June 2, 2000                                                                     SIMMONS Environmental Services, Inc.
Reference #000304                                                           213 Elm St.
                                                                                      Salisbury, Ma 01952
                                                                                      Telephone:(978)-463-6669

Thomas Laudani
NORTHPOINT REALTY DEVELOPMENT CORP.
733 Turnpike Street, Suite 158
North Andover, Massachusetts 01845

RE:Stevens Street
Powder Mill Square Development

Dear Mr. Laudani:

   The purpose of this correspondence is to provide an update of the project status concerning environmental assessment for the reference project. As discussed below, the correspondence also contains recommendations for additional work that will be required to comply with the provisions of the Massachusetts Contingency Plan ('MCP").

   Per your authorization to proceed Simmons Environmental Services (SIMMONS) installed a series of test borings on the subject property as shown on the enclosed Figure 2. Selected test bores were also developed as monitoring wells. In addition, monitoring wells that had been installed on the subject property by the environmental consultant representing the westerly abutter, the Newton Gray LLC were also accessed and sampled.  Boring Logs and Well Construction Logs are provided as an appendix to this summary letter.

   The original concern regarding this project was a reported "fuel oil" odor observed by GEOTECHNICAL SERVICES, INC. ("GSI") in March of 2000 during that firm's study for soil for load bearing strength and foundation design. The location of the test pit, which GSI observed the "fuel oil" odor, was their designation TP-7. That location is shown on SIMMONS' figure as soil boring (SB) 1 SIMMONS monitoring well (SMW) 1, located along the easterly property bound with North Main Street.

   The balance of the test borings and monitoring wells were placed in a spatial pattern that was believed to represent conditions proximate to or hydraulically downgradient of portions of the property that had previously been used for commercial activities. SB-2/SMW-2 was placed downgradient of areas where GSI had observed a "fuel oil" odor in its Test Pit 7. The purpose of SB-2/SMW-2 was to determine how far a petroleum plume (if any) extended onto the subject property. SB-4 was selected to observe soil conditions proximate to a former sewer pump station and two monitoring wells installed by the Newton Group LLC's environmental consultant. SB-7 was placed proximate to the assumed property bound with the Shawsheen River. That boring is also adjacent to monitoring wells also installed by Newton Group LLC's environmental consultant.  SB-7, SB-9/SMW-9 and SB-10/SMW-10 were installed in the vicinity of the property that had previously been used for commercial purposes and where buildings associated with the former MARLAND MILLS operation had been located. SB-8/SMW-8 was placed in the center of a previous parking area for employees.

   During placement of the borings, soil was screened for volatile organic compounds using the procedure recommended by the Massachusetts Department of Environmental Protection (MDEP) and commonly referred to as the jar headspace method. This screening is used to make a semiquantitative measurement of the presence of volatile organic compounds by trapping gases from a soil sample beneath an aluminum foil seal on a jar and then measuring the concentration of trapped gases against a device calibrated to a relative standard, typically isobutylene. Headspace results of<10 parts per million (by volume relative to the selected standard expressed as ppmvr) generally do not require further analysis by conventional laboratory methods. For fuel oil releases, MDEP guidance indicates that only extractable petroleum hydrocarbons ("EPH") need to be analyzed if headspace screening results are less than 100 ppmvr. Headspace results ranged from 0 to 30 ppmvr throughout all of these borings with the highest result at SB-1 at 10'-12' below grade. However, fingerprint analyses of that sample for source identification purposes showed no petroleum hydrocarbons present. Consequently, EPH fractions and 5 characteristic heavy metals were included within the battery of analytical tests done to evaluate soil conditions against applicable Reportable Concentrations (RCs) for soil analytes as provided in the MCP. Tables 1 and 2 summarize these data and show only one exceedance of the RC for the applicable S-1 category. RCS- 1 category is applicable because property that is used for residential purposes or is within a residential zone is located within 500' of the exceedance. In this instance, the RCS-1 for arsenic (30 mg/Kg) was exceeded by a slight amount (4 mg/Kg). However, the arithmatic average of the arsenic concentration across all of the borings is less than the required cleanup level (30 mg/Kg). Therefore, no remedial actions are necessary, but MDEP must still be notified of the condition.

   With regard to groundwater, I had indicated to you previously during a telephone conversation that an exceedance of the reporting threshold for groundwater had been observed in one well, SMW-8. That exceedance was for 1,l-dichloroethylene (1,1-DCE). The reporting limit for that analyte is 1 part per billion (ppb). The exposure limits for that analyte are 1 ppb and 50,000 ppb for categories GW-2 and GW-3, respectively. The GW-2 exposure category is intended to protect against indoor exposure from volatile compounds that dissolve in water and partition. The partitioning process means the compound can change directly to a gaseous state and migrate through soil thus resulting in a potential exposure via inhalation. The GW-3 exposure category is intended to protect surface waters and aquatic organisms.  The GW-2 exposure category is applicable if groundwater depth below grade is less than 15' and the exceedance occurs within 30' of an occupied structure. In this instance, the depth to groundwater throughout the property is less than 15'.  Moreover, an appropriate Standard of Care requires that a Licensed Site Professional (LSP) look at reasonably foreseeable uses of land when evaluating exposure potential. Based upon the proposed development as provided to SIMMONS by MERRIMACK ENGINEERING, INC., SMW-8 is within 30' of a proposed building that will clearly be occupied. Therefore, a GW-2 exposure scenario applies. The GW-3 exposure scenario is applicable to all sites based on the presumption that groundwater ultimately discharges to surface water.

