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HomeMy WebLinkAbout0293 SEA STREET - Health 'r IITYANNIS EWE r P1 II s BENNETT ENVIRONMENTAL ASSOCIATES, INC. LICENSED SITE PROFESSIONALS,ENVIRONMENTAL SCIENTISTS,GEOLOGISTS,SANITARIANS 1573 Main Street,P.O.Bog 1743 (508)896-1706 Brewster,MA 02631 fax(508)896-5109 LETTER OF TRANSMITTAL TO: DATE: JOB NUMBER: Ms.Lara McLaughlin,Data Manager 12/23/2008 BEA08-10044 MA DEP SERO-B W SC 20 Riverside Drive REGARDING: Lakeville,MA 02347 RELEASE ABATEMENT MEASURE COMPLETION W/ CLASS A-2 RESPONSE ACTION OUTCOME—RTN 4-21596 Private Residence(Lola J.Fuccillo) SHIPPING METHOD: 293 Sea Street—Hyannis,MA[Assessor's Map 306,Parcel 78] Regular Mail ❑ Pick Up ❑ Priority Mail ❑ Hand Deliver ❑ Express Mail ❑ Other uploaded ❑X Certified Mail ❑ Green Card/RR ❑ COPIES DATE DESCRIPTION 1 12/19/2008 RELEASE ABATEMENT MEASURE COMPLETION W/ CLASS A-2 RESPONSE ACTION OUTCOME—RTN 4-21596 Private Residence 293_.Sea_Street Hyannis,MA[Assessor's Map 306,Parcel 78] For review and comment: ❑ For approval: ❑ As requested: ❑ For your use: REMARKS: cc: Lola J.Fuccillo,Lola J.Fuccillo Investment Trust-Property Owner Lieutenant Hubler-Hyannis Fire Department(Narrative,title page,site plan only) Thomas McKean-Barnstable Board of Health(Narrative,title page,site plan only) John Klimm-Barnstable Town Manager(Narrative,title page,site plan only) Doug Bentley- Friedline&Carter(Full report on CD) FROM: If enclosures are not as noted,kindly notify us at once f BENNETTENVIRONMENTALAsSOCIATES, INC. LICENSED SITE PROFESSIONALS 0 ENVIRONMENTAL SCIENTISTS 0 G:EOLOGISTS 6 SANITARIANS 1573 Main Street.-P.O. Box 1743, Brewster, MA 02631 6 508-896-1706 & Fax 508-896-5109 0 www.bennett-ea.com BEA08-10044 December 19, 2008 Ms. Lara McLaughlin, Data Manager MA DEPARTMENT OF ENVIRONMENTAL PROTECTION (MA DEP) Southeast Regional Office (SERO) Bureau of Waste Site Cleanup (BWSC) 20 Riverside Drive Lakeville,MA 02347 RE: RELEASE ABATEMENT MEASURE COMPLETION W/ CLASS A-2 RESPONSE ACTION OUTCOME—RTN 4-21596 Private Residence 293 Sea Street—Hyannis, MA [Assessor's Map 306,Parcel 78] Dear Ms. McLaughlin, BENNETT ENVIRONMENTAL ASSOCIATES, INC. (hereinafter referred to as`BEA") has prepared the following Release Abatement Measure Completion (RAMC) with Class A-2 Response Action Outcome (RAO) and Supporting Documentation as a summary of release discovery, environmental assessment and remedial action conducted at the above-referenced property as associated with a historic fuel oil release and the identification of a 120-Day condition. Additionally, the RAMC / RAO report summarizes the completed remedial response actions undertaken to mitigate potential human exposures and environmental impacts in accordance with the provisions of 310 CMR 40.0440 where there existed a threat of groundwater impact. Initial environmental assessment activities were conducted to qualify the magnitude and extent of significant soil impact associated with a previously unidentified historic release of an unknown quantity of#2 fuel oil in an earthen crawl space beneath the southern portion of the dwelling. The area of the former tank was clearly visible within the crawl space that underlies the former porch area in the southwest portion of the residence. Soil had been removed within the crawl space to allow for sufficient headroom to locate the tank and a concrete pad was poured to support the legs of the vessel. An initial investigation determined that 1 to 2 feet of soil along the perimeter of the concrete slab were impacted. Fuel oil had apparently flowed over the slab to the edge of the slab and entered into the underlying soils. In subsequent investigation, the vertical extent of soil contamination had been determined to extend at least to 16' below grade surface (bgs) at the angled HB-5 sampling location and, as such, represented a threat of groundwater impact as precluded a Limited Removal Action (LRA), wherein environmental monitoring 1 EMERGENCY SPILL RESPONSE 0 WASTE SITE CLEANUP SITE ASSESSMENT 6 ENVIRONMENTAL PERMITTING 0 LAND USE PLANNING WATER SUPPLY DEVELOPMENT,OPERATION&MAINTENANCE 0 WASTEWATER TREATMENT,OPERATION&MAINTENANCE DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 2 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 beyond soil removal was deemed appropriate and necessary in review of potential exposure risks. As such, a Release Abatement Measure (RAM) Plan, with Release Notification, dated October 24, 2008 was submitted for soil removal operations and construction of a sub-slab venting system to mitigate potential exposure risks and facilitate any potential future treatment of residually impacted soils. An Environmental Monitoring program was further prescribed with end point soil sampling, testing of monitoring wells and Level 1 screening of ambient air quality in review of cleanup performance and exposure risks towards a Class A, Response Action Outcome (RAO) objective. The Release Abatement Measure was subsequently implemented wherein some 22 tons (15 cubic yards) of fuel oil contaminated soils were removed from an approximate 8'x 6'x 4' (D) [10' bgs] area. End-point sampling of sidewall and bottom-of-hole (BOH) areas reported petroleum hydrocarbon concentrations (VPH/EPH) in the discrete areas as below the most stringent S-1/GW-3, Method 1 — Risk Characterizations standards. The re-sampling of the previously installed and representative downgradient groundwater monitoring wells reported petroleum hydrocarbon concentrations (TPH) concentrations as below the applicable GW-3, Method 1 — Risk Characterization thresholds. Additionally, the dwelling and the sub-slab venting system was monitored for residual vapors wherein measured total organic vapors (TOV) concentrations were less than the Method 2 Risk Standards established in the MA DEP Policy WSC-02-411, Implementation of MA DEP VPHIEPH Approach. As such, the environmental assessment of soil, groundwater and ambient air associated with the RAM indicates a condition of No Significant Risk for any ingestion, inhalation or dermal contact exposures to identify human receptors and the environment in support of a Class A-2, RAO as a permanent solution for project closure. The information herein serves as a summary of the remedial response actions and environmental assessment conducted as associated with the RAM Plan as an addendum to, an essential element of, the public record. The environmental data herein has been reviewed and validated and potential exposure risks evaluated under Method 1, Method 2 and Method 3 risk considerations as the technical rationale and justification for the LSP Opinions presented to document regulatory compliance and project closure under the provisions of the MA Contingency Plan, (MCP) 310 CMR 40.0446 and 40.1035. This work has been conducted under direct LSP oversight in a manner consistent with the MCP Response Action Performance Standards (RAPS) pursuant to 310 CMR 40.0191 and the QA/QC policies of BENNETT ENVIRONMENTAL ASSOCIATES, INC. The facts and statements herein are, to the best of our knowledge, a true and accurate representation of the Site activities, remedial response actions and environmental conditions associated with the project and LSP Opinions acknowledged by the certification on the attached BWSC-106 Transmittal Form. ENVIRONMENTAL CONDITIONS [Refer to Appendix A] The subject property at 293 Sea Street is noted on the Town of Barnstable Assessor's Map 306 as Parcel 78 and is located along the northwest corner of the Sea Street/Stetson Street DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 3 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 intersection [Refer to Figure 1]. The residentially zoned property contains approximately 0.3 acres of land area and is developed by a two-story residential style building constructed in 1900+/-. This building has historically and is currently being used as a private, single-family residence. The surrounding area is developed in similar use, as characterized by residential properties. Access to the subject property is unrestricted with high frequency/high intensity of use and children potentially present. Access to the area of release, however, as within the crawl space of the subject building and is restricted with low frequency/low intensity of use with children potentially present as infrequent visitors. Residents of the dwelling are identified as the primary potential human receptors to any ingestion, inhalation or dermal contact exposures. Monitoring well installation, conducted September 25, 2008, indicated that groundwater exists at + 25' bgs. Regional groundwater contours indicate a southerly flow direction towards Hyannis Harbor (0.5 mi south) and Lewis Bay (0.75 mi southeast). Static water level measurements conducted on September 25 (low tide), September 30 (high tide), October 28 (full moon/ ebb tide) and November 19 (flow tide) indicates significant tidal influence from westerly towards Stewart's Creek to southwesterly towards Hyannis Harbor + 0.5 miles to the south. As such, Stewarts Creek and the associated wetlands and also Hyannis Harbor are identified as the potential environmental receptors. According to the MA DEP BWSC GIS mapping program, the subject property is located within a medium yield, non-potential drinking water source area (NPDWSA) as attributed to housing density in an urbanized area. The property does not fall within the Zone II Protective Radius of any Public Water Supply (PWS), nor is it located within the Zone A protective radius of any surface water reservoir. No private wells are known to exist within 500' of the Site wherein the area is serviced extensively by the Town of Barnstable municipal water supply and distribution system. Based on this mapping and field observations, the GW-3 groundwater category is applicable under Method 1 —Risk Characterization, per 310 CMR 40.0974. Based on Site conditions relative to frequency/intensity of use and accessibility of soils, wherein the release area is within the crawl space of the basement of the subject building, the S-2 and S-3 (GW-3) Method 1 —Risk Characterization standards are applicable to soil impact in accordance with the provisions of 310 CMR 40.0975. In review of all foreseeable future uses and activities at the Site, the most restrictive S-1 (GW-3), Method 1 — Risk Characterization standards are considered. These standards were developed in consideration of potential ingestion, inhalation and environmental/dermal contact exposures and in review of potential leaching of contaminants to groundwater. BACKGROUND [Refer to Appendix A] BEA received a phone call from the property owners during the weekend of August 23/24, 200& The homeowners were in the process of selling the house and a home inspector detected the presence of a fuel oil odor in the crawl space area. A visual inspection evidenced what appeared to be an excavation with an adjacent pile of dirt that apparently was cast from the excavation. No public records of any permits relative to the former existence or removal of a fuel tank for the property could be located. Additionally, forensic evaluation of the degree and amount of hydrocarbon degradation indicated that the fuel oil residuals were significantly DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 4 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 degraded as indicating that the release had occurred at least 10 years earlier and prior to the current owner's purchase of the property. At the time the current owners took possession of the property in 2001, the domestic heating already had been converted to natural gas and the storage tank had been removed. BEA contracted with the homeowners, who live out of state, to meet with their realtor, photo-document conditions within the crawl space area and conduct limited soil sampling and analysis to qualify environmental impacts and determine if release notification and/or remedial response liability was present under the provisions of 310 CMR 40.0000. These initial preliminary response actions and assessment activities are summarized in the following section of this report. The reader should review the written RAM Plan for additional details. ENVIRONMENTAL ASSESSMENT [Refer to Appendix A] Soil BEA conducted the initial soil sampling on August 27, 2008 in the earthen crawl space under the addition on the south side of the dwelling. Analytical results from HB-1 and HB-2 samples reported total petroleum hydrocarbon (TPH) concentrations of 12,000 parts per million (ppm) and 7,800 ppm respectively in the surficial soils under the former tank. These concentrations are significantly above the applicable RCS-1 Reportable Concentration threshold of 1,000 mg/kg and the applicable S-3/GW-3, Method 1 — Risk Characterization standard of 5,000 mg/kg. This testing further indicated that more than 2 yards of soil had been impacted above the aforementioned standards. Wherein a 120-Day Reportable Condition was identified, BEA returned to the property on September 8, 2008 to collect additional sidewall samples and advance additional hand borings in the areas at the perimeter of the buried concrete slab, towards defining the extent of significant soil impacts and potential for groundwater impacts. BEA collected sidewall samples from the dug out area of the crawl space for field testing and advanced hand borings adjacent to the area of documented impacts. Hand borings HB-3 and HB-4 were advanced to 6' and 8' feet below grade surface (bgs) off of the east and west ends of the exposed concrete slab, respectively. Borings at these locations were limited by available headroom and the friable nature of soils underlying the dwelling. Field screening of soil samples from HB-3 and HB-4 reported low-level total organic volatiles (TOV)concentrations from zero to 2.4 parts per million(ppmv). Hand boring, HB-5, was advanced to a depth of 16 feet bgs between the paved driveway and building footing, immediately adjacent to the crawl space release area [Refer to attached site plan]. This hand boring was angled to intercept soils under the release area. Soils at the HB-5 location consisted of loose, medium to coarse grain sands with nominal cohesion. Field screening of soil samples from HB-5 reported moderate TOV concentrations from zero to 44 ppmv and increasing with depth. Groundwater was not encountered at the HB-5 location as projected at 25' below existing grade. DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 5 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 Soil samples HB-5: 8'-10' and 12'-14' were submitted for MA Certified laboratory analysis of TPH and the 15'-16' interval sample was submitted for laboratory analysis of extractable/volatile petroleum