for inorganic arsenic, NIOSH in 2. Buchanan, W.D.: Toxicity of Arsenic Compounds. Elsevier, • 1973(12). recommended 0.05 mg As/m3 (as a TWA) as a - Amsterdam, (1962).Cited in ref.1. workplace air standard. This was changed in 1975 to 0.002 3. Snegriff, L.S., Lombard, O:M: Arch. Ind. Hyg. Occup. Med. • mg/m3 as a 15 minute ceiling. 4:199(1951.) Ibid. • The first limit was based primarily on reports of cancer 4. Graham,J.H.et a1:J. Invest. Derm.37:317(1%1). among workers exposed to arsenic, as well as non-occupa- 5. Hill,A.B.,Faning,E.L: Brit.J. Ind. Med.5:6(1948). tional cancer resulting from arsenic medications. The only 6. Hueper,W.C.,Payne,W.W.:Arch. Env. Health 5:445 (1%2). • pertinent environmental data cited not already noted con- 7. Baroni,C.et al: Ibid. 7:668(1%3). sist of an average concentration of 0.56 mg/m3 computed & Vallee,E.L.et al: Arch. Ind. Health 21:132(1960). • from the paper by Perry et al(13).on an English sheep dip 9. Goldblatt,M.W.,Goldblatt,Ja Occupational Carcinogenesis, factory study, and a study by Lee and Fraumeni(14) in a in Industrial Medicine and Hygiene, E.R.A. Merewether,ed., ' smelting plant.Concentrations of 1.47,1.56 and 1.50 mg/m3 pp. 210-215, Butterworth, London (1956).Cited in ref.1. • _ were reported in "medium and high exposure areas" and 10. Watrous,R.M.,McCaughey,M.B.: Ind. Med.14:639 (1945). 0.65, 0.17 and 0.002 mg/m3 in "light exposure areas". In 11. Pinto,SS.,McGill;C.M.: Ind. Med. &Surg.22:281 (1953). • both plants an increased incidence of cancer was reported- 12. NIOSH: Criteria for a Recommended Standard - Occupa- ly found. tional Exposure to Inorganic Arsenic(1973). • The Committee is not aware of any published explana- 13. Perry,K.et at., Brit.d Ind. Med.5:6(1948).Cited in ref. 12. • tion of the reasons for the reduction of the.NIOSH 1973 14. Lee, A.M., Fraumeni, J.F. Jr.: ). Natl. Cancer Inst. 42:1045 recommendation of a TWA of 0.05 mg/m3 as a standard,to (1%9). . a ceiling of 0.002 mg/m3 in 1975. 15. Seifert, P.: Deut. Med. Wochschr. 741122 (1954). Abstracted • Normal values of arsenic in urine, as recorded in the in Arch. Ind. Health 11:665 (1955). literature, vary from 0.013 to 0.046 mg/L;111 to 0.13,01) to 16. Elkins,H.B.: Am. Ind. Hyg.Assoc.J.28:305 (1%7). • . 25 • Health and Safety Plan • 72 Flint Street,Salem,MA I � APPENDIX D I � . � # . � .\ . . \ 4 � y : 4 g$ .y. � 7 « < . ± v » - «: W �. 2y o { -! to cc $J :- o 0. \\ c _ ! ! ■ 777 r \ \ LL \ \ k •The TMX412 automatically recognizes and displays the UNPACKING THE INSTRUMENT sensor configuration when switched on. ted. ' • One-Button microprocessor controlled calibration. The shipping box should contain the following items. • Illuminated display for viewing in low light conditions. Account for each item before discarding the box. QUANTITY PART NUMBER DESCRIPTION _ • Round-the-clock monitoring capability using the interchangeable nickel-cadmium rechargeable, 1 1810-2183 TMX412 Multi-Gas Monitor disposable lithium,or disposable alkaline battery packs. or 1 1810-2434 TMX412 Multi-Gas Monitor •Plug-in sensors that can be changed or replaced without (Australian Version) special tools or soldering equipment. 1 1705-0816 TMX412 Instruction Manual •Audible and visual alarm indicators. 1 1705-0745 Keypad Overlay 1 1810-1824 Leather Carrying Case • Optional external audible or vibrating alarms. 1 1705-2946 Maintenance Tool • High and low alarms for combustible and toxic gases; or 1 1705-0278 Maintenance Tool enrichment and depletion alarms for oxygen. (Australian Version) • User selectable access code for security of calibration 1 1704-2839 Calibration Cup and alarm settings. 1 1704-4157 Teflon Lined Tygon Tubing • Combustible gas OVER-RANGE protection. After unpacking, if any listed item is missing, contact • PEAK reading mode. either your local distributor of Industrial Scientific products, • Press and hold power switch to prevent accidental turn or call Industrial Scientific Corporation at 1-800-DETECTS on or turn off. (338-3287)in the United States and Canada, or 412-788-4353. • Hygiene/Data Log option that can be installed by the factory or the customer,to provide short term exposure limit(STEL) and time-weighted average(TWA) TMX412 FEATURES readings with data logging. ° •The TMX412 is classified as intrinsically safe by the The Industrial Scientific TMX412 Multi-Gas Monitor may following agencies: be configured to continuously monitor one,two, three or -Underwriters laboratories (UL). four gases in any combination of the following: - Canadian Standards Association(CSA). Canadian • Oxygen Standards Association has assessed only the combustible gas portion of this instrument for • Combustible gases(%LEL)or methane (%by volume performance. CHO. User selects%LEL or%CH4 prior to calibration. -Mine Safety and Health Administration(MSHA). •Any two of the following toxic gases: -Workcover Authority,NSW;Australia. Carbon Monoxide -Department of Mineral Resource,NSW,Australia. Hydrogen Sulfide Sulfur Dioxide Chlorine Nitrogen Dioxide Chlorine Dioxide 4 5 t ' Parts Identification for the DusTTRAKTm II Desktop Aerosol Monitor Models 8530/8531 Stylus t� Inlet Orloff Touchscreen } z I S . Analog/Alarm Power output USB Host USB Device Ethernet < Zero Module Connector Fitter Access Battery Access Figure 14:Features on Desktop Model 6 Chapter 1 ® L ^m Figure 23: Putting on Inlet Cap Size-Selective Impactors Size-selective impactors can be attached to the inlet of the DUs MAKr II instruments.Size-selective impactors can be used to pre-condition the size range of the particles entering the instrument.PMt,PM2.5,PM4(Respirable) and PMu,impactors are available.The instrument must run at the factory defauk setting of 3.0 L/min for the impactors to achieve the correct cut points. The size-selective impactor is composed of three parts;the cap,impaction plate and bottom.Selection of the cap will determine cut size of the impactor.Each cap is labeled with the particle cut size(I pm,2.5 µm, 4.0 pm or 10 pm).The same impaction plate and bottom are used on all impactor sizes. Cap(1 pm, 2.5pm,4pm or 10 pm) Qom_Impaction Plate &,' Bottom Figure 2d: Size-selective Impactor The impactor assembly is attached to the instrument in place of the inlet cap. The inlet cap does not need to be used if an impactor is being used.See Charter 4. "Maintenance."for instructions on how to add oil to the impaction plate. Setting Up 11 Appendix A Specifications Specifications are subject to change without notice. Sensor Type 90`light scattering Range 8530 Desktop 0.001 to 150 mg/m3 8531 Desktop HC 0.001 to 400 mg/m3 8532 Handheld 0.001 to 150 mg/m3 Resolution ±0.1%of reading of 0.001 mg/m3,whichever is greater Zero Stability 30.002 mg/m3 24 hours at 10 sec time constant Particle Size Range Approximately 0.1 to 10 pm Flow Rate 3.0 L/min set at factory 1.4 to 3.0 L/min adjustable Flow Accuracy t5%factory setpoint Internal flow controlled Temperature Coeffictent +0.001 mg/m3 per"C Operational Temp 0 to 50"C Storage Temp -20 to 60"C Operational Humidity 0-95%RH,non-condensing Time Constant Adjustable 1 to 60 seconds Data Logging 45 days at 1 minute samples Log Interval 1 second to 1 hour Physical Size(HWD) Handheld: 4.9 x 4.75 x 12.45 in. Desktop: 5.3 x 8.5 x 8.8 in. Weight Handheld: 2.9 Ib,3.3 Ib with battery Desktop: 3.45 Ib,4.45 Ib–1 battery, 5.45 Ib–2 batteries Communications 8530131: USB(Host and Device)and Ethernet. Stored data accessible using thumb drive 8532 USB(Host and Device).Stored dada accessible using thumb drive. Power—AC AC power adapter included. 115 to 240 VAC 51 Battery 8530/31: Up to 2 Removable Lalon External and Internal charging Life, 1 battery: 9 hours typical Life,2 battery: 18 hours typical 8532: 1 Removable Li-Ion Extemal and Internal charging Life: 6 hours typical Analog out 8530/31: User selectable output 0 to 5 V or 4 to 20 mA User selectable scaling Alarm Out 8530/31: Relay or sound buzzer Relay No latching MOSFET User selectable set point 5%deadband Connector 4-pin,Mini-DIN connectors 8532: Sound buzzer Screen 8530131: 5.7'color touchscreen 8532: 3.5"color touchscreen Gravimetric Sampling 8530/31: Removable 37-mm Cartridge EMI/RF Immunity: Complies with Emissions Directive Standard: EN50081-1:1992 Complies with Immunity Directive Standard: EN50082-1:1992` -ESL)Shock may roquirc msat nt reboot 52 Appendix A V� r Massachusetts Department of Environmental Protection Provided by.DEP: Bureau of Resource Protection -Wetlands DEP File Number WPA Form 3 - Notice of Intent Document Transaction Number Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Salem Cityrrown Important: When filing out A. General Information forms on the computer,use 1. Project Location (Note: electronic filers will click on button for GIS locator): only the tab key to move your 72 Flint Street Salem 01970 curuse or-the return do not a.Street Address b.City/Town c.Zip Code use the key. UTM 70.907494 E 42.520464 N Latitude and Longitude: d.Latitude e. Longitude Map 6 26-0091-0 f.Assessors Map/Plat Number g.Parcel/Lot Number 2. Applicant: Michael O'Brien Riverview Place, LLC a. First Name b. Last Name c.Company Note: 5 Broadmoor Lane Before d.Mailing Address completing this forth consult Peabody Ma. 01960 your local e.Cityrrowri f.State g.Zip Code Conservation 978-979-4072 Commission h.Phone Number i.Fax Number j.Email address regarding any municipal bylaw 3. Property owner(if different from applicant): ❑ Check if more than one owner or ordinance. h. a. First Name b. Last Name c.Company d.Mailing Address e.City/Town f.State g.Zip Code