CDW CONSULTANTS, INC. CIVIL & ENVIRONMENTAL ENGINEERS
April 30, 2020
U.S. Environmental Protection Agency 5 Post Office Square, Suite 100 Mail Code OEP06-4 Boston, MA 02109-3912 ATTN: Remediation General Permit NOI Processing
Re: Notice of Intent for Remediation General Permit 263 Monsignor O’Brien Highway, Cambridge, MA 1 McGrath Highway, Somerville, MA CDW Project # 1476.10
To Whom It May Concern:
CDW Consultants, Inc. (CDW) is submitting this Notice of Intent (NOI) on behalf of Somerbridge Hotel, LLC for a Remediation General Permit (RGP) under EPA’s National Pollutants Discharge Elimination System (NPDES) program. The RGP is required to discharge groundwater encountered during construction activities for development of a new hotel at the above-referenced site.
Construction activities will take place on a property which consists of two parcels of land (the “Site”), one in Cambridge, MA and one in Somerville, MA, totaling approximately 0.75 acres (32,670 square feet). The parcel at 263 Monsignor O’Brien Highway is shown on the City of Cambridge Assessor’s Maps as Parcel 7-35 and is also known as 241 and 245 Monsignor O’Brien Highway. The second parcel is known as Parcel 115-B-8 on the City of Somerville Assessor’s Maps, and is located at 1 McGrath Highway in Somerville, MA. The property is listed as a disposal site under the Massachusetts Contingency Plan and has been listed as one since December 1993 and again in February 1995 with the Massachusetts Department of Environmental Protection (MassDEP) under Release Tracking Number (RTN) 3-10317 and 3- 10852, respectively. Known contaminants in groundwater at the Site include non-chlorinated volatile organic compounds (VOCs), petroleum hydrocarbons, and polycyclic aromatic hydrocarbons (PAHs), poly-chlorinated biphenyl’s (PCB’s), and heavy metals. The VOCs, petroleum, and PCB’s were likely attributed to the historical use of reconditioning used metal drums which included cleaning, rinsing, and repainting the barrels. In addition, a portion of the site served as a gasoline station starting in 1967 until approximately 1988. The dewatering is occurring in conjunction with a Release Abatement Measure (RAM) and EPA TSCA Risk Based Cleanup Plan to manage contaminated soils during excavations for the building foundations and utilities.
6 Huron Drive, Natick, MA 01706 508-875-265 www.cdwconsultants.com
To obtain more updated groundwater quality, CDW collected groundwater samples for VOCs, total metals, total petroleum hydrocarbons (TPH), polychlorinated biphenyls (PCBs), total phenols, chloride, total cyanide, total suspended solids (TSS), total residual chlorine (TRC), trivalent chromium, hexavalent chromium, 1,4-dioxane, EDB, and semi-volatile organic compounds (SVOCs) (Table 1). Our proposed groundwater treatment system for this project consists of a frac tank and bag filters to remove suspended solids along with dual carbon treatment units, and ion resin exchange filter and a cartridge filter before entering a catch basin in Monsignor O’Brien Highway and ultimately discharging to the Charles River. Dewatering will be intermittent and will not be encountered at all locations during construction.
CDW reviewed online databases including the Massachusetts Division of Fisheries and Wildlife (NHESP), Massachusetts Geographical Information Systems (MassGIS), Cambridge GIS Viewer, and Massachusetts Cultural Resource Information Viewer (MACRIS). Based on these findings, the Site and the location of proposed discharge, do not appear to be located within an Area of Critical Environmental Concern (Appendix A). Historical Site information from MACRIS showed that there is a historical location listed at the Site, a Boston and Lowell Railroad Retaining Wall from the 19th century. At this time, CDW’s opinion is that dewatering of the Site will not affect the retaining wall (Appendix C).
In addition to the NOI application form, we have attached: Figure 1A: Water Flow Schematic and Discharge Location Figure 1B: Water Flow Schematic and Discharge Location Figure 2: Water Treatment System Schematic Figure 3: MassDEP Priority Resource Map Appendix A: Endangered Species Act Documentation Appendix B: StreamStats Flow Statistics Report Appendix C: Massachusetts Cultural Resource Information Report Appendix D: Effluent Limitations Calculations Table 1: Influent & Effluent Data Table Contest Analytical Influent Data Report Contest Analytical Effluent Data Report
Please call if you have any further questions.
