34 Peabody Street Phase I Environ. Site Assessment
ASTM-AAI
PHASE I ENVIRONMENTAL SITE ASSESSMENT
34 Peabody Street
Salem, MA 01970
April 12, 2021
Prepared for:
North Shore Community Development Coalition, Inc.
102 Lafayette Street
Salem, MA 01970
Prepared By:
33 West Central Street
Natick, MA 01760
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TABLE OF CONTENTS
1. SUMMARY ......................................................................................................................................... 1
2. INTRODUCTION............................................................................................................................... 3
2.1 LOCATION AND LEGAL DESCRIPTION ............................................................................................... 3
2.2 PURPOSE ........................................................................................................................................... 3
2.3 SCOPE-OF-SERVICES ......................................................................................................................... 4
2.4 SIGNIFICANT ASSUMPTIONS .............................................................................................................. 4
2.5 LIMITATIONS AND EXCEPTIONS ........................................................................................................ 4
2.6 SPECIAL CONTRACTUAL TERMS AND CONDITIONS ........................................................................... 5
2.7 USER RELIANCE ................................................................................................................................ 5
3 USER PROVIDED INFORMATION ............................................................................................... 5
3.1 TITLE RECORDS ................................................................................................................................ 6
3.2 ENVIRONMENTAL LIENS OR ACTIVITY AND USE LIMITATIONS ......................................................... 6
3.3 SPECIALIZED KNOWLEDGE ............................................................................................................... 6
3.4 COMMONLY KNOWN OR REASONABLE ASCERTAINABLE INFORMATION .......................................... 6
3.5 VALUATION REDUCTION FOR ENVIRONMENTAL ISSUES ................................................................... 7
3.6 OWNER, PROPERTY MANAGER, AND OCCUPANT INFORMATION ....................................................... 7
3.7 REASON FOR PERFORMING PHASE I .................................................................................................. 7
3.8 USER PROVIDED REPORTS ................................................................................................................ 7
4 RECORDS REVIEW ......................................................................................................................... 9
4.1 STANDARD ENVIRONMENTAL RECORD SOURCES ............................................................................. 9
Comprehensive Environmental Response Compensation and Liability Information System (SEMS)
– 0.5 mile ............................................................................................................................................ 10
Federal RCRA Corrective Action Sites – 1.0 mile ............................................................................ 10
State and Tribal Brownfields – 0.5 mile ............................................................................................ 10
State and Tribal Releases– 1.0 mile reduced to 0.5 mile ................................................................... 10
Non geocoded Sites ............................................................................................................................. 11
4.2 ADDITIONAL ENVIRONMENTAL RECORD SOURCES ......................................................................... 11
4.3 PHYSICAL SETTING SOURCE(S) ....................................................................................................... 12
4.3.1 Topographical Map ................................................................................................................... 12
4.3.2 Sensitive Receptors .................................................................................................................... 12
4.4 HISTORICAL USE INFORMATION ON THE PROPERTY ........................................................................ 12
4.4.1 Site Subsurface Investigation ................................................................................................ 13
4.5 HISTORICAL USE INFORMATION ON ADJOINING PROPERTIES .......................................................... 14
5 SITE RECONNAISSANCE ............................................................................................................. 15
5.1 METHODOLOGY & GENERAL SITE SETTING .................................................................................... 15
5.2 EXTERIOR OBSERVATIONS .............................................................................................................. 15
5.3 INTERIOR OBSERVATIONS ............................................................................................................... 16
5.4 CURRENT USE OF THE PROPERTY.................................................................................................... 16
5.4.1 CURRENT USE ............................................................................................................................. 16
5.4.2 CURRENT USE OF HAZARDOUS SUBSTANCES .............................................................................. 16
5.4.3 WASTE MANAGEMENT AND DISPOSAL PRACTICES ...................................................................... 16
5.4.4 CURRENT CORRECTIVE ACTIONS AND RESPONSE ACTIVITIES ...................................................... 16
5.4.5 ENGINEERING CONTROLS ........................................................................................................... 16
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5.4.6 INSTITUTIONAL CONTROLS ......................................................................................................... 16
5.5 CURRENT USES OF THE ADJOINING PROPERTIES ............................................................................. 17
6 INTERVIEWS .................................................................................................................................. 17
6.1 INTERVIEW WITH OWNERS .............................................................................................................. 17
6.1.1 Current Owner ........................................................................................................................... 17
6.1.2 Past Owner(s) ............................................................................................................................ 17
6.2 INTERVIEW WITH SITE MANAGER ................................................................................................... 17
6.2.1 Current Site Manager ................................................................................................................ 17
6.2.2 Past Site Manager ...................................................................................................................... 17
6.3 INTERVIEWS WITH OPERATORS AND OCCUPANTS ........................................................................... 17
6.3.1 Current Operators and Occupants ............................................................................................. 17
6.3.2 Past Operators and Occupants .................................................................................................. 18
6.4 INTERVIEWS WITH USER AND OTHERS ............................................................................................ 18
6.5. INTERVIEWS WITH LOCAL GOVERNMENT OFFICIALS ................................................................. 18
6.5.1 Fire Department ......................................................................................................................... 18
6.5.2 Health Department ..................................................................................................................... 18
7 EVALUATION ................................................................................................................................. 18
7.1 FINDINGS ..................................................................................................................................... 18
7.3 OPINION ....................................................................................................................................... 20
7.3.1 Data Gaps ............................................................................................................................. 20
7.4 CONCLUSIONS ............................................................................................................................ 21
7.6 ENVIRONMENTAL PROFESSIONAL STATEMENT ............................................................... 21
7.7 REFERENCES ............................................................................................................................... 21
8 APPENDICES ................................................................................................................................... 22
8.1 QUALIFICATIONS OF ENVIRONMENTAL PROFESSIONALS AND STAFF ....................... 22
8.2 SITE PHOTOGRAPHS ........................................................................................................................ 23
FIGURE 1 - SITE LOCUS MAP ........................................................................................................................
