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HomeMy WebLinkAbout0000 CAMP STREET - Health CAMP STREET . SHELL GAS STATION i • V E REIGN CONSU January 31,2017 Thomas A. McKean Town of Barnstable Public Health Division 200 Main Street Hyannis,Massachusetts 02601 John C. Klimm Barnstable Town Manager 387 Main Street Hyannis,Massachusetts 02601 Re:. Notice of Availability of Phase V Remedy Operation Status and Remedial Monitoring Report Former Shell-Branded Gasoline Station 381 Camp Street West Yarmouth, Massachusetts MassDEP RTN 4-1179 To Whom It May Concern: In accordance with the Massachusetts Contingency Plan (MCP) 310 CMR 40.1403 (3)(e), this correspondence serves as notification that a Phase V Remedy Operation Status and Remedial Monitoring Report (ROS-RMR) was submitted to the Massachusetts Department of Environmental Protection (MassDEP) for the above referenced location (the disposal site). The report summarizes activities conducted between July 2016 and January 2017. Continued activities on site will include: • Quarterly groundwater, gauging and sampling scheduled for January and April 2017;and, • Submittal of a ROS-RMR Status Report in July 2017. Copies of the report can be obtained at the Massachusetts Department of Environmental Protection Southeast'.Regional Office in Lakeville, Massachusetts. -If you have any questions please call the undersigned at(508) 339-3200. Sincerely, SOVEREIGN CONSULTING INC. Diann Ewanchuk Rachel B. Leary,PE,LSP Project Manager Senior Project Engineer cc: MassDEP SERO Annette Dokken,Motiva Sovereign File-2N774 16 Chestnut Street, Suite 520 • Foxborough, MA 02035 •Tel: 508-339-3200 • Fax: 508-339-3248 SOVEREIGN CONSULTING July 31,2017 Thomas A. McKean Town of Barnstable Public Health Division` 200 Main Street CID Hyannis,Massachusetts 02601 John C. Khmm Barnstable Town Manager 387 Main Street Hyannis, Massachusetts 02601 - - - Re: Notice of Availability of Phase V Remedy Operation Status and Remedial Monitoring Report ..„ ; Former Shell-Branded Gasoline Station 381 Camp Street West Yarmouth,Massachusetts MassDEP RTN 4-1179 i To Whom It May Concern: f In accordance with the Massachusetts Contingency Plan (MCP) 310 CMR,40.1403 (3)(e), this correspondence serves as notification that a Phase V Remedy Operation Status and Remedial Monitoring Report (ROS-RMR) was submitted to the Massachusetts Department of Environmental Protection (MassDEP) for the above referenced location (the disposal site). The report summarizes`activities conducted between January 2017 and July 2017.' t Continued activities on site will include: • Quarterly groundwater gauging and sampling scheduled for July and October 2017;and, • Submittal of a ROS-RMR Status Report in January 2018. Copies of the report can be obtained at the Massachusetts Department of Environmental Protection Southeast Regional Office in Lakeville, Massachusetts. If you have any questions please call the.undersigned at(508) 339-3200. Sincerely, In SOVEREIGN CONSULTING INC. Diann Ewanchuk s ti 4 Rachel B..Leary;PE,LSP Project Manager. :, Senior Project Engineer cc: MassDEP SERO Marc Oler,Equilon Enterprises LLC DBA Shell Oil Products US(Equilon) Sovereign File-2S774 16 Chestnut Street, Suite 520 • Foxborough, MA 02035 •Tel: 508-339-3200 • Fax: 508-339-3248 PERMANENT SOLUTION STATEMENT AND IMMEDIATE RESPONSE ACTION COMPLETION STATEMENT SUPPORTING DOCUMENTATION REPORT RTN: 4-26030 14 Iyannough Road W. Yarmouth, MA Prepared for: John Handel 59 Horseshoe Bend Way Masphee, MA 02649 Prepared by: Streamline Environmental Services 49 Hilton Avenue Woods Hole, MA 02543 Project 16ZAA STREAMLINE ENVIRONMENTAL SERVICES•49 Hilton Ave,Woods Hole,MA 02543 508.274.4228•sesolutionsl(aDcomcast.net•RTN:4-26030•PSS ARAC Report i sts.Jp TABLE OF CONTENTS 1 INTRODUCTION 1 2 BACKGROUND 1 3 RELEASE DISCOVERY, INITIAL RESPONSE AND MADEP NOTIFICATION 2 4 IMMEDIATE RESPONSE ACTION (IRA) 3 4.1 IRA Plan Oral Approval 3 4.2 Release Control, Containment and Mitigation Measures 3 4.3 Assessment 5 4.3.1 Soil and Groundwater Sampling Plan 5 4.3.1.1 Excavation Soil and Groundwater Sampling 5 4.3.1.2 Stockpile Soil sampling 7 4.3.2 Borehole Advancements and Well Installation 8 4.3.3 Excavation Soil Sampling 9 4.3.4 Stockpile Soil Sampling 10 4.3.5 Groundwater Sampling 10 4.3.6 Soil Analytical Results 11 4.3.7 Groundwater Analytical Results 12 4.3.8 Stockpile Analytical Results 12 4.4 Remediation Waste Management and Disposal 14 4.5 Electro-Magnetic Resistivity (EMR) Survey 15 5 CONCEPTUAL SITE MODEL 16 6 PROVISIONS FOR A PERMANENT SOLUTION 18 7 FEASIBILITY OF ACHIEVING BACKGROUND LEVELS OF OHM 18 8 RISK CHARACTERIZATION 18 8.1 Identification of Human Receptors 19 8.2 Identification of Environmental Receptors 19 8.3 Identification of Site Activities and Uses 19 8.4 Identification of Exposure Points 20 8.5 Identification of Exposure Pathways 20 8.6 Identification of Exposure Point Concentrations for Soil and Groundwater 20 8.7 Identification of Site Groundwater Categories 20 8.8 Identification of Site Soil Categories 20 9 CHARACTERIZATION OF RISK TO SAFETY 20 10 METHOD 1 RISK CHARACTERIZATION 21 STREAMLINE ENVIRONMENTAL SERVICES•RTN:4-26030•Permanent Solution 8 IRA Completion Report•141yannough Rd.,W.Yarmouth•Table of Contents f_..a;.` TABLE OF CONTENTS (continued) 11 DATA REPRESENTIVITY AND USABILITY ASSESSMENT 22 11.1 Data Usability Assessment 22 11.2 Data Representativeness Evaluation 22 11.2.1 Field Screening 22 11.2.2 Selection of Analytical Methods and Parameters 22 11.2.3 Selection, Number and Spatial Distribution of Sampling Locations 23 11.2.4 Temporal Distribution of Samples 23 11.2.5 Critical Samples 23 11.2.6 Completeness 24 11.2.7 Inconsistency, Uncertainty and Unused Data 24 11.2.8 Representativeness Summary 24 12 SUMMARY 24 CONSTRAINTS TABLES Table 1: SUMMARY Of SOIL PHOTIONIZATION DETECTOR MEASUREMENTS Table 2: SUMMARY OF WATER QUALITY INDICATOR MEASUREMENTS Table 3: SUMMARY OF LABORATORY SOIL ANALYSES Table 4: SUMMARY OF LABORATORY GROUNDWATER ANALYSES FIGURES Figure 1: TOPOGRAPHIC LOCUS OF DISPOSAL SITE Figure 2: DISPOSAL SITE BASEMAP SHOWING RELEVANT IMMEDIATE RESPONSE ACTION FEATURES INSET"A FROM DISPOSAL SITE BASEMAP SHOWING RELEVANT Figure 3: IMMEDIATE RESPONSE ACTION FEATURES Figure 4: DISPOSAL SITE MAP SHOWING ELECTRO-MAGNETIC RESISTIVITY SURVEY CONTOURS APPENDICES Appendix A: IRA PICTURES Appendix B: IRA WASTE MANIFEST DOCUMENTS Appendix B: BORING LOGS Appendix C: SOIL AND GROUNDWATER LABORATORY REPORTS Appendix D: BOURNE(LANDFILL)SOIL REUSE SUBMITTAL STREAMLINE ENVIRONMENTAL SERVICES•RTN:4.26030•Permanent Solution&IRA Completion Report•141yannough Rd., W.Yarmouth•Table of Contents a stS �g 1 INTRODUCTION In accordance with the Massachusetts Contingency Plan (MCP 40.0000, the "MCP"), Streamline Environmental Services (Streamline) has prepared the following Permanent Solution Statement and Immediate Response Action Completion Statement Supporting Documentation Report (the "Report") to document activities which have resulted in achieving a Permanent Solution with no conditions and reaching a level of No Significant Risk relative to the disposal site located at 14 lyannough Rd, West Yarmouth, Massachusetts (the "Site"). The Site has been issued the Release. Tracking Number (RTN) 4-26030 due to the documented sudden release (the "Release") of petroleum hydrocarbons and the impact to a storm drain. This report was prepared on behalf of Mr. John Handel (the "Client" and Potentially Responsible Party "PRP"),Trustee for the owner of the Site, Main Street Trust. .2 BACKGROUND The Site has a Northern latitude of 41.65773 and Western longitude of-70.26976. The Site is located within a highly commercialized area along the north side of Route 28 in West Yarmouth, approximately 250 feet east of the border of the Town of Barnstable. The Site includes an automobile service station (Dan's Tire) and a Recreation Vehicle sales center (MDC RV Center). Abutting the Site are the following: 1) Route 28 / lyannough Road, then a gasoline dispensing station and convenience store (Speedway) and Dunkin Donuts to the south; 2) A medical outpatient diagnostics facility(Shields MRI)to the west; and, 3) A small strip mall to the east containing a barber shop (Richard & Son), wireless retail store (Cricket Wireless) and The Sign Shop of Cape Cod. The Site is located approximately 1/4-mile from three (3) municipal wells serving the Town of Barnstable, Massachusetts. The Site is located within Zone II for these public water supply wells, and is adjacent to a wetland which is hydrologically connected to the northwestern upper reach of Mill.Pond, the primary recharge area for the municipal wells. The Site is located -on Cape Cod, so it is part of the Cape Cod designated sole source aquifer. Groundwater beneath the Site is characterized as a Potentially Productive Aquifer (PPA). The soil associated with the PPA consists of highly transmissive sand and gravel deposits. Based on over one hundred (100) soil borings conducted across the Site from former MCP remediation work, in conjunction with the IRA conducted, soil persistently consists of low to moderately conductive, gap-graded, sandy silt backfill ranging from land surface (below asphalt) to_four (4) to seven (7) feet below land surface across the Site. The sandy silt surficial layer abruptly grades into an underlying peat layer which ranges in thickness from approximately six (6) to eight (8) feet. The highly permeable sand and gravel zone begins sharply where the peat layers ends. STREAMLINE ENVIRONMENTAL SERVICES• RTN:4.26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 1 of 26 SES Refer to Figures 1 and 2 for the Property locus on the USGS quadrangle and Basemap of the Site, respectively. 