Very truly yours, CDW CONSULTANTS, INC.
Shelby Amsel Environmental Scientist
cc: Massachusetts Department of Environmental Protection Division of Watershed Management 205B Lowell Street, Wilmington MA, 01887
MAG910000 Appendix IV – Part 1 – NOI NHG910000 Page 14 of 24
II. Suggested Format for the Remediation General Permit Notice of Intent (NOI)
A. General site information:
1. Name of site: Site address:
Street:
City: State: Zip:
2. Site owner Contact Person:
Telephone: Email: Mailing address:
Street: Owner is (check one): □ Federal □ State/Tribal □ Private City: State: Zip: □ Other; if so, specify:
3. Site operator, if different than owner Contact Person:
Telephone: Email:
Mailing address:
Street:
City: State: Zip: 4. NPDES permit number assigned by EPA: 5. Other regulatory program(s) that apply to the site (check all that apply):
□ MA Chapter 21e; list RTN(s): □ CERCLA
□ UIC Program NPDES permit is (check all that apply: □ RGP □ DGP □ CGP □ NH Groundwater Management Permit or □ POTW Pretreatment □ MSGP □ Individual NPDES permit □ Other; if so, specify: Groundwater Release Detection Permit: □ CWA Section 404
MAG910000 Appendix IV – Part 1 – NOI NHG910000 Page 15 of 24
B. Receiving water information: 1. Name of receiving water(s): Waterbody identification of receiving water(s): Classification of receiving water(s):
Receiving water is (check any that apply): □ Outstanding Resource Water □ Ocean Sanctuary □ territorial sea □ Wild and Scenic River
2. Has the operator attached a location map in accordance with the instructions in B, above? (check one): □ Yes □ No Are sensitive receptors present near the site? (check one): □ Yes □ No If yes, specify:
3. Indicate if the receiving water(s) is listed in the State’s Integrated List of Waters (i.e., CWA Section 303(d)). Include which designated uses are impaired, and any pollutants indicated. Also, indicate if a final TMDL is available for any of the indicated pollutants. For more information, contact the appropriate State as noted in Part 4.6 of the RGP. 4. Indicate the seven day-ten-year low flow (7Q10) of the receiving water determined in accordance with the instructions in Appendix V for sites located in Massachusetts and Appendix VI for sites located in New Hampshire. 5. Indicate the requested dilution factor for the calculation of water quality-based effluent limitations (WQBELs) determined in accordance with the instructions in Appendix V for sites in Massachusetts and Appendix VI for sites in New Hampshire. 6. Has the operator received confirmation from the appropriate State for the 7Q10and dilution factor indicated? (check one): □ Yes □ No If yes, indicate date confirmation received: 7. Has the operator attached a summary of receiving water sampling results as required in Part 4.2 of the RGP in accordance with the instruction in Appendix VIII? (check one): □ Yes □ No
C. Source water information: 1. Source water(s) is (check any that apply):
□ Contaminated groundwater □ Contaminated surface water □ The receiving water □ Potable water; if so, indicate municipality or origin: Has the operator attached a summary of influent Has the operator attached a summary of influent □ A surface water other sampling results as required in Part 4.2 of the RGP sampling results as required in Part 4.2 of the than the receiving water; if in accordance with the instruction in Appendix RGP in accordance with the instruction in so, indicate waterbody: □ Other; if so, specify: VIII? (check one): Appendix VIII? (check one): □ Yes □ No □ Yes □ No MAG910000 Appendix IV – Part 1 – NOI NHG910000 Page 16 of 24