hydrocarbons (EPH/VPH). Analytical results were received on September 11, 2008. The analyses reported TPH concentrations in the HB-5: 8-10' sample as 1,900 parts per million (ppm) and in the HB-5: 12-14' sample as 1,100 ppm. However, the "worst case", TOV-biased HB-5: 15-16' sample reported EPH and VPH carbon range and target analyte concentrations as less than the applicable S-3/GW-3, and most stringent S-1/GW-3, Method 1 —Risk Characterization standards. As such, the TPH samples were re-analyzed for the risk-based EPH/VPH analysis in order to quantify the magnitude of impact in the consideration of risk as critical to the formulation of a remedial strategy. These analytical results were received the afternoon of September 16, 2008 and reported all fractional VPH/EPH standards and target analytes at concentrations less than the applicable S-3/GW-3 and most restrictive S-1/GW-3, Method 1 — Risk Characterization "cleanup" standards. These results indicated that the excavation of soils to 8' bgs in the area of release should meet closure objectives. As such, a+ 4-6' excavation to a depth of 8-10' bgs was proposed within the RAMP as approximately 15 yards of significantly contaminated soil. Groundwater Although the soil testing indicated that the S-1/GW-3 standards were met in soil samples below 8' bgs, residual soil impacts extended to depth as threatening potential groundwater impact. As such, the monitoring well were prescribed and installed for determination of site- specific groundwater flow, aquifer characteristics and groundwater quality. BEA returned to the Site on September 25, 2008 to direct test borings and the installation of monitoring wells as performed by Jenkins Well Drilling of Brewster, MA [Refer to Site Plan—Appendix A]. BEA personnel returned to the site on September 30, 2008 to re-gauge purge and subsequently sample all three monitoring wells for laboratory analysis of total petroleum hydrocarbons (TPH) as a cost savings measure to serve as an indicator for any environmental impact. The groundwater samples were collected in appropriately preserved laboratory containers and field preserved on ice. A series of rising-head slug tests were performed at monitoring well MW-3 to qualify hydraulic conductivity in review of aquifer characteristics and solute fate and transport mechanisms. The Geraghty and Miller AQTESOLV program was employed to interpret the results of the slug tests wherein a hydraulic conductivity of 38.31 feet per day. Based on the calculated hydraulic conductivity and hydraulic gradients reported along specific groundwater flow vectors from MW-1 to MW-2 and MW-1 to MW-3, the groundwater velocity from the release area was reported as 0.12 ft/day. Well gauging and static water level measurements demonstrated tidal influence on groundwater flow as westerly to south westerly beneath the site as confirming MW-2 in a downgradient location and as representative of potential downgradient groundwater impacts. Groundwater samples collected from all monitoring well locations reported TPH concentrations as BRL with reporting limits less than the applicable GW-3,Method 1 —Risk Characterization standards. DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 6 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 The release discovery was framed within the Release Notification Transmittal Form filed with the MA DEP on October 20, 2008. On the MA DEP assignment of a Release Tracking Number(RTN 4-21596) a Bill of Lading was prepared and incorporated into a written RAM Plan as filed with the MA DEP on October 24, 2008. RELEASE ABATEMENT MEASURE [Refer to Appendices B and C] Subsequent to discussions with the property owner and the selected contractor (N. P. Christiani —NPC) regarding the Scope of Work and construction logistics, BEA returned to the Site on Thursday October 23, 2008 to review project status and deliver the executed Bill of Lading (BWSC-012A, B, C) and Aggregate Industries Soil Recycling Submittal to the contractor. Upon arrival BEA personnel noted that the joists supporting the first floor of the residence had been supported with two steel beams and cribbing extending from the driveway area adjacent to the release area to the interior of the main basement area. BEA and NPC personnel discussed the proposed area of contaminated soil removal and associated activities which were coordinated to commence the following Monday, October 27 following the submittal of the RAMP. Excavation operations began the morning of the 27fl' with a brief "tailgate" health and safety meeting followed by the commencement of soil vactoring of all soil cast from the former tank area onto the native grade of the crawlspace. Once all of this former tank related soil was removed, soil removal continued laterally to the final dimension of the excavation and vertically down to the concrete slab which supported the former tank (± 6' bgs) in the tank grave resulting in an approximate 8' x 6' x 6' bgs excavation as originally planned. The concrete slab was easily broken with a sledge hammer and removed along with additional soil down to the 6' to7' bgs horizon across the entire excavation bottom. BEA personnel collected end-point soil samples representative of the excavation sidewalls via hand auger. Additional bottom of hole samples were collected at the limits of the excavation and field screened in review of remedial performance. Field screening of these end-point soil samples reported low—moderate headspace TOV concentrations. All soil samples were also field screened via a Dexsil "Petro-flag" TPH analyzer. The tabulated field screening results for the initial sampling is presented below. Location PID(pp Dexsil TPH(gym) BOH @6'/7' 23 1850 East SW 6-10' 2.1 81 West SW 6-10' 3.1 180 South SW(east)6-10' 4.6 106 South SW(west)6-10' 5.1 113 North SW 6-10' 23 1600 BB-6(7-9') 23 2100 NSW 6-10'-x 6.0 102 Based upon the initial field screening results (TOVs = 23ppm, TPH = 1600ppm), the north sidewall was extended approximately 1.5 feet and retested. Based on these subsequent results (NSW 6-10'-x; PID=6.Oppm / TPH=102ppm), the lateral extents of the excavation had been established and soil samples placed in the appropriate containers and preserved and ices as necessary for laboratory analysis. BEA personnel conducted a hand boring (HB-6; 7'-9') centrally in the excavation to assess the vertical BOH objective. A composite sample was field DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 7 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 screened with the above results indicating fuel residuals still in excess of the strictest S-1/GW-1, Method 1 —Risk Characterization thresholds. Additionally, this 7' to 9' bgs interval consisted of very loose "sugar' sand which was determined to necessitate the installation of shoring. NPC began the installation of shoring along the north and south sidewalls. The shoring was advanced in a narrow trench created by the soil vactor along the sidewalls in front of the vertically installed 2"x10" pressure treated lumber in anticipation of extending the excavation to 10' bgs. At this point the soil vactor departed the site to meet the Aggregate facility's closing time. It was later verified that the initial vactor load contained 12.41 tons of soil [Refer to BOL — Appendix C]. BEA departed the site leaving instructions to be contacted the next day when the shoring was completed and the excavation reached 9' bgs. Contractor personnel returned to the subject property the next day October 28, 2008 to complete soil removal as specified. Vactoring advanced the excavation within the shoring box to approximately 9'. BEA returned to the Site late in the morning and soil vactoring continued vertically until the intended 10' bgs depth had been reached at which point representative, confirmatory bottom soil samples were collected. The bottom soil sample consisted of 6-8 equal aliquots of soil from across final grade of the excavation as placed in the appropriate containers and preserved and ices as appropriate for laboratory analysis. At this point the soil vactor again departed the site to meet the Aggregate facility's closing time. It was later verified that the final vactor load contained 9.66.41 tons of soil [Refer to BOL—Appendix C]. BEA personnel advanced a hand boring (HB-7) between the center BOH and the exterior HB-5 and collected composite samples in 2' intervals for field screening is further consideration of residual soil impacts to depth. Field screening of these and BOH end-point soil samples reported low — moderate headspace TOV concentrations. All soil samples were also field screened via a Dexsil "Petro-flag" TPH analyzer. Field TPH screening of these end-point soil samples reported low — moderate TPH concentrations. These tabulated field-screening results are presented below. Location PID(gym) Dmil TPH(gym) BOH @ 10' 10.2 380 HB-7 10-12' 8.1 435 HB-7 12-14' 3.1 169 HB-7 14-15' 10.2 60 Field TPH screening of the soil samples collected reported TPH concentrations significantly less than the most restrictive S-1 (GW-3), Method 1 — Risk Characterization standard of 1,000 ppm. As such, field-testing had indicated the effective removal of significant soil impacts. Ambient air monitoring within the work zone at the extent of excavation reported TOV concentrations as BDL(<O.1 ppmv). All confirmatory samples were submitted to be laboratory analyzed via MADEP EPH methodology. Additionally, the "worst case" excavation BOH and HB-7 samples were analyzed via the MA DEP VPH methodology. Laboratory analytical results for the east, south and west confirmatory sidewall soil samples reported all EPH/PAH concentrations as BRL wherein the reporting limits were less than or equal to the most restrictive S-1/GW-3, Method 1 — Risk DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 8 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 Characterization thresholds. Laboratory analytical results for the north sidewall, BOH and HB-7 locations all reported low level EPH/PAH concentrations and low level VPH/BTEX concentrations wherein the reporting limits were less than or equal to the most restrictive S- 1/GW-3, Method 1 — Risk Characterization thresholds. The sum of these post-excavation laboratory analytical results for end-point soil sampling is presented in Table I and Table II below. The significance of these laboratory results is further discussed in the Risk Characterization section of this report. TABLE I: SUMMARY OF SOIL EPH LABORATORY ANALYSIS- METHOD 1,2,3-RISK CHARACTERIZATION: SOIL [ug/g=ppm] Exposure Point RESULTS S-1 SOIL STD. S-2 SOIL STD. S3 SOIL STD. DIR.CONTACT UPPER CONC. Location&Analyte (µg/g=ppm) (µg/g=ppm) (µg/g=ppm) (µg/g=ppm) STANDARDS LIMITS 310 CMR 310 CUR 310 CMR (µg/g=ppm) 40.0975(6)(a) 40.0975(6)(a) 40.0975(6)(a) 310 CUR 40.0985(6) (µg/g=ppm) (depth below grade surface 10/28/08 GW-3 GW-3 GW-3 S-1/S-2/S-3 310 CMR 40.0996 7 H ESW 6-10' p ,q r `� . _ ' 4:. � x r __...__......................._.__._............._.._....._........._......__.._.......-.._.........._........__...._...._................_........._..............................._._............_ C9-C18 Aliphatics <30 1,000 —3,000-- 5r000 ' 1,000/3 000/Sr000 20r000 4..° z r C19-C36 Akhphatics_— — — <30 — _ 3,000 _ 5,000— _ ' f5,000` .. «2 500/5 000/$000 4"";Z0,000k , �..__...... ......._.__.._. Cl 1-C22 Aromatics <30 1000 3 000 'r 5 000 5 1 000/3 000/5 000 r 10 000 ...-�... —.._..---•----- ----..... —_.....�. ........_...................._. .r..�-"_ _ .... r.. .r -. .. ..... r ... ......:-_ ........ Taz et PAH 4 .rr a t u'4 - ..... All Target Anal es <0.50 ?0.7 >4 �'>10Y ' HSSW 6-10' -.r x -, C9-C18 Ali�tics-- — _ <30_ 1z000 3 000 I ..._.•.__._Sz000 1 000/3 000/500,0 20 000 ': _ r C19-C36 Ah_phatics_ _ <30 3,000 ;45 000 S a 5 000 2 500/5 000/5 006 t r20 000 --- _—......__..__—..._—...._..--- ....._.... _._.._._ ._....................._ ..... .....__. ____..... .. . ..._ r As-a.w 5_.00,0Cl1-C22Aromatics <30 1000 5,000 r1 - .�10�0 _0_ 30 _ . ... 7- Target PAH ^^. P ,. r - r_ x ` ----...._....._.___........—_._..._.. _ ....._....—_._....._....---.............._....................._.. . .._.....—......................_ . AH Target Anal s <0.51 >0.7 ---->4 �'r >10 ................._.........._..-- —...-- ........_...._........--.. _.............. d .:.... ................. C9-C18 Aliphatics <30 11000 3 000 5 000 A1000/3,000/5;000 ? 20 000 _� _....__—.......�.___._.._._...._._.._.:- ---- r ......._ .... . C19-06 Ali hatics <30 3,000 5 000500/S1660/S�000 p rt�z20,000 S �� s Y * d Cl 1-C22 Aromatics c30 1 000 3 000 5 000� 2 1 000/3 000/5 0001 ' 10 000 ._.___._.—.._.—._..._......__...__.._....------._.._....'--......._.._...._v_ ._._....__.....__......._...._._..__a._._.._...---...... - t ..a . L... r ._ .... Taz et PAH ! _ �. �.. _ _ ... ma's .. All Target Anal es <0.50 >-0.7 >_4 >10 H NSW 6-10' . * ,. ._' -`_� —�.--...—_...... ....---._._--... —..-- % s 'rs 1 �V. C9 C18 Aliphatics 33 _—._...___._. 1Z000_-- _ _ 3 000 _— _ 5 000 t a 1 000/3,000/5,000 20 000� C19-C36 Ahphatics_ _— <30 3,000 _ _ 5,000 — 5,000 *' a 3 500/5,000/5 OOOi ,020 000 C11-C22 Aromatics <30 1 000— — 3 OOO , .5 000 1;000/3 000/5,000 10 000 Taz et PAH—.. - .._ __._......-- _.............................................__..__.._._ ............ .: *1 ;+ a ,' * ` All Target Anal es <0.50 ?0.7 >4 _—.—._. --_._.._ t C9-C18 Nliphatics __ 120_ -- 1,000 -- _3,000— .....*t5,000 1000/3 000/5 060 20 000 y_ C19-C36 Ali hatics 33 3,000 5,000 5 000 , '2 500/5 000/5 000 ' 20 000 g a — r Cl1-C22 Aromatics 89 1s000 _ 3,000 — s .a 5,000,, t1#000/A00/5.000 s 107000 .....—. t Taz et PAH g€_r DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 9 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 TABLE I: SUMMARY OF SOIL EPH LABORATORY ANALYSIS- METHOD 1,2,3-RISK CHARACTERIZATION: SOIL [ug/g=ppm] Exposure Point RESULTS S-1 SOIL STD. S-2 SOIL STD. S-3 SOIL STD. DIR.CONTACT UPPER CONC. Location&Analyte (µg/g=ppm) (µg/g=ppm) (µg/g=ppm) (µg/g=ppm) STANDARDS LIMITS 310 CMR 310 CMR 310 CMR (µg/g=ppm) 40.0975(6)(a) 40.0975(6)(a) 40.0975(6)(a) 310 CMR 40.0985(6) (µg/g=ppm) (depth below grade surface 10/28/08 GW-3 GW-3 GW-3 S-l/S-2/S-3 310 CMR 40.0996(7) Other Target Anaes —...--- --- :5.__._._.. ....----......_ :Z....__.......__......__.......__...._ 4........_._ . ....... >I0 ...- >07/4/30 ..................... >300f . IWAV 2-Meth lna hthalene 0.79 300 500 500 ' 300/500/500 ti5,000: ;.. EP...............—..._.....---.—.......—._.._._—.._..—_-.._......._..._.__....----_._.......—.._._...__... ..--......._.._._........._... C9 C18 —' AG hatics -- —'---200—._...--'--...—z.._.._....__.—..._...---...__:_.._.... x .. . ................ r ..:.... ....... C19-06 Ali tics 43 3 000 5 000 p W. 5 00 0� � 2 500/5 000/5 0-0 �� 20r000 "a Cl1-C22 Aromatics 150 . 1000— 3 000 r 15 000 # 1 000/3 000/5 000 10 000�� ..------............—....._._...._._._........_......_..._._.._..-_......_....._....._......_. ......._. .r._._................... .... r .:: _. r .r ............. r _.. -Target PAH s a ------- - ------ - — - — .... ....::.. ,.. ,..:. .. Other T et A t <.5 >_0.7 >4 ° >10 >0 7/4/30` 300 � # 2-Methylnaphtluilene _._.... .........._.__Z.:S_.__._...._. _...._..___..._300 500 500 s E300/500/500 5 000 ..........---._ .........................................._.............._._........._ .......... -....... ......... .......... _.::.._. r...._ .. ... uorene 0.6 11000 3 000 — : 5 000 ir1,000/3 000/5 OOO x, 140 000 Phenanthrene 0.8 500 1,000 :3 000, 40/1 000/3;000 , �� "]0 000. TABLE 4: SUMMARY OF SOIL VPH LABORATORY ANALYSIS- METHOD 1,2,3-RISK CHARACTERIZATION: SOIL [µg/g=ppm] S-1 SOIL STD. , Exposure Point RESULTS S 2 O�STD sS 3 SOIL STD sDIR CONTA !UPPER CON Location&Analyte (µg/g=ppm) (µP�B=PPm) ,(µg/g ppm) (µg/g ppm)§ ° STD$'. 4 LIMITSy � 310 CMR '.310 CMR ' .310 CMR. `'�(µg/g ppm) ° t 40.0975(6)(a) 40.0975.(6)(a) 40 0915(6)(a) 310 CMR 40:0985(6) (µg/g=,ppm)a4 (depth below grade surface 10/28/08 GW-3 _, IGW-3 GVd-1 310 CMR 40.0996(7) VPH-BOH 10'b s ' .T.: a'. - ; --.........__.......------.--._._.. T. CS C8 Ali hatics — — <1.3 100 500 r t500 * 100/500/500 t + - 5 00o f � ......._— __..__.:S!._..__.....—........................._.—.._................. ......:.. ......... ..-_..... ......:: .. ......_+. .__.._...� .... .L....... ...... k .�. � -. - y� C9-C12 Aliphatics 16 1,000 :' 3y-0�0�0, 5 000 7 1-000/3 000/5 000 a R20 000 Y .'e y 4'A ( O ! R Vr C9-C10 Aromatics 11 100— f 500 500: + 100/5...... a........ ..r....._.�...... .. Taz et BTEX �` a� £` i� $'; 5 *4 All BTEX All<0.25 All>30 t {All>200 ; All>066 ,. ' All>30/200/900 All>4?000 MTBE <0.07 100 500 k � +500..a� t00/500/500 °5 000 u- er as .-_-._.-......-----.._._.-_......—.___...._._....._._...._........._.._.......---..........._...—_...................._.__._ ... �.� a,,, ,�,�� .............-. Naphthalene <0.66 500 1,000 a �_3,Op0_= SDO/1,000/3,000 W a10;000 VPH BB-75 10-15' ...................... 3 .........-:.. R� � y r 100 x a F t Homo,.TM 5 000C -C..Ali _.......—_....__.._......_.................< _......._ -................__...................... - 3 ' —� 003000 000C9-C12Aliphatics 32 30 2r C9-C10 Aromatics 26 100 ' ``500 r ,4 500 4100/500 Taz etPAHs v+ a '_ _ M 'r' r — ... _._— .�gr,,-.'wc•�"�..s -;:`a�g ^w, -. +mom, $ ,qya ..,,; All BTEX All<0.25 All>30 All>200 * ,�. _ All>900: 3 All>30/200/900 ��All>9;000 --- - MTBE <0.08 100 � I500 � 500 100/5 0/500 5w;ti* .�.....---- ...: .... .... ...... .: r ..... Naphthalene <0.78 500 , ,s1,000 •�- zt Vs..3 000+R i00/1 000/3 000 �,�10 000-4t- VPH=Volatile Petroleum Hydrocarbons,BTEX=Benzenetroluene/Ethylbenzene/Xylene BRL=Below Reportable Limit Shaded areas represent applicable MCP criteria. DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 10 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 BEA personnel returned to the Site on November 19, 2008 to gauge and sample the monitoring wells, install and screen a sub-slab soil gas sampling probe and perform indoor ambient air monitoring and modified Level 1 Soil Gas Screening at the sub-slab venting system riser in review of risk characterization. All of these potential exposure points reported a TOV concentration of BDL (<0.1 ppmv) which is inherently less than the strictest response standard (ethylbenzene) for the instrument used (PID with 11.6 eV lamp) reported in Table 4-9 of the MA DEP Policy #WSC-02-411, Implementation of the MA DEP VPHIEPH Approach. BEA personnel returned to the Site several times over the remainder of the reporting period to conduct ambient air monitoring and Level 1 Soil Gas Screening via the sub-slab venting system and soil vapor probe. The maximum TOV reading of 0.2 ppmv was recorded in these supplemental inspections as significantly less than the strictest response standard (ethylbenzene) for the instrument used (PID with 11.6 eV lamp) reported in Table 4-9 of the EPH/VPH policy (#WSC- 02-411). As such, modified Level 1 Soil Gas Screening has demonstrated that degradation of indoor air quality due to low-level residual impact in soil is unlikely, in accordance with Table 4- 9 of the EPH/VPH policy. The sum of Level 1 Soil Gas Screening and indoor ambient air monitoring is presented in Table V. The significance of these results is further discussed in the Risk Characterization section of this report. TABLE V: 293 SEA STREET-HYANNIS,MA SUMMARY OF TOTAL ORGANIC VOLATILE MONITORING-PID RESPONSE METHOD 2-RISK CHARACTERIZATION:AMBIENT AIR BASEMENT PASSIVE SVE RISER SUBSLAB VAPOR POINT DATE TOV TOV TOV REMARKS (Ppmv) my my 11/19/2008 BDL(<O.1) BDL(<O.1) BDL(<O.1) Thermo 580B OVM(11.8 eV) BDL=Below Detectable Limits All three monitoring wells were sampled a second time for laboratory analysis of total petroleum hydrocarbons (TPH) as a cost savings measure to serve as an indicator for any groundwater impacts. The groundwater samples were collected in appropriately preserved laboratory containers and field preserved on ice. The analytical results for all three monitoring on each of the sampling rounds were BRL wherein the reporting limit concentration is significantly lower than the applicable GW-3, Method 1, Risk Characterization standard. The significance of the end point soil sampling, groundwater analysis and post excavation ambient air quality screening relative to potential exposures and risk is presented in the following section of this report. RISK CHARACTERIZATION [Refer to Appendix D] Soil As presented, the S-2 and S-3 (GW-3) soil categories are applicable to potentially accessible and isolated soils within the defined area of release under current Site conditions in consideration of exposures under Method 1 - Risk Characterization, as consistent with the DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 11 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 provisions of 310 CMR 40.0933. For the purposes of risk characterization in consideration of foreseeable future uses, the most restrictive S-1 (GW-3), Method 1 - Risk Characterization standards are further considered relative to potential ingestion, inhalation and dermal contact exposure risks to identified human and environmental receptors. Laboratory testing of end point soil samples in the sidewall (SW) and Bottom of Hole (BOH) areas by risk-based, fractional EPHNPH data has reported concentrations of fractional aromatic/aliphatic compounds and target analytes in each discrete sidewall and BOH areas are significantly below the applicable S-2 and S-3/GW-3, and most stringent S-1/GW-3, Method 1 — Risk Characterization standards. Furthermore, this testing has been considered to qualify the vertical extent of significant soil impact and threat of groundwater impact wherein the most restrictive soil samples below the extent of excavation also report fractional compounds and target analytes as significantly below the S-1/GW-3, Method 1 —Risk Characterization standards. The S-1 standards are developed in consideration of ingestion, inhalation and dermal contact exposures and as a measure of potential leaching to groundwater. As such, the data indicates a condition of No Significant Risk for potential exposures to identified human and environmental receptors associated with remaining isolated residual soil impacts. As a conservative measure, averaged low level petroleum hydrocarbon concentrations were use to calculated an EPC from the reported EPH/PAH and VPH/BTEX concentrations reported along the extent of contaminated soil removal. These averaged concentrations were applied to the Residential Short Form/Exposure Scenario to qualify risk under Method 3 — Risk Characterization, as presented in Appendix C. The Residential Short Form computed the "Subchronic Hazard Index" as 1 E-02 and the "Chronic Hazard Index" as 6E-02. Wherein all of the calculated values for were reported as significantly less than 1.0, the Residential Short Form/Exposure Scenario supports a finding No Significant Risk relative to potential exposures to human and environmental receptors as consistent with the Method 1 — Risk Characterization of soils. Groundwater As noted above,the GW-3 groundwater category is applicable in consideration of Method 1 - Risk Characterization at the Site as based on the NPDWA designation on the current Mass GIS Mapping (21E Overlay) wherein ingestion exposures are not considered as a foreseeable exposure risk. Furthermore, based on the depth of groundwater, inhalation exposures from impacted groundwater also not considered a foreseeable exposure risk. The GW-3 standards are developed in consideration of any significant environmental impacts and potential dermal contacts associated with impacted groundwater. The results of two (2) rounds of groundwater testing for all monitoring well locations has reported no groundwater impact wherein TPH concentrations are reported as BRL and the reporting limit concentrations are significantly less than the GW-3, Method 1 —Risk Characterization standards. Site-specific groundwater flow and solute transport modeling show that MW-2 and MW-3 are in downgradient locations. Monitoring well MW-2 is adjacent and immediately downgradient of the projected solute pathways as representative of groundwater impacts associated with a historic release of fuel oil more than 10 years prior to this filing. As such, groundwater conditions characterized at the Site represent a condition of No Significant Risk as associated with potential inhalation and dermal DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 12 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 contact to humans and environmental impacts to downgradient resources. It is noted that TPH concentrations indicate no impact to groundwater as meeting even the most stringent GW-1, Method 1 —Risk Characterization standards. Indoor Air No evidence of petroleum has been reported with the basement or living areas of the subject dwelling as based on olfactory observations and TOV screening of the dwelling interior. Indoor air quality screening within the basement routinely conducted with a PID [Thermo Environmental 580 B PID,11.8 eV lamp, calibrated to a benzene standard with isobutylene gas] has consistently reported no detectable response (BDL <0.1 ppmv) as indicating no measurable organic vapors. Subsequent to soil removal operations, low-level residual volatile (VPH — carbon range aliphatics, aromatics) impact was reported at the BOH (10'bgs) and HB-7 (10-15') within the former excavation. Based on the concentrations and locations of the residual volatile impact beneath + 6' of flowable fill with a sub-slab venting to the exterior of the dwelling, intuitive reasoning would indicate that impacts to indoor air quality are unlikely. In order to further evaluate and qualify any potential for adverse impacts to indoor air quality, BEA conducted TOV monitoring at the sub-slab venting system riser as consistent with Method 2, Level 1 — Soil Gas Screening. The TOV concentrations were consistently reported as 0.2 ppmv as consistent with background and less than the strictest response standard (ethylbenzene) and applicable response standards (C9-C12 aliphatics, C9-C10 aromatics) for the instrument used [PID, 11.8 eV lamp, calibrated to a benzene standard with isobutylene gas], as reported in"Table 4-9: Soil Gas PID/FID Screening Levels for Evaluating Indoor Air Impacts"of the Implementation of the MA DEP UIFEPHApproach (Policy#WSC-02-411, 10/31/02). This monitoring of the sub-slab vent was further substantiated relative to the potential impact to indoor air via the installation of a sub-slab, soil vapor monitoring probe in accordance with MADEP Indoor Air SOP August 2007 guidance document with the results reported as less than the detectable limit of the instrument (<0.1 ppmv). Based on the results of the TOV monitoring via multiple evaluation technologies, impacts to indoor air are not likely, in accordance with the provisions of Section 4.3.1.1 of the above referenced policy. As such, TOV testing under Method 2, have demonstrated no degradation of indoor air quality within the subject building in support of a finding of No Significant Risk associated with indoor air quality and potential inhalation exposures at the subject Site. Imminent and Substantial Hazard Evaluation As stated, all significantly impacted soils have been removed from the area impacted by the historic release. Laboratory analytical data for confirmatory soil samples collected from the extent of excavation reported all petroleum hydrocarbon concentrations as below the applicable S-1/GW-3 Method 1 — Risk Characterization standards as supporting a condition of No Significant Risk relative to soils. No groundwater impact has been documented by representative monitor well sampling and analysis as documenting No Significant Risk associated with groundwater. Additionally, ambient air quality screening by Level 1 — Soil Gas Screening methods within the dwelling has established and a condition of No Significant Risk associated DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 13 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 with ambient air quality. Wherein a condition of No Significant Risk is established for potential inhalation, ingestion and dermal contact is soil, groundwater and air medium for all foreseeable future activities and use of the property, there are no conditions of Imminent or Substantial Hazard. DATA USABILITY ASSESSMENT & REPRESENTATIVENESS EVALUATION The following presents a discussion of the Site information used to support the RAO as required by 310 CMR 40.1056(2)(k) and incorporating the guidance provided in MA DEP Policy WSC-07-350. It provides an evaluation and demonstration of the adequacy of the spatial and temporal data sets used to support the RAO and makes conclusions on the accuracy, precision and sensitivity of the data used. Conceptual Site Model An unknown volume of#2 heating oil was historically released from a former fuel oil storage tank that was removed prior to occupancy by the current owner. This release was discovered during a home inspection as part of a real estate transfer. The fuel oil had apparently been released to the natural ground surface over a concrete slab beneath the former tank and flowed off of the pad infiltrating into underlying soils. The fuel oil mobilized vertically as impacting underlying soils to a depth of approximately ± 16' bgs. Contaminated soils were excavated from the area of release and transported directly to a licensed asphalt batch facility. Based on field