3 RELEASE DISCOVERY, INITIAL RESPONSE AND MADEP NOTIFICATION On the morning of 14 March 2016, at approximately 10:00 AM, reportedly, during excavation activities associated with the routine repair of a municipal water line by Town of Yarmouth Department of Public Works personnel, a buried, crumpled, metal drum was encountered. The drum was located next to the water line, under repair. While moving the metal drum, a black oily substance was suddenly released (the "Release") within the excavation soil, and on the groundwater. Subsequently, the metal drum was immediately exhumed and placed on the asphalt next to the excavation.-Additional soil was then removed and stockpiled near the excavation, next to the metal drum. At this point, the excavation was terminated. The excavation for the repair of the water line was located on the north side of Route 28/lyannough Road, adjacent to the southeast corner of the Site property line. The dimensions of the final excavation measured approximately 15 feet long by 6 feet wide by 5 feet deep (161 x 6'W x 5'D), with approximately 15 cubic yards of stockpiled soil generated therefrom. The Release impacted the excavation sidewalls and groundwater within the excavation. The groundwater within the excavation was representative of the local water table and located approximately two (2)feet from ground surface. The Town of, Yarmouth Fire and Health Departments, and the Massachusetts Department of Transportation (MassDOT) were contacted. Following their arrival to the Site, the Town of Yarmouth-Fire Department deployed absorbent booms and pads on top of the groundwater within the excavation, and absorbent booms within the nearest storm drain, as well as, several bags of absorbent granular media around the stockpile to collectively mitigate migration of the Release. Due to excess water generated from gravity drainage of wet soil exhumed during the excavation, a temporally diminishing amount of emulsified oily substance co-advanced with the drainage water. Collectively, the mixture of water and emulsified oil flowed along the drainage swale of,the northern shoulder of Route 28 to the first storm drain located.approximately two hundred and twenty (220) feet from the Release source. The storm drain is located in front of the roadway entrance to the business,Shields MRI. At 11:21 AM, on 14 March 2016, Mass DOT representative Thomas Burnett contacted and reported the Release to the Massachusetts Department of Environmental Protection (MADEP), Southeast Regional Office (SERO). Because the Release was estimated by MADEP personnel to "likely exceed" 10 gallons, pursuant to the MCP, the Release was therefore a "reportable quantity". As such, obligatory notification to MADEP was required. Further, since conditions of the Release were "sudden" in nature and had demonstrated impact to a storm drain, a "Two-Hour" notification. under the MCP was triggered. Consequently, using the Bureau of Waste Site Cleanup (BWSC) transmittal form BWSC-101, the Release Tracking Number (RTN): 4-26030 was assigned to the Release by MADEP, t, STREAMLINE ENVIRONMENTAL SERVICES RTN:4.26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA page 2 of 26 Sts J Refer to Appendix A for IRA pictures 4 IMMEDIATE RESPONSE ACTION (IRA)—Refer to Figure 3 Pursuant to 310 CMR 40.0412, sites where an IRA is required include sites or vessels where a release or threat of release of oil and/or hazardous material has occurred which require notification to the Department under the "Two Hour" notification provisions. Consequently, an IRA became a regulatory requirement to address the Release. Specifically, in accordance with 310 CMR 40.0414, the purposes of the IRA are to 1) at a minimum, involve the assessment of the release or threat, 2) most likely require the initiation of one or more containment or removal actions, 3) eliminate, prevent and/or mitigate Critical Exposure Pathways (CEPs) from impact to a release, and, 4) prevent impact(s) to public water supplies at sites where such impact is likely to occur within an extended period of time, such as the time period that is required for the implementation and/or completion of Comprehensive Response Actions. 4.1 IRA Plan Oral Approval By around 12:30, on 14 March 2016, MADEP field officer Robert Murphy arrived at the Site and assessed the conditions of the Release. At this time, being aware of the regulatory need to conduct IRAs relative to the Release, on behalf of the PRP, Streamline personnel engaged Mr. Murphy to discuss, develop and, in a timely manner, effect the components of a required IRA. In discussions with Mr. Murphy, it was agreed that because a Licensed Site Professional (LSP) was imminently being retained, a preliminary oral IRA Plan was developed by Mr. Murphy and acknowledged by Streamline in order effect more expeditious response actions. Consequently,in satisfaction of 310 CMR 40.0420 (3) and (7), the following IRA Plan components were eventually agreed upon between Robert Murphy and the LSP: 1) apply absorbent medias to impacted areas; 2) remove up to 20 cubic yards of remediation waste; 3) dispose of up to 5,000 gallons of oily water; 4) clean out the storm drain; and, 5) conduct assessment work. 4.2 Release Control, Containment and Mitigation Measures In response to the Release, on the same day of the Release, 14 March 2016, at approximately 2:30 PM, Clean Harbors, Inc. (Clean Harbors) arrived at the Site to carry out additional IRA Plan elements. When Clean Harbors arrived, in order to mitigate migration of the Release, initial response actions had already included: 1) covering the stockpiled soil with plastic sheeting and clean sand to hold down the sides, 2) spreading approximately thirty (30) bags of granular absorbent material around the pavement surrounding excavation, and topographically downgradient thereto, leading to the STREAMLINE ENVIRONMENTAL SERVICES•RTN:4-26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 3 of 26 ES \_ impacted storm drain, 3) placing absorbent booms and pads on groundwater within the open excavation, 4) placing absorbent booms in: the storm drain directly impacted, the nearby lateral storm drain which the impacted storm drain flows into and surrounding the outfall area of the culvert which the said storm drains discharge into. In order to further mitigate potential migration of the Release and remove impacted soil, groundwater and absorbent granular and synthetic material medias, Clean Harbors personnel employed the use of a Vactor Truck to suction the following to the holding tank of the Vactor Truck for subsequent disposal: 1) Several hundred gallons of groundwater and all floating and emulsified oily products within the excavation, along with all floating absorbent pads and booms; 2) For all intent and purposes, essentially all the absorbent granular media spread on the ground along with any soil located below the granular media; 3) Several hundred gallons of storm water and previously placed absorbent booms from the directly impacted drain holding tank and from within the paired storm drains,,proximally located to the impacted storm drain in which the directly impacted storm drain discharged thereto; and, 4) Soil/sediments from within the impacted storm drain. Following transference of impacted medias to the Vactor Truck from all areas outside the excavation, Clean Harbors deployed new booms to all storms drains herein referred, and to the outfall pipe discharge of the storm drains. After .completion of the site work, Clean Harbors reportedly transported the collected medias (absorbents, groundwater and soil) off-site to their Braintree facility for temporary storage under a Uniform Hazard Waste Manifest document for non- hazardous, non-DOT regulated, sediments and water. Refer to Appendix B for a copy of Waste Manifest documents. Following the completion of transferring oily surficial water and pads and booms from the excavation to`the Vactor Truck, the Town of Yarmouth Department of Public , Works backfilled the excavation with clean, gap-graded, sand. ' There was no sheen was ever observed discharging from the outfall pipe discharge of the storm drains. Refer to Appendix A for pictures of IRA activities. STREAMLINE ENVIRONMENTAL SERVICES•RTN:4.26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 4 of 26 /'• � ( SEs l) 4.3 Assessment - refer to Figure 3 Following aggressive response action impacted medias control, containment and removal measures, a confirmatory sampling plan was developed to assess the effect of all initial response actions conducted on the same day as the Release. 