FIGURE 2 – ASSESSOR’S MAP .......................................................................................................................
APPENDIX A - LIMITATIONS .........................................................................................................................
APPENDIX B - ENVIRONMENTAL DATABASE REPORT ...................................................................................
APPENDIX C – LEGAL DESCRIPTION .............................................................................................................
APPENDIX D –SITE USER QUESTIONNAIRE ...................................................................................................
APPENDIX E – SANBORN MAPS ....................................................................................................................
APPENDIX F – LOCAL RECORDS ...................................................................................................................
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1. SUMMARY
David Valecillos, Senior Project Manager for the North Shore Community Development
Coalition, Inc (“Client” or “User”) requested this Phase I ASTM Environmental Site
Assessment (“ESA”) of the Site in conjunction with the planned development of the
property for affordable housing. The Site is identified as Salem Assessor’s map 34, Lot
384, containing 0.235 acres. A locus map, Assessor’s map and Site plan are presented in
Figures 1, 2 and 3, respectively. The current owner of record is 34 Peabody Street, Inc
according to the Salem Assessors. The address of the Site is 34 Peabody Street, Salem
MA 01970. The Site is located downtown Salem near the waterfront in a densely
developed mixed use neighborhood. The Site is currently a parking lot.
This ESA was accomplished by (1) researching reasonably ascertainable records from
standard sources and additional sources as needed, (2) conducting a Site visit, (3)
conducting interviews, (4) and considering information provided by the User. The
objective of this process of all appropriate inquiries into previous and current uses of the
Site and adjacent area is to identify, to the extent feasible, Recognized Environmental
Conditions. [Italicized terms are defined in the ASTM Standard Practice E 1527-13.]
Findings:
This assessment was conducted for the Site which is currently used as parking lot. Past
uses include: automotive repair garage, manufacturing oil barrel racks, machining, and
paint dipping, oil storage and machining.
The following findings may be considered known or suspect Recognized Environmental
Conditions (“RECs,”) Controlled Recognized Environmental Conditions (“CRECs,”)
Historical Recognized Environmental Conditions (“HRECs”) or de minimus conditions.
There is an HREC on the Site associated with a removal action which was undertaken in
late July 2005 following the discovery during construction excavation of an abandoned,
open top, steel tank found below grade containing tar and oily dirt. The steel tank was
removed with a permit from the Salem Fire Department indicating that the tank was a
275 gallon tank and last contained #2 fuel oil. The Inspector’s notes indicated “tank
leaking”. Reportedly, an estimated 15 tons of soil were removed from around the tank.
The soils, when tested for disposal characterization, contained concentrations of total
petroleum hydrocarbons (qualitatively characterized as unknown hydrocarbons), PAHs
and lead that exceeded reportable concentrations under the MCP. The consultant
conducting the work claimed that those compounds were associated with the presence of
coal/coal ash observed in the excavation and were, therefore, exempt from reporting. The
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scheduled analyses for total petroleum hydrocarbons and PAHs on samples from the
excavation walls were then canceled and testing was limited to analysis of lead. In early
October 2005, residual concentrations of lead were characterized in remaining soils
surrounding the excavation with a maximum detected concentration of 634 mg/kg of
lead. The report indicates that “after testing on October 4, 2005 showed clean walls, an
additional 15 tons of soil was removed [excavated from near the tank]”; but, there was no
indication of confirmatory samples being collected or analyzed following the additional
excavation or where the additional excavation was conducted. The accumulated
stockpiled soils were shipped out early November 2005 on a 21E Bill of Lading.
Also encountered in late July 2005 was an abandoned, concrete, basement structure
containing metal debris, oily soil and oily water. An estimated 30 tons of impacted soils
was shipped out early November 2005 on a 21E Bill of Lading, 2100 gallons of “oily
water” were shipped as MA01 waste on a Hazardous Waste Manifest, and metal debris
including an abandoned boiler with asbestos containing insulation were removed from
concrete structure and reportedly managed for asbestos removal and disposal before the
metal was sent for scrap. The concrete basement structure was emptied with the removal
action and the floor and walls appeared physically intact. There was no additional
characterization around the structure beyond testing that had been conducted in 2000.
The 2001 Phase II Environmental Assessment Supplement presented a boring log for
boring B-6, drilled in the central portion of the Site, which included a sample description
of black tar/asphalt present at a depth of 5 – 7 feet. The condition was not characterized
by laboratory testing.
In 2015, IRWIN conducted an environmental site assessment of the Site. That report
concluded that there was evidence of two Recognized Environmental Conditions
(“RECs”):
The former underground tank excavation and soil removal action HREC that is
considered to currently be a REC based upon the apparent lack of data
characterizing residual concentrations of petroleum hydrocarbons, PAHs and lead
following the removal actions.
Conditions noted in a historical boring B-6 drilled in the central portion of the Site
during which included a sample description of black tar/asphalt present at a depth
of 5-7 feet.
In late 2015, early 2016 IRWIN conducted a limited subsurface investigation into these
two RECs. Laboratory analysis of soil samples did not find contaminants above
reportable concentrations and the investigation concluded that the conditions were de
minimus.
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Conclusion:
We have performed a Phase I Environmental Site Assessment in conformance with the
scope and limitations of ASTM Practice E 1527-13 of 34 Peabody Street, Salem MA
01970, the “Site.” Any exceptions to, or deletions from, this practice are described in
Sections 2.5 and 7.8 of this Report. This assessment has revealed no evidence of
Recognized Environmental Conditions in connection with the property.
2. INTRODUCTION
2.1 Location and Legal Description
The Site is identified as Salem Assessor’s map 34, Lot 384, containing 0.235 acres. A
locus map, Assessor’s map and Site plan are presented in Figures 1, 2 and 3, respectively.