h. Phone Number i.Fax Number j.Email address 4. Representative (if any): S P Engineering Inc. Z a. Firm aBruce Poole =a Z g b.Contact Person First Name c.Contact Person Last Name z W 45 Congress St. PO Box 848 �� g r d. Mailing Address LU� x ° Salem Ma. 01970 U '0 - e. Cityrrown f.State g.Zip Code o t� 2 978-745-4569 978-745-4881 brucepoolesp@aol.com LU 0 0 h . Phone Number i.Fax Number j.Email address U 5. Total WPA Fee Paid (from NOI Wetland Fee Transmittal Form): 2175 1075 1100 a.Total Fee Paid b.State Fee Paid c.City/Town Fee Paid 6. General Project Description: Demolition of slab and footings, removal of oily soil, landfill materials and other soils with metal levels over the S-1 limits with a DEP approved RAM plan for recycling , secure landfill disposal or on-site stabilization. Materials would be on plastic and covered while stored outside of the 200' buffer zone. Erosion logs would be placed beside the river and Mon. wells installed to view GW quality. wpaform3.doc•rev.4/12/06 Page t of 7 f Massachusetts Department of Environmental Protection Provided by DEP: Bureau of Resource Protection -Wetlands DEP File Number WPA Form 3 - Notice of Intent Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Document Transaction NumberSalem City/Town A. General Information (continued) 7. Project Type Checklist: a. ❑ Single Family Home b. ❑ Residential Subdivision c. ❑ Limited Project Driveway Crossing d. ® Commercial/Industrial e. ❑ Dock/Pier f. ❑ Utilities g. ❑ Coastal Engineering Structure h. ❑ Agriculture—cranberries, forestry i. ❑ Transportation j. ❑ Other 8. Property recorded at the Registry of Deeds for: Essex South 89 a.County b.Page Number 6690 c.Book d.Certificate#(if registered land) 9. Has work been performed on the property under an Order of Resource Area Delineation involving Simplified Review within 3 years of the date of this application? a. ❑ Yes b. ® No If yes, no Notice of Intent or Request for Determination of Applicability may be filed for work within the 50-foot-wide area in the Buffer Zone along the resource area during the three-year term of an Order of Resource Area Delineation, or any Extended Order, or until the applicant receives a Certificate of Compliance, whichever is later. 10. Buffer Zone Only-Is the project located only in the Buffer Zone of a bordering vegetated wetland, inland bank, or coastal resource area? a. ® Yes-answer 11 below, then skip to Section C. b. ❑ No-skip to Section B. 11. Buffer Zone Setback—For projects that involve work only in the buffer zone, select the applicable adjacent resource area (check one): a. ❑ BVW b. ® inland bank c. ❑ coastal resource area The distance between the closest project disturbance and the associated resource area is: 10 d.linear feet wpaformIdoc•rev.4/12/06 . - - Page 2 of 7 Massachusetts Department of Environmental Protection Provided by DEP: Bureau of Resource Protection -Wetlands DEP File Number WPA Form 3 - Notice of Intent Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Document Transaction Number City/Town B. Resource Area Effects 1. Inland Resource Areas Check all that apply below. Attach narrative and any supporting documentation describing how the project will meet all performance standards for each of the resource areas altered, including standards requiring consideration of alternative project design or location. Online Users: Include your Resource Area Size of Proposed Alteration Proposed Replacement(if any) document transaction a. ❑ Bank 1.linear feet 2.linear feet number b. ❑ Bordering Vegetated (provided on Wetland 1.square feet 2.square feet your receipt page)with all c. ❑ Land Under 1.square feet 2.square feet supplementary Waterbodies and information you Waterways 3.cubic yards dredged submit to the d. El Bordering Land Department. Subject to Flooding 1.square feet 2. square feet 3.cubic feet of flood storage lost 4.cubic feet of flood storage replaced e. ❑ Isolated Land Subject to Flooding 1.square feet 2.cubic feet of flood storage lost 3.cubic feet of flood storage replaced -❑ For f. ® Riverfront area 1. Name of Waterway(if available) projects impacted by 1.Width of Riverfront Area (check one): the riverfront area and a ❑ 25 ft. -Designated Densely Developed Areas only buffer zone of another ❑ 100 ft. -New agricultural projects only resource area, add ® 200 ft. -All other projects 50% to the 81,900 total fee. 2. Total area of Riverfront Area on the site of the proposed project: Square Square Feet 3. Proposed alteration of the Riverfront Area: 71,000 28,000 43,000 a.Total Square Feet b.Square Feet within 100 ft. c.Square Feet between 100 ft.and 200 ft. 4. Has an alternatives analysis been done and is it attached to this NOI? ❑ Yes® No 5. Was the lot where the activity is proposed created prior to August 1, 1996? ® Yes❑ No wpaform3.doc•rev.4/12/06 Page 3 of 7 r Massachusetts Department of Environmental Protection Provided by DEP: Bureau /�ofResource Protection -Wetlands DEP File Number WPA Form 3 — Notice of Intent Document Transaction Number Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Cityrrown B. Resource Area Effects 2. Coastal Resource Areas: Check all that apply below. Attach narrative and supporting documentation describing how the project will meet all performance standards for each of the resource areas altered, including standards requiring consideration of alternative project design or location. Online Users: Include your Resource Area Size of Proposed Alteration Proposed Replacement(if any) document transaction a. ❑ Designated Port Areas Indicate size under Land Under the Ocean, below number (provided on b. ❑ Land Under the Ocean 1.Square feet your receipt page)with all 2.Cubic yards dredged supplementary Indicate size under Coastal Beaches and/or Coastal Dunes information you c. ❑ Barrier Beach below submit to the Department. d. ❑ Coastal Beaches 1.Square feet 2.Cubic yards beach nourishment e. ❑ Coastal Dunes 1.Square feet 2.Cubic yards dune nourishment f. ❑ Coastal Banks 1. Linear feet y. ❑ Rocky Intertidal Shores 1.Square feet h. ❑ Salt Marshes 1. Square feet 2. Sq ft restoration, rehab.,or creation i. ❑ Land Under Salt Ponds 1.Square feet 2.Cubic yards dredged j. ❑ Land Containing Shellfish 1.Square feet 2.Square feet restoration, rehab. k. ❑ Fish Runs Indicate size under Coastal Banks, inland Bank, Land Under the Ocean, and/or inland Land Under Waterbodies and Waterways, above 1.Cubic yards dredged I. ® Land Subject to Coastal 28,000 Storm Flowage 1.Square feet 3. Limited Project: Is any portion of the proposed activity eligible to be treated as a limited project subject to 310 CMR 10.24 or 310 CMR 10.53? a. ❑ Yes ® No If yes, describe which limited project applies to this project: b. Limited Project wpaformIdoc•rev.4/12/06 Page 4 of 7 Massachusetts Department of Environmental Protection Provided by DEP: Bureau of Resource Protection -Wetlands DEP File Number WPA Form 3 - Notice of Intent Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Document Transaction Number City/Town C. Bordering Vegetated Wetland Delineation Methodology Check all methods used to delineate the Bordering Vegetated Wetland (BVW) boundary: Online Users: 1. ❑ Final Order of Resource Area Delineation issued by Conservation Commission or DEP Include your (attached) document transaction 2. ❑ DEP BVW Field Data Form (attached) number (provided on 3. ❑ Final Determination of Applicability issued by Conservation Commission or DEP(attached) your receipt , page) with all 4 ❑ Other Methods for Determining the BVW Boundary(attach documentation): supplementary information you a. ❑ 50%or more wetland indicator plants submit to the Department. b- ❑ Saturated/inundated conditions exist c. ❑ Groundwater indicators d. ® Direct observation For all projects affecting other e. ❑ Hydric soil indicators Resource Areas, please f. ❑ Credible evidence of conditions prior to disturbance attach a narrative 5. Other resource areas delineated: explaining how D. Other Applicable Standards and Requirements the resource PP q area was delineated. 1. Is any portion of the proposed project located in estimated habitat as indicated on the most recent Estimated Habitat Map of State-Listed Rare Wetland Wildlife published by the Natural Heritage and Endangered Species Program? a. ❑ Yes M No If yes, include proof of mailing or hand delivery of NO] to: Natural Heritage and Endangered Species Program Division of Fisheries and Wildlife Route 135, North Drive b. Date of Map Westborough, MA 01581 2. For coastal projects only, is any portion of the proposed project located below the mean high water line or in a fish run? a. ❑ Yes ® No If yes, include proof of mailing or hand delivery of NOI to: Division of Marine Fisheries-Southeast Marine Fisheries Station 50A Portside Drive Pocasset, MA 02559 b. ❑ Not applicable—project is in inland resource area only 3. Is any portion of the proposed project within an Area of Critical Environmental Concern (ACEC)? a. ❑ Yes ® No If yes, provide name of ACEC (see instructions to WPA Form 3 or DEP Website for ACEC locations). Note: electronic filers click on Website. b.ACEC wpaform3.doc•rev.4/12/06 Page 5 of 7 Massachusetts Department of Environmental Protection Provided by DEP: Bureau of Resource Protection -Wetlands DEP File Number WPA Form 3 - Notice of Intent Document Transaction Number Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Cirylrown D. Other Applicable Standards and Requirements Online Users: 4. Is any portion of the site subject to a Wetlands Restriction Order under the Inland Wetlands Include your Restriction Act(M.G.L. c. 131, §40A)or the Coastal Wetlands Restriction Act(M.G.L. c. 130, § 105)? document transaction a. ❑ Yes ® No number (provided on your receipt 5. Is any activity within any Resource Area or Buffer Zone exempt from performance standards of the page)with all wetlands regulations, 310 CMR 10.00. supplementary information you a. ❑ Yes ® No If yes, describe which exemption applies to this project: submit to the Department. b. Exemption 6. Is this project subject to the DEP Stormwater Policy? a. ❑ Yes ® No If yes, stormwater management measures are required.Applicants should complete the Stormwater Management Form and submit it with this form. b. If no, explain why the project is exempt: No permanent alteration of grade backfill all excavations E. Additional Information Applicants must include the following with this Notice of Intent(NOI). See instructions for details. Online Users:Attach the document transaction number(provided on your receipt page)for any of the following information you submit to the Department. 