NOTICE OF INTENT FOR DISCHARGE PURSUANT TO …

2269 Massachusetts Avenue Cambridge, MA 02140 (617) 868-1420

NOTICE OF INTENT FOR DISCHARGE PURSUANT TO MASSACHUSETTS REMEDIATION GENERAL PERMIT MAG9100000

OMNI BOSTON SEAPORT HOTEL 450 SUMMER STREET

SOUTH BOSTON, MASSACHUSETTS

MAY 7, 2018

Prepared For: U.S. Environmental Protection Agency

Office of Ecosystem Protection 5 Post Office Square ? Suite 100

Mail Code OEP06-01 Boston, MA 02109-3912

On Behalf Of: OH NBH Owner, LLC 125 High Street, 12th Floor Boston, MA 02110

PROJECT NO. 6311

May 7, 2018

U.S. Environmental Protection Agency Dewatering GP Processing Industrial Permit Unit (OEP 06-4) 5 Post Office Square ? Suite 100 Mail Code OEP06-01 Boston, MA 02109-3912

Attention: To Whom It May Concern

Reference:

Omni Boston Seaport Hotel ? 450 Summer Street; South Boston, Massachusetts Notice of Intent for Construction Dewatering Discharge Under Massachusetts Remediation General Permit MAG910000

Ladies and Gentlemen:

On behalf of OH NBH Owner, LLC, McPhail Associates, LLC (McPhail) has prepared the attached Notice of Intent (NOI) for coverage under the Massachusetts Remediation General Permit (RGP) MAG910000 for the discharge of construction dewatering effluent into Boston Inner Harbor via the City of Boston storm drainage system. The temporary construction dewatering discharge will occur during construction of the proposed development of the Omni Boston Seaport Hotel located at 450 Summer Street on Massachusetts Port Authority (Massport) Parcel D-2 in South Boston, Massachusetts (subject site). Refer to Figure 1 entitled: "Project Location Plan" for the general site locus.

These services were performed and this permit application was prepared in accordance with our proposal dated December 23, 2016, and the subsequent authorization of The Davis Company. These services are subject to the limitations contained in Appendix A.

The required Notice of Intent Form contained in the RGP permit and Boston Water & Sewer Commission (BWSC) Dewatering Discharge Permit Application are included in Appendix B and supporting information is included in Appendix C.

A Best Management Practice Plan (BMPP) is contained in Appendix F.

Applicant/Operator

The applicant for the Notice of Intent-Dewatering General Permit is:

OH NBH Owner, LLC Address: 125 High Street 12th Floor, Boston, MA 02119

Attention : Dante Angelucci Title : Director Phone: (617) 936-4808 Email: dangelucci@

GEOTECHNICAL AND GEOENVIRONMENTAL ENGINEERS 2269 Massachusetts Avenue Cambridge, Massachusetts 02140 (617) 868-1420

U.S. EPA May 7, 2018 Page 2

Site Location and Existing Conditions

Parcel D-2 occupies an approximate 87,849 square-foot area generally bounded by Summer Street to the south, World Trade Center Avenue Bridge/Fargo Street to the west, the D Street bridge abutment to the east, and Massport Haul Road, a retaining wall and a railway right-of-way to the north. The site is presently vacant and the ground surface generally consists of gravel and grass. The limits of the subject site are depicted on Figure 2. Existing ground surface across the Massport Haul Road side of the site is generally level at about Elevation +9 to Elevation +11, sloping upward to the south to about Elevation +15 to Elevation +17 in the middle of the site, and again sloping upward to about Elevation +24 to +29 along Summer Street.

Proposed Scope of Site Development

It is understood that the proposed scope of development includes the construction of two, 21-story above-grade hotel towers, an 8-story above-grade mid-rise hotel, a 4 to 6-level podium, and one-below-grade level. The proposed below-grade footprint is indicated on Figure 2.

The proposed development will include the construction of two, 21-story above-grade hotel towers with mechanical penthouse levels and below grade space. The towers will occupy an approximate 20,000 square-foot plan and 7,000 square-foot plan area connected by an 8-story mid-rise building and a 4- to 6-level podium structure. The one level below grade space will occupy an approximate 52,800 square-foot and extend to elevation +6. The combined above-grade building footprints will occupy an approximate 73,000 square-foot plan area. The ground level slab will be at Elevation +24.5.