The current owner of record is Salem Point Rental Property Corp. The address of the Site
is 34 Peabody Street, Salem MA 01970. The Site is located downtown Salem near the
waterfront in a densely developed mixed use neighborhood. The Site is currently a
parking lot.
The legal description is attached hereto in Appendix C.
2.2 Purpose
This study was conducted by Irwin Engineers, Inc. (IRWIN) with the goal of identifying
Recognized Environmental Conditions, defined by ASTM Standard Practice E-1527-13
as “the presence or likely presence of any hazardous substances or petroleum products
in, on, or at a property: (1) due to release to the environment; (2) under conditions
indicative of a release to the environment; or (3) under conditions that pose a material
threat of a future release to the environment. De minimis conditions are not recognized
environmental conditions.”
This ASTM Practice is intended to constitute All Appropriate Inquiry and permit the
User to satisfy one of the requirements to qualify for the innocent landowner, contiguous
property owner, or bona fide prospective purchaser limitations on CERCLA liability
(collectively, the “landowner liability protections” or “LLPs”). CERCLA is the
Comprehensive, Environmental Response, Compensation and Liability Act. While
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petroleum products are not classified as hazardous substances under CERCLA they are
included in the ASTM Practice and will, therefore, be included here.
The scope of this study does not address requirements other than All Appropriate Inquiry,
which may be required for the user to qualify for the LLPs such as ongoing obligations to
comply with activity and use limitations, or state or local laws.
2.3 Scope-of-Services
IRWIN has reviewed records at the local municipal offices and those maintained by the
Department of Environmental Protection concerning the Site (if any) and the surrounding
area within applicable ASTM search radii. A search was conducted using a commercial
environmental database company to identify known critical environmental resources and
sensitive receptors, registered underground storage tanks, hazardous waste generators,
state disposal sites, RCRA sites, CERLIS sites, federal sites, listings in tribal databases of
equivalent sites, Federal Brownfield sites, and available registries of institutional and
engineering controls. Due to the COVID state of emergency, inquiries were made
remotely.
A Site reconnaissance visit was conducted by an Environmental Professional or under the
supervision of an Environmental Professional to observe the current conditions of the Site
and surrounding area for evidence of Recognized Environmental Conditions.
Photographs were taken of the Site and of any notable current Site conditions. Interviews
were conducted with the current owner and manager (if any) of the Site. Certain local
officials were also interviewed to obtain current and historical information regarding the
Site and immediate surrounding area.
2.4 Significant Assumptions
IRWIN has relied on the information contained in a prior report provided by the User
without independent verification of the data.
2.5 Limitations and Exceptions
This assessment is designed to satisfy the ASTM standard for the User to qualify for one
of the limitations on CERCLA liability, therefore, the following considerations will not
be addressed: business environmental risk; non-scope items including but not limited to:
asbestos or PCB containing material in buildings; radon; mold; lead-based paint; lead in
drinking water, wetlands, regulatory compliance, compliance with applicable institutional
and/or engineering controls, cultural and historic resources, industrial hygiene, health and
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safety, ecological resources, endangered species, indoor air quality unrelated to releases
of hazardous substances or petroleum products into the environment, and biological
agents. The former list is not all-inclusive. A review of land title records or of judicial
records for environmental liens is not within the scope of this assessment. That review is
the responsibility of the User.
As stated in the ASTM standard, “No environmental site assessment can wholly
eliminate uncertainty regarding the potential for recognized environmental conditions.”
This report is subject to the limitations outlined in Appendix A attached hereto and
incorporated herein. The report has been prepared in accordance with the Terms and
Conditions set forth in our contract dated March 29, 2021. No other warranty, express or
implied, is made.
2.6 Special Contractual Terms and Conditions
None.
2.7 User Reliance
This study and report have been prepared on behalf of and for the exclusive use of Client
solely for use in an environmental evaluation of the Site. This report and the findings
contained herein shall not, in whole or in part, be disseminated or conveyed to any other
party, nor used or relied upon by any other party in whole or in part, without the prior
written consent of Irwin Engineers, Inc. However, Irwin Engineers Inc., acknowledges
and agrees that, subject to the Terms and Conditions of our contract, the report may be
conveyed to the Client’s attorney, lender, title insurer, or regulatory agencies. In addition
to the Limitations contained in Appendix A and in addition to our Standard Provisions for
Environmental Services, please note that the ASTM E1527-13 standard provides (1) that
this report is valid for 180 days and (2) if within this period the assessment will be used
by a user different than the user for whom the assessment was originally prepared, the
subsequent user must also satisfy the User’s Responsibilities.
3 USER PROVIDED INFORMATION
The Client provided copies of:
2001 Phase II Environmental Assessment Supplement prepared by Gulf of Maine
Research Center Inc. (GMRC”);
2005 Remedial Action Report prepared by GMRC.
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These reports are summarized below in Section 3.8, User Provided Reports. The Client
was asked to provide the information listed below via the User Questionnaire attached as
Appendix D.
3.1 Title Records
It is an obligation of the User to arrange for a search of recorded land title records and
lien records that are filed under federal, tribal, state or local law to identify environmental
liens and Activity and Use Limitations (“AULs”) that are currently recorded against the
Site. Where applicable, judicial records must also be searched.
The User was asked to provide this information. A title rundown was provided covering
from December 5, 2003 to July 29, 2015 and it showed no environmental liens or AULs.
The User also provided a title update dated April 7, 2021 from Keith Hersey, Title
Examiner. It found no liens or restrictions.
3.2 Environmental Liens or Activity and Use Limitations
In addition to the User’s obligation to conduct a title search, AULs or institutional
controls were searched via a commercial database search company, EDR Environmental
Data Resources, Inc. The results are discussed in Section 4.1
Further, the Client was asked if he knew of any environmental liens, AULs, intuitional
and/or engineering controls on the Site. He responded that a title search would be done.
