commitment integrity t 800.446.5518 drive results t 781 ... · 8/27/2015 phone discussion ka spoke...

COMMITMENT & INTEGRITY

DRIVE RESULTS

980 Washington Street | Suite 325Dedham, Massachusetts 02026www.woodardcurran.com

T 800.446.5518T 781.251.0200F 781.251.0847

August 12, 2016

Mr. Richard Fisher, EPA Project CoordinatorEnvironmental Protection Agency – Region 1, New EnglandFive Post Office Square, Suite 100Mail Code OSRR07-1Boston, MA 02109-3912

Transmittal via electronic mail only

Subject: Access AlternativesLewis Pond Sediment and Floodplain Soil RemedyBlackburn & Union Privileges Superfund Site, Walpole, MA

Dear Mr. Fisher:

Pursuant to the Consent Decree (CD) in connection with the case United States v. BIM InvestmentCorp., et. al. (Civil Action No. 1:10-cv-11263) with an effective date of December 21, 2010 the SettlingDefendants1 are performing work related to the Remedial Design/Remedial Action (RD/RA) at theBlackburn and Union Privileges Superfund Site in Walpole, Massachusetts (the “Site”).

The enclosed materials related to property owner access discussions and access alternatives areprovided in response to your July 14, 2016 email. Table 1 provides property information and a summaryof contact attempts for those property owners who have not signed agreements or respondedsubstantively to the Settling Defendants’ requests for access. In general, those instances in whichcontact with property owners has not occurred or has been limited reflects the severe lack of feasibilityof using those properties for the significant work required to be performed. Table 2 is an analysis ofpotential alternative access approaches utilizing either a smaller portion of the parking lot on WestStreet (“Manzo Lot”), or a combination of other properties. This table also provides a summary of thefeasibility of these alternative access approaches. Figure 1 is a map of the Lewis Pond vicinityhighlighting the properties referenced in Table 2.

Consistent with Paragraph 98.a. of the CD, in order to protect certain information regarded as BusinessConfidential, a supplement to Table 2 is being provided under separate cover.

Please contact one of the designated Project Coordinators (David Kelley 774.284.2207 or Paul Bucens617.899.0354) should you have any questions concerning this deliverable.

Sincerely,

Eric E. HultstromWoodard & Curran – Supervising Contractor

1 The “Settling Defendants” is a defined term in the Consent Decree, and includes BIM Investment Corporation (now known asPhilip Shaffer Family Corp.), Shaffer Realty Nominee Trust (now known as Philip Shaffer Family Corp.), Tyco HealthcareGroup LP (now known as Covidien LP) and W.R. Grace & Co.-Conn., for itself and on behalf of W.R. Grace & Co. andRemedium Group, Inc. (effective April 2, 2014, Remedium Group, Inc. was merged into its affiliate W. R. Grace & Co.-Conn.)

Blackburn & Union (223203.00) 2 Woodard & CurranAccess Alternatives Transmittal Letter August 12, 2016

Enclosures:Table 1: Property Owner Contact SummaryTable 2: Matrix of Conceptual Access AlternativesFigure 1: Potential Access Alternatives

CC: Peter DeCambre – USEPA (1 electronic copy)Sean Czarniecki – AECOM (1 electronic copy)Paul Craffey – MassDEP (1 electronic copy)Robin Chapell – Town of Walpole (1 electronic copy)David Kelley – Covidien (Project Coordinator) (1 electronic copy)Paul Bucens – W.R. Grace (Project Coordinator) (1 electronic copy)Sol Feldman, Esq. (1 electronic copy)

Table 1: Property Owner Contact Summary

Lewis Pond Sediment and Floodplain Soil Remedy

Blackburn & Union Privileges Superfund Site, Walpole, MA

Date Type of contact Notes

3/10/2015 Letter Notification to property owner (Keegan) of impending sediment remediation Bid Walk.

6/10/2015 Notification Notification to W&C by Robin Chapell (Town of Walpole) that property changed hands (to Sansone).

7/31/2015 Letter to Introductory letter (overview of project and need for access) and request for preferred meeting date to discuss access.

8/4/2015 Phone call from Call from Richard Sansone (RS). Set up meeting time for 8/5/2015 at property.