4.3.1 Soil and Groundwater Sampling Plan Based on visual and olfactory evidence of the impacted medias acquired during the initial response, in conjunction with the known current and former history of the Site, as well as, the well-documented previous widespread release (MADEP RTN: 4-15369) of non-point source waste oil and lubricating oils, a groundwater and soil sampling plan was developed with the focus of targeting analytes associated with fuel-based hydrocarbons, the estimated constituents of concern (COCs). Further, waste characterization parameters, which would be necessary to subsequently enable off-site disposal of the apparently, oil- impacted stockpiled soil, would also be analytically evaluated for the same COCs as the in-situ medias, for whence they came. 4.3.1.1 Excavation Soil and Groundwater Sampling The first set of soil borings were chosen to intercept the four (4) midpoints of the four (4) sidewalls of the excavation. Borehole completion depth was chosen to terminate at four (4) below grade since the bottom of the excavation was approximately five (5) feet below grade and the Release source was approximately located at two (2) to four (4) below grade. Further, the local water table varies from approximately (2) to four (4) feet below grade. These depths are expected to be representative of the soil and groundwater environment laterally located next to the Release source based on the mobility of the COCs. The fifth borehole was chosen to be advanced ,in the location of the removed drum to a minimum depth of 8.0 feet below ground surface, approximately 3.0 feet below the bottom of the excavation. This location was chosen to enable the subsequent installation of a temporary monitoring well screen to straddle the average water table elevation of approximately 3.0 feet below grade, and, to profile the soil and groundwater quality directly in the area of the removed drum. STREAMLINE ENVIRONMENTAL SERVICES•RTN:4.26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 5 of 26 is During advancement of all excavation boreholes, until the termination depth of the boring, at two (2) foot intervals, two soil samples would be retained. One of the samples would be collected and field screened pursuant to MADEP Underground Injection Control (UIC), Jar Headspace Analytical Screening Procedure, while the other sample would be retained for potential laboratory submission of non-volatile analytes. Should Photoionization Detector (PID) Total Organic Vapor (TOV) readings reveal levels not significantly different from other PID levels in other borehole soil samples, these samples would be then be composited for laboratory submission of a variety of semi-volatile compounds, metals and polychlorinated biphenyls (PCBs). Should a significantly higher PID value yield from these field screenings, a separate grab sample would then be laboratory submitted for a variety of semi- volatile compounds, metals and PCBs. The PID would be calibrated in the field. Following PID screening of all borehole soil samples, the sample location depth demonstrating the highest PID value would be laboratory submitted for a variety of volatile compounds. To minimize volatilization, this sample would be collected by re-advancing the auger to the desired depth in the appropriate borehole location and collecting a new soil sample. Groundwater samples would be collected from the temporary monitoring well and laboratory submitted for a host of semi-volatile, volatile, dissolved metal and PCB compounds. The monitoring well would be purged and sampled for non-volatile compounds following guidelines from Environmental Protection Agency (EPA) Low Stress (Low Flow) Purging and Sampling Procedure. Groundwater samples collected for laboratory submission of volatile compounds will be obtained using a dedicated bailer. The water quality probe used in connection with Low Flow sampling method would be calibrated for each parameter prior to using it in the field. • I The following analytical parameters were chosen to evaluate soil and groundwater quality as a result of the initial response actions based on the identified COCs: Soil Analyses: GC/MS Volatiles.(SW846 8260C); GC Volatiles (MADEP VPH REV 1.1); STREAMLINE ENVIRONMENTAL SERVICES•RTN:4.26030 Permanent Solution&IRA Completion Report•141yannough Rd.,W.Yarmouth•MA• page 6 of 26 GC Semi-volatiles (MADEP EPH REV 1.1); GC Semi-volatiles (SW846 8082A); and, MA 14 Metals By Method SW846 6010C. Groundwater: GC/MS Volatiles (SW846 8260C); GC Volatiles (MADEP VPH REV 1.1); GC/MS Semi-volatiles (SW846 8270D); GC Semi-volatiles (MADEP EPH REV 1.1); GC Semi-volatiles (SW846 8082A); and, MA 14 Metals By Method SW846 6010C. 4.3.1.2 Stockpile Soil Sampling Stockpile soil sampling for non-volatile compounds analyses would be conducted by advancing four (4) soil borings located approximately equidistant across the prism-shaped surface area of the stockpile to a depth of approximately two (2) feet below the soil surface, half-way between the surface and`the below lying asphalt. Following, these samples would be composited and laboratory submitted for analyses. Stockpile soil sampling for volatile compounds analyses would be conducted by advancing one (1) soil boring approximately two (2) feet below the surface of the stockpile at a position approximately midway across the long axis of the top of the prism-shaped stockpile and equidistant between the shorter boundaries of the stockpile axes. Following, two (2) samples would be collected. One (1) sample would be field screened using UIC, Jar Headspace Analytical Screening Procedure, while the other sample would be retained for subsequent laboratory submission of volatile compounds analyses. The following analytical parameters were chosen to evaluate stockpiled soil quality based on the analytical needs of two (2) different soil reuse and recycling facilities: y i Soil Analyses: STREAMLINE ENVIRONMENTAL SERVICES• RTN:4-26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 7 of 26 "DES-11 GC/MS Volatiles (SW846 8260C); GC/MS Semi-volatiles (SW846 8270D); GC Volatiles (MADEP VPH REV 1.1); GC Semi-volatiles (MADEP EPH REV 1.1); GC Semi-volatiles (SW846 8082A); MA 14 Metals By Method SW846 6010C; Corrosivity as pH; Cyanide Reactivity; Ignitability (Flashpoint); Specific Conductivity; and, Sulfide Reactivity. 4.3.2 Borehole Advancements and Well Installation On Sunday, 3 April 2016, following the acquisition and confirmation of a Dig-Safe number (2016-120-9601) and markings, respectively, Streamline personnel advanced a total of five (5) test borings around and within the former excavation where the metal drum was discovered. To advance each borehole, a 3 and %-inch diameter hand-auger was manually advanced through the subsurface to each desired completion depth. Four (4) test borings (TB-101, TB- 102, TB-103 and TB-104) were advanced to a completion depth of four (4) feet below ground surface. One more test boring, TB-105, was advanced in the former area of the discovered drum to a completion depth of approximately seven (7) feet below ground surface. At borehole TB-105, following completion of the advancement of the auger to approximately seven (7) feet below grade, or, approximately two (2) feet below the bottom of the excavation, a ten (10) foot section of a 10-slot (0.010-inch), stainless steel, continuously wrapped, 2-inch diameter well screen with a welded drive point was placed into the borehole and driven to a completion depth of approximately 8.5 feet below ground surface. This well was identified as TMW-101. During advancement, soil samples were collected at two (2) foot intervals until the completion depth was reached. Each soil sample was field screened STREAMLINE ENVIRONMENTAL SERVICES RTN:4.26030 Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 8 of 26 ES I using UIC,.Jar Headspace Analytical Screening Procedure. The rental PID was received with a receipt indicating recent calibration. The PID was calibrated once in the middle of said screening events. At each borehole location, soil samples were classified following the Burmister Soil Classification System. Borehole soil and construction logs were prepared for each these borings. Between each sampling location, the hand- auger was cleaned and rinsed at least twice using a soapy solution and distilled water, respectively. Soil encountered in boreholes TB-101 to TB-104 consisted primarily of various sand fractions, little gravel, and trace silt and small cobbles. These borings were advanced to a completion depth of four (4) feet below ground surface. Soil encountered in TB-105 consisted of a similar soil type as encountered in TB-101—TB-104. However, at approximately 6.0—6.5 feet below grade, a peaty layer was encountered. This boring was completed as temporary monitoring well TMW-101. Based on several dozens of borings advanced across the entire Site, the depth of the peaty layer is consistent with the ubiquitous nature of the peat which underlies 14 lyannough Road. Refer to Appendix C for soil boring logs and Table 1 for a summary of PID measurements. 