3.3 Specialized Knowledge
The Client was asked if he had any information or special knowledge (professional as
well as personal experience) concerning the Site and surrounding area. The User
responded “no” and that prior reports had been provided to IRWIN.
3.4 Commonly Known or Reasonable Ascertainable Information
The Client was asked if he was aware of any commonly known or reasonably
ascertainable information about the Site that would help IRWIN identify conditions
indicative of release or threatened releases. The User responded that he knew that the Site
had been an automotive garage prior to 1985 and that it had been a machine shop back to
1890.
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3.5 Valuation Reduction for Environmental Issues
The User was asked if the purchase price being paid for the Site reasonable reflects the
fair market value of the Site and, if not, whether any difference is attributable to actual or
suspected contamination. The User is in this case has owned the Site since 2003. Mr.
Valecillos stated that he believes the Site was previously purchased at fair market value.
3.6 Owner, Property Manager, and Occupant Information
The Client provided the following information with regards to current and past owners,
managers, operators and occupants:
Current owner: North Shore Development Coalition’s through 34 Peabody Street,
Inc
Current manager: David Valecillos
Current occupant: N/A
Past owner: City of Salem
Past manager: N/A
Past occupant: N/A
3.7 Reason for Performing Phase I
The Client stated the reason for performing this Phase I assessment is due diligence for
financing for development of the Site into affordable housing.
3.8 User Provided Reports
2001 Phase II Environmental Assessment Supplement
In December of 2000, GMRC conducted a ground penetrating survey (GPR”) to assess
the Site for unknown underground storage tanks based on the Site history. GMRC also
conducted soil and groundwater testing. Seven soil borings were made and four
groundwater monitoring wells were installed.
“The GPR survey report indicated that although some metal debris (likely rebar or pipes)
was present in the light construction fill, there was no record of hyperbolic features which
would indicate the presence of an underground storage tank.”
For the seven soil borings, samples were collected at five foot intervals. The samples
were field screened for VOCs with an HNu monitor. Four soil samples were sent for
laboratory analysis of EPH, VPH and total RCRA metals. GMRC selected reporting
category RSC-1 for soil. The laboratory results did not exceed reportable thresholds
according to GMRC. In one of the borings, boring B-6 drilled in the central portion of
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the Site and which was not characterized by laboratory testing, conditions noted the
boring log included a sample description of black tar/asphalt present at a depth of 5 – 7
feet. No explanation was provided in the report why that sample was not submitted for
laboratory analysis.
Groundwater samples were collected from the four wells after stabilization. Depth to
groundwater was measured as 6.5 to 7.2 feet below surface. These samples were also
analyzed for EPH, VPH and total RCRA metals. The results were “well below” the
applicable GW-2 reporting thresholds.
GMRC concluded that there was “no geophysical evidence of underground storage
tanks” and while small quantities of petroleum hydrocarbons were present they were
below reportable thresholds.
2005 Remedial Action Report prepared by GMRC.
In June of 2005 during construction activities for a parking lot, two underground
structures were unearthed. One was a “buried open container of tar and oily dirt” and the
other was a “basement with a concrete sump containing oily soil.” Before removal of the
sump, 2100 gallons of oily water were pumped out and disposed off-Site under manifest.
Thirty tons of oily soil and debris were also removed from “the surface of the sump” and
stockpiled. An asbestos covered furnace was also discovered in the basement. The
asbestos was removed and the furnace was disposed of as scrap metal.
The container was also removed, cleaned and disposed of with a disposal permit from the
Fire Department. The permit lists the container as a 275 fuel oil tank. After the tar
container had been removed an additional 15 tons of “obviously contaminated” soil was
removed from around and under it and stockpiled. Samples were taken from below the
concrete floor, below the tar container and from the stockpiles. An additional 15 tons of
soil was removed from the area of the tar container. The excavations were backfilled with
soil from other portions of the Site.
GMRC stated that the presence of coal and coal ash in area of the tar container explained
the elevated metal levels found. They also stated that the Massachusetts Contingency
Plan (the “MCP”) exempted the elevated levels of lead which were found from reporting
since they were associated with the coal and coal ash.
A total of 58.2 tons of soil was transported off-Site. GMRC concluded that “oil
contaminated soil which exceeded RCS-1 reportable concentrations was removed from
the property as a Limited Removal Action…”
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4 RECORDS REVIEW
4.1 Standard Environmental Record Sources
A database search was conducted through Environmental Data Resources, Inc. (“EDR”)
on March 30, 2021. The EDR Report is attached hereto as Appendix B. The date that
each database was last updated in also listed in Appendix B. Due to the density of the Site
area the search radii were reduced in accordance with section 8.1.2.1 of the ASTM
Standard 1527-13.
A review of the following databases revealed no sites listed within the ASTM reduced
search radii:
Federal National Priority List (NPL) (includes delisted sites)- 1.0 mile
Federal CERCLIS No Further Action Planned – 0.5 mile
Federal RCRA Treatment, Storage & Disposal facilities – 0.5 mile
Federal RCRA Generators - property & adjoining
Federal institutional control/engineering control registries (Brownfields) –
property only
Federal Emergency Response Notification System – property only
Registered Underground Storage Tanks – property & adjoining
Solid Waste Landfills – 0.5 mile
State and Tribal institutional control/engineering control registries (AULs)
– property only
Institutional controls are legal restrictions on the use of, or access to, to a property
to (1) reduce or eliminate potential exposure to hazardous substances or
petroleum products in the soil or ground water on the property, or (2) to prevent
activities that could interfere with the effectiveness or a response action.
ASTM requires searches of state “lists of hazardous waste sites identified for
investigation or remediation.” ASTM identifies the appropriate radius for “state-
equivalent NPL” as 1.0 mile and for “state equivalent CERCLIS” as 0.5 mile. In
Massachusetts the investigation and cleanup of hazardous waste sites has been privatized
through the Licensed Site Professional program. All sites are given a Release Tracking
number and, therefore, there is only one database to search.