Site History

Prior to the early 1890's, the site was a tidal flat of Boston Harbor. In the 1890's the land was reclaimed utilizing dredged fill material obtained from the adjacent tidal flats, Fort Point Channel and Boston Harbor. The dredged fill material typically consisted of organic silt and marine clay. In addition, "city ashes, refuse, earth and waste" materials were also reportedly utilized as fill material. The top of the site was capped with approximately 5 to 10 feet of granular fill material.

Site Environmental Setting and Surrounding Historical Places

Based on an on-line edition of the Massachusetts Geographic Information Systems DEP Priority Resources Map (GIS Map) viewed on April 13, 2018, the subject site is not located within the boundaries of a Sole Source Aquifer, Potentially Productive Aquifer or within a Zone II, Interim Wellhead Protection Area as defined by the Massachusetts Department of

U.S. EPA May 7, 2018 Page 3

Environmental Protection. Further, there are no public drinking water supply wells, no Areas of Critical Environmental Concern, no fish habitats, no habitats of Species of Special Concern or Threatened or Endangered Species within specified distances of the subject site.

A review of information provided by the U.S. Fish and Wildlife Service in an Information for Planning and Conservation (IPaC) Trust Resource Report for the subject site did not identify the presence of no endangered species at or in the vicinity of the marine discharge location and/or discharge outfall. Based upon the above, the site is considered NMFS criterion pursuant to Appendix IV of the RGP. A copy of the IPaC Trust Resource Report and supporting data are included in Appendix C.

The GIS Map indicates that there are no water bodies or wetland areas on the subject site. The map also indicates that the closest Protected Open Space to the subject site is located approximately 2,500 feet to the east. The closest water body is the Boston Inner Harbor is located approximately 1,000 feet to the northeast of the subject site. A copy of the Massachusetts GIS Priority Resources Map is included in Appendix C.

A review of the online Massachusetts Cultural Resource Information System (MACRIS) and the National Register of Historical Places for Suffolk County in Boston, Massachusetts did not identify records or addresses of historic places that exist in the immediate vicinity of the subject site and/or outfall location. A copy of the MACRIS Report is included in Appendix C.

Summary of Groundwater Analysis

In 2018, two (2) groundwater observation wells were sampled at the subject site. Samples were collected from wells B-111 (OW) and B-106 (OW) and submitted for laboratory analysis on April 3, 2018 and April 4, 2018, respectively. Laboratory results indicate detectable concentrations of ammonia, arsenic, chromium, chloride, copper, iron, lead, total suspended solids, and select semi-volatile organic compounds (SVOCs). A summary of the groundwater results is shown in the enclosed Table 1. The associated laboratory analytical data reports are included in Appendix D.

In accordance with Section 4.2.1 of the updated 2017 NPDES RGP, a sample of water from the Boston Inner Harbor was obtained and analyzed for recoverable metals, ammonia, pH, and salinity summarized in Table 2. The associated laboratory analytical data reports are included in Appendix E.

In summary, the groundwater testing completed indicates detectable concentrations of ammonia, arsenic, chromium, chloride, copper, iron, lead, total suspended solids, acenaphthene, fluoranthene and phenanthrene were detected. Concentrations were utilized in Appendix V of the 2017 RGP, to determine if Water Quality-Based Effluent Limitations (WQBELs) for specific inorganics apply. For discharging to saltwater with a dilution factor of 0, WQBELs apply for Total Residual Chlorine, however, because the groundwater at the site has not, nor will be chlorinated, prior to or during discharge, hence the WQBEL does not apply to this specific discharge. The Appendix V calculations also indicate Technology-Based Effluent Limitations (TBELs) apply for other Inorganics and SVOCS. A copy of the TBEL and WQBEL calculations is attached in Appendix C.

U.S. EPA May 7, 2018 Page 4

Construction Dewatering

It is anticipated that dewatering by means of strategically located sumps and trenches should suffice to manage groundwater during foundation and utility excavations and manage water which may become trapped within the excavation areas following periods of precipitation. If on-site recharge is not feasible, it will be necessary to discharge construction dewatering effluent into the city storm drainage system.