2. Source water contaminants: a. For source waters that are contaminated groundwater or contaminated b. For a source water that is a surface water other than the receiving water, potable water surface water, indicate are any contaminants present that are not included in or other, indicate any contaminants present at the maximum concentration in accordance the RGP? (check one): □ Yes □ No If yes, indicate the contaminant(s) and with the instructions in Appendix VIII? (check one): □ Yes □ No the maximum concentration present in accordance with the instructions in Appendix VIII. 3. Has the source water been previously chlorinated or otherwise contains residual chlorine? (check one): □ Yes □ No
D. Discharge information 1.The discharge(s) is a(n) (check any that apply): □ Existing discharge □ New discharge □ New source Outfall(s): Outfall location(s): (Latitude, Longitude)
Discharges enter the receiving water(s) via (check any that apply): □ Direct discharge to the receiving water □ Indirect discharge, if so, specify:
□ A private storm sewer system □ A municipal storm sewer system If the discharge enters the receiving water via a private or municipal storm sewer system: Has notification been provided to the owner of this system? (check one): □ Yes □ No Has the operator has received permission from the owner to use such system for discharges? (check one): □ Yes □ No, if so, explain, with an estimated timeframe for obtaining permission: Has the operator attached a summary of any additional requirements the owner of this system has specified? (check one): □ Yes □ No
Provide the expected start and end dates of discharge(s) (month/year):
Indicate if the discharge is expected to occur over a duration of: □ less than 12 months □ 12 months or more □ is an emergency discharge Has the operator attached a site plan in accordance with the instructions in D, above? (check one): □ Yes □ No
MAG910000 Appendix IV – Part 1 – NOI NHG910000 Page 17 of 24
2. Activity Category: (check all that apply) 3. Contamination Type Category: (check all that apply)
a. If Activity Category I or II: (check all that apply)
□ A. Inorganics □ B. Non-Halogenated Volatile Organic Compounds □ C. Halogenated Volatile Organic Compounds □ D. Non-Halogenated Semi-Volatile Organic Compounds □ E. Halogenated Semi-Volatile Organic Compounds □ F. Fuels Parameters
□ I – Petroleum-Related Site Remediation □ II – Non-Petroleum-Related Site Remediation b. If Activity Category III, IV, V, VI, VII or VIII: (check either G or H) □ III – Contaminated Site Dewatering □ G. Sites with Known □ H. Sites with Unknown Contamination □ IV – Dewatering of Pipelines and Tanks Contamination □ V – Aquifer Pump Testing c. If Category III-G, IV-G, V-G, VI-G, □ VI – Well Development/Rehabilitation VII-G or VIII-G: (check all that apply) □ VII – Collection Structure Dewatering/Remediation □ VIII – Dredge-Related Dewatering □ A. Inorganics □ B. Non-Halogenated Volatile Organic Compounds d. If Category III-H, IV-H, V-H, VI-H, VII-H or □ C. Halogenated Volatile Organic VIII-H Contamination Type Categories A through Compounds F apply □ D. Non-Halogenated Semi-Volatile Organic Compounds □ E. Halogenated Semi-Volatile Organic Compounds □ F. Fuels Parameters
MAG910000 Appendix IV – Part 1 – NOI NHG910000 Page 18 of 24
4. Influent and Effluent Characteristics Known Known Influent Effluent Limitations Test Detection or or # of Parameter method limit Daily Daily believed believed samples (#) (µg/l) maximum average TBEL WQBEL absent present (µg/l) (µg/l)