4.3.3 Excavation Soil Sampling On Sunday, 3 April 2016, following the advancement of all test borings relative to the former excavation, in conjunction with the review of relevant PID measurements, Streamline personnel began collecting confirmatory soil samples to evaluate extant soil quality of in-situ soil. Composited soil samples were obtained from each borehole termination depth and distributed into laboratory supplied sample containers. Subsequently, the samples were put them into a cooler with ice until submission to a state- certified laboratory for GC Semi-volatiles (MADEP EPH REV 1.1); GC Semi- volatiles (SW846 8082A); and, MA 14 Metals By Method SW846 6010C. Composited samples Were obtained by combining soil from four.(4) feet below grade from TB-101 through TB-104, and, from six (6) feet below grade from TB- 105. These soil samples were composited due to the fact that there was no significant difference in PID values from all borehole measurements. These soil samples were labeled "TB-101-C". Streamline personnel collected two (2) grab samples from six (6) feet below grade in TB-105 and put each into laboratory supplied sample containers. STREAMLINE ENVIRONMENTAL SERVICES•RTN:4-26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 9 of 26 ���ES�)) �% Subsequently, the samples were put them into a cooler with ice until submission to a state-certified laboratory for GC/MS Volatiles (SW846 8260C) and GC Volatiles (MADEP VPH REV 1.1). This soil sample location was chosen due to the fact that it yielded the highest PID measurement, 1.2 parts per million by volume (ppmV) of Total Organic Vapors (TOVs), and was closest in proximity to the discovered drum.These soil samples were labeled "TB-105-6". 4.3.4 Stockpile Soil Sampling On Sunday, 3 April 2016, using a hand-auger, Streamline collected confirmatory waste characterization soil samples to evaluate the extant soil quality of stockpiled soil. Composited soil samples were obtained from each borehole termination depth and distributed into laboratory supplied sample containers. Subsequently, the samples were put them into a cooler with ice until submission to a state- certified laboratory for GC/MS Semi-volatiles (SW846 8270D); GC Semi-volatiles (MADE.P EPH REV 1.1); GC Semi-volatiles (SW846 8082A); MA 14 Metals By Method SW846 6010C; Corrosivity as pH; Cyanide Reactivity; Ignitability (Flashpoint); Specific Conductivity; and, Sulfide Reactivity. Composited samples were obtained by combining soil from four (4) samples locations, approximately equidistantly spaced, at two (2) feet below the surface area of the stockpile. These soil samples were labeled "SP-101-C". Two (2) grab samples were obtained from one location at two (2) feet below the top and center of the stockpile and put each into laboratory supplied sample containers. Subsequently, the samples were put them into a cooler with ice until submission to a state-certified laboratory for GC/MS Volatiles (SW846 8260C) and GC Volatiles (MADEP.VPH REV 1.1). These soil samples were labeled "SP-10171". 4.3.5 Groundwater Sampling On Sunday, 3 April 2016, following the installation of temporary monitoring well TMW-101 (section 4.3.2, IRA: Borehole Advancements and Well Installation), Streamline collected confirmatory groundwater samples to evaluate groundwater quality within the former excavation. In order to better obtain a representative groundwater sample, Streamline employed EPA Low Stress (Low Flow) Purging and Sampling Procedures. Prior to the retention of groundwater samples, the well was purged of approximately 4 times the amount of standing water within the well screen. A STREAMLINE ENVIRONMENTAL SERVICES RTN:4.26.030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 10 of 26 ( (sEs' peristaltic pump, silicon tubing and %-inch outside diameter polyethylene tubing were used to purge groundwater for, approximately 90 minutes, at approximately 165 mL/min (approximately 3.93 gallons), prior to commencement of field screening for groundwater quality parameters. Subsequently, a flow cell was connected in-line with the discharge of the peristaltic pump to record the following groundwater quality parameters: Dissolved Oxygen, Oxidation-Reduction Potential, pH, Temperature, Conductivity and Depth to Water. After approximately thirty (30) minutes of screening for the indicated water quality parameters, they stabilized within acceptable criteria. Subsequently, the flow cell was disconnected from the discharge of the peristaltic pump and discharged groundwater was then distributed into laboratory supplied sample containers for non—volatile compounds analyses. Subsequently, the samples were put them into a cooler with ice until submission to a state-certified laboratory for GC/MS Semi-volatiles (SW846 8270D); GC Semi-volatiles (MADEP EPH REV 1.1); GC Semi-volatiles (SW846 8082A); and, MA 14 Metals By Method SW846 6010C.These samples were labeled "TMW-101 Following completion of the collection of the non-volatile compounds analyses, Streamline installed a dedicated bailer into the well and purged groundwater therefrom and decanted it into laboratory supplied sample containers. Subsequently, the samples were put them into a cooler with ice until submission to a state-certified laboratory.for GC/MS Volatiles (SW846 8260C) and GC Volatiles (MADEP VPH REV 1.1). These groundwater samples were also labeled "TMW-101". Refer to Table 2 for a summary of water quality indicator measurements. 4.3.6 Soil Analytical Results Upon review of the laboratory results from the submitted confirmatory excavation soil samples, it is noteworthy that the only organic compounds detected were at relatively low levels of longer-chain hydrocarbons, consistent with waste oil by-products, the COCs of the Release. Organic compounds detected in TB-101-C were C19-C36 Aliphatics at 41.6 mg/Kg and C11-C22 Aromatics at 65.2 mg/Kg. Inorganic compounds detected (metals) were Arsenic at 1.3 mg/Kg, Barium at 5.8 mg/Kg, Chromium at 4.8 mg/Kg, Lead at 4.9 mg/Kg, Vanadium at 5.8 mg/Kg and Zinc at 13.6 mg/Kg. The low level detection of Acetone in TB-101-1 in the Volatile Organic Compounds analytical results is inconsistent with the other suite of analytes STREAMLINE ENVIRONMENTAL SERVICES•RTN:4.26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 11 of 26 ES ) detected. However, more importantly, the detected presence of the low level of acetone is a consistent by-product with low detection limits employed when Sodium Bisulphate is used as a preservative for soil samples, as was the case for this sample. The detected concentrations of all soil analytes fall well below the site- specific MCP Reportable Concentration soil category of S-1 (RCS-1). Refer to Table 3 for a summary of laboratory soil reports and Appendix D for a copy of laboratory reports. 4.3.7 Groundwater Analytical Results Upon review of the laboratory results from the submitted confirmatory excavation groundwater samples, it is noteworthy that only organic volatile compounds were detected at relatively low levels, consistent with oil by- products. This statement is consistent with the type of release which has apparently occurred. The Release was "sudden", which suggests that oil product released to the groundwater had very little time to dissolve since IRA activities recovered and pumped out excavation groundwater within a few hours after the release occurred. Consequently, due to the 'nature of the lower solubilities associated with longer chain hydrocarbons/those associated with the Release COCs, there was not much time for dissolution of the heavy weight hydrocarbons (waste oil COCs) to occur. Dissolved volatile organic compounds detected in TMW-101-1 were Total Xylenes at 1.2 ug/L and C9-C10 Aromatics at 55.6 ug/L. The only inorganic dissolved metal detected was Zinc at 63.1 ug/L. There were no detected levels of any semi-volatile organic compounds in TMW-101. The detected concentrations of all groundwater analytes fall well below the site-specific MCP Reportable Concentration groundwater category of GW-1 (RCGW-1). Refer to Table 4 for a summary of laboratory groundwater reports and Appendix D for a copy of laboratory reports. 