UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

ONE CONGRESS STREET SUITE 1100 BOSTON, MASSACHUSETTS 02114-2023

MEMORANDUM DATE: April 14, 2008 SUBJ: Property Use Assessment Lowell Iron & Steel Silresim Superfund Site, Lowell, MA FROM: Dan Keefe, Remedial Project Manager, U.S. EPA Region I THRU: Bob Cianciarulo, Chief, MA Superfund Section Meghan Cassidy, Chief, Technical Support Section TO: Site File

SummaryThe purpose of this memorandum is to document an inspection performed on March 19th, 2008, of the Lowell Iron and Steel (LIS) facilities located at 50 and 44 Tanner Street, Lowell, Massachusetts. The LIS parcel is described as Parcel No. 5640-16 by the City of Lowell Tax Assessor’s office in an area zoned as “General Industry”. The 4.17-acre property has three improved structures, each of varying age, size, and construction (refer to Property Map included in Attachment A). Specifically, the inspection was conducted to document the degree to which the building were occupied and the activities performed by the various occupants. The inspection team consisted of Dan Keefe (EPA), Janet Waldron (MassDEP), David O’Connor (USACE) and Dennis Scannell (LIS). Background The LIS property is located north of, and adjacent to, the Silresim Superfund site. Numerous investigations and reports, including the most recent Status Report (SR30), reveal a relatively stable plume of VOC-contaminated groundwater; the plume extends substantially onto the LIS property (inclusive of the footprint of some of the LIS buildings). An assessment of indoor air at the LIS property (1999 – 2002) and a property use assessment of the B&L Used Auto Parts property (September 2005) have been previously completed. Based on the indoor air sampling, benzene (5 occurrences); 1,2,4-trimethylbenzene (4); 1,3,5-trimethylbenzene (3) were detected the most frequently with more infrequent detections of MIBK; MEK; 1,2-dichlorobenzene; and trichloroethene. It was also noted that many of the compounds that were detected “may have been associated with operations within the building

themselves”. The 2005 inspection of the B&L property confirmed the presence of a wide array of industrial and automotive cleaners and automobile fluids (e.g., oil, gasoline, and antifreeze). These observations are described in more detail in a 2007 Memorandum to the Site File prepared by Jim DiLorenzo. The 2007 Memorandum concluded that any attempt to characterize ambient air for the possible presence of site-related volatile organic compounds (VOCs) would be difficult given the industrial use of the property. Accordingly, ambient air samples were not collected from the B&L property. The 2007 Memorandum also memorialized EPA’s determination that vapor intrusion into the LIS facilities was not a complete pathway. This determination was made based on the lack of any occupants in the “lower levels” (i.e., in basements) as well as the industrial-nature of operations in which LIS and/or their tenants were engaged. This assessment is meant as a follow-up to the 2007 Memorandum. Based on the continued lack of utilization of basements as well as the various industrial operations conducted, EPA does not consider the indoor migration pathway to be complete at any of the LIS properties. Given the identification (in 2001) of primarily BTEX-related compounds and the observation made during this assessment, EPA concludes that there are significant potential sources of these compounds from occupationally-used materials which contain these substances. As noted in the Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway, November 2002, OSHA will generally take the lead role in addressing occupational exposures. Moreover, the guidance recommends that “any change in future use of the facility might suggest a need to reevaluate the indoor air pathway”. Accordingly, EPA recommends periodic evaluation of groundwater sampling results (noting any substantially increasing trends of groundwater VOCs in the vicinity of the LIS properties) as well as evaluation of how the properties are utilized; this evaluation could be completed annually and be associated with annual collection of groundwater samples. EPA will assess this no less than every 5 years as part of its future 5-year reviews or sooner based on review of groundwater data or if provided notice as described below. Lastly, in June 1995 the United States of America, acting through EPA, and Scannell Boiler Works (LIS property owners) entered a Grant of Easement and Restriction. Based on these restrictions, prior to any construction activities, the Grantor (LIS) must notify EPA and request the opportunity to consult with EPA with the respect to conditions at the site. This restriction affords additional assurance that no new construction could be initiated without advance knowledge by EPA which, in turn, would necessitate a re-evaluation of the vapor intrusion pathway. Building No. 1 This 2,400-square-foot (sf) commercial building was constructed circa 1976 and is located immediately adjacent to Tanner Street and is currently occupied by two tenant businesses. Historically, this building was the location of parts storage for LIS; and LIS continues to utilize the lower level/basement for this purpose. The inspection team noted that the basement is poured concrete of moderate to good condition. According to Mr. Scannell, there are no building sumps and there was no evidence of groundwater penetration (staining, watermarks, etc…). Numerous steel parts were observed as well as miscellaneous paints, adhesives and vinyl coatings.