screening and laboratory analytical data, wherein non detect and low level petroleum concentrations in soil are compliance with the site specific Method 1 cleanup standards were reported and no groundwater impact as a result of the subject release is apparent based upon the analytical results from successive sampling and analytical evolutions, a condition of No Significant Risk exists at the Site. Field Screening PID screening and observations were used to qualify significant impact in soils and to make informed dynamic decisions in the field in advance of submitting samples for MA Certified analyses. In some cases, Dexsil Petroflag testing was conducted to qualify TPH concentration in the field. Samples with higher levels of odor or PID screening results are assumed to be more contaminated than those samples with lower levels. Comparison of visual, PID and observations with limited analytical data indicates the screening data roughly correlates with the analytical data. Sampling Locations Hand boring locations for environmental assessment of petroleum hydrocarbon concentrations in soils were selected as based on apparent preferential pathways beneath the crawlspace as would most likely result in impact to underlying soils. Based on the magnitude of significant impact and the hand boring locations, an approximate 8' x 6' x 4'(6-10'bgsD) area of impact was qualified as the target of prescribed soil removal operations. Field PID and TPH DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 14 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 screening was used to qualify the extent of contaminated soil removal. Six soil samples were collected for analyses from the extent of soil removal as above groundwater. Field duplicates or trip blanks were not collected or considered necessary because the disposal Site was small and QA/QC protocols were employed and documented. After collection, the samples were kept within a cooler with ice and subsequently within a refrigerator pending shipment to the laboratory under a properly executed chain-of-custody. Temporal Data Multiple evolutions of monitoring well sampling at times well in excess of the calculated time of solute travel since the historic release indicate that the fuel oil release did not impact the aquifer. Laboratory analytical data, soil gas screening and Method I/Method 2 — Risk Characterization indicate that future indoor air quality will not be impacted as a result of low- level residual impact along the extent of excavation. Field Completeness The analytical data set is complete. Data from the four sidewalls and the bottom-of-hole as well as extended vertically to the HB-7 location was obtained as representing the extent of significant impact and the limits of contaminated soil removal. The complete data set supports the RAO wherein all QA/QC thresholds and Presumptive Certainty requirements were met. Data Inconsistency No inconsistent data was identified. Visual observations, odors and field screening were generally well correlated. No inconsistency was identified between the field screening of end- point soil samples and their respective laboratory analyses. Data Not Used The complete analytical data set associated with confirmatory end-point soil samples was used to support the RAO as representative of Site and environmental conditions subsequent to the excavation of significantly contaminated soils. Analytical data associated with soil assessment, as representative of the identified impact, was used for disposal characterization. Field screening of significantly impacted soil samples collected during environmental assessment was used to select appropriate soil samples for laboratory analysis in review of remedial response actions and risk characterization. The complete analytical data set associated with groundwater sampling was also incorporated herein to support the RAO as representative of Site and environmental conditions subsequent to the excavation of significantly contaminated soils. DECEMBER 19,2008 FUCCILLOBEA08-10044 PAGE 15 OF 16 RAMC w/CLASS A-2 RAO RTN 4-21596 Data Usability Laboratory analytical results associated with confirmatory, end-point soil samples and groundwater samples were reviewed under the current REDUA policy WSC-07-350 for reliability and usability. The methods utilized (PID soil screening, Dexsil, EPH/VPH and TPH) all respond to the contaminants of concern identified in the release and are appropriate for a release of#2 fuel oil. Based on the Representativeness Evaluation, the analytical data quality of all endpoint soil samples and groundwater samples have been reviewed and evaluated. The analytical data provided in support of this RAO have met the method quality control requirements and performance standards for "Presumptive Certainty" as described in CAM VII A, Section 2.0 (a), (b), (c), and (d) or have been evaluated as comparable to CAM requirements. The validity and defensibility of the analytical data used to support the findings of the RAO for this Site with respect to accuracy, precision and completeness pursuant to 310 CMR 40.1056(2)(k) have therefore been satisfied. It has been determined that the Site data is sufficiently representative of actual Site conditions and may be used to support this Class A-2 RAO. CONCLUSIONS Excavation activities have resulted in the removal of all significantly impacted soils from the crawlspace area to a depth of +6' below the basement floor (10' bgs). Environmental assessment and monitoring have been used to develop a preponderance of physical evidence wherein No Significant Risk is associated with low-level residual soil impact and documented lack of impact to site groundwater and ambient air within the developed Conceptual Site Model in support of a condition of no significant risk. Method 1, Method 2 and Method 3 Risk Characterization have been evaluated within the Conceptual Site Model to qualify the condition of No Significant Risk as associated with all potential media exposures to identified human and environmental receptors. As such, a Class A-2 Response Action Outcome is appropriate to support the RAM Completion Statement and project closure without any restriction of Site activities or reliance on additional passive treatment provided beyond project closure. A review of cost and feasibility to meet background conditions through additional soil removal was considered as part of this RAM, in accordance with the provisions of 310 CMR 40.1020. Residual EPH/PAH and VPH/BTEX impact in soil is located beneath the footprint of a building noted as a permanent structure and further isolated beneath a poured fill cap. In consideration of the logistics associated with the additional removal of isolated soils at depth, such remedial actions would result in significant endangerment to the structure wherein worker safety would be compromised. Further, wherein laboratory analytical reports document soil conditions along the extent of the excavation as less than the S-1/GW-3, Method 1 — Risk Characterization standards, additional soil removal is not justified wherein no significant reduction in risk would be accomplished. As such, current environmental conditions associated with non-persistent, naturally degrading petroleum hydrocarbons within isolated soils meet the "Conditions of Categorical Infeasibility" established in Section 9.3.2 of the MA DEP policy "Conducting Feasibility DECEMBER 19,2008 FUCCU LOBEA08-10044 PAGE 16 OF 16 RAMC w/CLASS A-2 FAO RTN 4-21596 Evaluations Under the MCP" (04-160), as specifically pertaining to Section 9.3.2.1, "Excavations Under Permanent Structures", and Section 9.3.2.3, "Remediation of Degradable (Nonpersistent) Contaminants". Therefore, such soil removal without significant risk reduction is considered practically infeasible as logistically and financially unjustified. The findings of this investigation, as represented herein, set forth the rationale and technical justification f6r the LSP Opinions offered, as established by the certifications made on the attached Response Action Outcome Statement (BWSC-104) and the Release Abatement Measure Transmittal Form (BWSC-106). The LSP Opinions are based on available data and regulations in effect at the time of this reporting specific to the subject Site. If you have any questions regarding this Immediate Response Action Completion with Class A-2 Response Action Outcome, or need additional information regarding this project, please contact our office at your earliest convenience. Sincerely, BENNJETT ENVIRONMENTAL ASSOCIATES, INC. ill', D v1d C e ett,LSP Brian 1 e, Geologist Pri 'pal Project Manager Encl: Supporting Documentation [Appendices A-F] cc: Lola J. Fuccillo,Lola J. Fuccillo Investment Trust- Property Owner Lieutenant Hubler-Hyannis Fire Department(Narrative,title page, site plan only) Thomas McKean- Barnstable Board of Health(Narrative, title page, site plan only) John Klimm- Barnstable Town Manager(Narrative,title page, site plan only) I RELEASE ABATEMENT MEASURE COMPLETION STATEMENT W/CLASS A-2 RESPONSE ACTION OUTCOME SUPPORTING DOCUMENTATION RTN#4-21596 Private Residence 293 Sea Street—Hyannis,MA [Assessors Map 306, Parcel 78] DECEMER 19,2008 Prepared For: MA DEPARTMENT OF ENVIRONMENTAL PROTECTION Southeast Regional Offices: Bureau of Waste Site Cleanup/Emergency Response Section 20 Riverside Drive -Lakeville,MA 02347 Prepared By: BENNETT ENVIRONMENTAL ASSOCIATES, INC. 1573 Main Street- Brewster, MA 02631 David C. Bennett, LSP On Behalf Of. Lola J. Fuccillo Investment Trust 2424 Crowe Ridge Road—Winchester, KY 40391 APPENDIX A: Reference Plans -Figure 1: Site Locus Plan [USGS Topographic Quad.,Hyannis,MA. 1998] (excerpt) -Figure 2: Ground-Water Resources of Cape Cod,MA[LeBlanc et al, 1986] (excerpt) -Figure 3: MA DEP BWSC GIS Map [2008] - Site Plan entitled,"Release Abatement Measure Completion..."Prepared by BENNETT ENVIRONMENTAL ASSOCIATES,INC.,dated December 17, 2008. APPENDIX B: Field Reports -Field Inspector's Records of Work Progress [#1 (10/27/2008)through#3 (11/19/2008)] -Monitoring Well Sampling Logs [10/28/08, 11/19/081 APPENDIX C: Environmental Records/Permits -Aggregate Industries Soil Recycling Submittal -BWSC-012A-C: Bill of Lading -eDEP Authorization Agreement -BWSC-104:Response Action Outcome Form w/eDEP Submittal Summary and Receipt -BWSC-106:Release Abatement Measure Transmittal Form w/eDEP Submittal Receipts -Method 3 Residential Short Form APPENDIX D: Laboratory Analysis -Laboratory Analytical Results- Soil [GWA]: #121292(10-29-08)w/Table Maker Summary -Laboratory Analytical Results-GW[GWA]: #121832(11-21-08)w/Table Maker Summary APPENDIX E: Quality Assurance/Quality Control Plan 1.5. 20119 110.46AN1 W'-S Der Nc 1 A4i�� COMMONWEALTH OF MASSACHLTSETTSA2,1 _ _ EXECUTIVE OFFICE OF ENERGY & ENVIItONMEN�'AI AFFAIRS # DEPARTMENT OF ENVIRONMENTAL PROTECTION #,1 ; { SEE SOUTHEAST RE�:'r'i'Oi�iF�L 'FFICF; 20 Riverside Drive., ;sakeville=, ILIA 02347 j 946-2700 { S v2r-°c r fij 0drlfY i-.AFuRRAY LAURIE Bul:' , j Li zuteyj0A,Governor Commis:;ioriol. 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Town Manager 508 790 6226 } t Fire Dept. 506 77B 6448 s'0',1,'&rA a NTJMBER OF PAGES. 4 (INC1'eUNNG COVER PACE} :E1LP SE CALL IF YOU DO NOT RECEIVE COMPLETE PAZo , Nrit,ice of Responsibility, 293 Sea 6t. , Hyannis 1 � 1 t f'_t t �.��C1' F 'I• i4 t�'114+•l !'Alr� gd 'fhls infor¢nation in available in aleewaato fot°fmat,Cal!Dauald'VI.Gamt'E,,+°DA Coordinator a6 617-.136-1037."f'DD S¢rvie¢-119U0-;.i 91iZ3D7, DE9 on the World Wld�Web: rttglhvrnw.maea.guv/dap PBm:ed or,Req+eled Paper ,r Es` t j a rh ' I iTt' L °J!a�, 5. 2009 HARM Maas DEP Nc. 9237 P. 2/' c� i` 14 e �i al I.� •� COMMONWEALTH OF 1VIASSACHUSETTS I I j l i A 613P�3 ECUIVE OFFICE F ENERGY &E-J , RS + DEPARTMENT OF ENVIRONMENTAL PRO SOUTHEAST ]REGIONAL OFFICE ' l:�'` 20 RWERSID1E DRIVE,LAKEVLLE,M1 A 02347 508-9 iRD1; VA-1 L.PATRICK + ��.,1✓ LAN A.BOWLE,S '' ; ' i:(�riyexnar 3ocraeary 'I i Et ut6�t ItfilRJ`.f:SITY F'_MURRAY LAUME BUR,T ° + �6191 rsant G)varnor + i# Commis2ioner ' l ,lal URGENT LEGAL MA 11`TXR:PRO AC110N NECESSARY � 141 t i1 ! ' January 8,2009 f 4 f�tfi � Yplyil4 ' Pair.;fim Fuccillo,Trustee RE: BARNSTABL E m BWSC I ;G,Vl, •Lola 1 Fuccillo Trust 293 Sea Street,Hyannis I i l l i ;Etta'' 4 2424 Crowe Ridge Road RT N#4-21696 ! l� ,�t!j )iVinchester,Kentucky 40391 1. i.. h Vl ,'3 I. tlt X NOTICE OF RESPONSIBILITY IUMEASE ABATEMENT(MEASURE FLAN/RESPONSE ACTION OUTCOME STATZMENT M.G.L. c. 21E,310 CMR 40.0000 j ��T"CT✓ItifTIOTd:Mr. Fuccillo i illr On October 21, 2008 the Department of FErwironmental Protection("Ml assDEP")received a Release l 'a �io`iiis;ation Form("RNF )," which indicates that a release of oil and/or hazardous material has occurred at the 1'ncation referenced above. A Release Abatement Mf,asure Plan (RAM Plan) prepared by Bennett ,1 Envixorarnental Associates,Inc.was received on October 25,2008, The Response Action Outcome Statement (RAO)was received on December 23,2008. �� t Nptl �� tif Ai'.• 1. The Massachusetts Oil and Hazardous Material Release Prevention and Response Act, M.G.L. c,'21%;, and the Massachusetts Contingency Plan (the"MCT'), 310 CMR 40.0000, require the perforinance of 'c,' response actions to prevent harm to health,saftty,public welfare and the environment which may result from �. this release and/or threat of release and govern the conduct of such actions. The purpose of this notice is to � ! 17 ,, 11,r - infonrn you of your legal responsibilities under State law for assessing and/or remediating the release at this 'ry pro;peny. For purposes of this Notice of Responsibility, the terms and phrases used herein shall have the nn,ean:ing ascribed to such terms and phrases by the MCP unless the context clearly indicates otherwise. MassDEP has reason to believe that the release and/or threat of release,which has been reported, is or may be a disposal site as defined by the MCP. MassDEP also has reason to believe that you (as used in this letter, "you" m 91 refers to the Lola J. Fuccillo Trust) a a Potentially Re6iponsible Party (a PRI'11) with ,,!; liability under M.G.L. c.21E §5, for response action costs. This liability is "strict", meaning that it is not ,alsi€I based on fault, but solely on your status as owner, operator, generator, transporter, disposer or other person specified in M.G.L. c.21 E §5. This liability is also "joint and several", meaning that you may be liable for all � l jYl#aa I y r,sponse action costs incurred at a disposal site regardless of the existence of any other liable parties. i , X Till's information is available in alternate[ortnat.Call Donal!A1.Gomes,ADA Coordinator at 617-546-1S7.TDD Service-1.804-29&-22V. i lit i i 9 I! DEP on the World Vide Vieb: h'.ipl/wwm mas3.