A. Inorganics Ammonia Report mg/L --- Chloride Report µg/l --- Total Residual Chlorine 0.2 mg/L Total Suspended Solids 30 mg/L Antimony 206 µg/L Arsenic 104 µg/L Cadmium 10.2 µg/L Chromium III 323 µg/L Chromium VI 323 µg/L Copper 242 µg/L Iron 5,000 µg/L Lead 160 µg/L Mercury 0.739 µg/L Nickel 1,450 µg/L Selenium 235.8 µg/L Silver 35.1 µg/L Zinc 420 µg/L Cyanide 178 mg/L
B. Non-Halogenated VOCs Total BTEX 100 µg/L --- Benzene 5.0 µg/L --- 1,4 Dioxane 200 µg/L --- Acetone 7.97 mg/L --- Phenol 1,080 µg/L MAG910000 Appendix IV – Part 1 – NOI NHG910000 Page 19 of 24
Known Known Influent Effluent Limitations Test Detection or or # of Parameter method limit Daily Daily believed believed samples (#) (µg/l) maximum average TBEL WQBEL absent present (µg/l) (µg/l)
C. Halogenated VOCs Carbon Tetrachloride 4.4 µg/L 1,2 Dichlorobenzene 600 µg/L --- 1,3 Dichlorobenzene 320 µg/L --- 1,4 Dichlorobenzene 5.0 µg/L --- Total dichlorobenzene 763 µg/L in NH --- 1,1 Dichloroethane 70 µg/L --- 1,2 Dichloroethane 5.0 µg/L --- 1,1 Dichloroethylene 3.2 µg/L --- Ethylene Dibromide 0.05 µg/L --- Methylene Chloride 4.6 µg/L --- 1,1,1 Trichloroethane 200 µg/L --- 1,1,2 Trichloroethane 5.0 µg/L --- Trichloroethylene 5.0 µg/L --- Tetrachloroethylene 5.0 µg/L cis-1,2 Dichloroethylene 70 µg/L --- Vinyl Chloride 2.0 µg/L ---
D. Non-Halogenated SVOCs Total Phthalates 190 µg/L Diethylhexyl phthalate 101 µg/L Total Group I PAHs 1.0 µg/L --- Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fluoranthene Benzo(k)fluoranthene As Total PAHs Chrysene Dibenzo(a,h)anthracene Indeno(1,2,3-cd)pyrene MAG910000 Appendix IV – Part 1 – NOI NHG910000 Page 20 of 24
Known Known Influent Effluent Limitations Test Detection or or # of Parameter method limit Daily Daily believed believed samples (#) (µg/l) maximum average TBEL WQBEL absent present (µg/l) (µg/l) Total Group II PAHs 100 µg/L --- Naphthalene 20 µg/L ---
E. Halogenated SVOCs Total PCBs 0.000064 µg/L --- Pentachlorophenol 1.0 µg/L ---
F. Fuels Parameters Total Petroleum 5.0 mg/L --- Hydrocarbons Ethanol Report mg/L --- Methyl-tert-Butyl Ether 70 µg/L 120 µg/L in MA tert-Butyl Alcohol --- 40 µg/L in NH 90 µg/L in MA tert-Amyl Methyl Ether --- 140 µg/L in NH
Other (i.e., pH, temperature, hardness, salinity, LC50, additional pollutants present); if so, specify:
MAG910000 Appendix IV – Part 1 – NOI NHG910000 Page 21 of 24
E. Treatment system information
1. 1. Indicate the type(s) of treatment that will be applied to effluent prior to discharge: (check all that apply)
□ Adsorption/Absorption □ Advanced Oxidation Processes □ Air Stripping □ Granulated Activated Carbon (“GAC”)/Liquid Phase Carbon Adsorption □ Ion Exchange □ Precipitation/Coagulation/Flocculation □ Separation/Filtration □ Other; if so, specify:
2. 2. Provide a written description of all treatment system(s) or processes that will be applied to the effluent prior to discharge.
Identify each major treatment component (check any that apply): □ Fractionation tanks□ Equalization tank □ Oil/water separator □ Mechanical filter □ Media filter □ Chemical feed tank □ Air stripping unit □ Bag filter □ Other; if so, specify:
Indicate if either of the following will occur (check any that apply): □ Chlorination □ De-chlorination
3. Provide the design flow capacity in gallons per minute (gpm) of the most limiting component.
Indicate the most limiting component:
Is use of a flow meter feasible? (check one): □ Yes □ No, if so, provide justification:
Provide the proposed maximum effluent flow in gpm.
Provide the average effluent flow in gpm.