A review of available sanitary and storm sewer system plans accessed from the BWSC indicates the presence of a dedicated stormwater drain system located within Massport Haul Road. Records supplied by BWSC indicate one discharge flow path adjacent to the site flows to a primary discharge outfall location. The discharge flow path runs east-northeast towards the harbor under Massport Haul Road. The primary discharge location is an outfall pipe listed as #SS1 according to the BWSC. The site storm drains, discharge location, and discharge flow path are shown on the enclosed Figure 3A & 3B.

Groundwater Treatment

Based on the results of the above referenced groundwater analyses, it is our opinion that a minimum of one (1) 10,000-gallon capacity settling tanks and 10 micron bag filter in series will be required to settle and filter out suspended and dissolved inorganic metals in the discharge to meet applicable effluent limits established by the US EPA prior to off-site discharge. If necessary, an Ion Exchange Resin Filter will be utilized to further treat levels of metals in the effluent to meet the WQBELs that are considered applicable. A schematic of the treatment system is shown on Figure 4.

U.S. EPA May 7, 2018 Page 5

Summary and Conclusions

The purpose of this report is to assess site environmental conditions and groundwater data to support an application for a Massachusetts Remediation General Permit for off-site discharge of dewatered groundwater which will be encountered during the proposed development of the Omni Boston Seaport Hotel located at 450 Summer Street on Massport Parcel D-2 in South Boston, Massachusetts (subject site).

Based on the results of the above referenced groundwater analyses, treatment of construction dewatering will be necessary to meet allowable TBELs for inorganics and SVOCS established by the US EPA prior to off-site discharge. The proposed construction dewatering effluent treatment system will consist of a minimum of one (1) 10,000-gallon gallon capacity and bag filter in series to filter out sediment containing elevated levels of metals. However, should the effluent monitoring results indicate levels of in excess of the applicable TBELs and/or WQBEL established in the Massachusetts RGP, additional mitigative measures in the form of Ion Exchange Resin Filtration will be implemented to meet the allowable discharge limits.

We trust that the above satisfies your present requirements. Should you have any questions or comments concerning the above, please do not hesitate to contact us.

Sincerely,

McPHAIL ASSOCIATES, LLC

Kirk W. Seaman

William J. Burns, L.S.P.

N:\Working Documents\Reports\6311_RGP_041018.docx KWS/wjb/jwp

NORTH

D STREET BRIDGE

WORLD TRADE CENTER AVENUE

B-101 B-106 (OW)

SUMMER STREET

B-102 B-107

B-110

RAMP ST. MASSPORT HAUL RD.

B-103

B-104

B-104A (OW)

B-105

APPROXIMATE LIMITS OF SUBJECT SITE

B-108

B-111 (OW)

B-109

B-113

B-112

FILE NAME: N:\Acad\JOBS\6311\Dewatering\6311-E02.dwg

LEGEND

APPROXIMATE LOCATION OF BORING PERFORMED BY CARR-DEE CORP. DURING JANUARY AND FEBRUARY 2017 FOR McPHAIL ASSOCIATES, LLC

(OW) INDICATES OBSERVATION WELL INSTALLED WITHIN COMPLETED BOREHOLE

REFERENCE: THIS PLAN WAS PREPARED FROM A 30-SCALE DRAWING ENTITLED "TEST PIT, BORING & OBSERVATION WELL LOCATION PLAN" DATED

GRAPHIC SCALE

FEBRUARY 1, 2017 BY VANASSE HANGEN BRUSTLIN INC. AND A 70-SCALE

20

0

20

40

80

DRAWING ENTITLED "LEVEL B1" DATED FEBRUARY 23, 2016 BY

ELKUS|MANFREDI ARCHITECTS.

OMNI BOSTON SEAPORT HOTEL

BOSTON

MASSACHUSETTS

SUBSURFACE EXPLORATION PLAN - ABOVE-GRADE BUILDING FOOTPRINT

FOR

OH NBH OWNER, LLC

BY

McPHAIL ASSOCIATES, LLC

APRIL 2018

F.G.P. 6311

K.W.S.

1" = 20'

FIGURE 2

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