4.3.8 Stockpile Analytical Results Upon review of the laboratory results from the submitted stockpile soil samples, it is,noteworthy that the predominantly organic compounds detected were at relatively low levels of longer-chain hydrocarbons, consistent with waste oil by-products,the COCs of the Release. STREAMLINE ENVIRONMENTAL SERVICES• RTN:4.26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 12 of 26 (ES Semi-volatile compounds detected in stockpile sample SP-101-C were the following: C9-C18 Aliphatics at 208 mg/Kg; C19-C36 Aliphatics at 2,960 mg/Kg; C11-C22 Aromatics at 1,810 mg/Kg; Total Petroleum Hydrocarbons (TPH) as Diesel Range Organics (DROs) at 2,800 mg/Kg; Benzo(a)a nth race ne at 0.204 mg/Kg; Benzo(a)pyrene at 0.268 mg/Kg; Benzo(b)fluoranthene at 0.218 mg/Kg; Benzo(g,h,i)perylene at 0.252 mg/Kg; Benzo(k)fluoranthene,at 0.189 mg/Kg; Chrysene at 0.526 mg/Kg; Fluoranthene at 0.315 mg/Kg; Indeno(1,2,3-cd)pyrene at 0.189 mg/Kg; and, Pyrene at 0.621 mg/Kg. Volatile compounds detected in stockpile sample SP-101-1 were the following: C9-00 Aromatics (Unadjusted) at 113 mg/Kg; C5-C8 Aliphatics at 7.42 mg/Kg; C9-C12 Aliphatics at 65.9 mg/Kg; Acetone at 0.0202 mg/Kg; n- Butylbenzene at 0.006 mg/Kg; p-Isopropyltoluene at 0.0045 mg/Kg; 1,2,4- Tri methyl benzene at 0.0059 mg/Kg; and, 1,3,5-Tri methyl benzene at 0.0057 mg/Kg. Metals detected in stockpile sample SP-101-C were the following: Arsenic at 1.5 mg/Kg; Chromium at 3.3 mg/Kg; and, Lead at 50.7 mg/Kg. The low level detection of Acetone in SP-101=1 in the Volatile.Organic Compounds analytical results is inconsistent with the other suite of analytes detected. However, more importantly, the detected presence of the low level of acetone is a consistent by-product with low detection limits employed when Sodium Bisulphate is used as a preservative for soil samples, as was the case for this sample. General chemistry waste characterization parameters detected in stockpile sample SP-101-C were as follows: pH at 7.3 units; Ignitability (Flashpoint) at 2300 Fahrenheit (F); and, Specific Conductivity at 148 umhos/cm. The detected concentrations of all soil analytes fall below the site-specific MCP Reportable Concentration soil category of S-1 (RCS-1) with the exception of stockpile sample SP-101-C, with C11-C22 Aromatics at 1,810 mg/Kg, and stockpile sample SP-101-1, with C9-00 Aromatics(Unadjusted)at 113 mg/Kg. These two (2) analytes exceed the site-specific Reportable Concentration for soil category S-1 (RCGW-1)for C11-C22 Aromatics at 1,000 mg/Kg and C9-C10 Aromatics at 100 mg/Kg. Therefore, these two analytical results require notification to the MADEP pursuant to MCP 40.0315. However, the purpose of characterizing the stockpiled soil was to enable eligibility of the stockpiled to be transported and disposed of at a soil reuse or recycling facility. Consequently, since extant, in-situ, excavation soil and groundwater sample confirmatory concentrations fall well below the site-specific applicable reporting STREAMLINE ENVIRONMENTAL SERVICES• RTN:4-26030 Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 13 of 26 concentrations for the Site, there would be no more reportable concentration conditions remaining which would make the Site eligible for notification under the current MCP after the stockpiled soil is properly disposed of under the MCP Bill of Lading process.. The predominant concentrations of detected analytes in SP-101-C are consistent with a waste oil character profile. The relatively lower levels of volatile organic compound concentrations of analytes present in stockpile sample SP-101-1 are consistent with a weathered gasoline character. It is noteworthy to mention that a documented MADEP release and cleanup of a gasoline occurred directly across the street from the Site several years ago from a gasoline dispensing station. Currently, the site still operates as a gasoline dispensing station. At the time of the release at the gasoline dispensing station, a groundwater survey determined that the 14 lyannough Road (the "Site") was hydrologically downgradient to the former gasoline dispensing station. Refer to Table 3 for a summary of laboratory soil reports and Appendix D for a copy of laboratory reports. 4.4 Remediation Waste Management and Disposal Remediation waste as soil was generated and stockpiled at the Site from the removal of oil impacted soil from an excavation which manifested a sudden release of oil discharged from a buried, crumpled, steel drum as it was moved within the excavation. As a result, approximately 15 cubic yards of oil-impacted soil was stored and stockpiled under plastic sheeting at the Site. The sheeting was held down on the edges with clean sand to prevent the plastic from flying away. Subsequent stockpile waste characterization yielded analytical data results which, in part, chemically qualified the stockpiled soil to be eligible for disposal at the Town of Bourne lined landfill for reuse as daily cover material. An MCP Bill of Lading (BOL) process was completed to prepare the soil for transport to the Town of Bourne landfill. Mr. William Baird, LSP (#2791) for the Site, and the PRP collectively authorized the BOL. Following, Streamline completed the Town of Bourne Soil Reuse Submittal application (the "Submittal"), which included the BOL as an attachment, all associated remediation waste characterization analytical data, a table to compare analytical data to Soil Reuse chemical limits and a figure of site-specific features which including remediation waste sampling locations. The Submittal was approved 5.May 2016 by the Town of Bourne landfill operations manager, Mr. Asa Mintz. Refer to Appendix E for a copy of the Town of Bourne Soil Reuse Submittal. STREAMLINE ENVIRONMENTAL SERVICES•RTN:4-26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 14 of 26 �ES 1 On 10 May 2016, Vicente Trucking Company personnel of Agawam, Massachusetts arrived at the Site and loaded the stockpiled oil-impacted soil into a 10- wheel dump truck using a front end loading Bobcat. Following the loading of soil, he drove the loaded soil to the Town of Bourne landfill along with a copy of the BOL. Two (2) trips were made to the landfill to enable removal of all stockpiled remediation waste, with a total of 25.90 tons of remediation waste having been transported to the landfill. 4.5 Electro-Magnetic Resistivity(EMR) Survey On Sunday, 24 April 2016, at the behest of the LSP, an EMR survey was conducted by Streamline personnel to evaluate for the presence of buried metal objects. A significant positive aspect of doing an EMS survey is that it picks up.only metal. You are then assured that any anomalies are due to metal objects, and not other buried objects like boulders, concrete (unreinforced) surfaces, debris, or layering variations (either natural or manmade, like trenching or excavating). Furthermore, an EMR survey will not be affected by the electrical conductivity variations of the subsoil the way that Ground Penetrating Radar survey (GPR) is, and, you are assured that all significant metal objects WILL be found. GPR quality is site specific and objects, especially small ones, can be missed or misinterpreted. Since the history of the Site lends itself to the presence of buried metal objects as being the only source of historic impact to the subsurface of COCs, in conjunction with the fact the currently buried metal drum had a small footprint, a GPR was. recommended by the manufacturer of the equipment over doing a GPR survey. To conduct the survey a Geonics model EM61-MK2 metal detector was used. The EM61-MK2 is a high sensitivity, high resolution;time domain metal detector suitable for the detection of both ferrous and non-ferrous metal. Typical target response is a single, sharply defined peak, facilitating quick and accurate determination of location. Achievable depth of detection will depend on several target characteristics, with the surface area and orientation of the target of particular importance. A single 55-gallon drum can be detected at depths greater than 15 feet. The metal detector includes towing two (2) large rectangularly-shaped bars vertically stacked and-carried along the ground using a pair of wheels connected to an electronic odometer. This is the cart. A backpack is carried which contains a battery pack which is tethered to the cart and provides the power to provide electromagnetic pulses which emanate from the rectangular bars as they are towed along a previously gridded area. A console/controller is connected to the handle of the cart and provides control capabilities and settings for the instrument, as well as, records sensor data. The principle of operation is that the bars periodically emanate electromagnetic pulses through the ground which induce voltage in any metallic object. The induced voltage is sensed by one of the stacked bars and it value is transmitted to the console. STREAMLINE ENVIRONMENTAL SERVICES• RTN:4.26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 15 of 26 S 5. } Prior to conducting the survey, a metal bar was placed on the ground and surveyed with the unit to determine the relative response of the unit to a known metal object. Also, a survey of "background" conditions was conducted to establish the response of the unit to an area presumably known to not contain significantly sized metallic objects