8/5/2015 In-person meeting Kyle Apigian (KA) of Woodard & Curran (WC) visited RS at 46 Riverview to discuss concerns.

8/13/2015 email to KA emailed RS to inform him of survey work at his property. He responded indicating that it was OK.

10/2/2015 Letter to Mailed Access Agreement

10/30/2015 email to KA emailed RS asking about agreement status.

11/1/2015 email from RS emailed KA and indicated he would call.

11/20/2015 Phone discussion KA spoke with RS on the phone. RS indicated that he is going to consult some family members in real estate, as well as an attorney, to make sure his

interests are addressed by the agreement. He does not want to hold up the process, and does intend to sign, but wants to make sure that the

agreement is sound based on the amount of work planned.

12/15/2015 email to KA emailed RS asking about agreement status.

12/21/2015 email from RS emailed to indicate that he is still waiting on advice on the agreement, and that he does not expect to hear back until January.

3/14/2016 email from Emily Bender (EB) forwarded letter (dated 3/11/2016) from Sansone counsel. The letter presents a list of requests for inclusion in the access agreement.

4/4/2016 Phone discussion Grace counsel and Sansone counsel in discussions.

4/22/2016 email to Grace counsel transmitted Revised Access Agreement and supporting information to Sansone counsel, including $5000 monetary offer.

5/16/2016 Phone call to Grace counsel following up with Sansone counsel about agreement status -no response.

5/27/2016 email from Sansone counsel email to Grace counsel indicating that he has not heard back from RS.

6/23/2016 email to Grace counsel following up with Sansone counsel about agreement status -no response.

7/8/2016 email to Grace counsel following up with Sansone counsel about agreement status -no response.

7/20/2016 In-person Grace counsel spoke with Sansone counsel about agreement status -Sansone counsel is awaiting response from client.

8/3/2016 certified mailing Letter from Settling Defendants to owner requesting response about proposed agreement.

3/10/2015 Letter to Notification of impending sediment remediation Bid Walk to Charles Harcovitz (CH).

7/31/2015 Letter to Introductory letter (overview of project and need for access) and request for preferred meeting date to discuss access

9/1/2015 Phone discussion Spoke briefly on phone - KA will call back on cell Friday morning.

9/4/2015 Phone discussion Spoke briefly on phone - determined that it would be best to meet in person on 9/10 at the property in Walpole.

9/8/2015 Phone discussion CH moved date of meeting to 9/14.

9/14/2015 In-person meeting Met with Charlie and Linda Harcovitz (CH/LH) at their property. Agreeable about the work. Would like to see the willow trees come down. LH provided

email address.

10/2/2015 Letter to Mailed Access Agreement.

10/30/2015 email to KA emailed Mr. and Mrs. Harcovitz asking about agreement status.

11/17/2015 Phone discussion KA spoke briefly with CH on the phone - CH has briefly reviewed agreement, concerned that the agreement is too broad, suggested the contractor

could find alternate access. CH may follow up with KA.

11/17/2015 Phone discussion KA spoke briefly with CH on the phone. Unwilling to sign agreement in current form, but also unwilling to discuss details or have any type of

conversation about the agreement. Noncommittal about willingness to review agreement or provide a response.

1/26/2016 Phone discussion KA had brief phone discussion with CH. CH not able/willing to talk.

2/11/2016 email to KA emailed CH/LH, at their request through Emily Bender (EB) of USEPA, to provide a summary of our conversations and a copy of the draft agreement.

2/17/2016 email to KA emailed CH/LH to confirm that the 2/11/2016 email was received.

2/18/2016 email from CH/LH responded by email to confirm that the emails from 2/11/2016 and 2/17/2016 were received.

3/8/2016 USEPA update Emily Bender indicated that conversation with Harcovitz is on hold based on Mr. Harcovitz' personal issues.

7/13/2016 USEPA update USEPA attempting contact.

8/3/2016 certified mailing Letter from Settling Defendants to owner requesting response about proposed agreement.