®ovldep 0 Pr!f4te0 wl aeryc'lad Paper + I t Il i 15. 20�9 i0. 4bAM MASS DF_P No. 9237 P. 1/ ' 1 ' MassDEP encourages parties with liabilities under M.G.L. c.21E to take prompt end appropriate actions in response to releases and threats of release of oil and/or hazardous materials. By taking prompt ''� +. a ,„ action, you may significantly lower your assessment and cleanup costs and/or avoid liability for costs l�l R inmmed by MassDEP in taking such actions. You may also avoid the imposition of,the amount of or reduce r' i ertarnpermit and/or annual compliance assurancd fees payabk under 310 CMR 4.00. Please refer to M.G.L. c.21E for a complete description of potential liability. For your convenience, a summary of liability under M.011,c.21E is attached to this notice. You should be aware that you may have claims against third parties for damages, including claims f ;# •lor contribution or reimbursement.for the costs of cleanup. Such claims do not exist indefinitely but are rzovd.nled by laws that establish the time allowed for bringing litigation. MassDEP encourages you to take ,any action necessary to protect any such claims you may have against'third patties. st , SITE INFOR IAT10N Information on file with MassDEP indicates the following contaminant(s) were detected in soil 1 ,s;sm„al Ws collected from the site at concentrations which exceeded the Reportable Concentrations for Soil (Category 1 (RCS-1)per 310 CMR 40.1600, CHEIMCA)L CONCENTRATION RCS-1 �.+! i !' �M Total Petroleum Hydrocarbons(TPH) 12,000 ppm 1,000 mg/kg rs a i RELEASE ABATFNE tT 10'ItEASURE PLAN b The Release Abatement Measure Plan received on October 25, 200i3, prepared y Bennett , ` ;Envarorr-mental Associates, Inc. (BEA)proposed the removal of twenty five(25)cubic yards of soil from the r:rpwls ace area where a former tank was located.The dimensions of fie area excavated is estimated to be Vx ,6'x 4'. Following the soil removal a sub-slab venting system was to be installed to mitigate potential i�:xpos rt e risk. Groundwater monitoring wells were installed to assess potentiai groundwater impact. 1� This site shall not be deemed to have had all the necessary and required response actions taken unless and until all substantial hazards presented by the release and/or threat of release have been eliminated and a levO of No Significant Risk exists or has been achieved in compliance with M.G.L.c.2I E and the MCP. e;" Unless otherwise provided by MassDEP, potentially respor.siblP parties ("PRP's") have one year ,, ftorr, the initial date of notification to MassDEP of a release or threat of a release, pursuant to 310 CMR 1i='�" + b =10.0300, or from the date MassDEP issues a Notice of Responsibility, whichever occurs earlier, to file with lgm:sDEP one of the following submittals: (1) a compl(=.ted Tier Classification Submittal; (2) a Response Action Outcome Statement or, if applicable, (3)a Downgradient Property Status. The deadline for either of t he:First two submittals for this disposal site is October 21,2009. If required by the MCP,a completed'Pier I 1'emill: Application accompany lication must also a Tier Classification Submittal. The MCMCPIrequires that a fee of P Y �'00.00 be submitted to MmDEP when a response Action Outcome ("RAID") statement is filed 11,'F; lgr eatc r than 120 days from the slate of notification, The RAO, also prepared by BEA, was received by � r{ I .! 1,;; Ivia9,s1)E.P on December2,,2008. , - -' ,,; You must employ or engage a Licensed Site Professional ("LSP11)to manage, supervise or actually I perform, the necessary response actions at this site. You may obtain a list of names and addresses of LSPs frorn the Board of-Registration of Hazardous Waste Site Cleanup Professionals by calling(617) 556-1091 or visiting http://www.state.ma.usJlsp, MassDEP has David C. Bennett of Bennett Environmental Associates, Inc. as the LSP of Record for this Site. 1 'illa'. 15. 2009 : 5 i PM MA88 DEP No. 9?48 P. 2 ,, ,r •} 3 ';; if you have any questions relative to this Notice, please contact Julie J. Hutcheson at t1ja letterhead 1� }` s>ddre,s or at(508)946-2852. All fixture communications regarding this release must reference the following if ' f;,, ! R elease Tracking Number:4-21596, Very truily yours, t _ D "I", f ban Crafton,Acting Chief ill ! Emergency Response/Release Notification Section , RN 21.596 RAM NOR 120.doc Alla.A-ments: Summary of Liability under M.G.L.c.21 E:fe� Board of Selectmen Board of Health Fire Dept. A T"Ill: Data Entry 1 � -.c: Bennett Environmental Associates,Inc. 1573 Main Street li 4 1 P.O.Box 1743 Brewster,MA 02631 dbennen@bermett-ea,com �• 11 ,, jft � }I Sled Il r i f : , I f al a I rt � '1 �� ► s fe a I �Ies I f ,, � 'i ' r' BENNETT ENVIRONMENTAL ASSOCIATES, INC. LICENSED SITE PROFESSIONALS,ENVIRONMENTAL SCIENTISTS,GEOLOGISTS,SANITARIANS 1573 Main Street,P.O.Box 1743 (508)896-1706 Brewster,MA 02631 fax(508)896-5109 LETTER OF TRANSMITTAL TO: DATE: JOB NUMBER: Ms.Lara McLaughlin,Data Manager F�" BEA08-10044 MA DEP SERO-B W SC 20 Riverside Drive REGARDING: Lakeville,MA 02347 RELEASE NOTIFICATION W/ RELEASE ABATEMENT MEASURE PLAN—RTN 4-21596 Private Residence SHIPPING METHOD: 293 Sea Street—Hyannis,MA[Assessor's Map 306,Parcel 78] Regular Mail ❑ Pick Up ❑ Priority Mail ❑ Hand Deliver ❑ Express Mail ❑ Other uploaded ❑X Certified Mail ❑ Green Card/RR ❑ COPIES DATE DESCRIPTION 1 10/24/2008 RELEASE NOTIFICATION W/ RELEASE ABATEMENT MEASURE PLAN—RTN 4-21596A a a Private Residence 1 CD 293 Sea Street—Hyannis,MA[Assessor's Map 306,Parcel 781 For review and comment: ❑ For approval: ❑ As requested: ❑ For your use: ❑X REMARKS: cc: Lola Fuccillo-Property Owner Lieutenant Hubler-Hyannis Fire Department(Narrative,title page,site plan only) Thomas McKean-Barnstable Board of Health(Narrative,title page,site plan only) John Klimm-Barnstable Town Manager(Narrative,title page,site plan only) FROM: Brian Clarke/gjb If enclosures are not as noted,kindly notify us at once BENNETTENVIRONMENTALAssoCIATES, INC. LICENSED SITE PROFESSIONALS 0 ENVIRONMENTAL SCIENTISTS 6 GEOLOGISTS & SANITARIANS 1573 Main Street-P.O. Box 1743, Brewster, MA 02631 & 508-896-1706 d Fax 508-896-5109 www.bennett-ea.com BEA08-10044 October 24, 2008 Ms. Lara McLaughlin, Data Manager MA DEPARTMENT OF ENVIRONMENTAL PROTECTION (MA DEP) Southeast Regional Office (SERO) Bureau of Waste Site Cleanup (BWSC) 20 Riverside Drive Lakeville, MA 02347 RE: RELEASE NOTIFICATION W/ l �' RELEASE ABATEMENT MEASURE PLAN—RTN 4-21596 Private Residence 293 Sea Street—Hyannis, MA [Assessor's Map 306, Parcel 78] ' Dear Ms. McLaughlin, � cry BENNETT ENVIRONMENTAL ASSOCIATES, INC. (hereinafter referred t as `BRA") r}' has prepared the following Release Abatement Measure Plan (RAMP) and upporting .Documentation as a summary of release discovery and environmental assessment conducted at the above-referenced property as associated with a historic fuel oil release and the identification of a 120-Day condition. Additionally, the RAMP outlines the proposed remedial response actions to be undertaken to mitigate potential human exposures and environmental impacts in accordance with the provisions of 310 CMR 40.0440 where there is a threat of groundwater impact. Environmental assessment activities have been conducted to qualify the magnitude and extent of significant soil impact associated with a previously unidentified historic release of an unknown quantity of #2 fuel oil in an earthen crawl space beneath the southern portion of the dwelling. The excavated area of the former tank is clearly visible within the crawl space. An initial investigation determined that 1 to 2 feet of soil overlies a concrete slab which was beneath the former tank and that the slab does not extend to the vertical limit of the crawl space interior or exterior sidewalls. Fuel oil apparently flowed over the slab to the edge of the slab and entered into the underlying soils. The vertical extent of soil contamination has been determined to extend at least to 16' below grade surface (bgs) at the FIB-5 sampling location and, as such, represents a threat of groundwater impact(as precluding)•a Limited Removal Action (LRA), wherein environmental monitoring beyond soil removal is appropriate and-necessary in review of potential exposure risks. As such, a Release Abatement Measure (RAM) Plan, with Release Notification, is being submitted for soil removal operations and construction of a sub-slab 1 EMERGENCY SPILL RESPONSE 6 WASTE SITE CLEANUP b SITE ASSESSMENT 6 ENVIRONMENTAL PERMITTING 6 LAND USE PLANNING WATER SUPPLY DEVELOPMENT,OPERATION&MAINTENANCE b WASTEWATER TREATMENT,OPERATION&MAINTENANCE OCTOBER 24,2008 FUCCILLOBEA08-10044 PAGE 2 OF 13 RELEASE ABATEMENT MEASURE PLAN venting system to mitigate potential exposure risks and facilitate any potential future treatment of residually impacted soils. Monitoring wells have been installed and tested in consideration of potential groundwater impacts. Additional environmental assessment activities are prescribed herein to further evaluate cleanup performance and exposure risks, following soil removal operations. This information will be used to determine the need, if any, for additional treatment of any significant residual soil impacts or groundwater impacts to meet regulatory closure objectives for a Class A, Response Action Outcome (RAO). The Release Abatement Measure Plan prescribes the excavation and off-site recycling of some 15 to 25 cubic yards of fuel oil contaminated soils from within an approximate 8' x 6' x 4' (D) [10' bgs] area. This work will be accompanied by end-point sampling of sidewall and bottom-of-hole (BOH) areas and the re-sampling of previously installed groundwater monitoring wells. Soil and groundwater samples will be submitted for laboratory analysis of petroleum hydrocarbons in accordance with the current VPH/EPH Implementation policy (WSC-02-411). Some TPH analyses may be utilized as a cost saving measure wherein TOV screening and or field Dexsil Petroflag testing indicates low level or background conditions. Subsequent to the removal of contaminated soils, a structure venting system will be installed along the bottom-of- hole area to provide exterior ventilation of any potential residual organic vapors from the area of excavation. The structure venting system can also be retrofitted to serve as a delivery system for remedial additives to the subsurface for potential in-situ treatments if necessary or be adopted for Level 1, ambient air screening as consistent with MA DEP Policy WSC-02-411, Implementation of MA DEP VPH/EPHApproach. Future environmental assessment/monitoring activities will dictate the need for any additional remedial measures to be represented as a RAM Modification in the next RAM Status Report to be filed within 120 days of this filing should regulatory closure standards not be met. Additional RAM Status Reports, if necessary, will be filed every six months thereafter. Remedial response activities proposed herein, and potentially to follow, are intended to mitigate any potential Critical Exposure Pathways (CEPs) and to facilitate a permanent solution in order to mitigate potential risks to identified human and environmental receptors in support of a Class A, RAO within the one-year statutory deadline to avoid Tier Classification and Disposal Site assignment. The proposed RAM Plan is being presented in accordance with the provisions of the Massachusetts Contingency Plan (MCP), 310 CMR 40.0000, as specifically pertaining to 310 CMR 40.0440. The information herein serves as the technical rationale and justification for the response actions proposed within, which include the excavation of some 15 to 25 yards of contaminated soils, the construction of a sub-slab venting system and environmental monitoring to support project closure based on a preponderance of physical evidence wherein a condition of "No Significant Risk" is achieved. This work has and will continue to proceed under direct LSP oversight in a manner consistent with the MCP Response Action Performance Standards (RAPS) pursuant to 310 CMR 40.0191 and the QA/QC policies of BENNETT ENVIRONMENTAL ASSOCIATES, INC. The facts and statements herein are, to the best of our knowledge, a true OCTOBER 24,2008 FUCCILLOBEA08-10044 PAGE 3 OF 13 RELEASE ABATEMENT MEASURE PLAN and accurate representation of the Site activities, remedial response actions and environmental conditions associated with the project and LSP Opinions acknowledged by the certification on the attached BWSC-106 Transmittal Form. ENVIRONMENTAL CONDITIONS [Refer to Appendix A] The subject property at 293 Sea Street is noted on the Town of Barnstable Assessor's Map 306 as Parcel 78 and is located along the northwest corner of the Sea Street/Stetson Street intersection [Refer to Figure 1]. The residentially zoned property contains approximately 0.3 acres of land area and is developed by a two-story residential style building constructed in 1900+/-. This building has historically and is currently being used as a private, single-family residence. The surrounding area is developed in similar use, as characterized by residential properties. Access to the subject property is unrestricted with high frequency/high intensity of use and children potentially present. Access to the area of release, however, as within the crawl space of the subject building and is restricted with low frequency/low intensity of use with children potentially present as infrequent visitors. Residents of the dwelling are identified as the primary potential human receptors to any ingestion, inhalation or dermal contact exposures. Monitoring well installation, conducted September 25, 2008, indicated that groundwater exists at + 25' bgs. Regional groundwater contours indicate a southerly flow direction towards Hyannis Harbor (0.5 mi south) and Lewis Bay (0.75 mi southeast). Static water level measurements conducted on September 25 (low tide) and September 30 (high tide) indicate however, that local groundwater flow at the Site is westerly towards Stewart's Creek and associated wetlands, located approximately 0.25 miles to the west. As such, Stewarts Creek and the associated wetlands are presently identified as the potential environmental receptors pending confirmation of groundwater flow direction and seasonal/tidal variations. According to the MA DEP BWSC GIS mapping program, the subject property is located within a medium yield, non-potential drinking water source area (NPDWSA) as attributed to housing density in an urbanized area. The property does not fall within the Zone II Protective Radius of any Public Water Supply (PWS), nor is it located within the Zone A protective radius of any surface water reservoir. No private wells are known to exist within 500' of the Site wherein