because of previous excavations conducted in that area. Finally, a gridded region was plotted on the asphalt using spray paint. The gridded area included the survey area.of interest; the area bounded by the northern side of Route 28 and heading north therefrom, towards the Site building. Subsequently, . the metal detector was pulled along the asphalt area in straight,lines starting at the northern edge of Route 28, in rows two (2)feet apart, heading towards the Site building. A total of five (5) rows of survey lines were conducted. The survey was limited to the presence of parked cars in the front of the Site building. Previously known metallic objects were located and placed on the map depicting the results of the survey. Refer to Figure 4 for the Disposal Site Map showing Electro-Magnetic Resistivity Survey Contours. Results of the survey yielded the significant likelihood that the EM61-MK2 unit located the municipal water line, the associated water meter cover and the natural gas lines which collectively service the Site because the dig-safe markings are consistent with these objects. One unknown metallic anomaly was located between the natural gas and municipal water lines which supply service to the building. The pattern and signal strength of the anomaly resembles the pattern of the underground municipal water and natural gas piping. Contours of the response of the unit to the survey were started at a level slightly above surveyed background levels. 5 CONCEPTUAL SITE MODEL Based on the of initial release conditions, the sudden release of oil within the excavation was responded to by appropriately timed response actions designed to mitigate and prevent significant migration of oily water to environmental receptors through road drainage into a storm drain located on Route 28. Protection of the environmental receptor was the first line of defense to subsequently protect human receptors from potential subsequent exposure due to the fact that the impacted area is located in a delineated Zone II for municipal potable water system. The primary source of oil impact was initially, immediately controlled by removing the drum from the excavation. Further, the volume of impact from the sudden release from the drum was significantly less than a full 55-gallon barrel (estimated at less than 10-gallons) due to STREAMLINE ENVIRONMENTAL SERVICES•RTN:4.26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 16 of 26 it SE'� Luf the fact that it was not intact when it was discovered. It was already crushed, and consequently, the volume of the release was limited to the crushed volume of the drum. . The secondary source of impact, gravity drainage of oily groundwater from the wet stockpiled soil, became the main source of impact to control since it was able to initially freely transport along the asphalt and roadside swale to a storm drain located approximately 220 feet from the Release. This source of impact was also limited to the amount of gravity drainage which could naturally occur from approximately 15 cubic yards of mostly unsaturated, stockpiled soil. The secondary source of impact was controlled and eliminated by the placement of absorbent pads and booms and granular absorbent media within the path of drainage flow from the stockpiled soil, as well as, within the storm drain initially receiving drainage runoff from the stockpile. The cleaning of the storm drain influent and sediments by a Vactor Truck reduced the likelihood of any post-secondary impact from subsequent releases of oil adsorbed to soil within the storm drains. Upon inspection of the-absorbent booms to the nearby outfall pipe indicated that no discernable oil product had migrated beyond the storm drain. Covering of the stockpiled soil with plastic prevented any further drainage of oil from precipitation. Since the release was sudden, and the COCs primarily included long-chain hydrocarbons,there was not much time for the dissolution' of the COCs into groundwater given their relatively low solubility limits. Therefore the primary mode of transport of the COCs would be through media adsorption, not absorption. Finally, all media applied to control and mitigate the initial Release were transported off-site on the same day as the initial response. Since all preceding response actions were conducted within 7-hours of the Release, it was estimated that all COCs migration pathways and significant risk of routes to future human or environmental exposure have been contained and controlled. At this point in time, assessment of potentially remaining residual impact to soil and groundwater would be effected to determine the next response action measure. The impact and potential exposure routes to humans and the environmental from the Release were estimated to be permanently eliminated when the following occurred: 1) Removal of stockpiled remediation waste from the Site on 10 May 2016 to the Town of Bourne lined landfill; and 2) Laboratory results of the assessment of residual levels of COCs in soil and groundwater samples collected at locations encapsulating the former metal drum within the excavation indicating levels of COCs detected at substantially below STREAMLINE ENVIRONMENTAL SERVICES•RTN:4.26030 Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth MA• page 17 of 26 SIES) Method 1 standards for site-specific groundwater (GW-1) and soil (S-1/GW-1) categories. 6 PROVISIONS FOR A PERMANENT SOLUTION In accordance with 310 CMR 40.1003, the remedial status of Site qualifies it for a Permanent Solution because Response actions have adequately identified and addressed all sources of oil and hazardous material (OHM) impact to groundwater and soil at the Site and surrounding area. Soil and groundwater were the only medias identified at the Site which have indicated relevant exposure potential with regard human or environmental routes of exposure. Through performance of the immediate response action measures, critical exposure pathways and public water supply sources to impacted medias were prevented and mitigated, and subsequently, eventually eliminated following the off-site disposal of stockpiled impacted soil. There were no additional measures implemented at the Site which were determined to be necessary to control future releases of impacted soil and groundwater since residual levels fall well below site specific groundwater and soil categories for Method 1 standards 7 FEASIBILITY OF ACHIEVING BACKGROUND LEVELS OF OHM At this time, soil and groundwater Exposure Point Concentrations qualify the Site for a Permanent Solution primarily since they fall well below levels of the relevant MCP Method 1 category standards for the site-specific soil and groundwater categories. Background levels of OHM have not been reached. The bulk volume of oil-impacted soil has been removed. In order to potentially achieve background levels of OHM within a reasonable time period, the incremental cost of these comprehensive response actions would be substantial and disproportionate to the incremental benefit of risk reduction and environmental restoration. The site is located in the commercial and industrial area of the Hyannis/West Yarmouth town line and is classified as "water quality impaired" pursuant to Parcel and MacConnell Categories. As such, the soil and groundwater, quality in the surrounding area may be considered commensurate with the soil and groundwater quality at the Site. 8 RISK CHARACTERIZATION Risk Characterization is used to establish whether a level of No Significant Risk exists or has been achieved at a disposal site. The results of the Risk Characterization is the basis for a decision whether a remedial action is necessary and to select the appropriate Permanent or Temporary Solution. A chemical-specific approach has been chosen for the Site based on the following: STREAMLINE ENVIRONMENTAL SERVICES RTN:4-26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 18 of 26 d SES � 1) There are promulgated MCP Method 1 Standards for each oil and hazardous material of concern at the Site; 2) Oil or hazardous material at the Site is not present in, or likely to migrate at potentially significant concentrations to an environmental medium in addition to groundwater and soil; 3) The current or foreseeable future human exposure to the OHM would occur predominantly through contact with the groundwater or soil; 4) Environmental Receptors have been identified for the Site; and, 5) One or more Volatile Organic Compounds is not present in the vadose zone soil adjacent to an occupied structure, as defined in 310 CMR 40.0942(1)(d). 8.1 Identification of Human Receptors There are no human receptors who are likely to be present at the disposal site or t and who as a result would like) be in the surrounding environment, Y exposed to g unacceptable oil and/or hazardous material in the present or foreseeable future because all remaining concentrations of oil impacted soil and groundwater relative to the Release fall below the Method 1 standards for the applicable, site-specific groundwater category GW-1 and soil category S-1/GW-1. 