If Activity Category IV applies, indicate the estimated total volume of water that will be discharged:
4. Has the operator attached a schematic of flow in accordance with the instructions in E, above? (check one): □ Yes □ No
MAG910000 Appendix IV – Part 1 – NOI NHG910000 Page 22 of 24
F. Chemical and additive information 1. Indicate the type(s) of chemical or additive that will be applied to effluent prior to discharge or that may otherwise be present in the discharge(s): (check all that apply)
□ Algaecides/biocides □ Antifoams □ Coagulants □ Corrosion/scale inhibitors □ Disinfectants □ Flocculants □ Neutralizing agents □ Oxidants □ Oxygen □ scavengers □ pH conditioners □ Bioremedial agents, including microbes □ Chlorine or chemicals containing chlorine □ Other; if so, specify:
2. Provide the following information for each chemical/additive, using attachments, if necessary:
a. Product name, chemical formula, and manufacturer of the chemical/additive; b. Purpose or use of the chemical/additive or remedial agent; c. Material Safety Data Sheet (MSDS) and Chemical Abstracts Service (CAS) Registry number for each chemical/additive; d. The frequency (hourly, daily, etc.), duration (hours, days), quantity (maximum and average), and method of application for the chemical/additive; e. Any material compatibility risks for storage and/or use including the control measures used to minimize such risks; and f. If available, the vendor's reported aquatic toxicity (NOAEL and/or LC50 in percent for aquatic organism(s)).
3. Has the operator attached an explanation which demonstrates that the addition of such chemicals/additives may be authorized under this general permit in accordance with the instructions in F, above? (check one): □ Yes □ No; if no, has the operator attached data that demonstrates each of the 126 priority pollutants in CWA Section 307(a) and 40 CFR Part 423.15(j)(1) are non-detect in discharges with the addition of the proposed chemical/additive? (check one): □ Yes □ No
G. Endangered Species Act eligibility determination
1. Indicate under which criterion the discharge(s) is eligible for coverage under this general permit: □ FWS Criterion A: No endangered or threatened species or critical habitat are in proximity to the discharges or related activities or come in contact with the “action area”. □ FWS Criterion B: Formal or informal consultation with the FWS under section 7 of the ESA resulted in either a no jeopardy opinion (formal consultation) or a written concurrence by FWS on a finding that the discharges and related activities are “not likely to adversely affect” listed species or critical habitat (informal consultation). Has the operator completed consultation with FWS? (check one): □ Yes □ No; if no, is consultation underway? (check one): □ Yes □ No □ FWS Criterion C: Using the best scientific and commercial data available, the effect of the discharges and related activities on listed species and critical habitat have been evaluated. Based on those evaluations, a determination is made by EPA, or by the operator and affirmed by EPA, that the discharges and related activities will have “no effect” on any federally threatened or endangered listed species or designated critical habitat under the jurisdiction of the FWS. This determination was made by: (check one) □ the operator □ EPA □ Other; if so, specify: MAG910000 Appendix IV – Part 1 – NOI NHG910000 Page 23 of 24
□ NMFS Criterion: A determination made by EPA is affirmed by the operator that the discharges and related activities will have “no effect” or are “not likely to adversely affect” any federally threatened or endangered listed species or critical habitat under the jurisdiction of NMFS and will not result in any take of listed species. Has the operator previously completed consultation with NMFS? (check one): □ Yes □ No 2. Has the operator attached supporting documentation of ESA eligibility in accordance with the instructions in Appendix I, and G, above? (check one): □ Yes □ No
Does the supporting documentation include any written concurrence or finding provided by the Services? (check one): □ Yes □ No; if yes, attach.
H. National Historic Preservation Act eligibility determination 1. Indicate under which criterion the discharge(s) is eligible for coverage under this general permit: □ Criterion A: No historic properties are present. The discharges and discharge-related activities (e.g., BMPs) do not have the potential to cause effects on historic properties. □ Criterion B: Historic properties are present. Discharges and discharge related activities do not have the potential to cause effects on historic properties. □ Criterion C: Historic properties are present. The discharges and discharge-related activities have the potential to have an effect or will have an adverse effect on historic properties. 2. Has the operator attached supporting documentation of NHPA eligibility in accordance with the instructions in H, above? (check one): □ Yes □ No
Does the supporting documentation include any written agreement with the State Historic Preservation Officer (SHPO), Tribal Historic Preservation Officer (TPHO), or other tribal representative that outlines measures the operator will carry out to mitigate or prevent any adverse effects on historic properties? (check one): □ Yes □ No
I. Supplemental information
Describe any supplemental information being provided with the NOI. Include attachments if required or otherwise necessary.