However, review of the following database(s) did reveal the listed properties as follows:
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Comprehensive Environmental Response Compensation and Liability
Information System (SEMS) – 0.5 mile
This database was renamed in 2015 to the Superfund Enterprise Management System
although the ASTM standard has not been updated as of this report.
There is one listing for the abutting property listed as Peabody Street Asbestos located at
15 Peabody Street across the street to the north. The database report indicates that no site
assessment work was required and that the property was listed for removal of asbestos.
As such, the contaminant of concern, asbestos is expected to have been limited to that
property and not to pose a threat of migration of contamination to the Site.
Federal RCRA Corrective Action Sites – 1.0 mile
There is one listing on this database for New England Power Co located approximately
0.889 miles to the northeast. This location on a peninsula to the northeast of the Site is
expected to be downgradient with respect to the Site and not to pose a threat of migration
of contamination.
State and Tribal Brownfields – 0.5 mile
There are three listings for this database within 0.5 miles of the Site. All three have been
closed with a Response Action Outcome. All three are also in a downgradient or cross-
gradient location relative to the Site. Based on this information, these Brownfields are not
expected to pose a threat of migration of contamination.
State and Tribal Releases– 1.0 mile reduced to 0.5 mile
The ASTM Standard does not provide a definition for this database since it will vary by
state. In Massachusetts all releases are tracked through the same database which assigns
Release Tracking Notification numbers. Therefore, there are no separate databases for
leaking underground storage tanks. The database report shows that there are 72 releases
within the reduced search radius. There are also 29 releases from leaking underground
storage tanks and 6 from aboveground storage tanks although these are repeat listings
since in Massachusetts there is one tracking system. The vast majority of the releases are
in a downgradient or cross gradient location relative to the Site. Details were reviewed
for those releases expected to be upgradient from the Site. That review showed those
releases to have been closed with a Permanent Solution or with an Activity and Use
Limitation.
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Non geocoded Sites
A review of “orphan” releases indicates that they are not on streets upgradient within ¼
mile of the Site.
4.2 Additional Environmental Record Sources
Health Department
Inquiry was made regarding environmental contamination issues on or affecting the Site.
Maureen Davis, Principal Clerk stated that she checked and found no such files for the
Site.
Fire Department
The City of Salem requires requests to be made in writing for records for USTs located at
or removed from the Site. During the 2015 assessment a review of records made
available showed that one 275 gallon UST containing #2 fuel oil was .removed on
August 4, 2005. No record was provided regarding fire department oversight or
information regarding sampling. No permit information was provided. This information
provided differed from the attachments to the reports provided at the time by the Client in
that the newly provided information lacked the handwritten notes and detail of the
original forms but instead was a copy of a tank disposal receipt.
As the Client had owned the Site since the 2015 assessment further inquiry to the Fire
Department was not made. The Client verified that they have not installed or removed
any tanks from the Site.
Permits for Site
Permits were not found for storing, generating or handling hazardous substances or
petroleum. According to the User/Owner, he does not know if the Site has have permits
for solid waste disposal, hazardous waste disposal, wastewater discharge, NPDES
discharge, or underground injection permits.
Asbestos Removal
The Site is listed in the database report for asbestos removal in 2005. Asbestos in
building materials is not within the scope of this assessment. The details do not show that
the asbestos was reported as a release under the Massachusetts Contingency Plan.
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4.3 Physical Setting Source(s)
4.3.1 Topographical Map
The USGS 7.5 x15 Minute topographical map for the Salem quadrangle (1985) was
reviewed. Based on that review, the inferred direction of groundwater flow is expected to
be in a northeasterly direction. However, local geology and other factors such as utilities
can affect localized flow patterns.
4.3.2 Sensitive Receptors
The Site is located within a Not Potentially Productive Aquifer according to the database
report. It is in a medium yield aquifer according to the Massachusetts GIS mapping
system. It is not located within a Zone II wellhead area.
Based on a review of the online database maintained by the Massachusetts Division of
Fisheries and Wildlife, the Site is not within ¼ mile of either an Estimated Habitat of
Rare Wildlife or Priority Habitat of Rare Species.
4.4 Historical Use Information on the Property
Historical sources were reviewed to identify obvious uses of the Site back to 1890 which
is the date of the oldest available Sanborn Fire Insurance map.
The owner has provided information revealing that the Site was an auto garage prior to
1985. The Site has been vacant since at least 2001. No permits were found within the
online database maintained by the City.
Sanborn Fire Insurance maps were reviewed for the Site. Dates of available maps and
how the Site appeared are described below:
1970: The Site contains a Private Garage on the east side of the property. The remaining
area is empty.
1965: Same as 1970.
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1957: Manufacturing oil barrel racks, machining, and paint dipping are on the east side
of the property. The structure at this time appears to be the same on the 1965 and
1970 maps of the Site. The remaining area of the property is empty.
1950: Same as 1957.
1906: Oil storage and vacant painting area located in center of property.
1890: Vaughn Morocco Machine Co. located in northeast corner of the property.
Machine shop located on the west side of the property. Carpenter with a cabinet
shop located on the south side of the property in the center.
Past use of hazardous substances
Paint, machining lubricants and cleaning solvents, oil.
Past Waste management and disposal practices
Unknown.
Past corrective actions and response activities
None.
4.4.1 Site Subsurface Investigation
In order to address the two RECs which were identified in the 2015 Phase I assessment,
IRWIN conducted a limited subsurface investigation. The areas in question were the
former tank area and area of one of the borings which had been made by Gulf of Maine.
Four borings were installed in the former tank area. One soil boring was drilled within
the estimated area of the tank excavation with composite samples collected from 0-5 feet,
5-10 feet, and 10-15 feet and submitted for laboratory analysis of EPH and lead. Three
borings were made immediately outside the estimated extent of the former tank
excavation in the north, south, and west directions. Composite samples were collected
from each boring at 0-5 feet and 5-10 feet and submitted for laboratory analysis of EPH
and lead.
