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19 April 2021 File No. 133860-003 US Environmental Protection Agency

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19 April 2021 File No. 133860-003 US Environmental Protection Agency HALEY & ALDRICH, INC. 465 Medford St. Suite 2200 Boston, MA 02129 617.886.7400 19 April 2021 File No. 133860-003 US Environmental Protection Agency Office of Ecosystem Protection 5 Post Office Square – Suite 100 (OEP06-01) Boston, MA 02109-3912 Attention: EPA/OEP RGP Applications Coordinator Subject: Notice of Intent (NOI) Temporary Construction Dewatering 15 Necco Street Boston, Massachusetts Ladies and Gentlemen, On behalf of our client, ARE-MA Region No. 74 LLC, and in accordance with the National Pollutant Discharge Elimination System (NPDES) Remediation General Permit (RGP) in Massachusetts, MAG910000, this letter submits a Notice of Intent (NOI) in Appendix A and the applicable documentation as required by the US Environmental Protection Agency (EPA) for temporary construction site dewatering under the RGP. Haley & Aldrich, Inc. (Haley & Aldrich) has prepared this submission to facilitate off-site discharge of temporary dewatering during construction activities at the 15 Necco Street site in Boston, Massachusetts (the “site”). SITE LOCATION AND HISTORICAL SITE USAGE The approximately 45,000 square foot (sq ft) site is located at 15 Necco Street in Boston, Massachusetts, as shown in Figure 1. The site is currently a vacant paved lot. The site was most recently used as a laydown area for the adjacent development at 5 and 6 Necco Court. The site is bordered by 6-story brick office building at 5 and 6 Necco Court to the north; paved parking lots (planned for future redevelopment) to the south; Necco Street to the east, beyond which is a parking garage; and the Boston Harbor Walk and Fort Point Channel to the west. Current ground surface elevations range from approximately El. 13.5 to El. 15.5. The Harbor Walk along the west edge of the property has an elevation of approximately El. 14.5. Site history is based on review of available historical information, including Sanborn Fire Insurance Maps and historical maps available online from the Boston Planning and Development Agency. The general area of the site was part of Boston Harbor prior to filling in the 1860s, with land depicted at the site on the 1869 Boston Colton map. Boston Wharf Company is the earliest depicted occupant, with portions of three storage warehouses (No. 10, No. 14, No. 15) and several small outbuildings occupying the site by 1888. The warehouses stored sugar, molasses, and glass. www.haleyaldrich.com U.S. Environmental Protection Agency 19 April 2021 Page 2 By 1910, the warehouse building No. 14 that occupied most of the site was reconfigured to include a storage tank, which is also depicted on the 1919 Bromley Map. By 1923, the portion of warehouse building No. 15 on the site appears to be demolished and building No. 10 was reconfigured. The 1923 Sanborn Map also depicts an oil house and “50-gallon chemical tank on wheels” on the southern side of building No. 15, which is depicted through at least 1964. By 1938, an aerial photograph shows buildings No. 10 and No. 15 had been demolished along with the eastern portion of building No. 14 (including the tank). The 1950 Sanborn Map indicates the remaining portion of building No. 14 was used for warehousing floor covering supplies and tar in drums, and the 50-gallon chemical tank is still depicted. A wooden platform is also shown on the eastern portion of the site that connected building No. 14 to the abutting buildings at 5 and 6 Necco Court, and a small office building is located on the southeast corner of the site. By the late 1990s, structures at the site had been demolished, and the site has been used for parking and most recently as a construction staging area. PROPOSED CONSTRUCTION The proposed development is planned to consist of a new 12-story new lab/office building with supplemental heating and cooling provided by geothermal wells and 1 level of below-grade space below a portion (7,300 sq ft) of the above-grade building. Temporary construction dewatering will be required for the drill water generated during geothermal well installation, during excavation below the water table for new site elements including the partial basement at El. 9.5 and to manage stormwater run-off into open excavations. The building will be supported by deep foundations bearing in bedrock installed from current ground surface. Also note, that the groundwater levels on the site are tidally influenced therefore pumping will vary based on the construction activity and astronomical tide cycles. Thirty-five (35) geothermal wells are planned to be installed in the area shown on Figure 2. The wells will be drilled to depths of approximately 600 feet below ground surface. Drilling for geothermal well installation will be followed by pile installation and below-grade excavations. Proposed site grades will be raised up from current grades sloping up to El. 21 and will consist of a combination of softscape and hardscape landscape features. A Best Management