Owner: Sansone

Address: 46 Riverview Place

Access Needs:

Access road

Staging/support (secondary)

Remediation (possible)

Access Contact SummaryProperty Information:

Unresponsive Owners

Owner: Harcovitz

Address: 28 Riverview Place

Access Needs:

Haul road

Remediation

Blackburn & Union Privileges Superfund Site

Sediment and Floodplain Soil Remedy Page 1 of 3 8/12/2016






Unresponsive Owners

7/31/2015 Letter Introductory letter (overview of project and need for access) and request for preferred meeting date to discuss access.

9/2/2015 In-person meeting KA met with Elizabeth Lasala (EL) and Jason Kirby (JK) at property. Discussed proposed work. EL provided a list of items she would like incorporated into

agreement. EL indicated that she handled business for the Condo Trust and to direct communication to her. EL provided phone number.

9/25/2015 Letter Mailed Access Agreement that addressed EL requests.

10/27/2015 Left voicemail KA left voicemail for EL inquiring about access agreement.

12/4/2015 Left voicemail KA left voicemail for EL inquiring about access agreement. Second voicemail left (at phone number provided by Ms. Lasala) after sending draft

agreement. No responses.

12/16/2015 Property visit - not

home

KA visited Lasala residence at approx 6:30 pm -no lights on, no answer at door. No answer at Kirby residence.

1/12/2016 Property visit - not

home

KA left copy of agreement at door with letter requesting that she call.

4/25/2016 Left voicemail KA left voicemail for EL inquiring about access agreement.

7/13/2016 USEPA update USEPA attempting contact

8/3/2016 certified mailing Letter from Settling Defendants to owners requesting response about proposed agreement (letters sent independently to Lasala and Kirby).

7/31/2015 Letter Introductory letter (overview of project and need for access) and request for preferred meeting date to discuss access

8/27/2015 Phone discussion KA spoke with Sonia Shaw (SS). She does not want heavy equipment "on her land", but also said that we can do whatever we want "in the mud behind

the bushes". Wants us to send agreement/map.

9/25/2015 Letter Mailed Access Agreement

10/27/2015 Phone discussion KA received call from SS. She said that she is not prepared to sign anything now. She plans to put property on market in Jan 2016 - if that does not work

out she will engage a lawyer as part of access process.

1/26/2016 Phone discussion KA spoke to SS on the phone. She did not recall the agreement, or our conversations from October 2015. She asked for the agreement to be re-sent to

her home. She did not discuss her selling the property, as she had previously.

2/4/2016 Mailed Revised

Access Agreement

WC mailed Revised Access Agreement based on Sonia Shaw's conversation with Emily Bender. Agreement clarifies location where work will and will not

be permitted on property.

2/18/2016 Email to WC emailed Revised Access Agreement (2/4/2016) to Nancy Shaw (NS), Sonia Shaw's daughter. Sonia and Nancy wanted assurance that the driveway

adjacent to the restaurant would not be used. The agreement was clarified to include this language. EPA leading discussions.

7/13/2016 USEPA update USEPA attempting contact.

8/2/2016 Phone discussion SS called KA about the agreement to clarify some points. She will call Emily to discuss further.

8/2/2016 Email from EPA to

W&C relaying terms

EB emailed KA to relay several items that SS would like added to the access agreement

8/10/2016 Email to KA emailed revised (8/10/2016) agreement to Sonia Shaw. Revised per her requests from 8/2/2016.

3/17/2015 Letter Notification of impending sediment remediation Bid Walk.

8/20/2015 In-person visit Paul Bucens (PB) met with Dan Clemmer, property manager, about potential access. PB to follow up with Mike Manzo, Jr. (MM).

8/21/2015 Phone Call PB spoke with MM about potential access. PB and MM plan to meet on 8/28.

8/28/2015 In-person visit PB met with MM to discuss potential access, provided detailed conceptual property use plans, discussed property development plans by Manzo and

initiated discussions of alternate parking options.

9/25/2015 In-person visit PB met with MM to discuss potential terms of access, including leasing space from MBTA for parking.

11/12/2015 In-person visit -

discussing terms

PB met with MM in person to discuss potential access. Discussions on-going related to the complexities of relocating parking spaces and the planned

future development on the north side of West Street. To provide a term sheet for additional evaluation.

