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
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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
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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
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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.
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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,
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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
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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.
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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.
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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);
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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:
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Soil Analyses:
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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
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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.
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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
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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
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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.
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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
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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.
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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.
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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
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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
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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:
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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.
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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
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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.
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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
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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
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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
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(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.
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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.
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