Practices Plan (BMPP), which outlines the proposed discharge operations covered under the RGP, will be available at the site and is not being submitted with this NOI, as requested by EPA. ENVIRONMENTAL CONDITIONS AND REGULATORY BACKGROUND The development site includes two separate parcels with different Release Tracking Numbers (RTNs), summarized below and shown on Figure 2: 15 Necco Property - RTN 3-33854 is associated with polycyclic aromatic hydrocarbons (PAHs), petroleum hydrocarbons (TPH), and metals (antimony, lead, zinc) in soil. Environmental conditions were reported to MassDEP by the previous owner, General Electric (GE), in U.S. Environmental Protection Agency 19 April 2021 Page 3 March 2017, and GE submitted and a Tier II Site Classification on 13 March 2018. GE filed a Release Abatement Measure (RAM) Plan in April 2017 for soil management activities associated with a formerly planned development at the site. Due to changes in the planned development and property ownership, a RAM Completion report was filed in January 2020 documenting the limited site preparation activities conducted for the former development. Haley & Aldrich prepared and filed a new Tier II Classification submittal on 6 September 2019 on behalf of the new property owner, ARE-MA Region No. 71 Holding, LLC to establish new regulatory deadlines as an Eligible Person under Chapter 21E. 5 Necco Property - RTN 3-34132 is associated with PAHs, TPH, and metals (arsenic and lead) in soil associated with the 5 Necco Street parcel. A portion of this RTN is within the current development. GE filed a RAM Plan in July 2017 for soil management activities associated with this RTN, which included excavation for utilities and treatment of TCLP lead impacted soils. The RAM was completed in February 2020, and RTN 3-34132 achieved a Permanent Solution in September 2020 relying on an Activity and Use Limitation (AUL) to maintain a condition of No Significant Risk. Soil management for the new development will be conducted under a new RAM Plan that will include both site RTNs noted above. The RAM Plan will be filed prior to construction and will outline procedures for management of contaminated soil during construction of the new building and site improvements. Following completion of RAM activities, it is anticipated RTN 3-33854 will achieve conditions for a Permanent Solution without relying on an AUL and that the portion of RTN 3-34132 within the new development will achieve conditions for a Revised Permanent Solution and partial AUL termination. The AUL is anticipated to remain on a portion of the RTN 3-34132MCP site including the 5 and 6 Necco Court buildings. Groundwater is not part of either MCP Disposal Site at the site. In preparation for site development, 182 soil samples were collected at the site to characterize soils. Fill soils contained concentrations of PAHs, TPH, and metals typical of urban fill and attributed to historic site filling and use, as documented in regulatory filings for the RTNs described above. GROUNDWATER QUALITY DATA On 18 April 2016, groundwater sampling was conducted by the previous owner of the site at four observation well locations (B-102, -104, -105, -106(OW)) located within the site for volatile organic compounds, extractable petroleum hydrocarbons, volatile petroleum hydrocarbons (carbon ranges only), and total metals. This historical data did not detect concentrations above applicable Massachusetts Contingency Plan RCGW-2 reportable concentrations. On 12 January 2021, a groundwater sample was collected for this permit application from observation well BWC-22(OW), located across Necco Street as indicated on Figure 2. (Observation wells previously sampled at the site in 2016 were destroyed during site work for the former development.) The collected sample was submitted to Alpha Analytical Laboratory (Alpha) of Westborough, MA, for chemical analysis of 2017 NPDES Remediation General Permit parameters including volatile organic compounds, semi- volatile organic compounds, polycyclic aromatic hydrocarbons, total metals, total petroleum U.S. Environmental Protection Agency 19 April 2021 Page 4 hydrocarbons, pesticides, polychlorinated biphenyls, total suspended solids, chloride, total cyanide, total phenolics, and total residual chlorine. Refer to Table I for a summary of groundwater analytical data, and observation well locations are shown on Figure 2. Laboratory Data reports are provided in Appendix F. The 2016 data represents site specific contaminants of concern, and the 2021 data represents regional groundwater conditions that will be managed during temporary construction dewatering. The groundwater analyses did not detect concentrations of chemical constituents above applicable Massachusetts Contingency Plan (MCP) RCGW-2 reportable concentrations. Section D.4 of the NOI includes the maximum and average detections from the data collected in 2016 and 2021. Soil data was also considered for Section D.4 of the NOI. Dewatering effluent may include drill water, which is potable water from the City of Boston that is anticipated to contain chlorine.
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