8.2 . Identification of Environmental Receptors Environmental Receptors which are likely to be present at the disposal site or in the surrounding' environment and which, as a result, would likely be exposed to unacceptable levels of oil and/or hazardous material include none because remaining concentrations of oil impacted soil and groundwater relative to the Release fall below the Method 1 standards for the applicable, site-specific groundwater category GW-1 and soil category S-1/GW-1. 8.3 Identification of Site Activities and Uses Current and reasonably foreseeable site activities and uses which include all likely activities occurring at the disposal site or in the surrounding environment which could result in exposure to oil and/or hazardous material by Human or Environmental Receptors include none because remaining concentrations of oil impacted soil and groundwater relative to the Release fall below the Method 1 standards for the applicable, site-specific groundwater category GW-1 and soil category S-1/GW-1. STREAMLINE ENVIRONMENTAL SERVICES•RTN:4.26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 19 of 26 (SES,I 8.4 Identification of Exposure Points Identification of an exposure points are locations of potential contact between a human or environmental receptor and a release of oil and/or hazardous material. Exposure Points relative to the Release include soil located in the former excavation from four (4) to six (6) feet below grade and tap water derived from Barnstable municipal wells BW-MELI,.BW-MEL2 or BW-MEL3. However, remaining concentrations of oil impacted soil and groundwater relative to the Release fall below the Method 1 standards for the applicable, most- stringent, site-specific groundwater category GW-1 and soil category S-1/GW-1. As such, pursuant to the MCP, No Significant Risk exists.. 8.5 Identification of Exposure Pathways Identification of an exposure pathways (EPs) are the mechanism by which human or environmental receptors inhale, consume, absorb, or otherwise take in oil and/or hazardous material at an Exposure Point. EPs relative to the Release include contact of soil and inhalation of dust from soil located in the former excavation from four (4) to six (6) feet below grade and consumption of tap water derived from Barnstable municipal wells BW-MEL1, BW-MEL2 or BW-MEL3. However, remaining concentrations of oil impacted soil and groundwater relative to the Release fall below the Method 1 standards for the applicable, most- stringent, site-specific groundwater category GW-1 and soil category S-1/GW-1. As such, pursuant to the,MCP, No Significant Risk exists. 8.6 Identification of Exposure Point Concentrations for Soil and Groundwater Identification . of an exposure point concentrations (EPCs) of soil and groundwater are concentration of oil or hazardous material in a specific medium which a human or environmental receptor may contact at an Exposure Point. Consequently, EPCs include all detected COCs listed in the Summary of Soil and Groundwater Laboratory results listed Tables 3 and Tables 4,respectively. 8.7 Identification of Site Groundwater Categories The groundwater categories describe the potential for three different types of exposure. More than one category may apply to a single disposal site. In such cases all applicable categories shall be identified. The land at the Site is currently located within a Public Water Supply-Wellhead Protection Areas (Zone II). Therefore, by default, the land at the Site is located within a STREAMLINE ENVIRONMENTAL SERVICES RTN:4.26030 Permanent Solution&IRA Completion Report 14 lyannough Rd.,W.Yarmouth•MA• page 20 of 26 it (IS S I Current Drinking Water Source Area, and, as such, is located within the Groundwater Category GW-1. 8.8 Identification of Site Soil Categories Identification of the Site soil category for the purpose of risk characterization from the Release shall be considered S-1 to invoke the application of the most stringent Method 1 standards to the impact from the Release. 9 CHARACTERIZATION OF RISK TO SAFETY The risk of harm to safety was characterized based on the data collected pursuant to the response action being performed and the site, receptor, and exposure information identified. The risk of harm to safety was also characterized by comparing current and reasonably foreseeable conditions at the disposal site and in the surrounding environment to applicable or suitably analogous safety standards. In sum, since the remaining concentrations of oil impacted soil and groundwater relative to the Release fall below the Method 1 standards for the applicable, site-specific groundwater category GW-1 and soil category S-1/GW-1, a condition of no significant risk of harm to safety has been achieved at the Site. 10 METHOD 1 RISK CHARACTERIZATION A Method 1 Risk Characterization compares the conditions at the disposal site to promulgated MCP Method 1 Standards. Each list of groundwater and soil standards has been developed by the Department considering a defined set of exposures considered to be a conservative estimate of the potential exposures at most sites. The exposures assumed by the Department correspond to the groundwater and soil categories. A condition of no significant risk of harm to health, public welfare and the environment exists at the Site because no soil and groundwater sample analyte concentration exceed MCP Method 1 groundwater category GW-1 and soil category S-1/GW-1 standards. Refer to Table 3 for a Summary of Laboratory Soil Reports compared to MCP Method 1 soil category S-1/GW-1 standards. Refer to Table 4 for a Summary of Laboratory Groundwater Reports compared to MCP Method 1 groundwater category GW-1 standards. STREAMLINE ENVIRONMENTAL SERVICES• RTN:4.26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 21 of 26 l 1E1 11 DATA REPRESENTIVITY AND USABILITY ASSESSMENT 11.1 Data Usability Assessment- Pursuant to 310 CMR 40.1056(2)(k), a data usability assessment documenting that data herein relied upon is scientifically valid and defensible, and of a sufficient level of precision, accuracy, and completeness to support the Permanent Solution is discussed below. Soil and groundwater samples were collected at the Site. on 24 April 2016. Samples collected were placed in the appropriate laboratory-provided, pre-cleaned and pre-preserved containers. Sample volumes and weights were sufficient, holding times were achieved and minimum field quality control requirements were met.. Samples were maintained on ice and transported to the laboratory under chain-of-custody protocol. All analyses are consistent with the types of OHM present and potentially present at the Site based on the current and historic use of the Site, in conjunction with visual and olfactory evidence obtained as a result of the Release. The analytical reporting limits are sensitive enough for site-specific soil and groundwater categories at the Site and. met the relevant data quality objectives. The detection limits for a statistically representative number of samples were at or are below the applicable Method 1 Soil and Groundwater Standards. All of the selected analyses have specific MassDEP CAM protocols for the acquisition, analysis and reporting of MCP-related analytical data. According to the analytical laboratory, the CAM protocols were followed for each sample submitted for laboratory analysis. Presumptive Certainty was achieved for all data sets. No data was rejected. The data included within this report is considered suitable to characterize risk at the Site and to support a Permanent Solution with Conditions. 11.2 Data Representativeness Evaluation Pursuant to 310 CMR 40.1056(2)(k), a Data Representativeness Evaluation, documenting the adequacy of the spatial and temporal data sets to support the Permanent Solution is summarized below. 11.2.1 Field Screening All confirmatory soil boring samples were field screened for TOVs with a PID (10.6 eV lamp) using DEP jar headspace methodology. As tabulated in Table 2, TOV concentrations were detected from below the instrument detection limit STREAMLINE ENVIRONMENTAL SERVICES•RTN:4-26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 22 of 26 5 S.ES (0.1 ppmV) to a maximum of 24 ppmV during soil investigations and excavation activities. 11.2.2 Selection of Analytical Methods and Parameters The analytical methods and parameters selected are consistent with the type of OHM detected at the Site, and are appropriate based on the historical and current use of the Site. The analytical reporting limits are sensitive enough to support the Permanent Solution and meet the relevant data quality objectives. 