12/21/2015 email to PB transmitted draft term sheet to MM for continued discussion (includes monetary compensation, insurance, indemnification).

12/22/2015 email from MM emailed PB to indicate that he had received the draft termsheet and would review after New Years.

1/25/2016 phone call from MM called PB with update. Further review required by TMC 100 Elm management.

2/11/2016 email from MM to PB, suggesting meeting with TMC 100 Elm management and counsel to discuss term sheet.

2/19/2016 email from MM to PB, requesting feedback on possible meeting date(s).

3/3/2016 email exchange PB confirmed to MM meeting/teleconference with TMC 100 Elm management and counsel for 3/16/16

3/16/2016 meeting Grace/Covidien team met with Manzo team to discuss parties projects and potential for agreement on access. Further discussions about alternative

parking possibilities. MM to provide PB with specific logistical information related to parking needs (number and timing)

3/30/2016 email to PB requested specific logistical information related to parking needs (number and timing) from MM

4/21/2016 email from Manzo declines to provide access and not willing to entertain future proposals absent outright offer to purchase parking area for ca. $7MM

Owner: Kirby/Lasala

Address: 42/44 Riverview Place

Access Needs:

Haul road

Owner: Shaw

Address: 1057 Main Street

Access Needs:

Ancillary support

Owner: TMC 100 Elm ("Manzo")

Address: West Street (parking

lot)

Access Needs:

Staging/support (primary)

Haul road

Remediation (possible)








Unresponsive Owners

Note:

Support from the Town of Walpole and the USEPA Community Involvement Coordinator has been sought since November 2015. All contact attempts by the Town and USEPA are not reflected above.

Access Needs notes:

The notes associated with access needs reflect the remedy requirements based on the approach presented in the Draft Remedial Action Work Plan - Lewis Pond Sediment and Floodplain Soil, October 8, 2015.

Ancillary support includes low-intensity access needs such as survey work, erosion control, and personnel access by foot.

Haul road refers to a constructed gravel roadway that will be used to move excavated materials from a Remediation Area to the primary Staging Area (Manzo Lot), and/or to deliver backfill materials.

Access Road refers to a gravel entry/exit road for trucks built leading from a public roadway on to private property.

Staging/support refers to areas used for management of excavated material, storage of equipment and backfill materials, office/administrative support.

Remediation indicates that a currently defined Remedial Area is clearly within the property boundary. Excavation extents may expand based on verification sampling. Certain property boundaries within

Lewis Pond are not well-defined relative to the Remediation Areas.



Option Lots UsedSpace Occupied in

Manzo Lot

Parking spaces used in

Manzo LotSummary of Approach Key Qualitative Considerations Summary of Impacts and Feasibility

Manzo Lot used as primary staging area for equipment, materials, water treatment system and

sediment loading, as presented in the Draft Remedial Action Work Plan. Haul roads across other

properties used to bring material from Areas 1 and 2.

- Rental of alternate parking spaces required

- Displaces MBTA parking

- Displaces commercial tenant parking

- N/A -

Feasible but for the consideration requested by Manzo. This is the Primary Option, reflecting the approved 100%

Remedial Design to which all others are compared

Same as Primary Option, with Cleveland Lot redeveloped to offset some Manzo parking.

- 20K ft2 (approx. 55 parking spaces) available in Cleveland Lot.

- no discussions with Cleveland Lot owner yet

Use of the Cleveland lot for partial offset of the occupied parking spaces in the Manzo Lot is feasible; however,

timing of obtaining access, permitting, and redevelopment, and likelihood of acceptance of alternative by Manzo, is

unknown.

OVERALL: Medium Feasibility; Schedule and cost impacts to offset some commercial impacts on the Manzo Lot.

Alternative 1:

Reduced Manzo Lot

(Harcovitz as

Primary)

Remediation: Multiple privately owned lots in river and wetlands

Sediment staging and loading: Harcovitz

Support and clean material management: Harcovitz, Cleveland, Sansone

Access (entry/exit) Road(s): Manzo, Sansone, MBTA

Haul road(s): Manzo, Sansone, Harcovitz, Lasala/Kirby

8,000 ft2, expanding

to 20,000 ft2 to reach

Areas 3/3A.