1. ® USGS or other map of the area (along with a narrative description, if necessary) containing sufficient information for the Conservation Commission and the Department to locate the site. (Electronic filers may omit this item.) 2. 0 Plans identifying the location of proposed activities(including activities proposed to serve as a Bordering Vegetated Wetland [BVW] replication area or other mitigating measure) relative to the boundaries of each affected resource area. 3. ❑ Other material identifying and explaining the determination of resource area boundaries shown on plans (e.g., a DEP BVW Field Data Form). 4. ® List the titles and dates for all plans and other materials submitted with this NOI. 5. ❑ If there is more than one property owner, please attach a list of these property owners not listed on this form. 6. ❑ Attach proof of mailing for Natural Heritage and Endangered Species Program, if needed. 7. ❑ Attach proof of mailing for Massachusetts Division of Marine Fisheries, if needed. 6. ® Attach NOI Wetland Fee Transmittal Form s. ❑ Attach Stormwater Management Form, if needed. wpaform3.doc•rev.4/12/06 Page 6 of 7 Massachusetts Department of Environmental P Provided by DEP:. p to Protection Bureau of Resource Protection -Wetlands DEP File Number WPA Form 3 - Notice of intent Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Document Transaction Number Cityrrown F. Fees The fees for work proposed under each Notice of Intent must be calculated and submitted to the Conservation Commission and the Department(see Instructions and NOI Wetland Fee Transmittal Form). No filing fee shall be assessed for projects of any city, town, county, or district of the Commonwealth, federally recognized Indian tribe housing authority, municipal housing authority, or the Massachusetts Bay Transportation Authority. Applicants must submit the following information (in addition to pages 1 and 2 of the NOI Wetland Fee Transmittal Form)to confirm fee payment: 23521 10-6-11 1. Municipal Check Number 2.Check date 23522 10-6-11 3:State Check Number 4.Check date SP Inc. Bruce Poole, President 5. Payor name on check:First Name 6. Payor name on check:Last Name G. Signatures and Submittal Requirements I hereby certify under the penalties of perjury that the foregoing Notice of Intent and accompanying plans, documents, and supporting data are true and complete to the best of my knowledge. I understand that the Conservation Commission will place notification of this Notice in a local newspaper at the expense of the applicant in accordance with the wetlands regulations, 310 CMR 10.05(5)(a). I further certify under penalties of perjury that all abutters were notified of this application, pursuant to the requirements of M.G.L. c. 131, §40. Notice must be made in writing by hand delivery or certified mail (return rece' t re nested)to_all utters within 100 feet of the property line of the project ca ion. �% 11 6 A Signature of Applicant 61 Date Signature f Property Ownr if ediffer e Date Signature of Representative(if any) Date For Conservation Commission: Two copies of the completed Notice of Intent(Form 3), including supporting plans and documents; two copies of pages 1 and 2 of the NOI Wetland Fee Transmittal Form; and the city/town fee payment must be sent to the Conservation Commission by certified mail or hand delivery. For DEP: One copy of the completed Notice of Intent(Form 3), including supporting plans and documents; one copy of pages 1 and 2 of the NOI Wetland Fee Transmittal Form; and a copy of the state fee payment must be sent to the DEP Regional Office(see Instructions) by certified mail or hand delivery. (E-filers may submit these electronically. Other: If the applicant has checked the"yes"box in any part of Section D, Item 3, above, refer to that section and the Instructions for additional submittal requirements. The original and copies must be sent simultaneously. Failure by the applicant to send copies in a timely manner may result in dismissal of the Notice of Intent. wpafonn3.doc"rev.4112/06 Page 7 of 7 Massachusetts Department of Environmental Protection Bureau of Resource Protection -Wetlands NOI Wetland Fee Transmittal Form Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Important: A. Applicant Information When filling out forms on the 1. Applicant: computer, use only the tab Michael O'Brien Riverview Place LLC key to move a.First Name b.Last Name c.Company your cursor- 5 Broadmoor Lane do not use the _ d.Mailing Address return key. Peabody Ma. 01960 e.Citylrown - f.State g.Zip Code °6 978-979-4072 h.Phone Number 2. Property Owner(if different): a.First Name b.Last Name c.Company 'd.Mailing Address e.City/Town f.State g.Zip Code h.Phone Number 3. Project Location: 72 Flint Street Salem a.Street Address b.CityTown To calculate B. Fees filing fees, refer to the category Notice of Intent(Form 3) or Abbreviated Notice of Intent(Form 4): fee list and examples in the The fee should be calculated using the following six-step process and worksheet. Please see instructions for Instructions before fillip out worksheet. filling out WPA 9 Form 3(Notice of Intent). Step 1/Type of Activity: Describe each type of activity that will occur in wetland resource area and buffer zone. Step 21Number of Activities: Identify the number of each type of activity. Step 3/individual Activity Fee: Identify each activity fee from the six project categories listed in the instructions. Step 4/Subtotal Activity Fee: Multiply the number of activities (identified in Step 2)times the fee per category(identified in Step 3)to reach a subtotal fee amount. Note: If any of these activities are in a Riverfront Area in addition to another Resource Area or the Buffer Zone, the fee per activity should be multiplied by 1.5 and then added to the subtotal amount. Step 5/Total Project Fee: Determine the total project fee by adding the subtotal amounts from Step 4. Step 6/Fee Payments: To calculate the state share of the fee, divide the total fee in half and subtract $12.50. To calculate the city/town share of the fee, divide the total fee in half and add $12.50. Wpaf.3 d=•Not WeUand Fee Twsmdtal Form•rev.3/1105 Page 1 of 2 Massachusetts Department of Environmental Protection Bureau of Resource Protection -Wetlands NOI Wetland Fee Transmittal Form Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 B. Fees (continued) Step 1/Type of Activity Step 2/Number Step Step 4/Subtotal Activity of Activities 3/Individual Fee Activity Fee Category 4, k. Oil and Haz. 1 2175 2175 Materials release response actions in Riverfront area (1.5X) Step 5/Total Project Fee: 2175 Step 6/Fee Payments: Total Project Fee: 2175 a.Total fee from Step 5 State share of filing fee: 1075 - b. 1/2 total fee less$12.50 - City/Town share of filling fee: 1100 c. 1/2 total fee plus$12.50 C. Submittal Requirements a.) Complete pages 1 and 2 and send with a check or money order for the state share of the fee, payable to the Commonwealth of Massachusetts. Department of Environmental Protection Box 4062 Boston, MA 02211 b.) To the Conservation Commission: Send the Notice of Intent or Abbreviated Notice of Intent; a copy of this form; and the city/town fee payment. c.) To DEP Regional Office (see Instructions): Send a copy of the Notice of Intent or Abbreviated Notice of Intent; a copy of this form; and a copy of the state fee payment. (E-filers of Notices of Intent may submit these electronically.) Wpar .d.•NOI Wetlar Fee Twsmftal Folm•rev.311/05 Page 2 e 2 [PENGINEERING, INC. P.O. Box 848• Salem, Massachusetts 01970•Telephone: 978-745-4569 • Fax: 978-7454881 Project Narrative Riverview Place, LLC 72 Flint Street, Salem INTRODUCTION This Notice of Intent has been prepared on behalf of Riverview Place LLC to obtain an Order of Conditions for work in the Buffer Zone of the North River. The project would include demolition of the floor slabs and footings to access the oil and metal contaminated subsurface soils that exceed the S-1 criteria and recover any free petroleum product from the groundwater. The work would be conducted under the auspices of the Mass. Contingency Plan as regulated by DEP and outlined in the LSP generated RAM Plan. The restoration of the Site is necessary to allow the approved development plan for residential apartments to proceed. Removal of these constituents will also protect the North River from contaminated groundwater and sediment erosion. The Site has been subjected to historical filling since the 1800's and contains tanning bark,burn debris from the Salem fire, coal ash, leather wastes and landfill materials. The test pits excavated through the floor slabs in 2009 identified many areas of contaminated soil, including oily soil next to the #4 Fuel oil tank grave. The quantity of material to be recycled, landfilled and/or stabilized is estimated to be 2000-2500 cubic yards. This data is discussed in a later section. As part of the RAM Plan, additional subsurface investigations will occur during the first phase of the remediation (oily soil removal)to identify other removal areas and document the groundwater quality. The proposed investigation includes; visual inspection of soils, the installation of monitoring wells and test bores, screening of soils with a photoionization detector, as well as soil and groundwater analysis. It is estimated that 10-12 test bores advanced with split spoon sampling at five foot intervals will be needed to check other areas. 