Soil boring SB-105 was drilled near the location of the historical soil boring (B-6) with
observed black tar/asphalt. Composite samples were collected from this boring from 0-5
feet and 5-10 feet and each was submitted for laboratory analysis of EPH and lead.
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Additionally one sample from each area was submitted for laboratory microscopic
analysis to evaluate for the presence of coal or coal ash.
Based upon the testing conducted the limited removal action for petroleum impacts
around the former underground storage tank was successful in achieving less than
reportable conditions for the petroleum hydrocarbon fractions. Testing of soils in both
the former tank area and the former boring B-6 area detected lead and polycyclic
aromatic hydrocarbons which prompted microscopic evaluation for identification of
whether coal/coal ash and asphalt were present.
MCP regulations exempt reporting of hazardous materials associated with coal/coal ash
or with asphalt binder in bituminous pavement. IRWIN concluded that the results
supported the reclassification of both the limited removal action area and boring B-6 area
REC conditions as de minimis conditions not requiring further assessment.
4.5 Historical Use Information on Adjoining Properties
Sanborn Fire Insurance maps were reviewed for the adjoining properties. Dates of
available maps and how the Site appeared are described below:
North of the Site
1970: Essex County Electric Co. Power Plant covers the portion of Peabody Street north
of the Site. The property consists of open space, voltage regulators, small
buildings in the center of the property, and a coal pile in the northeast corner.
1965: The property is still owned by Essex County Electric Co. Power Plant; however,
the area contains more buildings on the east side and in the center. These
buildings contain turbines, coal conveyors, and maintenance areas. The coal pile
is still present in the northeast corner.
1957: Same as 1965.
1950: The property is owned by Salem Electric Lighting Co. and occupies the eastern
half of the space north of the Site. The western portion of the property is vacant.
1906: Same as 1950; however, the western portion of the property is now also occupied
by Salem Electric Lighting Co.
1890: Salem Electric Lighting Co. occupies the center and western portions of the
property and WM. Pickering JR. and Co. Coal and Wood Wharf occupies the
western portion of the property.
West of the Site
1970: Flats.
1965: Same as 1970.
1957: Same as 1970.
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1950: Same as 1970.
1906: Dwellings and tenements
1890: Dwellings and tenements in a different arrangement than in 1906.
East of the Site
1970: Flats.
1965: Same as 1970.
1957: Same as 1970.
1950: Same as 1970.
1906: Tenements.
1890: Same as 1906.
South of the Site
1970: Dwellings.
1965: Same as 1970.
1957: Same as 1970.
1950: Same as 1970.
1906: Dwellings in a new arrangement.
1890: Same as 1906.
5 SITE RECONNAISSANCE
5.1 Methodology & General Site Setting
The visit was conducted by foot. The perimeter of the Site was walked and the Site was
viewed from adjacent public ways. One Site visit took place on April 5, 2021 at
approximately 10am. Lana Carlsson-Irwin of IRWIN visited the Site. It was cloudy and
approximately 50 degrees Fahrenheit.
The general area is characterized by densely developed residential apartments buildings
on the south side of Peabody Street and behind the Site on Ward Street. The south side of
Peabody Street has a variety of uses including a park, an electric utility property and a
fast food restaurant.
5.2 Exterior Observations
The Site is parking lot with a small landscaped strip adjacent to Peabody Street. The
asphalt appears freshly recoated. Several monitoring wells and two square areas from the
subsurface investigation were observed. The latter were cuts in the asphalt with gravel
cover. A trailer was observed placed along the rear of the Site. According to Mr.
Valecillos, it contains tables and chairs. Traffic cones, an empty trash can, a rooftop
carrier and a few miscellaneous items were observed behind it.
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The following were not observed: pits, ponds or lagoons, stained soil or pavement,
stressed vegetation, solid waste fill, wastewater and stormwater disposal other than to a
sewer, wells, septic systems, oil storage tank vent or fill pipes, odors, pools/sumps,
drums, unidentified substance containers suspected of being hazardous waste. There are
no water bodies on the Site.
The Site is relatively flat with a 15-20 foot retaining wall at its rear (southern) edge.
Apartment buildings border it east and west with single family homes to the south.
5.3 Interior Observations
N/A.
5.4 Current Use of the Property
5.4.1 Current use
The Site is a parking lot.
5.4.2 Current use of hazardous substances
N/A.
5.4.3 Waste management and disposal practices
N/A.
5.4.4 Current corrective actions and response activities
N/A.
5.4.5 Engineering controls
N/A.
5.4.6 Institutional controls
N/A.
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5.5 Current Uses of the Adjoining Properties
Apartment buildings border the Site east and west with single family homes to the south.
Across Peabody Street is a park and an electric power utility station.
6 INTERVIEWS
6.1 Interview with Owners
6.1.1 Current Owner
The Owner of record is an entity controlled by the User with the same people involved so
no separate interview was conducted.
6.1.2 Past Owner(s)
The past owner, the City of Salem, is not expected to provide material new information to
known history of the Site.
6.2 Interview with Site Manager
6.2.1 Current Site Manager
The identified site manager is the User so no separate interview was conducted.
6.2.2 Past Site Manager
None identified.
6.3 Interviews with Operators and Occupants
6.3.1 Current Operators and Occupants
The current operator is the User so no separate interview was conducted.
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6.3.2 Past Operators and Occupants
None identified.
6.4 Interviews with User and Others
An interview was conducted with the User of this assessment, the Client. As required by
the ASTM standard, the User, David Valecillos, was asked if he had any knowledge of
pending, threatened or past litigation, administrative proceedings, or notices of
proceedings or violations of environmental laws regarding the Site or relevant to
hazardous substances or petroleum in on or from the property. He stated that he had no
such knowledge.