Has the operator attached data, including any laboratory case narrative and chain of custody used to support the application? (check one): □ Yes □ No Has the operator attached the certification requirement for the Best Management Practices Plan (BMPP)? (check one): □ Yes □ No
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APPENDIX A ENDANGERED SPECIES ACT DOCUMENTATION
United States Department of the Interior FISH AND WILDLIFE SERVICE New England Ecological Services Field Office 70 Commercial Street, Suite 300 Concord, NH 03301-5094 Phone: (603) 223-2541 Fax: (603) 223-0104 http://www.fws.gov/newengland
In Reply Refer To: April 23, 2020 Consultation Code: 05E1NE00-2020-SLI-2295 Event Code: 05E1NE00-2020-E-06766 Project Name: 245-263 Monsignour Highway - Somerbridge
Subject: List of threatened and endangered species that may occur in your proposed project location, and/or may be affected by your proposed project
To Whom It May Concern:
The enclosed species list identifies threatened, endangered, proposed and candidate species, as well as proposed and final designated critical habitat, that may occur within the boundary of your proposed project and/or may be affected by your proposed project. The species list fulfills the requirements of the U.S. Fish and Wildlife Service (Service) under section 7(c) of the Endangered Species Act (Act) of 1973, as amended (16 U.S.C. 1531 et seq.).
New information based on updated surveys, changes in the abundance and distribution of species, changed habitat conditions, or other factors could change this list. Please feel free to contact us if you need more current information or assistance regarding the potential impacts to federally proposed, listed, and candidate species and federally designated and proposed critical habitat. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of the Act, the accuracy of this species list should be verified after 90 days. This verification can be completed formally or informally as desired. The Service recommends that verification be completed by visiting the ECOS-IPaC website at regular intervals during project planning and implementation for updates to species lists and information. An updated list may be requested through the ECOS-IPaC system by completing the same process used to receive the enclosed list.
The purpose of the Act is to provide a means whereby threatened and endangered species and the ecosystems upon which they depend may be conserved. Under sections 7(a)(1) and 7(a)(2) of the Act and its implementing regulations (50 CFR 402 et seq.), Federal agencies are required to utilize their authorities to carry out programs for the conservation of threatened and endangered species and to determine whether projects may affect threatened and endangered species and/or designated critical habitat. 04/23/2020 Event Code: 05E1NE00-2020-E-06766 2
A Biological Assessment is required for construction projects (or other undertakings having similar physical impacts) that are major Federal actions significantly affecting the quality of the human environment as defined in the National Environmental Policy Act (42 U.S.C. 4332(2) (c)). For projects other than major construction activities, the Service suggests that a biological evaluation similar to a Biological Assessment be prepared to determine whether the project may affect listed or proposed species and/or designated or proposed critical habitat. Recommended contents of a Biological Assessment are described at 50 CFR 402.12.
If a Federal agency determines, based on the Biological Assessment or biological evaluation, that listed species and/or designated critical habitat may be affected by the proposed project, the agency is required to consult with the Service pursuant to 50 CFR 402. In addition, the Service recommends that candidate species, proposed species and proposed critical habitat be addressed within the consultation. More information on the regulations and procedures for section 7 consultation, including the role of permit or license applicants, can be found in the "Endangered Species Consultation Handbook" at: http://www.fws.gov/endangered/esa-library/pdf/TOC-GLOS.PDF
Please be aware that bald and golden eagles are protected under the Bald and Golden Eagle Protection Act (16 U.S.C. 668 et seq.), and projects affecting these species may require development of an eagle conservation plan (http://www.fws.gov/windenergy/ eagle_guidance.html). Additionally, wind energy projects should follow the wind energy guidelines (http://www.fws.gov/windenergy/) for minimizing impacts to migratory birds and bats.
Guidance for minimizing impacts to migratory birds for projects including communications towers (e.g., cellular, digital television, radio, and emergency broadcast) can be found at: http:// www.fws.gov/migratorybirds/CurrentBirdIssues/Hazards/towers/towers.htm; http:// www.towerkill.com; and http://www.fws.gov/migratorybirds/CurrentBirdIssues/Hazards/towers/ comtow.html.
We appreciate your concern for threatened and endangered species. The Service encourages Federal agencies to include conservation of threatened and endangered species into their project planning to further the purposes of the Act. Please include the Consultation Tracking Number in the header of this letter with any request for consultation or correspondence about your project that you submit to our office.
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