6-8 monitoring wells would be installed with 4 located between the excavations and the river. The wells would be developed and sampled for metals and EPH compounds. In addition to remaining soil analyses more test bores and wells would be placed in the remediated areas to confirm the resulting conditions. This information would be compiled into a Phase 2 report, RAM completion report and Response Action Outcome Statement. i b �C Q' .i - may: _ '.Y, •� .. nY .n \kms •3r- __ s ' r SITE HISTORY The subject site had contained several large connected industrial buildings that were occupied by a leather manufacturing facility called Salem Suede Inc. The facility was originally a full beam,tan, color and finish cowhide tannery Leach and Heckel Inc. There have been two four story wooden, brick and concrete structure on the site dating back to 1925. There were paved parking areas in the front and rear of the buildings and an attached metal structure that had been used for hide storage. The site is located on the east side of Flint Street in Salem, Ma.just north of the intersection with Bridge Street. The site is at UTM Coordinates 42.520464 N and 70.907494 E, beside the North River. The rectangular lot is 3.8 acres, located on the North River canal and is depicted as Map#6, Parcel 26- 0091-0 on the Salem Assessor's map. The property slopes rapidly from north (Mason Street)to south, draining to the North River. The Tax Map and Sanborn Maps can be found in the appendix. The Sanborn maps show the area was heavily industrialized with tanneries, oil manufacturers and wood workers in the late 1800s. The site was occupied by J. Gibney Tannery in 1890. A large tannery, Patrick O'Keefe,existed behind and to the east side along with other leather industries and dwellings. Tannery wastewater was discharged to the North River up to the 1950s.By 1906 the buildings on the site were gone, due to the Great Salem Fire of 1904. Dwellings were still located along the road and the Broadly Leather Co. was in operation to the east. The 1925 map shows the buildings as they currently exist with a side building, extending to the east. The structures are brick for two stories with wood frame 3`d and 4th floors. At that time the abutting properties to the north are residences, the Morris Leather Co. (a finisher and embosser) and to the east a State Garage. The original tannery on the site was Leach and Heckel Inc. a full cowhide tannery. The company conducted leather beaming, tanning, coloring and finishing operations. Photographs from 1954 showed a lime or wastewater pit beside the North River in the south comer of the property. As of 1970 the building remained the same and surrounding uses were consistent with 1950-1970. The site slopes to the river and one-third of the property is in the Zone A floodplain. The Site Locus can be seen in Figure One. In 1978 the tannery was purchased by Salem Suede Inc. and an entrance was created on Mason Street. In the 1980's a steel sided warehouse was constructed on the east property line. Beginning in 2007 the chemicals, tanks, leather and machinery were removed and by 2009 the building had been demolished to the floor slabs. The pretreatment system was decommissioned and cleaned in 2009-2010. t�l 'Y�e(T7),ii �+�. I0�1�. �,' \ .\ '.") f Q ►f//r C� _ \ t11 , 1r l --L` )1 -- �` —2<Pete,YS�I/l[ III/ rr�� L h=r I ��- -] 1. �.'P�lt]l� J_�a. o //r• ��L 11 i�. 1•�nurc': \ \If''_• - // ..j Jl� \ ! 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C\✓rR , t / �" ST' ii�.ln�ym'I.o ny .. .r` `a -�.EYPty�. rl r� r-�•'•� 1).\�. 5��ct til ox\\ II s(�r �If �F+/t�; Ltblorkr \ L r r Le of � � r,5 / \ " f'.o \, fl fnkI � ,i � 1/�p�" � 1/ L3 M' wa( l i 2r r / ) ]/ �•� a '�.-.cL`�-=✓./(lv /\:�l_ \ - ,�lJ� \�i'-- i j�O/Zj \�y�(fiC#i ,l O � )IJ n. �'SCt}.,\�t_. y .�,` S 'Ti`- \- •MyNbTWfJ �/3t? \' \ ��\ �\ 0 �,�y� \i_. �\ ` I 11 ( I�`\ �.�� \ \ ! \� Vfib \D1, Vli_ A��q+T• l 1/ �l ��'v l l� ��.� �`-'� ""� �.��, v *� 1 �� / _l 11_ _ V- �v S i IJ , C � <�/' 11 / � C ( \� tit• \� � S h �� / � ✓ r i 2i l -11 � \. : `"\ � � \ \\\ (( ,� \\� ilk \ ` J/�..:U/ � `��`il 1t1 +1 iI- -II �✓li J d ( `A)�� \ i FIrP)11_- � rlr `SO , Z•ust� ,� - YPI _x 1'�� )1�� t O (�'�/l r�� t /(l �� / �f\�✓I/. `1` � ISA��i v�fL � ��i-+l-�'� �f � d CnhcYa• - SITE LOCUS FIGURE ONE SALEM SUEDE INC SALEM, MA TEST PIT INVESTIGATION The results of the Limited Site Investigation conducted at 72 Flint Street, Salem helped to determine whether hazardous materials are present or had been released on the property at the above referenced site.Now that the demolition is complete the proposed test pits through the floor slabs identified areas of contamination that could be released during the destruction of the slab and footings. The Test pit locations are shown in Figure Two,the Site Plan. A visual inspection,photoionizer screening and soil sampling was conducted to ascertain the risk to human health and the environment. After the inspection and chemical analyses,this letter report was prepared to describe the site conditions and recommendations for removal of identified release areas. The floor slabs were penetrated in 9 areas and soils sampled to the groundwater table,natural soils or red Tanning Bark, which was deposited before the 1900's before chromium was used as a mordant. There was one test pit each in the finishing, fat-liquor,hide storage and fence company areas, The tan and color storage areas had 2 test pits each. When contamination was observed in TP-3 (under boiler room slab) an additional test pit, TP-3A was placed 20' away.at the color room footing. Both of these soil samples had #4 Fuel oil residues and Extractable Petroleum Hydrocarbons that exceeded the DEP S-2 criteria. As shown in the Soil Logs natural alluvial soils; fine sands, grey clay, and peat with green silt were encountered at 6-10 feet below grade. Red tanning bark(which was used to color leather in the 1800's before chromium mordants were developed) was deposited on the natural soils to a depth of 3-6 feet below grade. The remaining top fill material consisted of large rock and gravel, ash, brick and wood from the Salem fire as well as leather, concrete, minor coal ash etc. Samples of the fill material and soils in the top 3-6' were taken for analysis. Three areas(TP-3, 3A and 4)had soils with Photoionizer readings of 2.5-50 ppm and were subjected to VOC analysis. Soils adjacent to the former UG fuel tank grave had visible oil staining, sheens and odor and were tested for EPH compounds. These soils would have the greatest potential for migration and would be removed first. The soils would be placed on plastic and covered with plastic in the stockpile area greater than 200' from the river until recycling at Aggregate Industries in Stoughton. Surface oil product encountered during excavation would be skimmed for recycling and a 3' diameter oil recovery manhole would be installed and backfilled for periodic surface oil removal. ANALYSIS RESULTS The metal analysis results are shown in Table One. Lead values ranged from 11.4 to 145 mg/kg,which is below the DEP S-1 limit of 300 mg/kg. Cadmium levels were 0.26 to 2.82 mg/kg in all samples except TP-4 at 11.6 mg/kg compared to a S-1 limit of 2 mg/kg. The chromium levels in the samples vaned widely because of leather pieces, shavings, buffing dust and trimmings deposited with fill before the current structures were constructed in the 1920's. It should be noted that these waste streams were delisted by the EPA in 1985 because the chromium was exclusively trivalent and non-toxic when bound to leather. Two of the test pit soils had chromium values below 30 mg/kg,the DEP S-1 limit while TP-2, 4, 5 and 6 ranged from 897-2260 mg/kg. TP-2 with 2260 mg/kg is greater than 250' from the river and is not likely to result in erosion after slab removal. It would be advisable for the contaminated soils found under the slab in the areas of TP-4, 5 and 6 to be removed immediately to the stockpile area and the remaining soils covered with a minimum of 6" crushed brick and concrete to stabilize the surface. The exterior walls by the river should stay in place until the remediation is complete. Volatile Organic analysis of soil from TP-3 and 4, which had low photoionizer readings, found low levels of only one compound,Naphthalene at 0.436 and 0.248 mg/kg,respectively compared to a DEP S-1 limit of 40 mg/kg.Naphthalene was used as a cleaner for spray guns and nozzles from finishing. Petroleum compounds were found in the subsoils at TP-3 and 3A beside the Fuel tank grave. The levels