TOWN OF ANDOVER
MASSACHUSETTS

Town Offices
36 Bartlet Street
Andover, MA 01810
(978) 623-8200
www.town.andover.ma.us

September 27, 2000

Bob Durand, Secretary
EOEA - MEPA Office
Attn:Richard Foster (EOEA 12306)
251 Causeway Street — Suite 900
Boston, MA 02114

Dear Mr. Durand:

   This letter is submitted as a comment regarding the ENF for Powder Mill Square, North Main Street, Andover, MA (EOEA #12306) by Northpoint Realty, 733 Turnpike Street, Suite 58, North Andover, MA 01845. The project proposes the construction of 72 units of housing and a 65,000 sq. ft. office building on 5.01 acres in the downtown Andover area.

   The main purpose of this comment letter is to alert you to several critical public health and environmental concerns, which are not identified in the ENF as a result of incorrect answers to the standard ENF question format.

   The list of local permits and approvals is incomplete in that it does not identify a local sewer connection permit. This permit is required by regulation of the Andover Board of Health and Andover Sewer Commissioners and is critical to the efficacy of the sewage disposal system for the project.

   Several issues relative to the issuance of the sewer permit remain unresolved. The project directly abuts and is in the flood plain area of the Shawsheen River. With regard to the AREAS OF CRITICAL ENVIRONMENTAL CONCERN SECTION, the proponents have stated that the project is not in or adjacent to such an area. This abutting section of the Shawsheen River has been subject to periodic overflow and flooding into the project area. The town's main sewer trunk, the Shawsheen River Interceptor Sewer, directly abuts the river and has been subject to overflow and the release of raw sewage on several occasions. These discharges might be attributed to several variables affecting pipe integrity including, but not limited to, vandalism of manholes, crushed or otherwise defective pipes, root growth or other factors facilitating inflow and infiltration. All of these issues must be addressed in a manner satisfactory to the town prior to issuance of a sewer connection permit for an additional 18,543 gpd flow from the proposed facility.

   Additional public health and environmental concerns include a proposal to provide storage capacity on-site via basement storage tanks of some 30,000 gallons (2 day flow capacity) of raw sewage. The Andover Board of Health is particularly concerned with the ventilation of methane gas associated with this storage capacity in a habitable dwelling area.

  In the SOLID AND HAZARDOUS WASTE SECTION the proponents indicate that the project will not meet any review thresholds related to hazardous waste nor will it require any permits related to hazardous waste. Project proponents have informed the town that the site is currently undergoing a MGL Chapter 21 E site assessment and that there may indeed be releases that require DEP review and approval under the provisions of the Mass. Contingency Plan.

   Owing to the above concerns, the Andover Board of Health requests that the above issues be addressed in the ENF Certificate by requiring a full Environmental Impact Report for the project.

Please contact this office if I may be of any further assistance in this matter.
Sincerely yours,


Everett F. Penney,Jr.
Director of Public Health
For the Board of Health

EFP:jpn
Cc:Andover Board of Health
 Reginald S. Stapczynski, Town Manager
Thomas Urbelis, Town Counsel