the area is serviced extensively by the Town of Barnstable municipal water supply and distribution system. Based on this mapping and field observations, the GW-3 groundwater category is applicable under Method 1 —Risk Characterization, per 310 CMR 40.0974. Based on Site conditions relative to frequency/intensity of use and accessibility of soils, wherein the release area is within the crawl space of the basement of the subject building, the S-2 and S-3 (GW-3) Method 1 —Risk Characterization standards are applicable to soil impact in accordance with the provisions of 310 CMR 40.0975. In review of all foreseeable future uses and activities at the Site, the most restrictive S-1/S-2/S-3 (GW-3), Method 1 — Risk Characterization standards are I considered. These standards were developed in consideration of potential ingestion, inhalation and environmental/dermal contact exposures and in review of potential leaching of contaminants to groundwater. OCTOBER 24,2008 FUCCILLO/BEA08-10044 PAGE 4 OF 13 RELEASE ABATEMENT MEASURE PLAN BACKGROUND [Refer to Appendix B] BEA received a phone call from the property owners during the weekend of August 23/24, 2008. The homeowners were in the process of selling the house and a home inspector detected the presence of a fuel oil odor in the crawl space area. A visual inspection evidenced what appeared to be an excavation with an adjacent pile of dirt that apparently was cast from the excavation. No public records of any permits relative to the former existence or removal of a fuel tank for the property could be located. Additionally, forensic evaluation of the degree and amount of hydrocarbon degradation indicated that the fuel oil residuals were significantly degraded as indicating that the release had occurred at least 10 years earlier and prior to the current owner's purchase of the property. At the time the current owners took possession of the property in 2001, the domestic heating already had been converted to natural gas and the storage tank had been removed. BEA contracted with the homeowners, who live out of state, to meet with their realtor, photo-document conditions within the crawl space area and conduct limited soil sampling and analysis to qualify environmental impacts and determine if release notification and/or remedial response liability was present under the provisions of 310 CMR 40.0000. These results and follow up assessment activities are summarized in the RAMP as follows. ENVIRONMENTAL ASSESSMENT [Refer to Appendix B] Soil BEA conducted the above noted initial soil sampling on August 27, 2008 in the earthen crawl space under the addition on the south side of the dwelling. The homeowners had indicated that their perspective buyers home inspector had noted a petroleum odor in this area. Analytical results from BEA's two initial sampling locations HB-1 and HB-2 immediately above a buried concrete slab (initially thought to have supported the former oil tank) reported total petroleum hydrocarbon(TPH)concentrations of 12,000 parts per million(ppm) and 7,800 ppm respectively. These concentrations are significantly above the Site-specific RCS-1 Reportable Concentration threshold of 1,000 mg/kg and the applicable S-3/GW-3, Method 1 — Risk Characterization standard of 5,000 mg/kg. This testing further indicated that more than 2 yards of soil had been impacted above the aforementioned standards. Wherein a 120-Day Reportable Condition was identified, BEA returned to the property on September 8, 2008 to collect additional sidewall samples and advance additional hand borings in the areas at the perimeter of the buried concrete slab, towards defining the extent of significant soil impacts and potential for groundwater impacts. BEA collected sidewall samples from the dug out area of the crawl space for field testing and advanced hand borings adjacent to the area of documented impacts: Hand borings HB-3 and HB-4 were advanced to 6' and 8' feet below grade OCTOBER 24,2008 FUCCILLOBEA08-10044 PAGE 5 OF 13 RELEASE ABATEMENT MEASURE PLAN surface (bgs) off of the east and west ends of the exposed concrete slab, respectively. Borings at these locations were limited by available headroom and the friable nature of soils underlying the dwelling. Field screening of soil samples from HB-3 and HB-4 reported low-level total organic volatiles (TOV) concentrations from zero to 2.4 parts per million(ppmv). Hand boring, HB-5, was advanced to a depth of 16 feet bgs between the paved driveway and building footing, immediately adjacent to the crawl space release area [Refer to attached site plan]. This hand boring was angled to intercept soils under the release area. Soils at the HB-5 location consisted of loose, medium to coarse grain sands with nominal cohesion. Field screening of soil samples from HB-5 reported moderate TOV concentrations from zero to 44 ppmv and increasing with depth. Groundwater was not encountered at the HB-5 location as projected at 25' below existing grade. Soil samples HB-5: 8'-10' and 12'-14' were submitted for MA Certified laboratory analysis of TPH and the 15'-16' interval sample was submitted for laboratory analysis of extractable/volatile petroleum hydrocarbons (EPHNPH). Analytical results were received on September 11, 2008. The analyses reported TPH concentrations in the HB-5: 8-10' sample as 1,900 parts per million (ppm) and in the HB-5: 12-14' sample as 1,100 ppm. However, the "worst case", TOV-biased HB-5: 15-16' sample reported EPH and VPH carbon range and target analyte concentrations as less than the applicable S-3/GW-3 standards. As such, the TPH sample (HB-5/8'-10'; 1,900 ppm) was re-analyzed for the risk-based EPH/VPH analysis, as was the HB- 4: 6'-8' sample, in order to quantify the magnitude of impact in the consideration of risk, as critical to the formulation of a remedial strategy. These analytical results were received the afternoon of September 16, 2008 and reported all fractional VPH/EPH standards and target analytes at concentrations less than the applicable S-3/GW-3, Method 1 — Risk Characterization "cleanup" standards. These results indicate that the excavation of soils to 8' bgs in the area of release should meet closure objectives. As such, a + 4-6' excavation to a depth of 8-10' bgs is proposed within this RAMP. Although this testing indicates that the S-1/GW-3 standards are met in soil samples below 8' bgs, residual soil impacts extent below 16' bgs and indicate the potential for groundwater impact. As such, the installation and testing of monitoring wells was prescribed to assess this potential. The sum of the laboratory analytical results for the soil samples submitted to date is presented in Table I and Table II. The significance of the laboratory results as they relate to potential exposure risk is further discussed in the Risk Characterization section of this report. The significance of these laboratory results as associated with proposed remedial response actions is further discussed in the Release Abatement Measure Plan section of this report. f OCTOBER 24,2008 FUCCILLOBEA08-10044 PAGE 6 OF 13 RELEASE ABATEMENT MEASURE PLAN TABLE I: 293 SEA STREET-HYANNIS,MA SUMMARY OF TPH/EPH LABORATORY ANALYSIS-ENV.ASSESSMENT Exposure Point RESULTS S-1,S6II,STD:. 9-2 SOIL STD., S-3 SOIL STD DIP.CONTACT UPPER CONC. Location&Analyte (µg/g=ppm) (µg/g=ppm) (48/9=ppm) (µg/g=pgm) 'STANDARDS_ LIMITS 310 CMR 310 CMR 310 CMR (µg/g ppm) 40.0975 6(a) 40.0975(6)(a), 40.0975(6)(a) 310 CMR 40.0985(6) (µg/g=ppm)_ _ de th below grade surface 4.16.08,5.27.08 GW-1/GW-2/GW-3 .z GW=1/GW 2/GW-3 GW-1/GW-2/GW-3-- `, -_S-1/S-2/S-3 310 CMR 40.0996 7 HB-1:0-1'(6-7');8-27-08 TPH 12,000 1 000/1 000/1 000_-3 000-/3 00013 060 .-'5 000/5 000/5 000 -1 000/3 000/5 000_ 10,006 -. .. HB-2:0-1.5'(6-7.5');8-27-08 TPH 7,800 ` - .-1000/1 000/1000 .3 000/3 000/3 000 5 000/5 000/5 000- -.1 000r3 000/5 000 - _.10,000_. HB-5 8-10'•9-8-08 - TPH refer to EPHWH retest 1900 1000/1000/1000 _3,000/3,000/3,000 -5,000/5,000/5,000 ,1,000/3,000/5,000 _ __ 10,000 =_ H11-5 12-14'• 9-8-08 TPH refer to EPH/VPH retest 1,100 1000/1000/1000- F 3,000/3,000/3,000 5,000/5,000/5,000 1000/3,000/5 000_ _, _J0,000 HB-4;(6-81);9-8-08 EPH C9-C18 Aliphatics 31 1,060/1 006/1;0,00 3,000/3,000/3,000 5,000/5,000/5,000', 1,000/3,000/5,000 20,000 C19-06 Aliphatics <30 3,000/3,000/3,000 , 5,000/5,000/5;000. 5,000/5,000/5,000 2,500/5,000/5,000 20,000 CI1-C22 Aromatics 45 1,000/1 000/1,000 1,000/31000-8,000 1,000/5,000/5,000: 1,000/3,000/5,000 10,000 Target PAH ' 2-Methyhiaphthalene <0.51 0:7/80/300:c ` 0.7/80/500' 0.7/80/500. 300/500/500 5,000 Phenanthrene <0.52 10/500/500 J0/1000/1,000 10/3,000/3,000 500/1,000/3,000 10,000 Acenaphthene <0.51 �4h,000/1060' '4/3;000/3,- °4/5,000/5;000 1;000/3,000(5,000 +10,000F *. Fluorene <0.51 1,000/1000/1,000 3 000/3,000/3;000, 5,00015,00015,000: { 11000/3,000/5,000 10,000 Pyrene <0.51 1,000/1 000/1 000 3,060/3 000/3,000 5,060/5 000/5,O 00, 1,000/3,000/5,000 10,000, All Other Targets BRL <0.51 ' 't a 4/4/4 .�M, >_30/30/30' -5 .2/4/30,��+ ;,_ .�>300( ; �„ ?0:7/0.7/0.7�, > HB-5;(8-10');9-8-08 i , ``z _ l EPH } C9-C18 Ahphatics 990 1,00011 000/1 000 3 000/3 0000/3 000 5 000/5 000/5,000 t 1,000/3 000/5,000 20,000 s m :- r- C19-C36 Aliphatics 190 1 3 000/3 000/3 0005 000/5 000/5,000 t 5,000/5 000/5,0001 +�2,500/5 000/5 000 ;+° 20 000 " Cl1-C22 Aromatics 570 1,000/'l 000/1,000 1 000/3 000/3,000. 1,000/5 000/5,000; ;'1,000/3 000/5,000• 10,000 TargetPAH -- i� 2-Methylnaphthalene 0.93 0.7/80/3001;`'s ? ''0:7/80/500 0.7/80/500 '300/500/500; 5,000' Phenanthrene 1.2 10%500/500 * 10/1 00 1;0, e'10/3 000/3,000 500/11,000/3,O@ j i 10,000x.` Acenaphthene 1.3 -4/1,000/1000. ^ 4/3 006/3 060, '4/5 000/5,000 j ' 1,000/3 00015 000 _ 10 000 Fluorene 4.1 t-1,000/1,000/1,000 r 3,000/3 000/3 000 t • 5,000/5 000/5,000 1,000/3,60015 000 10,060 'Y Pyrene 0.52 j,000/1000/1d000 1 3,000/3 000/3 0.00 5,000/5 000/5 / ,000 ,`,1,000/3;000%5 000; j 10,000 t 'r, All Target Analytes BRL(<0.51) >0-.710.7/0.7 "' >_((17/4/4= ?0%6/10' ?0 7/4/30 >300 r OCTOBER 24,2008 FUCCILLOBEA08-10044 PAGE 7 OF 13 RELEASE ABATEMENT MEASURE PLAN TABLE I: 293 SEA STREET-HYANNIS,MA SUMMARY OF TPH/EPH LABORATORY ANALYSIS--ENV.ASSESSMENT Exposure Point RESULTS S;1 SOIL STDi S 2 SOIL STD: S-3 SOII.STD } D&CONTACT SUPPER CONC - - Location&Analyte (µg/g=ppm) (µg/g ppm) (µg/g ppm)a ;(µg/g ppm) STANDARDS .$ LIM TS� � 310 CMR -310 CMR =310 CMR' {µg/g 40.0975(6)(a) 1 i40.0975(6)(a)1 40 0975(6)(a) 310 CMR 40 0985(6) (µ`g/g ppm) " (depth below grade surface 4.16.08,5.27.08 GW-1/GW-2/GW-3 t GW-1/GW-2/GW-3 GR?-1/GW 2/GW 3 _ S 1/S-2/S=3 — 310 CMR 40;0996 7 HB-5:(15-16');9-8-08 EPH C9-C18 Aliphatics 640 1`000/1000/1,000 3 000/3 000/3,000 5,00015 000/5,000 r000/3 000/5 000 "°' 20 000 C19-C36 Aliphatics 94 3 000/3 000/3,000 5,000/5 000/5,000 51100 0/5 000/5;000 2;500/5 000/5 000 20 000 s� - ' -3 -b � Cl1-C22 Aromatics 400 1 000/1000/1,000 1 000/3 000/3,000 1,000/5 000/5 000, 1000/3,00015 000 10 000 Target 2-Methylnaphthalene 2.4 0.7/80/300' 0:7/80/500' 0 7/80/5001 " "300%01500 1 A 5 000i Phenanthrene 1.9 10/500/500 10/1,000/1,000 f '10/3 000/3,000 500/1,000/3,000; 8 10 000 ". Acenaphthene 0.54 4/1,000/1,000 v4/33^,000/3 000 4/5 000/5,000 1,000/3,000/5 060 fix., 10.666, Fluorene 2.5 1,000/1000/1,000< 3;000/3,000/3;000` 5606/5 000%5,000 # 1,000/3 000/5,000 10 000 r_ / Pyrene <0.52 1,000/1,000/1,006 3 000/3 000/3;000 5,000/5,000/5,000 1;000/3 00015 000., °:;� 10,000 O- All Target Anal es BRL <0.52 >Ai/0 7/0.7- y, >_0 714/4,.�— ?0.7/301101 s'_ _ �0 7/4/30L_ TPH=Total Petroleum Hydrocarbons,EPH=Extractable Petroleum Hydrocarbons,PAH=Polynuclear Aromatic Hydrocarbons BRL=Below Reportable Limit,Shaded areas represent applicable MCP criteria. TABLE II: 293 SEA STREET-HYANNIS,MA SUMMARY OF VPH LABORATORY ANALYSIS-ENV.ASSESSMENT Exposure Point RESULTS S 1 SOIL STD.» S 2 SOIL STD S.3 SOII STD DDL CONTACT$1, UPPER CONC Location&Analyte (µg/g=ppm) a QL919 PPm) � (�g ,PPm)� (µFHB PPm)) t � �` 3 � � LIMITS a r310 CMR'' .8 y310 C R t"31 CMR '. 'k fi r e y (µP�BPPm) y 40 0975(6)(a); r40.0975(6)(a); 40 0975(6)(a)t 9310.CMR 40 0995(6) (depth below de surface 4.16.08,5.27.08 GW-11GV✓2/GW-3 �GW-1/GW 2/GW-31 GW°1/GW-2/GW 35 1/S-2/S-3 _ 3.10 CMR 40.0996 7VPH `. 100%100/100 ` 500/500/500 v 500/500/500' �1001,5001500 " 5 000,: C5-C8 Aliphatics BRL(<1.1) z -` a x F a ' 1000/1 000/1 000 3000/3 000/3,000 5 00015 00015,000 1-000/3 00015 000 20,009' C9-C12 Aliphatics BRL(<I.1) 100 0/0 1x 300/500/500 Y t 300/500/500 100/500/590 500 C9-C10 Aromatics BRL(<I.I) .:} t Target BTEX L 4/46/500 4/40/1 000 4/40/3 000 50011 000/3,000 10 000 Naphthalene <0.57 *� ; Xylenes(MixedLsomers) 0.11 `4007300/500> 4001300/1000. +¢400/300/3,000 500/1000/$000 10,OQ0 OCTOBER 24,2008 FUCCILLOBEA08-10044 PAGE 8 OF 13 RELEASE ABATEMENT MEASURE PLAN TABLE II: 293 SEA STREET-HYANNIS,MA SUMMARY OF VPH LABORATORY ANALYSIS-ENV.ASSESSMENT Exposure Point RESULTS S-1 SOIL STD. S-2 SOM STD. S-3 SOIL STD. DIIL CONTACT UPPER CONC:., Location&Analyte (µg/g=PPm) (gtg=PPm) •(µP/g=PPm) 01619-7pPm)' STDS? LIMITS' 310 CUR =310 CMR 310 CMR ( 40.0975(6)(a) 40.0975(6)(a) _ 40.0975(6)(a) 310 CMR40.0985(6)- (µ)g—ppm) (depth below grade surface) 4.16.08,5.27.08 6W-i/GW-2/GW-3 GW-1/GW-2/GW-3 GW-1/GWs2/6W-3' S-I&VSS-3 310 CMR 40.0996 7 >-2/30/30 �2/30/30 �2/300/900 2:30/200/900 >_9000-` All Other Targets BRL <O.11 == HB-5:8-10' VPH 100/100/100. 