The User was asked the questions contained in Appendix D regarding the Site and any
relevant documentation.
6.5. Interviews with Local Government Officials
6.5.1 Fire Department
Direction was provided that inquires must be submitted in writing which was done for the
2015 assessment. As noted, above further inquiry was not made as the User/Owner has
owned the Site since then.
6.5.2 Health Department
Maureen Davis responded on April 1, 2021 to email inquiry.
No other interviews were conducted for the Site.
7 EVALUATION
7.1 FINDINGS
This assessment was conducted for the Site which is currently used as parking lot. Past
uses include: automotive repair garage, manufacturing oil barrel racks, machining, and
paint dipping, oil storage and machining.
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The following findings may be considered known or suspect Recognized Environmental
Conditions (“RECs,”) Controlled Recognized Environmental Conditions (“CRECs,”)
Historical Recognized Environmental Conditions (“HRECs”) or de minimus conditions.
There is an HREC on the Site associated with a removal action which was undertaken in
late July 2005 following the discovery during construction excavation of an abandoned,
open top, steel tank found below grade containing tar and oily dirt. The steel tank was
removed with a permit from the Salem Fire Department indicating that the tank was a
275 gallon tank and last contained #2 fuel oil. The Inspector’s notes indicated “tank
leaking”. Reportedly, an estimated 15 tons of soil were removed from around the tank.
The soils, when tested for disposal characterization, contained concentrations of total
petroleum hydrocarbons (qualitatively characterized as unknown hydrocarbons), PAHs
and lead that exceeded reportable concentrations under the MCP. The consultant
conducting the work claimed that those compounds were associated with the presence of
coal/coal ash observed in the excavation and were, therefore, exempt from reporting. The
scheduled analyses for total petroleum hydrocarbons and PAHs on samples from the
excavation walls were then canceled and testing was limited to analysis of lead. In early
October 2005, residual concentrations of lead were characterized in remaining soils
surrounding the excavation with a maximum detected concentration of 634 mg/kg of
lead. The report indicates that “after testing on October 4, 2005 showed clean walls, an
additional 15 tons of soil was removed [excavated from near the tank]”; but, there was no
indication of confirmatory samples being collected or analyzed following the additional
excavation or where the additional excavation was conducted. The accumulated
stockpiled soils were shipped out early November 2005 on a 21E Bill of Lading.
Also encountered in late July 2005 was an abandoned, concrete, basement structure
containing metal debris, oily soil and oily water. An estimated 30 tons of impacted soils
was shipped out early November 2005 on a 21E Bill of Lading, 2100 gallons of “oily
water” were shipped as MA01 waste on a Hazardous Waste Manifest, and metal debris
including an abandoned boiler with asbestos containing insulation were removed from
concrete structure and reportedly managed for asbestos removal and disposal before the
metal was sent for scrap. The concrete basement structure was emptied with the removal
action and the floor and walls appeared physically intact. There was no additional
characterization around the structure beyond testing that had been conducted in 2000.
The 2001 Phase II Environmental Assessment Supplement presented a boring log for
boring B-6, drilled in the central portion of the Site, which included a sample description
of black tar/asphalt present at a depth of 5 – 7 feet. The condition was not characterized
by laboratory testing.
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In 2015, IRWIN conducted an environmental site assessment of the Site. That report
concluded that there was evidence of two Recognized Environmental Conditions
(“RECs”):
The former underground tank excavation and soil removal action HREC that is
considered to currently be a REC based upon the apparent lack of data
characterizing residual concentrations of petroleum hydrocarbons, PAHs and lead
following the removal actions.
Conditions noted in a historical boring B-6 drilled in the central portion of the Site
during which included a sample description of black tar/asphalt present at a depth
of 5-7 feet.
In late 2015, early 2016 IRWIN conducted a limited subsurface investigation into these
two RECs. Laboratory analysis of soil samples did not find contaminants above
reportable concentrations and the investigation concluded that the conditions were de
minimus.
7.3 OPINION
The HREC associated with removal actions conducted in 2005 were reviewed and a
limited subsurface investigation was conducted in late 2015 due to the absence of
confirmatory data for petroleum hydrocarbons or PAHs in remaining soil from the 2005
removal action. That investigation found that the Site conditions did not contain
reportable concentrations of contaminants and that the remaining levels were de minimus.
Based on those results, it is our opinion that the HREC is not a current REC.
7.3.1 Data Gaps
The available Sanborn maps for the Site and surrounding area yield three data gaps. The
function of the Site and surrounding area was not identified between 1957-1965, 1906-
1950, and 1890-1906. As the 2015 subsurface assessment found no REC regarding the
prior remediation activities, these data gaps, of themselves, do not change the opinion
reached.
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8 APPENDICES
8.1 QUALIFICATIONS OF ENVIRONMENTAL PROFESSIONALS AND
STAFF
J. ANDREW IRWIN, P.E., LSP, TURP, is responsible for projects involving
environmental site assessment, risk assessment, engineering feasibility studies,
remediation design, permits and compliance auditing programs. Mr. Irwin holds Bachelor
of Science (1981) and Master of Engineering (1982) degrees in Chemical Engineering
from Cornell University. He is a Member of the American Institute for Chemical
Engineers and belongs to the Licensed Site Professional Association. He is a registered
Professional Engineer in the State of New York, Massachusetts, Connecticut, Rhode
Island and New Hampshire. He has been actively practicing in environmental
engineering since 1982.
LANA CARLSSON-IRWIN, ESQ. is responsible for environmental site assessment
projects. Ms. Carlsson-Irwin holds a Bachelor of Arts in Biology from Cornell University
(1981) and a Juris Doctor summa cum laude from Syracuse Law School (1985). She has
been actively conducting site assessments since 1996. She has completed the Phase I Site
Assessment & Transaction Screen Assessment Modules for Environmental Site
Assessments for Commercial Real Estate Course, 2003 and attending on-going training
seminars.