of C9-C18 aliphatics (2750 mg/kg)and Cl 1-C22 aromatics (2170 and 3710 mg/kg) in TP-3 and 3A exceeded the DEP S-1 criteria of 1000 and 800 mg/kg,respectively. The EPH and PAH levels can be seen in Table 2. As these substances ride on the water surface they could be released to the environment during flooding or rain events, therefore it is recommended that the slab in these areas; the boiler room and color room be removed first for the comprehensive remediation that will be necessary before development. In summary the test pit investigations in 2009, soil testing around the treatment system in 2011 and previous knowledge have identified 8 different areas'of contamination as shown on Figure 2, Site Plan. Soil removal estimates are 2500 cubic yards of 3 different waste streams, oily soil, coal ash and landfill materials that include burn debris, leather, blue shavings and brick. The materials will be disposed of at licensed facilities for recycling and secure burial. The new owner has notified the DEP that a Reportable Release condition has been observed and has submitted a Remedial Action Measures Plan (RAM) that deals with the removal of the oil impacted soils and other areas of historical landfill and coal ash disposal. A more detailed discussion of the remediation and techniques can be found in the RAM Plan. MITIGATION MEASURES Erosion control measures would include but not be limited to; 1. Installation and maintenance of erosion control logs between the property and the river. The existing logs are in good shape, except beside the building where they would be replaced. Removal of contaminated soil will not occur during any rainfall event exceeding 1" in 4 hours or during higher than normal tides (for the areas within the 100' Buffer). 2. Exterior walls and footings next to the river will remain in place until the soil removal and backfill is complete. All exposed surfaces will be covered by 6-12' of crushed concrete and brick to stabilize the backfill soils. Where the wall is not present a 2' soil berm will be placed along the excavation on the river side. 3. Excavated soils are to be loaded directly to dump trucks and stored on plastic and be covered with plastic in the stockpile area greater than 200' from the river. The stockpile area has a rear retaining wall and half of it is a concrete slab. There will be 3 different storage piles for the 3 waste streams; A. oily soil to be recycled at Aggregate Industries in Stoughton,B. landfill/soil materials that have to be buried at the secure landfill, Turn Key in NH or Pine Tree in ME and C. Coal and wood ash, incinerator residue that may require stabilization before recycling at ARC in Elliot,ME or on-site containment. 4. An equipment and truck decontamination area will be set up next to the soil stockpiles for manual soil removal of soil from treads, fenders,buckets, etc .A Health and Safety manual will be prepared for workers, protective gear and activities. I hope this information is sufficient for your review,please call if you have any questions. Respectfully submitted, n Bruce M. Poole, President S P Engineering Inc. BMP/bp TABLE ONE 72 FLINT STREET UNDER SLAB SOIL SAMPLES METAL ANALYSIS RESULTS PID SOIL mg/kg Lead Cadmium Chromium ppm TP -1, 0-4' 27.3 0.60 15.1 0 TP-2, 0-4' 15.4 0.26 2260 0 TP-3, 0-6' 140 2.82 73.0 2.5 TP-3A, 04' 11.4 0.37 8.87 3.5 TP-4, 0-4' 24.4 11.6 1510 50 TP-5, 2-5' 120 1.27 915 0 TP-6,4-6' 145 1.10 897 0 TP-7, 0-6' 12.2 0.56 65.7 0 TP-8, 0-6' 47.8 0.86 196 0 DEP S-2 Criteria 600 30 200 100 * VALUES IN BOLD EXCEED THE S-2 LEMTS,HOWEVER FOR TRIVALENT CHROMIUM THE LIMIT IS 2000 mg/kg. Chromium levels that are from leather pieces,shavings,trimmings and buffing dust were delisted by the EPA in 1985.The site has received fill materials from the late 1800's to—1920. TABLE TWO 72 FLINT STREET, SALEM EXTRACTABLE PETROLEUM HYDROCARBONS Boiler room Color room Soil under slabs TP-3 TP-3A TP-7 0-6' 0-4' 0-6' DEP S-2 912005 912006 912010 Limits PAHs mg/kg Napthalene 0.497 0.401 BRL 40 Phenanthrene 27.3 30.3 BRL 100 2-Methylnapthalene 0.301 0.337 BRL 1000 Acenaphthylene 15.1 18.2 BRL 1000 Acenapthene 11.6 16 BRL 2500 Anthracene 11.7 19.2 BRL 2500 Benzo (a)Anthracene 11.5 13.1 BRL 40 Benzo (a)Fluoranthene BRL BRL BRL 40 Benzo (b)Fluoranthene 11.2 BRL BRL 40 Benzo (a)Pyrene BRL BRL BRL 4 Benzo (g, h, i)Perylene BRL BRL BRL 2500 Benzo (k)Fluoranthene 10.7 BRL BRL 400.0 Chrysene 21.1 20.5 BRL 10.0 Dibenzo (a, h)Anthracene BRL BRL BRL 4.0 Fluorene 20.4 36.3 . BRL 2000 Fluoranthene 24 19.8 BRL 3000 Indeno (1,2,3-cd) Pyrene BRL BRL BRL 40.0 Pyrene 34.3 37.8 BRL 3000 Extractable Petroleum Hydrocarbons mg/kg 912005 912006 912010 C9-C18 Aliphatics 2750 1880 BRL 2500 C19-C36 Aliphatics 3890 2990 BRL 5000 C -C22 Aromatics 2170 3710 BRL 2000 BRL=Below reporting limits (<0.20 mg/kg PAH, 40.0 mg/kg EPH). Bold =Exceeds S-2 Limits DEPTH LOCATION (Feet) TP-1 Finish room HNu ppm TP-2 Color Trench ppm 0 2 Layers concrete 0 Brick over concrete 0 Large stone and gravel Large stone, concrete rubble 1 Coara Brown Gravel 2 0 Concr to slab 0 3 Red Tanning Bark Gravel, ash, brick and wood 4 1 0 Red Tanning Bark 0 5 0 6 Sandy grey clay no GW 7-- 0 GW 0 8 Peat with green silt 9 72 Flint Street, Salem Soil Logs DEPTH LOCATION (Feet) TP-3 Boiler room floor HNu ppm TP-3A Color room footing ppm 0 concrete slab 0 Concrete slab 0 Dark coal ash and grit, stone Large rock, brick rubble 1 perch d water Coarse Black Gravel 2 0 Oily sheen 3.0 3 Wood pieces large, gravel, silt r. 4 Oily sheen 2. Red Tanning Bark, dry 0 5 0 GW 6 Footing bottom Sandy grey clay S GW 0 Peat with green silt 9 72 Flint Street, Salem Soil Logs DEPTH LOCATION (Feet) TP4 Tan Room corner drain HNu ppm TP-5 Beamshop ppm 0 Brick floor, concrete slab 0 Brick floor and Concrete slab 0 Tan sand and stone with black Open air space 1 vein, organic layer 2 50 Yello Crust, grey gravel and ash mothball odor 0 3-- 4-- Red Tanning Bark 2.0 Red Tanning Bark, dry 0 5 0 6 GW 7 g GW 0 9 72 Flint Street, Salem Soil Logs l DEPTH LOCATION (Feet) TP-6 Beamshop 15' from wall HNu ppm TP-7 Center Hide storage ppm 0 Brick floor, concrete slab 0 3 Layers concrete 0 Air space, floor on concrete Tan sand and rock piles 2 0 0 3- - 4-- Gravel, ash, leather, wood, rock 0 5 0 g Black Coal ash Red Tanning Bark Red Tanning Bark 7- - 8- - 0 9 GW GW 72 Flint Street, Salem Soil Logs r DEPTH LOCATION (Feet) TP-8 Fence Co. Bldg. river corner HNu ppm 0 Concrete slab 0 Tan sand and rock 1 2 Grey gravel 0 3-- 4-- Tan 4Tan brown sand 5 0 6 GW 8 9 72 Flint Street, Salem Soil Logs YNFO. � tl 1 6 r z BE9M mss« ,yo. �•�a+n w<oer. O//2 rwlY YMRO 1. Cvrrwr we 1i'•wrnr Tiv.v Y,vo. y. r J C E,rP.r 2'¢� rig NA� R 1( r Y••C.S EO.` r l- If z < Z F 1 L rw�3r r�ccwriswr ':b ♦ `4•s�r' l6RY>;ETj/ �uua i� /« Nc +�tt Tie L ry r P'-01 �CcaS<of Enit / � ��- J 44- 'HEFT .Q Mif III of ilk \ - 117 1 LL I G n: i r, L3 w ` 81LP!PE,� 5AAj €w 0 f G'f0 s.• D 7 RR15 TANNIN "IC6 rw- L g�q Trf o p • i.4 ^ M as ' - s ..: a Ire �r✓''s D IM6 L b Mel �"•� D � ,aa Z Bat wo IL Ff� 14FGKF pa er.: •3 o„ 01 s~ de ♦ Vic. p ;ems M'� J Structures North OO [ [VTMI 60 Washmgtan Sri Suite 401 Salem Massachusetts 01970- 3517 .` 1 .- . , r , C P,0 Box 01971-8560 T 978_745.6817 1 F 478.745.6067 . ➢ wr;rasvuctcres-northe.com 17 April 2014 Salem Conservation Commission 120 Washington Street, 3`d Floor Salem, MA 01970 Reference: 72 Flint Street, Former Salem Suede Site Order of Conditions #64-518, Condition 46 Dear Salem Conservation Commission: This letter is to inform you that Structures North has been retained by Bruce Poole of S.P. Engineering in order to conduct the Order of Conditions, Item 46 review, which is on page 6 of 6 or order#64-518. That condition states, "Prior to start of demolition of removal of slabs, a structural analysis of the riverbank and bulkhead shall be conducted by a registered structural engineer and be submitted to the Conservation Commission. If this analysis concludes that any site activity will impact the integrity of the bank or bulkhead, a work plan, stamped by a registered structural engineer, shall be submitted, describing how the integrity of the bank and bulkhead will be maintained. No activity that may impact the structural integrity of the bank or bulkhead may begin prior to the Commission's approval of said work plan." We have reviewed the proposed scope of remediation on the site, and present the following observations and conclusions: Observations: The proposed scope of work to be conducted by S.P. Engineering is the removal of 3'-0" of soil behind the revetment along the North River Canal. The structure of the revetment is depicted in plan and elevation on drawings 1 and 18 of Mass Highway "Salem North River Canal Pedestrian Bridges and Retaining Walls," dated March 23, 1996, attached as Structures North sketches SKS-1 and SKS-2. The excavation is to take place behind the revetment wall that is depicted on Section A-A, drawing 14 of 18 of MHD drawings noted above. We have attached as SKS-2 the original design cross section of the revetment stone. The revetment generally consists of 2'-0" of stone facing laid up on a 1:1 slope on top of compacted crushed stone and separated from the subsoil with filter fabric. Conclusions: In order to not disturb the revetment structure, the following criteria are established: 1. Excavations shall start not closer than 2'-0" from the visible revetment stone furthest away from the canal. The excavation zone of influence is a 1 vertical to 2 horizontal slope from the 2'-0" mark, as indicated in the attached SKS-2. Salem Conservation Commission Structures North Consulting Engineers 72 Flint Street, Former Salem Suede Site 17 April 2013 Order of Conditions#64-518, Item 46 page 2 of 2 2. The exaction depth for removal of contaminated soils is 3'-0". This depth shall not be exceeded without further consultation with the engineer. 