500/506/500 50015001500 100/500/500 5%000' C5-C8 Aliphatics BRL(<I.I) _ 1 000/1,000/1,000 3000/3,000/3,000 5;000/5 000/5,000 T,000/3,00015,000;" 20,000 C9-C12 Aliphatics 9.2 = - ;1 C9-CIO Aromatics 26 100/100/100 300/500/500 300%500/500 10015001500 5,000. Target BTEX 1. x - Naphthalene 1.5 4/40/500 4/40/1,000 4/40/3,000 500/1,000/3000 10,000 Xylenes(Mixed Isomers) 0.11 400/300/500 460/300/1,000 400/300/3,000 500/1 000/3,000 10,000 A >2/30/30 /200/200 >-2/300/900- >!30/200/900 >9000 az All Other Targets 0.11 — — e_.. - HB-5;(15-16');9-8-08 VPH CS CS Aliphatics BRL(<1 2) 100/100/100 ' 50615001500 50015001500• 1001500/600, 5,000 C9 C12 Aliphatics 20 1,000/1,000/1,000 3000/3,000/3,000 5,00015 00615,000 1,000/3,000/5,000, 20,000 100/100/100 300/500/500 300/500/500' 100/500/500 5,000 C9-C10 Aromatics 47 Target BTEXz Naphthalene 1.6 4/4060 0 4/40/1,000 4/40/3,000 s 500/1 000/3,000 10,000 R " Xylenes(Mixed Isomers) 0.11 400/300/500 400/300/1,000 400/300/3,000 500/1 000/3,000, 10,000 >_2/30/30 2!2/206/200 >2/300/900 >_30/200/910;_ >9.000 All Other Tar ets BRL TPH=Total Petroleum Hydrocarbons,VPH=Volatiles Petroleum Hydrocarbons,BTEX=Benzene/Toluene/Ethylbenzene/Xylene BRL=Below Reportable Limit,Shaded areas represent applicable MCP criteria. Groundwater BEA returned to the Site on September 25, 2008 to direct test borings and the installation of monitoring wells as performed by Jenkins Well Drilling of Brewster, MA [Refer to Site Plan]. Discrete soil sampling along the capillary fringe at the MW-1, MW-2 and MW-3 locations reported no TOV concentrations as consistent with background and indicating no significant groundwater impact in these wells. The monitoring wells were subsequently secured before BEA departed the Site. All soil samples were placed in the appropriate laboratory containers for potential EPHNPH and target analyte analyses and field preserved on ice. Based upon field screening results, no samples were submitted for laboratory analyses. BEA conducted monitoring well development, aquifer characterization and established top-of-casing elevations the same day. BEA personnel returned to the site on September 30, 2008 to re-gauge, purge and subsequently sample all three monitoring wells for laboratory analysis of total petroleum i OCTOBER 24,2008 FUCCILLOBEA08-10044 PAGE 9 OF 13 RELEASE ABATEMENT MEASURE PLAN hydrocarbons (TPH) as a cost savings measure to serve as an indicator for any environmental impact. The groundwater samples were collected in appropriately preserved laboratory containers and field preserved on ice. BEA personnel re-gauged groundwater elevations in all wells and confirmed top-of-casing elevations in order to qualify Site-specific groundwater flow direction as more westerly than suspected. Well gauging and static water level measurements at high and low tide indicate that there is no apparent tidal influence on groundwater beneath the site. At the time of this reporting, Site-specific groundwater flow appears to be westerly and as such only MW-2 is in a downgradient location as representative of potential downgradient groundwater impacts. However, due to the minimal spatial separation of these wells and the sensitivity of the measuring equipment wherein the difference in groundwater elevations between wells is 0.02', the need for an additional monitoring well will be further evaluated by additional groundwater gauging and the evaluation of groundwater flow variability. A proposed monitoring well location is shown at the back of the property as a contingency under the RAMP [Refer to Site Plan—Appendix A]. A series of rising-head slug tests were performed at monitoring well MW-3 to qualify hydraulic conductivity in review of aquifer characteristics and solute fate and transport mechanisms. The Geraghty and Miller AQTESOLV program was employed to interpret the results of the slug tests wherein a hydraulic conductivity of 38.31 feet per day was computed as consistent with the clean, medium to coarse sands encountered within the upper portion of the aquifer. Based on the calculated hydraulic conductivity and hydraulic gradients reported along specific groundwater flow vectors from MW-1 to MW-2 and MW-1 to MW-3, the groundwater velocity from the release area was reported as 0.12 ft/day. With a retardation factor of 10%, the Time of Travel from the release area to MW-2 would be 184 days [Refer to Computations in Appendix B]. Groundwater samples collected from all monitoring well locations reported TPH concentrations as BRL with reporting limits less than the applicable GW-3, Method 1 — Risk Characterization standards. As such, no groundwater impact is indicated at this time as subject to confirmation of monitoring well utility and data reliance as downgradient from the release area. The significance of these laboratory results is further discussed in the following Risk Characterization section of this report. RISK CHARACTERIZATION/IMMINENT HAZARDS [Refer to Appendix D] Soil As presented, the S-2 and S-3 (GW-3) soil categories are applicable to potentially accessible and isolated soils within the defined area of release under current Site conditions in consideration of exposures under Method 1 - Risk Characterization, as consistent with the provisions of 310 CMR 40.0933. For the purposes of risk characterization in consideration of foreseeable future uses, the most restrictive S-1 (GW-3), Method 1 - Risk Characterization standards are further considered relative to potential ingestion, inhalation and dermal contact i OCTOBER 24,2008 FUCCILLOBEA08-10044 PAGE 10 OF 13 RELEASE ABATEMENT MEASURE PLAN exposure risks to identified human and environmental receptors. Laboratory analysis has reported TPH concentrations as significantly greater than the applicable Method 1 — Risk Characterizations standards in a 8' x 6' x 4' (D) area (8-10' bgs) within the earthen crawl space under the footprint of the dwelling as driving the need for proposed soil removal and recycling as representing a potential significant risk to identified receptors. These concentrations further indicate the potential leaching of contaminants to groundwater. Laboratory testing of risk-based, fractional EPH/VPH data has further been used to qualify the vertical extent of significant soil impact and threat of groundwater impact wherein the most restrictive S-1/GW-3, Method 1 —Risk Characterization standards are met. Such testing at the HB-5 location reported fractional VPH/EPH and target analytes at concentrations less than the S-1/GW-3, Method 1 —Risk Characterization standards in the 8-10' and 15-16' bgs samples. This analysis indicates that residual soil impact in potentially accessible soils at a depth greater 10' bgs represents a condition of No Significant Risk. In the review of cost to benefit and risk, soil removal below 10' is practically infeasible. Excavation of soils below 10' bgs represents a disproportional cost, risk to workers and property damage without reduction in risk, wherein the most restrictive S-1/GW-3 standards are met. However, since low-level concentrations exist in soils beyond 16' bgs with groundwater projected within 25' bgs, there still could be a threat of groundwater impact and associated risks are being investigated. Groundwater As noted above,the GW-3 groundwater category is applicable in consideration of Method 1 - Risk Characterization at the Site as based on the NPDWA designation wherein ingestion exposures are not considered as a foreseeable exposure risk. Furthermore, based on the depth of groundwater, inhalation exposures from impacted groundwater area also not considered a foreseeable exposure risk. The GW-3 standards are developed in consideration of any significant environmental impacts and potential dermal contacts associated with impacted groundwater. The results of initial groundwater testing has reported no groundwater impact wherein TPH concentrations are reported as BRL and the reporting limit concentrations are significantly less than the GW-3, Method 1 — Risk Characterization standards. As such, a condition of No Significant Risk is apparent as requiring additional investigation of groundwater flow variation and solute transport to qualify potential exposure risks. Imminent/Substantial Hazard Evaluation Access to significantly impacted soils within the earthen crawl space is limited with the area capped by poly-sheeting and passive venting provided. As such, no ingestion or dermal contact exposures are complete. TOV monitoring of the living space reports no detectable organic vapors (0.1 ppmv) and no persistent petroleum odor is noted as indicating no significant inhalation exposures at the present time. As such, No Substantial or Imminent Hazards to the dwelling occupants or visitors is apparent under current conditions. I OCTOBER 24,2008 FUCCILLOBEA08-10044 PAGE 11 OF 13 RELEASE ABATEMENT MEASURE PLAN Furthermore, since the area of the release and defined Site are under the footprint of the dwelling, the area is not subject to rainfall infiltration and there is no additional leaching of contaminants to the groundwater. Available groundwater data from monitoring wells intermediate to defined environmental receptors indicated no groundwater impacts. Additionally, based on the hydrogeologic properties of solute transport and distance to potential environmental receptors, No Imminent or Substantial Hazard conditions related to environmental receptors appears to be present at the current time as to be qualified by future testing. RELEASE ABATEMENT MEASURE PLAN [Refer to Appendix E] The information from the assessment of current soil and groundwater conditions was used to develop a remedial strategy for the excavation of significant soil impact from the identified release area noted on the Site Plan. A licensed shoring contractor will install structural support for the interior partition and exterior wall of the crawl space area, in advance of excavation operations. The environmental contractor will then remove contaminated soils with via soil vactoring and direct load into the vactor truck. Personal protection and safety standards for BEA are specified in the Site Specific Health and Safety Plan (HASP) outlined in Appendix F. Site Contractors are required to adopt and monitor compliance with the HASP or prepare and implement their own Health and Safety Plan. BEA will inspect and document the removal of some 15-25 yards of contaminated soils from the projected area of soil removal as approximately 8' x 6' x 4' (D) [6' bgs to 10' bgs]. Field PID screening and Dexsil field-testing will be utilized as technical guidance in support of excavation operations. This material will be transported directly on an executed Bill of Lading to the Aggregate Industries facility in South Dennis, MA for asphalt recycling. At which point field screening indicates the effective removal of all significant soil impact; end-point samples will be collected and preserved for MA Certified analysis of EPH/PAH and VPH/BTEX in review of remedial response performance and risk characterization. TPH analysis may be used as a cost saving measure wherein field-testing indicates petroleum impacts are clearly absent. Upon the excavation and disposal of all significant impact as supported by laboratory analysis, a sub-slab venting system will be constructed and installed in the former area of significant impact. The venting system will be constructed of 4"perforated PVC pipe laterals, as set in washed stone along the bottom-of-hole area. A 4" solid piece of PVC riser will be plumbed to the lateral component, run outside the footprint of the building and connected to a wind turbine for the passive venting of residual petroleum volatiles outside the building. The venting system will also provide the flexibility to deliver remedial additives if necessary to mitigate potential residual impact in soils or to potentially treat groundwater if necessary. The SVE/Sub slab venting system can also be utilized to evaluate potential vapor entry into the occupied structure via Level 1, Soil Gas Screening. Such work will be compiled and reported in a RAM Status Report (RAMS) or RAM Completion Report (RAMC) within 120 days of this filing. OCTOBER 24,2008 FUCCILLOBEA08-10044 PAGE 12 OF 13 RELEASE ABATEMENT MEASURE PLAN As noted above, two rounds of monitoring well gauging have resulted in .similar calculated groundwater flow vectors with groundwater flowing northwesterly, bearing 295 degrees. These calculations support the necessity to install at least one additional monitoring well in the relatively inaccessible backyard or garage area. The need for this well will be evaluated by additional groundwater gauging and the well will be installed and tested accordingly. Each downgradient monitoring well will be sampled and analyzed for groundwater impact at least twice as consistent with the VPH/EPH Guidance Policy WSC-02-411. ENVIRONMENTAL MONITORING Subsequent to the completion of soil removal operations and end point soil analysis, BEA will monitor TOV concentrations within the dwelling and at the venting system riser in consideration of indoor air quality as consistent with the provisions of the VPH/EPH Guidance Policy WSC-02-411 and 310 CMR 40.0942. The reported TOV concentrations will be recorded in review of the potential for adverse impact to indoor air quality. Based on the historic nature of the release, groundwater monitoring will be conducted at least twice as indicated. EPH/VPH methods with target analytes will be utilized in downgradient wells. TPH analysis may be utilized in upgradient wells as a cost saving measure to screen for petroleum hydrocarbons impacts. During sampling events, all associated monitor wells will be gauged to confirm groundwater flow direction. Field measurements of groundwater elevations, olfactory and visual observations and the field-testing of pH, dissolved oxygen; conductivity and temperature will be reported on Monitoring Well Sampling Logs. Field inspections will be conducted and Inspectors Daily Record of Work Progress reports will be completed to document Site inspections and environmental monitoring as consistent with the QA/QC Policies of BEA outlined within Appendix E. CONCLUSIONS The Release Abatement Measure Plan, represented by this filing, will employ an aggressive soil removal strategy for the excavation and recycling of some 15-25 yards of significantly impacted soils from within the identified release area. Field PID screening and Dexsil Petroflag testing as performed by BEA personnel will direct excavation operations. This work will eliminate the contaminant source in all accessible and potentially accessible areas and facilitate the construction of appurtenances that can be utilized for additional treatment of residual hydrocarbons as may be necessary. The venting system will provide a preferential pathway for the removal of organic vapors from isolated soils and vent such vapors outside the subject building. In the future, the sub-slab system may also serve as a delivery system for remedial additives if necessary. It is our intent to proceed with the proposed remedial response activities immediately following the submittal of this report, as a real estate transfer is pending. The first RAM Status Report with proposed modifications will be submitted within 120 days of this filing. Subsequent OCTOBER 24,2008 FUCCI LLOBEA08-10044 PAGE 13 OF 13 RELEASE ABATEMENT MEASURE PLAN RAM Status Reports will be filed every six months thereafter until a preponderance of physical evidence supports a condition of"No Significant Risk" and Response Action Outcome (RAO) objectives are met as supporting a RAM Completion Statement. The findings of this investigation, as represented herein, set forth the rationale and technical justification for the LSP Opinions offered, as established by the certifications made on the attached Release Abatement Measure Transmittal Forms (BWSC-106). The LSP Opinions are based on available data and regulations in effect at the time of this reporting. Should the Department have any questions regarding this project, please contact our office at your earliest convenience. Sincerely, BENNETT ENVIRONMENTAL ASSOCIATES, INC. D id C. Be ett, LSP Brian Clarke, Geologist Principal Project Manager Encl: Supporting Documentation [Appendices A-F] cc: Lola Fuccillo -Property Owner Lieutenant Hubler- Hyannis Fire Department(Narrative,title page, site plan only) Thomas McKean- Barnstable Board of Health(Narrative, title page, site plan only) John Klimm- Barnstable Town Manager(Narrative, title page, site plan only) RELEASE ABATEMENT MEASURE PLAN SUPPORTING DOCUMENTATION RTN#4-21596 Private Residence 293 Sea Street—Hyannis, MA [Assessors Map 306, Parcel 78] OCTOBER 24,2008 Prepared For: MA DEPARTMENT OF ENVIRONMENTAL PROTECTION Southeast Regional Offices: Bureau of Waste Site Cleanup/Emergency Response Section 20 Riverside Drive -Lakeville, MA 02347 Prepared Byl BENNETT ENVIRONMENTAL ASSOCIATES, INC. 1573 Main Street- Brewster, MA 02631 David C. Bennett, LSP On Behalf Of: Lola J. Fuccillo Investment Trust 2424 Crowe Ridge Road—Winchester, KY 40391 APPENDIX A:Reference Plans -Figure 1: Site Locus Plan [USGS Topographic Quad.,Hyannis,MA. 1998] (excerpt) -Figure 2: Ground-Water Resources of Cape Cod,MA [LeBlanc et al, 1986] (excerpt) -Figure 3:MA DEP BWSC GIS Map [2008] - Site Plan entitled,"Release Abatement Measure Plan..."Prepared by BENNETT ENVIRONMENTAL ASSOCIATES, INC., dated October 12,2008. APPENDIX B: Field Reports -Field Response Log -Borehole Logs -Monitoring Well Sampling Logs Agtesoly and Time of Travel Calculations APPENDIX C: Environmental Records/Permits -Aggregate Industries Soil.Recycling Submittal(proposed) -BWSC-012A-C: Bill of Lading(proposed) -BWSC-103: Release Notification Form(submitted to secure RTN) -BWSC-106:Release Abatement Measure Transmittal Form w/eDEP Submittal Receipts and copy of compliance fee check APPENDIX D: Laboratory Analysis - Soil [GWA]: #119709(8-28-08); #119981/#120095 (9-9-08);#120091 (9-12-08) -Groundwater [GWA] (10-1-08,#120573) APPENDIX E: Quality Assurance/Quality Control Plan APPENDIX F: Health and Safety Plan No:... Fus....05.it 00........ THE COMMONWEALTH OF MASSACHUSETTS BOARD OF,- HEALTH - Town........OF.........Barnstable------------------------------------------------ ��° Appliration for Disposal Works Tonstrurtion Urrutit Application is hereby made for a Permit to Construct ( ) or Repair ( X) an Individual Sewage Disposal System at: 293...Bea...Streat.,...Hyannis,....Q26.01......... ----------------•-.............------................................... Location-Address or . No. CharlEs__Fras -•------------------------------------------------------ -2-q3...S.e a....5.tme.e t.r�-ya nnis.,...02 6Q1.---•---- Owner Address W _A_.&...B...0.eaagaol--.S ervice-------------------•----------... .128...Bishope--._Terrace,....li3ranni.s-r...II2b.01 a Installer Address Q Type of Building L Size Lot............................Sq. feet a Dwelling—No. of Bedrooms___...V--------------------------------- Expansion Attic ( ) Garbage Grinder ( ) p, Other—Type of Building ............................ No. of persons........._._..__...._ Showers ( ) — Cafeteria ( ) Q+ Other fixtures .......-.............................................................................................................................................. W Design Flow............................................gallons per person per day. Total daily flow--------------------------------------------gallons. WSeptic Tank—Liquid capacity............gallons Length................ Width---------------- Diameter---------------- Depth................ x Disposal Trench—No..................... Width.................... Total Length.................... Total leaching area....................sq. ft. Seepage Pit No--------------------- Diameter.................... Depth below inlet.................... Total leaching area..................sq. ft. Z Other Distribution box ( ) Dosing tank ( ) Percolation Test Results Performed by.......................................................................... Date........................................ aTest Pit No. 1................minutes per inch Depth of Test Pit.................... Depth to ground water-________----_---____. fi Test Pit No. 2................minutes per inch Depth of Test Pit.................... Depth to ground water........................ Ri .............................•••••-------••-•-•-••--•-------------•----•••--•-..............------.................•--------•--.....------............•-••-- 0 Description of Soil--------------------------Sand----------------------------------------------------------------------------- ----.---------•-------------------------_----- V ------------------------- •------------------------------ ---------------------- -......... -------------•---•-----•----------•-----•--•----•---- W ••-•-•-----------------------------------•-•----•--...-•------•..........---••-......-----•...................... -------------------••----•--•----••--•-••••••-----•--•-•••••---•------•-....--.------ UNature of Repairs or Alterations—Answer when applicable._._R tallatl D--_Of._.A-_-1 M..gal.1022_._. pre,!-cast.,...stane_...pac.kRd...leach...pit......................................................................................................... Agreement: The undersigned agrees to install the aforedescribed Individual Sewage Disposal System in accordance with the provisions of TITI. 5 of the State Sanitary Code—The undersigned further agrees not to place the system in operation until a Certificate of Compliance has been issued by the board of health. J Signed --L•-• --••......---•-.•........ •••-- _-----•--•-•-------- ........ /1`5�7�_._. ate Application Approved By------ .. ---•----- 1 ----------4- 1b/79---- Date Application Disapproved for the following reasons:..,............................................................................................................... ---------•------------------••----•-------•-------------------------••----•--------------------------------------•-•-••-•-------•--------------------------•------------------------------------------- Date PermitNo.....79.n-------------------------------------------- Issued--•------•-------41.1 ✓79..------......... Date THE COMMONWEALTH OF MASSACHUSETTS BOARD OF HEALTH ........................T.o.wn.....OF.......BsZ..rn ts�..�?.�.e.........-----............................... �rr#ifiratr of Tllmpliattrr THIS IS TO CERTIFY, That the Individual Sewage Disposal System constructed ( ) or Repaired (X ) by.A._&...B... ...Terrac-e_,...Hyannis.,...Ma..___02b01.......... Installer at---29.3.... ea--Btrse t,...Hyrannia-...---Ma..-----m---------.Charles...Fras_er-................................................. has been installed in accordance with the provisions of TITLE 5 of The State Sanitary Code as described in the application for Disposal Works Construction Permit No------Z_9_-_.._-�_.. ._....._. dated------- 1.7-9...................... THE ISSUANCE OF THIS CERTIFICATE SHALT. NOT BE CONSTRUED AS A GUARANTEE THAT THE - SYSTEM WILL FUNCTION SATISFACTORY. DATE............................•---------..........------------..............------ Inspector................................................................................... .f)0........ THE COMMONWEALTH*o� ASSACHUSETTS r' BOAR-D-'OF _H.EALTH' .. .. .....................-T.gvn........OF.-....-....Urnstab ------- '='- Ii4•. .4`ppIutttion for Utipaaal Workii Tonotrurtion thrmit Application is hereby made for a Permit to Construct ( ) or Repair ( X) an Individual Sewage Disposal System at 2.9re� , y�Aaia., 02601.._... ...- � e wa wL'o�a�;oq `Address or 1�No Y 3' Yf 2Q 3_._Se_�... tr�s t, �tenla..s _02` 01......... �di1.Ct.E w,-c az--_____Owner------___ - Address !- j;. e 2b�01 ° t i Installer Address d Type o $ulldmg y Size Lot_---- ---Sq. feet V ' o Expansion Attic ( ) Garbage GrmderUDw" hng, a,No f Bedrooms____ .__.._._ aOther Type of, Building _______. .___.... No. of persons____________________ Showers ( ) Cafetena ( ) Other fixtures ................................................. -------•--•-. W Design ylow� -,- -•-=--gallons per person"per day. Total daily flow____________________ #._._gallons. WSeptic jF,ank LiF iiid"capacity............gallons. Length-------------_ Width---------------- Diameter__._._: __ Depth_______.__._.-- -- Disposal Trench No...................... Width.....................Total Length_:_.__.__.__.__.____ Total leaching area___.. ...sq. ft. Seepage.,, No .. . `. Diameter.................... Depth below inlet_.______..__.__..... Total leaching area___ sq. ft. Z Other l fjrlbu"fioti bok ( ) Dosing tank ( )� Percolat ion�est�Results h. Performed by-----•--;------••--•-•......-----•---•••------•--•--....._-- •-•-•---_... Date••• . 41 u ,� Tesf Pft into. 1_................minutes per inch Depth of Test Pit.................... Depth to ground water .................... :..: (i, TesX Pit No.. 2________________minutes per inch Depth of Test Pit___.._._____________ Depth to ground water...,_.:.___.______.._... *• ,.. . f tion o Soil -_------- -Sand •...._-•--•-•-----•-------•--••----•---••-•••..-•••-•-••----••---. D Descrip --•••--••----•------•--•-•. _ ................. U ............... ---•=----•............... --------------- •------------------------------- V Nature,'bt Repairs or Alterations—Answer when applicable._._,TARtEL110L:t_i_o?n___4Z ___a___�.>r.00 ---gallon pre,..& ••.pack€ leaeh__Pit,+..............................................• = - Agreei5�nt b rk NF'j._ . • , - - The tmd'ersigned agrees to install the aforedescribed Individual Sewage Disposal System in accordance with the provisions of T 1 T LE 5 of the State Sanitary Code-The undersigned;further agrees not to place the system in operari n' until'a',Certificate of Compliance has been issued by th`board of health. t fr r , Signed_ _..-- .-_ "- - 4 :1_ o, Z7 r �f, , ate i. i Applic3 onL4APprdved By. •---=- -- --•---214....'!. 71.7.9.... r / ApphcatxonrDisapproved for the following reasons:....................................................................................f-__._Date.-----_---•- -.�n'p .{ }# - Date �Perinit No ,' � -------------------•----•---•-- Issued /171` A 5 d a i,Date" '•i, THE COMMONWEALTH OF MASSACHUSETTS �s+�af3 BOARD OF HEALTH 4r x .........TO ►A.....OF........$E bb.E........................................ �. 4.AG11a'+ t t # %Dir ifirFa#r of `TIOU"tolf anrr THIS IS:TO CERTIFY, That the Individual Sewage Disposal System constructed ( •) or Repaired (X ---Hi�_MObz---Ter�alc.�,---��tanx,.�,� A. ! i Inst Ilex' N u has beei,dhsiall,ed,iit accordance with the provisions of TTTLY: 5 of T.he State Sanitary Code as described in the application for Disposal Works Construction Permit No....... 9.!t._.77�_/ "----------- dated _.-_411-7/79 ................. Tk4XASS.UANCE..OF:THIS CERTIFICATE SHALL NOT BE CONSTRUED AS A GUARANTEE�THAT THE SYSTEK,14V.ILL':.FUNCTION SATISFACTORY. 8 DATE �z 4 L = Inspector _:. > rF 1 THE COMMONWEALTH OF MASSACHUSETTS �. BOARD OF HEALTH . ., ......................ToWn........OF.....Bi -natab e..._..._.......-_....._..__._........._.._---... 5. No FEE ... r.r �iu�ru�at� urk� �un��riun �erani� Per tsslon` Is.hereby..grantedA.. 'C._.B BQfi 001.. a?L' ` -G �--- 2�s . �iS?72fi____�`_eT";.,_ 1$IIIOis to Construct'( ) or Repair ( Y) an Individual Sewage Disposid System at No..2� �a t :�t..a..•.I_varlri98.,._. 2fC� , - - Gh&r1c�j9...rreSar... ---•- . ............. Street ' as shown on the application for Disposal Works Construction Po it g ..........._ Dated.__.__��17/?9 ...:.......... Board of Healtu/ r DATE.= --- .............................................. • FORM 1g5511 HOBBS=& WARREN, INC.. PUBLISHERS i I I 4r�` 1 . , 8'x 4'Concrete Slab Hyannis. Covered by Dirt MA Window PROPOSED AREA OF EXCAVATION REFERENCE Q 8'x G'x 4'(D)--1 O yds I _ Mortgage Inspection Plan Prepared by Yankee Sw[,ey Consultants, MW '7 Dated 12/29/00. H Mw-I e La ern HB-4 t �� �S6 D w LOCUS r. 6 /HI3 2 I HB�3 Crawl Space O Qow A so %CX HB-5 BENCHMARK: _ Top of Bottom Step ` ` J KEY M" 91- EL=30.0± (Assumed datum) LEGEND GtS o� HB HAND BORING5 �� e MW EX15TING MONITORING WELL MW-2 i 7 o�' MW PROP05ED MONITORING WELL DEPTH TO GROUNDWATER N l - � o J MW-3 DETAIL \\\" Existin G.14 0 10 20 30 Garage v SCALE I"= 1 O' p. Pri Existing T \` vot ryeage MW DM1'elbng PASSIVE WIND ("� •:'' - �:'�.'2`_. URBINE \ Mw-ILQ G.12S? we veNr 1 G.14 v srsreM avD PJSER _ G m 9PAC! .1 Cq} PRO.IEGIED ARPA OF 90R RPMOVAI IOY�M, va A 5 �i.{t ...- STETSON •:.AS`.Y Q_' n+:�'i. -?Se%IW FLOWAI3LC PILL SOIL VAPO PROBE STREET TI�EET P. WASHED 5TONG - R PLAN to , RL5IDUAL IMPACT IN /� B 9�DE ISOLATED WILD L>15'ba,,) 0 30 G V 0 90 Projecti. LOLA FUCCILLO INVESTMENT TRUST IS SCALE I"-30 2424 Crowe Ridge Winchester,KY40391 Title: RELEASE ABATEMENT MEASURE PLAN zo 293 Sea Street,Hyannis,MA BENNETT ENVIRONMENTAL E ASSOCIATES, INC. 2s �-zs bys± LICENSED SITE PROFESSIONALS,ENVIRONMENTAL SCIENTISTS GEOLOGIST,SANITARIANS 1573 MAIN STREET,P.O.BOX 1743,BREWSTER,MA 02361 PROFILE OF PROPOSED VENTING SYSTEM PHONE:(508)896-1706 www.bemett-ea.com FAX:(508)896-5109 DATE SCALE 113Y I CHECK I JOB NUMBER Schematic I i DPAWING:...AAJobs\Bennett Environmental\Fucallo\10044.RAMP 10/12/08 As Noted BWC/f IDCB 13EA08-10044 I ' i r 8'x 4'Concrete Slab REFERENCE Hyannis, Covered by Dirt MA Mortgage Inspection Plan Prepared by Yankee Survey Consultants, C�`a\� ti• Window PROPOSED AREA OF EXCAVATION nV Dated 12/29/00. 8'x G'x 4'(D)—10 yds A(G 2 so 9 29So 9 30 1 r' MW-I ® s.�S 88 hn h LOCUS Lantern 0 � (<ow Tqe i B 2 / HBt3 Crawl Space _ s0 HB-sue BENCHMARK: To of Bottom Ste `v 4 Gis ° ✓— ~J KEY MAP Iy F P P 91- EL=30.0± (Assumed datum) LEGEND L 7 c � HB HAND BORINGS D N w MW EXISTING MONITORING WELL MW 2 t c9 �_ _ DEPTH TO GROUNDWATER — 0 6, 1 1/19/08 ON � N i ' Nry e MW-3 CO r D ETA I L \ AREA Of C1A55 A-2 Existnne RESPONSE ACTION 10 20 30 Garag OUTCOME STATEMENT RTN 4-21 59G [•--35'L x 35'W1 SCALE I"= 10' :. Eyi5t,nq Prnvot 17ed Wellin \ 9 9 LQ G.41' � - _ G.3 n Nov 37 srsron AHD wsrx ��J,/��`/ CRAWL 9PAC! •.l .-;,•' .:• — a.H.�. Mr)�♦�i, NtPA OP 901ER OVR • J '. g �DW��FlLL T TSpN STREET WA9MW S N I RTN 4-21596 PLANi44+4ii#.#+4444' Io 4.4i#.+#._. ... Project: R IDUPLIMPACTW y LOLA FUCCILLO INVESTMENT TRUST L%OI TPD901L9p151 0 30 GO 90 2424 Crowe Ridge Road,Winchester,KY40391 5 5CALE 1"=30' Title: RELEASE ABATEMENT MEASURE COMPLETION WITH CLASS A-2 RESPONSE ACTION OUTCOME 293 Sea Street,Hyannis,MA 20 BENNETT ENVIRONMENTAL ASSOCIATES, INC. 29 25'byst LICENSED SITE PROFESSIONALS,ENVIRONMENTAL SCIENTISTS GEOLOGIST,SANITARIANS PROFILE OF SUB-SLAB VENTING SYSTEM i 1573 MAIN STREET,P.O.BOX 174.c BREWSTER,MA PHONE:(506 896-1706 www.bennett-ea.wm FAX: 508509)896.5109 Schematic i DATE : SCALE BY CHECK JOB NUMBER DRAWING:...AAJobs\Bennett Environmental\Fuccillo\l0044.RAMP.I2-17-08.dwg 12/17/08 As Noted BWC/f DCB BEA08-10044