24, expanding to 60

during Area 3/3A

remediation

- Reduce the use of the Manzo Lot to only truck entry/exit , minimal staging, and access to Area

3/3A. The perimeter area of the Manzo Lot would be used.

- Residential Harcovitz lot(s) used as primary area for sediment loading and possible staging of

water treatment system.

- Cleveland lot used for "clean" operations or parking offset.

- 38-40K ft2 available in Harcovitz lot; 20K ft2 available in Cleveland Lot.

- Disruption on residential lot (++)

- Increased truck traffic in proximity to houses on

Riverview Place (+)

- Wetland disturbance (+)

- Owner (Harcovitz) has not expressed willingness to

provide access.

- Harcovitz land prone to flooding.

Residents: high impact due to traffic and property occupation.

Wetlands: moderate impact due to increased work in floodplain.

Schedule: high impact due to access negotiations with owner.

Safety: moderate impact due to closer proximity of work to residents, and more work on unstable surface

(floodplain). Increased flood risk.

Cost: high impact.

OVERALL: Low Feasibility; Increased impacts to residents, wetlands, cost, and safety in exchange for reduced

commercial impacts on the Manzo Lot.

Alternative 2:

Minimal Manzo Lot

(Harcovitz as

Primary)




Access (entry/exit) Road(s): Manzo, Sansone, MBTA

Haul road(s): Manzo, Sansone, Harcovitz, Lasala/Kirby, Neponset River

(multiple parcels)

8,000 ft2 24

- Minimal use of southern portion of Manzo Lot only as a truck entry/exit point, and for minimal

staging.



- Cleveland lot used for "clean" operations or parking offset.

- Construct a new stream crossing and construction road on east side of river (500') to reach Area

3/3A remediation.


- Disruption on residential lot (++)


Riverview Place (+)

- Wetland/river disturbance (++)


provide access.



Wetlands: high impact due to increased work in floodplain and within river/wetlands.



(floodplain). Substantially increased flood risk.

Cost: high impact.



Alternative 3:

Harcovitz Lot Only

(No use of Manzo

Lot)




Access (entry/exit) Road(s): Harcovitz, Sansone, MBTA

Haul road(s): Sansone, Harcovitz, Lasala/Kirby, Neponset River (multiple

parcels)

(none) (none)

- No use of Manzo Lot



- Truck entry/exit through new entrance constructed from Riverview Place on to Harcovitz Lot.

- Cleveland lot used for "clean" operations.

- Construct a new stream crossing and construction road on east side of river (500') to reach Area

3/3A remediation.


- Disruption on residential lot (+++)


Riverview Place (++)



provide access.


Residents: very high impact due to traffic, property occupation, and truck entry on Riverview Place.

Wetlands: high impact due to work in floodplain and within river/wetlands.


Safety: high impact due to closer proximity of work to residents, traffic on Riverview Place, and more work on

unstable surface (floodplain). Substantially increased flood risk.

Cost: high impact.



Alternative 4a:

Doherty Lot - Main

Street Access


Sediment staging and loading: Doherty/McDonough

Support and clean material management: Doherty/McDonough

Access (entry/exit) Road(s): Doherty

Haul road(s): Doherty/McDonough, McDonough, Sansone, Harcovitz,

Lasala/Kirby, Neponset River (multiple parcels)

(none) (none)

- Operations staged in Residential Doherty/McDonough lots

- Truck entry/exit on to Main Street

- Area 3/3A reached by constructing road (500') on east side of river

- 35-37K ft2 available in Doherty (plus McDonough) lot.

- Disruption to residences (+++)

- Main Street traffic disruption (+++)

- Wetland/river disturbance (+++)

- Congested entry points on to Main Street, visibility to

Town Center

- Risk of damage to Town sewer

Residents: very high impact due to traffic and property occupation.

Wetlands: very high impact due to extensive work in floodplain and within river/wetlands.


Safety: high impact due to closer proximity of work to residents, traffic on Riverview Place, and more work on

unstable surface (floodplain). Substantially increased flood risk.

Cost: high impact.