3. If obstructions are encountered in the exaction depth, including old pipes, large rocks, old foundations, tree remnants, etc., and these obstructions cannot be removed without going deeper than 3'-0", then the engineer shall be notified for each specific instance where an obstruction is encountered. 4. The engineer shall visit the site periodically and at the beginning of excavations closest to the revetment in order to confirm that the as-built conditions are in substantial agreement with the original design documents. We are confident that should the above procedures be followed, there is no danger to the revetment structure. Should you have any questions regarding the recommendations of this letter, please do not hesitate to contact this office. Very Truly Yours, Structures North Consulting Engineers, Inc. ham ' OF HA NI Gn L 8 OI T ALP� Edward Moll, P.E. Principal MA Reg No 33718 Attachments: Excerpts from MHD drawings 1 and 14, Salem North River Canal Pedestrian Bridges and Retaining, drawings dated 23 March 1996 C Fu�aT►iFij -�,v,.� Lq,.� y APPROX. EXIST. GROUND SLOPED RIP—RAP (HAND PLACED) l FINISHED GRACE 41 SPRING TIDE E�, 6.50 ! j MEAN HIGH WATER _ = 120 K41N � - EL. 4.60 CRUSHED STONE winisTuP ' EXIST. BorroM 24"1 (TYP.) Fa�twn�+a-� E OF CANAL �'-npC 0 4 MEAN SEA LEVEL 1 EL. 0.00 E 2'-60 - `r - i MEAN. LOW WATER 42" i '" � ` ;.�- -y�yr i. IN L. —4.92 E FILTER FABRIC COMPACTED CRUSHED 5TONE SECTION A-A � ........_.. ............. . _ �.._► . ..._.. SCALE: 3/4"Ste- �� ,�� `, ISS - 2 1"o.Box a so Con,ulr Yugrx T'.U.Hos SSfiO SulcM,MA 01970 srV. A 130+37.58 FLINT STREET caNsr. : � STA. 0+00.04 AUXILIARY STA, 169+9.4,65 OFFSET 161 ,23' L PROP. REP—RAP EMBANKMENT -A STA. 169.1`77.97 OFFSET 144.88' E_ "/ s PROP. PEDESTRIAN BRIDICE #1 (BRIDGE NO. S-01-026) )AK STREET � \ _ 1 AUEfIL€AE7Y � �' 1.... N Y . Ilt�I' i S59*_ '_ PROP. TIMBER BOLLARD PROP. T€1v •� ', TIMSER R.R. BRIDGE BOLLARD GRAN,RETAINfNC, �' ';' ,`'F'•:.�1 WALL A� ter.:::. _ ...., ..... r %G P.U. A A 60 01 .. _.. Salcm.MA 01970 ..-_....... .......-- ��e0*1t71Tgq�� CITY OF SALEM CONSERVATION COMMISSION SITE VISIT FORM ' PROJECT LOCATION: DATE OF SITE VISIT'S PROJECT PROPONENT: DEP FILE NUMBER: PROPOSED WORK: �r.�I G Lxt. INA�EI�"ANGE€' .: mak.. Commission Members/Agent: Abutters: Applicant/Property Owner/Representative: �P"-ac-'t _ sLs m��"�rf "" r ba A '_ SITF��ESI7'DO'CU'�EI�'t�l'f!t1'N ❑Photos ❑ Site Map El Other: ABS�I�Vd'f iIOR3: Take into account relevant aspects or features such as: natural or piped drainage or obvious pollution; topography; existing vegetation; possible alternative sites; signs of wildlife, possible vernal pools, rare species habitat; landmarks; recent or historical disturbances; proximity to other water bodies r drainage areas; adjacent land uses. ENGINE INC. P.O. Box 848 • Salem it"lassachusetts 01970 0 Telephone: 978-745-4569 • Tai: 978�-745-4881 . _ November 28, 2012 Mayor Kimberley Driscoll City Hall 93 Washington Street Salem, MA 01970 Subject: Phase I Initial Site Investigation and Tier Classification Former Salem Suede 72 Flint Street, Salem, Massachusetts RTN 3-30380 Dear Mayor Driscoll: On behalf of Riverview Place, LLC, SP, Inc. notifies you that a Phase I - Initial Site Investigation, Numerical Ranking System Score Sheet, and Tier Classification have been prepared in accordance with the Massachusetts Contingency Plan, 310 CMR 40.0000 for the detection of heavy metals and Polycyclic Aromatic Hydrocarbons at the above- referenced property. A copy of this report may be obtained from the Massachusetts DEP Searchable Sites Waste Site List/Site Files web site htto://ptiblic.dep state mai us/wscviewer/main cisox under Release Tracking Number (RTN) 3-30380. Also attached a copy of the legal notice, which was published in the Salem News on November 16, 2012, the Disposal Site map, and a summary of findings and statement of conclusions from the Phase I report. Pursuant to the MCP, local officials or ten or more residents may request an opportunity for public involvement activities. Such request shall be made in writing to Bruce Poole, SP,Inc., 45 Congress Street, PO Box 848, Salem, MA 01970. The request shall be copied concurrently to Northeast Regional office of the DEP. Sincerely, _fit Bruce Poole, President SP, Inc. Attachment c: Larry Ramdin, Health Agent Thomas St. Pierre, Director Inspectional Services Rebecca Curran, Chair- ZBA DEP, BWSC, Northeast Regional Office without attachment 1 SUMMARY OF FINDINGS Phase 1— Initial Site Investigation The Site, which is vacant, is located on the east side of Flint Street, south of Mason Street, and north of the North River Canal in a primarily residential area of Salem, Massachusetts. The generally rectangular lot contains 3.69 acres and it is identified on Map No. 6 as parcel No. 26- 0091-0. The site slopes toward the North River and based on the topography, the groundwater flow direction is southerly toward the North River. The Site is served by municipal water and sewer. Oil formerly was stored in a 10,000-gallon underground storage tank in the southwest portion of the Site. Electricity and telephone service formerly were provided via overhead lines. Stormwater drains to the North River. According to the DEP Priority Resource Map for the Site and vicinity generated on October 2, 2012, the Site is not located within a current or potential drinking water source area as defined in the MCP. However, much of the Site is located within a 200-foot Riverfront Area and a 100 foot Wetland Buffer Zone. According to personnel at the Salem Board of Health, private, potable water wells are not known to exist within 500 feet of the Site. Therefore, groundwater at the Site is classified as GW-2 and GW-3. The North River (tidal) abuts the Site to the south and is classified as SB. Tanneries have occupied the property since the 1800s; the last was the former Salem Suede that operated from 1978 to 2005. Salem Suede was a traditional chrome tanning facility. Dioxin was not used in the tanning process but is a common impurity in chlorinated phenols that were used in some tanneries. Subsurface investigations were conducted by SP in 2005 and 2009 and by Weston& Sampson in 2012 as part of the Brownfields assessment. Laboratory analyses of soil samples collected detected the presence of elevated concentrations of the metals arsenic, chromium, lead, nickel, several hydrocarbon fractions, and PAHs. The latter are believed to have originated from the use of coal in the former boiler the ash from which was spread on the Site. Also the fire in 2009 likely contributed to the presence of the PAHs. In addition, an Imminent Hazard condition exists due to the presence of elevated concentrations of arsenic in the surficial soil in the southwest portion of the Site. Immediate response actions included the completion of a six-foot high chain-link fence around the perimeter of the Site, posting of warning signs on the fence, and covering the arsenic-containing soil with a 12-inch deep layer of"clean" soil. Exposure Point Concentrations are less than the Method 1, S-1 cleanup standards except for the Cg-C,()Aromatic hydrocarbon fraction several PAHs, arsenic and chromium. Groundwater samples were analyzed for VOCs, EPH, metals, and PCBs. None of the analytes were detected at concentrations that exceed the Method 1, GW-2 and GW-3 cleanup standards. SP has classified this Site as a Tier IC disposal site based on an NRS score of 368 points and the presence of an IH condition. Additional response actions will be conducted in accordance with a RAM Plan that is scheduled to be submitted to the DEP in early December 2012. RAM SOIL REMOVAL •rP-1 1C &I / SOIL STOCKPILE EQUIP� 710 ♦ FINISHING DECONTAMI BI 155 N�TION � /a / ♦ /� SLAB AREA I B2 178 C TP-2 17 D . / ♦ F'' ♦ p Op 90 \ RIGH T OF E 90 0 2e • vacuum ppTB 21- �_�_�J OTB-9 F 592 OFFICES / ue G 355 _ _ p prlriw ❑p 8811189 ♦ � r 234_8 CY TOTAL / PgUits Roo\ � I I �♦� � — Grit SS-, -J i .� M TP- O 0 ar ��'9r"l I T 3A TB-6 A A,TS-1 —7 — i ueae.9.aea saepar.�11 �l I ' ___ • { I DumPst rtdW-4 � '� int-�2001 9'-o'Db.2r.e � ' &_1. ` DI 2�-T 1RIVER _ (REMOVED a-991 4*W ,L1477T , TB-6 R Tra '�s0'�'�"�� oo E Su t TOOL 1�-5. -5 Fence Co. BUFFER ZONE E ' i g • ROOM STB-5 „�.>\ _ .:=.—TP_ .yy n /Ewgouna,ao.el.voll �IQOOOI � Tp 0. 