   As a result of our conversation concerning the reporting threshold exceedance for 1,1-DCE, it was agreed to re-sample that well and either confirm or deny the previous exceedance. The most recent data received on May 25, 2000, confirm that 1,l-DCE is present above the reporting threshold (RCGW-2) and the most simplistic exposure limit (Method 1) GW-2. Therefore, reportable conditions exist at this property for arsenic at a concentration of 34 mg/Kg and for 1,1- DCE at a concentration of 8 g/L. All of the groundwater analytical results are displayed in Table 3. These data constitute a condition where notification must be provided to MDEP within 120 days of the owner/operator's knowledge of these conditions.

   As indicated above, the soil issue can be dealt with easily by calculation of an exposure point concentration average across the property that includes the result for arsenic from all of the borings. The groundwater issue can also be resolved, but it will require more effort. MDEP requires that the affected area (called the disposal site) be defined both horizontally and vertically. This will require installation of additional monitoring wells to the south and east of SMW-8 to determine if there is an upgradient source of contamination. Both the April and May 2000 analyses for groundwater showed the presence of l,l,l-trichloroethane (TCA) but at concentrations below the reporting threshold for that analyte. Those data suggest that something is going on with groundwater as l,l-DCE is rarely, if ever, found as a single component of contamination. It is usually associated with a degradation product of trichloroethylene (TCE) or perchloroethylene (PCE).  Chlorinated volatiles such as 1,1,1 -TCA, TCE and PCE have historically been used for degreasing or cleaning activities. Moreover, the owners of the adjacent property to the west has recently submitted a Phase II Comprehensive Site Assessment Report to MDEP regarding a release of chlorinated solvents (TCE).  That consultant theorizes that contaminated groundwater from the former MARLAND MILLS complex migrates below the river bed and subsequently rises along the westerly portion of the subject parcel where low concentrations of several chlorinated compounds were observed. (See Table 3). Therefore, that theory will need to be evaluated with regard to the observed conditions at SMW-8 as well as the reporting threshold exceedances for the well on the Powder Mill Square property.  That consultant's theory may be appropriate for wells near the river, but it does not adequately explain the contaminant or concentration observed at SMW-8 which is substantially upgradient.

   Pending the results of further subsurface investigation around SMW-8, a Method 2 Risk Characterization could be used to show that site specific conditions will prevent migration of l,l-DCE via partitioning to structures to be developed on the site. Therefore, the remaining l, l-DCE and l,l,l-TCA would not present a problem with regard to impact on surface water as these contaminants migrate toward the Shawsheen River.

   Concurrent with the additional investigation for groundwater in the vicinity of SMW-8, it is also recommended that a boring/well be placed closer to the easterly property bound with North Main Street. Research at the MDEP regional office has confirmed that a release of gasoline has occurred from the Sunoco Station located on the easterly side of North Main Street.  The database review for the subject property has listed only 200 North Main Street as a release location. The Andover Fire Department also confirmed activity at 200 North Main, but claimed to have no confirmatory information concerning contamination levels. Information supplied by Attorney Robert Lavoie suggested that a separate MDEP case file had been started at 200 North Main Street. Review of that file at the MDEP Regional Office confirmed that contaminated soil and groundwater were encountered during utility line installation in North Main Street during late 1997. MDEP databases are keyed on street addresses and the Town's Consultant identified the location as 200 North Main Street although the work area was in the public street. Subsequently, the SUN COMPANY, INC. (SUNOCO) accepted responsibility for the release and is progressing through various steps in the MCP process. Consequently, the source of the petroleum odor identified by GSI and reported as a 30 ppmvr headspace screening result by SIMMONS is gasoline, not fuel oil as originally suspected. Therefore, installation of a boring/well at the edge of the subject property near North Main Street should take place to confirm if volatile petroleum hydrocarbons (VPH) fractions exceed reporting thresholds. If an exceedance is measured, a Downgradient Property Status (DPS) Opinion could be filed relieving the owner/operator of Powder Mill Square from further response measures concerning the petroleum (gasoline) release. A copy of the correspondence to MDEP from Sun's representative accepting responsibility for the release is also provided in the Appendix.

   Although additional work will be required to address MCP requirements, my professional opinion is that none of the conditions that we have observed should preclude the development of the property. Each of the conditions should be manageable by appropriate site investigation techniques and risk characterization measures.

   Please review this status report and call me with any questions you may have.
   Very truly yours,



William A. Simmons
Licensed Site Professional

WAS: rac

Enclosures:
Figure 1-Site Locus
Figure 2-Site Plan
Figure 3-Overlay of Proposed Buildings
Table 1-Comparison of Soil Analytical Results to MCP
Applicable RCs for RCRA 5 Metals
Table 2-Comparison of Soil Analytical Results to MCP
 Applicable RCs for EPH
Table 3-Comparison of Groundwater Analytical Results to MCP
Applicable Groundwater Standards for Halogenated Volatiles
Subsurface Exploration Logs
Revised Release Notification Form (Handex®)

Cc:   Robert W. Lavoie, Esq.
DEVINE, MILLIMET & BRANCH
12 Essex Street
Box39
Andover, Massachusetts 01810