SITE ASSESSMENT & PERMAN SOLUTION STMT - SALEM SUEDE SP ENGINEERING, INC.
P.O. Box 848 • Salem, Massachusetts 01970 • Telephone: 978-745-4569 • Fax: 978-745-4881
September 21, 2018
Kimberley Driscoll, Mayor
City Hall
93 Washington Street
Salem, MA 01970
RE: Comprehensive Site Assessment and
Permanent Solution Statement
Former Salem Suede and Former Bonfanti Leather
72 Flint Street and 69-71 Mason Street
Salem, Massachusetts
RTN 3-30380
Dear Mayor Driscoll:
On behalf of Riverview Place, LLC,the purpose of this letter is to notify you that a combined
Phase II—Comprehensive Site Assessment and Permanent Solution Statement has been
prepared for the release of metals, polycyclic aromatic hydrocarbons, dioxins/furans and
petroleum at the former Salem Suede facility at 72 Flint Street and the former Bonfanti Leather
facility at 69-71 Mason Street in Salem, Massachusetts (the "Site") in accordance with the
Massachusetts Contingency Plan, 310 CMR 40.0000.
The Permanent Solution Statement documents that a Permanent Solution has been achieved
for the release and that a condition of No Significant Risk to human health and the environment
exists. A summary of findings and statement of conclusions is attached. A copy of this report
may be obtained from the DEP Searchable Sites Waste Site List/Site Files web site
https://eeaonline.eea.state.ma.us/portal#!/search/wastesite under Release Tracking Number
(RTN) 3-30380 or by contacting SP, Inc. at 508-745-4569.
Sincerely,
SP, INC.
Bruce M. Poole David L. Bramley, PE, LSP
President
Attachment
c. Thomas St. Pierre, Director Inspectional Services
Elizabeth Gagakis, Acting Health Agent
MassDEP, NERO
Michael O'Brien
David Zion
SUMMARY OF FINDINGS
Permanent Solution Statement
72 Flint Street and 69-71 Mason Street, Salem, MA
RTN 3-30380
The Riverview Place Site includes the former Salem Suede property at 72 Flint Street,the
former Bonfanti Leather property at 69-71 Mason Street, and an adjacent former residence at
67 Mason Street. The Salem Suede Site property has been vacant since 2009;the Bonfanti
properties have been vacant since 2012. The properties are 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 Site slopes southerly 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 Salem Suede property and in the
northeast portion of the Bonfanti property. Electricity and telephone service formerly were
provided via overhead lines. Stormwater drains to the North River.
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 Salem Suede property is
located within a 200-foot Riverfront Area and a 100-foot Wetland Buffer Zone. 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 portion of the North River adjacent to the Site is
known as Proctor Brook Segment MA93-40 and it is classified as Class SA. The River at this
location is not managed as an active shell fishing growing area in accordance with the
requirements of National Shellfish Sanitation Program (MassDEP, 2012). Further,the North
River is categorized as a Category 5 water body,which is impaired and requires a Total
Maximum Daily Load (TMDL). Impairments identified in this segment of the river include
debris/floatables/trash,fecal coliform,foam/flocs/scum/oil slicks, and taste and odor
(MassDEP, 2013).
Subsurface investigations were conducted by SP in 2005 and 2009 as due diligence and by
Weston &Sampson in 2012 as part of a Brownfields assessment. Laboratory analyses of soil
samples collected detected the presence of elevated concentrations of the metals arsenic,
chromium, lead, nickel, several hydrocarbon fractions, PAHs, and dioxins. The PAHs and the
dioxins were thought to have originated from the use of coal in the former boiler the ash from
which was spread on the Site. Also,the fires in 1914 and in 2009 may have contributed to the
presence of the PAHs and dioxins.
No definitive source of the dioxins has been identified. However, MassDEP is of the opinion
that the presence of dioxins is related to former process operations. As such, MassDEP has
stated that dioxins at the Site are not due to coal ash, wood ash, or anthropogenic background
because Site homologue patterns are not consistent with coal ash or wood ash. Site
homologue patterns were consistent with anthropogenic background, but mean homologue
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concentrations were as much as an order of magnitude greater than anthropogenic
background. The site homologue patterns were consistent with homologues at another
tannery site with soil affected by pentachlorophenol. However, use of pentachlorophenol has
not been identified based on historic research.
Between April 2013 and November 2017 approximately 4,311 tons of soil were excavated and
transported off the Site to appropriate disposal facilities under the March 2013 and the
July 2016 Release Abatement Measure (RAM) Plans and the July 2017 RAM Plan Modification.
Groundwater samples for all or some of the monitoring wells were analyzed between 2012 and
2016 for VOCs, EPH, metals, and PCBs. None of the analytes were detected at concentrations
that exceed the Method 1, GW-2, and GW-3 Reportable Concentrations, except that lead has
been detected in groundwater samples from monitoring well MW-2, MW-3, and MW-9 at
concentrations slightly greater than the GW-3 standard. The source of the lead is thought to be
suspended silt particles caused by the excavation activities as the lead concentration in the
post-remediation groundwater samples are less than the GW-3 standards. Concentrations of
constituents of concern in groundwater samples from the most recent sampling events are less
than the GW-2, and GW-3 standards. The concentrations of lead in the samples collected
during the latest two analyses (November 2014 and May 2016)were less than the laboratory
Reporting Limit.
A Method 1 Human Health Risk Characterization and a Method 3 Environmental Risk
Characterization were performed to assess the risk of harm to human health, public welfare,
safety, and the environment using site-specific data, current and potential future uses of the
site, and recommended MassDEP risk characterization guidance.
The risk characterization results indicate the following:
➢ A condition of No Significant Risk of harm to human health and public welfare exists for
current and future residents under unrestricted site uses.
➢ The Site poses No Significant Risk of harm to safety because no conditions related to the
release that could pose a threat of physical harm or bodily injury was identified.
The site poses No Significant Risk of harm to the environment. After redevelopment,
undeveloped portions of the Disposal Site will occupy less than two acres and there are no
areas of special concern within 500 feet of the site. Due to size, use, and location, the Site does
not provide a balanced terrestrial community, so no further assessment and remediation for
terrestrial environmental concerns are needed. Therefore,the risk characterization concludes
that the release poses No Significant Risk of harm to the environment and a Stage II
Environmental Risk Characterization is not needed. Aquatic environmental exposure pathways
potentially are complete; however, COC concentrations in groundwater are less than the
surface water-based criteria in groundwater or after discharging to and mixing with the North
River. Therefore,the conclusion is that the North River will not be adversely affected by
current site groundwater conditions.
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Based on the information presented herein, no condition of readily apparent harm or any
potentially significant exposures have been identified at the Disposal Site. Therefore, based on
the criteria set forth in the MCP (310 CMR 40.0995), conditions present at the Disposal Site do
not warrant a Stage II Environmental Risk Characterization and the Disposal Site conditions do
not present a significant risk of harm to the environment.
Based on the findings of the assessment activities, the remedial actions, and the Risk-
Characterization presented herein, a level of No Significant Risk as defined in the MCP exists for
all foreseeable uses. These findings and the additional information presented below support
the applicability of a Permanent Solution for the Disposal Site.
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