11 nwnIth 12a D r.o.0 TP-8 enowEL 19.5 �,tT*SI� e � I I Formic Fat �4qq��8 E _ I --- 2 e 1 1 WET•Nl DE'Z1V"• . �.TB•10 Jwy,.,,j-- — ;'• ' BMW` R Tp_7 ♦ E MW_6 —100' U- Q- '-- - OTS-II BUFFER EROSION LOG Bogs of o i Bags of M -.B Sluo�e i�Du: EROSION LOG I t I ° cc yy.ewM, y�qy.w YC m¢ ProMiY Llm SITE PLAN TB-TESTBORE �® 3 MW=MONITORING WELL - - SALEM SUEDE,INC. SS-SURFACE SOIL SAMPLE ✓✓✓ RIVER CANAL (tidal) 72 FLINT STREET NORTH SALEM,MA ' �TURE PHASE II 2009 TEST PITS SCALE1 In=40' SP INC, REPORT 2011 TP-ITO80 25 TEST BORES ♦ 2-21-1I 10-10-II - 10 MON. WELLS FIGURE 2 I Public Notices Page 1 of 1 esI ! wti W�•''M PT P3;+cx. MYw.2 'v 5`w Home Wednesday, November 28, 2012 NOTICE OF INITIAL SITE INVESTIGATION AND TIER I PERMIT NOTICE OF INITIAL SITE INVESTIGATION AND TIER I PERMIT APPLICATION Former Salem Suede 72 Flint Street RTN 3- 30380 A release of oil and/or hazardous materials has occurred at this location, which is a disposal site as defined by 1,1.G.L. c 21E, § 2 and the Massachusetts Contingency Plan, 310 CMR 40.0000. To evaluate the release, a Phase I Initial Site Investigation was performed pursuant to 310 CMR 40.0480. As a result of this investigation. the proposed permit category for the site is Tier I C pursuant to 310 CMR 40.0500. On November 5, 2012, Riverview Place, LLC filed an Initial Tier IC Permit Application with the Department of Environmental Protection (t•lassDEP) pursuant to 310 CMR 40.0703 and 40.0704. A permit is required to perform Comprehensive Response Actions at Tier I sites. Anyone interested in reviewing the Initial Tier I Permit Application should contact Bruce Poole of SP, Inc, the applicant's representative, at 45 Congress Street, Salem, MA, 508-745-4569 to request a copy of the Application. Written comments related to this Application must be submitted within 20 days of the publication of this notice to: (1) Massachusetts Department of Environmental Protection, Northeast Regional Office, 205B Lowell Street, Wilmington, NA by mail or by hand delivery during normal business hours; and (2) Bruce Poole of SP, Inc, the applicant's representative, at 45 Congress Street, Salem, 14A. Failure to provide written comments as set forth herein may affect your right, if any, to challenge MassDEP's permit decision. The Application and the disposal site file can be reviewed at http:// p hf r at ma us'wsNewer( main.aspx or at the ticrtheast Regional Office, 2058 Lowell Street in Wilmington, FIA, 978-694-3200. Additional public involvement opportunities are available under 310 Ct4R 40.1403 (9)and 310 CPIR 40.1404. SN 11/16/12 Appeared in: The Salem News on Friday, 11/1.6/2012 Pr nter-fne'dly version E-mail oo a_`n Hume I Privacy Policy I Terms of Use I About Us I Contact Us ,r;Copyright 2001-2012 Leaac .com All Right--- Reserved _ . .. ., _.:,n.._..D„ I,•.u,.d,- .¢• Arlltl=?975137 11/23/2012 RAM SOIL REMOVAL �' 22 6TPI I ' � r AREA SY EQUIP �- 710 i h mica DECONTAM NA TION R Q Af i B 155 St rage AREA \ % / 3 r B2 178 / 0 WIN C 90 SOILTP- 2 Storage _. R I G H T O D 178 / A STOCKPILE 0'-21 0OTB- 21-41 SECOND E 90 i. SLAB - f SOIL STOCKPILE OTB F 592. R - OFFICES p0 Bellies J ON SITE CONCRETE l eter prinkler G 355 r H 130'- / I - PI°� - . Polls ► - DISPOSAL CELL AND BRICK ' � L STORAGE 2478 i Y TOTAL � fz, i I � — — a... ... /- \f / / \\R l l . C { � ... mss. , r I `-�� Plug ! e � ssssk ' t TP- 0 !1 Grit SS �/ ii 6°Dameste.t' i d T -3A TB-6 Q ,-' 1 1 0 _ 8" water Line _ _f� � '��{( - _ S I MW-4 ^ 200 TB-I --Underground Storage Tank No. l i- �__ _, , , Dumpst r 1_ 1 /r DRIVER 9'-0" Dia. x 21'-6"Long — 2 7 1 TB-8 BUFFER ZONE (REMOVED 6-99) 0 4" ter Line 1 - I -5. MW-5 Fence Co. ® � Tu farmers E F t TOOL 00 •� a a" prinkler–� ` oo Liquo PpON4, � yd. .Ira — Berm " ev�� --�-0 ITB-5 IMert 9.94.5\ r== 6eeenpt - t - Earth • Invert 9.9 M% f 1 Veter T --- - Pum,pit TP-8 - W6 - N2�r Aboveground,double ally lop o% wall 4o5M M75 ..�- 010,000gal,steeltankwith 12 x Ei. 19.5 O • • �_ � 32'x4'enclosure o 0 1 � / Formic 81 Fat --��PP 56 – ' .E.. / Liquor. 2 $�' pppP0aibiiam PR cr W-17 H I D C T I " • tea♦..TB-10 1 Prop. ARo a+aowRE 120o I 0 NAW-6 ' --100 r ±T as Invert' 5-G /- Eart-h tanks I 'E � TP- 7 - BUFFER P0rlm1 . StakedHayHay Bal, S. 'E21. �M - Berm al a,w,,,, , T-ole i I Berm Invert 67 Q_S�{L ie,13.4 (ume 1 111 OTB-II I Invert 6.9 1 �I I e Caustic Tanks,a Pump Alienate 18! 1�' KKKKp` I Bogs 21 41 EROSION LaG EROSION LOG Bags:f S ED AI8 - o I Butfin� Du: I I CR III Sludge Ch rTP- 6 , AI I Staked Hay Bale I, Mt .esL. 1971 /Treatment rank Fea 1 t— -; aProparty Line _ O b Sim F�GFI• L PAM AND ST & Silt Fence SITE PLAN Inver. 0, 2 1 STACK 4 M,ving Bridge Sludge- PROPOSED 01 '� % - RemwN I Ed e g of Bank O 7 ._ � . \ • Mixing ra:amber __ -- Ian M.H.W.9.03 Porce Main - �" TB = TEST BORE RIPRAP See Tie In SALEM SUEDE, INC. MW=MONITORING WELL REVETMENT Detail CANAL ( tidal) 72 FLINT STREET SS= SURFACE SOIL SAMPLE I DETAIL : -ORTN F'c1VER SALEM, MA 1 -7-13 �FUTUR E PHASE '11 2009 TEST PITS SCALE I"= 201 2-6-12 REPORT 2011 TP-1 TOB SP INC, I-9- 12 25 TEST BORES ! V FIGURE 2 2-21- 11 10..- 10- 11 12-5- 11 10 MON. WELLS 19 A A 10 %A^kII'rn0(' FIN i S H IN G \ gV \ RIGH T O OFFICES _ WaterMeteretSprinklel -_.... PAVED CO) Plug O / ) d / 6 only wast)�I - L ; - _ 8" Water Line _ _f�_ I I Underground Storage Tank No. I / 1 i l i 0 ! I FORMER LAGOON ' / ' R DUMPSTER l 9'-0" Dia. x 21'-6°Long - ('REMOVED 6-99) / 4"Water Line — — — 1 - (d Transformers - "-0 �_ STORAGE / BaSprinklerJ� TOOL _ _ _ — — -- - '� - --- ROOM --� / MV,A rim 14.5It i Screen Pit / r Transformer mver1 9.9 - --_ /Meter _--- w6 _---- New Aboveground,double-wall; Topoiwall �/ O I0,000gal,steel tank with 12 x / - asoD segs Pump Pit - 32 x4'enclosure E!. 195 c, p / - CHEMIC _ � � STORAGE I Z M,.E.. J?J?,, O T G I 1 It PROPOSED BELT PRESS i Cr �➢r>� H I D E S . rim 13.1 / ProP .Y I AND Etd(xDSUR 1 1200 �"— Invert 7.45 / gas Pump Pk I e� B - / ton ks 1 1 •aL>%» -" I I J MICH. Invert 13.6.7 t 5 / all 13.1 ---O---------- 1 I - Raw Wostewaler Transfer Panic W Brim 13.4 • ---- - Q- - -fume - - I FAT LIQUOR - ' ! Invert 6.9 pole _+I lO Caustic Tanks 6 PUMP 1 f _ t / I O y,— I_ 1 • - Abandon - 1$• No Scale I MixeY I Ir PROPOSED AIR --- 1 ' I SCRD9BEfi TAN N Chemical Dust 1 1 I T-� 1 Mi 1 S.ESD. 1971 Treatment Tank -Feed box I I O O b Rim 12.1 —_ - Invert 6.0/12 1 duildm9 O II I L------ Pro Perry Line M."I Bridge Sludge, I .0 IIr(J� Removal I I PROPO - i + Mixing Chamber DUCT -" y of Bonk _ - E Sludge Storage Edge Tank - - - Forty Main ct� M.H.W. 9.03 RIVER CANAL ( tidal) FIGURE 3 rIORTH SITE PLAN PAST CONDITIONS 72 FLINT STREET SALEM, MA - SP, INC. 1 - 7— IS E,-57 Z� xK, F 0 C) 0 — ledge Hill R T. R'C4 d Btenn Equipment Cleaning Existing Slabs OCKP W- L 6 IL Elev. I 1.6-t "RAM SOIL Cr I F REMOVAL 1 JI Depth of Excavation 2 -4 0- 2' AREAS : A— aSAREAS 7 ISO SAS 5' ISO oun I or ron dory A 2 - 7 1 EP too D PAH I'-4' ♦ As, Cr, Pb COCS 3Fj w I , \' 1. 40 C Pb or 100 Feet R �A ICE Pb � 2 -4' �O- -------- GAS 10 G No Scale ��Ai� Monitoring Station ( TYPA 071 FIGURE 4 L As Cr Pb 21- 6 'TISO SITE PLAN ucU C ---- --- ------- CURRENT CONDITIONc CCr ommonweQtt 1h bf As Massachusetts` B Dioxin "�Dralm 72 FLINT STREET in I — BUI-KHEAD SALEM , '� R%PRAP -28-13 S S INC. C-Al FLOOD A "KT A T 1 g•t ,.t . 165 S/L + RI-I - Q"61 --- 73 t!_ ¢ Proposed Building No.-3 � 24 Units 3&� 5000 SF Commercial Space 9 a Mock Park Condominium 24 Ledge Hill R.T. m - - Richard Brennan, Tr. _ �+ George E � Cobb Astero 41b Deligionnidis LD L I 6all � IY EL:— -- UTILITIES F =5' ( I7P.) Chars E' o� �� R=10' _ i Bo & Rifa A. — i hannon �N Dumes f er J I6s DISPOSAL CELL PadP �- m Daniel & ---r — Judi Li#t-w i` —T Add']. Disposal 251 I84 &orrrnda f - 6 Areas I Garage Spaces I Harvey _+ J 200 Foot Riverfront I _zo` .i, Bu Id Proosged oo BOUndafy Y &2 No. 2 UTI LITI S E t Floor 11.5 tea' IEWT 42 Units o0 011 20 Garage SpacesCD va o —D d a -- Proposed Building No. I 11'' r 8 C ' 64 Units v Floor 11.5' 100 Feet from River ERoss- FR WALK- o H � I o q> c o I' = 40r •o Green Space. co BP \ 24 FIGURE 5 c° LANDSCAPED ( ) o/ SITE PLAN In I R=io' - °2 ; FUTURE CONDITIONS XoA. �'� FLOOD PLAIN 72 FLINT STREET R' 9'EL. — —UTILITIES — /— 10.3 SALEM+ MA 00 - WIDE SP INC.WALK s PROPOSED 6 1 -7- 13 I -7R- I� \ e �- } ct 14 f4�` � j. r e , t � _ �v a A Hozmot / Trailer \ (_ RAM SOIL REMOVAL . 2��TP- I ® EQu1P ` a AREA CYY / SOIL STOCKPIL �L h mica 710 A St rage DECONTAMIA�ATION \ Q AY 0 B1 155 AREA \ 0 B2 178 % I 3 / _ � � o wN 90 TP-2 Storage \ R I G y 7 O • D 178 A F I 0 TB-7 0 E 90 i. 01-2' L B 0 2'- 4' SECOND �- • F 592 JUR OFFICES SOIL STOCKPILE OTB-9 eters v CONCRETE 0 0 Bellies G 355 _ - Plea rmkler Palls 0 2348 CY TOTAL AND BRICK I ~ STORAGE / 1 • Roof i I u9 C — • I Gr TP-SS-I bPI l i TP- 0 6Dopmesteaste 1 T -3A TB-6 e°Water Line _ -�j{ l 1 1 MW-4 1 200' • TB-I —UndergroundSiorogeTankNo.I — -�— `-t—�' % 'RIVER 9'-0" DID. x 21'-6"Long i I -- - p l' ' Dumpst r 2._7. TB-8 rzEnnove0 6-99) oO 4"Water Llne:�T _ — ' BUFFER ZONE i Trpnstprm¢re £ F f TOOL I -5. MW-5 Fence Co. / - - g .B"Sprinkler-� O ' •lTron _ 00 LIQUO ® ROOM • .00� .0 —�. --0 1 AH.Arim14.5\ Screen pt 'TP-4� ' Earth Berm % ev lTB-5 Invert 9.9 ��'' -^ ♦ / M -------0- A 0 Meter _ i,�ys- j q =-=--- P„ TP-8 " N2W AbOVegroUad,double�rroll,; Top of wall 4500- 5ey5 Pem • --'�°"- �lo,000go,l,steel_tankwith 12 x EI, 19.5' o o0 y, 1�'�1 _ I— 32'x4'enclosure A — 0 0100 Formic a Fat o TP �j �' M E,. Liquor 2 8�f PRO P09ESeF1TPR �� — I D • Prop VV I AND 00.0S11NE 1 1200 WET H TB 10 5 / took „ --7- ♦ MW-6 - 100 Invert \ ttt tanks 0 MDrml3 Staked Hay Bol 5 _2 Berm ell �" Tom,,, i 4I TP- 7 BUFFER 81 Silt a -- �w��b" Il Berm TB-II -j=r' 6i m E2- OM _ (y t3A 1 I; p O LL. T Invert 6.9 t (�}� futie it 1_o CousNe TaMGB Pump N • II I L4G AEpndo 1�' t 1 Bags 02'-4' 0 I EROSION Mh- --- Bags of �RpEpptR 0 I . B uffinDue I ® EROSION LOG v i I Sludge �DeeER ist • - AHI S.E3L. 197I /Treatment Ttmk F t' TP-6 . ; AI -..Staked Hay Bale - j . o av\ ` m 4 Property Line00 &-Silt Fence• O ! Mng erRlge Sludge: PRopoSED•FAN AND STACK SITE PLAN I% • I �O • Mixina a�pmbee ._.. Edge o f Bonkio - Too �o`- • - - Force MPIn r .' 1 • TB = TEST�E See Tie In SALEM SUEDE, INC. MW= MONITORING WELL Detail R CANAL ( tidal) 72 FLINT STREET SS= SURFACE SOIL SAMPLE �f = NO R'r}-{ Fc 1 V E SALEM, MA 0 y FUTURE PHASE II .' 