11.2.3 Selection, Number and Spatial Distribution of Sampling Locations A total of five (5) soil borings were installed during this IRA. There were a total of five (5) soil samples collected for laboratory analyses from the area of the excavation. From the total number borings advanced,.one (1) monitoring well was therein constructed which straddled the watertable interface. The watertable ranges from approximately an average of 2 to 4.0 feet below ground surface in the vicinity of the Release. The COCs have a density less than that of water. Therefore,the COCs tend to be present near the watertable interface. One (1) round of groundwater samples was collected since the Release was considered sudden.Therefore extended impact to soil and groundwater was temporally limited to approximately 7-hours. Based upon the Release conditions at the Site, the selection, number and spatial distribution of sampling locations is considered adequate with regard to data representivity of impacted soil and groundwater medias. 11.2.4 Temporal Distribution of Samples Based upon the Release condition, the time-varying distribution of soil and groundwater samples is considered.suitable for providing data representivity for Site conditions. 41.2.5 Critical Samples Consistent with the MassDEP's MCP Representativeness Evaluations and Data Usability Assessments guidance document dated September 19, 2007, a critical sample is a sample for which a usable result is necessary to support a conclusion that the response action objectives have been met (i.e., absent of a usable result for such sample, it cannot otherwise be demonstrated that the STREAMLINE ENVIRONMENTAL SERVICES•RTN:4.26030•Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 23 of 26 objective has been achieved). No critical samples were identified in connection with the release, and the collection of critical samples is not necessary to support the Permanent Solution with Conditions. 11.2.6 Completeness Completeness is a measure of the amount of valid data obtained from a measurement system compared to the amount expected under normal conditions and is usually expressed as a percentage. Based on the surrogate recoveries for the soil and groundwater datasets generated for response actions at the Site, and the achievement of presumptive certainty of all the laboratory analytical data,the completeness of the project is 100 percent. The samples collected are sufficient to assess the horizontal and vertical extent of the impact and support the Permanent Solution with Conditions. 11.2.7 Inconsistency, Uncertainty and Unused Data Visual observations, olfactory data, and field screening were generally well correlated with each other and with laboratory analytical data. No other inconsistent data was identified during response actions. All data collected as part of this response action were used to support this Permanent Solution with Conditions. 11.2.8 Representativeness Summary In summary, the soil and groundwater, field screening and laboratory analytical data collected at the Site are considered representative of disposal site conditions and suitable for assessing risk and supporting this Permanent Solution with Conditions. 12 SUMMARY On 14 March 2016, a sudden release of waste oil (the "Release") occurred from the movement of a buried, crumpled, metal drum encountered within an excavation while work was being conducted at 14 lyannough Road, West Yarmouth (the "Site"), during the routine repair of a municipal water line by the Town of Yarmouth Department of Public Works personnel. The drum was removed from the excavation and approximately 15 cubic yards of impacted soil was exhumed therefrom and stockpiled next to the excavation. At this point, all work stopped and no further soil excavation activities occurred, ever. Subsequently, MADEP was notified of the release by respondent, Tom Burnett of the MassDOT at approximately 11:21 AM, and subsequently, based on the sudden release of oil and the impact to a storm drain (from gravity drainage runoff of groundwater and emulsified oil from STREAMLINE ENVIRONMENTAL SERVICES•RTN:4.26030•Permanent Solution&IRA Completion Report•141yannough Rd.,W.Yarmouth•MA• page 24 of 26 (ES.) the stockpiled soil), the "Two-Hour" MCP notification was invoked and the RTN: 4-26030 was assigned to the Release.. MADEP field officer, Robert Murphy, responded to the release by visiting the site at approximately 12:30 PM. Prior to his arrival, the Yarmouth Fire Department had responded by deploying booms and pads within the excavation and the impacted storm drain.and spread granular absorbent media on the ground around the stockpiled soil. Streamline arrived at the Site prior to Mr. Murphy and, based on the knowledge of the imminent retention of an LSP, Mr. Murphy discussed the elements of the oral IRA Plan to enable an expeditious response. The elements ultimately included: 1) apply absorbent medias to impacted areas; 2) remove up to 20 cubic yards of remediation waste; 3) dispose of up to 5,000 gallons of oily water; 4) clean out the storm drain; and, 5) conduct assessment work. At approximately 2:30 PM, Clean Harbors arrived at the Site with a Vactor Truck and performed the following: • Pumped several hundred gallons of groundwater and all floating and emulsified oily products within the excavation, along with all floating absorbent pads and booms; • Pumped all the absorbent granular media spread on the ground along with any soil located below the granular media; • Pumped several hundred gallons of storm water and previously placed- absorbent booms from the directly impacted drain holding tank and from within the paired storm drains proximally located to the impacted storm drain in which the directly impacted storm drain discharged thereto; and, • Pumped soil/sediments from within the impacted storm drain. . Following transference of impacted medias to the Vactor Truck from all areas outside the excavation, Clean Harbors deployed new booms to all storms drains herein referred, and to the outfall pipe-discharge of the storm drains. After completion of the site work, Clean Harbors transported the collected medias (absorbents, groundwater and soil) off-site to their Braintree facility for temporary storage under a Uniform Hazard Waste Manifest document for non-hazardous, non-DOT regulated, sediments and water. Following the completion of transferring oily surficial water and pads and booms from. the excavation to the Vactor Truck, the Town of Yarmouth Department of Public Works backfilled the excavation with clean, gap-graded, sand. 4 annou h Rd. W.Yarmouth•MA• page 25 of 26 STREAMLINE ENVIRONMENTAL SERVICES RTN:4.26030•Permanent Solution&IRA Completion Report 1 ly g P g Es} Ij. These activities were completed by approximately 5:00 PM, and included the ' containment, control and elimination of the threat of a further release of oil, and controlled all exposure routes to humans and environment. i On 3 April 2016, assessment work was conducted at the site which included: the installation of five (5) soil borings (TB-101 through TB-105) in and around the excavation; the completion of one (1) soil boring as a temporary monitoring well (TMW-101); screening of all soil borings at two (2) foot intervals using a PID; subsequent collection of confirmatory excavation soil and groundwater samples for laboratory analysis of Volatile Organic Compounds (VOCs); Semi-Volatile Organic Compounds (SVOCs); Polychlorinated Bi-Phenols (PCBs); and, 14 MA Metals. In addition, stockpile soil waste characterization sampling was conducted to enable off- site disposal of the impacted soil. As such these samples were submitted for laboratory analysis of: VOCs; SVOCs; PCBs; Total Petroleum Hydrocarbons (TPHs); RCRA Metals; Corrosivity as pH; Cyanide Reactivity; Ign'itability (Flashpoint); Specific Conductivity; and,.Sulfide Reactivity. Laboratory results of the excavation confirmatory samples indicated that all soil and groundwater analyte concentrations were well below MCP Method 1 standards for the site- specific groundwater category GW-1 and soil category S-1/GW-1. On 9 May 2016, in accordance with prior approval of the stockpiled soil at the Site for reuse as daily landfill cover by the Town of Bourne landfill, all 25.90 tons of stockpiled soil at the Site was transported off-site to the Town of Bourne landfill for disposal. All elements of the IRA Plan have been completed. The results of the IRA included the initiation of one or more containment or removal actions, the prevention and elimination of Critical Exposure Pathways (CEPS) from impact to a release, and, the prevention of impact to the Barnstable public water supply system. Based on confirmatory laboratory analyses, concentrations of the constituents of concern remaining in the groundwater and soil at the Site are at levels which bolster a condition of no significant risk. As such,this report has been prepared to support: 1) the filing of the transmittal form for a Permanent Solution with no conditions for the.Site; and, 2) the filing of a transmittal form for the completion of an oral IRA Plan. STREAMLINE ENVIRONMENTAL SERVICES• RTN:4.26030 Permanent Solution&IRA Completion Report•14 lyannough Rd.,W.Yarmouth•MA• page 26 of 26