Alternative 4b:

Jacob Lot - Main

Street Access


Sediment staging and loading: Jacob, Aquilo, Jacobs/Byblos

Support and clean material management: Jacob, Aquilo, Jacobs/Byblos

Access (entry/exit) Road(s): Jacob

Haul road(s): Sansone, Harcovitz, Lasala/Kirby, Neponset River (multiple

parcels)

(none) (none)

- Operations staged in Jacob lot (Restaurant), as well as adjacent commercial/residential lots.

- Truck entry/exit on to Main Street.

- Area 3/3A reached by constructing road (500') on east side of river.

- 38-40K ft2 available in Jacob (plus Aquilio and Jacobs/Byblos) lot.

- Disruption to residences and businesses (+++)

- Main Street traffic disruption (+++)


- Congested entry points on to Main Street, visibility to

Town Center

- Risk of damage to Town sewer


Commerical: hIgh impact to local business (Restaurant parking occupied).

Wetlands: high impact due to work in floodplain and within river/wetlands.



(floodplain). Increased flood risk.

Cost: high impact.

OVERALL: Low Feasibility; Increased impacts to residents, wetlands, cost, and safety. Commercial impacts similar

due to restaurant business disruption.

Additional lots not carried forward for detailed evaluation

Epiphany Church

Use of the Epiphany Church lot was not evaluated in detail for the

following reasons :

- street access is restricted by curbs, sidewalks, and utilities

- small available space relative to the required effort to use

- church infrasturcture present (gazebo, sign, landscaping)

- proximity to day care/kindergarten

-- -- -- ----

Infeasible

1167 Main Street

(David John Realty /

"Work Force")

Use of the 1167 Main Street property was not evaluated in detail for the

following reasons :

- lack of proximity to remediation areas

- limited space

- disruption to business (loading docks present in vicinity of where

operations would need to be staged)

-- -- -- ----

Infeasible

Notes:

Areas and numbers of parking spaces are approximate.

Asphalt restoration: Charter bid assumed aphalt restoration of about 1/5 of the occupied parking area. Savings were calculated for each option as a cost differential between the Primary Option ($60K) and the cost to restore approximately 1/5 of the occupied area for each alternative.

Key Qualitative Considerations: Plus signs (+, ++, +++) convey the increase in effort/intensity relative to the Primary Option.


Table 2: Matrix of Conceptual Access Alternatives

Blackburn & Union Privileges Superfund Site, Walpole Massachusetts

There is significant uncertainty in the feasibility and costing of these conceptual alternatives especially in regards to the town’s approval for access drives onto these streets, stormwater management, pedestrian access, minimum setbacks from

property boundaries, and setbacks from railroad operations, to name a few.

Primary Option:

Manzo Lot


Sediment staging and loading: Manzo

Support and clean material management: Manzo, Sansone

Access Road(s): Manzo, Sansone, MBTA

Haul road(s): Manzo, Sansone, Harcovitz, Lasala/Kirby

Additional parking: Cleveland (possibly)

137, expanding to 157

during Area 3/3A

remediation

40,000 ft2, expanding

to 48,000 ft2 to reach

Areas 3/3A.


Access Alternatives Discussion - Sediment and Floodplain Soil Remedy Page 1 of 1 8/12/2016

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DRAWN BY: RDS

DATE: AUG 12, 2016

FIGURE 1

Notes:

1. Map of parcels obtained from MassGIS.

2. The property boundaries shown are appropriate for schematicreference purposes only. This map shall not be substituted for alegal property boundary survey or for the town of Walpole taxassessor's map.

3. The Assessor's Map and Lot ID are presented for each property,along with the owner's last name and the name of the business at theproperty (in quotes) where applicable.

4. Duplexes/ condominiums with separate owners are present onLot 33-348 and Lot 33-362.

DRAFT

West Street/ Kendall Mills/Lewis Pond Dam

Ownership of Lot 33-364, and the land beneath theNeponset River (i.e. Lewis Pond), is assumed to beheld by the owners of abutting properties. Propertylines of abutters generally extend to centerline of theNeponset River.

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commitment integrity t 800.446.5518 drive results t 781 ... · 8/27/2015 phone discussion ka spoke...

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