2009 TEST PITS SCALE: I"= 20' REPORT 2011 TP-I T08i '- 0SPINCP 1-9- 12 25 TEST BORES A 2-21- 11 10- 10- 11 12-5- 11 10 M,ON. .WELLS & FIGURE 2 • Haz Mat • Trailer Generator • w 1- ! EXIT f • 1 • Existi:ng • Concrete Sump Pumps • Stab 2" PVC Frac Tank No Liner A • Ex V .. or 40 Mii HDP • Exist. 6" Wall Cleaning • 4" Berm 5 I' • — =-= `- - I 1�30' Concrete .'Union , • Lined •DECONTAM.IkNATI N AREA Truck I 6" C 1-e oning I Plate • • Slope • 40 AAiI HDPM I 4' • • 4" Berm I • S-SECTION A • • Liner 81 Sump DefaiI �t Fence ' Back • iFIGURE THREE DECONTAMINATION AREA • N RAM SOIL REMOVAL / •TP- I r AREA CY_ SOIL STOCKPILE EQUIP / 710 ♦ F I IN I S H I NG DECONTAMINATION Q A BI 155 SLAB AREA \ B2 178 I / C 90 O0O \ IGH T pF D 178F TP- 2 ♦ OTB-7 I E 90 / I 0'-2' _0 vacuum OO 2'- 4' �TB -9 J O I F: 592 OFFICES ue G 355 O O Bellies 1 __.. r eter 6 Prinkler -: d , Plug Po I ls / 2348 CY TOTAL ~ A Roof / �.. plug �- j Grit SS-I J/ / I I il TP- 0 J �- /r e"Domestl.°E!�'i T -3A TB-6 A ,-� _ r 2001 8" Water Line _ _� ( � MW-4 •� .� `` TB-I -UndergroundSfomgeTankNo.I — -_ _ DUmpst r , , DRIVER 9'-0" Dia. x 21'1 Long d— I D I 21-71 TB-8 (REMOVED 6-991 / ¢/ 4°Waterline — - £ :� F t TOOL I '-51 MW-5 Fence Co. % BUFFER ZONE Transformers • / / 8"Sprinkler—� 00 LIQUO `i , Hyd •kTran ___ ROOM Mi,A rim 14.5\ ' S°reen pit TP-13 � 'i % v (TB-5 - Invert 9.9 �� - • I Meer N2x Above round,double7Nall ' W6 - g M Ta at wan =-=--- x TP-8 - -- - �10,000 al,steel tank with 12'x P - 4sr 5BI wmp p+^ 4 � - EL 19.5' O • r I-- / 32'x4'enclosure 00 0 I y: to goo •E --v / Formica Fat oa 0 ° Z f ' NWHI �., - Liquor 2 Ci T�osEPBE E7 PR j cr I I �LSa °�RW {1 D ' .� CI Prop , AND ENCLDSUR I 1200 1' WET . --...,..TB-10 • ' Invert 5 tanks I I-_�, I • MW-6 L lj Mi Orim l3.� °S- E2'_ e2 - ali - .` my wostmmlariM%fM F 'qV R TP- 7 BUFFER Invert 6.7 —0---- W MiBrim 134 4 (y --- fume Cowie TUNEB Pump L OTB-11 - I _I Abandp — 1 Bags 2'-4' EROSION LOG --- g MiEEt __ EROSION LOG O 1 I Bags of PRO PO6EDAIR� :BUffIn�.DU: SCRU�BSi �l . 1 I Sludge _Cherry �Omr' I TP-6 Mi S.FSL. 197i /Tr epiment Took Fee�7 . 0 0 b aim ;2.1 m L----�----_-! Property Line Inver: 6.D/L2 F� , l -� ' O I .\` MOWng Bridge Sludge. I - PROPOSED`FAN AND STS" SITE PLAN 0/ Rommel i ou 1 �OO• o . - �to /T Edge of Bank Mxing Ohomber Sludge FI Main, T103 M.H.W. 9.01 B i ' 1 TB = TEST BORE SALEM SUEDE, INC. MW= MONITORING WELL 72 FLINT STREETRIVER GANAL ( tidoI) SALEM, MA SS= SURFACE SOIL SAMPLE � NO RTH I ✓,. FUTURE PHASE i l . . 2009 TEST PITS SCALE= 1"=401 REPORT 2011 TP-1 TO89 SP INC, 25 TEST BORES ♦ FIGURE 2 2-21- 11 10- 10- 11 10 MON. WELLS i Chemical Storage Trailer 10' Wall Haz Mat Trailer Generator Soil Stockpile Slab EXIT Existing Existing Concrete _ _ _ Sump Pumps 2" PVC 6'Wai1 Slab A Frac Tank No Liner ExcdJotor 40 Mil HDPM Liner IL Exist. 6" Wall Cleaning 4" Berm 1 I 30' Concrete Union I �� Lined I PLAN : DECONTAMINATION AREA Truck I 6" Cleaning I Plate slope 4C Mil HDPM I 4' Liner a II Berm 4" Berm_ J X10' SECTION A Liner 8i Sump Detail Flow Double SIIt Fence Angle Attachment to — Buried 12" Back Building Slab Footing — _ 2 Hay Bales I /2 I/2 River . 2' PLAN 10' EARTH BERM DETAIL 6x6 Angle 6Redhd.- _ t /S" " Threaded Rod I j Wood Plate Double Silt Fence 1 Hay Bale '- - — ` Buried 6" SECTION TIE IN DETAIL NO SCALE REV. DATE DESCRIPTION BY SALEM SUEDE 72 Flint St. , Sa iem , MA DETAIL SHEET [PENGINEERING TECHNOLOGY 29 Congress Street • Salem, MA 01970 • Telephone: (617)745-4569 DESIGN BY JORAIVII BY CHECKED BY I DATE PROJECT N0. SHEET NO. BMP ETA 12/11 l of AI - HazMat� - `, ,� - ......... ' RAMOIL REMOVAL _ 2VOTP 1 r Trailer AREA SOIL STOCKPIL EQUIP` r-" A 710 , - h mica AIR B 155 St rage DECONTAM ATION 1 AREA 3 B2 178 - . . C 90 'Storage ,. RIGH F WN D 178 � F - TP - 2 TB 7 � � T E 90 p'- 2 ' ,_:: � 00 21 - 4' SECOND —� F . 592 /ItFR 5 L B ;n, r . _ SOILS OTB -'9 OFFICE ue TOCKPILE TB 9 G 355 : ... - . • Bellies r e#erapr'nker PIus Pall s ® CONCRETE / ' 2348 CY TOTAL �t AND BRICK fx' i I STORAGE G t /� `/ Plug P _ �s anew �r mom ...,. r& ••.. 4111111111110 � i SS - 1 �, l �l If 0 6" aomest waste T — 3A TB -6 -Q 0 TB - I8 Water Line Underground Storage Tank No. I , =., 200 I 9'-0" Dia. x 21,-6" Long i ; . , Dumpst r 2 ._ 7 • � R1VER 4" Water Lin -� — -- Dil TB -8 (REMOVED 6-99 ) '/ - 1E F 1 t-5. ' MW-5 Fence Co. ® ' � Transformers � TOOL BUFFER ZONE t Hyd. / Tran S Sprankier , 00 L iguo E � / __ ROOK! ��•� -''`�� T� —� MI, A rim 14.5, % Screen pit ' TP- Earth Berm V ® Invert 9.9 I Meter `,/ / M �� .— _ — _ _"�-- Q /"' ► WG _ — N Aboveground,double-waII Top of wall x ,J / ' IO,000gaf,steel. tank with 12'x EI . 19.5' p� , ' c500 �r5 Pump pit TP -8 �"— 32'x 4enclosure 00 p , , in� St�, r e / - Formic & Fat TQC o� - ,moo ! ..®"' °" „ z I " " Liquor TP� ' DE q O 2 0 PC;§SELT PR Cr O 0 Prop. 1! AND ENCLOSURE / ry120 WET H ® e STB - 10 Invert 1!4-52 E a rt-h ta�k5 , , o M W- 6 ' Staked Hay Bal i,s. 2� ® pail i TP - 7 100 .J WHDrim 13. p� •� - Berm I n ve r f 6.7 0[ S I �- - M W— 1 w` avr Wastewater Transfer i ; RM B rim 13.4 v Ber BUFFER Q }- m � lame Invert. 6.9 _ _ l� Cowstic Tonks6 Pump I I �� — I + 18C t 0TB II LOG Abando Ig" .[� " — G 2 '— 4 + � EROSION I Bags of M;xe� _ - EROSION LOG o I Bags of - -- - o I Baffin Du; i ® SCRUBBER AlR i I Sludge DistCh ' Mil TankT P- 6 ` (� S.E.SD. 1971 Treatment Fe Oar Staked Hoy 'Bale 0 O Rim 12.1inifin Invert 6.0/ 1:2 !!! -=_— — Property Line G V I L— 4 8c Slit Fence F y O ` Moving Bridge Sludge. C PROPOSED•FAN AND STACK-- % R SITE R emoval } I PROS SE PLAN, I O Mixing Chamber 7 forage — _ Edge of Bank Main Ton , M.F{w. 9.tJ; Force _ TB TEST BORE , See Tie In SALEM SUEDE INC. MW = MONITORING WELL Detail RI \ ER CANAL ( tida-f ) 72 FLINT STREET S S = SURFACE SOIL SAMPLE T H. . SALEM, MA FUTURE PHASE i l 2009 TEST PITS SCALE : 1 " = 20' REPORT 2011 TP - I T08 O SP, INC , 1 - 9- 12 25 TEST BORES A 2 - 21 - 11 10 - 10 - 11 12 -5 - 11 10 MON . WELLSFIGURE 2 --m-4---AIR- MONITORS RAM SOIL REMOVAL -'. HazMa2 p _ t r _ ( , TP 1 T aifer AREA CY - EQUIP` h � I J 'mica AIR B 155 DECONTAM AT ` BI _ St rage ION AREA Q • y u B2 178 3 C 9 0 - _ , ( � p WN ---_ D 178 SOIL TP - 2 Storage G � 90 STOCKPILE 01. 2 0 p 4` 0 ` IR � SLAB F 5.92 - 0 OFFICES - ue S.01L STOCKPILE T13 - 9 G 355 fl Bellies ON IT r peter & SP r i nkt>✓r - - __ I .. . . Plug - SITE / Polls CONCRETE 2348 CY TOTAL t DISPOSAL ® CELL AND - - ` RICK Roof j ®,gym � �, .� it ... TO r AGE j Grit / \� Plug ® �r ® SS - I _ i t TP - p ---� r I �- .,, ft 0 6° Danmestt>r wasfie i T A 8" Water Line �' A TB �6 A, ..` TB - I I . Q } MW-4 f- - - - - Underground Storage Tank No. I w� � � . .- . �_ , - _ - ,R Durnpst r , ,� . 6 200 I 9 o Dia. x 21 -6 Long ® , �. Di ' 2 - 7 � 1 RIVER (:REMOVED 5 -99 } � � 4 Water Line TB - 8 i ® ® Transformers - E C j I – M*5 Fence Co. BUFFER ZONE ® �/ 8;'Sprinkler _-� 00 1 ( TOOL. Hyd. Tran 1 Oo L �quo w+ pOQ � /'' M-I ; A rim 14.5 1 � % Screen pit - - / TB -5 TP Earth Berm invert 9.9 Meter �r M — w 14d Aboveground,double-wall; — - Qom- .. ® .� IOC OT WOII _ X _ . I 10,000goi ,steel tank With 12 x EI • l9.5 TP 4500 .5875 � - � C Cr Cr Pump pit 32 x 4 enclosure � , o Formic & Fat a� �l y. �� t� r - 0 4000 E BELT PR :. PRO OS� Cr ' - ` 4 5 / 0 a -0p w.i ' , # AND ENCLOsuRE 1 1200 W ET ! ' e Invert gas . � � a STB - 10 2 Earth I �h t `� - – tanks . Staked Hay Bol, t, - E2 .: ,� fv1-IDrim (3. SB Berm wall l ; TP - 7 MW- 6 a X100' Inverf 6.7 �( Si Lt e= — — – Transfer _ tt ofl ( AM 8 rim 13 a �, a Wasted N ii B e r m U. T � Invert 6.9 r0� l l 'i BUFFER ' d + �il ',.�0 Caustic Tanks Ex Pu,P i ; I. OTB – 1 1 t- EROSION G2 � 41 ' LGGAbend Mixes l Bags of I o l Bags of - ---- v - Buffin e e PROPOSED AIR i Due EROSION LOG ` S I U d e SCRUBBER 1 st I Mi 1 S.F-S.D. 1971 100 9 C C Drax , p 1 t Treatment Tank T ,- - I A I StakeHay -Bale O O O 1 Rim 12. I � ., in 1 i -- —_- Property Line � Invert 6.0i1:2 8i Silt Fence °pe �y O ! �� MoWng Bridge Sludge- •C PROPOSED-FAN AND STACK. 4 Removal l PRO SITE PLAIV 0 I DUC ^ l `O C amber f O Mixing .,h zmu. Edge of Bank TanForceMainHu. '41. 9.04 TB = TEST BORE s _ RIP RAP See Tie In MW MONITORING WELL r SALEM SUEDE , INC. REVETMENT Detail . SS = SURFACE SOIL SAMPLE ! p i � CANAL ( t id'a -1 ) 72 FLINT STETAIL �TBEET SALEMNOR , MA FUTURE PHASE I I 2009 TEST P ITS E : e °�� SCALE : I 2 - 6 - 12 REPORT 201 f TP - I TOB Q �' S F; INC - 1 - 9 - 12 2.5 TEST BORES � 2 - 21 - 11 10 - 10 - 11 12 - 5 -. 11 10 MONO WELLS 4 AIR MONITORS FIGURE 2 Chemical Storage Trailer 10' Wall i Haz Mat Trailer Generator Soil Stockpile Slab EXIT J NEW STONE RIP RAP Existing soil or backfill I foot thick 6-12"stone Rounding with 30%silt and clay 4' Gras Existing III= Concrete Existing Slob _ — _ Sump Pumps 2° PVC ° IIS 6' Wall 2 A 1 Frac Tank oDo°ao��I` I ODDp No Liner dd`'aa°v°��r Geotextile mat ExcbOat0 Exist. 6" {Pall Cleaning 40 Mil HDPM Liner Existing � Q _ 4_Bermr+ _ I It ii Rip Rap QQ ��— Redding gravel 6" — I 30' Concrete Union - - _ 3"minus Llned - PLAN : DECONTAMINATION AREA Truck I 6" Cleaning I Plate REVETMENT DETAIL-SECTION Slope 4C Mil HDPM I 4' 4° BermLlribt a I' Berm _ J r SECTION A _ Liner Es Sump Detail Flow Double Silt Fence Angle Attachment to _ _ Buried 12" Back Building Slab Footing 21 Hay Bales I /2 I/2 River ' 2 PLAN lo' EARTH BERM DETAIL 6x6 Angle 1 6" Redhd.--1 I /8" Threaded Rod I { i Wood Plate Double Silt Fence I 1 Hay Bale 1 J - - � — Buried 6" SECTION 1 2-6-12 Added Revetment Detail EA TIE IN DETAIL NO SCALE REV. DATE DESCRIPTION BY SALEM SUEDE 72 Flint St. , Sa Lem , MA iL DETAIL SHEET c � 3 r4 VV1.yVJi�`�~ l ENGINEERING • TECHNOLOGY 29 Congress Street • Salem, MA 01970 • Telephone: (617) 745-4569 DESIGN BY JDRAWN BY CHECKED BY I DATE PROJECT N0. SHEET NO. BMP ETA 12/I I 1 of