According to Mr. Scannell, in addition to part storage, this space is used occasionally by the tenant businesses to store papers and office documents (white goods). This area is occasionally visited by LIS personnel for the purpose of retrieving a necessary part (refer to pictures 1 – 5 in Attachment B). Building No. 2 This approximately 13,000-sf factory is the oldest of the three LIS buildings and was constructed circa 1860s (based on information provided from Mr. Scannell). Prior to LIS occupation, it was used as a shoe manufacturer. LIS acquired the property in 1880s and proceeded to fabricate and repair steel boilers. In the more recent past (last 20 years) boiler fabrication and repair have been eliminated and the business consist predominately of cutting, painting, welding, and fabricating common structural steel components (such as I- beams, Trestles, etc…) as well as the occasional fabrication of custom steel parts. Based on field observations, it is constructed predominately of brick (above grade) with an unfinished basement constructed of field stone. According to Mr. Scannell (and in part corroborated by the field team), the basement has a poured concrete floor. However, due to poor lighting (the basement does not have any lighting) the condition of the floor/concrete could not be ascertained. Occasionally surface water collects inside a portion of the basement, adjacent to and near an old, garage-style door on the southeast end of the facility. According to Mr. Scannell, the periodic accumulation of surface water was responsible for the accumulation of some dirt/sediment in the basement area. Several cars were stored in this area as well as miscellaneous old (defunct) milling and cutting equipment. In addition, some steel rods (stock) were contained in wooden racks for possible future use. According to Mr. Scannell there is not a building sump, and the area is very rarely (if ever), accessed for work-related purposes; this was further evidenced by the lack of power and lighting in this space. On the ground-level (first floor) of this building, some light machining of steel is performed. Several industrial rolling, grinding and cutting machines were observed with typical metal shavings and cutting oils noted on the floor surrounding these machines (refer to pictures 6 – 14 in Attachment B). Building No 3. Building No. 3 (with an address of 44 Tanner Street) is the principal location for LIS operations and is the farthest removed from the Silresim property. The original age of this building is unknown, however, due to a substantial fire, it was significantly rebuilt in the 1940s. It is approximately 20,000 sf of which approximately 1/3rd of the space is leased to Lowell Fleet Maintenance (Fleet), a company specializing in the maintenance and repair of commercial tractor trailers. There is no basement or crawl space under this building as it was constructed as “slab on grade”. Principle operations conducted by LIS in this building include the cutting, bending, rolling and fabrication of various steel work products. Industrial cutting and stamping machines and welding equipment were noted. In addition, occasionally finished products require painting which is also completed in this area. Numerous paints, oils, and gas cylinders were noted (refer to pictures 15 – 21 in Attachment B).

In regard to the remaining portion of Building 3, as noted above, a portion of the building is rented to Fleet. Fleet principally operates a garage for large tractors and commercial trailer fleets. Typical activities include routine truck maintenance such as oil changes, brake relining, etc... They utilize two “part-degreasers” (reportedly non-VOCs) and indicated that they burn their waste oil in an on-site furnace. New oil and automobile fluids are stored in an above ground storage tanks (refer to pictures 22 – 28 in Attachment B).

Attachment A Site Map

LIS Property

Bld #3

Silresim

G

Bld #2

Bld #1

WTP

Attachment B

Photographs

Picture No.: 1 Date: March 19th, 2008 Description: Building No. 1, immediately adjacent to Tanner Street.

Picture No.: 2 Date: March 19th, 2008 Description: Basement of Building No.1.

Picture No.: 3 Date: March 19th, 2008 Description: Miscellaneous materials and parts stored in basement of Building No. 1.

Picture No.: 4 Date: March 19th, 2008 Description: Miscellaneous materials and parts stored in basement of Building No. 1.

Picture No.: 5 Date: March 19th, 2008 Description: Paints and adhesives located in the basement of Building No. 1.

Picture No.: 6 Date: March 19th, 2008 Description: Vehicle storage in the Basement of Building No. 2.

Picture No.: 7 Date: March 19th, 2008 Description: Basement of Building No. 2.

Picture No.: 8 Date: March 19th, 2008 Description: Basement of Building No. 2. Note defunct equipment.

Picture No.: 9 Date: March 19th, 2008 Description: Basement of Building No. 2, miscellaneous debris.

Picture No.: 10 Date: March 19th, 2008 Description: Basement of Building No. 2, steel stock storage.

Picture No.: 11 Date: March 19th, 2008 Description: Building No. 2 (Ground level), additional steel stock storage.

Picture No.: 12 Date: March 19th, 2008 Description: Building No. 2, milling machine used on the first floor (ground level).

Picture No.: 13 Date: March 19th, 2008 Description: Cutting oil used in Building No. 2 operations (ground level)

Picture No.: 14 Date: March 19th, 2008 Description: Cutting oil used in Building No. 2 operations (ground level)

Picture No.: 15 Date: March 19th, 2008 Description: Inside of Building No. 3, principle location of LIS operations.

Picture No.: 16 Date: March 19th, 2008 Description: Building No. 3. Note: metal sheet rolling/bending machine.

Picture No.: 17 Date: March 19th, 2008 Description: Building No. 3. Note Metal stamping machine.

Picture No.: 18 Date: March 19th, 2008 Description: Building No. 3, miscellaneous operations and equipment.

Picture No.: 19 Date: March 19th, 2008 Description: Cutting flueind used in machines in Building No. 3.

Picture No.: 20 Date: March 19th, 2008 Description: Paint and steel coatings used in Building No. 3.

Picture No.: 21 Date: March 19th, 2008 Description: Paint and steel coatings used in Building No. 3.

Picture No.: 22 Date: March 19th, 2008 Description: Building No. 3 (Operations by Lowell Fleet Maintenance).

Picture No.: 23 Date: March 19th, 2008 Description: Building No. 3. Parts degreaser (1 of 2) used by Fleet Maintenance.

Picture No.: 24 Date: March 19th, 2008 Description: Building No. 3. Parts degreaser (2 of 2) used by Fleet Maintenance.

Picture No.: 25 Date: March 19th, 2008 Description: Antifreeze above-ground storage tanks (used by Fleet).

Picture No.: 26 Date: March 19th, 2008 Description: Virgin oil above-ground storage tank used by Fleet).

Picture No.: 27 Date: March 19th, 2008 Description: Building No. 3; miscellaneous parts and supplies used by Fleet.

Picture No.: 28 Date: March 19th, 2008 Description: Building No. 3; miscellaneous automobile/truck fluids (new and used).