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8.2 Site Photographs
SITE VIEWED FROM PEABODY STREET
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BEHIND TRAILER
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EXAMPLE AREA FROM SUBSURFACE INVESTIGATION WITH MONITORING
WELL
Figure 1 - Site Locus Map
Figure 2 – Assessor’s Map
NOTE:
LOCUS CIRCLES FOR 500 FT
AND 0.5 MILE RADIUS
North Shore Community Development Coalition
102 Lafayette Street
Salem MA 01970
31MAR21
DWG NO
673-06C NSCDC 34 Peabody St Salem MA site locus 0B
1 OF 1
33 West Central Street
Natick, MA 01760
(508) 653-8007
DRAWING BY:
CHECKED BY:
APPROVED BY:SCALE
CLIENT
TITLE
SIZE
SHEETNTS
ICL
JAI
JAI
FIGURE 1
SITE LOCUS
34 Peabody Street Salem, MA
Appendix A - Limitations
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Appendix A - Limitations
1.The observations described in this report were made under the conditions stated therein. The
conclusions presented in the report were based solely upon the services described therein, and not on
scientific tasks or procedures beyond the scope of described services or the time and budgetary
constraints imposed by Client. The work described in this report was carried out in accordance with
the Standard Provisions for Environmental Services in our contract.
2. In preparing this report, IRWIN has relied on certain information provided by other parties referenced
therein. IRWIN did not attempt to independently verify the accuracy or completeness of all
information reviewed or received during the course of this site assessment.
3.Observations were made of the Site and of structures on the Site as indicated within the report. Where
access to portions of the Site or to structures on the Site was unavailable or limited, IRWIN renders
no opinion as to the presence of hazardous materials or oil, or to the presence of indirect evidence
relating to hazardous material or oil, in that portion of the Site or structure. In addition, Irwin
Engineers renders no opinion as to the presence of hazardous material or oil, or the presence of
indirect evidence relating to hazardous material or oil, where direct observation of the interior walls,
floor, or ceiling of a structure on a Site was obstructed by objects or coverings on or over these
surfaces.
4.It is IRWIN’s understanding that the purpose of this report is to identify Recognized Environmental
Conditions as defined by ASTM Practice E1527-13. This stated purpose has been a significant factor
in determining the scope and level of services provided for in the Agreement. Should the purpose for
which the Report is to be used or the proposed use of the site(s) change, this Report is no longer valid
and use of this Report without IRWIN’s review and written authorization shall be at the sole risk or
the party using it. Should IRWIN be required to review the Report after its date of submission,
IRWIN shall be entitled to additional compensation at then existing rates or such other terms as
agreed between IRWIN and the Client.
5. The conclusions and recommendations contained in this report may be based in part, where noted,
upon the data obtained from a limited number of soil samples obtained from widely spaced subsurface
explorations. The nature and extent of variations between these explorations may not become evident
until further exploration. If variations or other latent conditions then appear evident, it will be
necessary to reevaluate the conclusions and recommendations of this report.
6.Any water level readings made in test pits, borings, and/or observation wells were made at the times
and under the conditions stated on the report. However, it must be noted that fluctuations in the level
of groundwater may occur due to variations in rainfall and other factors different from those
prevailing at the time measurements were made.
7. Except as noted within the text of the report, no quantitative laboratory testing was performed as
part of the site assessment. Where an outside laboratory has conducted such
analyses, IRWIN has relied upon the data provided and has not conducted an independent evaluation
of the reliability of these data. IRWIN did not perform testing or analyses to determine the presence or
concentration of asbestos at the Site or in the environment at the Site.
8.The conclusions and recommendations contained in this report are based in part, where noted, upon
various types of chemical data and are contingent upon their validity. These data have been reviewed
and interpretations made in the report. As indicated within the report, some of these data may be
preliminary “screening” level data and should be confirmed with quantitative analyses if more
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specific information is necessary. Moreover, it should be noted that variations in the types and
concentrations of contaminants and variations in their flow paths may occur due to seasonal water
table fluctuations, past disposal practices, the passage of time, and other factors. Should additional
chemical data become available in the future, these data should be reviewed, and the conclusions and
recommendations presented herein modified accordingly.
9.Chemical analyses may have been performed for specific constituents during the course of this site
assessment, as described in the text. However, it should be noted that additional chemical constituents
not searched for during the current study may be present in soil and/or groundwater at the Site.
10.This Report was prepared for the exclusive use of the Client. No other party is entitled to rely on the
conclusions, observations, specifications, or data contained therein without the express written
consent of IRWIN.
11. The observations and conclusions described in this Report are based solely on the Scope of Services
provided pursuant to the Agreement. IRWIN has not performed any additional observations,
investigations, studies, or testing not specifically stated therein. IRWIN shall not be liable for the
existence of any condition, the discovery of which required the performance of services not
authorized under the Agreement.
12. The passage of time may result in significant changes in technology, economic conditions, or site
variations that would render the Report inaccurate. Accordingly, neither the Client, nor any other
party, shall rely on the information or conclusions contained in this Report after six months from its
date of submission without the express written consent of IRWIN. Reliance on the Report after such
period of time shall be at the User's sole risk. Should IRWIN be required to review the Report after
six months from its date of submission, IRWIN shall be entitled to additional compensation at then
existing rates or such other terms as may be agreed upon between IRWIN and the Client.
13.No environmental site assessment can wholly eliminate uncertainty regarding the potential for
recognized environmental conditions in connection with a property. Performance of this assessment is
intended to reduce, but not eliminate, uncertainty regarding the potential for recognized
environmental conditions in connection with a property.
14. IRWIN has endeavored to perform its services based upon engineering practices accepted at the time
they were performed. IRWIN makes no other representations, express or implied, regarding the
information, data, analysis, calculations, and conclusions contained herein.
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Appendix B - Environmental Database Report
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Appendix C – Legal Description